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The Center for Biological Diversity (the "Center") appreciates the
opportunity to comment on the California Air Resources Board's
("CARB") August 2, 2021 Engineered Carbon Removal Technical
Workshop (hereinafter, "the workshop"). The Center was disappointed
that the workshop primarily featured speakers who assumed carbon
capture and storage ("CCS") by the State of California is necessary
to achieve carbon neutrality, and who asserted that CCS is safe and
minimally disruptive to frontline communities. The Center
vehemently disagrees with these assumptions. 

As CARB "consider[s]" engineered carbon removal, it is essential
that the agency take into account that according to the
Intergovernmental Panel on Climate Change ("IPCC"), CCS is not
necessary to achieve emissions reductions, nor is its effectiveness
or safety proven. Moreover, the types of dirty energy CCS may
prolong, and the infrastructure and energy required for CCS, will
cause additional pollution in communities already suffering from
unhealthy air and water quality.  

We urge CARB to reevaluate its approach to CCS in its upcoming
greenhouse gas emissions Scoping Plan update. CARB should focus on
a rapid phase out of fossil fuels rather than seeking to entrench
technologies that prolong the life of climate-damaging activities
and harm frontline communities. In doing so, CARB must ensure
meaningful community participation and input from the Environmental
Justice Advisory Council ("EJAC"), who, as we understand, has been
urging CARB throughout the Scoping Plan process to give greater
weight to its recommendations.

Our full letter is attached and we've emailed our compiled
references.