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Comment 2 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameTom
Last NameBecker
AffiliationT. Becker Power Systems
SubjectDraft 2022 Climate Change Scoping Plan

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.



Original File Name
Date and Time Comment Was Submitted 2022-05-11 11:24:15

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