Comment Log Display

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
 
Overview:
 
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:





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


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


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


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)


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.