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Comment 232 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameRaymond
Last NamePaulson
AffiliationCalifornia Resident and USA Citizen
SubjectGlobal Warming - Make Excessive Co2(e) 7th Criteria Pollutant with Standards

Global Warming - Make Excessive Co2(e) 7th Criteria Pollutant with Standards

The current USA Federal Clean Air Act requires EPA to set for six common air pollutants known as "criteria" air pollution. These pollutants are found all over the U.S. and primarily come from fossil combustion from automobiles. They can harm your health and the environment, and cause property damage. 

The six criteria air pollutants include particle pollution, ground-level ozone, carbon monoxide, sulfur dioxide, nitrogen dioxide, and lead.  EPA has set National Ambient Air Quality Standards (NAAQA) as baseline to enact laws and regulations to address through the state and local agencies given to meet the required standard.  California has enacted even more stringent ambient air quality standards for criteria pollution with associated laws and regulations.  

Another potential criteria pollutant that is causing harm and damage to human health, the environment and property is excessive Carbon Dioxide and the Equivalent Co2(e) from a warming planet (global warming).  Co2 (e) includes Carbon Dioxide (79% global warming contribution), Methane (CH4) (11%), Nitrous Oxide (N2O) (7%) and Fluorinated Gases (3%). Co2 (e) should be included as the seventh criteria pollutant with subsequent laws and regulations to allow society to transition to other technology in steps in a strategic economic plan.  Fossil fuel combustion, refrigerants and landfill gases are the primary sources of these global warming gases.

Carbon Dioxide sources are Transportation 33%, Electricity (31%), Industry (16%), Residential and Commercial (12%) and Non Fossil Fuel Combustion (8%).  There is also an available breakdown for the other gases that contribute to global warming. 

The Center for Biological Diversity and have formally petitioned the EPA to declare carbon dioxide (CO2) a “criteria” pollutant under the Clean Air Act, and to set a national pollution cap for CO2 at no greater than 350 parts per million (ppm).

This comment is to the state of California. Will the responsible parties in California government enact legislation and policy to assign Co2(e) as a “Criteria” Air Pollutant with goal to reduce Co2 concentration to the no greater than 350 parts per million (ppm) using updated California Ambient Air Quality Standards in feasible steps?   And to use Life Cycle Sustainability Analysis (includes considering the negative costs of a warming planet e.g. fire, flood, sea rise and more), consideration of the environment safe to live in, robust economy and quality of life to put together a strategic plan and subsequent legislation to meet this needed  goal to Save Our Planet (SOP).  If California does not lead then who? When? Where?   

The good news is that through efficiency technology the cost savings can be used to fund renewable energy sources and renewable energy storage to build an economy better than ever.  However, policy and standards are needed at this time to reach the goal before it is too late.  Will California Act? Acting now is paramount because the greenhouse gas concentrations are going up annually and the planet and the people cannot afford to go beyond a 1.5 degree Celsius increase stemming from man-made Co2(e) air emissions becoming a pollutant because of the concentrations being above the healthy limit of 350 ppm.  The only other option is to face devastating consequences at costs too high to calculate. 


Original File NameComments State California.docx
Date and Time Comment Was Submitted 2022-06-24 11:49:14

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