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Comment 158 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameMichael
Last NameChiacos
AffiliationCommunity Environmental Council
SubjectUpdate Modeling to Reach Carbon Neutrality by 2035 Using the Following Scenarios

Dear Chair Randolph and CARB Board Members, 

Please see our summary comments below and full version attached.

The Community 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 communities. 

CEC is 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: 

  • CARB 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 carbon neutrality. 
  • 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. 
  • CARB 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. 
  • CARB should install a technical advisory committee comprised of Natural and Working Lands (NWL) experts in order to inform modelling that captures the actual sequestration potential of California’s NWL. NWL carbon sequestration should be prioritized over Carbon Capture and Storage. 

  • 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 comments attached.


Original File NameCEC Comments on CARB draft 2022 Scoping Plan Final.pdf
Date and Time Comment Was Submitted 2022-06-16 16:51:43

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.

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