Fugitive Releases

In addition to using natural gas to provide end users with service, entities may also release natural gas directly, primarily through leaks and emergency maintenance operations. Staff refers to these as fugitive emissions and estimates that fugitive emissions account for less than 1% of GHG emissions in the sector. NRDC/UCS, SMUD, and SCE support including fugitive emissions from sources such as transmission and storage within the natural gas sector. SMUD argues that covering these emissions would be equitable relative to the electricity sector, which is responsible for its "transport" emissions in the form of line loss. NRDC/UCS support programmatic measures to address fugitive emissions, and also urge that fugitive emissions be considered for inclusion in a cap-and-trade program at a later date if the reported data is accurate enough.

Other parties, including Environmental Council, Kern, SDG&E/SoCalGas, El Paso/Mojave, and Southwest, oppose including fugitive emissions in the sector on the basis that they are relatively small and difficult to measure. SDG&E/SoCalGas believe that fugitive emissions are better addressed through programs aimed at best practices in managing leaks. El Paso/Mojave and Kern recommend that corrections to fugitive emissions be eligible for offset credits.

Lodi asserts that a reasonable threshold level should be established to allow for smaller amounts of fugitive emissions to be exempt from any GHG regulatory program, stating that the burden of regulation would outweigh any benefit from a reduction in emissions.

Two parties comment on measurement and reporting issues. IP, while not recommending that fugitive emissions be regulated, points out that the tracking of fugitive emissions could be feasible using existing data that are reported to State and federal air pollution and transportation authorities. PG&E states that fugitive emissions could be regulated like a point source if measurements are based on sound estimates. However, PG&E opposes regulation based on use of existing protocols for calculating fugitive emissions, such as miles of pipe or number of compression stations, because limiting supply would then be the only way to achieve reductions.