Danny Cullenward

@ghgpolicy.org

13722 Followers 1664 Following

Forensic climate economist and lawyer • The carbon accounting canary in your climate policy coal mine • https://ghgpolicy.org

"The administrative penalties imposed on a reporting entity shall not exceed five hundred thousand dollars ($500,000) in a reporting year."
From my resignation letter: "After manipulating the Board’s decision-making process on forest carbon accounting and withholding the technical working group documents from the public for more than a year, the Protocol is now planning an extended public comment period on issues that have already been delegated to a secret, industry-dominated drafting process. I again reiterate my request that the Protocol publish all documents from the forest carbon accounting technical working group, all related complaints and official responses, all pilot testing results evaluating the industry proposal, and any written agreement(s) documenting the Protocol’s working relationship with the ISO that may exist."
Text too long; see machine-readable PDF at this link: https://ghgpolicy.org/s/2026-06-08-Cullenward-resignation.pdf
But thanks to oil lobbyists, California will make accessible up to 118 million free pollution passes to industrial polluters. This is the same amount that CARB has stated needs to be taken off the market to meet our 2030 emission reduction goals. If this proposal passes as is, California risks missing our 2030 emission reduction target, which is mandated by legislative statute—all to give more free passes to fossil fuel companies. Because these corporations get to pollute for free, they won't have to buy as many allowances at the auction. Recent analysis from UC Santa Barbara projects this backdoor giveaway will drain $4 billion in state revenue over the next four years. That means slashing $2.3 billion from the GGRF and cutting the California Climate Credit’s direct electricity rebates by $1.7 billion—a massive 17% cut across the board. Defunding these programs means some of the world’s richest, dirtiest companies get a discount on their pollution while shifting the financial burden directly onto working families. Nobody is stepping in to cover this $4 billion shortfall. If CARB allows this fund to be gutted, our communities will immediately lose vital funding for:
So many bottles of hot sauce, where to even begin
Sustainable Aviation Fuel The Budget includes a tax credit against diesel excise tax liability to incentivize the in-state production of sustainable aviation fuel, a lower-carbon alternative to petroleum-based jet fuel. This investment advances California's climate and air quality goals by reducing emissions from the aviation sector, one of the most difficult sources to decarbonize, while supporting innovation and private investment in clean transportation fuels.
Recommendation Reject Proposed Tax Credit. We recommend the Legislature reject the proposed budget trailer legislation establishing a credit against diesel excise tax revenue for sale of SAF in California. The proposal appears to be a relatively expensive approach to reducing GHGs and may not result in the full anticipated environmental benefits. Moreover, the implementation of the proposed tax credit could have negative implications for transportation funding—potentially even larger than those estimated by the administration—and would not be consistent with the spirit of voter‑approved restrictions on the use of diesel tax revenues.
Not entirely satisfactory email evidence of my $100 donation BUT IT'S ALL I GOT because the ACH network is stuck in the stone age and thank you for reading
A sign on a restaurant in Calgary that was closed for renovations that hits the Canadian linguistic trifecta (please, thanks, and sorry) all in service of one single message.
ye old-timey photo of the Standard Oil refinery in El Segundo, c1920 and perched on the otherwise-picturesque bluffs of southern California, care of the wonder of contemporary civilization that is Wikipedia https://en.wikipedia.org/wiki/El_Segundo,_California#/media/File:StandardOil1920.jpg
1940s Dave checkin’ out 2020s Dave
Ray from Achewood dancing to Toto’s Africa. That’s it. That’s the gag.
"Tim [Wayne] has worked on hundreds of campaigns for clients like Gavin Newsom, … "
Under Section 1.45V-4(d)(2)(iv)(G), a qualifying cap-and-trade program is one that: "(G) Generally ensures that the cap on greenhouse gas emissions cannot be exceeded for less than $90 per metric ton of CO2e, adjusted for inflation from 2025 dollars using at a minimum the most recently available twelve-month value of the CPI-U, as published by the BLS."
Bar chart showing the maximum conventional hydrogen that could qualify for the 45V tax credit using methane offsets, assuming blending. About 35 million tpa could be produced, primarily from fugitive fossil methane emissions but also from landfills, manure, and wastewater.
The Environmental Defense Fund's "About us" page: "Guided by science and economics, and committed to climate justice, we work in the places, on the projects and with the people that can make the biggest difference."
Screenshot of paper title and summary info: Improved assessment of baseline and additionality for forest carbon crediting Nina A. Randazzo, Doria R. Gordon, Steven P. Hamburg First published: 08 February 2023 https://doi.org/10.1002/eap.2817 Handling Editor: Mingkai Jiang Funding information: Bezos Earth Fund
Figuring showing the rapid increase in renewable diesel consumption driven almost entirely by California, which consumption reaching nearly 30 million barrels per year in 2021. US production in 2021 was substantially smaller at over 20 million barrels, primarily from states other than California. Source https://www.eia.gov/todayinenergy/detail.php?id=57180
Screen shot of @nature.com.web.brid.gy Reading "Nature is the foremost international weekly scientific journal in the world and is the flagship journal for Nature Portfolio. It publishes the finest ..."
