BY CEAL SMITH

Thursday, July 18, 2019

Senate Dems urge Dunleavy to include oil tax reform in special session

In the midst of the worst budget battle in Alaska's history, Senate Democrats delivered a letter urging Governor Dunleavy to put oil tax reform, including Senate Bill 14, on the table for the second special session set to resume this afternoon, July 18th.

The press release states:

Senate Democrats are proposing Governor Dunleavy add Senate Bill 14 to the call, but are also open to other proposals from the Administration to revise Alaska’s oil tax structure to ensure the policy to serve the people’s maximum benefit. Alaska is facing massive budget reductions, loss of services, and an economic recession. Lawmakers have received an unprecedented amount of emails, phone calls, and messages to right the economy and reverse budget reductions to provide stability for the state.   

Alaskans for Oil Tax Credit Repeal/Yes on SB14 has been at the forefront of calling for oil tax reform, including a floor vote on SB14, since the beginning of the 2019 legislative session.  "SB21 has failed Alaskans and set the stage for this so-called fiscal crisis. Eliminating the $1.2 billion oil production tax credit, as SB14 would do, is the most common sense solution to balancing the state's budget that still allows for a full Permanent Fund Dividend while preserving education and public service programs that are vital to Alaska's well-being and future.  We commend the Senate for their courage and initiative", said Ceal Smith, one of the groups organizers.By Ceal Smith - July 18, 2019 2 comments: Email ThisBlogThis!Share to TwitterShare to FacebookShare to PinterestLabels: Alaska budget crisis, oil tax reform, SB14  

BY CEAL SMITH

Sunday, July 7, 2019

It’s not PFD vs STATE. It's BIG OIL GREED vs ALASKANS

  In Alaska, the people own the natural resources. Unlike other states, Article 8 of our Constitution requires that those resources, including oil and gas, be used wisely for "the maximum benefit of its people".  Royalties from non-renewable oil and gas sales are collected and part of the earnings redistributed to Alaskans in the form of a Permanent Fund Dividend (PFD) according to a specific formula.

In Alaska, the cost of living is quite high.  Many middle and low income earners rely on the annual PFD to cover annual expenses not otherwise covered by other income sources.

In fact the PFD lifts many Alaskans out of poverty.  In 2015, an Institute for Social and Economic Research (ISER) study found that PFD's helped 25,000 Alaskans avoid poverty.  That's 1 out of every 33 Alaskans. Child poverty rates have grown a staggering 50% since 1990.  The PFD makes life tangibly better for children, rural families,  seniors, the disabled and many others. 

[Check out Senator Bill Wielechowski's excellent talk on the history of the PFD here.]

Last year, "restore our PFD" became the battle cry for Governor Dunleavy's election campaign.  Now his foolhardy and dangerous veto cuts have sparked a justifiable backlash.  In some circles, that backlash is wrongfully aimed at the PFD.  

Neither Dunleavy or GOP members of the legislature want to talk about it, but Big Oil should be the real target.   Contrary to the usual story, they've been stealing from Alaskans, corrupting our politics and dumping the true cost of doing business on us for more than 40 years.  And it's about to get worse.

To start with, the oil and gas industry is taking more and giving less now than at any time in Alaska's history.  This year alone, industry is writing off $1.2 billion in per barrel oil production tax credits, from it's payments due to the state.

Climate warming is driven by greenhouse gases emitted mostly from burning fossil-fuels. This week Alaska shattered every temperature record on the books.  More than 150 wildfires are burning and there's no immediate relief in sight.  These extreme temperatures are accelerating sea ice melt, permafrost thaw and ocean acidification; three dangerous tipping points, that if crossed, could result in run-away climate disruption that, no matter how fast we cut greenhouse emissions, may not be stoppable.   

The cost to Alaskan's of fossil fuel combustion-driven climate disruption; hundreds of coastal communities facing relocation, collapsing fisheries, wildlife, ecosystems, infrastructure, health and safety is incalculable and perhaps subject for another blog.

The point to be made here is this:  Alaskans need to come together to build a statewide bipartisan movement to end fossil fuel subsidies and protect the Permanent Fund Dividend.  While the greed expressed by Dunleavy and his defenders is truly reprehensible, let's not vilify low-mid income families who rely on the PFD to make ends meet and rise out of poverty.

It’s not PFD vs STATE. It’s BIG OIL GREED vs ALASKANS. By Ceal Smith - July 07, 2019 4 comments: Email ThisBlogThis!Share to TwitterShare to FacebookShare to PinterestLabels: Alaska, Climate Change, fossil fuel subsidies, Permanent Fund Dividend  

BY CEAL SMITH

Wednesday, July 3, 2019

Alaska's State of Emergency: an open letter to the legislature

  To members of the Alaska legislature:

Governor Dunleavy’s veto budget cuts are aimed at the heart and soul of Alaska.   Many experts agree, if enacted, they will deal a blow that is not only unconstitutional, but from which the state will likely never recover.  Alaskans across the state are stunned, shocked and mortified by the cruelty and short-sightedness of Dunleavy’s veto cuts.  This is not who we are, and it could not have come at a worse time.   
Some of you may think this is a good thing; that a robust and functioning government and education system is unnecessary to civil society; that the Climate Emergency is not real.  Such thinking does not hold up to the facts.  It’s profoundly irresponsible, dangerous and ignorant.  
One fact that is irrefutable is that climate disruption is accelerating[1],[2],[3].  As members of the Alaska Climate Action Network (AKCAN!), a statewide grassroots organization of more than 1300 Alaskans deeply concerned about climate disruption, we are acutely aware of how vital robust science, research and education programs are to the future survival of our state, nation and planet.  As our nation’s only Arctic state, Alaska is on the front lines of that change and the University of Alaska is at the center of national and global climate change research and education.   The proposed 41% reduction in funding would devastate vital programs, endanger Alaska’s frontline communities and Arctic research in every corner of America and beyond[4].
The Alaska Center for Climate Assessment and Policy (ACCAP) is the primary academic center in our nation doing Arctic research, including critical social science research that supports the needs of frontline communities struggling with the rapid and profound effects of climate change; coastal erosion, permafrost thaw, changing sea ice, ocean warming and acidification, increasing risk of infectious diseases, and the destruction of traditional livelihoods and ways of life. Without a dedicated home, research on these life-threatening issues will fragment or cease to exist, leaving Alaskans in the dark about the threats of climate change and science-based solutions and causing untold suffering and death.  And the loss of research would ripple through the entire U.S. Arctic research community and beyond.
The University of Alaska’s International Arctic Research Center (IARC) is among the world’s premier Arctic science institutes, with an unusual breadth of disciplines and ability to conduct interdisciplinary research collaboration between Arctic nations.  Disrupting these collaborative research efforts would fragment the daily connections forged by researchers here and across the global network of scientists studying the Arctic.The university is responsible, in part, for maintaining four sites that are part of Long-Term Ecological Research program run by the federal government. Those sites provide a continuous look at key pieces of the Arctic ecosystem and the impacts of climate change, including changes to fire season, the disappearance of sea ice, and changes to the base of the ocean food chain that could impact the state’s fisheries. Any interruption or downgrade in monitoring at those sites would hamper our understanding of the changes gripping the region, setting research back by decades and further endangering Arctic communities.  
A thriving University system is vital to a healthy state economy.  According to the Anchorage Economic Development Corporation[5], the University of Alaska system provides $714 million directly and $402 million indirectly to the statewide economy.  Studies show that 68% of two-year graduates and 42% of four-year graduates from University of Alaska remain in the state to meet the workforce needs of Alaska businesses.  University of Alaska-Anchorage alone generated $40.2 million in research dollars in fiscal year 2016.  The loss of these revenue sources and the talented workforce to sustain business could push Alaska into economic collapse.   
There is an easy solution that gets at the duel problems of climate change and the state’s fiscal shortfall: removal of the per barrel oil production tax credit, currently costing Alaskans at least $1.2 billion annually in payments to profitable oil companies.  There is absolutely no justification for subsidizing a thriving oil industry that continues to profit from accelerating climate change harming our state in so many ways.  Adoption of Senate Bill 14 or its equivalent action to remove unnecessary and egregious fossil fuel subsidies, would allow us to balance the budget with full University and education funding while moving our state firmly into a decarbonized future.    
In closing; we implore you to override Dunleavy’s veto cuts, including the proposed 41% cut to the University of Alaska, and use the power of your office to eliminate the existing per barrel oil production tax credit, thus freeing up the funds needed to fulfill State Constitutional requirements to fund education, protect Alaskans from harm and avoid an irreversible descent into economic collapse.   
No less than our future depends on it. 

[1] https://www.washingtonpost.com/weather/2019/04/02/alaskas-historically-warm-march-ended-with-even-more-records/?utm_term=.c54c8a9bf3a4

[2] https://time.com/5610084/canadas-permafrost-thawing-surprising/

[3] https://nypost.com/2019/07/01/melting-alaska-sea-ice-has-residents-scientists-worried/

[4] https://earther.gizmodo.com/the-alaska-governor-s-proposed-budget-cuts-would-be-a-d-1836046296?fbclid=IwAR04BlN2Qvic9y2NRIdoQBDRh74i3phF3WlX6mBl7asDeMOCMiGPiAR6SN0

[5] https://aedcweb.com/wp-content/uploads/2017/03/3.21.2017-University-Presentation-updated.pdf

By Ceal Smith - July 03, 2019 1 comment: Email ThisBlogThis!Share to TwitterShare to FacebookShare to PinterestLabels: Alaska, Climate Change, Dunleavy veto, University of Alaska  

BY CEAL SMITH

Saturday, May 18, 2019

The Municipality of Anchorage Climate Action Plan: The Right Step, Right Now

  Tom Benson of the Heartland Institute posted a blog entry dated May 16, 2019, intended to cast a pall over the Municipality of Anchorage Climate Action Plan[1].  Written by lobbyists rather than by scientists, it is filled with assumptions, inaccuracies, outdated figures, and misleading distractions from the issue at hand.  Allow us to set the record straight.

(read the full response here)

BY CEAL SMITH

Sunday, April 21, 2019

VOTE GREEN: AK Railbelt Utility Elections Underway!

Many Alaskans on the Railbelt electric grid don't know they are utility association member-shareholders with voting rights.

Alaska is very fortunate to have the same electric cooperatives established during the Roosevelt New Deal era.  As such, each household that pays an electric bill gets to vote annually for members of their utility cooperative board of directors.  And elections are currently underway!

AKCAN! has endorsed Kerry Williams for Matanuska Electric Association (MEA), Mitchell Roth  for Chugach Electric Association (CEA) and Erin McKittrik for Homer Electric Association (HEA).

All three candidates have demonstrated a strong commitment to reducing greenhouse gas emissions to net-zero by 2050.  They know how to do it through energy efficiency measures and deployment of renewable energy and pumped hydro energy storage while keeping member electricity rates low, and protecting the health of Cook Inlet communities, the environment and our future.

To learn more about the candidates, election and annual meeting dates and how you can make a difference visit AKCAN's new Utility Member Action Campaign page.

Especially if you've never voted before - now is the time to use your VOTE and VOICE to elect GREEN members of the board of directors for Alaska's Railbelt grid.

Please spread the word and happy Earth Day!

Learn more about the candidates:

Kerry Williams, Matanuska Electric Association HERE.
Mitchell Roth, Chugach Electric Association HERE.
Erin McKittrik, Homer Electric Association, OpEd HERE and video interview HERE.  





By Ceal Smith - April 21, 2019 4 comments: Email ThisBlogThis!Share to TwitterShare to FacebookShare to PinterestLabels: Alaska, Electric Association, Green Candidates, Railbelt utility  

BY CEAL SMITH

Saturday, March 16, 2019

It takes courage to stand up to Big Oil in Alaska

  The pressure on Alaska's elected officials to conform to the Fossil Fuels Forever narrative is intense and it takes humongous courage to go against it.

But that's what happened last week.

In a largely symbolic act, Alaska's legislature passed a resolution calling upon the federal government to open oil and gas leasing in the coastal plain of the Arctic National Wildlife Refuge.

Not everyone agreed.

In the House, Rep. Sara Hanna (Juneau), Rep. Adam Wool, (Fairbanks), and Rep. Geran Tarr, (Anchorage) voted against it citing climate change impacts as their reason for opposition.

Senators Tom Begich and Elvi Gray-Jackson also said no.  Senator Begich's views on climate change are well known and he was joined by Gray-Jackson who stated she was unwilling to vote for the resolution without language calling for protection of northern caribou herds.

These five state legislators, fewer than 1% of Alaska's elected officials, understand the gravity of climate change enough to just say no to expanding fossil fuel development.

The conventional wisdom is that voting against the interests of the 'hand that feeds' can be fatal to political careers in Alaska (and indeed, in a  fossil fuel funded rant, Rep. Tarr was publicly attacked for her vote).

But is it? 

 The Senate's own 2019 Web Poll, found that 35% of Alaskans "strongly oppose" and 9% "somewhat" oppose opening ANWR to oil and gas leasing compared to 41% and 14% respectively that support or somewhat support it (see the chart).

Yet, only 1% had the chutzpah to vote with the people of Alaska.  

The signs are everywhere that we've reached a tipping point on public opinion on climate change.

Extreme weather, emerging attribution climate science, bigger and stronger global climate protests

 (including Alaska),  technology innovation and renewable energy market trends, state and local adoption of climate policy solutions are just a few.

But the biggest catalyst of all was the UN Intergovernmental Panel on Climate Change (IPCC) 

report, released in December, giving humanity just over 10 years to avert catastrophic climate change.  

Extreme weather reports keep pouring in from Alaska's Front Line communities.  Last fall the cold pool in the Bering Sea collapsed and for the second year in a row, they had no sea ice in the middle of winter.   Patience is running thin.  People are, rightfully, angry.  These are signs the tide is turning, not only against our friends in coastal communities, but against their elected "leaders" who refuse, out of fear, vested interests, or dirty $ in their pockets, to stand up to Big Old Energy interests that keep Alaskans locked into a dying past.   

  A landmark study by McGlade and Ekins found that globally, a third of known oil reserves, half of known gas reserves, 80% of current coal reserves and all unconventional and new fossil fuel -- including resources in the Arctic -- must remain unused if we are to avoid catastrophic climate disruption.

In other words, the time has come for Alaska to let the fossil fuel spigot run its course, bump up our per barrel share and inject it into building a New Energy Future, starting with communities most dependent on oil revenue first. 

Difficult times call for great leadership.  Representatives Hannan, Wool, Tarr, and Senators Begich and Gray-Jackson deserve our thanks.   May they be the tip of a rising spear of political will sharp enough to induce real action on the Front Lines of climate change in 2020.   

By Ceal Smith - March 16, 2019 5 comments: Email ThisBlogThis!Share to TwitterShare to FacebookShare to PinterestLabels: Adam Wool, Alaska, Climate Change, Elvi Gray-Jackson, fossil fuel, Geran Tarr, legislature, Sara Hannah, Tom Begich  

BY CEAL SMITH

Sunday, February 10, 2019

AK CAN's written testimony to oil and gas commission, Dec 18, 2018

  Alaska Oil & Gas Conservation CommissionDecember 18, 2018 HearingWritten comments submitted to: Samantha.Carlisle@alaska.gov Call in: 1-800-315-6338 access code 14331
Comments submitted by Ceal SmithAlaska Climate Action NetworkEagle River, AKceal@akclimateaction.org
·       I’m speaking today on behalf of the Alaska Climate Action Network, a statewide grassroots network of scientists, policy and renewable energy experts, partner groups and Alaskans from all walks of life who are worried about the increasingly dangerous and costly impacts of climate change, especially in rural Alaska.  
·       I would also like to thank the Commissioners French, Foerster and Seamount for granting this hearing in response to Kate Troll’s request and the 48 Alaskan’s who signed the petition at our Climate, Jobs & Justice rally in Anchorage on Sept 8th.  
·       Since then, nearly 300 more Alaskan’s have joined in our appeal to the AOGCC Commission to do everything in your power to reduce Alaska’s GHG emissions (petition attached). 
·       I won’t repeat what others have already spoken to, but I would like to address Kate Troll’s question: “What is the track record for full compliance?” 
·       On November 18th Kristen Nelson reported in the Petroleum News[1] that:1.     The commission revised its flaring regulations effective Jan. 1, 1995. “The goal of the flaring oversight program is the elimination of unnecessary flaring whenever possible, and 
2.     The commission’s current regulations allow no gas release except for up to an hour for emergencies or operational upsets or for planned lease operations authorized for safety; to purge or test a safety flare system; and de minimus venting incidental to normal operations. The regulations also say the commission can authorize flaring for more than an hour under specific circumstances.”
·       We looked at the data, and here is what we found (disclaimer: we are not OG experts):  o   First, according to the 2018 Alaska Greenhouse Gas Emissions Inventory Report[2] that “describes and quantifies human-caused sources of greenhouse gas (GHG) emissions occurring between 1990 and 2015 from Alaska operations and facilities” the oil and gas industry contributed an average of 52% of Alaska’s total GHG emissions equal to 44.5 million metric tons of carbon dioxide equivalents (MMT CO2e)/per year or a cumulative total of 552 million metric tons of carbon dioxide equivalents.
o   Based on these figures, between 1990 and 2015, average annual emissions from the oil and gas sector was 23.22 million metric tons of carbon dioxide equivalents (MMT CO2e) (range: 20.26/2010 – 27.02/2005).  That’s equivalent to[3]:o   5 million passenger cars/year o   53.5 million barrels of oil/year, or 17% of California’s total annual (320 MBO/year)o   3 million average U.S. household electricity use
·       Then we looked at data obtained directly from AOGCC.   Between January 2012 and Feb, 2017 industry:·       Flared or vented  = 17,374,472 thousand cubic feet (Mcf) of gas equal to 17.4 billion cubic feet or roughly 3.5 billion cubic feet (3,474,894 Mcf)/year, including:·       1,468 releases greater than 1 hour·       Range: §  747,534 Mcf in Pt. Thomson Exp on Apr 16, 2016 to §  1 Mcf at Ninilchik Falls Creek on July 1st, 2017. ·       34 releases exceeding 100,000 Mcf* including:§  3 from Pt. Thompson including the release just mentioned, §  9 from Prudhoe Bay Gathering Center 1 §  3 from PBU GC2 §  8 from PBU CGF B, and §  9 from Northstar. and §  1 from PBU GC3 (see Table 1 below).
*NOTE:  100K Mcf of gas = 5,509 metric tons of C02 or roughly the equivalent of adding 13.5 million cars/yr. to our highways.  

