Addressed to: Chair
Randolph and Members of the Board
Subject: Comments
on Scoping Plan – Proposed Scenario Plan or Alternative 3 is
Not Acceptable with Respect to Plans Detailed for CCUS
There are numerous
deficiencies one can identify in the Proposed Scenario Plan not the
least of which is that it ranks third in its effectiveness and
speed at climate mitigation. However, I have chosen to focus
my comments on those aspects of the plan surrounding carbon
capture.
I
urge
CARB to pursue a more ambitious alternative that reaches carbon
neutrality by 2035 with minimal to no reliance on carbon capture
and sequestration (CCUS), most particularly no CCUS on fossil
fuel or bioenergy infrastructure. All four Alternatives in
the Scoping Plan including the Proposed Scenario Plan, propose
building new fossil fuel infrastructure. Rather than building
new fossil fuel infrastructure, the Proposed Scenario Plan should
pursue additional renewable energy and storage technologies, such
as the plans proposed for the Natural and Working Lands portion of
the Proposed Scenario. The case is made in various sections of
the plan that the cost of adding renewable power sources and
accompanying infrastructure is less costly than building new fossil
fuel plants and infrastructure. Therefore, from strictly a
financial POV, would not the funds expended for unproven
technologies fostered by fossil fuel companies be best spent on
Mother Nature and her great expertise and experience at
sequestering CO2? As the various alternatives presented in
the Scoping Plan makes clear this could be accomplished through
direct support of Natural and Working Lands projects.
The funding and support
proposed for CCUS in the Proposed Scenario could be redirected to
establish or expand financial mechanisms that support ongoing
deployment of healthy soils practices and organic agriculture
(e.g., regenerative farming). In words lifted from the Draft
Plan “…Natural and Working Lands—to ensure that
they play as robust a role as possible in incorporating and storing
more carbon in the trees, plants, soil, and wetlands that cover 90
percent of the state’s 105 million acres.”
It is appreciated
that the Proposed Scenario does recognize past reductions in the
role of offsets in the program was in recognition of ongoing
concerns raised by environmental justice advocates regarding the
ability of companies to use offsets for compliance instead of
investing in actions on site to reduce GHG emissions. It is a
given that the fossil fuel companies will continue to
‘greenwash’ all efforts to reduce their responsibility
for GHG emissions and the climate catastrophe humanity and all life
on this planet are facing. Oil and gas companies use deception to
avoid/dodge their climate responsibilities. We must reject their
efforts.
On somewhat of a side note,
I would like to take issue with the draft document in general. It
was made abundantly clear in the Executive Summary of the Draft
2022 Scoping Plan that “This is a plan that aims to shatter
the carbon status quo and take action to achieve a vision of
California with a cleaner, more sustainable environment and
thriving economy for our children. When final, this ambitious
plan will serve as a model for other partners around the
world (my emphasis added) as they consider how to make their
transition.” This point is made all that more poignant
because “…CA is not only the fifth largest economy on
the planet, but ultimately could be one of the most
energy-efficient economies, with a track record of demonstrating
the ability to decouple economic growth from carbon
pollution.” However, what is a bit disturbing is that
the Executive Summary does not appear to emphasize CCUS role but in
the body of the document the reader comes away with a quite
different version. It cannot be overemphasized that the
chosen plan scenario must pursue direct emissions reductions and
not rely on or fund carbon capture.
There will always be some
exceptions, of course, but only the most extreme cases should be
considered (e.g., cement manufacture where it is not currently
feasible to achieve the high temperatures strictly by renewable
energy sources).
Finally, please correct in the Executive Summary and
elsewhere in the document the definition of “green
hydrogen”. A footnote indicated that “For the
purposes of the Draft 2022 Scoping Plan, “green
hydrogen” is not limited to only electrolytic hydrogen
produced from renewables”. This is incorrect-it is widely
accepted that green hydrogen is defined as hydrogen produced using
only renewable energy sources.
Sincerely,
Mark
D’Andrea, Concerned Citizen
7772
Rocio Street
Carlsbad, CA 92009
Email:
mdandrea825@gmail.com
Cell:
760-4