May 30,
2022
California
Air Resources Board
1001 I
Street
Sacramento,
CA 95814
RE: CARB Proposed
Advanced Clean Cars II Regulations – OPPOSE;
Dear CARB,
Thank you for the
opportunity to make a written comment on the CARB Proposed Advanced
Clean Cars II Regulations.
I am writing this letter in OPPOSITION to the Proposed
Advanced Clean Cars II Regulations and include my comments in
opposition to the overall CARB 2022 Scoping Plan Update dated May
10, 2022 that is being reviewed for future adoption after the
appropriate periods of comment as required by
regulations.
With these proposals CARB is on track to adopt major
regulations over the next few months that have the potential to
drive businesses out of California, result in job losses, increase
the cost of living, and spiked energy prices.
I am part of the
larger business community that has deep concerns with CARB's
proposed 2022 Climate Change Scoping Plan of which the Advanced
Clean Cars II Regulations are part of. The result of the adoption of these regulations
will have far reaching impacts upon on all Californians, dictating
how they must run their businesses, what cars they can drive, where
they can live, and what stove they can cook with. Life as we know
it in California will be altered going forward.
Some of the
major implications for businesses and individuals in California,
include:
• Increasing costs to businesses, especially
agricultural and transportation sectors.
• Employment/Jobs –
despite a growing population, these policies will cost California
over 85,000 jobs.
• Higher utility costs disproportionately impacting
inland and rural communities.
• Eliminating consumer choice by mandating electric
vehicles, appliances, residential, and commercial
buildings.
• Worsening our electric grid reliability by pushing
electrification without infrastructure in place, thus increasing
the likelihood power outages
RE: CARB Proposed Advanced Clean Cars II
Regulations – OPPOSE
I believe these implications
cannot be overstated and in support of this I refer to the
following opening statements in the CARB Draft 2022 Scoping Plan
Update dated May 10, 2022 and its Executive Summary (Note the draft
summary is 277 pages long). I have highlighted the statements that I
believe point to the lack of a comprehensive energy and climate
policy that should include ALL the best technologies and best
practices available now and, in the future, and to consider that
there will be improvements to our existing technologies that will
make them very viable as part of a truly comprehensive solution
that can realistically be sustained. I remind my fellow Californians that the
fossil fuel industry is part of the energy solution that has made
the United States of America the greatest nation in the world and
one that I believe we all take for granted. This industry has
required huge amounts of investment capital and manpower to build
and sustain.
Any consideration of change
in energy policy of this magnitude must include an “ALL
available technologies” and “best practices”
approach as well as a thorough evaluation and consideration of
national security implications.
Executive
Summary
The 2022 Scoping Plan, once
final, will be a major milestone, laying out how the fifth largest
economy in the world can get to carbon neutrality by 2045 or
earlier. This is the first Scoping Plan that adds carbon neutrality
as a science-based guide and touchstone beyond statutorily
established emission reduction targets. It identifies a
technologically feasible, cost-effective and equity-focused path to
achieve carbon neutrality by 2045, or earlier, while also assessing
the progress the state is making toward reducing its greenhouse gas
(GHG) emissions by at least 40 percent below 1990 levels by 2030,
as called for in SB 32 and laid out in the 2017 Scoping Plan.1
Previous plans focused on specific GHG reduction targets for our
industrial, energy, and transportation sectors—to meet 1990
levels by 2020, and then the more aggressive 40 percent below that
for the 2030 target. Carbon neutrality takes it one step further by
expanding actions to capture and store carbon including through
natural and working lands and mechanical technologies, while
drastically reducing anthropogenic sources of carbon pollution at
the same time. What this means for California is an ambitious and
aggressive approach to squeezing the carbon out of every sector of
the economy, setting us on course for a more equitable and
sustainable future in the face of the greatest existential threat
we face, and ensuring that those who benefit from this
transformation include those communities now hardest hit by the
ongoing use of fossil fuels. The combustion of these fuels has polluted
our air, particularly in low-income communities and communities of
color, for far too long, and is the root cause of climate
change. This Draft Scoping Plan helps us chart the path to a
future where race is no longer a predictor of disproportionate
burdens from harmful air pollution and climate impacts.
