Wednesday, June 22, 2022
Clerks’ Office
California Air
Resources Board
1001 I Street
Sacramento, California
95814
Subject: California Needs a Better Climate
Plan -- Draft 2022 Climate Change Scoping Plan
To Governor Gavin Newsom, California Air
Resources Board Chair Liane M. Randolph, and CARB board
members:
I strongly urge you to revise the California
Air Resources Board’s climate scoping plan so that it meets
the scale and urgency of the climate crisis and environmental
racism here in California. As currently drafted, it’s an
abdication of climate leadership and a failure of ambition.
Climate delay is climate denial. So first and
foremost, the plan must ensure near-zero carbon emissions by 2035,
which would represent the accelerated progress Governor Newsom has
called for many times. Disappointingly, the draft 2022 Scoping Plan
recommends a path that delays achieving carbon neutrality until
2045. It requires little to no immediate action to reduce climate
pollution and relies on expensive and unproven technology to meet
its emission reduction targets. The path laid out in the Scoping
Plan will perpetuate fossil fuel production and continue to harm
California’s most vulnerable communities and ecosystems.
Retaining the grossly inadequate target of “carbon
neutrality” by 2045 is a recipe for disaster, enabling
further delay we can’t afford.
Likewise, the proposed timelines for ending
fossil fuel energy and electrifying transportation and buildings
are inadequate, as they’re based on a flawed cost-benefit
analysis that severely underestimates the costs of delaying rapid
decarbonization and relies on unproven, risky technologies such as
carbon capture and storage.
The California Air Resources Board modeled
four scenarios, or “alternatives,” and every
alternative modeled projects building new gas plant capacity,
including the “no combustion” Alternative 1.
CARB’s preferred pathway, Alternative 3, proposes to build 10
GW of new gas capacity, equivalent to at least 33 new mid-size or
100 peaker gas power plants. Continuing to rely on existing fossil
fuel infrastructure makes mitigating the negative effects of
climate change more and more difficult. Gas plants emit many
dangerous pollutants, and the majority of California’s
gas-fired power plants are located in or adjacent to disadvantaged
communities.
Further, the Draft does not propose the early
retirement of heavy-duty combustion vehicles, nor would it require
100% sales of heavy duty zero emission vehicles until 2040. Without
early retirement and an earlier 100% zero emission sales target,
California will leave millions of tons of NOx and carbon
emission reductions on the table.
Additionally, instead of promoting greater
investment in renewable energy resources and avoiding emissions
entirely, CARB’s plan relies extensively on the unproven
technology of carbon capture, usage, and sequestration (CCUS),
which environmental justice advocates have voiced concerns about
for years.
Instead, a revised plan must commit to:
1. a full, coordinated phase-out of fossil
fuels, with targets for ending oil and gas extraction, and a clean,
just electric grid by 2030;
2.
scaling up investments in mass transit and
accelerating electrification of transportation and buildings,
including 100% electric-vehicle sales by 2030, and no new gas
appliance sales by 2025; and
3.
eliminating reliance on climate policy
dead-ends like carbon capture and sequestration.
We already possess the technology and
resources to accelerate the transition away from fossil fuel energy
in a way that addresses environmental injustice, doesn’t
leave workers behind, and provides tremendous benefits to our
state’s economy. But the draft plan would prolong frontline
communities’ exposure to fossil fuel pollution for decades,
allow climate inaction with industry scams and unproven
techno-fantasies, forgo the many benefits of a rapid shift to
renewable energy, and keep us on a deadly path to climate
collapse.
I would also like to offer the following
suggestions to strengthen the natural working lands targets to
better reflect the importance of California’s coastal
habitats. Our state has felt firsthand the effects of intensifying
wildfires, record heat waves, and severe droughts, making
nature-based solutions that harness coastal wetlands’
carbon-absorbing properties a crucial element to advance emission
reduction goals.
Specifically, I ask CARB to:
* Endorse the draft plan’s
recommendation to restore at least 60,000 acres of the
Sacramento-San Joaquin Delta to reduce emissions, restart carbon
burial, and provide flood mitigation, water quality, and
biodiversity benefits to the region and state.
* Include an acreage target and related
management strategies for ALL of the state’s coastal
wetlands, including San Francisco Bay, Eel River Estuary, and
Humboldt Bay, and the sloughs and pocket estuaries found along the
central and south coasts.
* Improve accounting for coastal wetlands,
including tidal marsh, scrub-shrub, swamps, and seagrass, in the
state’s Natural and Working Lands greenhouse gas inventory,
drawing upon established U.N. Intergovernmental Panel on Climate
Change methodologies for these habitats. And collaborate with state
agencies and research institutions to incorporate newly released
and existing localized data sets into the inventory.
California has lost an estimated 90% of its
wetlands after decades of diking, draining, dredging, damming,
development, and other impacts. And eelgrass has faced extensive
loss in the state because of excess sedimentation resulting from
land use practices, pollution, and direct impacts from coastal
infrastructure. Morro Bay, site of a National Estuary Program, has
experienced a massive die-off in eelgrass habitat, with declines of
more than 90% since 2007. Sea level rise will accelerate this loss
if eelgrass beds, tidal marsh, and other coastal habitats are
unable to migrate shoreward.
These losses harm wildlife and people alike.
Coastal wetlands sustain resource- and recreation-dependent coastal
people and economies, protect cultural resources, improve water
quality, and reduce flooding. And the climate benefit of coastal
wetlands can have a flipside—their destruction releases this
stored carbon back into the atmosphere.
I applaud CARB for developing the draft 2022
Climate Change Scoping Plan and formally recognizing the role of
natural and working lands in this plan. I urge you not to miss the
opportunity to protect and expand the state’s blue carbon
sinks by including strong measures for ALL of the state’s
coastal wetlands. I’m also counting on you to demonstrate
true climate leadership to the world by fixing the scoping plan and
accelerating our path to near-zero carbon emissions to 2035, at the
latest.
Thank you for your consideration of my
comments. Please do NOT add my name to your mailing list. I will
learn about future developments on this issue from other
sources.
Sincerely,
Christopher Lish
San
Rafael, CA