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Comment 75 for Draft Proposed First Update to the Climate Change Scoping Plan (proposed-sp-ws) - 1st Workshop.


First Name: Jim
Last Name: Stewart
Email Address: jim@EarthDayLA.org
Affiliation: Earth Day Los Angeles

Subject: Set higher GHG reduction targets for 2020, 2030 and beyond
Comment:
Earth Day Los Angeles appreciates the opportunity to provide these
comments to the California Air Resources Board on the Climate
Change Scoping Plan First Update Draft dated February 2014. We
endorse the Sierra Club comments submitted November 1, 2013, on
ARB’s Discussion Draft AB 32 Scoping Plan Update, which has many
details on our main points below.

1.  New GHG targets.  We urge ARB to initiate a state process to
set more aggressive California greenhouse-gas reduction targets for
2020, 2030 and beyond.  ARB should recognize that Governor’s
Executive Order S-3-05 is no longer adequate, and a new state
trajectory should be mandated, through a new process that is
informed by the latest climate science, including IPCC’s new
urgency and new methane GHG values.  Stabilization of greenhouse
gas emissions at 450 ppm and targets of less than 2ºC increase are
insufficient to minimize the risk of catastrophic outcomes.

“Climate impacts accompanying global warming of 2ºC or more would
be highly deleterious. Already there are numerous indications of
substantial effects in response to warming of the past few decades.
That warming has brought global temperature close to if not
slightly above the prior range of the Holocene. We conclude that an
appropriate target would be to keep global temperature at a level
within or close to the Holocene range. Global warming of 2ºC would
be well outside the Holocene range and far into the dangerous
range.” Hansen, J., et al., PLOS ONE, 8, e81468 (2013).
  
We believe it is technically possible and economically feasible by
2030 to cut GHG emissions from the electric sector by 80% over 1990
levels and from the transportation sector by 50%.  

2.  Higher RPS.  We urge ARB to call upon CPUC to increase the
state’s Renewable Portfolio Standard (RPS) to 40% by 2020 and set a
2030 standard at 70%.  We believe a pathway is possible to achieve
these targets using only available and feasible current
technologies.  An open public process should develop
sector-by-sector near-term and medium-term targets.  New RPS
targets should have substantial carve-outs for distributed
renewable energy systems, far beyond the governor’s goal of 12 GW. 


3.  Total Decarbonization by 2050. We recommend that ARB formulate
the state’s ultimate 2050 target as total elimination of GHG from
the electrical and transportation sectors.  We believe that even
this may not be sufficient to moderate climate disruption to safer
levels and avoid catastrophic outcomes, and we recognize the need
also for serious work to remove substantial amounts of
anthropogenic carbon already in the atmosphere.

4.  New Utility Model.  We recommend that ARB and other state
agencies begin to examine and develop a New Utility Business Model
as well as a New Regulatory Model.   The traditional utility
business model was developed many decades ago for industrial-scale,
central-station, one-way flow, primarily fossil-fuel energy and is
no longer suited to advanced, emerging renewable technologies, new
flexible information flows, carbon reduction exigencies, and new
economic and consumption conditions.  

5.  No More Big Gas-Fueled Plants. We urge ARB to urge all agencies
to stand firm against any more new, major gas-fired generation
capacity in California.  Climate targets will not accommodate more
dirty fossil-fueled electricity.  There is now a sufficient array
of clean alternatives to integrate rapidly growing quantities of
renewables without more gas power plants, either baseload or
peakers, particularly if market penetration of the full span of
possibilities of decentralized power is facilitated by the
agencies.  (Some new, highly efficient combined heat-and-power
could be the exception to getting off gas.) 

6. Clean Transportation. The Draft Scoping Plan Update does a good
job of laying out the challenge and need to achieve and extend
movement toward zero and near-zero vehicles. We are glad the plan
recognizes that the Clean Air Act requires NOx reductions on the
order of 90% below 2010 levels to meet 2032 ozone requirements in
South Coast and San Joaquin Valley, which will necessitate much
greater use of ZEVs. 

We also appreciate the proposal to advance the use of zero and
near-zero vehicles in the freight sector. However, planning must
assure a sufficiently comprehensive charging infrastructure to
support not just the initial ZEVs but also eventually a mostly-ZEV
fleet.

However, the draft Scoping Plan’s transportation discussion falls
short in a number of areas. Although the Transportation Working
Paper, page 36, states, “ARB will assess the role of natural gas in
the low-carbon transportation fuel future,” the plan appears to
advocate for increasing dependence on natural gas as a fuel source,
when it states on p. 55, “A heavy-duty vehicle Phase 2 standard, …
Under these standards, natural gas (NG) trucks will likely be
deployed in large numbers.”  This makes no sense given that natural
gas extraction throughout the country, especially through fracking
technologies, is linked to high levels of methane leakage, making
the climate impacts of natural gas much worse than diesel.
Additionally, developing a larger natural gas infrastructure to
fuel vehicles will drain investment from truly clean vehicle fuels
and infrastructure.

Additionally, the state has in the past played a stronger, greater
role in helping ensure effective mass transit within cities,
especially through funding incentives and other methods. The
Scoping Plan should discuss ways in which the state can help
accelerate mass transit development and improve existing mass
transit operations.

Important market mechanisms can be advanced by new regulations,
laws and incentives, such as road use fees, appropriately adjusted
for differing emissions levels of vehicles. We appreciate the
mention of parking cash out (in the Transportation Working Paper,
page 23), but unbundling the pricing of parking is also an
important option. The scoping plan should note this and offer
recommendations that encourage the use of reasonable pricing
mechanisms.

The Scoping Plan should also note that in certain cases, modal
shifts may be the best route to accelerating emissions reductions
in the freight sector.

Finally, the ARB must set much higher targets for MPO VMT
reductions required under SB 375, so that they at least meet the
requirements of Executive Order S-3-05.  An example of the current
ARB targets being too low is shown in the case of the San Diego
Association of Governments (SANDAG). ARB required only 13%
reduction, which was exactly what SANDAG requested (and which would
allow all of their planned freeway expansions). However, the
California Attorney General sued SANDAG, and the judge found that
the EIR for the SANDAG transportation plan was “impermissibly
dismissive of S-3-05.”  We request the next set of targets be
transparently calculated to show how each of the regional
transportation plans will meet at least the requirements of S-3-05,
and hopefully the higher standard required by the latest climate
science.

Attachment: www.arb.ca.gov/lists/com-attach/83-proposed-sp-ws-Wj8GZAdqU2FRNARr.docx

Original File Name: EDLAComments on CARB 2014 Scoping PlanUpdateJim3.docx

Date and Time Comment Was Submitted: 2014-04-28 16:31:50



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