Comment Log Display

On behalf of the Association of Environmental Professionals (AEP),
Climate Change Committee, we appreciate the opportunity to provide
comments on the November 7, 2016, Public Workshop on the 2030
Target Scoping Plan Update: GHG Policy Scenarios, Natural & Working
Lands, and Public Health Analysis. This supplements our comments
provided to CARB on June 8, 2016 on the 2030 Target Scoping Plan
Concept Paper. 

AEP is a non-profit organization of California’s environmental
professionals. AEP’s Climate Change Committee (Committee) members
are actively involved in supporting California cities and counties
in the evaluation of greenhouse gas (GHG) emissions impacts for new
development subject to the California Environmental Quality Act
(CEQA), preparing communitywide GHG emissions inventories and
forecasts and developing Climate Action Plans (CAPs). 

The update to the Scoping Plan to address the 2030 target in Senate
Bill 32 (SB 32) and Executive Order B-30-15 is of great interest to
the Committee and our CEQA and climate action planning work with
California cities and counties, especially as it relates to local
target setting for climate action plans/GHG reduction plans. The
Committee supports CARB in its challenging work to establish a
working framework for achieving the next milestone in GHG
reductions for California. The Committee published two white papers
in 2015 and 2016 (update attached) that examine in detail the
challenges for both CEQA practice and local climate action planning
related to post-2020 GHG reduction targets and many of us are
already engage in developing local CAPs that include post-2020 GHG
reduction goals. As a result, we are concerned that the proposed
policies for local plan level goals extend too far into local
policy decision-making by specifically identifying a local target
for climate action plans. The committee is also concerned that
establishing a community-wide goal for 2050 will immediately shift
the focus of CEQA and Climate Action Plan target setting to the
2050 goal, for which no clear path is certain for local governments
and which will result in an ineffective and speculative focus on
2050 at the expense of the real and urgent necessity to focus on
meeting the ambitious 2030 goal.