  As quoted in Petroleum News above and according to rule 20 AAC 25.235: ·       Section(d): Gas released, burned, or permitted to escape into the air constitutes waste, except that (1) flaring or venting gas for a period not exceeding one hour as the result of an emergency or operational upset is authorized for safety;
·       We haven’t yet received all the documents requested in our Public Information Request, so we were unable to compare the gas disposition report form’s 10-422 (FACILITY REPORT OF PRODUCED GAS DISPOSITION) against the Xcel spread sheet data to determine if these were authorized releases.  Even if we had as a small nonprofit, dependent on volunteers, we don’t have the expertise or capacity to do the analysis (and we might well be off in the above calculation!).  So in the end, we are left with more questions than answers, including:  ·       Do these SUBSTANTIAL emissions fall under authorized emergency and normal operations and maintenance, or is something else going on?  ·       In addition to the 1400+ releases greater than hour, we did not see where industry reports vented gas (i.e. methane).  The state GHG report (page 21) notes that: §  In 2015, the industrial sector produced over half of Alaska’s GHG emissions. Fugitive methane contributed over 19% of the CO2e emitted by this sector in 2015. Most of the fugitive methane comes from oil production; a small portion comes from natural gas production. ·       Thus, how does the AOGCC track the more powerful methane GHG? ·       Additionally, we’d like to know how AOGCC data feeds into the state calculations of total GHG emissions, as required by the Federal Greenhouse Gas Reporting Rule?  (we’re essentially trying to relate the GHG report to industry disposition data), We would very much appreciate answers to these questions! 
It’s important to note that these GHG emissions carry with them a whole suite of hazardous pollutants, including volatile organic compounds that have serious direct and indirect community and environmental health impacts[4], including cancer, neurological, developmental and reproductive effects and the capacity to disrupt critical endocrine hormones.  
In closing, as Bjorn Olsen with Alaskans Know Climate Change and I wrote in a recent OpEd[5] (and it deserves repeating):  “our civilization has little more than a decade to rein in greenhouse gas emissions or face a series of cascading ecosystem and economic collapses”.  We urge you, as our duly appointed and trusted AOGCC commissioners, to do absolutely everything in your power to reduce waste, in the form of dangerous greenhouse gas emissions. 
We are the front lines of climate change; let’s get on the front lines of being the solution to climate change. 

Thank you,    

Ceal Smith

References
http://doa.alaska.gov/ogc/forms/10-422.pdf
The biggest emitters are the Prudhoe Bay Unit Gathering and Flow Stations, but Cook Inlet is also a significant contributor.
Precedence/Case history (from the 50-report):  
“In 1970 alone, nine billion cubic feet of gas were flared from just one Cook Inlet oilfield, Granite Point,” “It was a huge amount of energy just going up in smoke,” recalls Norman, who is currently a Commissioner of the AOGCC. 
The public [then, as now] was solidly on the side of the Commission. The gas flares could be seen from Anchorage on a clear night, and they became symbols of what the public considered to be wasteful practices. 
In 1971, following extensive hearings, the Commission ordered an end to the wasteful flaring of gas produced along with oil from Cook Inlet platforms, except for what was needed for safety flares on the platforms.  The Alaska Superior Court upheld the authority of the AOGCC in its action to prevent waste[7] and (according to the 50-year “Our resources Our past Our future” report[8]). The Commission's ban on gas flaring was extended to Prudhoe Bay when this giant North Slope field began production in 1977. 
Any gas flared after the order, except for the safety flare, was determined to constitute “waste” of the natural gas resource and was prohibited. 
“The companies didn’t want to stop flaring. They claimed there was no market for the gas and that it had no value.” But when forced to do so, the producers did find ways to use the gas beneficially.

Applicable Statutes and Rules
§AS 31.05.027 gives AOGCC authority over all land in the state of Alaska lawfully subject to its police powers, including Federal lands,
§AS 31.05.095 clearly states, “the waste of oil and gas in the state is prohibited”,
§AS 31.05.170(15) defines “waste” in addition to its ordinary meaning, “physical waste” and includes the inefficient, excessive, or improper use of, or unnecessary dissipation of, reservoir energy; and the locating, spacing, drilling, equipping, operating or producing of any oil or gas well in a manner which results or tends to result in reducing the quantity of oil or gas to be recovered from a pool in this state under operations conducted in accordance with good oil field engineering practices; the inefficient above-ground storage of oil; and the locating, spacing, drilling, equipping, operating or producing of an oil or gas well in a manner causing, or tending to cause, unnecessary or excessive surface loss or destruction of oil or gas; and other producing oil or gas in a manner causing unnecessary water channeling or coning; the operation of an oil well with an inefficient gas-oil ratio; the drowning with water of a pool or part of a pool capable of producing oil or gas; underground waste; the creation of unnecessary fire hazards; the release, burning, or escape into the open air of gas, from a well producing oil or gas; the use of gas for the manufacture of carbon black; and the drilling of wells unnecessary to carry out the purpose or intent of this chapter; and
20 ACC 25.235. Gas disposition. (a) For each production facility the operator shall compile and report monthly gas disposition and acquisition on the Facility Report of Produced Gas Disposition (Form 10-422). If a facility's production comes from multiple pools, the operator shall allocate production between each producing pool as a percentage of the total volume of gas that the facility handled for the month. The operator shall report gas acquisition or disposition by category, as follows: 

(1) gas sold; 

(2) gas reinjected;

(3) gas flared or vented* (form does not require separate flaring and venting disclosure); 

(4) gas used for lease operations other than flaring or venting; 

(5) natural gas liquids (NGLs) produced; 

(6) gas purchased; 

(7) gas transferred; 

(8) other.
(b) Any release, burning, or escape into the air of gas other than incidental de minimis venting as authorized under (d)(4) of this section must be reported as flared or vented on the Facility Report of Produced Gas Disposition (Form 10-422). The operator shall submit a written supplement for any flaring or venting incident exceeding one hour. The supplement must describe why the gas was flared or vented, list the beginning and ending time of the flaring or venting, report the volume of gas flared or vented, and describe actions taken to comply with (c) of this section. (c) The operator shall take action in accordance with good oil field engineering practices and conservation purposes to minimize the volume of gas released, burned, or permitted to escape into the air. (d) Gas released, burned, or permitted to escape into the air constitutes waste, except that 

(1) flaring or venting gas for a period not exceeding one hour as the result of an emergency or operational upset is authorized for safety; 

(2) flaring or venting gas for a period not exceeding one hour as the result of a planned lease operation is authorized for safety; 

(3) flaring pilot or purge gas to test or fuel the safety flare system is authorized for safety; 

(4) de minimis* venting of gas incidental to normal oil field operations is authorized; 

(5) within 90 days after receipt of the report required under (b) of this section, the commission will, in its discretion, authorize the flaring or venting of gas for a period exceeding one hour (A) if the flaring or venting is necessary for facility operations, repairs, upgrades, or testing procedures; (B) if an emergency that threatens life or property requires the flaring or venting, unless failure to operate in a safe and skillful manner causes the emergency; or (C) if the flaring or venting is necessary to prevent loss of ultimate recovery; 

(6) upon application, the commission will, in its discretion, authorize the flaring or venting of gas for purposes of testing a well before regular production. (e) Notwithstanding an authorization under (d) of this section, the commission will, in its discretion, review flaring or venting of gas and classify as waste any volume of gas flared or vented in violation of (c) of this section. (f) Notwithstanding conservation orders that the commission issued before 1/1/95, this section applies to flaring or venting of gas that occurs on or after 1/1/95.

[1] Petroleum News, AOGCC receives petition on gas flaring, http://www.petroleumnews.com/pdfarch/319393447.pdf#page=9

[2] https://dec.alaska.gov/commish/press-releases/2018/dec-releases-updated-alaska-greenhouse-gas-emissions-inventory-report/

[3] https://www.arb.ca.gov/cc/factsheets/1mmtconversion.pdf

[4] https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6069077/

[5] https://www.adn.com/opinions/2018/12/16/alaska-has-climate-solutions/?fbclid=IwAR0XrfWAkAeo2v36Tlqen1_baQUI1BFxxH1PIFcMWTEA0dB1aGE1DqQun1U#8046

[6] Fact Sheet Gathering Centers, Flow Stations, https://www.bp.com/content/dam/bp-country/en_us/PDF/alaska_separation_facilities_fact_sheet.pdf

[7] http://doa.alaska.gov/ogc/AboutUs/50th/aogcc50thBooklet.pdf

[8] http://doa.alaska.gov/ogc/AboutUs/50th/aogcc50thBooklet.pdf

By Ceal Smith - February 10, 2019

BY CEAL SMITH

Friday, February 8, 2019

Alaska heats up as regulators fail to watchdog oil and gas industry

“I think this is happening because I have been firmly standing up for the public interest in oil and gas conservation”     

                                       Hollis French, Alaska Oil and Gas Conservation Commission Chair (former)


According to University of Fairbanks climate scientist Rick Thoman, in February 2019 the average temperature in Alaska's most northern reaches rose 2.8 degrees Celsius over the 50 year norm, more than three times higher than the national average. 

 As an oil state, it's not surprising that industry is responsible for the lions share of the state's greenhouse gas (GHG) emissions.  Alaska's Department of Environmental Conservation reported last year that industry emits a whopping 53% of the state's total GHG emissions, although recent evidence suggests the numbers could be as much as 60% higher.

On Dec 18, 2018 citizens urged the Alaska Oil and Gas Conservation Commission (AOGCC) to step up enforcement of waste rules to reduce industry's carbon and methane greenhouse gas emissions.  Kate Troll, Lois Epstein with the Anchorage Wilderness Society (TWS) and Ceal Smith, with the Alaska Climate Action Network (AK CAN) delivered petitions, collectively signed by more than 400 Alaskans, and gave public testimony outlining the reasons why this action was important. 

Ceal Smith with AK CAN presented data obtained from AOGCC that showed more than 1,400 gas flare and venting events in excess of one hour occurred between Jan 1, 2012 and Feb 1, 2017; nearly one event every day for the past five years.   According to agency rules, any release in excess of one hour is unauthorized waste that must be justified or a fine levied if found to be without cause or due to negligence. Thirty-four of the venting/flaring incidences released more than 100,000 thousand cubic feet (Mcf)*of greenhouse gas, as shown in Table 1 below.  

  In subsequent follow-up, the Commissioners were unable to provide evidence of a single enforcement action relating to the 1,400 flare/venting events.  They offered information on four unrelated violations instead, two more than 10 years old.

Given the alarming lack of oversight revealed in our filing, the official agency response from Commissioners Foerster and Seamount, Jr., (posted below) is disturbing.   They misrepresented the facts in several important ways.

First, the Commissioner's assertion that "all witnesses were open about their root concern, the reason the hearing was requested, which is climate change" is incorrect. Troll, Epstein and Smith all stated clearly that, while escalating climate change was driving citizen concerns, the petitions and subsequent testimony was about enforcing existing waste statutes (as point #3 in their response letter posted below confirms).

The Commissioners "findings" are of even greater concern.  The assertion that "no specific example or claim of waste was raised during the hearing" defies the evidence.  In testimony, Kate Troll asked about compliance and (as noted above) Ceal Smith reiterated the question in relation to the >1,400 releases greater than 1 hour drawing specific attention to the 34 releases in excess of 100,000 Mcf (shown in Table 1 above) in her testimony.

The Commissioners response, and their assertion that "both testimony and the questions raised...appear to stem from a general lack of familiarity with how the AOGCC addresses issues related to venting and flaring" appears to be an attempt to side-step public concerns. 

  We received a separate response from Commissioner and Chair, Hollis French.  French's response (posted below) addressed our concerns, and the specifics of our testimony, more thoroughly.   

  Shortly after we received the AOGCC's response, on Feb 28th, Governor Dunleavy fired Commissioner French (also reported by ADN).   

In statements made to the media, French responded:

“I think this is happening because I have been firmly standing up for the public interest in oil and gas conservation”

“It’s about what we do as a watchdog agency,” “My view is a watchdog has to roam the whole property. And their view is, ‘no, we’re going to put the watchdog on a short chain.’ And I just disagreed with that.”​

But that's not all.  

In a dangerous irony, there are signs that emissions from Alaska's North Slope oil and gas industrial zone could be on the rise due to thawing permafrost, itself a result of climate change induced by the burning of fossil fuels.  

A 2014 study, Landscape and Permafrost Changes in the Prudhoe Bay Oil Field, from the Geobotany Center at University of Fairbanks, documented numerous changes in the permafrost and surrounding landscape and warned that it could have significant implications for infrastructure, including oil and gas well integrity.  

In April 2017 a BP well failed and leaked oil and gas for days before it could be controlled. According to the AOGCC emergency order, the root cause of the incident was a combination of the well construction geometry – the outer casing shoe set in the permafrost – and thawing permafrost and subsidence.  As reported by Inside Climate News, a second well failed for similar reasons in Dec 2018.  The AOGCC called for another inquiry and scheduled an emergency hearing in February 2019. 

Following the February 13the hearing the Commission concluded that BP’s assessment of the April 2017 well failure was inadequate, and that the oil company BP, “has no evidence that permafrost subsidence will not result in sudden catastrophic failure” at wells with two-casing-string designs, referring to a common design among the 1,700 wells at Prudhoe Bay" (read the full order here).

The order concluded that BP’s assessment of the April 2017 well failure was inadequate, and that the oil company BP, “has no evidence that permafrost subsidence will not result in sudden catastrophic failure” at wells with two-casing-string designs, referring to a common design among the 1,700 wells at Prudhoe Bay" and ordered PB to provide more information. 

  On his way out the door on Friday, Feb 28th, Hollis French filed the following two requests for a hearing. 

 The first (left) is in relation to the massive Hilcorp gas leak that occurred in the winter and spring of 2017.  As described in Wikipedia:

In December 2016,[1] a natural gas pipeline running beneath Turnagain Arm in Cook Inlet, near Nikiski, Alaska, southwest of Anchorage ruptured, leaking large quantities of natural gas into the water. The escaped gas rises, and is released into Earths atmosphere after clearing the surface. It is estimated that between 6 - 8.8 million litres (210,000 - 310,000 cubic feet) of natural gas is being released from the damaged pipe per day. The pipeline operator, Hilcorp Energy, has said that there is presently too much sea ice to safely launch a repair mission. They added that shutting off the flow of natural gas through the pipeline would compound the problem, because the pipe had previously been used to transport crude oil and the residual crude in the pipe would then be exposed to the sea water once the pipeline was depressurized. 

The leak was first reported in February 2017, but an investigation by the Pipeline and Hazardous Materials Safety Administration states that the leak may have begun in December 2016.[1]  The leak was reported to be dry natural gas being sent to the platforms as fuel, which consists of 99% methane. Divers reported that the leak was caused by the pipeline being laid across a rock on the ocean floor, resulting in a small hole. [2][3]  Non-profit organizations representing the environment have either sued or expressed interest in suing Hilcorp Energy, claiming that the ongoing situation is a danger to beluga whales and other marine life.[4][5]  The leak was repaired April 13, 2017 when divers were able to install a clamp on the leaking pipe. [2][6]

As Bill Wielechowski noted in a recent Anchorage Press report on the firing of Hollis French:'

“I don’t think the average Alaskan knows how influential the oil industry is in Juneau.  I don’t think that it was a coincidence that he was suspended on administrative leave the day that the AOGCC started one of the biggest hearings in recent history on a BP well issue.”

When asked what would he like to see get accomplished from this dispute, French replied:

“I feel like the Commission needs a course correction; that’s what I said to the Governor.  We just need to remember who we serve, that the laws apply statewide, and don’t give away anything.  Don’t just say that we are powerless. That is a surrender of sovereignty. Let the watchdog roam the whole property.”

We couldn't agree more. 

####

Research on these issues is on-going, check back for updates.  

Links to media and reports related to this post:

Oil and gas commission expands investigation into why 2 wells failed at Prudhoe Bay.  

KTUU, March 7, 2017

Pipeline and Hazardous Materials Safety Administration (PHMAS) 

reports

.

__________________

* 100K Mcf of gas = 5,509 metric tons of C02 or roughly the equivalent of adding 13.5 million cars/yr. to our highways.

By Ceal Smith - February 08, 2019

By Ceal Smith

Wednesday, December 12, 2018

Alaska’s Got Climate Solutions

Alaska, the state warming twice as fast as the rest of the nation, is a canary in the coalmine for climate disruption. Across the state, the effects of climate change are being experienced – some areas much more poignantly and life altering than others.

