Alan Journet, January 29th 2025 Comments submitted to the Ashland City Council in support of the Carbon Pollution Fee Ordinance.
Alan R.P. Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now
January 29th 2025
Testimony in support of Ordinance # 3254 the Carbon Pollution Impact Fee
Mayor Graham and Members of the Ashland City Council:
Introduction & Appreciations
I write as cofacilitator of Southern Oregon Climate Action Now, an organization of some 2,000 Southern Oregonians who are concerned about the climate crisis and encourage state action to address it. As rural and coastal Southern Oregonians, we live on the frontlines of the warming, reducing snowpack, heatwaves, drought and the increasing wildfire risk that these trends conspire to produce. Because of this, we pay close attention to what is happening locally in terms of relevant climate action. Although I live in Jacksonville rather than Ashland, many activists with SOCAN live in Ashland. We are concerned about carbon pollution and seek national, state, regional and local action to address it.
First, I’d like to express our great appreciation to the Youth Activists who brought this issue to the attention of the Ashland City Council in their effort to move the city forward on achieving the promise of its 2017 Climate and Energy Action Plan. Their energy and enthusiasm in seeking this action and following through to this moment, including their patience in the face of inevitable bureaucratic hurdles and delays, stand as examples to youth across the nation on how to actualize critical environmental goals. Kudos and thanks to all of them.
Second, I would like to express appreciation to the Ashland Climate and Environment Policy Advisory Committee plus the Ashland City Council and staff for moving forward on this Ordinance.
Second, I would like to express appreciation to the Ashland Climate and Environment Policy Advisory Committee plus the Ashland City Council and staff for moving forward on this Ordinance and express the hope that it will be approved in the near future.
Anyone paying attention to current events is aware of the conflagration occurring in LA. which represents today’s consequences of a similar constellation of events that caused a disaster here just a few years ago. We know that our historic climate of winter wet and summer dry conditions contributes much to the inevitability of fire risk where we live. But we also understand that this risk is exacerbated manyfold by our ongoing release of greenhouse gases such as carbon dioxide and methane into the atmosphere driving global warming which, in turn, drives the climate change that heightens fire risk.
It is important to appreciate that, contrary to the claims of opponents, this ordinance does not ban gas appliances in Ashland. Rather, it recognizes the environmental and health threats that this fossil fuel imposes on humanity and to life on the planet as we know it by imposing a cost on those who commit to engaging in behavior (i.e., gas utilization) that exacerbates the global warming process and its consequent threats.
Avista Claims to Reduce Greenhouse Gas Emissions
In particular, I comment on the claims of Avista representative Vincent that the company is committed to reducing their greenhouse gas emissions followed by his threat of legal action should the proposal be enacted. In this vein, I offer the following comments modified from testimony I submitted in February 2024 to the Oregon Public Utilities Commission regarding the draft Avista Integrated Resource Plan (IRP), a plan developed to map Avista’s expectations on how it might reduce greenhouse gas emissions. It is worth noting that a month later, the PUC rejected the IRPs of Avista and the other Oregon gas utilities on the grounds that they were all ‘unreasonably optimistic’ about future gas demand (Baumhardt 2024).
During the Rulemaking Advisory Committee meetings orchestrated in 2020-2021 by the Department of Environmental Quality to develop the initial Climate Protection Program (CPP) the state’s Natural Gas utilities were well represented. Throughout those discussions, these representatives claimed that they were committed to addressing the climate crisis by reducing their greenhouse gas emissions. Yet, time and again, they resisted reasonable efforts on the part of DEQ or other RAC members to develop a strong program. And then, of course, once the CPP was developed and approved by the Environmental Quality Commission, the gas utilities joined the effort of polluters statewide to undermine and negate the CPP through legal action. On a technicality rather than substance, they succeeded in this effort. It is unsurprising, therefore, that Avista identifies this obstruction as a success in the second paragraph of their response to PUC Staff comments on their draft Integrated Resource Plan (Avista 2024): “Much of Staff’s comments pertaining to their recommendation of non-acknowledgment relate to the Climate Protection Program (CPP) which on December 20, 2023, the Oregon Court of Appeals has ruled … as invalid.” This confirms Avista’s resistance to developing a business model that will lead to the kind of emissions reductions we know we need. Fortunately, DEQ – with the input of another Rulemaking Advisory Committee – again including gas utility representatives, has since redeveloped an updated CPP that approved by the Environmental Quality Commission, reinstating the program. Avista’s response to the PUC comments on its Integrated Resource Plan is consistent with Avista’s longstanding pattern of resistance to climate science and resistance to reducing its greenhouse gas emissions, as discussed further below.
