COMMENTS
ON AB 32 PROPOSED SCOPING PLAN,
(Issued by California Air Resources Board,
October 15, 2008)
SUBMITTED BY SIERRA CLUB CALIFORNIA, November
19, 2008
To California
Air Resources Board Members and Staff:
Sierra Club California commends CARB’s
forward movement on this comprehensive, far-reaching AB 32 Proposed Scoping
Plan. It can ultimately be a model for
the nation and the world. The
Plan will help California build a stronger, cleaner economy that will create
jobs, protect us from oil price surges, and reduce pollution that causes
climate disruption.
Sierra Club welcomes this opportunity for comment. At this critical decision point,
and in ensuing years as AB 32 implementation measures are developed in more
detail, Sierra Club will continue to press for those high-priority measures
most likely to move us forward quickly to a low-carbon energy economy while
maintaining fairness and equity.
CARB’s Proposed Scoping Plan is moving in the right
direction. We support the ten specific
changes on pages 3-4. We recommend further strengthening, however, before the
Plan is adopted in December. Sierra Club’s volunteers and staff have prepared a
full set of comments, presented below.
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Our
top priorities for changes in the Proposed AB 32 Scoping Plan:
1) Concentrate on carbon fees to
generate revenues, but if cap-and-trade is used, CARB should commit to a rapid
implementation of 100% auctioning of allowances. If offsets are allowed, they must be very
limited, located only within or near our state’s border, and have no adverse impacts
on environmental justice. Program revenues should go toward GHG reduction
programs, such as clean technologies, green jobs, and aid for low-income
consumers and small businesses.
2) Increase the goals for
emissions reductions from lower vehicle traffic by enforced regional land use
planning requirements.
3) Require commercial recycling
and take meaningful steps toward for zero waste and Extended Producer
Responsibility (EPR).
Additional
priorities include:
1)
Consider cap-and-auction just one tool among market mechanisms. Other tools
should be brought forward more robustly, including feed-in tariffs and carbon
fees in the Plan’s near-term action agenda. See details in the following pages.
2)
Make sure the 33% renewables
electricity standard is achieved before 2020, either through legislation or
regulatory action. Promote and enable
Community Choice Electricity Aggregation (CCA) and feed-in tariffs as
potentially powerful GHG reduction mechanisms. Implement the CPUC RPS Report, October
2008, which states (p. 10): “If the state is required to generate 33% of its
energy from renewable resources by 2020, then all new procurement of new energy
resources between now and 2020 must be entirely renewable energy, except some
new fossil for peaking capacity and to replace aging fossil plants critical to
renewable integration.”
3)
Give more specificity and amplitude to the goal of electrifying transportation,
especially greatly expanding ZEV numbers (plug-ins and electric cars) beyond
CARB's currently too low projected levels.
This would reap huge GHG
reductions.
4)
Place a higher priority on reducing methane emissions, since the Plan greatly
underestimates the significance of methane emissions by using the 100-year
global warming potential. Over a shorter time horizon, methane accounts for 17%
to perhaps well over 30% of the state’s GHGs, rather than the 5.7% indicated in
the 2004 inventory.
5)
Ensure that actions to reduce greenhouse gases also help, whenever possible, to
clean up California’s unhealthy air, especially in already highly impacted
areas.
