CIPA CEO Rock Zierman submitted comments to the California Air Resources Board (CARB) related to the initial kick-off workshop on the California Oil and Gas Methane Regulation, or COGR. This first step is coming less than a year after the last set of regulatory revisions to the COGR and is initially focused on the concepts and costs association with a different set of changes to the regulation.
CIPA’s comment letter is mainly focused on CARB’s request on the potential costs. CIPA remains strongly opposed to any amendments in which in-state crude, produced under the strictest environmental standards in the world, is replaced with imported crude either by direct regulation or indirect impact such as increased production costs.
This effect is known as ‘emissions leakage’ and CARB is statutorily mandated to minimize it. The 2022 Scoping Plan Update explicitly states that reducing in-state production will lead to increased crude imports that are the leading source of pollution in the LA Basin, according to the South Coast AQMD.
Concluding the linked letter above, Zierman writes, “The adopted 2022 Update to the AB 32 Scoping Plan acknowledges that California will need petroleum and natural gas fuels for many years, and that when in-state production is reduced faster than the demand reduction, GHG leakage occurs. During this time, California should prioritize in-state supply. Any regulatory proposals that run counter to the ultimate goal of reducing GHG emissions worldwide should be discarded. The last barrel of oil used in this state, should be produced in state.”
The CIPA staff team and consultants will continue to engage with CARB surrounding these important matters.