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Comment 58 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameSue
Last NameMossman
AffiliationHumboldt UU Climate Action Campaign
SubjectComments on Draft Scoping Plan

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 following: 

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 technologies.

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.

                                                                                                                                                                                                                                               Furthermore, 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 refining earlier.

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 chain. 

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

Original File Name
Date and Time Comment Was Submitted 2022-06-13 02:55:23

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

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