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Sierra Club Comments Table of Contents
Top Priorities.................................................................................................................................. 1
Additional Priorities....................................................................................................................... 2
Sierra Club Overall Comments.................................................................................................... 3
A. ROLE OF THE STATE: SETTING AN EXAMPLE......................................................... 4
B. ROLE OF LOCAL GOVERNMENT: ESSENTIAL
PARTNERS................................... 4
C. EMISSIONS REDUCTION MEASURES............................................................................ 4
1. California Cap and Trade Program........................................................................................ 5
Offsets.......................................................................................................................................... 6
2. California Light-Duty Vehicle GHG
Standards...................................................................... 7
3. Energy Efficiency...................................................................................................................... 8
4. Renewables
Portfolio Standard................................................................................................ 9
5. Low Carbon Fuel Standard.................................................................................................... 10
6. Regional Transportation-Related Greenhouse
Gas Targets................................................ 10
7. Vehicle Efficiency Measures................................................................................................... 14
6. Goods Movement..................................................................................................................... 14
9. Million Solar Roofs Program.................................................................................................. 15
10. Heavy/Medium-Duty Vehicles.............................................................................................. 15
11. Industrial Emissions............................................................................................................... 15
12. High Speed Rail...................................................................................................................... 15
13. Green Building Strategy........................................................................................................ 15
14. Recycling and Waste.............................................................................................................. 16
15. Sustainable Forests................................................................................................................ 19
16. Water...................................................................................................................................... 20
17. Agriculture............................................................................................................................. 20
D. Public Health and
Environmental Justice Issues………………………………………….
22
E. VOLUNTARY EARLY ACTIONS AND REDUCTIONS............................................... 23
F. USE OF ALLOWANCES AND REVENUES.................................................................... 23
III. EVALUATIONS................................................................................................................... 24
IV. IMPLEMENTATION.......................................................................................................... 24
V. A VISION FOR THE FUTURE........................................................................................... 26
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OVERALL
COMMENTS:
•
We are pleased that the Proposed Plan seeks to meet the law’s requirement of
rolling back our greenhouse gas emissions to 1990 levels by 2020.
•
Scientists now suggest, however, that goal of 1990 levels by 2020 may be
inadequate. The Plan now wisely incorporates intentional redundancies and a
“margin of safety” that could anticipate the possibility that urgent action is
more pressing than current assumptions would indicate. The GHG concentration in the atmosphere may
be at the tipping point, as evidence of the newly recognized rapid release of
arctic permafrost and seabed methane gives us even less time for GHG reductions
before runaway warming takes over.
•
We welcome this Plan’s statement that California cannot afford delay in
reducing pollution that causes global warming. The potential costs of inaction or
delayed action are immeasurably greater than the cost of implementation now.
• CARB's plan, which relies predominately on direct
regulations for the electricity and transportation sectors to reach the state's
2020 emission reduction goal, sets a standard for other states and the federal
government in most areas. However, there
are substantive flaws in the plan’s approach to “cap-and-trade” and “offsets.”
• Sierra Club strongly supports the new plan's promises
to cut more emissions than previous drafts did. We also support the plan’s
proposal to include: auctioning of emission allowances to polluters; more
limitations on offsets; recognition of much higher potential for recycling and
zero waste; more momentum for significant changes in current land use and
transportation planning; and more emphasis on green job creation in the fields
of clean power and energy efficiency. The Plan now makes a stronger case for
the economic and health benefits of clean energy.
• The Plan correctly points out that many powerful
parallel policies must be pursued in order to remove all the state's market
barriers and regulatory impediments to GHG reduction. State climate programs need the full force of
CARB’s backing to such parallel measures as Feed-In Tariffs, Carbon Fees and
Community Choice Electricity
•
We support the inclusion of co-benefits from GHG reductions such as public
health improvements and better energy efficiency.
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Comments by
section: (page numbers refer to pages in Proposed Scoping Plan and Appendices)
II. RECOMMENDED ACTIONS
A. ROLE OF THE
STATE: SETTING AN EXAMPLE (p. 24)
•
We applaud the explicit commitment of the state government to lead by example,
with a target of a minimum of 30 percent reduction by 2020. We encourage immediate implementation of all
the actions listed, plus more to be identified.
B. ROLE OF LOCAL GOVERNMENT:
ESSENTIAL PARTNERS (p. 26)
• We are pleased that SB 375
requires CARB to work closely with local governments to establish strong
regional targets for greenhouse gas reduction through the SB 375 process.
