As a concerned citizen
of these United States, I have my following concerns about the
proposed CARB Draft Scoping plan. The chief of them are below:
1.
The draft plan does not demonstrate that
California is on track to even meet the legally mandated goal of at
least a 40% reduction in greenhouse gases by 2030.[2] Short-lived
climate pollutants are particularly unlikely to achieve a 40%
reduction.
2.
The draft plan does not follow AB 32’s
requirement that California achieve “the maximum
technologically feasible” emission reductions, using the most
cost-effective methods.[3] “Air board officials
said they will propose the option that has the least impact on the
economy rather than accelerating the pace of achieving carbon
neutrality.”[1]
Scientific Issues
1.
The draft plan will not keep global
temperatures close to what scientists say will avoid
catastrophe. The world has only ten years to cut
greenhouse gas emissions by 50% if we are to attain the goal.
President Biden has committed the United States to a 50% reduction
by 2030. Yet the draft plan may not achieve even 40% by 2030.
2.
The science of climate change requires
front-loading our response. “If mitigation
pathways are not rapidly activated, much more expensive and complex
adaptation measures will have to be taken to avoid the impacts of
higher levels of global warming on the Earth system.”[4]
3.
California’s goal should be at least an
80% reduction in emissions by 2030. A former
coordinating author of the Intergovernmental Panel on Climate
Change and Professor of Sustainability at UC Berkeley, Daniel
Kammen, Ph.D., set out a scientifically backed and feasible program
for California in 2021. It calls for an 80% reduction in emissions
by 2030.[5]
4.
The draft plan only aims for an 80% reduction
emissions by 2045. The draft
plan’s reliance on carbon capture and sequestration (CCS) or
direct carbon capture (DAC) to balance 20% of our emissions is more
than New York (15%) and far more than the State of Washington
(5%).[6]
5.
Neither CCS nor DAC should be counted on as
scalable. The March 28, 2022 IPCC
report on the capacity of different actions to reduce greenhouse
gases puts CCS as the least effective and most expensive of the 43
climate actions the IPCC evaluated for deployment prior to 2030.[7]
Environmental Justice Problems
1.
The draft plan drags out elimination of
pollution that disproportionately affects poor people and people of
color. But rapid elimination of GHG pollution costs less than the
health costs of continuing pollution.[8]
2.
The Environmental Justice Advisory Council
(EJAC), which advises the CARB Board, has demanded faster and more
comprehensive measures than in the draft plan so as to protect
disadvantaged communities, particularly those suffering from air
pollution.[9]
Short-lived Climate Pollutants (SLCPs)
1.
The draft scoping plan recognizes the
importance of SLCP abatement but not the importance of moving very
quickly.[10]
2.
Reduction of emissions from HFC refrigerants
having thousands of times more warming effect than carbon dioxide
must be greatly accelerated.[11]
3.
The draft plan expects to reduce
fugitive emissions of methane by 50%, but it needs to be higher in
California to keep global warming to no more than
1.5°C.[12]
Cap and Trade
1.
Highly reputable critics of the Cap and Trade
program, a market-based carbon pricing method used in California,
believe the program may not be able to achieve even its limited
emission reduction goal by 2030.[13]
2.
As a market-based mechanism, the Cap and Trade
program does not reduce major sources of pollution fast enough.
CARB should consider replacing parts of it by direct
regulation.[14]
The people of
California and the world are watching what choice you make. Make
sure it's the truly right one.