Matthew Rodriquez Secretary for

Environmental Protection

The energy challenge facing California is real . Every Californian needs to take imm ediate 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 Agen cy (U.S. EPA) on April 15, 2014.

Assessing and addressing emissions of me thane, and other short-lived climate pollutants (SLCP), is a critical part of Calif ornia’s efforts to fight climate change. The Air Resources Board (ARB) recently approv ed the First Update to the Climate Change Scoping Plan, which highlight s the importance of SLCP, a nd 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 r educed emissions of hydrofluorocarbons, adopting and implementing a regulation for aerosol pr opellants, a deposit-return recycling program for small cans of motor vehicle air conditioning refrigerant and a program to require improv ed maintenance for commercial refrigeration systems. California’s methane program includes measur es to reduce emissions from landfills, and incentives for methane capture and us e in both the cap-and-trade and Low Carbon Fuel Standard regulations. We are pleased to see the prompt rel ease of these white papers, providing a key first step in the Pres ident’s strategy for reducing emissions of

methane from the oil and nat ural 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 compilati on will be useful to ARB as we move forward with our efforts to develop regulatio ns 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 ava ilable on California oper ations 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 lower ed oil and gas-related methane emissions. ARB’s survey of oil and gas operations in Ca lifornia 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 a ssessments to ensure California’s existing controls and lower emissions are accurately reflected.

As part of our expanded effo rts to reduce emissions from oil and gas operations, ARB has two ongoing research projects that could also inform your effo rt. 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 seco nd project looks specifically at different measurement techniques, their relative costs, and potent ial algorithms for me thane using traditional VOC measurement equipment. Although these dat a are not yet availa ble, we would be pleased to coordinate these effort s 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