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Comment 478 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameCynthia
Last NameMahoney
SubjectPlan earlier targets, direct emissions reductions, account for ALL health benefits


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.




Cynthia Mahoney MD

Clinical Assoc Professor, Stanford ( RET)

757 Park Hill Rd

Danville, CA 94526








Original File Name
Date and Time Comment Was Submitted 2022-06-22 15:52:57

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