• We believe CARB’s goal for
local governments of a 15% GHG reduction from current levels by 2020 is
feasible.
• CARB should set a higher goal of
at least 11 million metric tons in greenhouse gas reductions to be achieved
from reductions in vehicle miles traveled. We believe research supports the
feasibility of a higher goal.
• CARB should provide substantial
technical and financial assistance to local governments, in addition to
guidance protocols, to help them reduce greenhouse gases from transportation
and land use, as well as other sectors, including energy and recycling. These governments are fiscally hard-pressed
by the economy's downturn and credit collapse. Many are facing employee
layoffs. They do not have the talent or
expertise to devise and execute such GHG plans. They also need financial and
technical assistance from state and federal sources; compliance will be
difficult without that aid.
• SB 375 is insufficient by
itself. Needed also are tools for local
governments to translate GHG reduction targets into local action.
• CARB should actively promote and facilitate
Community Choice Electricity Aggregation (AB 117, 2002), which Sierra Club
believes is the single most potent step municipalities can take to quickly
reduce their greenhouse gas emissions substantially in the next decade.
See more discussion below in #6. Regional
Transportation-Related Greenhouse Gas Targets.
C. EMISSIONS REDUCTION
MEASURES
•
We are concerned about the following statement by CARB on p. 28:
“Expiration of existing
utility long-term contracts with coal plants will reduce GHG emissions when
such generation is replaced by renewable generation, coal with carbon
sequestration, or natural gas generation, which emits less CO2 per
megawatt-hour.” This statement is too vague to be of use for policy guidance,
since there is a big difference between replacing coal plants with natural gas
and building renewables. On average, when compared to
coal, natural gas plants reduce carbon dioxide by roughly 40%. And carbon
sequestration technologies—in the near term timeframe—are expected to capture
and sequester only a tiny fraction of carbon emissions from coal plants. Both
of these options compare quite unfavorably
with most renewables.
At present carbon sequestration is too costly and under-researched. The additional energy required to separate
and sequester carbon makes this an uneconomic strategy. Further expansion of natural gas generation
cannot be the direction if GHG reduction targets are to be met. Instead, no new fossil fuel generation plants
should be built and all new investment capital should be put into renewable,
zero-emission generation. All actions
should keep to the fast path toward >80% reduction by 2050. A careful
examination of data will show that achieving California’s clean energy
policies, including the 33% renewable standard and both the short and long-term
greenhouse gas reduction targets, will require all new generation to be
renewable.
1. California
Cap and Trade Program Linked to Western Climate Initiative (p. 30)
Direct Emission Reductions: Sierra Club is pleased that the Plan proposes
most of the required GHG reductions come from performance standards that directly
reduce emissions, such as California’s clean-car, renewable-energy, and
energy-efficiency programs, and incentive programs like the Solar Initiative,
with only 20% proposed for the carbon pollution market program. If possible, we
would like to see that percentage made even lower.
The Plan correctly points out
that many powerful parallel policies must accompany "cap and trade"
in order to remove all the state's ingrained market barriers and regulatory
impediments to GHG reduction. State
climate programs need to give these parallel measures – like Feed-in Tariffs, carbon
fees, and Community Choice Electricity Aggregation – the full force of ARB's
backing.
• Sierra Club urges CARB to consider the merits
of replacing cap and trade with a carbon fee. A carbon fee would aid business
planning and benefit businesses, because the price of carbon under a fee system
is more predictable than the outcome of a cap and trade/auction. In addition,
such a fee would provide a predictable source of income for the state to put
into Scoping Plan implementation. Under
the precedent of the Sinclair Paint
case, expenditures of revenue from carbon fees must be related to the issue of
carbon emissions. CARB has not given
this fee option the attention or study it merits.
We urge CARB
to make even clearer that cap-and-trade is no panacea. Over-reliance on
unproven cap-and-trade schemes would be a risky gamble.
