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Dear Chairperson Liane Randolph,
Thank you for the opportunity to comment on additional Scoping Plan
alternatives for 2022.

In general the extent of the consequences of climate change that we
are experiencing already makes it clear that we have to accelerate
change in every sector. So I believe the Carbon Neutral by 2035 is
worth setting as our goal. That is 14 years from now. It is
difficult to imagine the severity of climate change in 14 years.
And even if we achieve carbon neutrality by then things will get
worse for 25 to 30 years.  We don't really have a choice do we?

Specifically, on phasing out  oil and gas extraction we need to set
a limit. The sooner the better, so 2035 if not earlier. The IEA has
said that there is already more than enough oil and gas and coal
under production to take us past the 1.5C threshold. CCS will be
necessary but it should not offset or permit the continuation of
refineries.

The same reasoning applies to electricity generation. We need to be
all renewables by 2030 so that the changes to electrify
transportation and housing will actually move us toward our goal.

In residential housing, appliance in existing buildings should be
all electric when new by 2030 and all electric by retrofit except
in a relatively few big ticket items where it makes more sense to
replace with electric at end of life.

On cement and steel I don't think the options provided are
sufficient. We may need to use carbon capture and sequestration,
but I believe that technological changes in production will obviate
most of this need.

Low carbon fuels should not exist after 2035. Biomass is not carbon
neutral in the short term and probably will not be in the long run.
In addition, biomass waste should be used for alternatives that
sequester carbon rather than combusting it. 

In a similar way, only electrolytic hydrogen made from solar or
wind should be used in creating hydrogen. This is an area of great
research activity and should be encouraged by CA. Other forms of
hydrogen generation should not be supported in any way by the state
as ultimately those sources of hydrogen (e.g., hydrogen created
from biomass) will be producing greenhouse gas emissions.

For non-combustion methane production, Option B is necessary.
Ultimately the number of cattle in the world must be reduced
drastically, especially CAFOs. But in the meantime there is no
realistic alternative to digesters for all large farms and large
landfills. A large increase in funding for AMMP is also required.

HFC options are not appropriate. By 2025-2027 there will be options
available for refrigeration, air conditioning, and refrigerated
transportation with GWP of 15 or less. These should be required on
a time table that gives manufacturers a change to provide options
to the market. The biggest problem is the existing bank of HFCs.
Especially for supermarkets the state will need  to massively
increase incentives in order to have the stores with GWP of 1450 to
4000 switch to natural refrigerants. These stores are too low
margin to pay for the change themselves and since systems are
almost never replaced in entirety (just piecemeal as components
burn out), we will get nowhere if we wait for "end of life"
replacement. This is one area where CARB should increase ambition
quite radically, including setting a goal of reducing HFCs from the
2013 level by 85% in 2030 and 95% by 2035.

Carbon removal from the aid does not seem to be a technology that
CA can set realistic goals for at this point in time. 

These same comments are in the attached PDF.

Respectfully,
Daniel Chandler, Ph.D.