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Comment 23 for 2022 Scoping Plan Update - Scenario Inputs Technical Workshop (sp22-inputs-ws) - 1st Workshop.


First Name: Martha
Last Name: Walden
Email Address: marthawalden@suddenlink.net
Affiliation:

Subject: 2022 scoping plan update
Comment:
Thank you for this opportunity. I want to limit my comments to
those categories I feel most informed about. In general I would
like to encourage the sooner the better for all categories. The
urgency is unequivocal. I don't quite understand why Alternatives 3
and 4 are even on the table. 

Oil and gas extraction: Alternative 1. Target the dirtiest fuels
for the most immediate and severest cuts. Phase out natural gas the
most gradually under condition of extremely heightened vigilance
towards orphan wells and fugitive methane emissions. Drillers and
frackers have absolutely no excuse for methane pollution. 

Electricity generation: Alternative 1. As for Alternative 2,
biomass should have no place on the RPS. Burning it emits as much
carbon as coal, plus it's very bad for the air.
 
"Low carbon" fuels: Alternative 1. Low carbon fuels are fuels of
last resort and hopefully will not be needed after 2035.  Biomass
is not a low carbon fuel. In only very specific and small-scale
applications is it appropriate and only in conjunction with
pyrolosis and perhaps bio-energy carbon capture and sequestration.
 
Hydrogen production seems to hold much promise but makes sense only
when produced by solar or wind energy.

Non-combustion methane production: Alternative 2 modified to
include a large increase in funding for AMMP.. 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.
Also, oil and gas fugitive emissions should be reduced at least 75%
by 2030. They have the capacity to do that. Only the political will
is missing.

High GWP emissions: None of the alternatives reflect the urgency of
the situation and the availability of low GWP refrigerants. The
existing bank of HFCs in California equals 60% of its annual GHG
emissions. Phasing them out will be a huge challenge that can't be
handled by the private sector--especially supermarkets, which are
the worse offenders when it comes to leakage. A big increase in
incentives will be necessary. Drop-in HFOs could be a big help, but
the natural refrigerants should be the goal. We also need more
programs for rural areas assuring that appliances are treated
correctly at end of life. Someone should also look into the way
Underwriters' Laboratory is staffed almost entirely by chemical
industry representatives. Their codes are unnecessarily hindering
adoption of natural alternatives to HFCs. CARB should increase the
reduction goal to 85% by 2030.

I believe we must set 2035 as the goal for carbon neutrality.
Everything points to a catastrophe already well on the way, but if
we do everything in our power for the next fourteen years, we may
yet have a chance.

Thank you.
Martha Walden
Environmental Journalist

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Date and Time Comment Was Submitted: 2021-10-20 20:05:44



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