With a vote on the proposed LFCS regulations scheduled a few days after the presidential election in November 2024, California’s climate regulator is looking to finalize the future of the LCFS program in advance of upcoming discussions about the potential reform and extension of the state’s economy-wide cap-and-trade program. This sequencing has important implications for the ambition of the cap-and-trade program, which is likely to be politically constrained by consumer price impacts that are directly affected by the LCFS program, as well as for who stands to benefit from state climate finance. By updating the LCFS program ahead of the cap-and-trade program, the state climate regulator is effectively privileging the LCFS program’s beneficiaries—primarily biofuel producers—above the current and potential future beneficiaries of state funding collected from auctioning allowances in the cap-and-trade program.
"With a vote on the proposed LFCS regulations scheduled a few days after the presidential election in November 2024, California’s climate regulator is looking to finalize the future of the LCFS program in advance of upcoming discussions about the potential reform and extension of the state’s economy-wide cap-and-trade program. This sequencing has important implications for the ambition of the cap-and-trade program, which is likely to be politically constrained by consumer price impacts that are directly affected by the LCFS program, as well as for who stands to benefit from state climate finance. By updating the LCFS program ahead of the cap-and-trade program, the state climate regulator is effectively privileging the LCFS program’s beneficiaries—primarily biofuel producers—above the current and potential future beneficiaries of state funding collected from auctioning allowances in the cap-and-trade program."
Quote from CARB Board Chair Liane Randolph: the Low Carbon Fuel Standard “is one of California’s most significant and most effective climate programs. It’s a market program that comes with a mandate to fuel producers to reduce their carbon intensity over time.”
Brown submitted his second wildfire study to Nature earlier this year, acknowledging last year’s incident in his submission only to be turned down. Other prestigious journals, including Science, The Proceedings of the National Academy of Sciences, and Science Advances, didn’t want it either, Brown said. Currently, the paper is in peer-review at Environmental Research Letters, which Brown describes as “not a high-impact journal but a decent outlet.” He’s waiting to hear back.
"12. Between 2021 and 2023, the primary way CQC obtained VCUs was through its Cookstove Projects registered with Issuer-1. KENNETH NEWCOMBE, the defendant, was on the Board of Directors of Issuer-1 and, ni or about 2020, he proposed that Issuer-1 adopt a new methodology for calculating emission reductions from cookstove-related projects (the "Cookstove Methodology"). NEWCOMBE was in favor of the Cookstove Methodology because he believed ti would allow CQC to generate more VCUs than existing methodologies."
"Before coming to the United States, he was CEO of the Papua New Guinea Power Utility and Founding Head of Energy Planning for PNG. As an intrapreneur in the World Bank, Ken led the World Banks pilot phase of the Global Environment Facility which established the basis for one billion a year permanent GEF to support the incremental costs of aligning investment decisions with externalities of global environmental change and pioneered the investment portfolio of the Multilateral Fund of the Montreal Protocol to phase our ozone-depleting substances. He established the Forest Market Transformation Initiative which led to the launch of the leading NGO Forest Trends and its Ecosystem Marketplace and the successful Global Alliance for Forest Conservation and Sustainable use with the World Wildlife Fund."
In which I seek information about how to invest in the bitcoins
Quote from a book: "Realism about the scale of the challenge is often discouraged in climate policy circles because it is easy to confuse with pessimism."
Three Spiders-man pointing at one another; but which one is the REAL Spiderman?
Article 2 of the 2015 Paris Agreement, which reads: "Holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels, recognizing that this would significantly reduce the risks and impacts of climate change;"
Block quote of text from Washington Post oped linked in post, comparing hydrogen subsidy lock-in risks to the environmental and fiscal disaster that is US ethanol policy.
Among those options for managing climate risk, the ethical, technical, environmental, and governance questions that accompany solar radiation management are unique. “Because solar geoengineering and carbon removal have little in common, we will have a better chance to craft sensible policy if we treat them separately,” Keith wrote. Keith is now in charge of a program that not only, in a sense, lumps the two technologies together, but also throws in a few others for good measure. “I do feel there’s some level of crow eating because I spent a lot of time arguing how totally separate they are—I’ve even done that in congressional testimony. Now I’m running something that does both,” Keith said. “A lot of people I respect have been lumping them forever. And so sometimes you have to listen to people.” https://thebulletin.org/2024/06/the-university-of-chicago-new-climate-initiative/
Figure showing how units of recycled content are transferred between co-products of plastic pyrolysis to assign all of the recycled content to individual products in order to facilitate marketing statements about their percentage of recycled plastic content.