Release of the new Intergovernmental Panel on Climate Change and Fourth National Climate Change reports, place Alaska in the crosshairs of climate change. Both spell out, in no uncertain terms, that our civilization has little more than a decade to reign in greenhouse gas emissions or face a series of cascading ecosystem and economic collapses.

These reports verify that the unsettling changes we Alaskans are experiencing are part of a global problem - one that every state and nation must confront with conviction and vigor.

‘Learned Helplessness’ is defined as: a state in which nothing a person opts to do affects what is happening. It is the quitting or the give up response that follows the conviction that whatever a person does doesn’t matter.  The term was initially used to label the failure of certain laboratory animals to escape or avoid shock, despite giving an opportunity, subsequent to earlier exposure to unavoidable shock.

To hear many Alaskans, including people who study the climate system, postulate, one might be led to think that Alaska is left to eek out a living until the last drop of oil and puff of gas is gone; we must just hunker down and passively take the brunt of climate change with little or no hope of being part of the solution.  Following this status quo, business-as-usual model is to admit defeat and allow ‘learned helplessness’ to be our guide.   

We wholeheartedly reject this fate!  

Climate change is a historic opportunity for Alaska to transform, diversify and expand a robustly more sustainable new energy economy to the farthest corners of the state while firmly grounding us as a global leader on climate change.   

As the recent 7.0 Earthquake demonstrates, Alaskan’s got talent when it comes to dealing with natural disaster; we are tough and resilient and innovative and that translates into Big Climate Change solutions, some right in front of our noses.  

Alaska has renewable energy potential other regions of the world only dream about. We have world-class wind, tidal, hydro, geo-thermal, biomass and even great solar potential, for much of the year. Alaska has unique geographic and hydrological features, which allow us to hoard renewable energy in liquid reservoirs during times of surplus and then release that energy back out in the winter when our energy demands increase. We have world class expertise in climate science, rural micro-grids, cold-climate infrastructure design and relocation engineering, and much, much more. 

Our captors - the oil and gas industry, their lobbyists, and government officials – would like you to believe that our only salvation will come from more fossil fuel extraction. Even if the threats from climate change and ocean acidification did not exist, this would not be true. Our remaining oil is no longer worth enough to save us. It’s time to break free from our collective Stockholm Syndrome, address the very real threats of climate change and embolden the industries of the future.  

Bjorn Olson & Ceal SmithPrinted on 12.16.18, Alaska Daily News   

Bjorn Olson is an award winning film-maker, author, Native Alaskan living in Homer, and founder of Alaskan’s Know Climate Change.

Ceal Smith, is a Conservation Biologist and consultant living in Eagle River, and founder of the Alaska Climate Action Network.   

By Ceal Smith

Tuesday, December 11, 2018

Wondering where to find Alaska's Climate Change Action Leadership Docs?

As Alaska rocks on the front lines of climate change, its highly disturbing to see one of Governor Dunleavy's first acts was to delete Governor Walker's Climate Change Action Leadership Recommendations (CALT) from the state website (we tried again just to make sure and got this error message).   

Rightfully outraged, our friends at Cook Inletkeepers launched a petition calling on Dunleavy to "return the Climate Change Task Force information and action plan documents to the official state website".  SIGN here.

We have great respect for many of the knowledgeable, hard-working, dedicated members of the CALT.  The Leadership Team's recommendations are a start, especially when combined with the more thoroughly vetted 2009 recommendations from the Palin Administrations sub-cabinet on Climate Change (also removed from the state website), but they don't go far enough.

You can read why we think this is true in our draft comments to the CALT draft here.

We think the recommendations are milk toast in part because of the expected heavy influence of oil and gas industry on the CALT and behind the scenes.  Read more about that here.  

That said, in the meantime of wondering and waiting for Governor Dunleavy to do the right thing, you can download the two CALT final recommendation reports* HERE.  

* I. Climate Change ACTION PLAN recommendations to the governor

II. Alaska CLIMATE CHANGE POLICY RECOMMENDATIONS TO THE GOVERNOR

We also saved most of the CALT draft and supporting documents. If you would like them, email info@akclimateaction.org and we will happily share them with you. 


By Ceal Smith - December 11, 2018  

By Ceal Smith

Tuesday, December 11, 2018

Wondering where to find Alaska's Climate Change Action Leadership Docs?

As Alaska rocks on the front lines of climate change, its highly disturbing to see one of Governor Dunleavy's first acts was to delete Governor Walker's Climate Change Action Leadership Recommendations (CALT) from the state website (we tried again just to make sure and got this error message).   

Rightfully outraged, our friends at Cook Inletkeepers launched a petition calling on Dunleavy to "return the Climate Change Task Force information and action plan documents to the official state website".  SIGN here.

We have great respect for many of the knowledgeable, hard-working, dedicated members of the CALT.  The Leadership Team's recommendations are a start, especially when combined with the more thoroughly vetted 2009 recommendations from the Palin Administrations sub-cabinet on Climate Change (also removed from the state website), but they don't go far enough.

You can read why we think this is true in our draft comments to the CALT draft here.

We think the recommendations are milk toast in part because of the expected heavy influence of oil and gas industry on the CALT and behind the scenes.  Read more about that here.  

That said, in the meantime of wondering and waiting for Governor Dunleavy to do the right thing, you can download the two CALT final recommendation reports* HERE.  

* I. Climate Change ACTION PLAN recommendations to the governor

II. Alaska CLIMATE CHANGE POLICY RECOMMENDATIONS TO THE GOVERNOR

We also saved most of the CALT draft and supporting documents. If you would like them, email info@akclimateaction.org and we will happily share them with you. 


By Ceal Smith - December 11, 2018  

By Ceal Smith

Wednesday, September 26, 2018

Alaska Climate Action: three strikes and you're out, right?

  As a scientist, environmental and sustainability policy professional, and ordinary Alaskan worried about climate change, I supported Governor Walker in 2013 because he promised to stand up to Alaska's oil and gas industry.   

After his victory, my husband and I spent a week observing the Arctic & Climate Change Policy working group transition team meetings chaired by Craig Fleener and stacked with some of Alaska's most climate change policy savvy people.  The team quickly agreed that building upon the Palin Sub-Cabinet on Climate Change was the Governor's lowest hanging fruit.  

The Sub-Cabinet made the first heavy lift that seemed in 2009 to be a timely step to put Alaska at the forefront of policy action, a move that many agreed was essential given our oft-noted place, "on the front lines" of climate change.

We had high hopes that the Walker administration would hit the ground running on climate change. 

I anxiously watched my email box for the transition team's recommendations that I was assured by staff I would receive as soon as they were put together (they never came, but they do exist - here!).

We waited, and waited for action.  Our hopes began to fade.  Two years later still nothing; the governor had not taken one single meaningful step to address climate change.   

Sometime before the 2016 election Governor Walker announced he would answer the top 1 or 2 questions in a live FB "townhall".  Our FB community (now offically the Alaska Climate Action Network, or AK CAN!) rallied and lo and behold we got the #1 question: "will you commit to reconvening the Sub-Cabinet on Climate Change" on the FB poll.  

When the time came, the governor wiggled and wobbled out of a direct answer to our question, offering instead, "my administration is preparing to address climate change in the near future."  Several months and phone calls to his office later we learned that Governor Walker had hired a climate scientist, Nikoosh Carlo, to serve as Senior Advisor for Climate Policy and Arctic Policy in his cabinet.  This was good news, but again we waited.

Finally, on Oct 31st, 2017 Governor Bill Walker signed Administrative Order 289, establishing the Alaska Climate Change Strategy and the Climate Action for Alaska Leadership Team (CALT).  

This response was somewhat puzzling.  Why not build on the solid foundation built by the Palin Sub-Committee on Climate Change?  Why not act on the solid recommendations of the Arctic Policy and Climate Change transition team?  Why start all over again? 

Four years and immeasurable meters of coastal erosion later, here we are.  Today, the CALT formerly released it's recommendations to Governor Walker.  
In CALT meetings I attended online and in person, team leaders were notibly deferential to member Janet Weiss, President of BP Alaska Region.  The CALT had two advisory committees, the Oil and Gas Technical Advisory Panel comprised of "twelve technical experts from industry, academia, state agencies, federal agencies and Tribal and other organizations"and the Science Advisory Panel made of "up to fifteen Indigenous Knowledge holders from Alaska's university systems, state and federal agencies, Tribal community and other organizations."    

  It's worth noting the limited range of expertise of the CALT advisory panels.   Given the obvious need to transition our economy and energy systems away from oil and gas, why not have separate renewable energy, fisheries, climate science advisory panels instead of shoving everyone else (i.e. NOT oil and gas) into a single panel?   

Given the substantial influence of the oil and gas industry on the CALT, it is not a surprise that the recommendations are less than earth shaking.   Nevertheless, it reflects a consensus of some of Alaska's most informed policy professionals and deserves serious consideration.  

So let's take a look...

Of the two documents presented to the Governor today (the 12-page, Climate Change Policy Recommendations, and 40-page Climate Change ACTION PLAN Recommendations to the Governor), I could not find a single specific policy recommendation.  The only specifics are to:

• Reduce oil, gas and mining industry greenhouse gas emissions in Alaska by 30% (over 2005 levels) by 2030,
• Decrease greenhouse gas emissions due to thermal energy used in buildings by 5.5% (over 2010 levels) by 2030, and
• Decrease greenhouse gas emissions within electricity generation by 33% (over 2010 levels) by 2030. 

Even these are contingent upon "technology, policy, funding, and taking into consideration economic impacts".  

Given that the state has already reduced emission more than 30% over 2005 (Alaska's highest ever emissions) levels, this is not a meaningful goal.  We state so in the AK CAN draft comment to CALT but it apparently went unnoticed.     

  The press hammered the Governor on the purported CALT recommendation that the state adopt a carbon tax.  However, closer inspection reveals a much milder recommendation;  that the state merely “evaluate the development of a carbon fee and dividend program." That puts us at least 4 steps:  (1) study, (2) recommend, (3) adopt, and (4) implement),  from any real carbon pricing mechanism in Alaska.   

Even so, Walker appeared nervous.  He and Lt. Governor Mallott made it more than clear that this administration would not support a carbon tax in any form or any action that puts any burden whatsoever on the oil and gas industry.  Who, lest we forget, takes more and gives less to Alaska now than at anytime in the state's history.

I’ll keep waiting and hoping for, not only the Governor, but all of our leaders in the state legislature, to take substantive action on climate change but for now, I have to agree with Rick Steiner that "Alaskans should not be fooled into thinking [the CALT report] is new or significant”, and AK CAN council member Scott Gruhn who commented that Governor Walker "had a lot of committed individuals waste a year of their lives".

This is the Governor's third shot at taking climate change seriously.  Three strikes and you're out, right?

More to come....By Ceal Smith - September 26, 2018  

By Ceal Smith

Monday, August 6, 2018

Climate, Jobs & Justice Rally coming to Anchorage on Sept 8th

  Alaska is on the front lines of climate change. Rise for Climate, Jobs & Justice Anchorage will set the stage for an equitable and resilient new energy future by bringing together some of the state's most innovative thought leaders and visionaries to educate, inspire and empower Alaskans to act on critical climate change and energy issues. 

The Anchorage event is planned from 11-3 on Saturday, Sept 8th at Delaney Park Strip Mall in downtown Anchorage and is part of a nationwide action that includes Fairbanks, Juneau and Homer. 

The powerhouse stage line-up includes former Lt. Governor and Arctic Research Council Chair, Fran Ulmer, Anchorage Mayor Ethan Berkowitz, Senator Tom Begich, IBEW organizer, Chris Tuck, Arctic Solar Ventures CEO Steven Trimble, conservation biologist and Professor Rick Steiner, fisheries expert and author Kate Troll, artist & social justice activist Indra Arriaga, Savoonga Tribal President Delbert Pungowiyi, musician and activist Libby Roderick, Alaska Pacific University legal scholar Victoria Hykes Steere, and others.   

Regina MacDonald, of Mr. Whitekeys fame will preside over the stage. The event also features kid and art activities, food trucks and exhibits on renewable energy, local food, zero waste, green jobs, and community health and the environment. Free parking is available at First Presbyterian, at 10th and G.  

What the speakers have to say about Climate, Jobs and Justice: 

Rick Steiner:  "A noted civil rights leader once said that 'If you're not part of the solution, you're part of the problem.' The people gathering for the Anchorage climate rally today are clearly part of the solution to the climate crisis. As we approach the climate tipping point, we are also approaching a political tipping point, where governments the world over will, finally, begin to solve the climate crisis.”

Kate Troll: "This rally is an excellent way to learn and become part of the discussion to address climate challenges and seize clean energy opportunities."

McKibben Jackinsky: "Too many of us are unaware of the devastatingly high and unjust personal price paid to support the state’s financial addiction to oil and gas, unaware we are excluded from decisions that are turning lives upside down, that are a part of the equation that is causing Alaska to warm and destroy wildlife habitat faster than any other state. When criticisms of the fossil fuel industry are raised, the powerfully persuasive response is that letting go of our petroleum reliance will cost jobs, lower our standard of living, and bankrupt the state. The Rally for Climate, Jobs and Justice is about creating a new path for Alaska; one energized by renewable resources that secures a healthy and fair future for our land and people."

### Event sponsors include Alaska Climate Action Network (AK CAN!), Alaska NAACP, Arctic Solar Ventures, Bessenyey & Van Tuyn, Comforts of Home, Anchorage Friends Meeting (Quakers), Trustees for Alaska and Audubon Alaska.
RSVP for the rally HERE. _____By Ceal Smith - August 06, 2018  

By Ceal Smith

Thursday, May 31, 2018

AK CAN! draft comment to CALT

Draft COMMENT on the Draft Alaska Climate Change PolicySubmitted electronically to: https://institutenorth.org/engage/project-portfolio/public-input/ 


June 4, 2018Introduction

The Alaska Climate Action Network (AK CAN!) is a grassroots coalition of community-based groups, scientists, Alaskan Native leaders, renewable energy experts, artists and another concerned Alaskans who have come together to push for comprehensive, science and Traditional knowledge-based policy solutions to climate change that lay the foundation for an inclusive and wholistic new energy future for Alaska. 
We commend the Governor and Lt. Governor for convening a diverse Climate Action Leadership Team (CALT) to finally address critical climate change issues in Alaska.   We whole-heartedly support the values of “equity, inclusion and justice, science and technology, cost effectiveness, market-based solutions and public engagement” stated in the April 25th draft.
However, we are also worried.  
There are indicators that the work of the CALT may be thwarted by status quo fossil fuel interests seeking to render this important work, like the Palin administrations Executive Sub-Cabinet on Climate Change before it, to the dark corners of agency archives.  For example, this opening statement (page 2, paragraph 3) of the CALT draft:The state economy is dependent on natural resource development, including oil and natural gas production. While these resources are finite and contribute to global greenhouse gas emissions, which are a root cause of climate change, they also support essential government services and as such our ability to adapt and respond. Development of these resources can be consistent with continued diversification of the economy, increased opportunities for citizens, and an intentional focus on clean energy investments. The state recognizes its obligation to encourage this strategic transition, while strengthening Alaska’s economy.
This, in conjunction with continued efforts by Governor Walker, our congressional delegation and industry to aggressively expand oil and gas production (Table 1) into the next century and beyond[1], threatens to undermine the efforts of the CALT.  The oft touted rhetoric of “no conflict” between accelerated fossil fuel development and addressing climate change are completely out of step with the science, Paris Accord goals, global energy market trends and Alaskans everyday reality of climate change.  

[graphs and tables coming soon]
Table 1.  Current and proposed new developments on the North Slope (National Petroleum Reserve - Alaska and    the Arctic National Wildlife Refuge), offshore (Chukchi and Beaufort Sea’s) and Cook Inlet Alaska.
Equally concerning is the removal of forward thinking language from the earlier March 27th CALT draft (second half of paragraph 2 of the introduction):
There is an economic and ethical imperative to pursue a transition away from a global dependence on fossil fuels and toward renewable sources of energy. The state recognizes its obligation to encourage this transition and increase resilience in the face of climate change, while also maintaining Alaska’s economic viability. With a strategic, holistic approach, these aims are not in conflict.
Is this indicative of CALT’s weakening resolve to commit to a renewable energy transition?  
We are also worried by the seemingly popular, but nonsensical idea that Alaska is not a significant contributor to anthropogenic global warming because of its small population and therefore need not bother to reduce its emissions.  This view, espoused in a recent interview with Lt. Governor Mallot[2], the Alaska Oil and Gas Association President and CEO Karen Moriarty in a recent New York Times story[3], and echoed by at least one CALT member[4], is short-sited at best and negligent at worst. 
On a per capita net emission basis, Alaskans are the fourth highest greenhouse gas (GHG) emitters in the country[5] and we far outrank many other nations.  For example, Switzerland emits less carbon dioxide (CO2) than Alaska, with more than ten times our population.  Given also that our state is one of the nation’s biggest producers of fossil fuel energy, and we are warming at twice the rate of lower latitudes and experiencing a multitude of impacts from climate change, we have a great opportunity and an urgent moral imperative to lead the nation, and indeed the world, in reducing GHG emissions and RE-charging our economy.  Gross emissions are a more meaningful measure of our actual GHG contribution and should be included in subsequent analysis of state emissions.  By this measure, Alaskans may have the highest per-capita GHG footprint in the world.
When major oil companies publicly support policies, including carbon pricing, that address climate change, and some, such as Royal Dutch Shell[6] even outline a path towards a net zero-carbon future, then no governmental body should feel the need to censor themselves or avoid specific language describing the reality of climate change, most of all the Climate Action Leadership Team. 
We believe it is entirely appropriate to seize the economic and ethical imperative to pursue an immediate transition away from dependence on fossil fuels.  That is an accurate description of the global picture in energy and politics based on our current scientific understanding of the risks of climate change. If we insist upon ignoring this reality, we will not have the necessary level of political will and ambition to address the challenge before us.
We are dangerously close to a tipping point – the problem is the fuel itself.  We are down to the wire and members of the CALT have a crucial task ahead that will require the highest integrity, greatest vision, and boldest action in the history of our state.
The Science is ClearAside from the many ways in which Alaskans know climate change on a daily basis, the science is clear.  We must begin to reverse course now.  According to experts, carbon emissions must begin dropping by 2020 if we are to have a chance at meeting the Paris Agreement of “holding the increase in global average temperature to well below 2oC[7] above pre-industrial levels and pursuing effort to limit the temperature increase to 1.5oC above pre-industrial levels, recognizing that this would significantly reduce the risks and impacts of climate change”.   Global CO2 emissions hit a record high in 2017[8] and, according to the US Energy Information Administration (EIA) 2018 report[9], they are expected to continue rising. 
What we do today is crucial[10] -- to cut our emissions substantially to avert catastrophic warming – and the harms that the Paris Agreement seeks to avoid.  We need bold leadership from the CALT that lays out a clear time table with concrete steps, based on the best available science, to achieve net zero emissions by 2050.


