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Comment 30 for Public Workshop: 2022 Scoping Plan Update – Natural and Working Lands Technical Workshop (nwl-2021-tech-ws) - 1st Workshop.


First Name: Claire
Last Name: Broome
Email Address: cvbroome@gmail.com
Affiliation: Emory University

Subject: CARB NWL must include a net GHG removal scenario
Comment:
What are we missing?
A sufficiently aggressive, but necessary target.
The current projection that California NWL will produce up to 400
MMT of net emissions (no net removal) by 2100 should result in a
coordinated campaign of planning, implementation and evaluation to
accelerate NWL sequestration.
  
At least one of the scenarios to be considered should achieve net
removal of emissions from Natural and Working Lands (NWL) by 2050.

 
This will not be achieved by business-as-usual; however, the scale
of the climate crisis and a cost-effective approach to meeting
California's climate goals requires that CARB, CDFA, and CNRA model
such a scenario.
As documented again in the August 2, 2021 CARB workshop on
Engineered Carbon Removal, carbon sequestration from Natural and
Working Lands is substantially more cost-effective than
sequestration using Engineered Carbon Removal or Direct Air Capture
methods.  In addition, Natural and Working Lands sequestration has
the potential to be near term feasible and scalable. 


What are the biggest threats to NWL that must be included in
modeling?
While the importance of stakeholder involvement in the process was
emphasized at the workshop, it is ultimately CARB's responsibility
to assure the appropriate use of policy level levers and incentives
to achieve California's climate goals.  Not all stakeholders will
necessarily be in agreement--they should not hold veto power over
such a critical objective.

Reaching an aggressive target  for NWL sequestration will require
refining the strategies and GHG consequences, investing targeted
resources, and improving our models--using greater geographic
detail and independent verification to assure that long-term
sequestration is accomplished.

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Date and Time Comment Was Submitted: 2021-08-03 19:36:05



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