Comment Log Display

COMMENTS ON AB 32 DRAFT SCOPING PLAN, CALIFORNIA AIR RESOURCES
BOARD,   July 31, 2008    

BY SIERRA CLUB CALIFORNIA
 
Contact: Bill Magavern, Director 916-557-1100 x 102 
bill.magavern@sierraclub.org   

California Air Resources Board Members and Staff:   

Sierra Club California commends CARB’s tireless efforts in
preparing this comprehensive, far-reaching draft scoping plan.  
We believe this draft plan is moving in the right direction, and
recommend further strengthening before it is finalized in
November. Our volunteers and staff have prepared a full set of
comments, presented below.   

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Generally, we recommend the following eight crucial GHG actions
for CARB’s plan:

1) Make big polluters pay for all their emissions. Program
revenues should go toward clean  technologies, green jobs, and
cost-cutting measures for low-income consumers. CARB also should
narrowly limit offsets. 
2) Consider cap-and-auction just one tool among market mechanisms.
Other tools should be  brought forward more robustly, including
feed-in tariffs and carbon fees in the Plan’s near-term action
agenda. 
3) Give the 33-percent renewable electricity standard by 2020 the
force of law, either through  legislation or regulatory action. 
4) Promote and enable Community Choice Electricity Aggregation
(CCA) and its potentially powerful GHG reductions.  
5) Give more specificity and amplitude to the goal of electrifying
transportation, especially greatly expanding ZEV numbers (plug-ins
and electric cars) beyond CARB's currently too low projected
levels.  
6) Greatly strengthen the too-modest land use and agricultural
sections of the Plan. 
7) Bolster requirements for zero waste and recycling, as well as
Extended Producer Responsibility (EPR).  
8) Ensure that actions to reduce greenhouse gases also help,
whenever possible, to clean up California’s unhealthy air. 
   
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OVERALL COMMENTS:
    
•  We are pleased that the draft Plan seeks not only to meet the
law’s requirement of rolling back our greenhouse gas emissions to
1990 levels by 2020, but also sets a pace of greenhouse gas (GHG)
reductions  adequate to meet the scientifically established goal
of an 80% reduction by 2050. 
• Scientists now suggest that goal itself may be inadequate. We
suggest the Plan incorporate intentional redundancies that
anticipate the possibility that urgent action is more pressing
than current assumptions would indicate.   
• CARB’s Plan may wish to make explicit that a “cap” on GHGs may
not entirely be commensurate with the scale of the problem. We
must first reduce the growth of CO2 emissions; next reduce total
CO2 emissions; next reduce the growth of total CO2; and then go
beyond that to reduce total CO2 in the  atmosphere.  
• California cannot afford delay in reducing pollution that causes
global warming. The potential costs of inaction or delayed action
are much greater than the cost of implementation now.   
• We support the inclusion of co-benefits, such as public health
improvements and better energy efficiency, from GHG reductions.  


Comments by section: (page numbers refer to pages in draft Scoping
Plan)   

 II. PRELIMINARY RECOMMENDATIONS    

A. ROLE OF THE STATE: SETTING AN EXAMPLE (p. 12)    
• We support efforts to get the State to lead by example, and
encourage immediate implementation of all the actions listed, plus
more to be identified.    

B. EMISSIONS REDUCTION MEASURES   

1. California Cap and Trade Program Linked to Western Climate
Initiative (p. 15)    

Direct Emission Reductions: We are glad that the Plan proposes
that most of the required emissions in GHGs will come from
performance standards that directly reduce emissions, such as
California’s clean car, renewable energy, and energy-efficiency
programs, and incentive programs like the Solar Initiative, with
only 21% proposed for the Cap-and-Trade Program. If possible, we
would like to see that percentage made even lower.    
• If California establishes a cap-and-trade program, we strongly
recommend it require 100% auction in order to be fair to everyone,
including consumers and producers. 
• Revenues raised by fees and/or auctions should go toward clean
energy technologies, public transit,  environmental mitigation,
green jobs, and aid for low-income consumers. We’d also like to
see that funding used to provide training in renewable energy job
skills for people now working in the fossil fuel industry.    •
Aligning with the Western Climate Initiative (WCI) could dilute
California’s program and result in fewer emissions reductions and
more delays, unless California can bring other states up to higher
standards than WCI is currently recommending. The WCI Draft Design
Recommendations on Elements of the Cap-andTrade Program states
(WCI page 15): “The WCI recommends each Partner auction a minimum
percentage, between 25 percent and 75 percent, of its allowance
budget.” If California agrees to this, it could mean that between
25% and 75% of emissions allowances will be given away for free to
the biggest  polluters in the state.  
• The WCI proposal creates an enormous loophole by allowing all
reductions through 2016 to come from offsets, rather than direct
reductions in capped sectors. CARB should require power and oil
companies to  invest in renewable energy and cleaner
transportation rather than to pay someone else in some other
jurisdiction to reduce their pollution instead. Any offsets should
be limited in number and subjected to rigorous criteria (See more
discussion below in Section C-3). 
• We are also concerned about how WCI’s  recommendations for
cap-and-trade and offsets relate to concerns of the environmental
justice community: Will offsets be international? Will this amount
to “exporting” GHG emissions overseas?  We note that among WCI
member states California is the only state with an official
environmental justice advisory committee for climate issues, and
we are disturbed by the failure of the WCI process to attend to EJ
concerns. 
• California should not allow emissions trading with any
jurisdiction that does not have a hard emissions  cap of AB
32-like stringency because such trading would remove the assurance
that our emissions reductions were real. The WCI proposed baseline
of 2012 would create a perverse incentive to drive up emissions
between now and then, which is the opposite of the action needed. 