RE: CARB Proposed Advanced Clean Cars II
Regulations – OPPOSE;
The major element of this unprecedented
transformation is the aggressive reduction of fossil fuels wherever
they are currently used in California, building on and accelerating
carbon reduction programs that have been in place here for a decade
and a half. That means rapidly moving to zero-emission
transportation, electrifying the cars, buses, trains, and trucks
that now constitute California’s single largest source of
planet-warming pollution. It also means phasing out the use of
fossil gas used for heating our homes and buildings. It means
clamping down on chemicals and refrigerants that are thousands of
times more powerful at trapping heat than carbon dioxide (CO2).
It means
providing our communities with sustainable options for walking,
biking, and public transit so that people do not have to rely on a
car. It means continuing to build out the solar arrays, wind
turbine capacity, and other resources that provide clean, renewable
energy to displace fossil-fuel fired electrical generation.
It also means scaling up new options such as green hydrogen2 for
hard to electrify end uses and renewable gas where needed.
It seems to me in reading
this proposal that the “electric vehicle” has been
christened the industry of choice to succeed the fossil fuel
powered internal combustion engine. Many of the statements of facts I believe are
very subjective and would ask if we have indeed considered all the
costs of moving to this scenario as outlined in the draft
proposal? California
is currently and for some time now unable to provide for and
sustain its own electrical grid. I remind my fellow citizens that
electricy must be produced and generated by another source or many
sources. Many of
these sources are under attack because they do not meet the current
thinking of “the science.” Again I would submit we need to use ALL of the
resources that we have at our disposal to generate the energy that
a growing and prosperous state needs.
Have we really considered
the actual cost of this unprecedented approach? “an ambitious and
aggressive approach to squeezing the carbon out of every sector of
the economy, setting us on course for a more equitable and
sustainable future in the face of the greatest existential threat
we face, and ensuring that those who benefit from this
transformation include those communities now hardest hit by the
ongoing use of fossil fuels.”
Who decided this is the
greatest existential threat we face? California will be impacted by the almost
complete removal of fossil fuels as one of the main providers of
energy for our state if it is not done carefully and with a more
thoughtful approach.
I believe the fossil fuel industry is meeting the challenge
to produce new products that will meet the requirements of a more
clean energy. We do
not need to throw out this technology and form of energy to succeed
in our goals for a prosperous and clean California.
RE: CARB Proposed Advanced Clean Cars II
Regulations – OPPOSE;
Has the true life-cycle of
CO2 emissions really been calculated properly?
1.
Vehicle production which
includes CO2 emissions released during all vehicle stages of
production processes.
a.
This would include the
extraction of raw materials and include the final vehicle
assembly.
b.
Where will we get the raw
materials from?
This has national security implications.
c.
This includes the production
of the truck and the large lithium-ion battery.
2.
Energy production and
consumption which includes CO2 emissions released during the
production of energy (e.g. the production of electricity at a power
plant, or the refining of diesel fuel or gasoline from crude
oil).
a.
This would include the CO2
emissions from fuel consumption of the internal combustion
engine.
3.
Vehicle disposal and
recycling which includes emissions related to the disposal of or
recycling of the truck and all its related parts which would
include the recycling of any lithium-ion batteries or other
technologies to power the vehicle.
a.
Is there a method to
completely recycle a lithium-ion battery now or will some of this
end up in a landfill?
Good question.
You have been appointed as
the gatekeepers for these regulations but you serve every
Californian which means you have a huge responsibility to get this
correct and look thoroughly at every aspect, not to pick winners
and losers. I
respectfully request you give careful consideration to the issues I
have raised in my comments.
We look forward to a prosperous California in which all
stakeholders are fairly represented and all technologies are given
an equitable opportunity to participate in the marketplace of ideas
and commerce.
Thank you for your
consideration.
Respectfully,
Jeffrey M. Roe
President
Roe Oil Company, Inc.
Cc:file