| Comment | The following identifies the many problems and
inadequacies of the Draft Climate Change Scoping Plan that was
submitted on May 11, 2022.
Legal Issues
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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.
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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
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The draft plan
will not keep global temperatures close to what scientists say will
avoid catastrophe.
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The science of
climate change requires front-loading our response.
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California’s goal should be at least an 80 percent
reduction in emissions by 2030.
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The draft plan
only aims for an 80 percent reduction in emissions by
2045.
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Neither CCS nor
DAC should be counted on as scalable.
Environmental Justice Problems
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The draft plan
drags out elimination of pollution that disproportionately affects
poor people and people of color.
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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)
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The draft scoping
plan recognizes the importance of SLCP abatement but not the
importance of moving very quickly.
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Reduction of
emissions from HFC refrigerants having thousands of times more
warming effect than carbon dioxide must be greatly
accelerated.
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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
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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.
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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.
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