Comment Log Display

Here is the comment you selected to display.

Comment 587 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameCatalina
Last NameGonzalez
AffiliationThe Center for Progressive Reform
SubjectDetailed Comments on Strengthening the Draft Plan

We offer here an overview of our full comments, which are attached. Page numbers refer to the full document.


We understand that crafting a clean economy transition plan for California that eliminates net carbon emissions is a daunting task. CARB must make decisions that will have significant, if not existential, impacts on public health, employment, housing, communities, and the economy.   Other states like New York and Illinois are pressing ahead with visionary climate plans; to remain a leader in achieving an equitable transition to a clean economy, we encourage CARB to take a more ambitious path.


We offer a range of comments on the Draft 2022 Scoping Plan Update (the Draft Plan) that promote a vision and implementation strategies that embrace the urgent need for action and more explicitly foster improvements in well-being for the state’s frontline communities




The first section of these comments articulates several cross-cutting themes:


  • The first cross-cutting theme is the importance of developing a holistic vision that meets the climate challenge and human needs.  We urge CARB to meet the climate challenge with a faster timeline, to achieve multiple objectives with effective multi-sector coordination, to provide a just transition for workers, to foster environmental justice, and develop explicit equity standards. (p.3)

  • The second cross-cutting theme is the critical importance of the EJAC and broader public engagement in plan implementation. (p. 4)

  • The third cross-cutting theme is the vital role of public investments.  We note that, unless the state supports a clean transition for low-income individuals or businesses, it will not achieve carbon neutrality.  The Draft Plan should more deeply grapple with the needed scale of public investment and assess whether continued reliance on grant-based programs is a viable model for distributing resources effectively and equitably. (p. 4)

The second section of these comments emphasizes the need for a more detailed evaluation of past scoping plan implementation and the importance of including explicit evaluation in the implementation of the 2022 plan. (p. 5)


The third section of these comments turns to carbon reduction strategies. (p. 6)  We make two preliminary observations.


  • The first preliminary observation is that achieving justice will require intentional and explicit strategies in each sectoral context. (p. 6)

  • The second observation is that, because the Draft Plan is relatively silent about the specific mechanisms for achieving proposed technological shifts, CARB should develop a supplemental plan that more clearly assesses the relative roles of planning, regulation, incentives, investments, and cap-and-trade. (p. 6)

  • After these observations, we provide detailed comments on the following:

  1. Prioritize diesel reductions and develop an integrated approach to transportation. (p. 7)

  2. Prioritize renewables and avoid new natural gas and other alternatives that adversely impact overburdened communities, while enhancing environmental and economic equity. (p. 8)

  3. Increase ambition in the manufacturing and building sectors, including direct regulation phasing out fossil fuel use. (p. 10)

  4. To obtain the benefits of reducing fossil fuels, prioritize strategies that reduce fossil fuels and limit the role of carbon removal to the extent possible. (p. 12)

  5. Limit the role of cap-and-trade while prioritizing direct strategies for transitioning to a clean economy. (p. 12)

Please see attached document for full comments.


Original File NameCPR Comments on 2022 Draft Scoping Plan .pdf
Date and Time Comment Was Submitted 2022-06-24 16:23:49

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.

Board Comments Home