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Comment 593 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameSofia
Last NameMagallon
AffiliationRegenerate California
SubjectCARB Scoping Plan Recommendations

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.

  1. 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.

  2. 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.

  3. 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.

  4. 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.

Original File Name
Date and Time Comment Was Submitted 2022-06-24 16:46:17

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