Thursday, May 31, 2018

AK CAN! draft comment to CALT

Submitted electronically to: 

June 4, 2018

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 Clear
Aside 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.              ADAPTATION
a.     Food security
b.     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.     Monitoring
1.     Increase availability & use of technology
a.     Mapping
b.     Bathymetry
c.     Climate modeling
                                          vii.     Scenario and risk assessment
d.     Governance
                                               i.     Coordinate and empower local, regional, Tribal, state and federal efforts
1.     Recognize local rights to self-determination
2.     Empower and increase capacity of communities
3.     Strengthen municipal government collaboration & coordination
                                             ii.     Update statutes
1.     AK Disaster Policy sub-cabinet
e.     Funding
                                               i.     Private, philanthropic, state, federal, international
                                             ii.     Climate change emergency relief fund
II.            MITIGATION (decarbonization)
a.     Incentivize energy efficiency, renewable energy and electrification (local, municipal, Borough and state levels)
                                               i.     Increase state-led financing
1.     Carbon pricing
a.     Carbon fee and dividend
b.     Steadily increasing fee imposed at the source
2.     Green bank
3.     Invest energy efficiency savings into renewable energy
4.     Direct capital expenditures
5.     State endowments
                                             ii.     Incentivize private investment
1.     Venture capital funds
2.     Reinsurance
b.     Incentivize more efficient, cleaner fossil fuel development
c.     Carbon capture, use and sequestration
d.     Fund carbon offsets to compensate for emissions

I.              ADAPTATION

a.     Food security
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 4.1D: 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]. 


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 

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 3.1C: 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 pricing
Goal 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 Resources
Goal 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 future
GOAL 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 technology
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. 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]: 
Cost/kW (@190/kWh)[66]
Tesla S
75kW (350 volt)
310 miles

Tesla, Model 3
220 miles
$  9,500

Tesla, Model 3
75kW (350 volt)
310 miles

1957 Ford Fairlane[67]
120 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 Storage
Integration 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 assessed
Fossil 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.

Goal 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.


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

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:  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.


Ceal Smith
on behalf of AK CAN! partners and members

Bjørn Olson, Director of Advocacy, Kachemak Bay Conservation Society's Alaskans Know Climate Change Education Campaign, Homer
Scott Gruhn, AK CAN!, Anchorage
Eric Schaetzle, AK CAN!, Fairbanks
Elisa Russ, Citizens Climate Lobby, Homer, AK Chapter
Danielle Redmond, Renewable Juneau Coordinator, Juneau
Shonah Stone, AK CAN!, Anchorage
Alfredo Bolivar, AK CAN!,
Gretchen Keiser, AK CAN!, Juneau
Andy Romanoff & Elaine Schroeder, 350Juneau, Juneau
Jan Bronson, AK CAN!, Anchorage
Libby Roderick, AK CAN!, Anchorage, Owner, Turtle Island Records
Marybeth Holleman, Author, Anchorage

Post 6.4.18 submission signatores:

Sandy Harper, AK CAN!, Producing Artistic Director Emeritus, Anchorage
Tim Lyons, AK CAN!, Girdwood

[1] Hobson & King.  Trump's 'energy dominance' transforms Alaska's future.  E&E News, Energywire: November 15, 2017.
[2] Alaska Acts on Climate.  Living on Earth.  PRI.
[3] Brad Plummer, The New York Times. “Impossible to Ignore’: Why Alaska Is Crafting a Plan to Fight Climate Change.  May 15, 2018.
[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.
[6] Shell’s vision of a zero-carbon world by 2070 explained.
[7] 2020 The Climate Turning Point.
[8] Inside Climate News.  Global C02 emission to hit record high in 2017.
[9] No Drop in US Carbon Footprint Expected through 2050, Energy Department says.
[10] Three years to safeguard our climate, Nature Comment.!/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).
[12] Jakob Michael & Hilaire, Jerome.  Climate Science: Unburnable fossil-fuel reserves.  Nature, letters.
[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.
[14] Michaeleen Doucleff. NPR Morning Addition. 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.
[17] US Government Accountability Office (GAO) GAO-09-551.
[18] Yoder, Sarah, MS. Assessment of the Potential Health Impacts from Climate Change in Alaska. Jan 8, 2018.
[19] Ibid. Appendix 3: Potential Health Impacts of Climate Change, by Climate Change Factor.
[20] Denise Fairchild & Al Weinrub.  Energy Democracy.  Island Press.
[21] Burke, JM and Stephens, JC. Energy democracy: Goals and policy instruments sociotechnical transitions. Energy Research and Social Science. 2017.
[23] Alaska Grown Source Book.
[24] Adaptation Action Areas, Adaptive Management of Fish & Game.
[25] Alaska Native Subsistence: A matter of cultural survival.
[26] Wilson Justin.  Email communication with AK CAN members.  May 2018.
[27] Local Environmental Observer Network (LEO).

[29] Joe Vigil. LNG pipeline project by the numbers.  KTVA. Nov 20, 2017.

[30] Elwood Brehmer. Alaska Journal of Commerce. FERC sets Dec 2019 as deadline for AK LNG review. March 14, 2018.
[31] Acting on Climate Change: Solutions from Canadian Scholars.

