Matthew Rodriquez 

Secretary for 

Environmental Protection

 

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. 

For a list of simple ways you can reduce demand and cut your energy costs, see our website: http://www.arb.ca.gov. 

California Environmental Protection Agency

Printed on Recycled Paper

Air Resources Board Mary D. Nichols, Chairman 

1001 I Street • P.O. Box 2815 

Sacramento, California 95812 • www.arb.ca.gov Edmund G. Brown Jr.

Governor 

June 16, 2014 

Ms. Janet McCabe 

Acting Assistant Administrator 

Office of Air and Radiation 

U.S. Environmental Protection 

 Agency Headquarters 

William Jefferson Clinton Building 

Mail Code: 6101A 

1200 Pennsylvania Avenue, N. W. 

Washington, D.C. 20460 

Dear Ms. McCabe: 

 

We appreciate the opportunity to review and comment on the White Papers on 

Methane and Volatile Organic Compound (VOC) Emissions released by the 

U.S. Environmental Protection Agency (U.S. EPA) on April 15, 2014. 

Assessing and addressing emissions of methane, and other short-lived climate 

pollutants (SLCP), is a critical part of California’s efforts to fight climate change. The 

Air Resources Board (ARB) recently approved the First Update to the Climate Change 

Scoping Plan, which highlights the importance of SLCP, and commits to developing a 

comprehensive plan to address SLCP in 2015. ARB has already made great strides in 

reducing emissions of SLCPs including a 70 percent reduction in emissions of black 

carbon between 1990 and 2010, a benefit of ARB’s regulations to reduce toxic risk from 

diesel fuel and engines. We have also reduced emissions of hydrofluorocarbons, 

adopting and implementing a regulation for aerosol propellants, a deposit-return 

recycling program for small cans of motor vehicle air conditioning refrigerant and a 

program to require improved maintenance for commercial refrigeration systems. 

California’s methane program includes measures to reduce emissions from landfills, 

and incentives for methane capture and use in both the cap-and-trade and Low Carbon 

Fuel Standard regulations. We are pleased to see the prompt release of these white 

papers, providing a key first step in the President’s strategy for reducing emissions of 

methane from the oil and natural gas sectors. 
Ms. Janet McCabe 

June 16, 2014 

Page 2 

The white papers cover a wide range of oil and gas emissions and mitigation techniques 

both thoroughly and succinctly. The compilation will be useful to ARB as we move 

forward with our efforts to develop regulations to reduce methane emissions from oil 

and natural gas operations as well as address emissions related to well stimulation. 

We would like to make you aware of data available on California operations that show a 

difference compared to national level data. Several large air districts within the state 

have implemented programs with control technologies and inspection and maintenance 

requirements at oil and gas fields in order to meet air quality goals. As a co-benefit to 

these VOC controls, California has lowered oil and gas-related methane emissions. 

ARB’s survey of oil and gas operations in California confirms these lower emissions and 

can be found at: http://www.arb.ca.gov/cc/oil-gas/oil-gas.htm. We encourage you to 

expand your inventory and assessments to ensure California’s existing controls and 

lower emissions are accurately reflected. 

As part of our expanded efforts to reduce emissions from oil and gas operations, ARB 

has two ongoing research projects that could also inform your effort. One research 

project is aimed at estimating both methane and toxic emissions related to well 

stimulation through field testing at both hydraulic fracturing and acidization sites 

throughout the state. The second project looks specifically at different measurement 

techniques, their relative costs, and potential algorithms for methane using traditional 

VOC measurement equipment. Although these data are not yet available, we would be 

pleased to coordinate these efforts and provide updates periodically. 

Given our similar regulatory timeframes and our ongoing research, we would like to 

suggest a cooperative process for sharing information. We would be especially 

interested in any California-specific data that you have available. We look forward to 

working with U.S. EPA staff as both of our agencies proceed with reducing methane 

emissions from this sector. 
Ms. Janet McCabe 

June 16, 2014 

Page 3 

If you have any questions, please feel free to contact me at (916) 445-4383 or by email 

at: rcorey@arb.ca.gov or have your staff contact Ms. Elizabeth Scheehle, Chief, 

Alternative Fuels Branch at (916) 322-6312 or by email at: escheehl@arb.ca.gov. 

Sincerely, 

Richard W. Corey

Executive Officer

cc: Elizabeth Scheehle, Chief 

Alternative Fuels Branch