My name is Kyle Krueger, and I am a recent graduate
from the University of California, Davis with a B.S. in
Environmental Science & Management. While I have great respect
for the hard work of the CARB Board, I write to recommend changes
to the Scoping Plan, as the current draft plan does not adequately
address the climate-related challenges facing my
generation.
Having recently served as the UC Davis Student Body
President, I know of many UC Davis students who have lost their
homes to increasingly severe wildfires or suffered from
California's worsening heatwaves. With climate change's
self-reinforcing positive feedback loops, these problems will only
continue to burden my generation more over time. As a global leader
in climate policy, CARB is in an incredible position to ambitiously
address the challenges that my generation has inherited. While the
current Climate Change Scoping Plan shows promise, it ultimately
does not adequately address the challenges facing my
generation.
First, several studies suggest that to limit global
temperature increases to 1.5 degree Celsius and prevent
environmental devastation, carbon neutrality is not enough.
'Negative emissions' must be achieved past carbon neutrality, with
technologies that capture or sequester carbon (such as carbon
capture and storage, direct air capture, and/or reforestation)
being used to achieve these 'negative emissions.'
I do not mean to discourage the deployment of safe
'negative emissions’ technologies, as such technologies will
be necessary for negative emissions. But according to several
models of carbon capture technologies, it will already be very
difficult for 'negative emissions' technologies to achieve the
necessary ‘negative emissions’ worldwide for reaching
the 1.5 degree Celsius target. Since 'negative
emissions' technologies such as CCS will already have their hands
full with achieving negative emissions, such technologies cannot
also be expected to reduce emissions toward baseline carbon
neutrality. Instead, the Scoping Plan should focus on direct
emissions reductions as a means of meeting the 2045 carbon
neutrality target, with 'negative emissions' technologies being
used only for additional carbon dioxide reductions past carbon
neutrality.
I recognize that CARB may not have the authority to
plan for 'negative emissions' in addition to reductions toward
carbon neutrality, as the executive order in question mandates only
the 2045 carbon neutrality target. I would address this by stating
that CARB is seen as a global leader in climate policy; as such, it
should lead the way in recognizing the need for 'negative
emissions.' Even if CARB does not yet have the statutory authority
to create a plan around these negative emissions, it must avoid
actively encouraging plans (such as the current Scoping Plan) that
incorporate 'negative emissions' technology as a means of reaching
baseline carbon neutrality.
I also recognize CARB's concern that it is not
possible to achieve carbon neutrality without some form of carbon
capture or direct air capture, as there will always be residual
emissions. However, I believe that such residual emissions can be
significantly reduced compared to what is outlined in the plan. For
example, rather than relegating cap-and-trade to a reduced role in
achieving negative emissions, CARB should instead be actively
addressing the flaws in its cap-and-trade program in order to
achieve greater emission reductions through the program. CARB can
do so by setting expiration dates for future cap-and-trade credits
and setting more stringent caps, among other changes.
Finally, though I do not claim to represent an
environmental justice organization, I hope that CARB actively
respects and uplifts the voices of environmental justice
organizations that serve underserved communities in California. A
scoping plan should not be passed without seriously addressing the
concerns that EJ organizations have with CCS safety and
cap-and-trade's local consequences, among other topics mentioned at
today's meeting.
Thank you for granting me the opportunity to make a
public comment. I recognize that I am writing to a panel of experts
who have admirably dedicated much of their life's work toward
climate-related topics, and I know that CARB shares my goal of
protecting the health and livelihood of future generations. I am
confident that CARB can make the necessary changes to its Scoping
Plan to serve as a leader in guiding the state, and the world,
toward a safer and healthier future.
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