• If California establishes
a cap-and-trade program, it should require 100 percent auction from the start
in order to be fair to everyone, including consumers and producers. Auctioning pollution allowances is
the simplest, most fair and effective choice. Polluting
industries should receive a clear, immediate indication that the state is
heading in this direction. CARB's draft implementation plan says that achieving
100 percent auctioning is a "worthwhile goal.”
• In the event a cap-and-trade program is adopted, we agree with
the Market Advisory Committee’s recommendation of “a transition to full auction within the
cap-and-trade program, noting that a system in which California ultimately
auctions all of its emission allowances is consistent with fundamental
objectives of cost-effectiveness, fairness and simplicity.” (Appendix I, p.
C-19) On the other hand, we are very concerned by CARB’s quote that “WCI
Partner jurisdictions have agreed to a minimum percentage of allowances
auctioned increasing from 10 percent in the first three-year compliance period
to 25 percent in 2020.” These low
amounts would fail to provide an incentive for early GHG reductions. In addition, the climate crisis is so great,
that we need substantial revenue as soon as possible to support massive
reductions of GHGs and other air pollutants through fostering the transition to
a low-carbon society.
•All of the Northeastern and
Mid-Atlantic states involved in the Regional Greenhouse Gas Initiative (RGGI)
decided to auction nearly or fully 100 percent of their allowances, even though
a much lower minimum was discussed earlier in the RGGI process. Although RGGI was severely flawed by
over-issuing allowances, the RGGI states raised $38.6 million in the first U.S.
auction for global warming pollution permits. This money can be used to benefit
consumers and invest in clean energy and other green investments.
•Giving away
pollution permits for free would generate windfall profits for polluters and
enrich out-of-state corporate shareholders at the expense of Californians.
•
Sierra Club strongly supports the CPUC and CEC recommendation that “all auction
revenues be used for purposes related to AB 32.” This money should go toward clean energy
technologies, public transit and environmental mitigation, green jobs, and aid
for low-income consumers and small businesses. Funding will also be required to
provide training in renewable energy job skills for people now working in the
fossil fuel industry and to help low-income consumers and small businesses
reduce their utility bills through greatly improved energy efficiency.
• Sierra Club is concerned that
aligning with the Western Climate Initiative (WCI) could dilute California’s
program and result in fewer emissions reductions and more delays, unless
California can bring other states up to higher standards than WCI is currently
recommending. The Design Recommendations for the WCI Regional Cap-and-Trade
Program states (Appendix I, p. D-54): “The WCI recommends each Partner auction
a minimum percentage, between 25 percent and 75 percent, of its allowance
budget.” If California agrees to this, it could mean that between 25% and 75%
of emissions allowances will be given away for free to the biggest polluters in
the state. This is unacceptable.
•
Direct reductions in capped sectors are vastly preferable to offsets. CARB
should require power and oil companies to invest in renewable energy and
cleaner transportation, rather than to pay someone else in some other
jurisdiction to reduce their pollution. Any offsets should be limited in number
and subjected to rigorous criteria (See more discussion below). We are also
concerned about how WCI’s recommendations for cap-and-trade and offsets relate
to concerns of the environmental justice community. We note that, among WCI
member states, California is the only state with an official environmental
justice advisory committee for climate issues, and we are disturbed by the
failure of the WCI process to give sufficient attention to EJ concerns.
•
California should not allow emissions trading with any jurisdiction that does
not have a hard emissions cap of AB 32-like stringency, because such trading
would remove the assurance that our emissions reductions were real.
•
No trading in emissions should be allowed if it causes “hot spots” that
exacerbate air pollution at the local level, especially within communities
already beset by environmental justice issues.
•
Aggressive steps must be taken to guard against leakage by measuring the carbon
emission at its actual point of production for electrical generation consumed
in CA at its actual point of production.