Quote from end of this story: https://www.alleghenyfront.org/cnx-plan-to-turn-mine-gas-into-jet-fuel-a-win-win-or-carbon-accounting-gimmick/
Screen shot of the title of a book chapter from Dyson and Marland, don't ask me how I found it, I have no idea, either. https://babel.hathitrust.org/cgi/pt?id=uc1.31822016268419&view=1up&seq=2&skin=2021
Screen shot of the title of Dyson (1976), https://doi.org/10.1016/0360-5442(77)90033-0
Broken glasses scene from the Twilight Zone’s Time Enough At Last
"It is unlawful for a person to market, make available or offer for sale, or sell a voluntary carbon offset without explicitly marketing the voluntary carbon offset as not being physically equivalent to the climate impact of carbon dioxide emissions, unless it is reasonably expected [to have a durability of at least 1000 years]."
Unofficial vote for SB 1036, with 27 yes votes, 5 no votes, and 8 members not voting at this time.
A still frame of the famous Simpsons monorail episode, in which Lisa asks con man Lyle Lanley why Springfield should build a mass transit system in a small town with a centralized population.
A table showing the minimum share of electricity procurement that must be clean to earn a green power label from EPA, starting with a 50% requirement for the smallest entities and falling to just 7% for the largest entities.
“Unfortunately, it doesn’t include impacts from hydrogen, which itself is an indirect greenhouse gas that contributed to global warming.”
Final two paragraphs from Canary Media article, https://www.canarymedia.com/articles/food-and-farms/californias-biofuel-bias-is-hampering-its-ev-future-can-that-change
NYT: "Leon Schipper, Physicist and Iconoclast, Dies at 64"
"Drax has told BBC Panorama that the 2017 document is "now obsolete" and that its current policy and practices are "more sophisticated"." — from https://www.bbc.com/news/science-environment-68381160
From the Heatmap story: "However, Governor Gavin Newsom did not include any funding for the law in his budget proposal this year, creating concern that it will be delayed."
Selection of Miami Herald story reporting the gas utility's push to remove consumer protections from SB 480, see https://www.miamiherald.com/news/local/environment/climate-change/article285251917.html
Text available on page 14 of this PDF: https://www.flsenate.gov/Session/Bill/2024/480/Analyses/2024s00480.pre.fp.PDF
"After a utility's transmission and distribution storm protection plan has been approved, proceeding with actions to implement the plan shall not constitute or be evidence of imprudence."
Text available here https://www.flsenate.gov/Session/Bill/2024/480/BillText/c1/HTML
The saga of the 45V credits, however, highlights the challenges of attempting to build major climate policy on emissions accounting rules developed for individual, project level analysis. … Achieving these goals using any policy instrument - subsidies, taxes, or regulation - will generate large relative price changes between dirty and clean technologies, driving changes in production and consumption behavior across the economy. In the absence of economy-wide carbon pricing or regulation, these responses will act to undermine policy effectiveness and confound emissions reduction goals. We should take away two main lessons: design of major U.S. climate policy cannot rest on project-level lifecycle emissions accounting that omits partial and general equilibrium responses; and economy-wide carbon pricing or regulation directly addressing the unpriced externalities from greenhouse gas emissinos is likely to be an essential complement to the technology-focused policies of the IRA.
From CARB: "The California Air Resources Board (CARB or Board) is postponing the previously scheduled March 21, 2024 public hearing to consider amendments to the Low Carbon Fuel Standard (LCFS) until a later date. Staff continues to receive substantial feedback on the proposed regulatory package and is postponing the March hearing to enable additional discussion and re-evaluation of the carbon intensity benchmarks, including the proposed step-down and auto-acceleration mechanism, as well as more consideration of the proposed sustainability guardrails, among other topics. Staff plans to host a workshop in mid-April 2024 to discuss potential refinements to the proposed regulatory amendments. The 45-day public comment period, which began on January 5, 2024, and which is scheduled to close on February 20, 2024, will not be extended."
A graph showing the percentage of methane offsets required to achieve the emissions performance required to earn the top tier of the hydrogen production tax credit, based on the CO2 abatement rate. If a project captures 90% of its CO2 emissions, it needs about 4% methane offsets to qualify; and even if a project doesn't capture any CO2 emissions, it needs only about 25% methane offsets.
Text describing the overlapping individuals who have worked for TNC and the Government of Palau, from the main story link.
Table 4 from GREET H2 documentation, showing SMR-CC at 3.4 kgCO2e/kgH2 WTG with 96% CO2 capture and 1% CH4 leakage. At 2% leakaage, the carbon intensity rises to 4.5 kgCO2e/kgH2 WTG and falls short of the statutory 45V eligibility limit.
Projected costs of California's climate plan, showing gross costs of emission reductions of a few billion dollars per year (not including any benefits) and the costs of carbon removal from direct air capture at up to nearly $30 billion per year.
Lawrence Livermore Lab Foundation "Roads to Removal" report acknowledgments thanking Climateworks, Breakthrough Energy, and the Grantham Foundation.
"Earlier this summer, Duffy visited Sacramento with his wife and met with former colleagues socially, he said. During his tenure Duffy championed CARB’s staff scientists. In an email to colleagues announcing his retirement in April 2022, Duffy wrote that CARB’s fuel scientists were “the experts” on the LCFS, and they should not cede responsibility “to those who know less and have spent much less time thinking about the issues,” including “stakeholders, consultants, academics, CARB upper management and Board.”"