The California Air Resources Board ("ARB") published a Concept Paper on May 7, 2015, proposing initial strategies for reducing emissions of short-lived climate pollutants ("SLCPs"). SB 605, signed into law by Governor Jerry Brown on September 21, 2014, directs ARB to develop a comprehensive strategy by January 1, 2016, for reducing SLCP emissions. SLCPs are agents with a relatively shorter lifetime in the atmosphere but a greater warming influence than carbon dioxide.

ARB's Concept Paper identifies three categories of SLCPs—methane, black carbon (particulate matter from combustion sources), and fluorinated gases—that ARB estimates may be responsible for up to 40 percent of global warming to date. The Concept Paper contains "initial ideas" for reducing SLCP emissions. ARB will publish an initial draft Strategy and hold public discussion forums in the summer of 2015, and it will present a draft Strategy to the Board during the fall of 2015.

In developing the SLCP strategy, ARB will consider, for example, how to reduce methane emissions from California's natural gas infrastructure and agricultural sector (particularly dairies), eliminate the disposal of organic material in landfills, and expand the use of wastewater treatment facilities to recapture renewable natural gas and soil amendments. Regarding black carbon, ARB will look to expand upon ongoing programs for reducing diesel particulate matter emissions in the freight transportation and other sectors, and black carbon emissions from burning biomass (such as wood stoves, agricultural wastes, and wild fires). ARB will consider regulations limiting or prohibiting the use of high-global-warming-potential fluorinated gases from new refrigeration and air conditioning units, insulating foams, and aerosols, and for reducing leaks from current and end-of-life units.

ARB also is moving toward readoption of the Low Carbon Fuel Standard ("LCFS"). In Poet, LLC v. ARB (2013), the California Court of Appeals ordered ARB to correct deficiencies in the rulemaking process and readopt the LCFS. ARB published a proposed regulation readopting the LCFS in December 2014 and an amended version in June 2015. The amendments would, among other things, streamline the process for recertification of certain fuel pathways previously certified under the original regulation and remove certain limitations on the sale or transfer of LCFS credits. ARB will hold a public hearing on the proposed amended regulation on September 24, 2015.

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