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Comment 248 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameDavid
Last NameThompson
SubjectInput to Draft Climate Change Scoping Plan (submitted 5/11/22)
The following identifies the many problems and inadequacies of the Draft Climate Change Scoping Plan that was submitted on May 11, 2022.
Legal Issues
  1. The draft plan does not demonstrate that California is on track to even meet the legally mandated goal of at least a 40% reduction in greenhouse gases by 2030.

  2. The draft plan does not follow AB 32’s requirement that California achieve “the maximum technologically feasible” emission reductions, using the most cost-effective methods.

Scientific Issues
  1. The draft plan will not keep global temperatures close to what scientists say will avoid catastrophe.

  2. The science of climate change requires front-loading our response.

  3. California’s goal should be at least an 80 percent reduction in emissions by 2030.

  4. The draft plan only aims for an 80 percent reduction in emissions by 2045.

  5. Neither CCS nor DAC should be counted on as scalable.

Environmental Justice Problems
  1. The draft plan drags out elimination of pollution that disproportionately affects poor people and people of color.

  2. CARB’S Environmental Justice Advisory Council (EJAC), which advises the CARB Board, has demanded faster and more comprehensive measures than in the draft plan so as to protect disadvantaged communities, particularly those suffering from air pollution.

Short-lived Climate Pollutants (SLCPs)
  1. The draft scoping plan recognizes the importance of SLCP abatement but not the importance of moving very quickly.

  2. Reduction of emissions from HFC refrigerants having thousands of times more warming effect than carbon dioxide must be greatly accelerated.

  3. The draft plan expects to reduce fugitive emissions of methane by 50 percent, but that will not be enough to keep global warming to no more than 1.5°C.

Cap and Trade

  1. Highly reputable critics of California’s Cap and Trade program, our market-based carbon pricing method, believe the program may not be able to achieve even its limited emission reduction goal by 2030.

  2. As a market-based mechanism, the Cap and Trade program does not reduce major sources of pollution fast enough.


These issues must be corrected in the final, approved Plan.

Original File Name
Date and Time Comment Was Submitted 2022-06-24 12:21:39

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