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Comment 49 for 2022 Scoping Plan Update – Initial Air Quality & Health Impacts and Economic Analyses Results Workshop (sp22-econ-health-ws) - 1st Workshop.
First Name: Hari
Last Name: Lamba
Email Address: hlamba101@gmail.com
Affiliation: Brighter Climate Futures
Subject: Comments on Alternative 3
Comment:
Liane Rudolph, Chair May 3, 2022 California Air Resource Board RE: Comments by Brighter Climate Futures - Alternative 3 will not get us there Proposing instead an "Alternative 5" Instead that will get us zero emissions, plenty of clean energy and expanded carbon sink ecosystems. Our group stands ready to present the energy, emissions, economics, business development and timeline aspects if you will give us the opportunity to do so. Dear Chair and Members of the Board, During the recent workshop on your Scoping Plan, your staff indicated that they favored Alternative 3, as presented. Alternative 3 will not get California to Carbon Neutral by 2045. Already wildfires are devastating California and recently the Governor massively increased the wildfire management budget to over $500 billion but with very little for the energy transition. By pursuing Alternative 3 the wildfire management budget to grow tenfold by 2045, and the climate mitigation and transition (transition to renewable energy and emissions reductions) budgets to shrink. If you wish to get to a 100% reduction in greenhouse gas (GHG) emissions by 2045 (23 years from today), only strategies that reduce GHG emissions of about 4% per year will get you there. We talk of grid reliability, but one talks of climate change "reliability", the only action that will get you there for sure is reductions in fossil fuel emissions and replacement of all of them with renewable energy in direct and stored forms. Alternative 3 will not get us there for the following reasons: 1. Adding 10GW of natural gas power plants will only increase GHG emissions from the energy sector. 2. We already have a super example of carbon capture and storage (CCS) - it's called fossil fuels. Our dear planet has done us a big favor by capturing carbon out of the atmosphere over hundreds of millions of years and storing it in fossil fuels, thereby cooling the atmosphere of our Earth and making it favorable for our species and life as we know it. Digging them up, burning them and emitting the carbon back into the atmosphere and then turning around and trying to capture the carbon by technological means and then store it makes no sense. Why not keep the carbon captured in fossil fuels buried in the ground? The planet has already done it for us for free. CCS and DAC (Direct Air Capture) are expensive unproven technologies that we should not waste our money on - if you have to include them, put them on notice that you will only agree to them if they prove themselves and do it with no GHG emissions. 3. Most of California's GHG emissions came from transportation. Alternative 3 does very little to put forward a program for reducing emissions from gasoline and diesel vehicles. 4. California has 15 refineries. Alternative 3 does little to begin to reduce the extraction, import, refining and use of oil that will help the refineries transition out of oil to forms of renewable energy. 5. California is currently suffering much from poor air quality (there are many non-attainment areas), mainly due to the burning of fossil fuels in energy, transportation and off-road engines, although admittedly legacy activities like wood burning fireplaces also add to it in winter. The adverse health aspects of especially particulates even of less than PM2.5 size have much more economic impacts than Alternative 3 calculates. With Alternative 3, we will be also more prone to steadily worsening air quality from wildfires. 6. The carbon capture and storage in natural working lands is a beneficial aspect, but this has more benefits in terms of protecting biodiversity and helping our ecosystems survive under the increasing stress of climate change related drought that we are suffering increasingly from. Besides, the actual carbon absorption by any kind of land is tough to quantify and much depends on actual management. Hence, it is our suggestion that we do not rely on quantitative calculations of carbon absorption, unless we engage in a massive effort to expand ecosystems, and quantify the actual carbon absorbed in practice by measurements and evaluations. In tabular form, here is what we propose instead by the way of "Alternative 5" S.No. Sector or Area Actions 1 Electric Power Replace existing natural gas power plants in a systematic programmed manner with solar plus battery power plants but with strict requirements for minimum environmental impact of large Solar PV power plants - but also to minimize added electric transmission line requirements and costs, such power plants should be located near the original fossil fuel power plants, so as to use the existing electric transmission lines as much as possible. 2 Road Transportation Replace all road fossil fuel vehicles with zero emissions vehicles (battery electric or fuel cell vehicles using green hydrogen) on a programmed annual basis to target the absence of fossil fuel vehicles by 2045. All EV charging should be matched with a corresponding increase in solar energy close by and an increase in green hydrogen and fuel cell vehicles produced using solar (and wind and geothermal) energy. 