From family farmers to biofuel investors, over 900 people and advocacy groups submitted comments on California’s draft plan for achieving carbon neutrality by 2045. In their comments, environmental advocates and justice groups expressed three major concerns with the state’s draft “scoping” plan. First, the plan fails to recognize the urgency of transitioning to a clean energy economy. Second, it relies too heavily on unproven technology. And third, it fails to specify concrete implementation measures.
Act Faster
Environmental organizations and justice groups are concerned that the California Air Resources Board (CARB), the agency charged with developing a new scoping plan and overseeing the state’s climate strategy, picked a transition pathway with a target of 2045 rather than 2035. Groups like the California Environmental Justice Alliance warn that the proposed 2045 target will perpetuate fossil fuel use and its unacceptable impacts on climate, air quality, and health, which disproportionately burden low-wealth people of color.
CARB justified its selection by citing cost and feasibility concerns. However, the Community Environmental Council, the Natural Resources Defense Council, and other groups argue that reducing and/or offsetting all carbon dioxide emissions by 2035 — or even 2030 — is attainable and deserves more thoughtful consideration.
In addition, many environmental advocates argue that specific sectors can decarbonize more quickly than currently planned. The Sierra Club, Climate Reality Project’s Bay Area Chapter, and the Central Coast Alliance United for a Sustainable Economy are among those calling on CARB to accelerate the target for a clean, renewable electric grid as well as the phase-out of fossil fuel extraction and refining. The Sierra Club and Climate Reality Project’s Bay Area Chapter, joined by the Community Environmental Council and the Asian Pacific Environmental Network, are also urging CARB to expedite the transition to 100 percent zero-emission vehicle sales.
In short, advocates want a response that reflects the urgency of the current climate emergency.
Avoid Unproven Technologies
Environmental organizations also warn against relying on technologies that have yet to be proven reliable, cost-effective, and safe, such as those that would capture and store carbon emissions underground or in the ocean. The Sierra Club, Hammond Climate Solutions Foundation, and the Asian Pacific Environmental Network are just a few of the advocacy groups concerned about the proposed reliance on carbon capture, utilization, and storage (CCUS) technologies.
Many advocates share concern about the burden communities already disproportionately affected by toxic pollution (also known as “environmental justice (EJ) communities”) will endure as a result of CCUS technologies. If California is to rely on CCUS, many advocates warn that this will only extend the use of fossil fuels and further burden EJ communities. Earthjustice and the Sierra Club fear that CARB has overlooked the potential that CCUS will increase air pollutants, which will be felt disproportionately by EJ communities.
Additionally, groups urge CARB to prioritize natural solutions over unproven technologies. Investments in natural carbon sinks, such as forests, soil, and oceans, which absorb more carbon than they produce, and urban greening, such as planting trees in cities, are better ways to reduce emissions, advocates note.
CARB has not engaged in a proper analysis of the role natural and working lands, such as farms, ranges, and forests, could have when it comes to reducing emissions, according to the Nature Conservancy and the Marin Conservation League. Without a proper investigation of natural emission reduction efforts, advocates warn that California will not be able to make an informed decision about emission reduction strategies.
Be More Specific and Collaborative
Many groups argue that the plan needs to include more specific and coordinated actions and strategies to achieve stated goals. Groups like Civic Thread and the Climate Center recommend that CARB describe in more detail its coordinating role and specific actions to encourage collaboration across state agencies, local governments, and other regional entities to support emission reduction efforts.
The mayor of Hayward, California, the Association of Councils of Governments, and the San Francisco Bay Area Regional Energy Network have recommended that CARB include actions to facilitate collaboration between local governments and establish regional support networks. In addition, San Diego Gas & Electric Company and Northern California Power Agency urge CARB to encourage coordination and collaboration across agencies and local governmental bodies.