In 2015, McGlade & Ekins[11] and Jakob and Hilaire[12] clearly show that we must leave the bulk of our known oil, gas and coal reserves in the ground if we are to avoid catastrophic increases in temperature of 1.5-2oC above pre-industrial levels warming.
"Globally, a third of oil reserves, half of gas reserves and over 80 per cent of current coal reserves should remain unused from 2010 to 2050 in order to meet the target of 2°C. We show that development of resources in the Arctic and any increase in unconventional oil production are incommensurate with efforts to limit average global warming to 2°C. Our results show that policy makers’ instincts to exploit rapidly and completely their territorial fossil fuels are, in aggregate, inconsistent with their commitments to this temperature limit. Implementation of this policy commitment would also render unnecessary continued substantial expenditure on fossil fuel exploration because any new discoveries could not lead to increased aggregate production."
Most scientists and climate analysts agree that 2oC is too risky and that we must stay below 1.5oC to avoid run-away warming[13].  Our experience in Alaska confirms this. 
Scientific reports that methane emissions from melting permafrost are on the rise[14] are particularly alarming.  As recently reported by NPR[15]:"We have evidence that Alaska has changed from being a net absorber of carbon dioxide out of the atmosphere to a net exporter of the gas back to the atmosphere," says Charles Miller, a chemist at NASA's Jet Propulsion Laboratory who measures gas emissions from Arctic permafrost. Scientists don't know yet how much carbon will get released from thawing permafrost or how fast it will happen. But once carbon begins to percolate up through the thawing soil, it could form a feedback loop "over which we would have zero control," Miller says. Thawing permafrost is a big wild card of climate change.Ignoring these trends is folly.   We cannot risk triggering critical permafrost tipping points that could induce run-away climate change on a global scale.   The state has already warmed 2°C from preindustrial levels and temperatures continue to escalate off the scale[16].   

We are reeling from the impacts of climate change, especially our disappearing cryosphere; the loss of glacial, sea and permafrost ice are changing the very shape of our state as coastal villages, infrastructure and ancient landforms collapse around us. 
Alaska is not exempt from science.  We must do our part and more.   We are indeed, “on the front lines of climate change” and thus in the greatest position to lead the nation in facing climate change with the vision and spirit of innovation for which our state is known for.  Alaska can and must become the leader on climate change front and forge a swift path away from fossil fuels to a new energy future.
Towards a just transition and energy democracy
As one of our nation’s most culturally diverse states, embedding principles of environmental and social justice and Energy Democracy into the Climate Action Plan will ensure a fair, inclusive and just transition.  Embracing a wholistic framework informed by Traditional knowledge, inherent in Alaskan Native perspectives, is key to realigning our policy and economic priorities with long-term sustainability goals that value people, communities and the planet over profits.
Alaska rural communities have been living with adverse economic, health, cultural and human rights impacts for decades.   The experience of Nuiqsut, on the North Slope, is a particularly egregious example of the failure of the state to uphold the rights of Alaskans to clean air, water and a safe environment.  Their experience underscores the need for the state to allocate sufficient resources to fully enforce existing laws, improve public access to critical information and work to strengthen Tribal and community decision-making powers.  
It’s been fifteen years since the US Government Accountability Office (GAO) reported that most of Alaska's more than 200 Native villages were affected to some degree by flooding and erosion and nine years since its follow-up report that “limited progress has been made on relocating villages threatened by flooding and erosion”[17].  
The recently completed Assessment of the Potential Health Impacts from Climate Change in Alaska[18] found that: 
Population groups that are particularly vulnerable to the impacts of climate change include people with low incomes, those with less literacy proficiency, indigenous groups, immigrant groups, children and pregnant women, the elderly, and persons with pre-existing or chronic medical conditions.  Rural Alaska has some of the highest rates of poverty in the United States as well as some of the highest costs for food and fuel. In 2014, the percent of residents living below the federal poverty level in the state was 10.2%, while the percent of people living below the federal poverty level in rural Alaska was over 60%. People who live in poverty may be particularly vulnerable to climate change because they have fewer resources to cope with adversity, relocate, evacuate, or respond in other ways (e.g., to increases in the cost of food and other resources; Alaska Native people living in rural areas may also be at increased risk for adverse health impacts from climate change, in part due to their close cultural ties to the land and subsistence food resources, such as salmon, caribou and whale. Stresses to traditional practices, which encompass a way of life, as well as cultural, spiritual, and personal identity, could have significant social impacts in Alaska; some villages report such changes have already begun.
The list of potential health impacts of climate change is shockingly long[19].   Changes in temperature and ecosystems, weather patterns, permafrost, sea ice and sea levels pose many challenges to the health, wellbeing, and safety of Alaskans, and include increased exposure to potentially hazardous materials, threats to subsistence, nutrition and food security, greater exposure to infectious disease and toxins, increased chronic disease and impacts to water and sanitation, health services infrastructure and capacity.   
We have more to say about the importance of a just transition and human rights below, particularly as they apply to affected and lower-income communities, but we want to emphasize here the importance of ensuring that every Alaskan receive the support and resources they need to understand, prepare for and deal effectively with the effects of climate change.  The global fight to save the planet—to conserve and restore our natural resources to be life-sustaining—must engage all Alaskans in the process of transforming the larger economy to be sustainable, democratic, and just. This will entail equal access to the benefits of moving away from fossil fuels towards a renewable energy-based economy through training, jobs and access to technical support and financing; what we call Energy Democracy[20],[21], reflected in the word cloud below:    

Section by Section Comments
The CALT draft Climate Change Policy Goals and Objectives (hitherto “draft”) fall under two broad categories: adaptation (policy statements 1 & 4) and mitigation (policy statements 2, 3 & 5).  Within this, we’ve identified the following subcategories and will structure our comments to the draft in relation to this framework.
I.              ADAPTATIONa.     Food securityb.     Ecosystem protection; plants, animals, air, soil, water, oceans, invasive species management, etc.c.     Information                                               i.     Data gathering                                             ii.     Integration of science and Traditional knowledge                                           iii.     Identification of information gaps                                            iv.     Research-decision support systems                                             v.     Baseline (Traditional knowledge/co-management) studies                                            vi.     Monitoring1.     Increase availability & use of technologya.     Mappingb.     Bathymetryc.     Climate modeling                                          vii.     Scenario and risk assessmentd.     Governance                                               i.     Coordinate and empower local, regional, Tribal, state and federal efforts1.     Recognize local rights to self-determination2.     Empower and increase capacity of communities3.     Strengthen municipal government collaboration & coordination                                             ii.     Update statutes1.     AK Disaster Policy sub-cabinete.     Funding                                               i.     Private, philanthropic, state, federal, international                                             ii.     Climate change emergency relief fundII.            MITIGATION (decarbonization)a.     Incentivize energy efficiency, renewable energy and electrification (local, municipal, Borough and state levels)                                               i.     Increase state-led financing1.     Carbon pricinga.     Carbon fee and dividendb.     Steadily increasing fee imposed at the source2.     Green bank3.     Invest energy efficiency savings into renewable energy4.     Direct capital expenditures5.     State endowments                                             ii.     Incentivize private investment1.     Venture capital funds2.     Reinsuranceb.     Incentivize more efficient, cleaner fossil fuel developmentc.     Carbon capture, use and sequestrationd.     Fund carbon offsets to compensate for emissions
I.              ADAPTATION
a.     Food securityGoal 4.1: The State of Alaska will reduce the impacts from climate change on Alaska’s natural environment and ecosystem, including food and water. Objective 4.1A: Maintain food security and sustainable and accessible fish, wildlife and plant harvest, based on science- and Indigenous Knowledge-informed decision-making and in the public interest.  Objective 4.1D: Adopt an approach that understands ecosystem and food security health as part of human and community health.
Alaskans are highly dependent upon food imported from out of state or harvested from reliable local food sources.  Climate change is significantly affecting cost, abundance, availability, reliability and the ability to harvest and store critical food resources. 
We are glad to see that DNR/DOA is collaborating with the Alaska Food Policy Council[22] (AFPC), including conducting trials to identify crop varieties that can be successfully grown in Alaska’s changing climate and production of the Alaska Grown Source Book[23]. 





Subsistence

We welcome efforts of the Board of Game to “accommodate local knowledge and changes in winter travel conditions” and adopt flexible regulatory structures for seasonal harvesting[24]. 
Native subsistence is complex and must be understood in its broader cultural context[25].  Major reforms in the management of subsistence resources for Alaskan Natives are needed. Community hunting and fishing zones should be managed as non-competitive harvest areas. Individual hunting or fishing licenses should not be required.  Instead the community or village should be given responsibility for maintaining its catch records until a negotiated amount of resources is harvested. The present system of rewarding people who have money to flood meetings with proposals needs to be abolished.  Fish and game management, meetings and community engagement must focus first and foremost on how best to meet the nutritional needs of a given community and less on law enforcement which has the unfortunate effect of criminalizing Alaskan Native subsistence activities[26]. AK CAN! RECOMMENDS:  Food security is ultimately a life and death matter to all Alaskans, urban and rural.  We urge CALT to prioritize and elevate the importance of food security, support the work of and strengthen collaborations with the Alaska Food Policy Council, commit to co-management of subsistence resources and regulatory reform to decriminalize Alaskan Native subsistence activities, develop subsistence mapping and monitoring programs in collaboration with the Local Environmental Observer Network[27] that provide technical support for monitoring, information sharing and improved storage methods of critical food resources to rural subsistence communities,  implement a co-management model for managing critical food resources for rural subsistence communities, and improve enforcement of recreational and commercial harvesting of subsistence food resources.
Plant-rich diet (Drawdown solution #4): to be addressed in subsequent comments.
Food Self-Sufficiency
AK CAN! RECOMMENDS: The formation of an expert working group to hammer out a visionary plan to make Alaska 50% food self-sufficient by 2030 and 100% food self-sufficient by 2050.  The expansion of Alaska’s food sector can be a significant new innovative economic driver, comprise a new source of state revenue and create many new jobs throughout the state. 
Food waste
Reduction of food waste[28], improved storage (Drawdown solution #3) are not included in the CALT draft.  We recommend it be added and will address it in subsequent comments.
b.    Ecosystem protection; plants, animals, air, soil, water, oceans, invasive species management, etc.Goal 4.1: The State of Alaska will reduce the impacts from climate change on Alaska’s natural environment and ecosystem, including food and water. Objective 4.1A: Maintain food security and sustainable and accessible fish, wildlife and plant harvest, based on science- and Indigenous Knowledge-informed decision-making and in the public interest. Objective 4.1.B: Assess threatened ecosystem response options, including reviewing harvest planning or increasing or decreasing oceanic/marine acidity. Objective 4.1C: Support increased research of impacted environmental systems. Objective 4.1D: Adopt an approach that understands ecosystem and food security health as part of human and community health.
Ecosystem protection under rapidly changing climate conditions requires extensive research and consultation.  Some of the above CALT objectives are addressed elsewhere in this comment, but we will compile comprehensive recommendations on this issue in future comments.
c.vii.1d.  Scenario and risk assessment
AK CAN! RECOMMENDS: Adoption of a scenarios approach that models the cost and effectiveness of different policy approaches to addressing climate change impacts (see the chart below for a good example from Canada).  Such an approach is a critical exercise in evaluating what Alaska and Alaskans are willing and able to do that can serve as an important tool for engagement and inspiring action.  It would allow us to compare the Business as Usual (BAU) scenario in which current trends are projected several years, several mid-level plans that consider the costs/benefits of making varying concessions to appeal to various groups of stakeholders or economic contingencies are examined, including a rapid transition scenario that pushes against the upper limits of what is possible. One of these scenarios should anticipate the possible future impact of a globally rising price on carbon and the growth of clean energy on a state budget heavily dependent on revenue generated from oil and gas in a declining market. 
We are especially worried that the rapid acceleration of oil and gas development and mortgaging our long-term future on a $43 billion liquefied natural gas (LNG) gas line[29], optimistically not projected to be in service until 2024-25[30] is a high-risk recipe for economic disaster that will leave the state with a broken economy and polluting infrastructure. It’s costs and consequences need to be weighed against other possible scenarios such as a rapid path to 100% renewable energy. 
The last climate change sub-cabinet generated considerable research findings and recommendations but did not succeed in translating this work into a format that was easily understood by the public, or if they did, we are not aware of it. 
Lastly, we recommend that CALT present its plan in terms easy for all Alaskans to digest.  The following table from a Canadian Climate Action Plan[31] is a useful model for laying out possible short-term, middle-term and long-term goals that are easy for stakeholders to follow.
d. Governance
It’s time for elected officials, appointed experts, agency staff and other civil servants to step up to the climate change plate and provide the bold, visionary leadership that Alaska needs today.  We hope the shift from the March 27th draft:
The state will pursue partnerships and international cooperation with countries or regions of the world that demonstrate an established or emerging leadership role in decreasing greenhouse gas emissions. 

to the April 25th draft:The state’s work with and alongside partners – including federal agencies, tribal and municipal governments, corporations, universities and global leaders – will strengthen and further develop realistic expectations for an economic and energy transition, including new forms of governance, attracting investment and financing for clean, affordable energy and energy efficiency, technological innovation, and new industries. Alaska’s efforts to reduce greenhouse gas emissions fit within a broader global leadership effort but are entirely driven by and responsive to where Alaska is today, and where it can be in the future. Alaska’s leadership and practical approach can serve as a model for the U.S., the Arctic and the rest of the world.suggests that CALT is moving towards less, not more collaboration with other states and nations.   Our world is increasingly interconnected.  Sharing expertise and ideas, collaborating at state, regional, national and international levels is increasingly essential, especially in the Arctic where the pace of change is accelerating. 
Considerable progress has and continues to be made in other states[32] and nations from which Alaska can benefit from.  It would be wasteful for Alaska to reinvent the Climate Action Plan wheel or work in isolation.  
AK CAN! RECOMMENDS: We urge the state to fully commit to meeting the Paris Agreement goals.  That can best be accomplished by becoming a formal and active member of the Pacific Coast Collaborative[33] and the US Climate Alliance[34].  The state can further bolster our climate change action capacity by encouraging municipal governments to join the Climate Mayors.    
We also urge our leaders to tap existing work from our neighbor to the east (with a similar climate) including: 
Acting on Climate Change Solutions from Canadian Scholars (see page 40, figure 6: Transitional Pathways for a good summary of the plan's goals in a single graphic.)Ontario's Climate Change Action Plan (Similar in many ways to "Beyond Fossil Fuels") Vancouver Renewable City Strategy (see the figure on page 6 for the long-term objective)Bay Area Smart Energy 2020 (nuts and bolts energy transition plans)
And incorporate work done previously in Alaska:  
Beyond Fossil Fuels Interior Issues Council Climate Change Task Force
Homer Climate Action Plan, 
Juneau Climate Action and Implementation Plan
Climate Action Plan for the Municipality of Anchorage
III.          MITIGATIONPolicy Statement 3: Goal 3.1: The State of Alaska will work to reduce greenhouse gas emissions in Alaska by 30% (over 2005 levels) by 2025. Maximize carbon neutral growth in Alaska through a rapid transition to clean energy, electrification and energy efficiency. Objective 3.1A: Increase efficiency of and reduce greenhouse gas emissions from natural resource development. Objective 3.1B: Increase the use of renewable and low emission energy resources in air, rail, road and marine transportation, and consider the impact to Alaska communities and economy of banning or implementing alternative fuels. Objective 3.1C: Periodically monitor for and report on emissions of greenhouse gases and the success of efforts to reduce emissions across the Alaska economy, government and communities. Objective 3.1D: Promote market-based solutions, technological innovation, a transition to natural gas, and implementing carbon capture, use and sequestration opportunities.Increasing efficiencies in resource development is fine, but this objective ignores just what those resources are.  Oil, coal, and gas are among Alaska's chief exports.  Indeed, our governor is currently pursuing a substantial increase in our fossil fuel exports (referring to a proposed LNG pipeline project).  If Alaska continues to ramp up fossil fuel development, we dare not frame that as someone else's emissions.  Nor can Alaska continue to subsidize the fossil fuel industry and claim to be a leader in climate action.  The primary cause and largest driver of climate change is greenhouse gas emissions from the fossil fuel industry[35]. Alaska has gotten vast amounts of wealth from this industry, and that wealth has brought much-needed development to the state.  Sanitation, transportation, communication - much of Alaska's infrastructure and quality of life has resulted from the fossil fuel industry.  We need to declare a sincere "thank you" for that, and then move on toward a future without further fossil fuel development, easing the transition to other economic engines through job training and shifted subsidies.  Or can industry money blind even a climate leadership team to the cause and resolution of our climate conundrum?