• No trading in emissions should be allowed if it causes hot spots
that exacerbate air pollution at the local level, especially within
communities already beset by environmental justice issues.  
• Aggressive steps need to be taken to guard against leakage by
measuring the carbon emission of electrical  generation consumed
in CA at its actual point of production.  
• Every product manufactured in the world today has its own carbon
footprint—the carbon emissions associated with the production of
that product. To maintain a fair market for California goods, CARB
 should require that producers of emission-intensive products
imported for consumption in California purchase the same emissions
allowances that California producers must when they sell their
products in the same market. Similarly, emissions associated with
products produced in California but exported should  be allocated
to the exporting state or nation rather than California. Any other
principle would sorely disadvantage California industries and act
as a powerful lever for driving additional jobs offshore.    

2. California Light-Duty Vehicle GHG Standards (p. 20)  

• We support implementation of the Pavley “Clean Cars” standards,
which continue to call for reduction  of global warming pollution
from personal vehicles. While the Pavley standards will help us to
meet 2020 requirements for greenhouse gas reductions, California
needs more improvements in vehicle technology before 2020 in order
to meet our 2050 goals. The state should immediately begin a
dramatic shift toward  plug-in hybrid electric vehicles and
battery electric vehicles to begin the ramp-up needed to meet 2050
greenhouse gas reduction goals. This should be stated specifically
in the Plan to make sure it is implemented.   
• The state should immediately create a Battery Electric Vehicle
Partnership with industry to speed the electrification of its
light-duty vehicle fleet. 
• The minimum goal of 7,500 Zero Emission Vehicles (ZEVs)
currently required by the Zero Emission  Vehicle Program in
2012-2014 is grossly inadequate. CARB should establish a goal of
hundreds of thousands of ZEVs in that timeframe, and recommend
increased funding for immediate development of plug-in hybrid
vehicles and infrastructure for all plug-in vehicles.  
• CARB should create a program and incentives to encourage
conversion of the100,000 hybrids now in use to plug-in hybrids,
and mandate all appropriate state fleet vehicles be plug-in or
zero-emission vehicles.    

3. Energy Efficiency (p. 21)   

• We support all the energy efficiency efforts listed by CARB. In
fact, we believe that even greater  reductions in the pollution
that causes global warming can be gained by further strengthening
efficiency and conservation efforts.  
• For example, the Plan’s goal of 32,000 gigawatt-hours of
electric power demand reduction by 2020 falls  far short of the
economic potential for 60,000 gigawatt-hours of savings if all
technology options are included (as described in the California
Energy Commission 2007 Integrated Energy Policy Report, p. 98).  
• The mandatory Green Building Standards Code update scheduled for
2010 needs to be strengthened.  CARB pressure could help.   
• Can CARB provide more detail in terms of the three measures in
CR-1 (separate out the expected reductions from the three
strategies outlined)?   
• By 2020, California should be able to go well beyond the SB 1470
goal of only 0.1 million tons of annual reductions from solar water
heating, through encouraging public private partnerships.  
• CARB should look at using independent providers and the
Standard-Offer model to administer energy efficiency
implementation, as opposed to utilities. The California Public
Utilities Commission investigated this in 2002 and concluded that
independent providers were more cost effective, particularly for
residential  customers.   

4. Renewables Portfolio Standard (p. 24)    

• We are pleased to see CARB’s recommendation for a 33% Renewables
Portfolio Standard for electricity providers. This forward-thinking
measure should be quickly given the force of law for all utilities,
either by  regulatory action or by legislation.  
• Community Choice Aggregation (CCA) allows city and county
governments to pool the electricity-buying power of all local
customers, which could help meet (or even exceed) the 33%
renewable energy  level. CCAs in advanced development stages, such
as Marin County and San Francisco, include 51% renewable
requirements in their plans. CCA is one of the most powerful GHG
reduction measures available to cities and counties to comply with
their responsibilities under AB 32. CARB’s scoping plan  should
spell out CCA authority as a key tool provided under California
law (AB 117, Migden) that grants local governments full power in
planning for their energy supply.  
• CARB should also recommend restructuring state law to allow more
favorable renewable energy price  structures, such as feed-in
tariffs, which ensure full compensation for renewable energy
costs, plus a fair rate of profit.   
• Feed-in Tariffs (FiTs) need explicit backing in CARB’s scoping
plan. FiTs are efficient tools for speeding  adoption of renewable
electricity generation and stabilizing market prices of new
technologies. Already used in more than 37 countries, and under
consideration in Michigan, Minnesota, Illinois and Rhode Island,
FiTs establish a price for renewables — guaranteed for 20 years or
more — based on the cost of  producing that electricity plus a fair
profit. These rates usually have a modest impact on customer bills
compared to conventionally generated electricity. (In Germany, for
example, the FiT cost to consumers equals the price of a loaf of
bread per month.) FiTs allow manufacturers and renewable project
developers  to predict demand, and to invest with confidence.
California should model its FiTs on those programs that have
achieved significant growth of renewables. A FiT in California
should be tied to meeting the state’s goals for renewables.   
• As the California Energy Commission’s recommended in its 2007
Integrated Energy Policy Report, any carbon trading system reduce
allowances according to an appropriate evaluation of the effects
of the renewable portfolio standard — in order to avoid oversupply
of allowances.    5. Low Carbon Fuel Standard (p. 25)    
• We are looking forward to implementation of a Low Carbon Fuel
Standard that accounts for all environmental impacts on a life
cycle basis.  
• However, we are disappointed that the draft Scoping Plan
contains no explicit projections for carbon  reductions from
implementation of a rigorous Zero Emission Vehicle (ZEV) program.
An ambitious ZEV program, plus plug-in hybrids, could achieve
significant GHG savings.  
• The plan should include specific requirements for automakers to
sell hundreds of thousands of zeroemission vehicles annually by
2020.   

