This is the second of two comments I am submitting for the Draft
2022 Climate Change Scoping Plan.
I request CARB staff respond to my itemized comments as required
by CEQA, NEPA and all state and federal statutes and regulations
pertaining to response to comments.
AAA) I am submitting the following alternative to the Advanced
Clean Car II regulation portion of the Draft Scoping Plan.
- establish a "closed loop" renewable liquid
fuel standard in the state of 25% content "closed loop" renewable
fuel by 2030 and 50% content "closed loop" renewable fuel by
- Reduce statewide VMT from a 2014 baseline
by 25% by 2030 and 50% by 2040.
-Reduce Port of Los
Angeles/Long Beach activity (tonnage) by 75% from a 2019
The above alternative provides far greater environmental
protection than the Advanced Clean Car II regulation. The above
alternative should be analyzed for the following reductions in
emissions and compared to reductions achieved by the ACC II
- Reduced emissions from mobile sources directly
achieved inside the state.
- Reduced GHG emissions achieved by reduced
-Reduced GHG emissions by transferring
manufacturing from China to the United States.
Points to the above alternative:
- The Ports of Los Angeles/ Long Beach are
owned by the respective cities. Those cities have every right and
power to limit activity at their ports.
- GHG emissions from manufacturing any
given item in the U.S are far less than GHG emissions from
manufacturing the same item in China.
- The above alternative to the ACC II
regulation will have a far less impact to other states than the ACC
II regulation. This is because the ACC II regulation will impact
the design, price, safety and utility of motor vehicles sold
throughout the U.S., to the detriment of consumers in other states
that do not want their motor vehicle designs, prices, safety or
utility influenced by the ACC II regulation.
CARB is required by CEQA to prepare an analysis of the above
environmentally superior alternative. It is also unlawful for CARB
to implement any motor vehicle emission standard that is more
stringent than federal standards without first exhausting all
emission reduction options available to the state, such as the
emission reduction strategies proposed in the above
T.Becker Power Systems