Objective 3.1D, Objective 3.3B, and Objective 5.3B all promote and incentivize oil and natural gas development and have no place in a Climate Action plan for Alaska. The Introduction and Statement of Purpose on page 2, lines 15-21 states our current dependence on oil and gas succinctly and correctly. We need those industries to pay Alaska's bills, and they do not count against our efforts to clean up our electric sector any more than Norway's gas and oil development discounts their 100% renewable status.We frequently hear there is no money for mitigation, monitoring, relocation, research, education, energy efficiency or transitioning to renewable energy yet the oil and gas industry is taking more and giving less now than at any time in Alaska’s history[36].  In the new era of climate change (the Anthropocene)[37], it makes utterly no sense to subsidize fossil fuels. Natural gas is no longer a so-called "bridge" fuel for most of the world, nor should it be considered that for Alaska. We have abundant renewable options now that are cheaper than adding more gas generation, and which can be deployed more quickly. Additionally, promoting natural gas for domestic use (Objective 3.3B) flies in the face of exporting it to fund greener energy. If LNG is money in the bank for Alaska, burning natural gas in Alaska is burning money. We can't afford to burn money needlessly.  Monitoring and reporting on greenhouse gas emissions is a necessity.  Just as we must set measurable goals in reducing emissions, we must measure our emissions to evaluate our reductions.  Unfortunately, this plan doesn’t really seek reductions in emissions.  It encourages efficiencies and development of clean energy, but it appears to do so only in conjunction with a steady fossil fuel economy.
As stated above (responding to Objective 3.1B), a transition to natural gas is completely unhelpful.  Even with a small amount of leakage, natural gas is worse than coal or oil.  So, we are left with two conclusions.  (1) The transition would be wholly ineffectual.  (2) The public effort required to make such a transition would signal to the uninformed that the job is done, and there would be little to no political will remaining to do something that would actually make a difference.  As such, Objective 3.1D could be the worst facet of this entire plan.  If we’re to make no progress on climate, let’s at least not deceive our public and drain their will for substantive change.  Metaphorically speaking, either put into gear a plan that substantially reduces emissions or turn off the engine.  Revving in neutral is counterproductive in every way.
AK CAN! RECOMMENDS:  It is time for the industry to pay the full cost of doing business in Alaska.  To meet the goal of transitioning to a net zero carbon future by 2050 its imperative that the state invest generously in renewable energy, redirect state energy subsidies to renewables and reform the state oil production tax system. The state needs to immediately start phasing out the lucrative tax credits[38], loop-holes and write-offs granted at every step of the oil and gas supply line.  In short, we urge the state to:1) Phase out all state subsidies to the oil and gas industry in the state of Alaska by 2025,2) Divest the Permanent Fund and Department of Revenue from all investments in fossil fuels,3) Adopt a fair-share oil production tax and allocate full funding to a clean energy transition.We are still researching best practice policies, but (as suggested by Goal 5.2: The State of Alaska will implement community adaptation funding strategies) some possibilities include creation of a 2
climate mitigation fund financed by an initial $1/barrel fee raised proportionately to phase out 90% of Alaska’s oil and gas production by 2050.  Full funding of technical and financial assistance for relocation of the 31“eminently threatened” coastal communities should be a funding priority.Carbon pricingGoal 5.3: The State of Alaska will develop a pathway to a carbon pricing mechanism. Objective 5.3D: Facilitate long-term growth of options and opportunities within communities by means of low carbon economic development. Objective 5.3A: Consider implementing a carbon fee and dividend program with reinvestment of dividend in renewable energy development and energy efficiency activities.AK CAN! RECOMMENDS:  Identify and implement a best practice carbon pricing policy and schedule for legislative adoption.  We support a carbon fee and at least a partial dividend to offset the cost to struggling lower income families.  AK CAN! partner Bjorn Olson recently suggested to the CALT Mitigation Working Group that Alaska would be the ideal place to pilot a national carbon fee and dividend as the state is already set up to disperse Permanent Fund dividends.  Local Citizen Climate Lobby (CCL) chapters in Anchorage, Fairbanks, Sitka and Juneau generally support this idea and efforts are underway to explore how it might best be implemented. 
The following CCL diagram lays out a possible scenario.
 
Fossil Fuel Divestment
Sadly, divestment isn’t addressed in the CALT draft yet decarbonization is fast becoming a major driver in the global economy[39] as Paris Agreement commitments, disruptive technologies and price signals kick in.  In November 2017, AK CAN submitted a petition[40] to the Alaska Permanent Fund Corporation (APFC) Trustees to divest from increasingly risky fossil fuel investments.  To date, more than 450 Alaskans have signed.   
In response, APFC Trustees invited Environmental, Social and Governance (ESG) experts from BlackRock, Goldman Sachs and Morgan Stanley to present to Trustees on May 23, 2018.  Their conclusion, as reported by Tim Brander in the MatSu Frontiersman[41], was clear and irrefutable; fossil fuel investments are under-performing compared to average market returns and increasingly risky. 
The chart (shown below) provided in APFC’s response to our petition shows that the Permanent Fund fossil fuel holdings are already losing the state and Alaskans billions of dollars. 


AK CAN! RECOMMENDS:  We urge CALT to investigate and address the growing risk of fossil fuel investments and to order Trustees to divest, not in “5-10 years” as indicated in their letter, but this year as it is clear those investments are currently costing us billions of dollars in lost revenue.  Continued investments in the fossil fuel and related sectors (such as Florida real estate and other sectors increasingly at risk from climate change) violates the fiduciary responsibilities of the Permanent Fund to optimize investments strictly based on fiduciary grounds. 
Redirect State ResourcesGoal 3.3 Develop an energy transition strategy that leverages current and potential oil and gas development for the benefit of increased clean energy alternatives, for different sectors and across an appropriate timeline.  Objective 3.3B: Promote and develop natural gas as a bridge fuel for export and for domestic use.
First and foremost, gas is not a bridge-fuel.  This myth was dispelled years ago[42] but still persists among fossil fuel industry advisors. 
Although less carbon dioxide is produced during the actual combustion of natural gas compared to coal, emissions from the extraction and transportation of gas (particularly when hydraulically fractured) are higher than other fossil fuels.  Natural gas is 86 times more powerful than carbon dioxide at trapping heat over a 20-year period.  Natural gas leakage and loss may make natural gas worse than coal for climate concerns.  The Union of Concerned Scientists states, "whether natural gas has lower life cycle greenhouse gas emissions, than coal and oil, depends on the assumed leakage rate, the global warming potential of methane over different time frames, the energy conversion efficiency, and other factors”[43].
A recent study found that methane losses must be kept below 3.2 percent for natural gas power plants to have lower life cycle emissions than new coal plants over short time frames of 20 years or fewer[44].  For natural gas-powered vehicles to deliver even marginal benefits, methane losses must be kept below 1 percent and 1.6 percent compared with diesel fuel and gasoline, respectively. Technologies are available to reduce much of the leaking methane but deploying such technology would require new policies and investments[45].  
It is important to also understand that there is a factor of two to five difference between “top down” and “bottom up” estimates of natural gas loss.  That difference shows the difficulty in measuring individual natural gas losses, but those losses show up clearly when scientists look at the overall atmosphere.  Do not be misled on this point; the natural gas industry is a major part of global greenhouse gas emissions.  Such claims otherwise are simply not credible.
Furthermore, continued investments in fossil fuel undercut the Paris Agreement and deprive Alaska of the opportunity to invest in a truly renewable future.  
The International Energy Agency (IEA), “Faster Transition Scenario[46]” predicts carbon pricing will be adopted globally by 2020 and rise to $170 per ton CO2 by 2040, an end to fossil-fuel subsidies by 2025 and coordinated decarbonization policies across all sectors (efficiency, recycling, light-weighting and retrofitting) by mid-century.
Even so, these measures do not go far enough, and in fact, may be leading us seriously off track[47].  According to the recent Oil Change International report: 
The IEA’s roadmap “New Policies Scenario” (NPS), the foremost guide to decisions on energy policies and investments, steers those decisions towards levels of fossil fuel use [particularly natural gas] that would cause severe climate change”Investment in fossil fuels beyond what is aligned with the Paris Agreement goals can lead to two possible outcomes. Either the sunk capital locks in emissions, causing the goals to be missed triggering run-away climate change. Or the goals are achieved, and the capital is wasted, potentially leading to economic upheaval. In calling for too much investment in fossil fuel supply, the IEA greatly increases the likelihood of one of these two outcomes occurring. Like a fallen lighthouse, the IEA has become a dangerous guide.
The remaining carbon budgets associated with the Paris Agreement goals are now extremely small: at current rates of emissions, the 1.5°C budget will be exhausted in eight years, and the 2°C budget in nineteen years. By accepting a mere 50% probability of success, by assuming negative emissions technologies will be invented, and by assuming unrealistically low non-energy emissions, the IEA’s Sustainable Development Scenario (SDS) significantly understates the degree of change in energy systems needed to achieve the goals.
Stranded Assets
Governor Walker’s single-minded push for a $45 billion Alaska LNG project is wrought with financial risk that could leave Alaska holding $ billions in stranded assets and massive debt. During a recent trade mission to China, the president of Sinopec, the giant state-owned oil and gas company and potential LNG partner, told the Alaska delegation, "After some of the work we did, in terms of assessment and evaluation in technology, economics and in terms of the resources of Sinopec — I think there’s a lot more work for us to be done than originally imagined[48].”Experts from the Rocky Mountain Institute, a Colorado-based renewable energy think tank well-known for accurately predicting energy trends[49], concludes:Around the world, an emerging “rush to gas” — a glut of investment in new natural gas-fired power plants and associated delivery infrastructure — threatens to result in significant stranded assets. Innovation in renewable energy and other emerging technologies, including battery storage, has already created cheaper electricity than any new natural gas-fired power plant. Renewable energy and other clean energy technologies are ready to disrupt the market for natural gas, just as natural gas has disrupted coal. Embracing this trend now can prevent wasteful and uneconomic investments in power plants, LNG facilities and pipelines, and avoid CO2 emissions over the coming decades. RMI analysis[50] found that the costs of renewable energy, battery storage and energy efficiency are continuing to fall very quickly. In the US, benchmark prices for wind, solar photovoltaic and battery projects have fallen by 65–90% in the past 10 years. They are forecast to continue falling by a further 50% or more through 2030. Globally, solar and wind projects now have the lowest life-cycle cost of all electricity sources, according to data from the World Economic Forum released in December 2016.  The rapid pace of decline in cost has important implications for the global market for new gas infrastructure. Even in the US, with its domestic sources of cheap natural gas, RMI found[51] that a portfolio of renewable energy, battery storage and energy efficiency can often be developed at a lower cost than a new gas-fired power plant, with lower financial risk and zero carbon emissions. RMI also found that because the cost to develop new clean energy portfolios is falling so rapidly, they are likely to beat just the operating costs of efficient gas-fired power plants within the next two decades.  RMI’s US-focused analysis suggests that hundreds of billions of dollars of planned investment in natural gas infrastructure could be stranded over the coming decades, despite the US’ abundance of cheap, local gas. In many global markets, imported LNG is much costlier than domestic gas in the US (adding US$2–4/MMBtu). In other markets, such as Western Europe, political risks associated with gas supply could limit availability or raise prices even further. As prices for renewable energy fall quickly around the world, more and more markets will find it attractive to lock in low-cost renewables, instead of paying more for natural gas-based power generation.Alaska must be part of the solution.  Not part of the problem of states and nations dragging their feet, claiming to care about climate change and meeting Paris Accord commitments while directing policy and financial resources in the opposite direction. 
Furthermore, Cornell engineer Dr. Anthony Ingraffea shows[52] (see graph below) how continued production of natural gas, particularly the US shale gas boom, has had the unintended consequence of delaying the transition to renewable energy by 12 years.   

AK CAN! RECOMMENDS: The state redirect resources away from LNG export to China towards building a vibrant fuel-free energy future based on Alaska’s inexhaustible, abundant and cheap renewable energy resources.  Investing in pumped hydro storage is an especially smart choice as it will allow integration of up to a Gigawatt of fuel-free energy onto Alaska’s Railbelt utility grid. Combined with our cold climate, clean, cheap energy has the potential to attract server farms, manufacturing and a diversity of new business and industry to Alaska that could form the foundation for a sustainable and stable new economy.   Objective 5.3B: Maximize revenue generation from current petroleum and natural gas development to support energy transition.
That said, obviously we can’t stop producing and generating revenue from fossil resources tomorrow.  However, energy markets are shifting at breakneck speed in response to rising #BeyondParis goals and emerging “worse than we thought” climate science projections.  New opportunities are on the horizon that may facilitate a sooner than later (certainly before next century) transition.
AK CAN! RECOMMENDS: Instead of marketing Alaska’s gas to China in a pooled market that puts us in competition with highly competitive global shale gas markets, we can fetch a premium by targeting sales of our conventional gas resources to emerging low-carbon markets in California[53] and the EU[54]. Global energy market signals are, as yet small but very clear; the world is decarbonizing and moving towards a clean energy economy[55].  Alaska must institute a clear timeline to transition off of dependency on fossil fuel revenue and commit to a clearly defined schedule of increasing renewable energy investments with a goal of achieving a 100% renewable energy-based economy by 2050. 
Towards a far more efficient 100% renewable energy futureGOAL 3) Accelerate the strategic decarbonization of Alaska’s economy through increased energy efficiency, renewable energy production and electrification. Objective 2.1A: Increase value-added blue economic activities (e.g.; fisheries, mariculture, high value processing, and marine biotechnology) that leverage clean energy as part of an in-place or relocation adaptation strategy. Objective 2.1B: Develop new climate-responsive models of community economic development that support diversification, leverage local investment, and strengthen the green economy, including tourism and clean energy. Goal 2.3: The State of Alaska will develop training and workforce development programs specific to reducing energy demand across all energy-use sectors, and to development of renewable energy systems. Objective 2.3A: Expand efforts to train rural Alaskans in home energy audits and weatherization and retrofit techniques. Objective 2.3B: Establish training centers in urban and hub communities to train on various renewable energy production systems (solar, wind, biomass, geo-exchange, etc.). Policy Statement 3: Goal 3.1: The State of Alaska will work to reduce greenhouse gas emissions in Alaska by 30% (over 2005 levels) by 2025. Maximize carbon neutral growth in Alaska through a rapid transition to clean energy, electrification and energy efficiency. Objective 3.1A: Increase efficiency of and reduce greenhouse gas emissions from natural resource development. Objective 3.1B: Increase the use of renewable and low emission energy resources in air, rail, road and marine transportation, and consider the impact to Alaska communities and economy of banning or implementing alternative fuels. Objective 3.2A: Improve generation efficiency and reduce line loss in industrial activities, within the Railbelt, and in rural Alaska. Objective 3.2B: Invest in renewable energy and energy efficiency measures across Alaska. Objective 3.2B: Update design and engineering standards to incorporate expected climate change metrics, work toward net zero energy public facilities, and implement a statewide residential and commercial building incentive program that responds to regional differentiation.
Energy Efficiency
Alaska need not reinvent the wheel.   Other state, non-governmental and private organizations are surging ahead on the energy efficiency front and we appreciate CALT’s considerable efforts to improve energy efficiency. 
AK CAN! RECOMMENDS: Many organizations and entities are working on energy efficiency as Alaska’s ‘low hanging fruit” so we will not go into great deal here except where we see gaps.   Best practice energy efficiency financing measures include Property Assessed Clean Energy Financing (adopted by the legislature) Feed-in-tariff/CLEAN financing, on-bill financing and building code reform (net-zero housing, solar ready and permit fee incentives).  One possibility we’ve not seen mentioned elsewhere is improved refrigerant management.  Identified as Drawdowns #1 solution[56], adoption and strengthening of the 2016 Section 608 EPA rule (see below) in Alaska[57] should be a priority.  We also encourage greater effort to identify and adopt fair and democratic best practice energy efficiency polices so that all Alaskan’s can benefit from improved efficiency efforts. 


New energy technologyObjective 2.1A: Increase value-added blue economic activities (e.g.; fisheries, mariculture, high value processing, and marine biotechnology) that leverage clean energy as part of an in-place or relocation adaptation strategy. Goal 2.2: The State of Alaska will encourage and strengthen business expertise that addresses climate change mitigation or adaptation. Objective 2.2A: Consider adaptation processes and technology as an export opportunity, such that Alaskans are able to meet a global demand for climate change adaptation services. Objective 2.2B: Export technological and process innovation as it relates to carbon emission reduction. Objective 5.1D: Explore additional one-time or endowed investments that the state may lead, including focused attention to science and technology and emerging clean energy technology.
We support all of the above objectives.  But before Alaska can export its expertise, it must be cultivated and grown.  We are falling considerably behind on the technological innovation front and risk falling further behind, losing the opportunity to show leadership.  At the end of the day, this sends a signal to the business community that we are not committed to investing in the future. CALT may be our last best chance to restore our leadership position and the faith of the rapidly transforming business community.
Cutting edge technology companies are eager to expand into Alaska, and they need to know they are welcome and encouraged to invest here and help our communities adapt. Much "ground work" has been done by others, and there is widespread consilience in their recommendations What we need now is to identify, apply and implement best practice policy suggestions. We wholeheartedly agree with Governor Walker and Lt Governor Mallott’s recent Juneau Empire Op-ed[58] that:We should not use our role as an energy producer to justify inaction or complacency in our response to the complex challenge of climate change. Instead, we must leverage our expertise and resources gained as an industry leader, creating solutions that empower individuals, communities and businesses. A responsible energy transition will help us to envision and create a future for Alaska that is prosperous, just, and competitive in a global marketplace that is increasingly shifting towards renewables and energy efficient technologies. A 2017 report estimated that jobs in the solar and wind energy sectors are growing 12 times as fast as the rest of the U.S. economy. Not only will this energy transition create jobs and investment opportunities, it will also enable communities and regions to take control of their energy systems, reducing costs and increasing local energy security. Alaska has incredible renewable energy resource potential — our economic future must reflect that.Alaska has perhaps the greatest, most diverse and inexhaustible renewable resources in the nation[59].  A current leader in solar energy, Germany[60], has less solar resource than Alaska, for example. 

