Comment | Hello, my name is Sofia Magallon, I am a
resident of Oxnard,CA and a member of Regenerate
California.
We
can have a reliable, affordable, and just energy system,
but CARB needs a more ambitious plan for the electric sector to
achieve it. There are four main problems with the electric sector
portion of the Draft Scoping Plan.
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First, the electric sector greenhouse gas target is too
high. By projecting
greenhouse gas emissions of 30 million metric tons (MMT) out
through 2045, this plan won’t achieve the zero-carbon grid
that SB 100 requires. As multiple sectors electrify to reduce GHG
emissions, that puts new demand on the electric sector. Without an
emissions limit of 0, this demand is likely to result in gas plants
cycling more frequently. When gas plants start up and shut down,
they can emit up to 90 times the NOx emissions that they produce
during steady state operations. 78% of California’s gas
plants are located within 5 miles of a disadvantaged community. New
or expanded gas plant capacity would worsen existing environmental
racism and injustice. Frontline communities will be the ones to
carry that pollution burden unless we reduce electric sector
emissions to 0.
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Second, any emissions from the electric sector in
2045 means relying on expensive and unproven carbon capture
technology. In order to
reach carbon neutrality in 2045, any emissions from the electric
sector have to be offset with carbon capture or direct air capture
technology. The Draft Scoping Plan addresses this by relying
heavily on unproven and extremely expensive carbon capture and
carbon dioxide removal technology. There are market-ready
zero-carbon technologies available to generate clean electricity.
It doesn’t make sense to create GHG emissions and then claw
those same emissions back with carbon capture. Furthermore, the
Scoping Plan failed to include the resources needed to power carbon
dioxide removal technologies, meaning that relying on these
technologies will require even more renewable resources than the
plan describes. Instead of relying on carbon capture and removal
technologies, the Plan should set a 0 electric sector emissions
target so that we avoid electric sector emissions
altogether.
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Third, the Scoping Plan projects that we need 10 GW of new gas
plant capacity, but we should not be spending any money on new
fossil fuel infrastructure. We can have a renewable, affordable, and reliable
electric system without investing in new gas capacity. We need more
investment in a diversity of renewable resources. For example,
investing in geothermal and offshore wind–even in small
amounts–can significantly decrease the amount of solar needed
by half, lower dependence on imports and in-state gas, and lower
levels of dependence on inverter-based resources while supporting
reliability through a more diverse resource mix. We don’t
need more gas plants to have a reliable grid–we need more and
diverse renewable resources.
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Last,
the health
benefits of a cleaner electric grid need to be
calculated. The Draft
Scoping Plan included only snapshots of health impacts between the
scenarios. The final Scoping Plan needs to incorporate the full
health benefits for avoiding gas power plant emissions into the
electric sector decision making. CARB should calculate the
projected health benefits associated with an electric sector plan
that reaches 0 MMT by 2035. A more ambitious electric sector plan
will have meaningful benefits for frontline communities.
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