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Comment 448 for Draft 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameThomas
Last NameMoran
SubjectImprovements Needed on 2022 Scoping Plan - 2030 Details, GHG to 2040, Zero-Carbon Grid

The Draft 2022 Climate Change Scoping Plan needs several improvements.

First: More detail is needed on meeting the 2030 goal, given the 2017 scoping plan's reliance on cap and trade and the current excess of allowances on the cap and trade system today. This is in 8 years and more specifics are needed on how California plans to meet this goal. 

Second: Greenhouse gas emission reductions modeling up to the year 2040 are needed; less reliance should be placed on carbon dioxide removal (CDR) than the current 25% target. Other states (Washington, New York) are aiming for 15% or less of their goal being achieved by CDR. We know as a planet & species CDR is needed (per IPCC reports), but as a leader California can do better. Other states are watching what California does and baking too much CDR into our plans increases our overall climate risk (it's a nascent technology). 

Third: The revised plan should include detailed modeling on a zero-carbon grid and what it should look like. California already has had days with 100% of electricity demand being met by renewables. Figuring out the details on this will be critical - energy storage (reducing curtailment), clean firm zero-carbon sources (e.g. nuclear, geothermal), and improved transmission to share the excess generation with neighboring states (versus curtailment) is critical. 

Fourth: Air pollution and air quality need to remain a factor and a priority. Disempowered communities are suffering from local plant pollution and this needs to be further regulated & reduced, not allowed to persist under cap and trade. 

California cannot skirt its critical role as a climate leader. From tailpipe emissions to electric vehicles to renewables, California is leading the states (and in some cases the world) on decarbonization for a large economy. More ambition and details are needed to achieve the ambitious goals California has set. 

Original File Name
Date and Time Comment Was Submitted 2022-06-22 12:15:45

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