Thank you, CARB
and staff for all the effort and work you put into the Draft
Scoping Plan. It is remarkably comprehenive and I applaud the
strategic thinking. However, the most important area to improve it
is the time frame. Please shorten the time frame in each segment of
the Scoping Plan to 2025-2030. The costs to California in climate
calamaties in every arena will cost more than any mitigation costs.
It is too late to be pro-active, but having a slow reactive
response will hurt our state beyond imagination. Please protect
California residents from disaster.
With respect, I
also support these specific improvements:
Legal Issues
-
The draft plan
does not demonstrate that California is on track to even meet the
legally mandated goal of at least a 40% reduction in greenhouse
gases by 2030.[2] Short-lived
climate pollutants are particularly unlikely to achieve a 40
percent reduction.
-
The draft plan
does not follow AB 32’s requirement that California achieve
“the maximum technologically feasible” emission
reductions, using the most cost-effective methods.[3] “Air board officials said they will propose the
option that has the least impact on the economy rather than
accelerating the pace of achieving carbon
neutrality.”[1]
Scientific Issues
-
The draft plan
will not keep global temperatures close to what scientists say will
avoid catastrophe. The world has
only ten years to cut greenhouse gas emissions by 50 percent if we
are to attain the goal. President Biden has committed the United
States to a 50 percent reduction by 2030. Yet the draft plan admits
that it may not achieve even 40 percent by 2030.
-
The science of
climate change requires front-loading our response. “If mitigation pathways are not rapidly activated,
much more expensive and complex adaptation measures will have to be
taken to avoid the impacts of higher levels of global warming on
the Earth system.”[4]
-
California’s goal should be at least an 80 percent
reduction in emissions by 2030. Prof. Daniel
Kammen, former coordinating author of the Intergovernmental Panel
on Climate Change and Professor of Sustainability at UC Berkeley,
set out a scientifically backed and feasible program for California
in 2021. It calls for an 80 percent reduction in emissions by
2030.[5]
-
The draft plan
only aims for an 80 percent reduction in emissions by 2045.
Even more troubling, the draft’s reliance on
carbon capture and sequestration (CCS) or direct air capture of
carbon (DAC) to reduce 20 percent of our emissions is more
than New York (15 percent) and far more than the State of
Washington (5 percent) anticipates.[6]
-
Neither CCS nor
DAC should be counted on as scalable. The March 28,
2022 IPCC report on the capacity
of different actions to reduce greenhouse
gases puts CCS as the least effective and most expensive of the 43
climate actions the IPCC evaluated for deployment prior to
2030.[7]
Environmental Justice Problems
-
The draft plan
drags out elimination of pollution that disproportionately affects
poor people and people of color. But rapid
elimination of GHG pollution costs less than the health costs of
continuing pollution. [8]
-
CARB’S
Environmental Justice Advisory Council (EJAC), which advises the
CARB Board, has demanded faster and more comprehensive measures
than in the draft plan so as to protect disadvantaged communities,
particularly those suffering from air pollution.[9]
Short-lived Climate Pollutants
(SLCPs)
-
The draft scoping
plan recognizes the importance of SLCP abatement but not the
importance of moving very quickly.[10]
-
Reduction of
emissions from HFC refrigerants having thousands of times more
warming effect than carbon dioxide must be greatly
accelerated.[11]
-
The draft plan
expects to reduce fugitive emissions of methane by 50 percent, but
that will not be enough to keep global warming to no more than
1.5°C.[12]
Cap and Trade
-
Highly reputable
critics of California’s Cap and Trade program, our
market-based carbon pricing method, believe the program may not be
able to achieve even its limited emission reduction goal by
2030.[13]
-
As a market-based
mechanism, the Cap and Trade program does not reduce major sources
of pollution fast enough. CARB should
consider replacing parts of it by direct
regulation.[14]
Sincerely, Stephanie Brown Climate Crisis Solution Activist 95124
[1] Nadia Lopez. Lower cost, slower gains:
California prepares controversial new climate strategy. CalMatters,
April 28, 2022. https://calmatters.org/environment/2022/04/california-climate-change-strategy/
[2] See the critique of the plan by Danny
Cullenward, Ph.D.: https://carbonplan.org/blog/scoping-plan-comments
[3] “Air board officials said they
will propose the option that has the least impact on the economy
rather than accelerating the pace of achieving carbon
neutrality.” Lopez, Nadia. “Lower cost, slower gains:
California prepares controversial new climate strategy.”
CalMatters, April 28, 2022. https://calmatters.org/environment/2022/04/california-climate-change-strategy/
[4] https://www.ipcc.ch/sr15/cross-chapter-boxes/
[5] Kammen, Daniel M., Teenie Matlock,
Manuel Pastor, David Pellow, Veerabhadran Ramanathan, Tom Steyer,
Leah Stokes, and Feliz Ventura. "Accelerating the timeline for
climate action in California." arXiv preprint
arXiv:2103.07801
(2021).
https://arxiv.org/abs/2103.07801?context=eess.SY
[6] Cullenward, op cit.
[7] https://www.ipcc.ch/report/ar6/wg3/figures/summary-for-policymakers
[8]Wang, T.,
Jiang, Z., Zhao, B. et al. Health co-benefits of achieving
sustainable net-zero greenhouse gas emissions in California. Nat
Sustain 3, 597–605 (2020). https://doi.org/10.1038/s41893-020-0520-y.
[9] https://caleja.org/wp-content/uploads/2022/05/CARB-draft-plan-vs-EJ-recommendations-FINAL-CORRECTED.pdf
[10] Gabrielle Dreyfus, chief scientist for
the Institute for Governance & Sustainable Development and lead
author of: Dreyfus, Gabrielle B., Yangyang Xu, Drew T.
Shindell, Durwood Zaelke, and Veerabhadran Ramanathan. "Mitigating
climate disruption in time: A self-consistent approach for avoiding
both near-term and long-term global warming." Proceedings of the National Academy of Sciences of the
United States of America 119, no. 22
(2022): e2123536119. https://www.pnas.org/doi/full/10.1073/pnas.2123536119. This article is the most current and comprehensive on
the forcing role of C02, SLCPs and aerosols.
[11] Daniel M. Kammen, et al.,
“Accelerating the timeline for climate action in
California,” March
2021, https://arxiv.org/abs/2103.07801
[12] Illissa B. Ocko, et al. "Acting
rapidly to deploy readily available methane mitigation measures by
sector can immediately slow global warming." Environmental Research Letters 16, no. 5 (2021): 054042. https://iopscience.iop.org/article/10.1088/1748-9326/abf9c8?addl_info=2021
The fastest way to slow warming
[13] https://calepa.ca.gov/2021-iemac-annual-report/
[14]
https://calepa.ca.gov/wp-content/uploads/sites/6/2022/02/Comment_on_IEMAC_Report___CVAQC.a.pdf
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