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Comment 676 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameKristen
Last NameLee
SubjectAdditional comments on CARB draft scoping plan and environmental analysis

CARB Staff and Leaders,

Thank you for putting in so much time and effort into making this plan. We share the same goal of creating a healthy place that humans can live in for a very long time to come.


Please consider 4 recommendations:

    1. Solar: Increase use of solar, including rooftop solar. Our tax incentives and rebates need to continue so that as many families and businesses as possible can have solar - right near where they use it. Solar is one of our only viable sources of clean energy and the sun’s light is virtually unlimited. Rooftop solar is not as invasive as some other sources of energy such as wind farms. Please make sure families and businesses are not penalized for using solar.

    2. Biomass incineration: CA should not consider biomass to be a carbon neutral source of energy, nor should it receive the benefits of "renewables". Biomass incineration is not carbon-neutral. It emits more carbon than coal-burning. If “excess woody material” exists today due to extensive logging, a more climate-friendly solution than burning biomass would be to reduce logging, which would in turn reduce the flammable slash piles and other excess material, and would reduce carbon emissions.

      1. No, Burning Wood Fuel Is Not Climate Friendly from the NRDC describes the issue with calling energy from biomass from trees "renewable" and allowing it all the same credits and benefits as truly climate-friendly energy.

      2. Bioenergy: 5 Reasons Why the World Must Stop Importing Bioenergy summarizes why bioenergy is not climate friendly, and describes its negative public health effects.

    3. Biofuel burning: Any use of biofuels should be limited and timebound. At best, they should be used with care, and only those with the lowest emissions and least negative impact should be used. If they are used, they should only be used temporarily, and for specific, minor, limited applications. Biofuel incineration creates pollution and efforts to create it may lead to more deforestation, depletion of water sources, and possibly the transfer of land use for more edible, nourishing crops into land use for fuels. The use of biofuels on a large scale basis could be devastating to our land, our air, our food/water supply and our health. Here are two relevant articles and the EPA’s own assessment:




    4. Forests: The plan assumes that logging forests will result in reduced wildfire, but (contrary to popular belief) research has not proven that logging forest decreases fires or fire severity. Fuel reduction (logging) immediately depletes carbon and reduces shade/cooling in forests, over time contributing to climate change. Beyond that, rapid and extensive logging may generate large quantities of flammable slash piles and create more fire danger. If/when these slash piles are burned, more carbon will be emitted. In addition, extensive logging increases soil erosion which could permanently and negatively affect forest regrowth, watersheds, and air quality. In order to protect communities, defensible space around homes should be established, homes should be hardened, and homebuilding in the WUI should be carefully limited.

      1. Please read this letter from Dr. Domenic Della Sala, which explains how logging does not reduce wildfire, and recommends defensible space and home hardening instead.

      2. Nov 2021 Letter from Scientists to Biden Urging Forest Protection asks Biden to remove logging and biomass incineration provisions from infrastructure and reconciliation bills. Per the letter, “Logging conducted as commercial “thinning,” under the rubric of fire management, emits about three times more CO2 than wildfire alone.” The information in the letter also applies to CA.


Original File Name
Date and Time Comment Was Submitted 2022-06-24 23:59:11

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