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Comment 215 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameMartha
Last NameWalden
Affiliation350 Humboldt
Subjectstrategies to achieve SB 32 emissions reductions


In lieu of a comprehensive critique of the draft Scoping Plan--I know you've read hundreds of them--I would like to advocate for strategies to help the state achieve its 2030 emissions reduction goal, which I believe is much more pressing than the goal of carbon neutrality by 2045.

Considering that a significant overestimation of the sequestration capacity of California's land use practices has gravely compromised the targets of the Scoping Plan, it's essential to reform those practices. Surely California can put its natural resources to better use by enhancing sequestration. Though using the offset market for incentives to preserve forest makes theoretical sense, the actual practice hasn't been an efficient or effective approach--partially because of fraud and partially because of the prevalence of wildfire. How to achieve sequestration despite wildfire is crucial. Many foresters now agree that prescription burning and other fuels reduction measures are misguided in many instances. Cal Fire could save a lot of money and actually reduce emissions by managing wildfires to protect communities instead of ineffectively burning the woods first or logging them.

Much of the acreage consumed by fire still sequesters a lot of carbon. Instead of acting as if all those trees are wasted wood if someone doesn't cut them down, post-fire logging should be limited and carefully focused. The disaster of wildfire heals faster than that of opportunistic logging.

A related issue is that of biomass electricity. Why burn wood deliberately? Incinerating wood emits carbon much more efficiently than a wildfire. It also emits SLCPs such as black carbon and methane, not to mention other air pollutants, yet California perversely subsidizes this practice by designating biomass incineration as "carbon neutral". The justification for this designation expired a few decades ago. Our local utility here in Humboldt county receives valuable points from the state for purchasing electricity from an antiquated biomass facility. Its owner, a local sawmill, has zero incentive to do something less carbon-intensive with its wood waste. Emerging technologies, such as gasification or nano-cellulose, don't have a chance because it's much easier to treat the atmosphere as a disposal ground. Composting, a tried and true method, is also too much trouble, according to the mentality of business as usual.

Thanks to the official designation of biomass as carbon neutral, forests are clear-cut in many places, chipped, and shipped to boilers all over the world to replace coal. California's endorsement of this practice contributes to a major, tragic step in the opposite direction of where we urgently need to go.

California has already recognized the crucial importance of short lived climate pollutants with its passage of SB 1383, but that law has weak points. Effectively reducing SLCPs seems essential to fulfill SB 32 and to limit catastrophic climate change. The SLCP in biggest need of more attention is hydrofluorocarbon, a chemical company creation that traps an astronomic amount of heat in the atmosphere--up to two thousand times more than carbon. SB 1206, a bill currently under consideration, has been watered down so much by the legislature that it hardly surpasses the federal Aim Act, which is woefully inadequate.

To drastically summarize what my colleagues at 350 Humboldt have said in their comment on the Scoping Plan, the SB 1383 target of reducing HFCs forty percent below 2014 levels will not make nearly enough difference. A variety of vigorous, strategic measures are necessary to get this situation under control in a world that is warming and turning increasingly to coolants.

These are the three primary threats. End of life disposal treatment for appliances that contain HFCs. Supermarket and grocery store refrigeration that is legally permitted to leak up to 25% of its refrigerant load every year. The proliferation of air conditioning and heat pumps, which leak less than commercial refrigeration but still pose a big problem just in terms of their sheer growing numbers.

1) California should educate and license an army of technicians to fan out around the world to recover HFCs from dead appliances. The use of offset credits might aid in this effort. The F-gas offsets comply more clearly to the necessary criteria to count and document the prevented emissions.

2) Financial incentives are needed to help grocery stores transition to low GWP refrigerants. The chemical companies' anointed HFOs are probably useful--especially if they're drop-ins or don't require extensive retrofitting of existing equipment--as a bridge to the natural refrigerants, which are ultimately much cheaper after the upfront cost of new equipment. The European Union and Japan have been successfully marketing equipment that uses natural refrigerants--propane, ammonia, and carbon dioxide--and can serve as a useful model for US markets. Underwriters Laboratory codes for regulatory compliance must be reformed and building codes as well.

3) Air conditioners and heat pumps require concerted attention--from the manner of their disposal to their replacement by equipment that uses natural refrigerants. New air conditioners that use propane are already widely in use in different parts of the world. Heat pumps that use carbon dioxide have also been invented but are very expensive right now. That situation will change more quickly if the manufacturers get the proper nudge from government.

Thank you for reading my thoughts about California's crucial course for the next five years. I do take some hope from the knowledge that I'm not alone in my opinions. Of course, I don't have to read all of them like you do!


Martha Walden

Editor of 350 Humboldt LookOut

Original File Name
Date and Time Comment Was Submitted 2022-06-24 10:42:54

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