For over a decade research demonstrating the fallacy that methane (natural gas) is a clean fossil fuel has been growing. Yet, Avista (2021) continued to reiterate this false claim. For example, in their promotional materials, they state: “Even though natural gas is a clean fuel, we believe we can make it greener, and we felt it was time to be clear about our path forward.” Continuing to repeat this false claim even though the contrary research is abundant seriously undermines Avista’s credibility in relation to any claims they make. While it is accurate to claim that the greenhouse gas emissions in terms of carbon dioxide released during combustion are lower per unit of energy generated than when coal or oil are the fuel (EIA 2024), this fails to consider the fugitive emissions. When full lifecycle assessment of the emissions of methane from natural gas extraction, processing, transmission and combustion are accounted, the evidence indicates that this gas is actually as bad and maybe worse than coal in terms of greenhouse gas emissions. This has been demonstrated time and again for over a decade (e.g., Howarth 2024, and many contained references). The problem that gas utilities seem consistently to ignore is that assessing greenhouse gas emissions solely on the basis of the results of combustion of that fuel completely ignores the very real problem resulting from fugitive emissions.
In exploring the use of methane gas (fossil gas/ Natural gas/methane pollution), Gordon et al. (2023) offered the following four important conclusions:
1- “gas with a 0.2% leakage rate is on par with coal at all analyzed levels of CMM [Coal Mine Methane] leakage.”
2- “Based on existing studies, coal has a median lifecycle GHG [emissions rate] of 980 kg CO2e per kWh (with an absolute minimum of 675 and maximum of 1689) and gas has a median life-cycle GHG of 501 CO2e/kWh (with a minimum of 290 and maximum of 988).”
3- “…global gas systems that leak over 4.7% of their methane (when considering a 20-year timeframe) or 7.6% (when considering a 100-year timeframe) are on par with life-cycle coal emissions from methane leaking coal mines.”
4- “methane leakage from gas production systems [ranges] from <1% to >66%.
Note that while the median value (item 2 above) for global warming emissions from gas usage is half that of coal, the range for gas emissions overlaps that for coal. This implies that gas is, in some situations, at least as bad as coal. Since leakage rates increase with pipeline age (e.g., Weller et al. 2020), it seems inevitable that emissions will increase as infrastructure ages.
When the negative health effects of domestic exposure to methane (e.g., Gottlieb & Dyrszka 2017, Seals & Krasner 2020, O’Rourke et al. 2022) are added to the climate equation, it becomes more obvious that Avista’s effort to maintain and even expand its marketing of methane should be challenged.
Given the serious climate damage that the gas utilities impose and the ongoing pressure to remedy the hazard of gas usage by electrifying everything, Avista seems reluctant in its IRP to recognize this and adequately address it. Avista seems intent on taking the minimum steps possible to reduce its contribution to the problem while maintaining a commitment to the basic business model that has been contributing to the climate crisis for decades.
