C/CAG thanks CARB staff and the many
contributors to the Draft 2022 Scoping Plan Update document. This
is an important update, especially as we approach being a mere 10
to 15 years away from needing to meet some of the most immense
targets set by the State and being adopted by many local
governments in response. Local efforts are essential to meeting
extensive decarbonization goals, some of which will require
significant change to our infrastructure, funding mechanisms, and
individual ways of life. As captured in the draft document, not
only are dealing with mitigation, but also meeting mitigation goals
now, is exacerbated by adaptation. Capacity of local government
staff to support the “transition”, is at risk.
The following are comments (potential
additions to the Scoping Plan) for consideration by CARB staff in
support of local government efforts:
1 1. The State
should explore providing community-scale GHG emission inventories
to each city in the State. Cities either spend considerable
resources to track the results of their GHG emission reduction
efforts, or do not track emissions at all. This effort at the state
level would provide multiple benefits: freeing up local government
staff time to plan and implement programs consistent with the
states Equity and VMT/GHG reduction targets, establishment of a
California map of emission generation, which could be overlayed
with other “layers” such as low income communities
and/or air quality, which would support not only progress but
targeting of funding and resources from the State. C/CAG and other
statewide partners have approached the CEC, requesting inventories
and, though initially supportive of the concept, have recently
heard that the CEC may reject this important project.
2 2. The State
provides valuable planning and other resources for local
governments, and some funding through grants. However, the largest
source of funding (and that which is mainly mentioned in the
Scoping Plan, is Cap and Trade. Local Governments share a large
responsibility to help meet GHG reduction goals. Some form of
regular funding should be provided to local and County governments
whose scope of work focuses on the transition to electrification of
transportation and buildings for the region they serve. For
counties that have no program for their community, this would serve
as an incentive to establish an agency.
3 3. The
electrification of transportation and buildings requires an
analysis of the reliability of the California, regional or local
power grid. The
ability to electrify will depend in part on the reliability of the
grid and also some form a redundancy or storage for the times when
the grid is not operational and/or green energy sources are not
available. Consumer
confidence is key to implementing a transition that could take 20
years. The State should require transparent local, regional, and
statewide power supply planning. That planning should be made
public through a Public Grid Reliability Confidence Campaign and
should include redundancy planning.
Sincerely,
Sean Charpentier, Executive Director
C/CAG
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