7. Sustainable Forests (p. 27)   

• Because forests remove carbon dioxide from the atmosphere and
sequester carbon in vegetation as well as wood products, forests
can make important contributions to reduction of greenhouse gasses
in the  atmosphere. 
• In general, the Plan sets very modest targets for contribution
from the forest sector. We encourage CARB to set a more aggressive
goal. As indicated in appendices, the 5 MMTCO2E target is
essentially what the forest sector is currently contributing in
terms of GHG reduction. We can do better. 
• Sierra Club California has serious concerns about essentially
delegating the development of a plan for the forest sector to the
Board of Forestry, Department of Forestry and Resources Agency. We
strongly urge  CARB to assert and maintain a leadership role in the
forest sector. History has shown, time and again, that Board of
Forestry is unlikely to take the necessary bold and visionary
steps to solve this (or any other) serious problem.   
• It should be remembered that three of the nine seats on Board of
Forestry are reserved for the timber industry, and are currently
held by employees of Sierra Pacific Industries, Timber Products
Company, and Hearst Corporation. A fourth seat is designated for
Range & Livestock, and is held by a former Farm  Bureau lobbyist.
These four members who directly represent the regulated community
generally vote as a block, and stonewall any proposals that may
run counter to the economic interests of their constituents. 
•There is also a substantial question as to what extent the Forest
Practice Act empowers Board of Forestry  to address climate change
issues. Indeed, Section 4513 of the Act states the intent of the
California Legislature as follows:  

 “4513. Intent of Legislature. It is the intent of the Legislature
to create and maintain an effective and comprehensive system of
regulation and use of all timberlands so as to assure that: (a)
Where feasible, the productivity of timberlands is restored,
enhanced, and maintained.  (b) The goal of maximum sustained
production of high-quality timber products is achieved while
giving consideration to values relating to recreation, watershed,
wildlife, range and forage, fisheries, regional economic vitality,
employment, and aesthetic enjoyment.”   

The Board of Forestry’s proclivity toward inaction and catering to
the interests of the timber industry, combined with its lack of
clear authority to adopt regulations addressing climate change and
carbon  sequestration, lead us to believe that it would be more
appropriate for CARB to adopt the rules necessary to achieve
appropriate contributions from the forest sector.   

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Comments on Specific Recommendations in the Scoping Plan
Appendices   

Forest Practice Rules Mechanisms:   

Improvements to California’s Forest Practice Rules to address
wildlife and water quality issues can also lead to additional
carbon sequestration. For example, there is currently an Emergency
Rule Petition pending at the Board of Forestry that would improve
habitat protections for critically endangered coho  salmon.
Amongst other changes, the rule package would require retention of
additional large trees near watercourses to provide shade, and
allow large wood recruitment into streams to improve the
complexity of stream structure. These rules would also lead to
permanent retention of additional carbon.   

CEQA Mechanism:   

It is widely acknowledged that the conversion of forestland to
other uses has substantial adverse impacts on habitat, water
quality and carbon sequestration. Unfortunately, the current
regulatory process has substantial weaknesses that prevent
adequate state-level oversight. The current regulatory process
needs to  be strengthened to discourage conversion of forestland,
and to require substantial mitigation when forests are converted
to other uses. Reducing forestland conversions will have the
related benefit of managing the ever-increasing fire suppression
challenge in California, which is seriously exacerbated by
development in  and near forestland.  

Implementing Strategies: 

Forest Biomass:   

Forest biomass for heat and power can provide positive carbon
benefits compared to fossil fuels. When gathering biomass from
forests, it is critical that the biomass be a byproduct of
thinning the forest to create a healthier stand condition, rather
than harvesting a healthy forest simply for biomass.    

Afforestation/Reforestation:   

Improving the stocking of depleted or poorly managed forestland,
and replanting historic forestlands, are important and obvious
ways to improve California’s carbon sequestering capacity.
However, these activities should be approached with prudent
planning and analysis. A warming climate will change the 
distribution and composition of California’s forests, and the
frequency and intensity of fire is likely to increase.
Tree-planting activities should take these and other factors into
account, and create a distribution and density of native species
that reflects an appropriate balance between carbon sequestration
and  resiliency to changing climate and fires.  

