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Amendment of the Site Certificate for the Carty Generating Station


Date:  25 September 2016

To:        Sarah Esterson, Siting Analyst

Oregon Department of Energy

625 Marion St. NE

Salem, OR 97301

Subject:  Technical Comments, NWCMTF-2of4-Rev-1

From:  NW Climate Methane Task Force


                Sierra Club, Portland Chapter                Out for approval

                350PDX                                Out for approval

                Engineers for a Sustainable Future        Out for approval


Technical Comments to PGE Carty Station Site Certificate Amendment


  1. 1.Carty Unit 1 and Unit 2 appear unjustifiable as clean energy projects when UN IPCC standards for GWP from 2013 are factored with current natural gas life cycle data. 

  2. 2.Upstream methane leakages and releases from logistics infrastructure supplying Unit 1 and Unit 2 are not quantified with publicly accessible data from owners and operators of the natural gas supply chain, precluding direct due diligence calculations of global warming damage associated with Carty natural gas operations. 

  3. 3.Peer reviewed technical reports conducted by third-party NGO experts put methane leakage and release at 5% of delivered product (some report 12%). 

  4. 4.It is possible to conduct simple checkbook calculations to determine the amount of natural gas supplied, the amount of upstream methane released, and the consequences bearing on Oregon GHG goal attainment. 

  5. 5.We conclude from simple calculations that Units 1 and 2 represent potentially stranded assets as the cost of renewable energy generation declines, resulting from high volume production efficiencies, and as economic externalities are offset for example by the social cost of carbon. 

  6. 6.Our findings are to be shared with PGE and the Oregon Global Warming Commission. 

  7. 7.Activist organizations are expected to endorse the significance of these findings as they relate to the root cause of declining climate. 



Principal Findings


Anthropogenic CO2 and CO2e

  •   o   have been tracked for over 40 years 

  •   o   have never yet declined year on year 

  •   o   have been misrepresented to the extent that many people think we have all century to eventually reverse climate trends 

  •   o   are acknowledged in new budget math concluding that no new wells can be added to produce burnable carbon



  •   o   show absolutely no evidence that any or all climate policies have yet been effective 

  •   o   of natural gas releases to the environment during the life cycle of production, processing and delivery are not reported by owners nor operators nor industry advocates 



  •   o   are difficult to conduct without critical industry measurements of their leaks and releases of CH4 

  •   o   rely on third party measurements from multiple sources 

  •   o   show that the Boardman replacement at Carty Station, due to evolving climate standards and previously under-reported upstream CH4 releases from natural gas infrastructure, does not reduce GHG emissions 

  •   o   show that Unit 2 does not improve GHG emissions over coal 

  •   o   show that the 2015 Oregon GHG Inventory miscomputes fugitive methane CO2e 




Anthropogenic CO2 and CO2e.  The IPCC reports 40 years of anthropogenic CO2 together with anthropogenic methane CO2e for the 40-year period, 1970-2010 in their report, “Summary for Policymakers.”

There is no evidence that climate policies deployed during this time period have had any effect to turn down the upward CO2e trend line that continues today.  For convenience, Figure SPM.1 is repeated here.


The lengthy caption for this figure states the basis for the data as depicted.  “Emissions are converted into CO2-equivalents based on GWP100 from the IPCC Second Assessment Report.”

By looking at the table of GWP standards reported in the previous Comment MCTF-1 we see that GWP100 from 1996 was GWP100 = 21.  We would agree with employing GWP100 assuming we have all century to contain CO2e.  Relying on the IPCC AR5 standard for GWP20 to modify Figure SPM-1, a depiction of the near-term effects of methane involves adjusting the blue methane bar by GWP100/GWP20 = 84/21 = 4x.  Such a depiction by IPCC or any other source has not been found.

The last biggest mistake.  Consequently the blue methane bar reported in SPM.1 is one-fourth its true height.  A pasted-up correction to figure SPM.1 is given in the following graphic and depicts the impact of the current near-term GWP20 standard regarding the root cause of climate change.

Who knew that for the last 50 years anthropogenic CO2 has actually been second to the real driver of climate change, CH4.  Due diligence suggests that Oregon climate goals must accurately account for the impact of CH4 in Oregon.

Although briefly acknowledged by the Oregon Global Warming Commission report to the Legislature, fugitive methane released to the environment is not identifiable in the 2015 GHG Inventory.  Curiously, in accounting for methane, the factor reported by OGWC is GWP100 = 28.  Again, who thinks we have all century to intercept potentially irreversible damage to seasonal weather patterns, life cycles, crop cycles, water distribution, shorelines, population distributions, economies, oceanic food chains, fisheries, insect cycles, pandemics, plus unknowns currently inconceivable.  We regard Oregon’s insistence on GWP100 as an inventory standard to be a significant error, comparable to the error in Figure SPM.1 corrected below.

Full disclosure:  we are unable to locate other reports correlating the conclusion that anthropogenic CH4 emissions exceed fossil fuel and industrial CO2 emissions