June 24, 2022
Chair Liane M. Randolph
California Air Resources Board
1001 I Street
Sacramento, CA 95812
RE: Concerns regarding draft 2022
Climate Change Scoping Plan
Dear Chair Randolph:
We, the undersigned Members of the
Legislature, appreciate the California Air Resources Board’s
(CARB) work on the draft 2022 Climate Change Scoping
Plan. This 2022 Scoping Plan is critically important
because it not only provides the statutorily required five-year
update to the 2017 Scoping Plan, but it will establish the
framework for California’s climate action to achieve carbon
neutrality in the next 20 to 25 years.
Hence, this 2022 Scoping Plan will have the longest planning
horizon of any Scoping Plan to date.
As such, it is imperative that this 2022 Scoping Plan
provide the necessary framework for California to achieve its
climate goals.
We are deeply concerned with the current
framework proposed in the draft 2022 Scoping Plan. The draft
plan:
·
Focuses on long-term climate goals at the
expense of near-term action.
Makes overly ambitious assumptions relating
to the performance of Carbon Capture and Sequestration (CCS) and
Carbon Dioxide Removal (CDR).
·
Focuses on long-term climate goals at the
expense of near-term action.
·
Makes overly ambitious assumptions relating to
the performance of Carbon Capture and Sequestration (CCS) and
Carbon Dioxide Removal (CDR).
·
Relies too heavily on CCS and CDR.
·
Lacks ambition on direct emission
reductions.
The most recent United Nations
Intergovernmental Panel on Climate Change (IPCC) report states that
“rapid emission cuts in this decade are necessary to minimize
the risk of exceeding the 1.5°C temperature increase.”
Whether we can make those steep reductions in greenhouse gas
emissions now will determine whether we will be able to avert the
most catastrophic climate impacts in the near future.
We are running out of time. We respectfully request
the Board to reject the proposed draft and direct CARB staff to
revise the draft in order to address the concerns discussed
below.
1.
The draft Scoping Plan focuses on long-term
climate goals at the expense of near-term
action.
SB 32
(Pavley, 2016) requires a GHG emission reduction target of 40
percent below 1990 levels by 2030. Based on the latest data from CARB on 2021 GHG
emissions, our state’s emissions are approximately two
percent below that of 2019 levels. This is well short of the trajectory needed to
meet the 2030 GHG target under SB 32, which would require a four
percent reduction each year.
Yet, the draft plan only briefly discusses why any concerns
about reaching the 2030 GHG target should be addressed in a future
cap-and-trade rulemaking.
Further, the lack of details and analysis on
exactly how the cap-and-trade program would serve to close the gap
in emissions reductions is concerning. The draft plan assumes cap and trade will
“close the gap” but frames the program’s role as
providing a steadily increasing price on emissions, not an actual
limit on emissions.
This leaves no basis to assess the current program design
against its assumed role in the plan going forward.
2.
The draft Scoping Plan makes overly ambitious
assumptions relating to the performance of Carbon Capture and
Sequestration and Carbon Dioxide Removal.
CARB is
assuming CCS devices have a capture rate of 90 percent, which
appears to be a very optimistic assumption. Based on information
from other CCS projects, the actual capture rates reported falls
well below the 90 percent target. The Petra Nova CCS project in
Washington, one of the largest CCS plants in the world, reported a
33 percent capture rate, while the Shell Quest CCS project in
Canada reportedly only captured 48 percent of carbon
emissions.
The
draft plan fails to provide a contingency plan should these
technologies fail to deliver on the expected emission
reductions. Moreover,
it is questionable that the reductions will manifest immediately,
given the need for required steps such as permitting and device
installation. The
draft plan anticipates reductions to take place within the refining
sector beginning in 2023, which appears unrealistic.
3.
The draft Scoping Plan relies too heavily on
Carbon Capture and Sequestration and Carbon Dioxide
Removal.
The
proposed draft relies on CDR to deal with 18.5 percent of emissions
of total emissions in 2045 and relies on CCS to reduce emissions at
petroleum refineries. We are concerned with the extent to which the
draft plan is relying on such technologies for emissions
reductions. As mentioned above, it is unclear whether these
technologies have the capacity to make that level of reductions.
Additionally, the use of CCS and CDR is not without controversy.
There are a number of concerns raised about the use of these
technologies, ranging from questionable net emission reduction
benefits to its impacts on local air and water quality.
Additionally, the planned use of CCS for
petroleum refineries is incongruent with California’s overall
climate goal, as it would serve to extend the life of refineries
and continue our reliance on fossil fuels.
4.
The draft Scoping Plan lacks ambition on
direct emission reductions.
The
proposed draft would reduce emissions by less than 80 percent by
2045, with only 63 percent coming from direct emission reductions.
This target is less ambitious than targets adopted by New York,
which requires 85 percent reductions, and Washington, which
requires 95 percent reductions. The Legislature is currently
contemplating legislation that would require 90 percent of
emissions be reduced.
SB 32,
AB 398, and AB 197 all required CARB to prioritize both direct
emissions reductions at large stationary sources of GHG emissions
and direct emission reductions from mobile sources, as well as
direct emissions reductions from other sources. The proposed draft
fails to maximize strategies that would provide more aggressive
direct emission reductions, such as increasing the sector reduction
targets or accelerating electrification in various sectors like
clean vehicles and buildings, or moving towards a coordinated
fossil fuels phase out.
In sum, California can do better than
this. We call for a
climate roadmap that is ambitious and places direct emission
reduction at the center of its strategy. We need an actual plan that clearly details how
California will achieve its 2030 goal, especially since our annual
rate of progress is clearly not on target to achieve that goal. We
cannot provide goals in the plan without more details on how to get
to the goals. We need more details in the plan to properly inform
policy and regulatory work.
We simply can do better. Let’s keep California a climate
leader.
Sincerely,
Al Muratsuchi, Assembly District
66
Luz Rivas, Assembly District 39
Cristina Garcia, Assembly District
58
Richard Bloom, Assembly District
50
Laura Friedman, Assembly District
43
Mark Stone, Assembly District 29