Comment Log Display

Thank you for the opportunity to comment on the SB 32 update
scenarios.These comments come from the perspective of physicians
who are  active in climate and health spheres. Health and equity
are guiding principles for our  work. Any scenarios must weigh the
health benefits of action, the health risks of actions not taken or
displaced,  as well as direct or indirect health harms of actions. 


First and foremost, as the American Lung Association  has said so
clearly "any scenarios in the Scoping Plan must rely on "direct
near-term emission reduction strategies that cut harmful
pollution".  Strategies must prioritize "ramping down of all
combustion sources as quickly as possible , with the goal of
exceeding the 2030 statutory standards and achieving carbon
neutrality as quickly as rapidly as possible."   We agree
entirely.

Unfortunately, the current scenarios do not meet those parameters.

Scenario 1 is implausible, while scenarios 2,3 and 4 include 
Carbon Capture and Storage. Carbon Capture and Storage raises many
significant health concerns which are covered below. These serious
health concerns mean that we  need scenarios that do not rely on
CCS. It is possible to achieve our emission goals without relying
on CCS.   Such scenarios should be developed. 


Reliance on non-direct emissions reductions.  

 The time frame of action of any strategies must be carefully
considered, not just their possible future contributions. 
Emissions reductions must be frontloaded to have the most benefit,
and to allow some margin to increase goals and targets  as the
science is likely to demand.  That means that any solutions that
are out of phase with needed emissions reductions must not be
relied on in the scoping plan, but rather seen as areas for future
research, innovation or deployment. We cannot kick the emissions
can down the road.  We cannot have a hamburger today, with the
promise that we will pay for it Tuesday (reference to Wimpy and
Popeye).  This includes  not just CCS, but also Nature based
offsets such as growing forests, whose time for sequestration is
measured in decades, and whose viability is threatened by the
drought and heat of climate change itself.  Nature based offsets
are not as secure as had been expected -   as we have seen already
this summer with wildfires burning carbon offsets in the North.
Even nature based soil sequestration is at risk, as heat and
drought threaten to aridify large areas of California.  In
addition, offsets may serve to allow continued pollution -
especially in already overburdened communities, who would benefit
much more from direct emissions reductions - both for their health
and their pocketbooks. 

Health concerns related to Carbon Capture and Storage

It is especially disturbing to see consideration of Carbon Capture
and Storage in these scenarios that are focused on the near term -
for the next 5 years.Technologies like CCS and DAC, which may hold
promise for the future, but which have thus far failed to meet the
scale or scope of the problem, must not be relied on. Where the
objective is to remove and sequester CO2 at scale,  the technology 
and safety are not established.  

 Some would argue that CCS or more likely Direct Air Capture
technologies may become necessary at some time in the future. It is
too early to say whether that will be necessary and whether it will
be possible - it is not at all clear that the technology can scale
adequately.   Nonetheless,  CCS and its variations should NOT have
any consideration in a scoping plan addressed at the next decade,
and certainly not for  the next 5 years. It is clear that spending
resources on CCS diverts funding from proven technology that we
know has tremendous co-benefits for health, especially in
communities currently suffering disproportionate burdens. 

Reliance on CCS threatens to lock in fossil fuel use and
infrastructure now for some hoped for future benefit which is
entirely uncertain. Rather  the majority of CCS is  used to enhance
oil extraction, further harming surrounding communities and the
climate. 

CCS perversely worsens the pollution burden on already impacted
communities. Studies have shown that running CCS equipment actually
requires power plants to burn more fuel - and release more
pollutants.  Attempts to limit increased pollution burden with
after the fact monitoring and penalties are in no way adequate. 
Monitoring is often inadequate, does not prevent the actual
pollution and health harms, and penalties are often no disincentive
- rather they are seen just as a cost of doing business. 

CCS can threaten water supplies as well  - an issue of special
concern here in CA as we experience what is widely expected to be a
megadrought of many years duration. CCS increases demand for water
at the plant - by a substantial 50-90%.  Its injection underground
leads to water contamination  by acidifying the water and promoting
leaching of arsenic, uranium, radium, cadmium, chromium, copper,
lead, mercury and selenium into the water at levels that exceed
federal drinking water standards.


The direct health hazards associated with CO2 pipelines must also
be considered. CO2 is an asphyxiant.  Its transport under high
pressure is risky - with high likelihood of leaks. 

Finally, for CCS to be a benefit, it must be capable of safely
sequestering CO2 for hundreds of years, yet our ability to evaluate
long term storage is completely inadequate.

For reference and specific citations  I would refer you to the
references in the report  from the Science and Environmental Health
Network 
​​https://www.sehn.org/sehn/2021/9/14/the-low-down-on-carbon-capture-and-storage
 and the paper by Professor Mark Jacobson 
https://web.stanford.edu/group/efmh/jacobson/Articles/Others/19-CCS-DAC.pdf

In conclusion, we would like to see a scenario which is plausible,
does not rely on future sequestration, and does not include Carbon
Capture and Storage.  Such a scenario is possible, and should be
developed. 

Thank you for your consideration of these comments.

Sincerely, 

Cynthia Mahoney MD
Clinical Assoc Prof, Stanford, (ret)

Wendy Ring MD, MPH

Jeffrey Mann, MD