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Comment 301 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameDaniel
Last NameLashof
AffiliationWorld Resources Institute
SubjectScoping Plan refinements to consider during implementation

Dear Chair Randolph,


WRI strongly appreciates California’s climate leadership and the groundbreaking nature of the 2022 Scoping Plan for achieving net zero emissions by 2045 in the 5th largest economy in the world. By aiming to directly reduce emissions by at least 85% and using a broad portfolio of emissions reductions and carbon removal strategies California’s climate policy framework will serve as a model for other jurisdictions to follow. 


As the California Air Resources Board prepares to consider the 2022 Scoping Plan at its meeting on December 15, we want to call your attention to “Observations on the Implementation of the 2022 California Scoping Plan” just published by Evolved Energy Research (EER). Based on their extensive analysis of multiple net zero scenarios, EER makes a number of important suggestions for how CARB and other California state agencies can build on the tremendous effort that went into developing the 2022 Scoping Plan by refining key assumptions and analytic approaches as the plan is converted into concrete policies and regulations through proceedings such as (1) the Integrated Resource Planning (IRP) and SB100 processes led by the CPUC, (2) the carbon management planning process pursuant to SB 905 led by CARB,  and (3) the interagency working group on the phase down of fossil fuel extraction and refining initiated with the publication of the final 2022 Scoping Plan.


We summarize some of EER’s observations here and request that their complete white paper (attached) be considered part of this comment.


  • Electricity System Decarbonization: The Inflation Reduction Act (IRA) provides powerful incentives for California and neighboring states to build new renewable and other zero-carbon generation over the next decade. Future analyses should fully incorporate the benefits of the IRA, which is likely to allow even deeper reductions in emissions from California’s electricity system in 2030 and beyond. The CPUC IRP process is already considering a scenario with emissions 9 Mt lower than in the Scoping Plan scenario in 2030 and incorporating the incentives in the IRA could make even greater reductions cost effective in that timeframe. EER also notes that a refined analysis of electricity system decarbonization should include geospatial analysis and consider greater regional integration of California with neighboring states. The idea of building hydrogen turbines rather than methane turbines for capacity needs should also be reconsidered given the risk of higher NOx emissions from hydrogen turbines and the limited emissions of carbon dioxide from methane turbines running only a few hours per year. Carbon removal and non-combustion options for providing firm capacity (e.g., long duration storage or geothermal) may be more cost effective than hydrogen turbines and Carbon Capture and Sequestration (CCS) retrofits to methane turbines that weren’t designed to incorporate CCS.  


  • Carbon Management: Both CCS and carbon removal have important roles to play in helping California reach net zero emissions by 2045 or sooner, but further analysis of how and where these approaches should be deployed will be needed as part of the future SB 905 and fossil fuel phase down processes outlined in the Scoping Plan. For example, applying CCS to cement kilns makes sense, but installing CCS at refineries that are expected to retire or substantially reduce their output within a few years due to transportation electrification does not. Applying CCS to emission sources does not remove carbon from the atmosphere and should not be counted toward the carbon removal goals set by Governor Newsom. California’s carbon removal strategy should examine a wider variety of approaches than those included in the Scoping Plan, such as kelp cultivation, enhanced mineralization, and converting waste biomass from agriculture and wildfire risk reduction treatments into biochar or pyrolysis oil. Although biomass energy with carbon capture and storage (BECCS) is included in the Scoping Plan as a carbon removal strategy, other recent studies suggest that BECCS-hydrogen could play a significantly larger role than envisioned in the Scoping Plan scenario. The location and energy sources for Direct Air Capture also need further analysis. Significant cost reductions could be achieved by operating DAC and hydrogen facilities as grid-connected flexible loads, rather than assuming they will be powered by dedicated off-grid renewables. 


As California takes the next steps to implement the Scoping Plan we hope that you will consider this comment, including the EER white paper on which this summary is based, in the spirit in which it is offered-- constructive suggestions for how California can further refine its world-leading climate policies.




Daniel Lashof

Director, WRI United States

Berkeley, California



Original File NameEER Scoping Plan Implementation Observations.pdf
Date and Time Comment Was Submitted 2022-12-15 07:53:24

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