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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 4 of 4

From: NW Climate Methane Task Force (hyperlink)

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. Accurate and candid reporting of severe pollution by the fossil gas industry must begin yesterday

  2. Protection of climate from irreversible damage is the responsibility of those associated with the root cause of global damage

  3. Regulatory mandates should be the last resort, not the first

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

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

Principal Findings

Oregon Energy Policy at the Oregon Global Warming Commission level

  • needs to clearly capture imports of coal-by-wire

  • needs to clearly capture imports of fugitive emissions of natural gas-by-wire

  • must require justification for in state fossil energy by non-renewable natural gas

  • must call for accurate measurement and reporting of methane pollution, including upstream leakage

Social Cost of Methane

  • is real, astounding and not generally recognized or acknowledged

  • cannot be fully tracked when natural gas developers and suppliers do not report, and are not required to report, pervasive methane leaks and releases

Authority to Protect Climate

  • should be enabled through science-based rules by agencies of elected leadership

  • is properly managed according to the rules, day-by-day by those responsible for dealing with natural resources in serving their rate-payers’ needs, investors, society and climate justice


Oregon energy policy. Attention to natural gas as an energy source is not addressed directly by Oregon SB1547B, Clean Electricity and Coal Transition Plan, except as follows.

Section 26 (b) states “Acquiring the additional electricity would require the electric utility to substitute qualifying electricity for electricity derived from an energy source other than coal, natural gas or petroleum.” Natural gas for electricity generation in Oregon is not excluded.

Although coal-by-wire is being precluded from import to Oregon in progressive steps, import of natural gas for energy generation is not addressed. Our previous 3 comments assert that currently natural gas generation is no better than coal, due to IPCC standards for methane CO2e combined with third-party estimates of natural gas infrastructure releases and leaks.

Due diligence in protecting climate calls for owners and operators of natural gas logistical supply to measure and report to Oregon authorities, rate payers and tax payers accurate reporting of powerfully polluting methane.

Subsidies allowed for fossil fuel development including natural gas, not limited to tax forgiveness, below market leases, allowances, favorable terms and permits, exclusive rights all serve to shift the burden of state (and federal) revenue sourcing to taxpayers including other industries. The unreported cost of measuring and accurately reporting methane leaks and releases, which imposes significant social costs, has been prepaid and is long overdue.

Social cost of methane. The basis for computing the social cost of methane is set by the social cost of CO2, “SC-CO2” noted in Comment 1 of 4. The methane GWP is an accurate and appropriate multiplier. For the 20 years after CH4 is released or leaked, with SC-CO2 typically $60/ton,

SC-CH4 = GWP20 x SC-CO2 = 84 x $60 = $5,000/ton

This valuation is not widely cited, due to variations in the way SC-CO2 is derived. Stanford researchers have reported a valuation of $200/ton CO2. Regardless of the analysis selected methane is damaging to the environment in the extreme.

Given the commitment to restrict fossil energy sources for Oregon electricity in SB 1547B, accurate reporting of upstream methane leaks and releases in Oregon and in transit to Oregon - the fugitive methane that profoundly undermines efficient natural gas generation in state – should be a forgone conclusion. Requiring such reports is clearly possible by simple changes to existing GHG rulemaking. Oregon industries and residents deserve to know the consequences of their energy choices. Appended to this comment is an example of such a report.

Authority to protect climate. A report from the Institute for Energy Research describes how Oregon promulgates authority in climate matters. Regarding climate goals Oregon’s HB 3543 (2007) “did not include the regulatory authorities necessary to achieve these goals. Instead, it established a Global Warming Commission responsible for recommending ways to meet the goals.”

Protection of our changing environment from irreversible damage deserves leadership rather than regulatory mandates. Legislators should not be required single out and prosecute those involved in serving energy needs when advancements in science, social valuation, climate justice and discovered pollutants suddenly reveal what we are doing to the place. Its hard to believe that an industry that has mastered geology, geophysics, geohydrology and metallurgy could not recognize emerging facts on GHG summaries and act responsibly to serve society and the nature they inherit with the rest of us. Curing climate damage is not a loss. We need a way to end anthropogenic CH4 release by 2030. Then take up much more difficult tasks involving CO2 and other CO2e pollutants.

comment_4.txt · Last modified: 2016/09/26 03:05 by admin