Avista’s resource strategy for Oregon, taken from its 2023 Integrated Resource Plan, is presented in Figure 1 where the emphasis on so-called Renewable Natural Gas (RNG) and Synthetic Methane is evident. There is abundant evidence that accurate full lifecycle assessment of RNG indicates that it is not superior to fracked natural gas (e.g., Feinstein and de Place 2021). This alone suggests that Avista has an IRP that merely pretends to reduce greenhouse gas emissions. Meanwhile, even if we accept the premise that RNG constitutes an improvement over fracked gas, a study of the potential for RNG incorporation in the state’s natural gas supply of state-produced RNG by the Oregon Department of Energy (ODOE 2018) concluded: “The gross potential for RNG production when using anaerobic digestion technology is around 10 billion cubic feet of methane per year, which is about 4.6 percent of Oregon’s total yearly use of natural gas.” As Figure 1 illustrates, Avista anticipates RNG comprising much more than 4.6% of its total supply. Even employing (energy and fossil fuel intensive) thermal gasification technology, the ODOE (2018) study concluded the maximum would be 17.5% of Oregon’s demand. One wonders if Avista imagines a massive increase in landfill and agricultural animal feedlot operations that both produce methane will counter this shortfall. Although Avista rejected the PUC concern about the quantity of in-state RNG available to meet the desired capacity, it should be noted that using national supplies of RNG in Oregon would require transmitting the gas from the distant corners of the nation. The result would inevitably be substantial leakage of methane from the pipelines through which this gas is pumped, an outcome substantially negating any RNG benefits. Additionally, Cyrs and Feldman (2020) assessed RNG supplies in the nation and concluded they could only fulfill between 4 and 7% of the nation’s fossil gas consumption. Assuming gas utilities across the nation seek to lower their greenhouse gas emissions by utilizing RNG, the supplies available nationally couldn’t possibly fulfill the needs of Avista locally. While we certainly seek to reduce emissions locally and in Oregon, this should not be achieved by importing gas from out-of-state and thereby simply exporting those emissions to transmission lines across the country.
Avista (Figure 1 again) also clearly relies heavily on a future with synthetic methane. Even if the process touted by Avista were possible. i.e., producing synthetic gas from hydrogen derived from the energy intensive electrolysis of water using renewable energy and combining this with Carbon dioxide captured and stored (CCS) using the economically questionable process of carbon capture from industrial process), NRDC (2020) indicated that synthetic gas “…is still projected to be very expensive in 2040 and 2050.” Relying on carbon capture to provide carbon dioxide also seems optimistic. While reporting on the rules proposed by EPA that challenge industry to fulfill its promise to establish carbon capture technology to reduce emissions, Hennessy (2023) concludes “CCS doesn’t have a strong track record of actually sequestering carbon — especially for the power sector, where 90 percent of proposed carbon capture capacity has failed or never gotten off the ground.” Synthetic methane seems unlikely to provide Avista with an economically feasible option. As has repeatedly occurred with this utility, we should once again be skeptical about claims from Avista that involve emissions reductions relying on synthetic methane and the questionable CCS technology.
Additionally, abundant problems exist with the concept of incorporating Green Hydrogen into the gas mix (e.g., St. John 2022; MITClimate 2023). The latter source, quoting Raju et al. (2022) pointed out: “In a study released last summer, the California Public Utility Commission found that up to 5 percent hydrogen blended with natural gas appears safe, but higher percentages could lead to embrittlement or a greater chance of pipeline leaks.” Erdener et al. (2023) concur, pointing out that “existing gas-fired power plants or industrial processes, may not be designed to tolerate hydrogen blending beyond a given limit; for many existing gas-fired power plants, this limit is 5% volume.” In short, Hydrogen, whether green, blue, gray, brown or pink, cannot contribute much to solving Avista’s greenhouse gas emissions problem.
As has repeatedly occurred with this utility, we should once again be skeptical about claims from Avista that involve emissions reductions relying on RNG, synthetic methane and the questionable CCS technology or Hydrogen. As demonstrated in its 2023 IRP, Avista seems to have lost sight of the fact that it is an energy company not merely a gas company. Avista’s best future seems to be in transitioning out of the gas arena and into renewable energy. Avista also seems to have abdicated the claims that it has often made that it accepts climate science and is willing to become part of the solution rather than continue as part of the problem. Avista’s track record encourages confidence in neither its IRP nor its commitment to reducing emissions rather than expanding its gas network; we should not consider as credible the claims of Avista ghat it will reduce its greenhouse gas emissions.
Cost of Construction and Maintenance
In relation to the argument that all-electric construction is more expensive to build and maintain than the combined electric/gas alternative Tan et al. 2022, in an RMI report, concluded: “Our analysis shows that all-electric, single-family new construction is more economical to build and operate than a home with gas appliances and has lower lifetime emissions in all nine cities studied.” Meanwhile, an IRENA (2024) report concludes “The new renewable capacity added since 2000 is estimated to have reduced electricity sector fuel costs in 2023 by at least USD 409 billion, showcasing the benefits renewable power can provide in terms of energy security.” The claims of gas proponents that it is economically beneficial to incorporate gas into new construction as opposed to focus on electricity should be rejected.
