| Comment | 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.
Sincerely,
Daniel Lashof
Director, WRI United States
Berkeley, California
|
|---|