To meet the considerable challenges ahead, Alaska will need a 180-degree turn around from its current trajectory.   We are greatly concerned by the common rhetoric, reflected in the following statement made by Lt. Governor Mallot in a recent PRI interview[61], that:“at least a quarter century of continuing to use petroleum at roughly the levels that we do now, followed by a weaning away during that period of time for national security purposes, for meeting market purposes, for revenue purposes for our state”. 
The idea that we have at least a quarter century before we need to begin weaning away from oil and gas production is completely out of step with science, the Paris Agreement and global energy market trends.
AK CAN! RECOMMENDS:  Rethinking and adoption of clear, stepwise goals to transition Alaska to a 100% Renewable Energy economy[62] by 2050.  Such an initiative will catapult Alaska into the 21st century, create thousands of new jobs, expand our nascent renewable energy sector and attract new industries to Alaska[63].  The Alaska Renewable Energy Roadmap tech team is currently collaborating with renewable energy advocates and experts across the state and elsewhere to identify and detail a specific timeline and financing strategy to move Alaska to 100% renewable energy by 2050.  The keystone of the Roadmap is the Eklutna Pumped Hydro Storage Project[64] (more below).  We encourage support for these efforts.  

To fulfill the governor’s promise “to leverage state resources and expertise” to drive the transition, we need a bold new vision that ensures full funding for the transition. At the very least we must redirect the state’s generous fossil fuel energy subsidies to renewables and re-design a bold new oil and gas production tax structure, starting today.  
Renew Rural Communities, Nuiqsut EVconversion/renewable energy pilot project
Alaska is a leader in rural microgrids and many have renewable energy as part of their generation mix (see Map below), especially wind.  Kodiak is the shining star, at 100% but other communities are gaining or working towards integrating fuel-less energy sources.  Storage is a constraint.  We’re still working out the details, but it may be cost effective to convert local vehicles (boats, trucks and snow machines, etc.) to electric which can double as a local battery system.  When vehicles are not in use, they can plug into the grid and recharge excess wind and solar energy that would otherwise need to be dumped from the system.    In essence, local car, trucks, boats, snow-machines can serve the dual purpose of diesel-free transportation and a local battery. 
A rough estimate based on a standard Tesla battery pack[65]: ModelCapacityRangeCost/kW (@190/kWh)[66]WeightTesla S75kW (350 volt)310 miles$14,250
Tesla, Model 350kW220 miles$  9,500
Tesla, Model 375kW (350 volt)310 miles$14,250
1957 Ford Fairlane[67]50kW120 kilometers?880 lbs (400 kg)





Conversion kit cost[68] can range from $5,000-100,000 depending on lots of variables[69] (DIY or professional workshop, type of vehicle, range, breaking system, battery management, charging, etc.).  Basic conversions of local vehicles can likely be done affordably (financed from fuel cost savings) and have the added benefits of creating new local jobs and improving air quality, community health and the larger environment. 
AK CAN! RECOMMENDS: adoption of finance incentives, technical training programs building on existing state expertise, for EV conversions of existing fleet, solar/wind installation and maintenance, aggregate purchasing/shipping.  Nuiqsut is very likely experiencing high rates of adverse health effects due the heavy use of highly toxic diesel fuel to run vehicles, oil and gas operations and local energy generation in close proximity to the village.  It should be a priority community on the North Slope for an EV vehicle conversion/renewable microgrid pilot project (wind, solar and other renewable energy sources deemed to have the lowest LOE locally), but many other rural communities could add or expand existing renewables with local battery storage.      

Regional-scale Energy StorageIntegration of renewable energy into the Railbelt grid will require energy storage to stabilize and store variable wind, solar and other intermittent sources for use on demand[70].   A recent Alaska case study on energy storage technologies[71] found pumped hydro storage to have the lowest capital cost, operation and maintenance cost, longest expected life and efficiency, superior performance and among the lowest levelized cost per cycle power (LCCP) of currently available storage technologies.  A pumped hydro storage concept is currently under development as an upgrade and expansion of the existing Eklutna Dam[72].  Bradley Lake offers a possible successful business model for financing and joint ownership of a regional-scale storage system[73]. 

AK CAN! RECOMMENDS:  Strong support for efforts currently underway to establish a Unified or Independent System Operator to manage the Railbelt grid on a regional-wide basis.  Such a unified entity should have the authority to set one universal transmission tariff, thus removing a significant barrier to renewable energy development providing certainty and predictability to all energy developers in the Railbelt and improve utility efficiencies and renewable energy generation.  To be successful, these efforts will need support from our legislators and renewable energy savvy commission appointees.  We further recommend the state underwrite (possibly through the Alaska Energy Authority Emerging Energy Technology Fund) a feasibility study of the Eklutna Battery Complex[74] and, assuming it pencils out, consider a capital investment in the project.
Job, jobs, jobs!
Comparing the employment impacts of energy efficiency, renewable energy, and fossil fuels using an input-output model, Heidi Garrett-shows that renewable energy creates five times more jobs than fossil fuel industries per $ invested[75]:
[On] average, 2.65 full-time-equivalent (FTE) jobs are created from $1 million spending in fossil fuels, while that same amount of spending would create 7.49 or 7.72 FTE jobs in renewables or energy efficiency. Thus each $1 million shifted from brown to green energy will create a net increase of 5 jobs.
Clean energy and sustainability industries are well-established in other states and growing more rapidly than the fossil fuel sector (ref) and deliver a win-win for the economy and the environment.  Clean energy sector jobs are local, pay above average wages, and could potentially create new economic and job opportunities and across the state, including rural communities.
AK CAN! RECOMMENDS: Energy efficiency and renewable energy investments create savings, more jobs per dollar invested, keep more energy spending in Alaska and create high-paying job opportunities that improve lives and stimulate local economies. We expect CALT will support the policies and programs that encourage growth and investment in renewable energy, energy efficiency, and electrification of our transportation system, starting in rural communities.An abundance of cheap, clean energy will attract significant new industry to Alaska, especially those that require cold climates (server farms).
Onshore wind (Drawdown solution #2)[76]: to be addressed in subsequent comments.
Electrification: to be addressed in subsequent comments.
Clean up existing fossil fuel operations.

Incentivize more efficient, cleaner fossil fuel development- Improve air and water-quality monitoring adjacent to oil and gas development- Reduce NS and CI carbon and methane off-gassing and flaring- Ban high-volume, slick-water hydraulic fracturing until risks to air, water, wildlife, subsistence resources and geo hazards can be fully assessedFossil fuel extraction is a dirty business.  Alaska’s North Slope is one of the biggest oil and gas industrial zones in the US and in the Arctic.  With an estimated 10,000 wells, as of 2011, the Prudhoe Bay Oilfield alone had 127 production pads, 25 facility pads, 145 support pads (power stations, camps staging areas, etc.), 103 exploration sites, 13 offshore exploration islands, 7 offshore production islands, 9 air-strips, 4 exploration airstrips, 2037 culverts, 27 bridges, 50 caribou crossings, and one active landfill.  The road network to support oil and gas production on the North Slope consists of 669 km of gravel roads, 154 km of abandoned peat roads, 12 km of causeways, 96 km of abandoned tractor trails, and 54 km of exploration roads with thin gravel or tundra scars. The 790-km pipeline network includes groups of parallel pipelines elevated 1–2 m above the tundra surface on vertical supports. Pipeline corridors included anywhere from 1 to 21 closely spaced parallel pipelines with diameters up to 60 cm. The length of major powerlines with towers totaled 541 km. The total oilfield infrastructure covered 7429 ha of the North Slope by 2011, mainly consisting of 2345 ha of gravel pads, 2737 ha of gravel mines, and 1255 ha of gravel roads and causeways. Impacted areas also included airstrips (125 ha), offshore gravel pads and islands (82 ha), exploration sites (290 ha) exploration airstrips (20 ha), peat roads (209 ha), tractor trails/scars (104 ha), exploration roads (72 ha), and areas where pads have been removed and are in the process of recovery (190 ha). Most of the direct effects to the landscape occurred within 18 years of the initial discovery of oil, reaching just over 25 square miles (6722 ha) by 1988. Since 2001, the oil development has expanded westward, increasing the infrastructure area to almost 30 square miles (7429 ha)[77].  Between 1996 and 2004, the Prudhoe Bay oil fields and Trans-Alaska Pipeline had an average of 504 spills annually according to the Alaska Department of Environmental Conservation (ADEC). Forty different toxic substances from acid to waste oil have been spilled during routine operations. These 4,532 spills totaled more than 1.9 million gallons of toxic substances, most commonly diesel, crude oil, and hydraulic oil[78].
Reduce venting and flaring

According to the recent Alaska greenhouse emission inventory report[79] (see Exhibit 4 below) the state had already reduced GHG emissions by 33.9% below 2005 levels by 2015, thus the goal to “reduce greenhouse gas emissions in Alaska by 30% (over 2005 levels) by 2025” is nonsensical. 

AK CAN! RECOMMENDS:  The state can reasonably reduce its GHG emissions by 80% below 2005 levels by 2025.  A reduction of 95% is probably possible with a bit more effort but in any case, Alaska can and should strive for 95% by 2030 and reach very close to zero net carbon by 2050.  Gross emissions are a more meaningful measure of our actual GHG contribution and need to be included in subsequent analysis of state emissions. 
Alaska fossil fuel producers flared 17,374,472 thousand cubic feet (Mcf) of gas between 2012-17, as reported to the Alaska Oil and Gas Conservation Commission[80]. This represents approximately 1/10th of the total annual Railbelt generation energy equivalent.  Due to its powerful greenhouse effect, minimizing methane emissions, including that from and permafrost melt, is a critical priority.  Reinjection of gas emissions is preferred over flaring and flaring is preferred over venting.
While we urge a rapid transition away from all forms of fossil fuel, experts agree that reducing natural gas venting and flaring on the North Slope and Cook Inlet through strong enforcement of Alaska Oil and Gas Conservation Commission’s existing policies that minimize “waste.” (20 AAC 25.235)[81] is Alaska’s “low hanging fruit”.  But the regulations do not specifically require emissions to be reduced-operators are only required to track their waste and justify why it occurred. 
A recent International Energy Agency report concluded that global oil and gas methane emissions could be reduced by up to 75% using technologies available today, with two-thirds of those reductions achievable at no net cost[82].  ExxonMobil’s recent announcement[83] that it plans to reduce oil and gas methane emissions by 15 percent and flared gas volumes by 25 percent across its global oil and gas operations by 2020 is a clear indicator that industry is not averse to such measures.Flaring reduces hazardous air pollutants, volatile organic compound emissions, and greenhouse gas emissions. Unnecessary venting and flaring should be prohibited as they represent pure "waste" of the state's energy resources.  Flaring wastes natural gas resources, even while the central parts of Alaska are in great need of cleaner sources. Flaring also produces air pollutants that are detrimental to air quality and climate. The CO2 emissions from flares are well-quantified and a significant contributor to global climate pollution.  Other pollutants from flares are not wel1-quantified, but flares can produce large amounts of carbon monoxide (CO), volatile organic compounds (VOC), unburned methane, nitrogen oxides (NOx), black carbon (BC), and other particulate matter, at least under some conditions. BC, the sooty particulate produced by incomplete combustion, is a climate pollutant of particular concern. BC is possibly the second most important climate pollutant, behind only CO2.
BC is particularly damaging to the climate when it is emitted in cold areas with significant snow cover such as Alaska. BC settles out of the atmosphere onto snow and ice, where the dark BC absorbs sunlight that would otherwise be reflected from the surface, warming it and accelerating the melting of snow and ice.
When natural gas is produced at oil wells with no pipeline to carry the gas to a market, the gas is often flared off as a waste product. In some U.S. locations, gas associated with oil wells is flared Such flaring may be prevalent at oil wells in shale formations for two reasons. First, re-injecting natural gas back into these formations may not be feasible. Second, geological formations which produce oil after hydraulic fracturing also typically produce significant amounts of natural gas
AK CAN! RECOMMENDS:  Review and update of the state oil and gas infrastructure reclamation standards, increase surety compliance bond requirement to equal real cost of reclamation (require a fixed bond amount per well plus an additional fee per foot of drilling depth) linked to production and well depth[84],[85]or better yet require companies to put up the full estimated cost in advance[86].  Alaska should limit flaring and venting to the smallest amount needed for safety, implement Reduced Emission Completions (RECs) and require operators to implement technically feasible gas control and collection practices, during hydraulic fracturing operations in particular, and to use gas recovered from wells-rather than diesel-to power equipment, thereby greatly reducing air pollution. The state should develop a plan to prevent flaring of associated gas during oil production, including a study of options to transport gas to market or injection sites and other productive uses of the gas, and require oil producers to analyze the economics of the various options before allowing flaring during oil production. In the event that gas recovery is not possible, we recommend that the Commission require gas flaring as an environmentally preferable alternative over venting. Finally, we recommend that operator reports on flaring and venting be made available to the public.
PermafrostGoal 1.2: The State of Alaska will actively engage researchers and local governments to develop a strategic approach to community risk monitoring, assessment and planning. Objective 1.2A: Increase the availability and use of monitoring equipment to track and understand sea level, permafrost and other environment changes, as well as mapping, bathymetry and climate modeling.
We are still compiling information and will have much more to say in subsequent comments, but we are concerned by the single mention of permafrost and complete absence of the term “methane” in the draft.  Given the high and growing cost and risk of permafrost melt, and associated methane releases, permafrost and methane need to much greater priorities.   For example, the AOGCC recently ordered review of all North Slope oil wells after a spill was linked to permafrost[87].  Permafrost around North Slope oil and gas infrastructure is melting at a more rapid rate, even than it is regionally, and expected to worsen[88].  Concerns are rising that permafrost melt could cause a more widespread failure of oil and gas infrastructure and pose a threat to the community of Nuiqsut and large areas of the North Slope.   The chart below is from the 2018 Assessment of the Potential Health Impacts of Climate Change in Alaska[89]

AK CAN! RECOMMENDS:  Monitoring permafrost degradation rates adjacent to North Slope oil and gas wells (especially older wells) and order a comprehensive, independent study to assess the risks, costs and mitigation of impacts from permafrost melt on abandoned and active well emissions[90] and expand permafrost melt and methane emission research and data collection and dissemination.
Fracking: to be addressed in subsequent comments
Little known to residents, hundreds of wells have been hydraulically fracked in Alaska
Geohazards: to be addressed in subsequent comments
High-volume, slick-water hydraulic fracturing (i.e. “fracking”) is a relatively new technology that’s only recently been used in Alaska.  It’s been scientifically linked to earthquakes, yet the state has conducted no assessment of the geohazard risks associated with volcanic activity, earthquakes and fracking in Cook Inlet.
Diesel
A large number of toxicological studies clearly show that diesel engine emissions have significant health effects[91].  The use of diesel in North Slope OG production facilities and to power rural communities is high. 
AK CAN! RECOMMENDS:  We urge a robust phase out of diesel fuels by 2030, especially in and near rural communities and sensitive subsistence resource areas.  Again, and again, local community concerns regarding impacts of oil and gas development have been brushed aside.  Local input over oil and gas development needs to be strengthened.  A good place to start would be by reinstating the Alaska Coastal Management Program and adopting legal and regulatory mechanisms that allow local communities to say NO to unwanted projects.
Setbacks & buffer zones
Scientists agree the existing setback laws in various jurisdictions throughout the U.S. are inadequate to protect the health and safety of residents who live, work, hunt and gather near oil and gas operations[92]. Alaska currently has no rules requiring setbacks of oil and gas wells or other major fossil fuel infrastructure from private residences, rural communities, schools or avoidance of subsistence harvesting areas. Due to the extreme winter conditions in Alaska and difficulty accessing failed infrastructure[93],[94], we recommend a minimum buffer-zone (or set-back) of 2 miles from private or commercial properties, rural communities and municipalities and known subsistence harvesting areas. 
Health Impact Assessment
Reports of health effects from the 2012 Repsol blowout[95] and continued concerns about health impacts of oil and gas development need to be investigated, especially in the Alaska Native community of Nuiqsut that is increasingly surrounded by oil and gas development.

