First Name: | Edward |
---|---|
Last Name: | Mainland |
Email Address: | emainland@comcast.net |
Affiliation | Sierra Club California |
Subject | Sierra Club's Questions on AB32 Scoping Plan Update |
Comment |
Questions Sierra Club would like answered in the AB 32 Scoping Plan Update Overview 1. Higher goals. Will CARB consider leading the call for higher and faster state greenhouse-gas (GHG) reduction goals and renewables targets in view of new science that shows global climate disruption moving much faster than expected? Sierra Club has urged, for example, a 50-percent RPS by 2030 and an 80-percent GHG reduction considerably sooner than 2050. See Sierra Club’s letter to CARB July 12, 2013, making the case for new targets; the Governor has cited a need for a 40-percent RPS goal; leading climate scientists have called for an global 80-percent GHG reduction by 2030. 2. Near-term Threat. How will CARB give more urgent attention to reducing short-lived, non-CO2 greenhouse gases like methane, nitrous oxides, tropospheric ozone, black carbon and soot, CFCs and hydrofluorocarbons like HFC134A, which collectively have been shown to cause more near-term forcing than CO2. See UNEP’s 2011 report, Near-term Climate Protection and Clean Air Benefits. Will CARB include these UNEP recomendations in the scoping plan update? (See www.unep.org/pdf/Near_Term_Climate_Protection_&_Air_Benefits.pdf.) 3. Target anomalies. How does CARB intend to deal with the fact that the state’s targeted rate of GHG decline from 2010 to 2020 is slower than the rate needed from 2020 to 2050? How can CARB demonstrate 2035 GHG targets CARB set for SB 375 are consistent with meeting the state’s 2050 GHG goal? When will CARB revise AB 375 GHG targets for all MPOs? How will CARB deal with 2035 SB 375 targets apparently being less than what would be needed for cars and light-duty trucks to support the GHG trajectory in Governor’s Executive Order’s S-3-05? Energy 4. No More Excess Natural Gas. How does CARB justify the fact that investors expect natural gas plants to have a 40-year life, which means that plants coming on line in 2014 will be expected to be operational in 2055, when the state will have had to electricity GHG emissions to zero to meet S-3-05, since other sources, such as transportation, may still be producing GHGs? When will CARB stipulate that no more new natural gas plants need be approved or built in the state, given that CA already has a huge and growing natural-gas generation-plant surplus and that a variety of new alternatives now exist to sustainably integrate and back up coming intermittent renewable resources without more natural gas? How will CARB highlight scoping-wise the loss of San Onofre low-carbon nuclear electricity as a major opportunity to get replacement power NOT from fossil fuels (which would be a serious setback to state GHG goals) but, utilizing a higher RPS target, from renewables, efficiency and conservation? 5. Fresh Look at Alternatives. How will CARB take the lead in calling for a fresh, in-depth look at new, rapidly developing alternatives to natural gas back-up, for example, through an ad hoc interagency task force combined with scientific and technical advice from appropriate independent experts? Particularly salient among a variety of newly economically competitive and interestingly sustainable technologies are fresh battery storage modalities, including battery storage with new distributed solar PV, retrofitting existing solar and wind energy with storage, implementing new smart inverter standards, bringing on-line more environmentally acceptable pumped hydro storage capacity, more baseload geothermal, better grid management, scaled-up demand response, and so forth. 6. Barriers and Blockages. How will CARB stipulate that the state’s new renewables should be linked to regional and local capacity needs? Will CARB lend more momentum in its AB 32 scoping update to eliminating the current blockages and barriers to interconnectivity of distributed renewables? Will CARB highlight the need to reduce “soft costs” and especially permitting at the municipal level in distributed solar PV installation? Will CARB emphasize standardization and promptitude in permitting and interconnectivity? How will CARB’s AB 32 scoping update act to help resolve bureaucratic and legal indecision over where jurisdictional and operational responsibility lies for implementing robust state demand response implementation? 7. Feed-in Tariffs. Will CARB recommend an integrated, comprehensive feed-in tariff (FiT) program for the state? FiTs have been demonstrated in many countries and localities as a main driver for accelerated penetration of solar power and other renewables. Much if not most of solar power growth abroad has been due to FiTs. 8. Zero-Net Energy. Will CARB help move up the dates by which all new residences and commercial buildings built are zero-net-energy? How will CARB help accelerate the state’s efficiency retrofit program for existing structures? Will the AB 32 scoping update highlight the City of Lancaster’s “all solar” requirement for new buildings and promote it for statewide adoption? 