The following letter is being sent to legislators to address the support that RNG is receiving in 2021 legislative proposals:

Legislator:

I write as co-facilitator of Southern Oregon Climate Action Now, an organization of some 1500 rural southern Oregonians who are concerned about the climate crisis and seek to address it.  For several years, we have been urging the establishment of a program that achieves meaningful greenhouse gas emissions reduction statewide.  To this end, we have paid close attention to legislative proposals that have been developed to address this issue, supporting those that offer positive approaches, opposing those that take us in the wrong direction, and offering amendments where these would improve either category of proposals. It is in the last of these modes that I write today.

As we try to address global warming at the state level, we find many members of the public trying to do the best they can to reduce their personal emissions, and many representatives at different levels trying to pass legislation that will have a meaningful impact on emissions.  Unfortunately, because of the efforts of some industry spokespersons to confuse and obfuscate in order to promote their own interests, there seems to be considerable confusion about which efforts are positive and which negative.

My interest in this letter is to consider the role of fossil (natural) gas and Renewable Natural Gas (RNG):

Contrary to industry claims, fossil gas is not ‘the clean fossil fuel.’  When this fuel is burned to generate energy, greenhouse gases are emitted.  Assuredly, generating electricity using fossil gas emits much less carbon dioxide per unit of energy generated than when either coal or oil are the combustion feedstock. However, fossil gas combustion emits vastly more greenhouse gases than wind turbines, solar panels, geothermal plants and hydroelectric facilities. Fossil gas use results in substantial greenhouse gases emissions. In addition, fossil gas leaks when it is extracted from the ground, processed, and transmitted.  Because fossil gas is some 90% methane, and because methane is a greenhouse gas with 86 times greater warming effect than carbon dioxide on a 20-year basis, not much leakage has to occur to completely negate the combustion benefits of fossil gas over coal and oil.  Indeed, recent studies suggest that this leakage may completely negate the combustion benefits, rendering fossil gas as bad an energy source as coal and oil.

Because electrical engines are much more efficient than the internal combustion engine, far fewer emissions result from vehicles powered by electricity than those powered by any of the fossil fuels.  Maybe surprisingly, this is true even if the electricity was generated in a coal-fired power plant. Since we can generate electricity using processes that emit no greenhouse gases, and soon will, we should make every effort to transform our energy system completely away from fossil fuel to electricity wherever possible.

In an effort to sustain their product, fossil gas proponents are now promoting a fuel termed ‘Renewable Natural Gas’ (RNG) as the replacement for the fossil gas that they now reluctantly seem to accept is a climate problem.  Meanwhile, regrettably, the fossil gas companies (such as Avista promoting fossil gas in southern Oregon, and Pembina promoting the Jordan Cove LNG export facility) still maintain the marketing obfuscation of claiming their gas is the ‘clean-burning fossil fuel’ (or words to that effect). The tactic is presumably designed to convince the public they are a responsible industry that is receptive to, and addressing, the climate issue.

On the surface, RNG seems valuable.  We know that landfills, waste treatment plants, and cattle operations emit methane resulting from the decay of biological materials. Also, because of the problems with methane stated above, this methane has a profound warming impact.  Thus, we should avoid promoting such emissions whenever possible.  One possibility is to capture that methane and use it as a fuel since when it is burned the less potent greenhouse gas carbon dioxide is the result.  The result of using RNG so generated is that carbon dioxide trapped from the current atmosphere by plants is released back into the current atmosphere.  This is far better than burning fossil fuel and releasing into the current atmosphere carbon dioxide trapped three hundred million years ago during the Carboniferous Period.  So far, so good.

Unfortunately, there are substantial drawbacks with this concept.  The most important is that although gas companies promote RNG as though they can replace their fossil gas with this product, they don’t explain from where that RNG will come in sufficient supply to replace the vast amount of fossil gas these companies have persuaded us currently to use.  To illustrate this concern, we should note that according to the 2019 DEQ list of permitted entities producing emissions, the top ten electricity generators powered by fossil gas account for over 50% of the total emissions from such facilities across Oregon.  This also equals some 17% of Oregon’s total in-boundary emissions in 2019.  To replace all the fossil gas used annually in Oregon would require a huge production of RNG.  However, a 2018 report released by the Oregon Department of Energy revealed that the technological capacity for RNG amounted to about 22% of the usage at that time ((https://www.oregon.gov/energy/Data-and-Reports/Documents/2018-RNG-Inventory-Report.pdf).  Meanwhile, national studies suggest the RNG capacity is much lower than that, somewhere in the 4 – 7% range (https://www.wri.org/insights/7-things-know-about-renewable-natural-gas).  This raises an inevitable question about the source of the RNG the gas companies claim they can generate.  Do they, one wonders, contemplate encouraging increased consumption and the number of landfills, an increasing number of Confined Animal Feedlot Operations and mega-dairies to supply the biological waste they need?  Surely abandoning gas as completely as possible and electrifying constitutes a far superior solution.  We could then use methane captured from landfills and waste decomposition in the niche market of those few industrial processes that cannot electrify.

Another concern regarding RNG is the energy used in its production.  Clearly, sites targeted for the capture of methane must be retrofitted to be anaerobic to allow the methane-producing bacteria to survive.  The gas resulting from this process must then be purified to a usable grade for transmitting through the pipelines along with conventionally harvested and processed fossil gas.  The question to address is from where the energy driving these processes comes.  If that is conventional fossil fuel energy, substantial emissions result from the production of the RNG, compromising the combustion benefits of that product. In order to assess the merits of RNG, it is necessary to compare the life cycle emissions of that gas with those from coal, oil and fossil gas, as well as the emissions from solar, wind and other genuine renewable energy sources. When reporting the benefits of RNG, gas companies do not undertake a full and honest accounting of their product possibly because this would be less flattering.

Further discussions of the limits of RNG can be are available in “THE FOUR FATAL FLAWS OF RENEWABLE NATURAL GAS: Gas utilities are telling tall tales about RNG” (https://www.sightline.org/2021/03/09/the-four-fatal-flaws-of-renewable-natural-gas/)  and “THE SMOKE AND MIRRORS DEFENSE OF RNG: The gas industry is writing checks that RNG alone can’t cash.” (https://www.sightline.org/2021/04/19/the-smoke-and-mirrors-defense-of-rng/?utm_source=Sightline%20Institute&utm_medium=web-email&utm_campaign=Sightline%20News%20Selections) both by Laura Feinstein and Eric de Place.

It is critical, when we evaluate legislative proposals, that we undertake a full assessment of the merits of each proposal.  While RNG may seem a productive step in the effort to reduce greenhouse gas emissions, and it potentially could serve a narrow niche purpose, proposals that include incorporating RNG into the pipelines of fossil gas will likely serve merely to encourage more gas infrastructure, with its life span of many decades.  This will promote an ongoing reliance on the same fossil fuel that is contributing to the climate crisis and is not serving to address it.  The evidence suggests that we should place fossil gas on an enforced phase-out, and simply not promote RNG.  Legislative proposals that are otherwise very positive but that promotes RNG should be cleaned of those components.

Thank you for considering this issue.

Respectfully submitted,

Alan Journet on behalf of SOCAN

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  1. […] Committee. Public Hearing held May 3rd. As introduced this was excellent, but now promotes the RNG scam. Watch for: HB3055  Modifies, adds and repeals laws relating to transportation. Text  Referred […]

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