AK CAN! RECOMMENDS:  In addition to requesting a comprehensive Health Impact Study, overseen by the Nuiqsut Tribal Council Office of Environmental Management, we recommend installation of emergency shut-off and air monitoring equipment and mandatory reporting to residents and communities within a 20-mile radius of residents and communities potentially affected by downwind toxic air releases.
Towards a circular economy
Zero Waste/Plastics
Plastic, one of the most preferred materials in today's industrial world is posing serious threat to the environment and consumer's health in many direct and indirect ways. Exposure to harmful chemicals during manufacturing, leaching in the stored food items while using plastic packages or chewing of plastic toys by children are linked with severe adverse health outcomes such as cancers, birth defects, impaired immunity, endocrine disruption, developmental and reproductive effects[96]
The massive, uncontrolled release of plastics into the environment is a particularly horrifying example of our failure to recognize and prevent widespread harms before they occur.  Recent studies show that plastics are now pervasive; microplastics were found in 90% of bottled water[97], and permeate the marine food chain[98],[99], [100].
AK CAN! RECOMMENDS:  The majority of the contamination comes from microfibers[101] and single-use plastics[102], such as water bottles, the materials that comprise the majority of plastic waste. A state ban on single use plastics is an important first step that we urge the Commission to support.  Efforts are also underway to collect, repurpose and replace plastics with biodegradable products. Apply the lessons of industrial ecology. Analyze the system-wide interactions within and between industries in terms of material and energy flows. This will provide opportunities for improvement for both society and the environment. Transitioning from a petroleum economy to a post-carbon economy requires looking at the webs of industries, communities, and corporate entities that grew up around it at the same time. We've only begun to explore sustainable industrial symbioses in Alaska. New ones will form as emerging technologies and the relationships they enable continue to disrupt old industry models. We've already seen a recent growth in uses for fisheries by-products. Which industries will be transformed next? (A possible subject for ISER).
Circular Economics & Industrial Ecology
Ultimately, our economy must be reconfigured to keep plastics and other sources of harmful pollution out of the environment, reduce waste and improve efficiencies all across the system. The circular economy is an approach that takes insights from living systems. It considers that our systems should work like organisms, processing nutrients that can be fed back into the cycle — whether biological or technical — hence the "closed loop" or "regenerative" terms usually associated with it[103].

A study of seven European nations found that a shift to a circular economy would reduce each nation's greenhouse-gas emissions by up to 70% and grow its workforce by about 4% — the ultimate low-carbon economy[104].
The circular economy is part of a trend towards intelligent decentralization — witness 3D printing, mass customization of manufacturing, 'labs-on-a-chip' in chemistry and functional services. We will have much more to say about growing a more localized, circular economy powered by renewable energy in subsequent comments. 
AK CAN! RECOMMENDS: Alaska needs to implement policies that incentivize activities that are good for society and the environment and disincentivize those that are not.  The world is on the verge of retrofitting its entire economy.  If we recognize what’s coming and invest early in R&D, we will become a center of innovation and realize the long-held dream of diversifying our economy.   There are many economic sectors in Alaska, including petroleum, tourism, fishing, mining, timber, agriculture, military/government, and many others. Within each industry are numerous separate operations. The system wide interactions within and between industries in terms of material and energy flows provide opportunities for improvement for both society and the environment. Transitioning from a petroleum economy to a post-carbon economy requires looking at the web of industries, communities, and corporate entities that grew up around it at the same time. I think we've only begun to explore sustainable industrial symbioses in Alaska. New ones will form as emerging technologies and the relationships they enable continue to disrupt old industry models. We've already seen a recent growth in uses for fisheries by-products. Which industries will be transformed next? Institute of Social and Economic Research (ISER) has done some preliminary work in this direction, but what is needed is a larger and more comprehensive project with a bolder mission: to address the immense challenges arising from pressure on the environment and the natural resources such as climate change, chemical risks and resource constraints on land, materials and energy, and a plan to do it within the time available[105]. 
Carbon sequestration & off-sets

Improve land use, coastal wetlands, peat lands, forest preservation, and Indigenous land management (Drawdown solution #5, etc.)[106]

Peat contains large amounts of carbon that gets released by fire which is increasing due to climate change.[107],[108],[109]

Case study: Chugach Alaska Corporation to sell Bering River coal rights

http://www.akbizmag.com/Alaskan-Native/Innovative-deal-sees-permanent-retirement-of-coal-reserves-while-securing-long-term-income-for-Chugach-community-via-forest-carbon-market/

AK CAN! RECOMMENDS:  Provide technical support to develop Alaska’s off-set markets, to preserve and protect valuable carbon sinks. Pilot and implement reintroduction, population enhancement use of megafauna, restoration of mammoth steppe ecosystems for preserving permafrost in the Arctic. Case study: Pleistocene Park, Siberia, Russia.[110],[111],[112]

Research and potential development of an Alaska olivine market:  https://www.nature.com/news/rock-s-power-to-mop-up-carbon-revisited-1.14560.  Explore carbon capture at the source and geologic burial including technologies for capturing CO2 directly from flue gases of power plants and injecting CO2 into abandoned oil or gas fields, including the Swanson River Oil Field, which is presently being used to store natural gas pumped out of Cook Inlet during the summer. It could however be used to sequester CO2 from the HEA Nikiski power plant. Investigate carbon capture by passing CO2 through a mixture of crushed limestone and water to make an alkaline bicarbonate slurry which is then pumped into the ocean, or (as Iceland is doing) pump CO2 into underground basalt and water, where it is precipitated as calcite. With the warmer climate some of the fast-growing Populus hybrids should have a very fast harvest rotation for pulp but could probably be used for carbon credits.
Towards a managed decline/phase down: to be addressed in subsequent comments
In conclusion…
Alaska is living with the amplified effects of climate change.  Decarbonization is now a major driver of global energy markets and economics.  It’s time for us to take the bull by the horns and face the undeniable fact that we must keep 80% of our known fossil fuel reserves in the ground. 

As daunting and dire as this may seem to many, in truth, it could ignite a new, and far more sustainable economic boom and catapult Alaska into the 21st century.According to REN21 2016 report[113], seven countries [Iceland (100 percent), Paraguay (100), Costa Rica (99), Norway (98.5), Austria (80), Brazil (75), and Denmark (69.4)] are already at, or very near 100% renewable energy power[114] from hydropower, wind, geothermal, and solar.
A study just out by Stanford scientists[115], suggests the economic benefits of meeting the 1.5 °C target potentially outweighs the costs:
“… by the end of this century, there is a more than 75% chance that limiting warming to 1.5 °C would reduce economic damages relative to 2 °C, and a more than 60% chance that the accumulated global benefits will exceed US$20 trillion under a 3% discount rate (2010 US dollars)….We find considerably greater reductions in global economic output beyond 2 °C. Relative to a world that did not warm beyond 2000–2010 levels, we project 15%–25% reductions in per capita output by 2100 for the 2.5–3 °C of global warming implied by current national commitments7, and reductions of more than 30% for 4 °C warming. Our results therefore suggest that achieving the 1.5 °C target is likely to reduce aggregate damages and lessen global inequality, and that failing to meet the 2 °C target is likely to increase economic damages substantially.”Delaying Alaska’s transition away from fossil fuels another 25, 50 or 100 years poses unacceptable climate change and economic risks for Alaskans.    
In contrast, the potential benefits of initiating an immediate transition away from fossil fuel and towards a new energy economy are huge[116] and include jobs, improved human well-being, renewed economic growth, increased efficiency, avoiding catastrophic climate change and more.
Alaska can and must craft a state win-win climate policy strategy that ensures Alaskans and Alaska a clean, prosperous, secure and renewable future.  This comment comprises a very preliminary sketch of our collective new energy vision.   Just as the draft represents an initial effort by CALT, we will continue to research, gather input from our affiliate and partner groups and members and consult with experts in various fields as we develop our understanding and ideas.  We look forward to future opportunities to comment on CALT plans and initiatives going forward.
Respectfully,
Ceal Smithon behalf of AK CAN! partners and members
Bjørn Olson, Director of Advocacy, Kachemak Bay Conservation Society's Alaskans Know Climate Change Education Campaign, HomerScott Gruhn, AK CAN!, AnchorageEric Schaetzle, AK CAN!, FairbanksElisa Russ, Citizens Climate Lobby, Homer, AK ChapterDanielle Redmond, Renewable Juneau Coordinator, JuneauShonah Stone, AK CAN!, Anchorage
Alfredo Bolivar, AK CAN!, AnchorageGretchen Keiser, AK CAN!, JuneauAndy Romanoff & Elaine Schroeder, 350Juneau, JuneauJan Bronson, AK CAN!, AnchorageLibby Roderick, AK CAN!, Anchorage, Owner, Turtle Island RecordsMarybeth Holleman, Author, Anchorage

Post 6.4.18 submission signatores:
Sandy Harper, AK CAN!, Producing Artistic Director Emeritus, AnchorageTim Lyons, AK CAN!, Girdwood

[1] Hobson & King.  Trump's 'energy dominance' transforms Alaska's future.  E&E News, Energywire: November 15, 2017. https://www.eenews.net/special_reports/year_of_trump/stories/1060066507[2] Alaska Acts on Climate.  Living on Earth.  PRI.  https://www.loe.org/shows/segments.html?programID=18-P13-00021&segmentID=1[3] Brad Plummer, The New York Times. “Impossible to Ignore’: Why Alaska Is Crafting a Plan to Fight Climate Change.  May 15, 2018.  https://www.nytimes.com/2018/05/15/climate/alaska-climate-change.html[4] Personal Communications between AK CAN members and CALT members at the Resiliency Summit, May 15, 2015, Anchorage, AK. [5] Kevin Gullufsen. Report: Alaskans fourth highest green-house gas emitters per-capita.  Juneau Empire. Jan 31, 2018.  http://juneauempire.com/news/local/state/2018-01-30/report-alaskans-fourth-highest-greenhouse-gas-emitters-capita[6] Shell’s vision of a zero-carbon world by 2070 explained.  https://www.vox.com/energy-and-environment/2018/3/30/17171370/shell-oil-climate-change-carbon-2070[7] 2020 The Climate Turning Point. https://newclimate.org/2017/04/10/2020-climate-turning-point/[8] Inside Climate News.  Global C02 emission to hit record high in 2017.  https://insideclimatenews.org/news/12112017/climate-change-carbon-co2-emissions-record-high-2017-cop23[9] No Drop in US Carbon Footprint Expected through 2050, Energy Department says. https://insideclimatenews.org/news/06022018/eia-trump-greenhouse-gas-emissions-rise-climate-change-natural-gas-wind-solar-energy[10] Three years to safeguard our climate, Nature Comment.  https://www.nature.com/polopoly_fs/1.22201!/menu/main/topColumns/topLeftColumn/pdf/546593a.pdf[11] McGlade, Christophe & Ekins, Paul. The geographical distribution of fossil fuels unused when limiting global warming to 2oC.  Nature 517, 187-190 (08 January 2015). https://www.nature.com/articles/nature14016[12] Jakob Michael & Hilaire, Jerome.  Climate Science: Unburnable fossil-fuel reserves.  Nature, letters.  https://www.nature.com/articles/517150a[13] Schleussner C., Lissner T.K., et al. Differential climate impacts for policy-relevant limits to global warming: the case of 1.5C and 2C.  Earth System Dynamics. https://www.earth-syst-dynam.net/7/327/2016/esd-7-327-2016.pdf[14] Michaeleen Doucleff. NPR Morning Addition. Is there a ticking time bomb under the Arctic? https://www.npr.org/sections/goatsandsoda/2018/01/24/575220206/is-there-a-ticking-time-bomb-under-the-arctic[15] Ibid.[16] June Average Temperature Trend Past 50 years Alaska Climate Divisions (map).  2018 Rick Thoman, NOAA/NCEI.  https://twitter.com/AlaskaWx?lang=en[17] US Government Accountability Office (GAO) GAO-09-551. https://www.gao.gov/products/GAO-09-551[18] Yoder, Sarah, MS. Assessment of the Potential Health Impacts from Climate Change in Alaska. Jan 8, 2018. http://www.epi.alaska.gov/bulletins/docs/rr2018_01.pdf[19] Ibid. Appendix 3: Potential Health Impacts of Climate Change, by Climate Change Factor.[20] Denise Fairchild & Al Weinrub.  Energy Democracy.  Island Press. https://islandpress.org/books/energy-democracy[21] Burke, JM and Stephens, JC. Energy democracy: Goals and policy instruments sociotechnical transitions. Energy Research and Social Science. 2017. https://www.sciencedirect.com/science/article/pii/S2214629617303031[22] https://www.akfoodpolicycouncil.org/[23] Alaska Grown Source Book.  http://dnr.alaska.gov/ag/[24] Adaptation Action Areas, Adaptive Management of Fish & Game. http://climatechange.gov.alaska.gov/actionareas/adaptation/[25] Alaska Native Subsistence: A matter of cultural survival.  https://www.culturalsurvival.org/publications/cultural-survival-quarterly/alaska-native-subsistence-matter-cultural-survival[26] Wilson Justin.  Email communication with AK CAN members.  May 2018.[27] Local Environmental Observer Network (LEO). https://www.leonetwork.org/en/#lat=65.2630284889142&lng=-166.365280151367&zoom=7[28] http://www.drawdown.org/solutions/food/reduced-food-waste

[29] Joe Vigil. LNG pipeline project by the numbers.  KTVA. Nov 20, 2017. http://www.ktva.com/story/36892564/lng-pipeline-project-by-the-numbers

[30] Elwood Brehmer. Alaska Journal of Commerce. FERC sets Dec 2019 as deadline for AK LNG review. March 14, 2018. http://www.alaskajournal.com/2018-03-14/ferc-sets-december-2019-deadline-ak-lng-review#.WwoaNakh0qI[31] Acting on Climate Change: Solutions from Canadian Scholars. http://www.sustainablecanadadialogues.ca/files/PDF_DOCS/SDC_EN_30marchlr.pdf

[32] McGhee & Reich. Here’s How States and Cities Can Fight Climate Change and Inequality in the Trump Era. The Nation. https://www.thenation.com/article/heres-how-states-and-cities-can-fight-climate-change-and-inequality-in-the-trump-era/

[33] Pacific Coast Collaborative.  http://pacificcoastcollaborative.org/[34] United States Climate Alliance. https://www.usclimatealliance.org/

[35] EPA. Sources of Greenhouse Gas Emissions. https://www.epa.gov/ghgemissions/sources-greenhouse-gas-emissions

[36] Robin Brena. Alaska needs to reclaim its fair share of oil revenue. Alaska Daily News. Oct 1, 2016 https://www.adn.com/opinions/2016/10/01/alaska-needs-to-reclaim-its-fair-share-of-oil-revenue/[37] What is the Anthropocene and Are We in It? https://www.smithsonianmag.com/science-nature/what-is-the-anthropocene-and-are-we-in-it-164801414/

[38] Ground Truth Trekking. Oil Tax Credits: What are they, and why are they a problem? http://www.groundtruthtrekking.org/Issues/AlaskaOilandGas/oil-tax-credits-what-are-they-and-why-are-they-a-problem.html

[39] IRENA. Decarbonizing the Global Economy: Thinking Differently to Achieve a Renewable Energy Future

14 November 2016. http://www.irena.org/newsroom/articles/2016/Nov/Decarbonising-the-Global-Economy-Thinking-Differently-to-Achieve-a-Renewable-Energy-Future[40] Alaska Climate Action Network petition to APFC Trustees.  https://actionnetwork.org/petitions/divest-alaska-permanent-fund-from-fossil-fuels

[41] Tim Brander.  PF sticking with fossil fuels, despite advice to the contrary.  Trustees don’t want to send unfriendly message to oil and gas industry.  The Frontiersman. https://www.frontiersman.com/news/pf-sticking-with-fossil-fuels-despite-advice-to-the-contrary/article_662aad82-6144-11e8-9d0e-af41a93eaced.html

[42] http://priceofoil.org/2017/11/07/scientists-argue-gas-isnt-green-call-for-urgent-phase-out-across-eu/[43] https://www.ucsusa.org/clean-energy/coal-and-other-fossil-fuels/environmental-impacts-of-natural-gas#references[44] https://www.ucsusa.org/clean-energy/coal-and-other-fossil-fuels/environmental-impacts-of-natural-gas#references[45] https://www.ucsusa.org/clean-energy/coal-and-other-fossil-fuels/environmental-impacts-of-natural-gas#references[46] https://www.vox.com/energy-and-environment/2017/11/16/16654222/iea-sustainable-development-scenario[47] Oil Change International Report, Off Track.  http://priceofoil.org/2018/04/04/off-track-the-iea-and-climate-change/[48] Rashah McChesney, Alaska’s Energy Desk.  Alaska’s China Trade Mission wraps up with no big gasline news.  May 30, 2018.  Alaska Public Radio.  https://www.alaskapublic.org/2018/05/30/alaskas-china-trade-mission-wraps-up-with-no-big-gasline-news/[49] Jules Kortenhorst and Mark Dyson.  The Medium.  Clean energy will do to gas what gas has done to coal.  May 30, 2018.  https://medium.com/world-economic-forum/clean-energy-will-do-to-gas-what-gas-has-done-to-coal-22df2cadeef1[50] RMI Report: Positive Disruption: Limiting Global Temperature Rise to well below 2 degrees. https://www.rmi.org/insights/reports/positive_disruption_limiting_global_temperature_rise/[51] RMI Report Release: The Economics of Clean Energy Portfolios: https://rmi.org/news/report-release-the-economics-of-clean-energy-portfolios/[52] Shale gas: the broader unintended consequences.  Dr. Anthony Ingraffea, Spring Creek Project Bedrock Lecture on Human Rights and Climate Change. https://www.youtube.com/watch?v=PGfIjCG-zB4&t=332s[53] Low Carbon Fuel Standard.  http://www.energy.ca.gov/low_carbon_fuel_standard/[54] Goldman Sachs. Transition to a low-carbon economy.  http://www.goldmansachs.com/our-thinking/archive/archive-pdfs/trans-low-carbon-econ.pdf[55] Goldman Sachs.  Transition to a Low-Carbon Economy.  http://www.goldmansachs.com/our-thinking/archive/archive-pdfs/trans-low-carbon-econ.pdf[56] Hawken, Paul, Ed. Drawdown: 100 Solutions to Global Warming. http://www.drawdown.org/solutions/materials/refrigerant-management[57] EPA Section 608 regulations.  https://www.epa.gov/section608[58] http://juneauempire.com/opinion/2018-03-20/time-conversation-climate-and-development-now

