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Comment 24 for Draft 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameRhoads
Last NameStephenson
SubjectComments of 2022 Scoping Plan

Comments on 2022 Draft Scoping Plan                                                          5/24/22

1.     You should extend the comment period to at least two weeks after the public meeting.

2.     Update technical basis to IPCC-AR6.  There are three working group reports.

3.     Include goals for every five years:  2025, 2030, 2035, 2040, 2045, and 2050

4.     Add “ocean acidification” and “sea level rise” to section on “Severity of Climate Change Impacts”

5.     Run scenarios for higher carbon fees - $100/ton;  $200/ton

6.     Use Social Cost of Carbon estimates using a 1 percent discount rate.  Climate is a multigenerational problem and we should not discount-away the impacts on our children and grandchildren.

7.     There are other negative emissions technologies besides CCS and DAC.  See NAS report at:

8.     Please add a scenario to get to 50% by 2030;

9.     Please add a scenario to get to net zero by 2040.

10.                        All non-natural carbon removal techniques should be limited to 10% of emissions.

11.                        Encourage Community Solar.


1.     Does this document actually mandate any action by State agencies, counties, cities or individuals?

2.     How do you account for products that are produced outside the State and imported into the State? (Cement, steel, electricity, other consumer products, etc.

3.     Same question for exports.

4.     Does California have any steel plants?

5.     Are Bloom boxes counted as a “combustion” source?  How many MWe of Bloom boxes are in the State? How will they be replaced when we phase-out NG?

6.     Purpose of scoping plan?

a.     Which actions can be taken with existing legislation? 

b.     Which actions require new legislation?

c.      Which actions require a CEQA EIR to move forward?  What is the schedule for starting and finishing each required EIR?

d.     Have you identified a lead State agency for each of the actions?



Typos and minor comments:

1.     PDF page 17.   Change “a” to “as”  …direct air capture.

2.     Figure 2-5 is hard to read.  It has four shades of blue that are hard to distinguish.

3.     Figure 1-1 is mislabeled.  It is percent change not total emissions.


Original File Name
Date and Time Comment Was Submitted 2022-05-24 12:38:04

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