Comment Log Display

Urgent Decarbonization Now.  Holding GHG emissions in check
purportedly enough to "stabilize" climate warming at 450 degrees
won't "stabilize" anything.  CARB should recognize that latest
climate science tells us that previous projections have been too
conservative,  that "climate stabilization" will require prompt and
radical decarbonization of the entire energy economy. 
Half-measures are no longer sufficient to overcome the existential
gravity of the climate disruption threat, and CARB should be in the
forefront of those who speak scientific truth about this
challenge.

Fix Transportation Gap.  There is a legislation gap for
transportation GHG reduction. It is of great significance to the
Scoping Plan. The gap was created by push-back from the oil
industry in SB 350 last year.  CARB now has a chance to address
this legislation gap.  Gov. Brown promised that
regulatory/administrative authority would do so.  What particularly
needs fixing is how to 1) greatly accelerate electric vehicles
(which seems to be lagging compared to state policy goals up to
2025, and needs a new higher target for 2030), 2) greatly improve
local public transit service so it can compete with the
functionality of cars, 3) build infrastructure for safe walking and
bicycles, which need separated roads not just "bike lanes" that are
inches from racing metal vehicles weighing a ton or more, 4)
implement alternatives that reduce the need to travel, including
higher density development and arcologies, and telecommuting.

Phase Down Natural Gas.  Also critically needed is a comprehensive
strategy--a policy "loading order"-- for phasing down domestic
natural gas which includes 1) conservation, 2) efficiency, 3) zero
net energy buildings, 4) non-electric energy technologies (solar
-hot water, -space heat, -cooking, -air conditioning, and
-lighting; geothermal heat; waste heat recovery, etc.), and 5)
using low carbon grid electricity to replace the balance of gas
use. This strategic approach should aim to reduce the cost, delay,
risk, and environmental burden of domestic natural gas reduction,
by using a diverse portfolio of tools rather than dumping all the
weight on the electric grid.

Get More Energy Efficiency Faster.  It would be very helpful to set
policy goals, regulations, and implementation strategies for energy
efficiency for the large segment of residential and commercial
buildings, especially in a serious manner to address the split
incentive between landlord and tenant. One of these measures might
be to give renters the right to access energy efficiency
technologies, which they are often denied today--similar to
California's right for renters to install electric vehicle charging
equipment if they choose.

Push Zero Waste.  It is also important to look at non-energy
systems, such as providing support for radical reduction of
waste--we should be looking toward up to 90% diversion from
landfills by 2030 (the current policy is reportedly 75% reduction
by 2020). And we need better systems of verification and
implementation that draw in single family homes, multifamily
apartments and condos, and businesses as well as transforming
"waste management" companies into recycling systems. Agriculture,
industry, concrete, high global warming gases, all need similar
attention. 

No Relying on Feds.  A particularly urgent factor to examine is
that we may not be able to continue to rely on the federal
government to pick up their responsibilities in the context of
climate policy. The recent election puts many things at risk, based
upon public statements and ideological extremism of the Republican
Party and president-elect Trump. CARB needs to consider even
contingencies that many people may consider "unthinkable", such as
what responsibilities California can and should assume if the US
EPA no longer enforces regulations or is eliminated, or if federal
climate research and data collection is scaled back or eliminated,
the diminished role of other federal agencies such as NASA, DOE,
USFS, DOI and DOD in climate and renewable energy, the risk to
objective data collection and information, and how policy changes
such as federal efficiency standards and subsidies could affect the
trajectory of GHG reductions in California, and how we can address
all of these. 

Get Consumption Estimates Right. The Energy Commission has been
consistently over-estimating growth in electricity demand for at
least the past decade. They have made important changes in the past
few years to help correct some of the worst errors, especially by
placing "additional achievable energy efficiency" into the official
forecast. In the first iteration this was significantly
underestimated, because it only included data from the three large
investor-owned utilities, but gradually this is being corrected
also. The next phase will need to incorporate the requirement in SB
350 to double additional achievable energy efficiency by 2030,
although this process will probably take a year or two. As a
consumer of forecasts, CARB should do what it can to push CEC
toward more accurate forecasting.

CEC Forecasts Lead to Gas Over-Procurement. This process time lag,
and lack of information and process feedback to planning, has been
a major factor in the gross over-procurement of natural gas
generation in California. A great example is Carlsbad, where the
"need" for a 600 megawatt power plant was established using the
2012 demand forecast. Well, guess what? The next two forecasts
reduced projected demand in SDG&E's service territory by at least
800 megawatts, more than canceling out the need for that $2 billion
plus power plant. However, there is no required review or
information feedback loop in California to correct this very
serious planning error, so--without intervention--billions of
dollars are on automatic pilot to get flushed down the toilet. The
thin ray of hope is continued efforts to block this plant in
courts, but this just shows how dysfunctional the planning process
really is.

These comments were prepared with input from Robert Freehling.