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Comment 427 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameChristopher
Last NameLish
SubjectCalifornia Needs a Better Climate Plan -- Draft 2022 Climate Change Scoping Plan

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.

Christopher Lish
San Rafael, CA

Original File Name
Date and Time Comment Was Submitted 2022-06-22 10:32:42

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

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