California has long been such a leader nationally on issues
related to combatting the climate crisis, so I've been surprised to
learn that CARB's draft 2022 scoping plan is less ambitious than
those of some other states, is lacking in transparency and detail,
and has the potential to fail to meet our greenhouse gas emission
reduction targets for both 2030 and 2045.
Please revise the plan's section addressing progress toward
meeting 2030 emission reduction targets by adding detailed data and
support for how the Board expects progress to unfold in the next
eight years, identifying the risk and potential flaws in
California's cap and trade program, and outlining improvements
needed in the program that would increase the likelihood it will
get us where we need to go by 2030. Specifically, please
address reforms to the program, such as a tighter emissions cap,
reducing the number of allowances currently in circulation,
establishing no-trading zones in disadvantaged communities and
eliminating the use of offsets and distribution of free allowances,
that would both help us meet 2030 objectives and do so in a way
that prioritizes climate justice.
It's also critically important that California develop an
ambitous plan and take action NOW to reduce the use of fossil
fuels, including natural gas, and quickly shut down the expansion
of new fossil fuel infrastructure. The draft plan's heavy reliance
on future carbon dioxide removal, technologies which may be
prohibitively expensive and may not even exist at the scale
required over the next 20 years, is the height of folly. Please
significantly reduce reliance on CDR in the plan, replacing it with
plans that would speed reductions in fossil fuel use in the short
and long term.
Time is running out. We can't wait another five years to
find out that we're falling short with cap and trade and CDR.
Thank you in advance for your efforts to significantly improve the