Comment Log Display

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.