3 Off Road Units Replace all off road vehicles and units (lawn mowers, leaf blowers, etc.) with electric vehicles and units. These units have high pollution and have very little pollution controls. Agricultural machines including tractors can be included in this legislation. 4 Transit Transportation & High-Speed Rail All existing or new transit modes or added transit systems must be zero emissions, with the use of solar and battery systems, and innovative so as to provide lower cost and greater area coverage. Target the reduction of vehicle miles traveled and aviation and tourism emissions, with maximum links to pedways and bikeways 5 Electrification All sectors should be electrified with replacement of use of fossil fuels with electric uses, and the added electrical energy all provided by renewable energy power plants. All existing uses should be retrofitted in a programmed manner: Sectors to include industry, homes & buildings, ships, and ports. - For transportation, EV charger installation, permitting, interconnection by utility and quality/reliability issues need to be addressed through combination of legislation, enablement of cities and funding 6 Added Electrical Power All the added energy due to electrification to be mostly met by distributed solar - behind the meter rooftop, front of the community microgrids, small solar near consuming communities, for EVs and solar for transit and high-speed rail. Mandate increased customer benefits for rooftop solar and reduced transmission access charges for electric users. Electrical transmission lines, sub-stations and points of interconnection only to be added for replacing large fossil fuel facilities for large Solar PV plus battery installations (with green hydrogen electric power generation to be added later, similar to Intermountain Power Project of the Los Angeles Department of Water and Power) 7 Green Hydrogen What cannot be electrified must rely on chemically stored forms of renewable energy, such as green hydrogen from electrolysis and green ammonia produced ONLY by use of renewable energy, with the development of programs for the production, storage, transport, and end uses of green hydrogen in all sectors. This should aim at overcoming the variability of renewable energy and supplying an energy dense portable non-carbon transportation fuel. 8 Methane Emissions Reductions Methane emissions must be reduced by elimination of fossil fuel uses, reduction in animal agriculture (especially CAFOs - concentrated animal feed operations), and avoidance of biowaste going to regular landfills, and instead being composted in industrial scale composting facilities. Carbon sink agriculture will then benefit from such increases in composted fertilizer. 9 Carbon sink Coastal Ecosystems Expansion of coastal ecosystems, especially in all bays along the coast for example with sea grasses, salt marshes and oyster reefs. The 30 by 30 program should be expanded to include the expansion of coastal wetlands to absorb more carbon and increase ocean biodiversity and revive fisheries. 10 Carbon sink Land Ecosystems All ecosystems identified in the 30 by 30 program must be restored and then expanded with massive reforestation and expansion of land-based wetlands but combined with strategies for wildfire management and wildlife biodiversity enhancement. Lumbering strategies need to transition to sustainable forestry, a banning of clear cutting, and include creating breaks for wildfires. One sure way of storing carbon in land is a massive afforestation program of say 20 million hectares to add standing forests, and from urban and agroforestry 11 Carbon sink agricultural systems Green revolution type chemical agriculture should be replaced by organic and natural farming but with massive increases in compost added (e.g., composted biowastes), and crops that need less water, pesticides, and herbicides with electrification of all agricultural equipment or transition to fuel cells using green hydrogen 12 Air Quality Pass legislation and empower and challenge all Air Quality Management Districts to begin controlling the major sources of pollution and accompanying greenhouse gas emissions in their areas - vehicles, off road engines, refinery emissions, wood burning, ports, ships, boats, locomotives, etc. 13 Jobs, Economy & Just Transition California already leads the world and has the most renowned Silicon Valley. California now needs to take the lead in business and technology solutions to climate change, new, green and clean energy technologies, through encouraging and funding R&D (Research and Development), and in incubating and accelerating low and zero carbon businesses, and in developing their needed infrastructure and end uses. In this way, California can provide a role model for the replacement of fossil fuels and provide a just transition for fossil fuel workers and companies. Such new businesses and jobs will help the state transition from its current fossil fuel economy, and replace the jobs lost in the fossil fuel sector Our group is available to present to your Board and in a future workshop, the quantitative aspects of energy transitions, costs, benefits, technologies and fossil fuel emissions reductions and natural absorptions. Thanks for allowing us to comment on your workshop! Regards, Dr. Hari Lamba Brighter Climate Futures Richmond, CA 94805 www.brighterclimatefutures.com
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Date and Time Comment Was Submitted: 2022-05-03 22:48:37
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