Advocacy at the California Air Resources Board (CARB)

Part 3 CA State Code

California’s landmark Global Warming Solutions Act of 2006 (AB 32) requires close collaboration by the Air Resources Board, Public Utilities Commission, Energy Commission, and Independent System Operator to implement the reduction of greenhouse-gas (GHG) emissions in order to obtain 100% of the state’s electricity from zero-carbon sources by 2045. CEERT’s Climate Program works to strengthen CARB’s GHG Scoping Plan and to lower the current target for GHG emissions.

Recent Developments:

CEERT and allied NGOs are advocating for the lowest feasible power-sector GHG target in CARB’s Scoping Plan Update. The first draft of the Scoping Plan met with widespread criticism, following which CEERT has helped organize a broad campaign of public and editorial support for a much stronger plan.

Critical errors in the draft Scoping Plan start with reliance on flawed assumptions in E3’s Resolve Capacity Expansion Model, which says we need to build 10,000 megawatts (MW) of new gas plants and fails to recognize sharp increases in gas prices and their impacts on rates. The draft Plan proposes much too long a timeframe to get to 100% clean energy, compared with the adopted plans of the Los Angeles Department of Water and Power (LADWP) and the Sacramento Municipal Utility District (SMUD), and opts to deploy carbon capture and sequestration to provide alternative carbon neutrality, which they claim, without evidence, would be a less expensive path.

CEERT’s Mark Hanin has been attending CARB board meetings on the Scoping Plan Update and monitoring monthly calls of the Scoping Plan Working Group. He reports that, following a series of Community Listening Sessions around the state, CARB staff expect to release the final draft for discussion at the Board’s September 1 meeting, with a likely vote on approval in November.

Mark notes that the CARB Board instructed staff to add a sensitivity analysis to the final draft of the Scoping Plan to address concerns raised by members of the public on the effect that different projects proposed in the Plan will have on their communities. He reports that the Union of Concerned Scientists will be drafting a letter to the CARB Board, in collaboration with the California Environmental Justice Alliance (CEJA) and Earthjustice, on the overreliance that the Scoping Plan places on Carbon Dioxide Removal, which staff view as a net economic-growth benefit.

V. John White participated in a CARB hearing on the draft Scoping Plan in Sacramento, and attended one of the listening sessions in Oakland, as well as a virtual hearing the week of August 8. His comments focused on increasing the transparency and accuracy of modeling assumptions, tracking progress on achieving actual emission reductions, accelerating clean energy targets, and establishing an independent scientific advisory panel on Carbon Removal, Capture, and Storage/Sequestration to review scientific, technical, and economic feasibility costs and impacts on disadvantaged communities.