We are in a climate crisis as evidenced by rising
sea levels to wildfires to droughts. On top of this, millions of
Californians continue to live in communities that are out of
compliance with federal air quality standards. For these reasons,
the state must urgently move away from fossil fuels, drastically
reduce greenhouse gas emissions and towards renewable energy
technologies as quickly as possible.
CARB’s Draft Scoping Plan (SP) would set
California on a path towards carbon neutrality that is unacceptably
slow and out of line with what the science on global warming shows.
Rather than move forward with Alternative 3, CARB must find a
pathway to carbon neutrality that is faster and delivers
significant reductions in greenhouse gas emissions, air pollution,
and adverse health impacts.
Please revise the SP to consider the
1) Exclude any new investments in fossil fuel
infrastructure and pursue renewable energy.
CARB’s preferred pathway, Alternative 3,
proposes to build the equivalent of at least 33 new midsize or 100
peaker gas powered plants. The latest IPCC report makes it clear
that we must rapidly reduce our reliance on fossil fuels.
2) Pursue direct emissions reductions rather than
gambling on carbon capture and other unproven
The Draft relies heavily on technologies such as
Carbon Capture, Usage and Sequestration and Direct Air Capture
rather than accelerating zero carbon renewable energy. These
technologies are still in the research phases, and can not be
counted on in the immediate future.
these cannot be used to prolong the lives of oil refineries or
methane gas powered plants.
3) Reduce emissions from the transportation sector
to comply with the Governor’s Executive Order.
The Draft lays out a slower path to heavy duty
zero emission vehicles than is necessary to achieve
California’s climate goals and air quality standards. Not
only would this fail to comply with the governor's executive order
to transition 100% of medium- and heavy-duty vehicles to
zero-emission vehicles by 2045, it could also leave dirty, diesel
trucks in California communities beyond 2050.
4) Phase out oil and gas extraction and petroleum
CARB should phase out oil refining by 2045 and oil
and gas extraction by 2035 as part of a managed reduction in use of
fossil fuels. The fossil fuel supply chain not only emits large
amounts of greenhouse gas, it poisons the air, water, and soil of
communities and ecosystems that are forced to live adjacent to
them. These communities, predominantly low-income communities of
color, have become sacrifice zones for the oil and gas supply
5) Set a date for electrification retrofits in
addition to replacing gas appliances at end-of-life
Alternative 3 recommends that gas appliances in
commercial and residential buildings are retired at the end of
their useful life. This is unwise from economic, climate, and
environmental justice perspectives. This approach hampers the
decommissioning of segments of the gas distribution system, as
commercial and residential buildings will require gas until their
appliances burn out. It also entrenches methane leakage and gas
combustion pollution, as gas appliances that were purchased before
2035 can operate for decades, potentially. And it risks leaving the
last customers on the gas system without heat when their gas
appliances burnout, if they are not adequately prepared to switch
to electric appliances.
I urge you to take these points into
account in your draft CCSP to protect earth’s life support
systems, and the health of our children, our grandchildren, our
great grandchildren and seven generations hence. We have a moral
obligation to do so.
Sue Y. Lee Mossman
PO Box 223
Arcata, CA 95518