California Agency to Vote on Climate Change Plan

After a year and a half of work, the California Air Resources Board (CARB) is poised to vote on an updated statewide climate plan. The final draft of the plan incorporates ambitious targets for achieving carbon neutrality by 2045, which were updated in September to reflect new legislation and Governor Gavin Newsom’s push for stronger action.

At its December 15 and 16 meeting, CARB will vote on the final version of the plan, which is known as the 2022 Scoping Plan. This will be the public’s last opportunity to comment on the plan and its targets.

Compared with earlier drafts, the final plan accelerates emissions reductions and transition away from fossil fuels. It includes more ambitious targets to reduce driving by 25 percent by 2030 and 30 percent by 2045. The final draft also includes updated targets for achieving 100 percent clean electricity, as required by a new state law that shifted the target date from 2045 to 2035. The agency also included a new goal of 20 gigawatts in offshore wind capacity by 2045 in the final draft. A gigawatt is enough energy to power 100 million LED bulbs.

The final draft of the scoping plan more explicitly incorporates fossil fuel reduction targets than earlier drafts. Rather than treating these reductions as an indirect consequence of other measures, the plan includes direct fossil fuel reduction targets, moving toward a 94 percent reduction in liquid petroleum and 86 percent reduction in total fossil fuel demand by 2045.

Despite these improvements, the most recent draft of the scoping plan offers little more than an outline of intended objectives to meet the state’s climate goals. It doesn't indicate how the state plans to achieve them. It doesn’t discuss the roles of regulations, the cap-and-trade program, or funding, nor does it spell out the role that equity should play in deciding among or implementing potential policy tools. There's also no detailed guidance for state agencies.

Lack of an Implementation Strategy

According to CARB staff, the plan is intended to be a guiding document for other agencies that have authority to implement specific rules and standards. However, by leaving many of the key decisions to other agencies, the planning process has not provided a strategic forum for debating key implementation options and their implications.

Advocates and members of the Environmental Justice Advisory Committee (EJAC), which provides detailed recommendations to CARB, have also expressed concerns about the lack of a clear implementation strategy in the plan. During the final EJAC meeting, committee members also pointed out that the plan doesn't contain instructions or recommendations to state agencies for prioritizing overburdened communities and low-income households.

These communities, many of which are overburdened with pollution, have the most to gain from decarbonization, but they often have the least capacity to invest in clean alternatives and suffer the greatest vulnerability to potential cost burdens associated with the transition to a clean energy economy.

Moreover, the lack of clear direction from CARB means that advocates and communities face many long and disjointed battles ahead as they advocate for specific implementation policies one agency — and one rulemaking — at a time.

These communities, many of which are overburdened with pollution, have the most to gain from decarbonization, but they often have the least capacity to invest in clean alternatives and suffer the greatest vulnerability to potential cost burdens associated with the transition to a clean energy economy.

Forecasts of residential electric bills, household incomes, and housing costs indicate that electricity will become less affordable between now and 2025. Due to several factors, including the war in Ukraine and closures and maintenance at refineries in the state, Californians also recently paid up to $2.61 more per gallon of gasoline that the rest of the country, which disproportionately hurt low-income households who commute the longest distances for access to work and basic services.

Without a coordinated strategy and clear direction from CARB to prioritize reducing fossil fuel pollution in impacted communities and ensuring that everyone has affordable access to clean energy upgrades and renewable energy sources, the most vulnerable communities in the state could once again be left behind.

Reliance on Carbon Capture and Storage

The second major concern EJAC members and advocates raised is the plan’s reliance on harmful and unproven carbon capture and storage (CCS) technology, rather than larger, more direct reductions in fossil fuel use and its associated emissions. This could potentially threaten overburdened communities that are already disproportionately exposed to health impacts of fossil fuel combustion.

Instead of prioritizing strategies to directly reduce carbon emissions and co-pollutants from the industrial sector, CARB is envisioning that CCS will be employed to address residual emissions — those emissions estimated to remain even after the state implements all proposed carbon emission reduction strategies. The plan currently estimates that industry will begin construction of CCS projects as early as 2028.

At a CCS symposium in Stockton in September, Jennifer Wilcox, an official with the U.S. Department of Energy’s Office of Fossil Fuel Energy and an expert in CCS technology, said that while CCS can be a tool for sectors that are hard to decarbonize, such as cement manufacturing, “CCS is not the right solution for refineries because it is not cost effective, and is not able to effectively capture carbon or help with air pollution from multiple air streams.”

Wilcox also reminded regulators that “every dollar spent on CCS is a dollar not spent on renewables.”

What’s Next?

California’s climate scoping plan is one of the most comprehensive and ambitious state climate plans in the country, and it should be adopted. However, much like previous scoping plans, the 2022 version lacks a coordinated vision and does not sufficiently prioritize pollution reduction in overburdened communities, identify concrete strategies for extending the benefits of clean energy to all, or identify strategies to protect low-income households from potential costs of a clean energy transition.

It is unclear whether CARB will consider amendments to the plan at this week's meeting, and it's uncertain what impact the final round of comment from the EJAC and the public will have on regulators. Whether or not it accepts additional changes, CARB and other state agencies should move forward and take affirmative steps to ensure that California takes advantage of its opportunity to better protect its residents from climate change and deliver climate and environmental justice to low-income communities and communities of color.