The California Farm Bureau recommends CARB specify the mechanisms to be deployed to protect natural and working lands moving forward. The Pacific Forest Trust, sharing a similar concern, urges CARB to provide a clearer vision for implementation to achieve the targets set out for forest restoration and protection. The draft plan acknowledges the importance of centering justice to alleviate the burdens experienced disproportionately by frontline communities (those in or near areas that are more likely to experience pollution, flooding, and other harmful climate and environmental impacts). But it lacks actions that will ensure justice is carried out. CARB can only do so by detailing and committing to concrete actions. In our comments, the Center for Progressive Reform joins other environmental advocates in urging CARB to pursue more specific strategies to achieve a clean energy transition that centers on justice.
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Clare Henry | September 7, 2022
From family farmers to biofuel investors, over 900 people and advocacy groups submitted comments on California’s draft plan for achieving carbon neutrality by 2045. In their comments, environmental advocates and justice groups expressed three major concerns with the state’s draft “scoping” plan. First, the plan fails to recognize the urgency of transitioning to a clean energy economy. Second, it relies too heavily on unproven technology. And third, it fails to specify concrete implementation measures.
David Hunter, Shade Streeter, William Snape, III | September 1, 2022
Our hemisphere’s shared natural heritage is threatened. The Convention on Nature Protection and Wild Life Preservation is a low-risk, high-reward pathway for the Biden administration to strengthen our strategic relationships in the hemisphere.
Grace DuBois | August 31, 2022
Climate change poses a serious threat to occupational health and safety. Workers — especially low-income workers and those who work outdoors — are particularly vulnerable to rising temperatures and increasingly frequent extreme weather and other climate-related disasters.
Daniel Farber | August 19, 2022
Production and combustion of fossil fuels impose enormous costs on society, which the industry doesn't pay for. I want to talk about some options for using the tax system to change that.
Alexandra Rogan, James Goodwin | August 18, 2022
With the signature of President Joe Biden, the Inflation Reduction Act (IRA) now marks the most significant climate policy action the United States has ever taken. The defining feature of this law is that it seeks to wring carbon dioxide emissions out of the U.S. economy by relying heavily on policy "carrots," like subsidies, instead of policy "sticks," such as regulating the fossil fuel industry or attempting to capture the external costs of greenhouse gas emissions through carbon pricing.
Alexandra Rogan, James Goodwin | August 18, 2022
The Inflation Reduction Act (IRA) will subsidize our nation's clean energy revolution and have a positive impact on climate-driven economics, as noted in Part I of this series. That said, the IRA isn't flawless. Notably, it includes several subsidies for fossil fuels, which will be counterproductive as our nation works toward its climate goals. Worse still, not all "carrots" for clean energy technologies are good, and the IRA includes a potentially bad one. Specifically, the IRA risks subsidizing the clean energy transition through perpetuating environmental injustice in how we obtain and use energy to fuel our economy.
James Goodwin | August 10, 2022
After more than 50 years, the Clean Air Act is due for an upgrade to account for changing circumstances. We can now recognize how the law is insufficiently attentive to the realities of structural racism and systemic disparities in environmental protections. Polluters have exacerbated these problems by weaponizing uncertainty to oppose stronger protections for those who need them most. In speaking to both challenges, the Public Health Air Quality Act would help ensure that the Clean Air Act is well positioned to continue serving the American people for the next 50 years.
Daniel Farber | August 8, 2022
What wetlands and waterbodies does the Clean Water Act protect? Congress failed to provide a clear answer when it passed the statute, and the issue has been a bone of contention ever since. The Biden administration is in the process of issuing a new regulation on the subject. Normally, you'd expect the Supreme Court to wait to jump in until then. Instead, the Court reached out to grab Sackett v. EPA, where landowners take a really extreme position on the subject. Not a good sign.
Sophie Loeb | August 4, 2022
On July 27, I had the privilege of testifying at the North Carolina Utilities Commission (NCUC) public hearing regarding the Duke Energy Carbon Plan. The Asheville hearing was one of six forums designated for public witness testimony on the proposed decarbonization plan. In 2019, North Carolina joined 34 other states investing in solar, wind, and other renewable resources when it passed its Clean Energy Power Plan, and, in 2021, when it passed House Bill 951, which commits to a 70 percent carbon reduction by 2030 and carbon neutrality by 2050. When Duke Energy, a major corporation with outsized influence over the state’s decarbonization plan, submitted its proposal to meet those goals, it failed to account for affordability and equity.