Review comments on CAR-6: U.S. Climate Action Report draft lacks long-term strategy

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U.S. Department of State headquarters, Washington, DC (Wikimedia Commons)

U.S. Department of State headquarters, Washington, DC (Wikimedia Commons)

The Sixth U.S. Climate Action Report does not set post-2020 emissions reduction goals nor discuss the effects of near-term actions, such as promoting the rapid expansion of natural gas use, that may undermine longer-term efforts to curb emissions and phase out fossil fuels. The administration's promotion of expanded natural gas fracking raises concerns about whether it will carry out an impartial assessment of the implications and risks.

Climate Science Watch submitted the following comments on October 24 to the U.S. State Department on the public review draft of CAR-6:

The continuing advance of climate science, as synthesized in the recently released IPCC Fifth Assessment Report (AR5), points ever more strongly to the need for a phase-out of carbon emissions from fossil fuels in order to avert disastrous impacts of global climatic disruption. Yet, while CAR-6 and the President’s Climate Action Plan outline numerous constructive near-term action items, they do not present a strategy for achieving a fossil-fuel phase-out. In fact, there appears to be a contradiction at the heart of the administration’s policy, as indicated by the adoption of an ‘all of the above’ approach to energy development, including increased extraction and use of coal, oil, and natural gas.

In the context of CAR-6 and its goals and projections for 2020 and 2030, the dramatic increase during the past five years in natural gas production using directional drilling technology and hydraulic fracturing of shale deposits seems particularly problematic. Significantly ramping up production of natural gas from fracking appears to be an essential component of meeting the administration’s 2020 goal for reducing U.S. greenhouse gas emissions “in the range of 17%” below the 2005 level.

The administration is relying on cheap natural gas to displace coal in electricity generation. Displacing coal can make a significant contribution to reducing U.S. emissions through 2020. But relatively cheap and plentiful natural gas does not only compete with coal. It competes with energy efficiency and renewable energy, which should be the fundamental basis for a long-term emissions reduction strategy. If cutting back on coal use is done by fully opening the natural gas valve, we may do more to undermine the goal of a fossil-fuel phase-out than to advance it.

CAR-6 lacks a sufficiently long-term perspective. As required, the report provides “with measures” emissions estimates for 2020 and 2030, based on policies in place as of 2012. However, the report fails to set post-2020 emissions reduction goals. It does not discuss the effects of the Climate Action Plan beyond 2020 -- including actions that the U.S. plans to take pursuant to its 2020 goal, such as promoting the rapid expansion of natural gas use -- that may undermine longer-term efforts to curb emissions. CAR-6 should extend its “with additional measures” (under the Climate Action Plan) projections at least through 2030 and identify trade-offs between curbing emissions before versus after 2020.

Fracking raises concerns about chemical contamination of drinking water in affected areas, large-scale use of water in drilling, air pollution, industrial degradation of rural landscapes, and, particularly relevant to GHG emissions reduction goals, fugitive emissions of methane.

The global warming consequences of different gases are based on their concentrations in the atmosphere and the “Global Warming Potential” (GWP) of each gas relative to CO2. CAR-6 uses the GWPs from the IPCC Second Assessment Report (SAR) published in 1996 – 17 years ago, rather than those in the Working Group I contribution to the Fifth Assessment Report (AR5) released in September 2013. However, many GWPs have changed substantially since the SAR. In particular, the IPCC AR5 increases the radiative forcing for methane. According to AR5, the 100-year GWP for methane without climate-carbon feedbacks is 28 and with those feedbacks it is 34. The GWP of 34 is more than a 50% increase above the GWP for methane that is being assumed in CAR6 (21). In addition, using a 100-year GWP discounts the near-term impacts of methane. The 20-year GWP for methane with climate-carbon feedbacks is 86, compared to the GWP of 1 for CO2. This adds to concerns about fugitive methane emissions that would erode the advantage of natural gas versus coal.

CAR-6 should discuss the implications of a 50% increase in the GWP for methane for historic and projected emissions, both in business-as-usual and “with additional measures” scenarios out to 2030. Can we really see a major, rapid expansion in natural gas while reducing total methane emissions in the U.S.?

The Environmental Protection Agency is responsible for protecting the public from harmful environmental impacts of fracking. The EPA has pulled back from several high-profile investigations into fracking contamination incidents in a manner that has raised concerns about whether political pressure may be compromising EPA’s ability to conduct an impartial assessment of the risks fracking presents to drinking water. EPA recently announced that it has delayed the expected final date of its fracking impacts study until 2016. Meanwhile, industry continues to create a fait accompli of expanded fracking operations.

Earlier posts:

2014 U.S. Climate Action Report for public review and comment

Q&A on the Public Review Draft of the Sixth U.S. Climate Action Report (CAR6)

"Obama and Harper — Modes of Support for Fossil Fuel Development"

Obama’s climate action plan: The devil is in the follow-through

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One Response to Review comments on CAR-6: U.S. Climate Action Report draft lacks long-term strategy

  1. Gustavo Orozco says:

    I cannot make a very elaborated post since I am starting to understand the climate change forces. However, I will like to say that politics like any other forces in nature can shape our present and our future and not allways in positive ways. Unfourtunately, the explotation of coal, as a natural source energy, can harm our environment and the majority of the mines are control by different politics and financial forces that don't allow us to change the big picture of climate change in our country.

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