Comment on Climate Change Draft Scoping Plan
June 22, 2022
Dear CARB Board Members,
Thank you for the opportunity to comment on
the Draft Scoping Plan.
I appreciate all the hard work that has gone into the draft,
but CARB can and must do better.
The health harms are already here and now from
fossil fuel pollution, while climate change health impacts are
protean and escalating. The health harms of fossil fuels are
underweighted, while the health benefits of meeting emissions
reduction goals – which move far beyond simply reducing
pollution – are underappreciated and undervalued in this
plan. Health
benefits must be fully accounted for – including benefits not
only of pollution reduction and lowered climate impacts, but also
benefits of active transport and plant forward diets.
My main message: Prioritize rapid
near-term direct emissions reductions with earlier
targets. This must be the foundations of the plan. By 2030 stop gas appliance
sales, by 2035 stop sales of ICE. By 2035 phase out gas plants, oil
drilling. CA is not on track to meet its goals. With a backlog of banked
allowances and increasingly unreliable offsets.
The risks of CDR and CCS
shortfalls are not adequately addressed in the plan: not quantified
or planned for. Although the IPCC says that some
CDR will be necessary. it says clearly that the sole role for CDR
is compensating for emissions in difficult to abate sector, and
that it should not be relied upon to make up for foot dragging in
sectors where solutions readily exist (IPCC, 2022). Relying on
unproven, unscaled risky carbon removal is just too dangerous. It
is beyond foolhardy – it is catastrophic if you bet wrong. On
the other hand, If it
proves to be better than currently can be counted on, it can be
incorporated in future scoping plans. CDR also diverts capital
from the clean energy investment needs of now. The
increased energy intensity of using CCS and CDR are not fully
accounted and are likely to further harm EJ communities.
Biomass as a fuel source with CCS as
proposed is troubling on at least 3 counts. First, there is a time
phase discordance, as Jonathon Foley has elegantly described. CO2
is released now, while there is a lag for trees to grow enough to
store much carbon. Using agricultural land to grow biomass is
fraught – and could lead to food shortages and mass
unrest. This is
especially pertinent now as we see large swaths of agriculture
threatened by heat, drought and floods across the world. Lastly, the non-CO2
pollution released by biomass combustion – even if the CO2 is
captured – has prompted Major national public
health organizations including the American Lung Association, the
American Academy of Pediatrics, the National Environmental Health Association
and the National Association of City and County Health Officers
oppose biomass energy as a public health harm.
Sincerely,
Cynthia Mahoney MD
Clinical Assoc Professor, Stanford ( RET)
757 Park Hill Rd
Danville, CA 94526
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