Thank you for the opportunity to provide
community input in to California’s 2022 Climate Change
Scoping Plan (CCSP).
Though the 2022 CCSP update includes several
useful measures to reduce Greenhouse Gas emissions (GHGe), it
nevertheless falls short in one glaring area. The 2022 update does not
adequately address the primary source of GHGe –
transportation vehicle emissions.
Per the 2022 CCSP’s
“Transportation Sustainability” measure, the
transportation sector accounted for over 50% of state-wide GHG
emissions and is by far the single largest sector source of carbon
pollution in the state (pg. 147, PDF pg. 174). Yet all the strategies listed in the CCSP
will take far too long to address this very large and growing
source of GHGe and other dangerous pollution. For example, the first
strategy, “Achieve 100 percent Zero Emissions Vehicles (ZEV)
sales by 2035…” or 2040 (medium duty vehicles) is at
least thirteen years away!
In addition, the 2022 CCSP does not discuss some
serious obstacles to ZEV transition, which include:
Electric vehicles rely on a
power grid that has been undermined by wildfires and drought
Electric vehicles use batteries
made from materials that are limited in supply and hazardous
Electric vehicles are way too
expensive for low-income buyers to purchase even with
Strategy does nothing to
directly address the millions of polluting vehicles on the roads
The CCSP authors understand more needs to be
done when they state “…, it is clear that California
must transition away from fossil fuels to zero-emission
technologies with all possible speed…” (p. 147)
My Request: Given the dire
urgency of our climate crisis, I request CARB staff investigate and
develop a large-scale strategy in the 2022 CCSP update to: 1)
expand the use of biofuels on a widespread scale, and 2) convert
existing fossil fuel vehicles to biofuel capability.
Suggested features for the large-scale CCSP
biofuel strategy include:
Establish a state tax rebate
for: a) purchasing vehicles that are certified as flex fuel or
biofuel (similar to ZEV rebate), and for b) certified/verified
conversion of a vehicle to flex or biofuel use.
Low-income residents can afford
conversions (at ~ $1,000) vs. buying a new ZEV
Educate and encourage drivers to
buy biofuels (vs gas or diesel), and to convert their polluting
fossil fuel vehicles to flex fuel capability (advertisements,
fliers). Being much
cheaper per gallon, drivers will have a natural incentive to buy
biofuels vs gas.
Other consumer incentives: clean-burning biofuels reduce
engine wear (less repair costs), and do not create air
Require or incentivize vehicle
manufacturers to make all their gasoline & diesel models flex
fuel capable. (* see
excerpt from Flex-Fuel vehicle model list at end).
Require or incentivize vehicle
manufacturers to offer conversion kits for their existing truck and
car models (conversion kits for many models can be $1,000 or
Incentivize gas station owners
to offer at least one pump with biofuel vs gasoline
Incentivize/Encourage City &
County governments to buy and use biofuel/biodiesel in their fleet
& construction vehicles where they cannot use ZEV** (see
calculation at end).
Work with Pacific Ethanol or
other partners to start producing biofuels from collected
carbon-based garbage, agricultural, landscape and/or forest
waste. Creating a waste-to-biofuel
closed-loop recycle process is achievable now technically and could
hugely improve our climate future.
Reduces methane pollution from
landfills. Per the
CCSP update, landfill methane releases are a major concern for the
future (ref. pg 188, PDF pg 215). Recycling carbon-based waste into
biofuels reduces methane releases.
Preserves infrastructure and
jobs: If oil companies can refine oil from shale (once thought
impossible), then they can transition to becoming waste-to-biofuel
refineries when consumer demand for oil declines. Biofuel
production could provide a way to preserve oil refineries,
distribution infrastructure, and industry jobs.
Supports environmental justice:
A program to convert existing gasoline/diesel vehicles to flex
fuels is more likely to be used by lower income residents. It will also greatly
improve air quality and environmental justice for those
Breaks oil monopoly: if needed,
waste-recycled biofuels can be distributed/sold at
independently-owned gas stations, and through city/county vehicle
Currently, the 2022 CCSP only mentions
Figures 4-2 and 4-7 show only minor use of biofuels in
Transportation and Industrial sectors through 2045. Why not have a strategy
for developing widespread use of biofuel/biodiesel? The biofuel, E-85, is made
by the oil industry from virgin corn crops and therefore has been
assumed to have a large carbon footprint. But biofuels and biodiesel can be made from
any carbon-based product – garbage, cleared forest brush,
and agricultural/landscape waste. Recycling carbon-based waste for biofuel use
cancels out any carbon footprint concerns.
Many auto models are already flex-fuel capable
(*see list excerpt at end), and the auto racing world currently
uses biofuels for sportscar racing. With active negotiation and/or incentives, many
more automakers would produce flex fuel vehicles and conversion
kits. With a strong
push to make it happen, many fossil-fueled vehicles could be
economically converted to using biofuels now.
Relying on Cap & Trade to control GHG is
also not sufficient.
NOAA scientists just announced that the amount of carbon
dioxide in our atmosphere had shot 50% beyond a key milestone and
is at levels not seen since millions of years ago**. Clearly, Cap & Trade policy is not
Converting fossil-fueled vehicles to
biofuel-vehicles is the only known strategy that can be immediately
implemented on a widespread scale to mitigate the largest GHG
Even if it’s an imperfect strategy, we have no
alternatives. We must
try to convert as many vehicles as possible that are on the road
now to biofuel & biodiesel use – even if only as an
interim strategy until most vehicles transition to
ZEV’s. Our state risks peril if we
do not act now to address vehicle GHG emissions. And with this expanded biofuel strategy,
California could also hopefully also finally free our state away
from costly oil dependency.
References on next page:
*Excerpt from Flex Fuel Vehicle List. See www.E85vehicles.com for GM
& other models.
** One gallon of
gasoline produces 19.5 lbs of CO2 (ref.
If a 15-mpg
county vehicle drives a 15-mile
daily commute (1
gallon used per day), using a biofuel vehicle
(19.5 lbs/gal x (15 mi./15
mpg) x 5 days) = 97.5 lbs CO2 per week per vehicle
100 government vehicles
(vs gas or
emitting ~ 5 tons (9, 750
CO2 and other
to our air
*** Ref: 6/6/2022 Sacramento Bee (Associated
Press) article by Seth Borenstein, pg 16A