•
Every product manufactured in the world today has its own carbon footprint—the
carbon emissions associated with the production of that product. To maintain a
fair market for California goods, CARB should require that producers of
emission-intensive products imported for consumption in California purchase the
same emissions allowances that California producers must when they sell their
products in the same market. Similarly, emissions associated with products
produced in California but exported should be allocated to the exporting state
or nation rather than California. Any other principle would sorely disadvantage
California industries and act as a powerful lever for driving additional jobs
offshore.
OFFSETS
CARB's Plan
undercuts its cap-and-trade program by unduly relying on offsets. These are credits that polluters in capped
sectors can buy based on estimated pollution reductions made by others in
uncapped sectors. In this way, offsets substitute for cuts that could have been
made directly by polluters in the electricity, industrial, and transportation
sectors directly addressed by cap-and-trade. Both CARB and WCI would allow
approximately half of the required pollution reductions under a cap-and-trade
system to occur through offsets.
However,
CARB's plan goes beyond the WCI's minimum offset limit. WCI allows states to
use offsets for as much as 49 percent of reductions over the lifetime of the
program without rules on when polluters can use offsets. Under that approach,
polluters could rely entirely on offsets in the early years of the program,
which could allow polluters in capped sectors to delay making their own
emission reductions until later years, in some cases not until 2018. In
contrast, California has decided it will limit the use of offsets to 49 percent
during each three-year round of reductions under WCI. In that way, California
will guarantee at least some real reductions in sectors covered by a
cap-and-trade system throughout the program's earlier years.
Rather than
outsourcing efforts around the world through offsets to cut GHG emissions,
California should be aggressively harnessing its own energies and capacities to
develop new clean technologies that can help reduce global warming pollution
here and around the world.
• If offsets are allowed, they
must be very limited in number and subjected to rigorous criteria. The Proposed
CARB Scoping Plan suggests limiting offsets to 10 percent of a firm's
"compliance obligation." CARB must clarify that this means that no
more than 10 percent of the emitter’s required reductions may come from
offsets, not 10 percent of its total emissions.
• While the proposed plan does limit emission offsets more than the draft did,
it still allows up to 49 percent of emission reductions to come from offsets, from anywhere
in the world – not just from California. This would
allow pollution to continue in low-income communities that already carry a
heavier burden of polluting industries. ARB must put in place strict safeguards
to assure that pollution trading and offsets do not harm air quality in those
communities.
• We are opposed to any system that
would relieve any domestic emitter of carbon from paying for their fair share
of the costs of the carbon they emit in exchange for “offsets,” either for
internationally produced CO2 emissions or domestically for activities designed
to enhance carbon sinks, like tree planting. While government and private
support of improved soil carbon content and reforesting are highly desirable,
it is impossible to retain the integrity and effectiveness of a program to
reduce domestic CO2 emissions if it is combined with an international trading
mechanism involving efforts to preserve and enhance carbon sinks.
• We oppose trading between
sources of carbon pollution and sinks, like forests, that store carbon. The
ability of forests to store carbon should not become a justification for
maintaining higher emissions of air pollution. We need both 80% reductions in
domestic CO2 emissions and strong programs to enhance carbon sinks; we should not
“trade” them off against each other. This separation of carbon control systems
is especially important given the increasing vulnerability of California’s
forests and other flora owing to fire, drought and potential effects of climate
change.
2. California
Light-Duty Vehicle GHG Standards (p. 38)
•
Sierra Club supports implementation of the Pavley
“Clean Cars” standards, which continue to call for reduction of global warming
pollution from personal vehicles. While the Pavley
standards will help us to meet 2020 requirements for greenhouse gas reductions,
California needs more improvements in vehicle technology before 2020 in order
to meet our 2050 goals. The state should immediately begin a dramatic shift
toward plug-in hybrid electric vehicles and battery electric vehicles to begin
the ramp-up needed to meet 2050 greenhouse gas reduction goals. This should be
stated specifically in the Plan to make sure it is implemented.
• The state should immediately
create a Battery Electric Vehicle Partnership with industry to speed the
electrification of its light-duty vehicle fleet.
