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Comment 629 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.
|Subject||Comment on Draft 2022 Scoping Plan|
The Scoping Plan's starting point is appropriately passenger
vehicles, for their 28.5% share of total California GHG
The Advanced Clean Cars II Rulemaking is a critical lever, but
gives too much space for PHEVs that may never be plugged in.
VMT reduction is the other critical transportation lever, but
“Smart Growth / Vehicle Miles Travelled — VMT per
capita reduced 12% below 2019 levels by 2030” (page 58) has
no mechanism beyond the tenuous Appendix D Local Actions.
The Scoping Plan relies excessively on economically and
technically questionable carbon capture and sequestration (CCS) and
direct air capture (DAC) technologies.
Can this Scoping Plan actually even meet the statutory SB 32
target of 40% below 1990 levels by 2030, despite modeling
|Original File Name|| |
|Date and Time Comment Was Submitted|| 2022-06-24 19:22:31|
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