Urban Forestry:   

Planting trees in urban environments offers myriad co-benefits:
aesthetics and increased property values, reduced energy
consumption due to increased shade, cleaner air, and increased
carbon sequestration.  Although the amount of carbon directly
sequestered may not be as large or as cost-effective as
afforestation efforts in rural parts of the state, an aggressive
urban tree planting program should be a priority forest sector
action.

Fuels Management:   

California is a fire-adapted landscape, and fire is an inevitable
and necessary part of California’s ecology. The appropriate focus
for fire policy in California is how we can co-exist with fire,
minimizing risk of injury and loss of property while respecting
ecological realities.    

Sierra Club supports the thinning of excessive surface and ladder
fuels near homes and communities to protect lives and property
from wildfires. Fire science indicates that reduction of
understory fuels is the  most important factor in preventing a
stand-replacing crown fire, and we have supported a number of
statutory and regulatory changes in recent years to streamline the
reduction of these types of fuels from priority areas.   

California’s sheer size, the relatively low value of wood products
in the current market, and the extremely high price of diesel fuel
all contribute to the need to prioritize areas meriting fuels
reduction activities.  Scattered fuel reduction projects across
the landscape are generally going to be less effective than
targeting areas of highest risk. These also tend to be the
communities where firefighters must use direct attacks to control
a fire to protect property.   

There have been a number of estimates of the carbon benefits from
fuels reduction activities and the resultant reduction in fire
severity. Some, including those from CalFire, vastly overestimate
the benefits of  fuels reduction activities. Given the extremely
speculative nature of this “benefit,” and the fact that fire is a
natural and necessary part of California’s environment, we
encourage the state to focus fuels reduction efforts (and other
proactive fire planning activities) on protecting communities.
There may be climate cobenefits to fire planning and suppression,
but trying to quantify them is difficult, highly questionable and
should be omitted from any accounting.  

Finally, CARB must include the effects of increasingly large
emissions from forest fires in its projections for forest
emissions/reductions.   

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8. Water (p. 28)    
• We support a public goods charge for funding investments in
water efficiency that will lead to reductions in greenhouse gases.
  
• We are pleased that CARB staff calls for a 20% reduction in
water use but disappointed that agricultural water use is not
included among the efficiency targets. Agricultural water use
accounts for more than three quarters of the state’s total water
use.    9. Vehicle Efficiency Measures (p. 29)    
• We are supportive of vehicle efficiency measures, such as
fuel-efficient tire standards.   10. Goods Movement (p. 29)    
• We support the ship electrification in ports approved by CARB in
2007.  
• Requiring on-dock electric rail and electric drayage would
eliminate all diesel emissions inside the port.    
• We want to know more details of the Plan’s proposed “Goods
Movement Efficiency Measures - System-Wide Efficiency
Improvements,” which CARB has predicted will yield savings of 3.5
tons.  
• CARB should work with state transportation agencies to plan
commercially viable electric rail systems  that would replace
diesel trucks and trains. That move would also reduce congestion
along California’s highways, potentially lowering total vehicle
emissions.    

11. Heavy/Medium-Duty Vehicles (p. 30)   
• We support all three proposals for aerodynamic efficiency,
hybridization, and engine efficiency.   
• We request that ARB consider requiring electrification of
medium-duty delivery trucks, as well as other means to reduce
emissions in this sector.    

12. Million Solar Roofs Program (p. 30)   
• We support the Million Solar Roofs Program and its goal of 3,000
megawatts of solar energy for homes  and businesses throughout the
state by 2017. We note, however, that some reforms in program
structure and funding may be necessary to achieve the goal.    

13. Local Government Actions and Regional Targets (p. 31)   
• The Plan should do more than just “encourage” local city and
county climate action plans. This planning  should be “required”
(the Attorney General has already sued San Bernardino to underline
this requirement’s urgency.  
• This should not be an unfunded mandate: most cities lack funding
and expertise to craft adequate climate  plans. CARB should take
the lead in devising incentives – carrots and sticks – and means
of financially assisting or persuading cities to comply. 
• The Plan should include stronger measures to reform land use
planning in ways that reduce vehicle miles  traveled (VMT). (See
Newman and Kenworthy paper on how one passenger-mile of transit
use can reduce 3–7 passenger-miles in a car.) Expand Regional
Blueprints already underway.  
• These should include transit-oriented development, walkable,
bikeable communities, mixed land uses, requiring Regional
Transportation Plans to have strong requirements for reduction of
vehicle miles traveled (VMT), and more.  
• We are concerned with how this section of the Plan deals with
land use measures. The Plan’s land use goals are not ambitious
enough. Targets are too modest. Tools identified to cope with the
problem are inadequate. And serious reflection of public health,
social and economic co-benefits of forceful action is  lacking.  
• The Plan only counts reducing 2 million metric tons (MMT) of
carbon equivalent per annum by 2020 from actions in this sector.
This is only about 1% of the total reductions. By comparison, the
Sacramento  Area Council of Governments (SACOG) blueprint could
reduce carbon emissions by roughly 1 MMT by 2020, even though
SACOG currently contains no more than 1/15th of California’s
population. 
• It is unclear why CARB acquiesced to only 2 MMT for the Plan,
which virtually equals business as usual.  An April 2007 Cal/EPA
report, “Climate Action Team Proposed Early Actions to Mitigate
Climate Change in California, Draft for Public Review,” allotted
18 MMT by 2020 to “regional transportation/smart growth land use
measures.”  
• More compact neighborhoods and less driving are the essence of
the EIR for SACOG’s Blueprint scenario. SACOG plans to devote much
less land devoted to urban uses and to cut carbon emissions while
saving farmland – providing public health and economic savings for
households and businesses where less  driving is required. 
• Although the Plan mentions “Community Energy” and “municipal
utility operations,” there is no mention of Community Choice
Aggregation (CCA), a specific authority under California law (AB
117,  Migden). CCA offers large potential for local governments to
move aggressively toward meeting or exceeding the state’s mandated
Renewable Portfolio Standards (RPS). Over 40 cities and counties
in the state have performed feasibility studies financed by the
California Energy Commission and the US  Department of Energy,
with over two dozen jurisdictions in advanced stages of planning
for actual implementation. Marin County, Oakland, Berkeley and
Emeryville, as well as San Francisco have either established or
are considering a target of 50% or more renewables for all
customers within their service  region by 2017. When achieved,
such targets represent the single easiest way for municipalities
to comply locally with whatever AB 32 stipulations may be imposed.