• The minimum goal of 7,500 Zero
Emission Vehicles (ZEVs) currently required by the Zero Emission Vehicle
Program in 2012-2014 is grossly inadequate. CARB should establish a goal of hundreds
of thousands of ZEVs in that timeframe, and recommend increased funding for
immediate development of plug-in hybrid vehicles and infrastructure for all
plug-in vehicles.
• CARB should create a program and
incentives to encourage conversion of the 100,000 hybrids now in use to plug-in
hybrids, and mandate all appropriate state fleet vehicles be plug-in or
zero-emission vehicles.
• CARB's Plan to reduce tailpipe emissions from
cars and trucks recommends that the state evaluate and possibly implement a
"feebates" program, a system of one-time
rebates and surcharges on new passenger cars and light trucks based on the
amount of global warming pollution they emit.
Sierra Club supports a feebates program that
could supplement California's tailpipe standards. According to a University of
Michigan study, implementing a clean car discount program would deliver an
additional 21 percent reduction in global warming pollution beyond the tailpipe
standards.
Important: Sierra Club
supports adoption of a “feebate” system in addition
to the Pavley regulations, not just as a back-up to
the Pavley regulations.
A feebate program would make cleaner cars more affordable for
everyone. Cleaner cars cost less to operate, so people would save money on gas.
Automakers would have an added incentive to produce cleaner vehicles.
3. Energy
Efficiency (p. 41)
• Sierra Club supports all the
energy-efficiency efforts listed by CARB. In fact, we believe that even greater
reductions in the pollution that causes global warming can be gained by further
strengthening efficiency and conservation efforts. In particular, it is
necessary to strengthen independent auditing, measurement and verification of
efficiency measures and programs.
• The Plan’s goal of 32,000 gigawatt-hours
of electric power demand reduction by 2020 falls far short of the economic
potential for 60,000 gigawatt-hours of savings if all
technology options are included (as described in the California Energy
Commission 2007 Integrated Energy Policy Report, p. 98). The larger goal is
more in line with the Western Governors efficiency recommendation of 20%
reduction from projected demand, which their advisory panel said was likely
achievable well before the 2020 target year if best practices were used.
• The mandatory Green Building Standards
Code update scheduled for 2010 needs to be strengthened. CARB pressure could
help. Commissioning, quality control and
enforcement of green building standards and practices in actual construction
and renovation has become acutely important as evidence mounts within the trade
that many so-called “green” projects do not deliver the efficiency savings
advertised.
• Can CARB provide more detail in terms
of the three measures in CR-1 (separate out the expected reductions from the three
strategies outlined)?
• By 2020, California should be
able to go well beyond the SB 1470 goal of only 0.1 million tons of annual
reductions from solar water heating, through encouraging public-private
partnerships.
• CARB should recommend to the CPUC
that energy-efficiency programs be administered independently from the utility
companies, and expand the use of Standard Offer contracts based upon
performance. The California Public Utilities Commission investigated this in
2002 and concluded that independent providers were more cost effective,
particularly for residential customers. The CPUC is developing independent and
objective systems for measuring and verification of energy-efficiency program
savings, and should be urged to fully deploy this in a timely manner.
4. Renewables Portfolio Standard (p. 44)
•
Sierra Club is pleased to see CARB’s recommendation for a 33% Renewable
Portfolio Standard (RPS) for electricity providers. This forward-thinking
measure should be quickly given the force of law for all utilities, either by
regulatory action or by legislation.
Sierra Club presented the Governor and the
legislature’s leadership with a 14-point plan to reform and supplement
RPS.
• We appreciate the mention of “broad-based
participation from many parties and the removal of barriers.” We look forward to more consideration of the
environmental and consumer points of view.
