This is the first of 2 comment letters I will be submitting on
the Draft 2022 Climate Change Scoping Plan.
I request CARB staff reply to the following itemized comments,
as required by CEQA and all applicable state and federal statutes,
rules and regulations pertaining to response to public
comments.
1A1) Any motor vehicle emission and/or fuel mileage standard
proposed by the state under the state's U.S EPA emission waiver
must be demonstrated by the state to be "needed" by the state to
meet federal air quality standards.
2A2) The state does not "need" to reduce motor vehicle emissions
beyond the standards set during the Trump Administration to meet
federal air quality standards.
3A3) The state must demonstrate that it has exhausted all other
emission reduction options available to the state before the state
can impose motor vehicle emission standards stricter that U.S EPA
standards.
4A4) The state can meet federal air quality standards by
reducing VMT in the state by 50% from a 2014 baseline by 2040. This
VMT reduction eliminates the "need" for the motor vehicle emission
standards proposed in both this Plan and the Clean Car II
regulation.
5A5) It would be a violation of federal law if the state
implemented motor vehicle emission standards that are stricter than
federal standards if the state failed to implement a 50% VMT
reducing strategy in lieu of stricter motor vehicle emission
standards.
6A6) As part of the proposed Draft 2022 Climate Change Plan, the
State should implement a 50% VMT reduction from a 2014 baseline by
2040, instead of the proposed 22% reduction from a 2019
baseline.