• Adopt and require the use of greenhouse performance standards,
goals and metrics for transportation  planning and projects. Hold
state, regional and local agencies accountable for meeting these
metrics.  
• We recommend fast-tracking regional mass transit infrastructure,
including Bus Rapid Transit programs (especially on existing
freeway HOV lanes).    14. High Speed Rail (p. 34)    
• Sierra Club has long endorsed the Altamont Pass route into the
Bay Area.  
• CARB is aware of the ongoing controversy over Altamont and
Pacheco Pass routes. We urge CARB to advise the High Speed Rail
Authority on the relative carbon footprints of competing routes
into the Bay  Area, and to assess the relative degrees of
cost-effectiveness in reducing carbon when constructed. To the
extent that CARB can bring to bear climate considerations and data
on this choice, the public will be well served.    

15. Recycling and Waste (p. 34)    
• CARB’s scoping plan should highlight more aggressively the
powerful carbon reduction potential of zero waste: first, reducing
waste by design in manufacturing process, then reusing, recycling
or composting products.  
• ETAAC submitted to CARB an excellent set of recommendations for
the waste sector but only several were included in the Plan. We
strongly urge CARB to include ALL the ETAAC recommendations for
the waste sector. 
• We commend to you the new report "Stop Trashing the Climate,"
released June 5, 2008 to mark World Environment Day. See
http://www.stoptrashingtheclimate.org/ The report, by GAIA with
the Institute for Self Reliance and Eco-Cycle, brings together
information about recycling, plus source  reduction, reuse and
composting. Further, it describes how scaling up recycling,
reusing materials and products, and shrinking the size of a
community's waste stream can greatly reduce greenhouse gas
generation and related climate damage:    

"Incinerators and landfills are relics of an unsustainable past
that have no place in our green economy. The report, "Stop
Trashing the Climate" shows that zero waste -- that is, 
preventing waste and strengthening recycling and composting -- is
one of the fastest, cheapest and most effective strategies for
confronting global warming."   - Carl Pope, Executive Director,
Sierra Club   

• CARB should implement “lifecycle tracking” of manufactured
products, giving priority to reusables and locally manufactured
items.   
• Landfill waste disposal should be phased out by requiring
recycling and making manufacturers responsible for the end-of-life
disposition of their products. Wastes should be separated,
particularly organic wastes, for effective composting. CARB should
work with the California Integrated Waste  Management Board to end
the practice of dumping green waste into landfills. 
• Alternative Daily Cover (ADC) that uses green waste or wood
waste should not be given recycling credits or counted as
recycling. This actually de-incentivizes diversion of green waste
into composting and  contained methane energy capture.  • CARB’s
suggestion to capture and utilize landfill methane gas should not
be construed as support for continued dumping of green waste into
landfills. Landfill capture of methane is far less efficient than
what  is possible with green waste separation. This is especially
crucial given that methane is a far  more potent greenhouse gas
than carbon dioxide. 
• Burning garbage arguably uses more energy than recycling, and
carbon reduction requires better options.   
• We propose statewide installation of “Resource Recovery Parks”
to include facilities for reusing, recycling, composting, and
minimizing the discarding of materials. They can also incorporate
facilities for repair services, retail sales of reclaimed products
and landscaping supplies, organically composted gardens, 
educational tours, and public amenities. Such a model park
currently operates in the city of Marina in Monterey County.  
• We believe there are many more tons of carbon reductions
possible from aggressive Zero-Waste and  recycling programs. For
example, the plan should include specific measures to increase
recycling of organics and other materials, and those measures
should have emission reduction numbers and deadlines attached to
them.   
• Extended Producer Responsibility (EPR), now CIWMB policy, needs
explicit CARB backing as a potent greenhouse gas reduction
measure.  
• CARB should explicitly reject carbon credits for landfill carbon
sequestration.   
• Successful Zero Waste initiatives require effective outreach and
educational programs so that others are advised of and can come to
appreciate the benefits. CARB should utilize the legions of young
people who are not only enthusiastic and care about waste
reduction, recycling and global warming but are also willing  to
go out and do something about it. CARB should have these
individuals help us educate our communities about the issue.
Recycling ambassador programs throughout state and local
government agencies should be instituted so that students and
other volunteers can go door to door educating residents  about
the need for and the benefits of recycling. In addition, new home
owners, apartment dwellers and other residents should receive
information after moving to a new residence that explains to them
the recycling policies in their neighborhood and encourages them
to do so. People are willing to do what it  takes to pitch in but
if they have no idea how to do it, they won't even begin. This
type of outreach should be a critical aspect of the CARB plan.   

