Comment | 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:
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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.
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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.
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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.
https://www.nrdc.org/stories/no-burning-wood-fuels-not-climate-friendly
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Bioenergy: 5
Reasons Why the World Must Stop Importing Bioenergy summarizes why
bioenergy is not climate friendly, and describes its negative
public health effects.
https://www.dogwoodalliance.org/2022/03/5-reasons-why-the-world-must-stop-importing-bioenergy/
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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:
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https://www.wired.co.uk/article/biofuels-aviation-carbon-emissions
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https://theconversation.com/biofuels-turn-out-to-be-a-climate-mistake-heres-why-64463
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https://www.epa.gov/environmental-economics/economics-biofuels
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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.
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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.
https://oversight.house.gov/sites/democrats.oversight.house.gov/files/DellaSala%20Testimony.pdf
- 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.
https://johnmuirproject.org/wp-content/uploads/2021/11/ScientistLetterOpposingLoggingProvisionsInBBB_BIF4Nov21.pdf
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