Randolph and CARB Board Members,
Please see our summary comments below
and full version attached.
Environmental Council (CEC), founded in 1970, has worked for over
50 years to pioneer environmental solutions in California. For the
last 15 years we have focused on building on-the-ground momentum to
reverse the threat of the climate crisis, working most closely in
Ventura, Santa Barbara, and San Luis Obispo counties. Our programs
work across energy, transportation, and buildings to mitigate
carbon emissions, sequester carbon in natural and working lands,
advance environmental justice, and build climate resilient
generally supportive of the Draft 2022 Scoping Plan and
California’s goal to reach carbon neutrality by 2035, but
finds the alternatives analysis as overly conservative. It does not
reflect the ability of zero emission technologies to scale more
quickly. It also does not reflect the potentially long and risky
high fossil fuel price environment we are now in due to Russian oil
and gas being shunned. The Climate Crisis is urgent and California
has the ability to move markets, lead the world toward climate
stability, and reap the benefits of the new clean energy economy.
CEC urges CARB to update modeling and accelerate actions to reach
Carbon Neutrality by 2035 through the following scenarios:
should model a scenario of a standard of 100% ZEV sales by 2030.
This is needed to achieve California’s 40% reduction in GHGs
by 2030 goal, and rapidly reduce GHG emissions in the
transportation sector and lead to an earlier feasible date of
- CARB should model accelerated
building electrification targets. Rather than all new appliances
being sold be zero emissions by 2035 for residential and for 2045
commercial, CARB should model 100% zero emission appliances by 2030
for residential and 2035 for commercial.
should model accelerated renewable and zero carbon electricity
procurement in line with SB 1020 (Laird), which sets a target of
90% by 2035, 95% by 2040, and 100% by 2045.
should install a technical advisory committee comprised of Natural
and Working Lands (NWL) experts in order to inform modelling
the actual sequestration potential of California’s NWL. NWL
carbon sequestration should be prioritized over Carbon Capture and
- CARB’s reliance on
Carbon Capture and Storage instead of more rapid phase-out of
fossil fuel extraction and production continues to place undue
burdens on environmental justice communities.
Please see the full