 16. Agriculture (p. 35)   
• We are extremely disappointed with the low expectations for
agriculture. CARB’s Plan only mentions 1  potential MMT of GHG
reduction from methane capture at large dairies.  
• Many studies by California scientists and others throughout the
world have shown how organically grown crops have significantly
lowered GHG emissions, from non-use of nitrate fertilizers and
other  means.  
• Studies have shown significant methane emissions from bovine
digestion, which raises the question of whether a carbon tax
should be applied to dairy products, such as beef and milk.   
• Support for urban agriculture should be considered, especially
community gardens.  
• In Department of Conservation’s study of greenhouse gas
emissions associated with conversion of agricultural land to urban
uses, both direct and indirect emissions should be considered.
Promoting more  compact, efficient, transit-oriented urban
development will not only reduce greenhouse gas emissions from
vehicle travel but also conserve agricultural land by minimizing
conversion to urban use. 
• The Plan should reference and encourage CDFA’s development of a
strategic plan for agriculture.  Efforts to minimize conversion of
prime farmland will be helped if agricultural enterprises now on
the land maintain profitability and sustainability. 
• The Plan should emphasize that linking good land use with local
food systems can reduce transportationrelated emissions, provide a
premium for farmers selling locally, and even improve access to
healthier foods. 
• State and local governments could increase access to local
foods, for example, by direct investments,  incentives and
public-private partnerships to develop needed local foods system
infrastructure. 
• Joint action by the Department of Food & Agriculture and CARB
could significantly increase the amount of locally produced food
consumed in the state – thus reducing more emissions from 
transportation. CDFA and CARB could work together to track and
measure “food miles traveled” and seek ways to cut distances from
food to producer. Cutting down on transport of agricultural
products from agriculture areas to other parts of the state would
lessen GHG.  
• Support for urban agriculture should be considered, especially
community gardens. 
• The Plan should address turban agricultural issues, such as: a)
What funding can the state supply to assist municipalities in
supporting urban agriculture?  b)  What focus can CARB bring on
removing barriers to urban agriculture? CARB and CDFA could work
together to: find useable land for community gardens, inventories
of such land; test for toxicity; reach out to potential urban
gardeners; recast city regulations in favor of urban orchards,
edible  landscaping, local composting, and rooftop gardens; and
provide more UC Master Gardener training and technical assistance?
 c) Could CARB facilitate funding of local offices in each
municipality to inventory potentially available  state-owned lands
and mobilize local community gardeners and organizers? 
• The Plan needs to highlight the greenhouse gas reduction
benefits of organic agriculture. The California Energy Commission
Climate Change Research Conference Sacramento, September 10-13,
2007 has five  presentations:
http://www.climatechange.ca.gov/events/2007_conference/presentations/index.html

• Data from The Rodale Institute’s long-running comparison of
organic and conventional cropping systems confirms that organic
methods are far more effective at removing the greenhouse gas,
carbon  dioxide, from the atmosphere and fixing it as beneficial
organic matter in the soil. See Laura Sayre, 2003
http://www.newfarm.org/depts/NFfield_trials/1003/carbonsequest.shtml
-- Another study shows confirmed ecological virtues of organic
farming  www.pnas.org/cgi/reprint/103/12/4522.pdf
http://news-service.stanford.edu/pr/2006/pr-organics-030806.html  
 

 17. Energy Efficiency and Co-Benefits Audits for Large Industrial
Sources (p. 36)   
• We support CARB’s plan to require assessment of large industrial
sources to determine whether  individual sources within a facility
can cost-effectively reduce GHG emissions and provide other
pollution reduction co-benefits.  
• However, we are disappointed that no specific measures,
including performance standards, efficiency  programs, or direct
regulations are proposed for industry, which is projected to emit
101 MMTCO2E in 2020.  
• California’s industries (and CARB) could learn from Japan.
“According to the International Energy  Agency, based in Paris,
Japan consumed half as much energy per dollar worth of economic
activity as the European Union or the United States, and
one-eighth as much as China and India in 2005.” (NY Times, July 4,
2008)    
• High efficiency co-generation needs to be required for all
appropriate new energy installations.   

