I write in
opposition to the draft 2022 Scoping Plan. Instead of evaluating pathways for the state to
achieve carbon neutrality by 2035, it
recommends a path that delays
achieving carbon neutrality until 2045. It requires little to no
immediate action to reduce climate pollution, and even worse,
relies on expensive and unproven technology to meet its emission
reduction targets. The path laid out in the Scoping Plan will
perpetuate fossil fuel production and continue to harm
California’s communities and ecosystems.
Every alternative modeled by CARB projects building new
gas plant capacity, including the “no combustion”
Alternative 1. CARB’s preferred pathway, Alternative 3,
proposes to build 10 GW of new gas capacity, equivalent to at least
33 new large gas power plants. The latest IPCC report makes it
clear that we must rapidly reduce our reliance on fossil fuels.
Continuing to rely on existing fossil fuel infrastructure makes
mitigating the negative effects of climate change more and more
difficult. Gas plants emit many dangerous pollutants, and the
majority of California’s gas-fired power plants are located
in or adjacent to many of the state’s most disadvantaged
communities.
Additionally, instead of promoting greater investment in
renewable energy resources and avoiding emissions entirely,
CARB’s preferred pathway relies extensively on carbon
capture, usage, and sequestration (CCUS) in addition to direct air
capture (DAC) of carbon dioxide. The model unrealistically projects
that, within the refineries sector, CCUS will operate on the
“majority of operations by 2030.”
Although CARB staff seem to recognize the urgency of the
climate crisis in their presentations to the Board each month, the
draft scoping plan does not have that same sense of urgency.
Especially concerning is the plan’s reliance on technologies
that haven’t been proven to provide the climate and health
benefits Californian’s need. CARB must select a pathway to
carbon neutrality that is faster and delivers significant
reductions in greenhouse gas emissions, air pollution, and adverse
health impacts. Additionally, the plan must not rely heavily or at
all on carbon capture, use, and sequestration (CCUS) or biofuels.
Californians deserve and demand better from our
regulators.
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