Legal Issues
1. The draft plan does not demonstrate
that California is on track to even meet the legally mandated goal
of at least a 40% reduction in greenhouse gases by 2030.[2]
Short-lived climate pollutants are particularly unlikely to achieve
a 40% reduction.
2. The draft plan does not follow AB
32’s requirement that California achieve “the maximum
technologically feasible” emission reductions, using the most
cost-effective methods.[3]
“Air board officials said they will propose
the option that has the least impact on the economy rather than
accelerating the pace of achieving carbon neutrality.”[1]
Scientific Issues
1. The draft plan will not keep global
temperatures close to what scientists say will avoid
catastrophe. The world has only ten years to cut
greenhouse gas emissions by 50% if we are to attain the goal.
President Biden has committed the United States to a 50% reduction
by 2030. Yet the draft plan may not achieve even 40% by 2030.
2. The science of climate
change requires front-loading our response. “If
mitigation pathways are not rapidly activated, much more expensive
and complex adaptation measures will have to be taken to avoid the
impacts of higher levels of global warming on the Earth
system.”[4]
3. California’s goal should be at
least an 80% reduction in emissions by 2030. A former
coordinating author of the Intergovernmental Panel on Climate
Change and Professor of Sustainability at UC Berkeley, Daniel
Kammen, Ph.D., set out a scientifically backed and feasible program
for California in 2021. It calls for an 80% reduction in emissions
by 2030.[5]
4. The draft plan only aims for an 80%
reduction emissions by 2045. The draft
plan’s reliance on carbon capture and sequestration (CCS) or
direct carbon capture (DAC) to balance 20% of our emissions is more
than New York (15%) and far more than the State of Washington
(5%).[6]
5. Neither CCS nor DAC should be counted
on as scalable. The March 28, 2022 IPCC report
on the capacity of different actions to reduce greenhouse gases
puts CCS as the least effective and most expensive of the 43
climate actions the IPCC evaluated for deployment prior to 2030.[7]
Environmental Justice Problems
1. The draft plan drags out elimination of
pollution that disproportionately affects poor people and people of
color. But rapid elimination of GHG pollution costs less than the
health costs of continuing pollution.[8]
2. The Environmental Justice Advisory
Council (EJAC), which advises the CARB Board, has demanded faster
and more comprehensive measures than in the draft plan so as to
protect disadvantaged communities, particularly those suffering
from air pollution.[9]
Short-lived Climate Pollutants (SLCPs)
1. The draft scoping plan recognizes the
importance of SLCP abatement but not the importance of moving very
quickly.[10]
2. Reduction of emissions from HFC
refrigerants having thousands of times more warming effect than
carbon dioxide must be greatly accelerated.[11]
3. The draft plan expects
to reduce fugitive emissions of methane by 50%, but it needs to be
higher in California to keep global warming to no more than
1.5°C.[12]
Cap and Trade
1. Highly reputable critics of the Cap and
Trade program, a market-based carbon pricing method used in
California, believe the program may not be able to achieve even its
limited emission reduction goal by 2030.[13]
2. As a market-based mechanism, the Cap
and Trade program does not reduce major sources of pollution fast
enough. CARB should consider replacing parts of it
by direct regulation.[14]
[1]
Nadia Lopez. Lower cost, slower gains: California prepares
controversial new climate strategy. CalMatters, April 28, 2022.
https://calmatters.org/environment/2022/04/california-climate-change-strategy/
[2]
See the critique of the plan by Danny Cullenward, Ph.D.: https://carbonplan.org/blog/scoping-plan-comments
[3]
“Air board officials said they will propose the option that
has the least impact on the economy rather than accelerating the
pace of achieving carbon neutrality.” Lopez, Nadia.
“Lower cost, slower gains: California prepares controversial
new climate strategy.” CalMatters, April 28, 2022. https://calmatters.org/environment/2022/04/california-climate-change-strategy/
[4]
https://www.ipcc.ch/sr15/cross-chapter-boxes/
[5]
Kammen, Daniel M., Teenie Matlock, Manuel Pastor, David Pellow,
Veerabhadran Ramanathan, Tom Steyer, Leah Stokes, and Feliz
Ventura. "Accelerating the timeline for climate action in
California." arXiv preprint arXiv:2103.07801 (2021).
https://arxiv.org/abs/2103.07801?context=eess.SY
[6]
Cullenward, op cit.
[7]
https://www.ipcc.ch/report/ar6/wg3/figures/summary-for-policymakers
[8]
Wang, T., Jiang, Z., Zhao, B. et al. Health co-benefits of
achieving sustainable net-zero greenhouse gas emissions in
California. Nat Sustain 3, 597–605
(2020). https://doi.org/10.1038/s41893-020-0520-y.
[9]
https://caleja.org/wp-content/uploads/2022/05/CARB-draft-plan-vs-EJ-recommendations-FINAL-CORRECTED.pdf
[10]
Gabrielle Dreyfus, chief scientist for the Institute for Governance
& Sustainable Development and lead author of: Dreyfus,
Gabrielle B., Yangyang Xu, Drew T. Shindell, Durwood Zaelke, and
Veerabhadran Ramanathan. "Mitigating climate disruption in time: A
self-consistent approach for avoiding both near-term and long-term
global warming." Proceedings of the National Academy of
Sciences of the United States of America 119, no. 22 (2022):
e2123536119. https://www.pnas.org/doi/full/10.1073/pnas.2123536119This
article is the most current and comprehensive on the forcing role
of C02, SLCPs and aerosols.
[11]
Daniel
M Kammen, Teenie
Matlock, Manuel
Pastor, David
Pellow, Veerabhadran
Ramanathan, Tom
Steyer, Leah
Stokes, Feliz
Ventura, Accelerating the timeline for climate action
in California, March 2021, https://arxiv.org/abs/2103.07801
[12]
Ocko, Ilissa B., Tianyi Sun, Drew Shindell, Michael Oppenheimer,
Alexander N. Hristov, Stephen W. Pacala, Denise L. Mauzerall,
Yangyang Xu, and Steven P. Hamburg. "Acting rapidly to deploy
readily available methane mitigation measures by sector can
immediately slow global warming." Environmental Research
Letters 16, no. 5 (2021): 054042. https://iopscience.iop.org/article/10.1088/1748-9326/abf9c8?addl_info=2021
The fastest way to slow warming
[13]
https://calepa.ca.gov/2021-iemac-annual-report/
[14]
https://calepa.ca.gov/wp-content/uploads/sites/6/2022/02/Comment_on_IEMAC_Report___CVAQC.a.pdf