Legal Issues
- The draft plan does
not demonstrate that California is on track to even meet the
legally mandated goal of at least a 40% reduction in greenhouse
gases by 2030.[2] Short-lived climate pollutants are particularly
unlikely to achieve a 40 percent reduction.
- The draft plan does
not follow AB 32’s requirement that California achieve
“the maximum technologically feasible” emission
reductions, using the most cost-effective
methods.[3] “Air board officials said they will propose the
option that has the least impact on the economy rather than
accelerating the pace of achieving carbon
neutrality.”[1]
Scientific Issues
- The draft plan will
not keep global temperatures close to what scientists say will
avoid catastrophe. The world has only ten years to cut greenhouse gas
emissions by 50 percent if we are to attain the goal. President
Biden has committed the United States to a 50 percent reduction by
2030. Yet the draft plan admits that it may not achieve even 40
percent by 2030.
- The science of climate
change requires front-loading our response. “If mitigation pathways are not
rapidly activated, much more expensive and complex adaptation
measures will have to be taken to avoid the impacts of higher
levels of global warming on the Earth
system.”[4]
- California’s
goal should be at least an 80 percent reduction in emissions by
2030. Prof. Daniel
Kammen, former coordinating author of the Intergovernmental Panel
on Climate Change and Professor of Sustainability at UC Berkeley,
set out a scientifically backed and feasible program for California
in 2021. It calls for an 80 percent reduction in emissions by
2030.[5]
- The draft plan only
aims for an 80 percent reduction in emissions by 2045. Even more
troubling, the draft’s reliance on carbon capture and
sequestration (CCS) or direct air capture of carbon (DAC) to reduce
20 percent of our emissions is more than New York (15
percent) and far more than the State of Washington (5 percent)
anticipates.[6]
- Neither CCS nor DAC
should be counted on as scalable. The March 28, 2022 IPCC report on the
capacity of different actions to reduce greenhouse
gases puts CCS as the least effective and most expensive of the 43
climate actions the IPCC evaluated for deployment prior to
2030.[7]
Environmental Justice Problems
- The draft plan drags
out elimination of pollution that disproportionately affects poor
people and people of color. But rapid
elimination of GHG pollution costs less than the health costs of
continuing pollution. [8]
- CARB’S Environmental Justice Advisory Council (EJAC), which
advises the CARB Board, has demanded faster and more comprehensive
measures than in the draft plan so as to protect disadvantaged
communities, particularly those suffering from air
pollution.[9]
Short-lived Climate Pollutants
(SLCPs)
- The draft scoping plan
recognizes the importance of SLCP abatement but not the importance
of moving very quickly.[10]
- Reduction of emissions
from HFC refrigerants having thousands of times more warming effect
than carbon dioxide must be greatly accelerated.[11]
- The draft plan expects
to reduce fugitive emissions of methane by 50 percent, but that
will not be enough to keep global warming to no more than
1.5°C.[12]
Cap and Trade
- Highly reputable
critics of California’s Cap and Trade program, our
market-based carbon pricing method, believe the program may not be
able to achieve even its limited emission reduction goal by
2030.[13]
- As a market-based
mechanism, the Cap and Trade program does not reduce major sources
of pollution fast enough. CARB should consider replacing parts of it by direct
regulation.[14]
[1] Nadia Lopez. Lower cost, slower gains: California
prepares controversial new climate strategy. CalMatters, April 28,
2022. https://calmatters.org/environment/2022/04/california-climate-change-strategy/
[2] See the critique of the plan by Danny Cullenward,
Ph.D.: https://carbonplan.org/blog/scoping-plan-comments
[3] “Air board officials said they will propose the
option that has the least impact on the economy rather than
accelerating the pace of achieving carbon neutrality.” Lopez,
Nadia. “Lower cost, slower gains: California prepares
controversial new climate strategy.” CalMatters, April 28,
2022. https://calmatters.org/environment/2022/04/california-climate-change-strategy/
[4] https://www.ipcc.ch/sr15/cross-chapter-boxes/
[5] Kammen, Daniel M., Teenie Matlock, Manuel Pastor,
David Pellow, Veerabhadran Ramanathan, Tom Steyer, Leah Stokes, and
Feliz Ventura. "Accelerating the timeline for climate action in
California." arXiv
preprint arXiv:2103.07801 (2021).
https://arxiv.org/abs/2103.07801?context=eess.SY
[6] Cullenward, op
cit.
[7] https://www.ipcc.ch/report/ar6/wg3/figures/summary-for-policymakers
[8]Wang, T., Jiang, Z., Zhao,
B. et al. Health co-benefits of achieving sustainable net-zero
greenhouse gas emissions in California. Nat Sustain 3,
597–605 (2020). https://doi.org/10.1038/s41893-020-0520-y.
[9] https://caleja.org/wp-content/uploads/2022/05/CARB-draft-plan-vs-EJ-recommendations-FINAL-CORRECTED.pdf
[10] Gabrielle Dreyfus, chief scientist for the Institute
for Governance & Sustainable Development and lead author of:
Dreyfus, Gabrielle B., Yangyang Xu, Drew T. Shindell, Durwood
Zaelke, and Veerabhadran Ramanathan. "Mitigating climate disruption
in time: A self-consistent approach for avoiding both near-term and
long-term global warming." Proceedings of the National Academy of Sciences of the
United States of America 119, no. 22 (2022):
e2123536119. https://www.pnas.org/doi/full/10.1073/pnas.2123536119. This article is the most current and comprehensive on the
forcing role of C02, SLCPs and aerosols.
[11] Daniel M. Kammen, et al., “Accelerating the timeline for climate action in
California,” March 2021, https://arxiv.org/abs/2103.07801
[12] Illissa B. Ocko, et al. "Acting rapidly to deploy
readily available methane mitigation measures by sector can
immediately slow global warming." Environmental Research Letters 16, no. 5 (2021): 054042. https://iopscience.iop.org/article/10.1088/1748-9326/abf9c8?addl_info=2021
The fastest way to slow warming
[13] https://calepa.ca.gov/2021-iemac-annual-report/
[14] https://calepa.ca.gov/wp-content/uploads/sites/6/2022/02/Comment_on_IEMAC_Report___CVAQC.a.pdf
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