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Comment 162 for Draft 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameIrena
Last NameAsmundson
SubjectConsistency Check Recommendations for Draft 2022 California Climate Change Scoping Plan

Dear California ARB staff,

Thank you for the comprehensive report laying out California's options to reach carbon neutrality by 2045 at the latest. We urgently need to work together if we are to have any hope of mitigating the effects on our state and catalyzing other economies to join our efforts. I am particularly encouraged by staff efforts to model additional sequestration efforts, as previous modeling that only focuses on emissions omits humanity's full impact on the carbon cycle.

However, there are two consistency checks that should be added before the Board makes its final decision: a flat/declining California population scenario, and the impact of this plan on a full inventory including embodied carbon of California consumption.

First, on the population, fewer people will lower emissions, but will also complicate efforts to transform our economy, with unknown net effects on the viability of the Scoping Plan Scenarios. The California Department of Finance has estimated that the state population shrank from July 2019 to July 2021. California single-family median home prices are at least twice the national price, and even before the pandemic one in five California households paid at least 50 percent of their income in housing costs. Jobs in the state are increasingly divided between highly-paid ones that require advanced degrees and that can be done remotely, and lower-paid ones that require long commutes every day. The Scoping Plan does include a massive expansion in housing, which makes it likely that the population will continue to decline. Much will depend on what is assumed about the population dynamics: will older homeowners sell and move out of state, allowing workers in the new industries to move in and broadening the tax base? Or will the state become increasingly skewed towards retired people who don't pay much in taxes? Staff should include a scenario to work through these issues and inform the public and the Board before making a decision.

Second, the report should include the impacts of embodied carbon in the carbon neutrality calculation, as California would severely undercount our carbon impacts if we continue to omit consumption but count sequestration. When working towards 1990 emissions, it was appropriate to focus purely on the emission side. But when working towards carbon neutrality, all impacts on the carbon cycle - positive and negative - need to be included. As the 5th largest economy in the world, the 40 million people in California consume much more per capita than India, which has a smaller GDP but 1.4 billion people. To identify problems that scale globally, we must include the embodied carbon of all the new electric vehicles and other goods we buy, even if they were produced elsewhere. This will make our path to carbon neutrality much more difficult, and likely makes a 2045 date more realistic. But if we are committed to the principle of leadership and doing our part, including embodied carbon is necessary.

Again, I thank the staff for their good work, and am available to answer any questions. Please note that these comments reflect my personal views, and do not represent the views of my employers past or present.


Irena Asmundson


Original File Name
Date and Time Comment Was Submitted 2022-06-23 21:13:20

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