Gas Appliances in Power Outages
A common claim of gas proponents regarding gas appliances is that they can continue running even during a power outage. However, as Shuff (2022) points out, this is largely untrue. For example, most gas furnaces will not work without electricity since the heat is delivered around the residence by electrically powered fans. Gas-powered water heaters, meanwhile, generally employ pilot lights that are ignited by electrically powered switches, while the tank will not monitor temperature without electricity. In short: “You may be able to use water that has already been heated at the start of the blackout, but it will not start heating again until you regain power…” Potentially, the only appliance that could continue without electricity may be the gas fireplace (depending on the model) though modern fireplaces generally rely on electricity for ignition. In summary, it is a myth often promoted by ardent supporters of the gas option, that having gas solves the problems imposed by electrical power outages. Gas stovetops may work without electricity unless they are ignited by a spark generated electrically. The same problem exists with gas ovens. However, recall that the gas emits toxins, so gas ventilation hoods are necessary, with electrically powered fans, for continued use of the cooktop.
Briefly Debunking the Climate Science Denial Hoax
Finally, I’d like to respond briefly to the claim that greenhouse gas emissions are not a problem. Of course, recommending an individual who is committed to the conspiracy hoax that claims global warming and its climate change consequences are not real to the evidence compiled over the years by the Intergovernmental Panel on Climate Change will likely not be convincing. However, just in case there is an open mind with willingness to consider the evidence, it is worth offering a link to the latest two reports of that prestigious organization (e.g., IPCC 2014, 2023).
It is difficult to know quite how to respond to the argument that carbon dioxide is a plant food apparently offered as evidence that this gas could not possibly be causing global warming. Of course, it definitely is the case that carbon dioxide is a critical driver of the essential process by which plants capture energy from the sun through photosynthesis, but this does not provide any evidence regarding the effectiveness of the gas as a global warming agent. Basically, the statement is irrelevant to the conclusion it is offered to justify. However, just to clarify, while carbon dioxide is required for photosynthesis, it is not a limiting resource for plant growth in most situations. As VanDerZanden (2024) points out, the limiting resources for plant growth are light quantity, quality and duration, temperature, water and humidity, and nutrients (nitrogen – N, phosphorous-P, potassium – K, magnesium-Mg, calcium-Ca and sulfur – S). It is unsurprising, then, that the fertilizers marketed to promote plant growth are NPK fertilizers. As Agren et al. (2012) point out in relation to Liebig’s Law of the minimum stating “the nutrient in least supply relative to the plant’s requirement will limit the plant’s growth” that N and P are of paramount importance. Under some circumstances, enhanced carbon dioxide may be beneficial for plant growth. As Cho (2022) discusses, increasing atmospheric carbon dioxide allows plants to continue photosynthesizing with narrowed stomatal apertures. This reduces water loss, and thus the plant’s need for water. With a higher atmospheric carbon dioxide concentration, some plants may thus continue growing under water restricted conditions. As Pearce (2024) suggests: “By allowing them to use scarce water more efficiently, the CO2-rich air fertilizes vegetation growth in even some of the driest places.” Under normal temperate conditions, the increasing atmospheric carbon dioxide probably has much less effect than under conditions of water shortage. This, however, bears no relation to, and offers no evidence regarding, the global warming impact of increasing atmospheric carbon dioxide.
We fervently hope that the attitudes of members of the Ashland City Council are not colored by claims that the science regarding global warming and its climate change consequences, driven by greenhouse gas emissions, are a hoax. We thus urge the council to reject claims of the conspiracy hoax proponents and take steps, however minimal, to reduce greenhouse gas emissions and toxic chemical emissions in new residential construction.
Conclusion
Clearly, Ashland City Council cannot solve the global climate problem that contributes to promoting climate chaos on its own, but Ashland can do its part to contributing to the solution rather than continuing to be part of the problem. Thank you for considering this step. Please approve the Carbon Pollution Impact Fee when the time comes to vote.
Respectfully Submitted
Alan Journet Ph.D.
7113 Griffin Lane
Jacksonville
OR 97530-4182
[email protected]
541-500-2331
541-301-4107
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