Comment Log Display

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