C. OTHER MEASURES UNDER EVALUATION (p. 37)    

1. Other Sector-Based Measures (p. 37)    
• We are supportive of all the measures listed as “under
evaluation.”  
• We suggest that mandatory employer parking cashout, like that
implemented by the city of Santa Monica, be added as an additional
measure to evaluate. Employer parking cashout rewards employees
that opt for  transit, carpooling, and other smart transit
choices.  
• Many other ways to reduce workplace vehicle-miles-traveled
(VMT), such as parking fee increases, telecommuting, etc. that
need further study.   • We are pleased with the mention of public
education in regard to transportation.  • We suggest that
increasing public transit services (both bus and rail) be included
among the sector-based methods.   
• We urge CARB to insure that electric power generators be held to
an increasingly stringent carbon standard, and that the carbon
standard be applied to all generators, whether under contract or
utility owned, and to all types of retail sellers of electricity
within the state.    
• We think CARB’s target of reducing coal generation 40%, or
13,000 gigawatt-hours, by 2020 is an achievable goal, provided
that utility companies are held to the renewable energy and
efficiency targets.  
• Industrial boilers, oil refineries and glass manufacturing
represent excellent opportunities to recover  waste heat for
electric generation and other purposes.  
• –CARB staff might consider a recent study by Jason E. Bordoff
and Pascal J. Noel, “Pay-As-You-Drive Auto Insurance: A Simple Way
to Reduce Driving Related Harms and Increase Equity" 
(www.brookings.edu/~/media/Files/rc/papers/2008/0417_payd_bordoff/0417_payd_bordoff.pdf).
Applied to California, the analysis indicates much larger benefits
than estimated in the Plan
(http://www.arb.ca.gov/cc/scopingplan/scopingplan.htm). This
emission-reduction estimate is about ten  times larger than the
Plan states, and the Plan overlooks co-benefits such as congestion
reductions, crash reductions and consumer benefits. 
• Here are a few of the study’s key findings. (The full paper will
be posted on the Bookings Institution  website shortly):  - An 8
percent driving reduction for light-duty vehicles - VMT decrease
by 24 billion miles;   - Less fuel consumption by 1.2 billion
gallons, based on 2006 levels.  - Direct annual CO2 reductions of
10.5 million metric tons -  Lower premiums for drivers; two-thirds
of households would save money.   
• CARB should consider and address the full life cycle of
emissions whenever possible. Unfortunately, the CPUC’s
interpretation of SB 1368 would allow about five million tons of
GHG per year per Liquid Natural Gas terminal to go into the
atmosphere without being “counted” as part of the state’s carbon
emissions, if these terminals are constructed. That’s a loophole
that should be closed: five million tons of GHG per year is
roughly equivalent to the emissions of one million cars.    

2. Carbon Fees (p. 41)    
• We are pleased that CARB has provided a positive discussion of
carbon fees. We think that the range recommended in the draft Plan
of $10 and $50/ton would be reasonable; this fee could start low
and  gradually increase over time as needed.  
• A $30-per-ton fee on all greenhouse gases would provide revenue
of approximately $12 billion per year, which is less than 1/100th
of the California economy. This money could be immediately
restored to the  state economy, encouraging local investment in
clean technologies and green jobs, activities with a bright
prospect in a carbon-constrained world. Revenues could also
provide rebates for low-income consumers.  
• We believe that it should be possible to quantify some of the
benefits from the expenditure of the funds  on projects that
provide considerable GHG emission reductions. For example, transit
operators know increased frequency of service and lower fares can
increase ridership. Recovering waste heat, either to generate
electricity or from generating electricity, has specific value to
commercial and residential utility  customers.  
• On carbon pricing, emissions fees should be analyzed along with
a cap-and-auction system, as the Plan proposes. We need the income
to fund CO2 reductions.    • Polluters always should have to pay
for cleaning up the damage they cause. Therefore, if a carbon
market is established, all emission allowances should be
auctioned. The Plan states (page 16), “These allowances could be
freely distributed to capped firms or auctioned in the trading
market.” We are  opposed to free distributions, since they don’t
encourage accountability and provide much less motivation to
reduce GHG emissions.  
• Major emitters should pay for the cost of administering this
program.  
• Sierra Club has supported the existing criteria pollutant
Indirect Source Rule (ISR) for the San Joaquin Valley. CARB should
now consider a statewide ISR that includes greenhouse gases. In
order for ISR to be effective in reducing VMT, it should
discourage developers from building far from existing services and
 jobs, and it should encourage close-in development. To this end,
the amount of the fee should be proportional to the VMT, and the
computer model used to compute a project’s emissions should
accurately account for the individual project’s VMT. As a means of
encouraging green building, reducing  energy use, and promoting
good community design measures such as mixed use and walkability,
such an ISR should follow the precedent set by the existing ISR to
incorporate fee reductions for onsite GHG reduction measures.
Remaining fees should be used for projects that reduce GHG as well
as criteria  pollutants and achieve other environmental
co-benefits.  
• Lawrence Frank’s new study, Reducing Global Warming and Air
Pollution: The Role of Green Development in California (July 1,
2008, prepared for Environmental Defense Fund), is very supportive
of ISR. CARB’s AB  32 Scoping Plan lists ISR as “under evaluation.”
 
• ISR is tested and effective and should be listed in part B of
the Plan as an emission reduction measure.   