[32] McGhee & Reich. Here’s How States and Cities Can Fight Climate Change and Inequality in the Trump Era. The Nation.

[33] Pacific Coast Collaborative.
[34] United States Climate Alliance.

[35] EPA. Sources of Greenhouse Gas Emissions.

[36] Robin Brena. Alaska needs to reclaim its fair share of oil revenue. Alaska Daily News. Oct 1, 2016
[37] What is the Anthropocene and Are We in It?

[38] Ground Truth Trekking. Oil Tax Credits: What are they, and why are they a problem?

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

14 November 2016.
[40] Alaska Climate Action Network petition to APFC Trustees.

[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.

[47] Oil Change International Report, Off Track.
[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.
[49] Jules Kortenhorst and Mark Dyson.  The Medium.  Clean energy will do to gas what gas has done to coal.  May 30, 2018.
[50] RMI Report: Positive Disruption: Limiting Global Temperature Rise to well below 2 degrees.
[51] RMI 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.
[53] Low Carbon Fuel Standard.
[54] Goldman Sachs. Transition to a low-carbon economy.
[55] Goldman Sachs.  Transition to a Low-Carbon Economy.
[56] Hawken, Paul, Ed. Drawdown: 100 Solutions to Global Warming.
[57] EPA Section 608 regulations.

[59] Alaska Renewable Energy Atlas.

[60] Germany Breaks A Solar Record — Gets 85% Of Electricity from Renewables.
[61] Living on Earth. Alaska Acts on Climate.

[62] 100% Renewable Electricity Worldwide Is A New Cost-Effective Reality.
[63]Data Iceland Utility Touts Cheap Clean Energy to Lure Data Centers.
[64] 100% Renewable Alaska.
[65] Luke John Smith. Express News. Tesla Model 3 details revealed – Battery pack size, horsepower and more.
[66] Ibid
[67] Fred Lambert.  A classic 1957 Ford Fairlane with a 50kWh battery pack.  Electrek. March 14, 2018.
[69] 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.
[71] An Alaska case study: energy storage technologies (2017).
[72] An elegant proposal to transform Alaska’s Railbelt to 100% renewable energy:
[74] Alaskans Know Climate Change. 100% Renewable Alaska. An elegant proposal to transform Alaska’s Railbelt to 100% renewable energy.
[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.
[77] Walker, Raynolds, et al., Eds.  Landscape and permafrost changes in the Prudhoe Bay Oil Field, Alaska. Alaska Geobotany Center.
[78] Drilling and Spilling on Alaska’s North Slope.
[79] Alaska Greenhouse Gas Emissions Inventory 1990-2015 Alaska Department of Environmental Conservation, Division of Air Quality January 30, 2018.
[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:

[82] International Energy Agency.  Commentary: The environmental case for natural gas.

[83] Exxon Mobile. ExxonMobil Announces Greenhouse Gas Reduction Measures.

[84] Bonding changes proposed, Petroleum News:
[85] The Rising Cost of Cleaning Up After Oil and Gas.
[86] Reclamation Costs and Regulation of Oil and Gas Development with Application to Wyoming.
[87] Alaska orders review of all North Slope oil wells after spill linked to permafrost.
[88] Landscape and Permafrost changes in the Prudhoe Bay Oil Fields.
[89] Yoder, Sarah, MS. Assessment of the Potential Health Impacts from Climate Change in Alaska. Jan 8, 2018.
[90] Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2016: Abandoned Oil and Gas Wells, April 2018.
[91] Steiner, Bisig et al.  Diesel exhaust: current knowledge of adverse effects and underlying cellular mechanisms.
[92] Wong, N.J. Existing scientific literature on setback distances from oil and gas development sites (June 2017).
[93] North Slope Oil Well Suffers a Blowout:
[94] Natural gas leak in Cook Inlet Stopped, Effects on Marine Life Not Yet Known (April 2017):

[95] 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.
[97] Graham Readfearn. WHO launches health review after microplastics found in 90% of bottled Water.  The Guardian.
[98] Nelms, Galloway et al., Investigating microplastic tropic transfer in marine top predators.  Environmental Pollution. Vol 238, July 2018.
[99] High levels of microplastics found in Northwest Atlantic fish.  Science Daily.  Feb 16, 2018.
[100] Damian Carrington.  Microplastic pollution in oceans is far worse than feared, say scientists.  The Guardian. March 12, 2018.
[103] Stahel, WR. The circular economy. Nature.  March 23, 2016.
[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.
[106] Hawkens, et al, Eds. Drawdown.
[108] EPA link to Alaska Peat inventory:
[109] Rapid deglacial and early Holocene expansion of peatlands in Alaska:
[111] Mammoth on Vimeo:

[112] Pleistocene Park an experiment in adventure:


[115] Michelle Horton.  New Stanford study suggests climate mitigation could yield trillions in economic benefits.


Update on the AKCAN investigation into Alaska oil and gas emissions

A recent Alaska Institute for Climate & Energy investigation of oil and gas industry emissions revealed that industry is flaring or vent...