The current draft
scoping plan is unacceptable because it does not seriously attempt
to determine pathways for meeting the state's legally-binding 2030
climate targets. CARB must present robust planning for all
statewide statutory targets, using proven technologies. Instead,
the current plan obfuscates the state's potential near-term
failures, while over-relying on unproven carbon dioxide removal
strategies in the long term. CARB should be prioritizing emissions
reductions in the near term, rather than postponing the bulk of the
work to the end of the study window, a strategy which creates
unacceptable risks of failure, and which allows for additional
emissions and additional warming during the interim
period.
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