3. Offsets (p. 43)   
• Any offsets should be limited in number and subjected to
rigorous criteria. The draft CARB Scoping  Plan suggests limiting
offsets to 10 percent of a firm's "compliance obligation." CARB
must clarify that this means that no more than 10 percent of the
emitter’s required reductions may come from offsets, not 10
percent of its total emissions.   
• We are opposed to any system that would relieve any domestic
emitter of carbon from paying for their fair share of the costs of
the carbon they emit in exchange for “offsets,” either for
internationally produced CO2 emissions or domestically for
activities designed to enhance carbon sinks, like tree planting.
While government and private support of improved soil carbon
content and reforesting are highly desirable, it is impossible to
retain the integrity and effectiveness of a program to reduce
domestic CO2 emissions if it is combined with a trading mechanism
for efforts to preserve and enhance carbon sinks.   
• We oppose trading between sources of carbon pollution and sinks,
like forests, that store carbon. The ability of forests to store
carbon should not become a justification for maintaining higher
emissions of air pollution. We need both 80% reductions in
domestic CO2 emissions and strong programs to enhance  carbon
sinks; we should not “trade” them off against each other. This
separation of carbon control systems is especially important given
the increasing vulnerability of California’s forests and other
flora owing to fire, drought and potential effects of climate
change.    

4. Use of Possible Revenues (p. 45)  
• We are supportive of most of the uses listed, particularly those
related to environmental justice, such as  “achieving environmental
co-benefits.”  
• Criteria and toxic air pollutants create health risks, and some
communities bear a disproportionate burden from air pollution. We
support ideas that benefit these unfairly impacted communities.  

• Revenues should be prioritized for projects that reduce both GHG
emissions and also provide reductions in air and other pollutants
that affect public health.     

III. ANALYSIS: Costs and Benefits (p. 49)   

While more detailed comments will be developed later in our
comments on the Appendices, specific economic benefits of energy
efficiency and clean energy measures can be evaluated based upon
the sum of:   1) projected and avoided costs for these energy
supplies,  2) in-state jobs and manufacturing due to green
economic activity,  3) federal tax credits benefits and in-state
tax revenues,   4) export revenues, and 5) environmental and
public health benefits. 
• CARB’s analysis of public health benefits of transportation
efficiency measures focuses only on  respiratory medicine and
economic benefits of reducing respiratory disease. While this
analysis provides powerful support for the Plan’s vehicle and fuel
improvements, the Plan overlooks large public health benefits to
other transportation efficiency measures not in the Plan.  
• Public health perils such as obesity, diabetes and heart disease
can be reduced by strategies the Plan should embrace more
aggressively. Auto-dependent neighborhoods make these diseases
more common; smart growth and reduced vehicle miles traveled can
help combat them.  
• CARB’s public health analysis needs to address the issue of food
security and “food deserts.” Lacking healthy food choices,
residents must travel long distances to obtain more healthy fare
or rely on expensive, locally available junk food. Although
emissions benefits of better access to healthy food may be modest,
 public health benefits can be significant and climate change
policy offers a chance for low-income “food deserts” to get
attention. 
• Gaps in the public health analysis in the Plan may stem from
lack of participation by California  Department of Public Health
in the CAT process. We hope CDPH and the larger public health
community are brought into the process of revising the Plan’s
first draft.   

IV. IMPLEMENTATION: Putting the Plan into Action (p. 65)   

A. Personal Action (p. 65)    
• We are pleased with the inclusion of Personal Action items.  
• We believe the plan needs to include specific personal actions
(coordinated with Public Outreach and  Education campaigns,
described below).  

B. Public Outreach and Education (p. 67)  
• All four strategies are excellent.  
• Funding is needed for training teachers in the climate change
curriculum.   
• The Plan should include detailed public awareness campaigns,
with budgets (funded by carbon fees), that will be used to involve
the public in all aspects of the Plan.  
• Successful implementation of California’s historic global
warming law will require a program that is open  and transparent
to the public, including performance and compliance tracking
information of all components accessible via the Internet.    

C. Tracking Progress (p. 68)   
• We are supportive of the measures proposed for tracking
progress.    

D. Enforcement (p. 70)   
• We agree that enforcement is a critical component of AB 32
implementation. CARB will need to significantly bulk up its
enforcement resources to meet this challenge. In addition, the
scoping plan should  explain the route for enforcing emission
reduction measures taken by other agencies outside CARB to hold
those agencies accountable for assuring the realization of
emission reduction measures assigned to them.   
• We support the measures proposed for enforcement, especially
including engaging local Air Quality Districts in tracking
emissions from local facilities.  
• We would support some program funding to these Air Quality
Districts to support their increased duties  under AB 32.   

E. State and Local Permitting Considerations (p. 70)
• We support including state and local permitting considerations
in the AB 32 implementation strategies.  
• We would support some program funding to the entities involved
to support their increased duties under AB 32.     

F. Program Funding (p. 71)  
• We support the measures proposed for program funding.    

V. A VISION FOR THE FUTURE (p. 73)    
• We support collaboration with key partners, as long as it
doesn’t dilute the effectiveness and speed of implementation.
California needs to stand up for a high standard of GHG
reductions, not sink to the “lowest common denominator.”   
• We applaud the planned expansion of research by California’s
universities to develop innovative solutions to all aspects of the
plan, but we cannot wait for the “perfect technologies.”    

 (For further detail on Sierra Club California’s positions, see:
http://www.sierraclubcalifornia.org/globalwarming.html.)   

Original File Name:

Date and Time Comment Was Submitted: 2008-07-31 23:32:04