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Comment 134 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameKyle
Last NameKrueger
SubjectComments on the Draft 2022 Climate Change Scoping Plan

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.


Original File Name
Date and Time Comment Was Submitted 2022-06-23 18:08:47

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