Thanks so much to everyone who attended and spoke at the EPA hearings this week! There was a huge turnout and testimonies were overwhelmingly in favor of regulations on carbon emissions. Thanks to Bobbie Mooney who delivered testimony on behalf of 350 Colorado (read below)!
Presented on July 30, 2014 at the
By Roberta Mooney, 350
Hello and thank you for this opportunity to provide public comment on the EPA Clean Power Proposed Rule. I am Roberta Mooney, an environmental attorney, and I’m speaking today on behalf of 350
350 Colorado is very supportive of EPA’s efforts to reduce carbon emissions from power plants through the Clean Power Plan, and while we believe that much deeper reductions in CO2 emissions than 30% below 2005 levels by 2030 are needed, we realize that this is an essential first step toward putting some limits on CO2 emissions that have so far been unregulated. The buildup of greenhouse gases in our atmosphere has already raised global temperatures by about 1 degree Celsius, and even now we have begun to experience terrible impacts, both here in
Of course, CO2 is not the only green house gas of concern. 350
In 2012 and 2013 studies, NOAA observed that 4-9% of the methane accessed from oil and gas production, leaks directly into the atmosphere, contributing significantly to climate destabilization. Another study by researchers at the
These leakage rates have led some analysts to surmise that natural gas produced by hydraulic fracturing and horizontal drilling, also known as fracking, is perhaps even more dangerous for the climate than burning coal, since many wells leak far more than the 3.2% “break-even” point beyond which methane leakage rates are considered worse for the climate than coal burning. Since 2007, atmospheric methane concentrations have been rising rapidly, and the recent increase in fracking for oil and gas in the
If the CO2 equivalent of methane is not considered as part of the Clean Power Proposed Rule, the consequence could be power-source switching from coal-burning to natural gas-burning Power Plants, since burning natural gas (which is mostly methane) produces about half as much CO2 per unit energy as burning coal. However, if the intention of the Clean Power Plan and the President’s Climate Action Plan is to mitigate climate change, then it would be folly not to consider the heat-trapping impacts of methane leakage during the production and transportation, as well as the burning, of natural gas.
In order to achieve the greenhouse gas reductions needed to avert catastrophic climate change, we must transition as rapidly as possible off all fossil fuels, including natural gas, and quickly ramp up our use of renewable energy, energy efficiency, and conservation. Resource switching from coal to natural gas would waste valuable time and utility ratepayers’ money, with little to no climate benefits. So it is vital that the Clean Power Plan does not inadvertently reward switching to natural gas by not considering the CO2 equivalent heat-trapping potential of methane.
 Toward a better understanding and quantification of methane emissions from shale gas development, http://www.pnas.org/content/early/2014/04/10/1316546111
 Alvarez, R. A., Pacala, S. W. Winebrake, J. J., Chameides, W. L. & Hamburg, S. P. Proc. Natl Acad. Sci. USA 109, 6435–6440 (2012).