[59] Alaska Renewable Energy Atlas. http://alaskarenewableenergy.org/index.php/focusareas/renewable-energy-atlas/

[60] Germany Breaks A Solar Record — Gets 85% Of Electricity from Renewables. https://cleantechnica.com/2017/05/08/germany-breaks-solar-record-gets-85-electricity-renewables/[61] Living on Earth. Alaska Acts on Climate. https://www.loe.org/shows/segments.html?programID=18-P13-00021&segmentID=1&utm_source=Governor%27s+Newsletter&utm_campaign=6e9e059eba-EMAIL_CAMPAIGN_2018_05_24&utm_medium=email&utm_term=0_3be3e1c299-6e9e059eba-173500641

[62] 100% Renewable Electricity Worldwide Is A New Cost-Effective Reality.

https://cleantechnica.com/2018/02/16/100-renewable-electricity-worldwide-new-cost-effective-reality/[63]Data Iceland Utility Touts Cheap Clean Energy to Lure Data Centers. http://www.datacenterknowledge.com/archives/2014/06/16/iceland-utility-touts-cheap-clean-energy-lure-data-centers[64] 100% Renewable Alaska. https://www.alaskansknowclimatechange.com/100-percent-renewable-alaska[65] Luke John Smith. Express News. Tesla Model 3 details revealed – Battery pack size, horsepower and more.  https://www.express.co.uk/life-style/cars/838841/Tesla-Model-3-electric-cars-UK-EPA-battery[66] Ibid[67] Fred Lambert.  A classic 1957 Ford Fairlane with a 50kWh battery pack.  Electrek. March 14, 2018.   https://electrek.co/2018/03/14/classic-1957-ford-fairlane-all-electric-conversion/[68] https://chargedevs.com/newswire/how-to-calculate-the-cost-of-your-ev-conversion/[69] Top 10 factors that determine your EV conversion budget. http://rebbl.com/top-10-factors-that-determine-your-ev-conversion-budget/[70] Robert Seitz. To meet renewable energy goals, Alaska and US need long-term storage plan. https://www.adn.com/commentary/article/alaskas-energy-systems-still-need-plan-whether-oil-and-gas-available-or-not/2016/02/27[71] An Alaska case study: energy storage technologies (2017).  http://acep.uaf.edu/media/254012/EnergyStorage_AlaskaCaseStudy_14986580.pdf[72] An elegant proposal to transform Alaska’s Railbelt to 100% renewable energy:  https://www.alaskansknowclimatechange.com/100-percent-renewable-alaska[73] Project Fact Sheet: Bradley Lake Hydroelectric Project:  http://www.akenergyauthority.org/Content/Programs/AEEE/PDF%20files/8BProgramFactSheets.pdf[74] Alaskans Know Climate Change. 100% Renewable Alaska. An elegant proposal to transform Alaska’s Railbelt to 100% renewable energy. https://www.alaskansknowclimatechange.com/100-percent-renewable-alaska[75] Garrett-Peltier, H. Green versus brown: comparing the employment impacts of energy efficiency renewable energy and fossil fuels using an input-output model.  Economic Modelling. November 2016. https://www.sciencedirect.com/science/article/pii/S026499931630709X?via%3Dihub[76] http://www.drawdown.org/solutions/electricity-generation/wind-turbines-onshore[77] Walker, Raynolds, et al., Eds.  Landscape and permafrost changes in the Prudhoe Bay Oil Field, Alaska. Alaska Geobotany Center. https://www.geobotany.uaf.edu/library/pubs/WalkerDA2014_agc14-01.pdf[78] Drilling and Spilling on Alaska’s North Slope.  http://www.nytimes.com/packages/pdf/national/15spill.pdf[79] Alaska Greenhouse Gas Emissions Inventory 1990-2015 Alaska Department of Environmental Conservation, Division of Air Quality January 30, 2018. https://dec.alaska.gov/commish/press-releases/2018/dec-releases-updated-alaska-greenhouse-gas-emissions-inventory-report[80] Flare report, 2012-2017.  From Alaska Oil and Gas Conservation Commission, data request.  ConocoPhillips Kuparuk River Unit was among the highest emitters.[81] Kate Troll, Key Climate Actions for state of Alaska: http://akcommonground.org/wp-content/uploads/2015/12/Kate-Troll-Climate-Presentation-2015.pdf

[82] International Energy Agency.  Commentary: The environmental case for natural gas. https://www.iea.org/newsroom/news/2017/october/commentary-the-environmental-case-for-natural-gas.html

[83] Exxon Mobile. ExxonMobil Announces Greenhouse Gas Reduction Measures. http://news.exxonmobil.com/press-release/exxonmobil-announces-greenhouse-gas-reduction-measures

[84] Bonding changes proposed, Petroleum News: http://www.petroleumnews.com/pntruncate/243886779.shtml[85] The Rising Cost of Cleaning Up After Oil and Gas.  http://insideenergy.org/2015/10/01/the-rising-cost-of-cleaning-up-after-oil-and-gas/[86] Reclamation Costs and Regulation of Oil and Gas Development with Application to Wyoming. http://ageconsearch.umn.edu/bitstream/92846/2/0801005.pdf[87] Alaska orders review of all North Slope oil wells after spill linked to permafrost. https://insideclimatenews.org/news/31102017/alaska-oil-wells-review-ordered-thawing-permafrost-cracked-casing-north-slope[88] Landscape and Permafrost changes in the Prudhoe Bay Oil Fields.  https://www.geobotany.uaf.edu/library/pubs/WalkerDA2014_agc14-01.pdf[89] Yoder, Sarah, MS. Assessment of the Potential Health Impacts from Climate Change in Alaska. Jan 8, 2018. http://www.epi.alaska.gov/bulletins/docs/rr2018_01.pdf[90] Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2016: Abandoned Oil and Gas Wells, April 2018. https://www.epa.gov/sites/production/files/2018-04/documents/ghgemissions_abandoned_wells.pdf[91] Steiner, Bisig et al.  Diesel exhaust: current knowledge of adverse effects and underlying cellular mechanisms.https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4894930/pdf/204_2016_Article_1736.pdf[92] Wong, N.J. Existing scientific literature on setback distances from oil and gas development sites (June 2017).http://www.stand.la/uploads/5/3/9/0/53904099/2500_literature_review_report-final_jul13.pdf[93] North Slope Oil Well Suffers a Blowout:  https://www.adn.com/economy/article/north-slope-oil-well-suffers-blowout/2012/02/15/[94] Natural gas leak in Cook Inlet Stopped, Effects on Marine Life Not Yet Known (April 2017): https://insideclimatenews.org/news/14042017/hilcorp-alaska-cook-inlet-temporary-fix-made-pipeline

[95] Health Worker Says Repsol Blowout Cause of Some Respiratory Illness Cases

 https://www.alaskapublic.org/2012/05/03/health-worker-says-repsol-blowout-cause-of-some-respiratory-illness-cases/[96] Rustagi, Pradhan, et al. Public health impact of plastics: an overview.  Indian Journal of Occupational & Environmental Medicine.  https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3299092/[97] Graham Readfearn. WHO launches health review after microplastics found in 90% of bottled Water.  The Guardian.  https://www.theguardian.com/environment/2018/mar/15/microplastics-found-in-more-than-90-of-bottled-water-study-says[98] Nelms, Galloway et al., Investigating microplastic tropic transfer in marine top predators.  Environmental Pollution. Vol 238, July 2018.  https://www.sciencedirect.com/science/article/pii/S0269749117343294[99] High levels of microplastics found in Northwest Atlantic fish.  Science Daily.  Feb 16, 2018.  https://www.sciencedaily.com/releases/2018/02/180216110513.htm[100] Damian Carrington.  Microplastic pollution in oceans is far worse than feared, say scientists.  The Guardian. March 12, 2018.   https://www.theguardian.com/environment/2018/mar/12/microplastic-pollution-in-oceans-is-far-greater-than-thought-say-scientists[101] https://www.theguardian.com/environment/2016/jun/20/microfibers-plastic-pollution-oceans-patagonia-synthetic-clothes-microbeads[102] https://www.theguardian.com/environment/2017/jun/28/a-million-a-minute-worlds-plastic-bottle-binge-as-dangerous-as-climate-change[103] Stahel, WR. The circular economy. Nature.  March 23, 2016.   https://www.nature.com/news/the-circular-economy-1.19594[104] Wijkman A. and Skanberg K. The Circular Economy and Benefits for Society:  Jobs and Climate Clear Winners in an Economy Based on Renewable Energy and Resource Efficiency.  https://www.clubofrome.org/wp-content/uploads/2016/03/The-Circular-Economy-and-Benefits-for-Society.pdf[105] https://pedon.blogspot.com/2017/06/circular-economy-alaska.html[106] Hawkens, et al, Eds. Drawdown. http://www.drawdown.org/solutions/land-use[107] https://www.adn.com/arctic/2016/08/09/as-northern-peat-bogs-burn-a-climate-threat-rises/[108] EPA link to Alaska Peat inventory: https://cfpub.epa.gov/si/si_public_record_report.cfm?dirEntryId=309935[109] Rapid deglacial and early Holocene expansion of peatlands in Alaska: http://www.pnas.org/content/107/16/7347[110] https://www.theatlantic.com/magazine/archive/2017/04/pleistocene-park/517779/[111] Mammoth on Vimeo: https://vimeo.com/207624364

[112] Pleistocene Park an experiment in adventure: https://www.gi.alaska.edu/alaska-science-forum/pleistocene-park-experiment-adventure

[113] http://www.ren21.net/[114] https://en.wikipedia.org/wiki/List_of_countries_by_electricity_production_from_renewable_sources

[115] Michelle Horton.  New Stanford study suggests climate mitigation could yield trillions in economic benefits. https://news.stanford.edu/2018/05/23/reducing-emissions-save-trillions/

[116] https://cleantechnica.com/2018/03/10/renewable-energy-economic-benefits-know/
By Ceal Smith - May 31, 2018  

By Ceal Smith

Friday, April 13, 2018

AK CAN! and Native Village of Nuiqsut, Alaska file amicus briefs on the Peoples' Tribunal on Fracking and Climate Change.

The Permanent Peoples’ Tribunal on Human Rights, Fracking, and Climate Change

CORVALLIS, ORE.—Spring Creek Project at Oregon State University will co-host a historic Permanent Peoples’ Tribunal Session on Human Rights, Fracking, and Climate Change from May 14 to 18, 2018. For the first time in its nearly 40-year history, this session of the Permanent Peoples’ Tribunal will be hosted completely online, will have an international focus, and will include arguments about the rights of nature in addition to the rights of people.
The Permanent Peoples’ Tribunal is a highly respected international forum that grew from the Russell-Sartre Tribunal to investigate whether breaches of human rights norms occurred during the Vietnam War. Since then, it has conducted a series of high-profile hearings to determine whether human-rights standards were abridged in Bhopal, Chernobyl, and other sites around the world. The Tribunal’s most recent session was on Myanmar’s crimes against the Rohingya and Kachin refugees.
The Tribunal’s upcoming session will focus on the potential human rights violations of hydraulic fracturing, or “fracking,” and climate change. The Permanent Peoples’ Tribunal judges will also be asked to consider the rights of nature, because the protection of a healthy environment may be a fundamental prerequisite for the protection of human rights. Two earth jurisprudence attorneys, Lisa Mead, LL.M., Director of the Earth Law Alliance in Scotland, and Dr. Michelle Maloney, Convenor of the Australian Earth Laws Alliance, will present witness testimony and oral and written arguments addressing the session’s central questions from a rights of nature perspective.
Another team of human rights attorneys will present witness testimony and reports from preliminary tribunals held in areas where fracking is an increasingly popular means of oil and gas extraction, including Ohio, Virginia, and Australia.   
More than a dozen amicus briefs have been submitted by attorneys and others representing non-governmental organizations, including Food and Water Watch, Food and Water Europe, Earthworks, Rogue Climate, the Community Environmental Legal Defense Fund, the Alaska Climate Action Network, the Center for Earth Jurisprudence, the Environmental Defender’s Office (in Australia), the Earth Law Alliance, the Native Village of Nuiqsut, Alaska, the Center for Human Rights and the Environment (in Argentina), and others. Some of these attorneys will present their evidence and arguments orally during the Tribunal.
After examining evidence and hearing testimony, judges selected by the impartial Permanent Peoples’ Tribunal board will be asked to provide an advisory opinion on four central questions:

1.   Under what circumstances do fracking and other unconventional oil and gas extraction techniques breach human rights protected by international law as a matter of treaty or custom? 
   
2. Under what circumstances do fracking and other unconventional oil and gas extraction techniques warrant the issuance of either provisional measures, a judgment enjoining further activity, remediation relief, or damages for causing environmental harm?
3.   What is the extent of responsibility and liability of States and non-State actors for violations of human rights and for environmental and climate harm caused by these oil and gas extraction techniques? 
4.   What is the extent of responsibility and liability of States and non-State actors, both legal and moral, for violations of the rights of nature related to environmental and climate harm caused by these unconventional oil and gas extraction techniques? 

The judges will likely spend several months reviewing the evidence and deliberating before issuing their opinion.

During the week of the Tribunal, attorneys, witnesses, and judges will convene via Zoom web conferencing software each day to hear evidence and testimony. The proceedings will be streamed on the Spring Creek Project Facebook page and in the OSU Student Experience Center. A full schedule of daily Tribunal proceedings will be posted on the Spring Creek Project website and on tribunalonfracking.org in advance of the Tribunal for those who wish to follow along.

Leading up to this session of the Permanent Peoples’ Tribunal, the Spring Creek Project is continuing to share the Bedrock Lectures on Human Rights and Climate Change, an online lecture series that invites artists, lawyers, scientists, writers, and activists to engage audiences in imagining how we can build communities in a world where environmental crises quickly become recognized as human rights crises. A new lecture is released each Wednesday by noon on YouTube, and screenings are held Wednesdays at noon in Bexell Hall 412 on the OSU campus. The final lecture will be presented on May 30.

On May 14, in the evening of the opening day of the Tribunal, celebrated writer and ecologist Sandra Steingraber, PhD, will deliver a keynote address at the Whiteside Theatre in downtown Corvallis at 7:00 p.m. Steingraber will share her personal experience with fracking along with scientific data to help us understand how environmental injustices are related to social injustices. The event is free and open to the public, though tickets are required. Attendees can reserve their tickets on Eventbrite.

By Ceal Smith - 

April 13, 2018

By Ceal Smith

Tuesday, March 6, 2018

Blasting Barriers to the AK Road to Renewables: an elegant solution

A major roadblock to moving Alaska's Railbelt electric grid forward on renewable energy has been the absence of cheap backup power required to match intermittent generation from solar and wind.

For example, the Regulatory Commission of Alaska (RCA) recently rejected a request from Fairbanks Golden Valley Electric Association to add more wind energy from Delta Junction on the basis that it was too costly.

Delta Wind claims that GVEA is demanding excessive fees, but according to Petroleum News:
The contentious issue of adding wind power to the Alaska Railbelt power transmission grid revolves around the cost of integrating the wind power into the system, the economic impact of displacing other power sources, and the environmental and cost stability benefits of adding wind power to the system. Wind power presents a challenge to an electricity utility, because the generated power fluctuates with the vagaries of the varying wind strength. That fluctuating power must be counterbalanced by equal and opposite fluctuations in some other power source, such as a gas or oil-fired power station. This regulation of the wind power costs money.In another recent case, RCA ordered Chugach Electric (also on the Railbelt) to withdraw its request to add more wind from Fire Island on similar grounds. 

In an OpEd last year, Robert Seitz, former chair of Alaska Section of the Institute of Electrical and Electronic Engineers, nailed the problem and need for a storage solution:
Before we shut off our hydrocarbon fuel supply and cheap electricity, we need to develop long-term energy storage means and mechanisms while we can still afford the development costs. This needs to become the focus of our long-term energy policy. Our power systems need to be looked at as systems, and not just as collection sources tied to the utility.Kerry Williams, a founding member of AK CAN! and Smart Energy Roadmap working group member has come up with an elegant solution that could blast the storage barrier to smithereens.  

In a nutshell, Kerry is proposing to expand the existing Eklutna Hydroelectric Power Plant by upgrading the two existing turbines and adding a series of new high-elevation storage reservoirs using excess solar and wind energy to pump water uphill.  In addition to lots of green jobs, cleaner air and eliminating the need for expensive fossil fuel, the project would restore the lake to historical levels, a big boost to efforts to bring anadromous salmon runs back to Eklutna Lake. 

You can read about the whole, wonderfully elegant idea here on the story-site created by intrepid Fat Bike explorer, founder of Alaskans Know Climate Change, film-maker and AK CAN! partner Bjorn Olson.   And check back.  The Eklutna Pumped Hydro Storage story-site is designed to evolve as this elegant proposal unfolds. 

###
Coming up next: an update on barriers to creating a Unified System Operator (USO) for Alaska's Railbelt grid also touched on by Robert Seitz and more recently by Tim Bradner in the Anchorage Press. 


By Ceal Smith - March 06, 2018