California should be the country's leader in emission reductions
but the draft plan is not the plan of a state trying to reach
maximum emission reductions. Here are my comments regarding
the deficiencies in the draft plan:
1. The draft plan does not even demonstrate that
California is on track to meet the legally mandated goal of at
least a 40% reduction in greenhouse gases by
2. The draft plan does not follow AB 32’s
requirement that California achieve “the maximum
technologically feasible” emission reductions, using the most
cost-effective methods. Air board officials said they will
propose the option that has the least impact on the economy rather
than accelerating the pace of achieving carbon neutrality.
3. The draft plan will not keep global temperatures even
close to what scientists say will avoid catastrophe. The world has
only ten years to cut greenhouse gas emissions by 50% if we are to
attain the goal. President Biden has committed the United States to
a 50% reduction by 2030. Yet the draft plan may not achieve even
40% by 2030.
4. The science of climate change requires front-loading
our response. “If mitigation pathways are not rapidly
activated, much more expensive and complex adaptation measures will
have to be taken to avoid the impacts of higher levels of global
warming on the Earth system.”
5. California’s goal should be at least an 80%
reduction in emissions by 2030. A former coordinating author
of the Intergovernmental Panel on Climate Change and Professor of
Sustainability at UC Berkeley, Daniel Kammen, Ph.D., set out a
scientifically backed and feasible program for California in 2021.
It calls for an 80% reduction in emissions by 2030.
6. The draft plan only aims for an 80% reduction emissions
by 2045. The draft plan’s reliance on carbon capture
and sequestration (CCS) or direct carbon capture (DAC) to balance
20% of our emissions is more than New York (15%) and far more than
the State of Washington (5%). California can do better.
7. Neither CCS nor DAC should be counted on as
scalable. The March 28, 2022 IPCC
report on the capacity of different actions to reduce greenhouse
gases puts CCS as the least effective and most expensive of the 43
climate actions the IPCC evaluated for deployment prior to
8. The draft plan drags out elimination of pollution that
disproportionately affects poor people and people of color. But
rapid elimination of GHG pollution costs less than the health costs
of continuing pollution.
9. The Environmental Justice Advisory Council (EJAC),
which advises the CARB Board, has demanded faster and more
comprehensive measures than in the draft plan so as to protect
disadvantaged communities, particularly those suffering from air
10. The draft scoping plan recognizes the importance of
SLCP abatement but not the importance of moving very quickly.
11. Reduction of emissions from HFC refrigerants having
thousands of times more warming effect than carbon dioxide must be
12. The draft plan expects to reduce fugitive emissions of
methane by 50%, but it needs to be higher in California to keep
global warming to no more than 1.5°C.
13. Highly reputable critics of the Cap and Trade program,
a market-based carbon pricing method used in California, believe
the program may not be able to achieve even its limited emission
reduction goal by 2030.
14. As a market-based mechanism, the Cap and Trade program
does not reduce major sources of pollution fast enough.
CARB should consider replacing parts of it by direct