9. Methane Problems. Why are no DOGGR (Department of Conservation) representatives included in the list of agencies involved in the AB 32 scoping update? Is not methane leakage from natural gas fracking, production, transport and delivery a significant and under-documented GHG source? How does CARB intend to spur proper measurement and correction of fugitive methane leakage? What will CARB be doing to help address the problem of methane leakage “behind the meter” through home-performance testing and time-of-sale PACE-type programs? What about the carbon intensity of fracked oil, much higher than conventional oil, as a significant GHG problem as yet unaddressed? Should not CARB require that Air Districts measure, tabulate and publicize methane emissions? Waste 10. Ban Landfill Organics. Why does the waste sector of the Scoping Plan only forecast 25% reduction by 2050 when technology exists now to divert almost all organics, plus using anaerobic digestion for the remainder, thus eliminating all future methane from landfills? Can CARB require elimination of legacy methane emissions from existing landfills by well-maintained synthetic covers? 11. Landfill Methane. When are CARB and other state regulators going to include fugitive methane emissions from landfills in the carbon footprint of landfill gas for LCFS standard and other rules? Why should landfill gas-to-energy be qualified for renewable credits when, as Sierra Club analysis and research contends, most LFGTE operations are likely to cause more rather than fewer net methane emissions? Agriculture 12. Organic Farming. Why does the agriculture section of CARB’s scoping not indicate the value of organic farming for reducing climate change compared to conventional agriculture? Can the AB 32 scoping update highlight Marin Carbon Project’s findings that composting agricultural lands materially increases carbon storage there (while also keeping organics out of methane-producing landfills and enriching depleted soils)? Transportation 13. Soot. Does CARB’s scoping properly highlight the huge climate and health co-benefits of eliminating diesel soot immediately by eliminating all older diesels, both on and off road? 14. Pricing. What will CARB be doing to remove barriers to emphasize the need for appropriate pricing mechanisms for parking and road use, increased investment in mass transit, and electrification of transportation? 15. Diesel versus CNG. What will CARB do to bring more clarity and scientific veracity to the debate about the comparative virtues or drawbacks of advanced diesel versus CNG vehicles? The recent 2012 report by MJB&A Strategic Environmental Consulting indicates, using the latest methane GWP, CNG vehicles have equivalent GHG emissions over 100 years and 31% higher GHG emissions over the next crucial 20 years. (See "Clean Diesel vs. CNG Buses: Cost, Air Quality and Climate Impacts", February 22, 2012, MJB&A, Concord, MA, 603-647-5746.) 16. Electrification. Will the AB 32 scoping update re-emphasize the broadly supported GHG strategy and benefits of electrifying (beyond fossil fuels) most transportation modes as soon as possible? 17. Highways. Can CARB underline the GHG reasons why highway widening must stop and CALTRANS’ endemic preference for highway expansion give way to GHG-sustainable modes including mass transit and others? Can CARB help force CALTRANS to actually use it “smart planning framework”, heretofore neglected, such as the Highway 5 widening included in the San Diego RTP, which was litigated by California’s Attorney General, and which has been rejected by the court as inconsistent with S-3-05? Water 18. On-bill Financing. Can CARB’s Scoping Plan’s specific recommendations include on-bill financing for end-use water efficiency? Studies in Sonoma Country have documented the sizeable impact on water conservation and related GHG reduction when new quantities of modern, water-saving appliances are financed in a PACE-like equivalent. Natural Lands 19. Natural Lands GHG Capture. Sierra Club applauds CARB’s inclusion of the role of natural landscapes, vegetation and ecosystems as an asset in carbon reduction. What can CARB do more to ensure existing data are properly aggregated and tabulated to properly document carbon sequestration of natural lands and the value of conserving them? As a basis for offsets, however, considerable caution should of course be exercised. |
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Original File Name:
Date and Time Comment Was Submitted: 2013-08-05 10:28:07 |
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