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Comment 173 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameShannon
Last NameFiume
Subjectincentivize net-zero as soon as possible in new scoping

Shall we leave a restored planet, or one perilously hot by our likely death late this century?

We need California to recalibrate high climate ambition and seek net-zero CO₂ emissions as soon as possible while keeping in line with the Kigali Amendment. We need the majority of California’s, the US's, and the World’s power to be from renewables, carbon-free energy storage, and have a carbon intensity of 0. The UNFCCC/IPCC, IEA, Energy Innovation, and Ember show we need to hit 100% clean energy by 2035 to keep 1.5ºC possible. (,,,

Is it not the realm of policy to incentivize the best-desired outcome? While these report a good start: 100% clean electric grid by 2035, we should go further and track faster to net-zero to save off the worst exacerbated effects of climate change such as drought, wildfire, wind erosion, local pollution, sea-level change, ocean acidification, and reduced fisheries, not to mention heat domes and ever-increasing new record-breaking mega-storms.
Not only should we achieve this faster, but we should export clean energy and deploy any additional infrastructure and capacity to neighboring states, countries, and the developing world. All this increased capacity and deployment will, like Germany did for solar, push renewables further down the cost curve enabling more deployment.

How can this be done?

Create policies to incentivize a dramatically lower cost for renewables and grid storage, and keep the Solar PV deployments YoY above 35% till 2030. The ideal is to have a 100% fossil fuel-free grid, transportation, and industry to reach net-zero emissions by 2031 (or sooner). Upgrade energy infrastructure connections to allow the export of clean energy to neighboring states and Mexico. Do everything in Rewiring America’s plan to incentivize durable goods replacement to lower the electricity burden and reduce the direct use of fossil fuels: heat pumps, induction, LEDs, EVs, and electrified mass transit. Add more policies that incentivize nature-based solutions and regenerative agriculture. Stop methane leaks. Stop all new permitting of the new expansion of fossil fuels. Phase out all fossil fuel subsidies in the next couple of years. Stop and remove fossil fuel from California state-run investments such as Calpers.
Incentivize the clean/electric version or carbon mineralization technology for any business that operates in California.
 Analyze and create ratching agreements to progressively increase overall emissions reductions and incentivizes a 100% clean grid by 2030.

 Given the current political climate for the US and abroad, which in 2020 granted the fossil fuel industry over 5.9T USD in subsidies, per the IMF:, and estimated for 2022 the oil and gas industry is projected to have profits exceeding 1.75 T USD, there ought to be funds that can be moved from fossil subsidies and allow for more renewable deployments and increase overall capacity. (See The additional income expected for the oil and gas industry in 2022 would be enough to fund nearly a decade of investment in low emissions fuels and CCUS under the NZE Scenario, Gas Market Report, p107, Q2-2022, IEA) 

And why go faster than 100% fully electric by 2035 and faster than net-zero by 2050?

Post COP26, the world is on track for 2ºC, with the negotiated ambition to reach 1.8ºC by 2100.
To enable keeping 1.5ºC a plausible forecast for 2100, the next ten years are critical that we do everything necessary to reach zero emissions globally. To avoid tipping points, the carbon budget: the amount of emission left to burn is radically curtailed, so we reach net-zero by 2031. To have the possibility to do better than 1.5ºC and reach a temperature similar to the 1900s (.2ºC about 300ppm) or even 1750 (0ºC and about 280 ppm), seeking the fastest path to zero emissions in the next ten years is paramount. Since 1750 over 2.5 trillion tonnes of human-caused CO₂ have accumulated and spread between the atmosphere, oceans, and land. (Global Carbon Budget 2021, This anthropogenic debt will continue to hold temperatures above pre-industrial until the CO₂ is mineralized or stored. Given the quantity that should be removed and scaled fossil-free carbon removal infrastructure doesn't exist, the best and most prudent path is to sharply limit emissions with clean energy while preferencing renewables, then use DAC and mineralization or otherwise store the CO₂ and go net negative. There is simply too much existing CO₂ pushing up beyond 420ppm to use negative emissions and continue to expand fossil or even delay reductions. Additionally, global temperature appears to have an impulse before responding to a drop in emissions. Given a hypothetical removal beyond reaching net-zero in 2025, the temperature didn't have a corresponding drop until 2029.

We ought to do everything to safeguard our future and not just hold the status quo.

Please refer to this comment as a guide in drafting new scoping plans to radically curtail emissions in this critical decade.


Shannon A. Fiume

Original File Name
Date and Time Comment Was Submitted 2022-06-23 23:27:34

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