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Comment 344 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameChris
Last NameParos
SubjectComments, Need for Biofuels Strategy

Board members,


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 incentives

·       Strategy does nothing to directly address the millions of polluting vehicles on the roads now.

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:

1)      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

2)      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 pollution. 

3)      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).

4)      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 less).

5)      Incentivize gas station owners to offer at least one pump with biofuel vs gasoline

6)      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).

7)      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 communities.

·     Breaks oil monopoly: if needed, waste-recycled biofuels can be distributed/sold at independently-owned gas stations, and through city/county vehicle fleet contracts.

Currently, the 2022 CCSP only mentions biofuels incidentally.  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 doing enough.

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 threat:  fossil-fueled vehicle emissions.  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.



Chris Paros


References on next page:


*Excerpt from Flex Fuel Vehicle List. See 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 would save:

 (19.5 lbs/gal x (15 mi./15 mpg) x 5 days) = 97.5 lbs CO2 per week per vehicle

Therefore, 100 government vehicles using biofuels (vs gas or diesel) would avoid emitting ~ 5 tons (9, 750 lbs) of CO2 and other pollutants to our air every 5-day workweek! 

*** Ref: 6/6/2022 Sacramento Bee (Associated Press) article by Seth Borenstein, pg 16A

Original File Name
Date and Time Comment Was Submitted 2022-06-21 10:08:07

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.

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