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Comment 629 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameDarrell
Last NameClarke
SubjectComment on Draft 2022 Scoping Plan

The Scoping Plan's starting point is appropriately passenger vehicles, for their 28.5% share of total California GHG emissions. 

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 results?


Original File Name
Date and Time Comment Was Submitted 2022-06-24 19:22:31

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