• Although the Plan mentions
“Community Energy” and “municipal utility operations,” there is no mention of
Community Choice Aggregation (CCA), a specific authority under California law
(AB 117, Migden). CCA offers large potential for
local governments to move aggressively toward meeting or exceeding the state’s
mandated Renewable Portfolio Standards (RPS). Over 40 cities and counties in
the state have performed feasibility studies financed by the California Energy
Commission and the U.S. Department of Energy, with over two dozen jurisdictions
in advanced stages of planning for actual implementation. Marin County,
Oakland, Berkeley and Emeryville, as well as San Francisco have either
established or are considering a target of 50% or more renewables
for all customers within their service region by 2017. When achieved, such
targets represent the single easiest way for municipalities to comply locally
with whatever AB 32 stipulations may be imposed. Sierra Club urges ARB to make
CCA a central part of its GHG reduction strategy in the near and medium term.
• Sierra Club is very pleased with the
inclusion of the option of “a Feed-In Tariff for all RPS-eligible renewable
energy facilities,” but questions the phrase “up to 20 megawatts in size.” We favor implementation of feed-in tariffs at
once for all sizes of facilities.
Feed-In Tariffs (FiTs) are efficient tools for
speeding adoption of renewable electricity generation and stabilizing market
prices of new technologies. Already used in more than 37 countries, and under
consideration in Michigan, Minnesota, Illinois and Rhode Island, FiTs establish a price for renewables
— guaranteed for 20 years or more — based on the cost of producing that
electricity plus a fair profit. These rates usually have a modest impact on
customer bills compared to conventionally generated electricity. (In Germany,
for example, the FiT cost to consumers equals the
price of a loaf of bread per month.) FiTs allow
manufacturers and renewable project developers to predict demand, and to invest
with confidence. California should model its FiTs on
those programs that have achieved significant growth of renewables.
A FiT in California should be tied to meeting the
state’s goals for renewables. CARB should also
recommend restructuring state law to allow more favorable renewable energy
price structures.
•
California Energy Commission's workshops on Feed-In Tariffs need to offer much
more aggressive and comprehensive options, and CARB must prod CEC to do this.
• As the California Energy Commission’s
recommended in its 2007 Integrated Energy Policy Report, any carbon trading
system should reduce allowances according to an appropriate evaluation of the
effects of the renewable portfolio standard — in order to avoid oversupply of
allowances.
• CARB should consider and address
the full life cycle of emissions whenever possible. Currently, there appears to
be an inconsistency across sectors. Transportation fuels take a full life cycle
approach, but the energy sources for electric generation and end-use natural
gas consumption do not. Unfortunately, the CPUC’s interpretation of SB 1368
would allow about five million tons of GHG per year per Liquefied Natural Gas
(LNG) terminal to go into the atmosphere without being “counted” as part of the
state’s carbon emissions, if these terminals are constructed. This is not an
abstract issue, as we already face the likelihood of imported LNG increasing
the carbon footprint of pipeline natural gas from Texas and Mexico. That is a
loophole that should and must be closed: five million tons of GHG per year is
roughly equivalent to the emissions of one million cars.
• Sierra Club urges CARB to ensure
that electric power generators be held to an increasingly stringent carbon
standard, and that the carbon standard be applied to all generators, whether
under contract or utility owned, and to all types of retail sellers of
electricity within the state.
• Sierra Club believes CARB’s target of
reducing coal generation 40%, or 13,000 gigawatt-hours,
by 2020 is an achievable goal, provided that utility companies are held to the
renewable energy and efficiency targets.
• Industrial boilers, oil refineries and
glass manufacturing represent excellent opportunities to recover waste heat for
electric generation and other purposes.
5. Low Carbon
Fuel Standard (p. 46)
•
We are looking forward to implementation of a Low Carbon Fuel Standard that accounts
for all environmental impacts on a life cycle basis.
• However, we are disappointed that
the Proposed Scoping Plan contains no explicit projections for carbon
reductions from implementation of a rigorous Zero Emission Vehicle (ZEV)
program. An ambitious ZEV program, plus plug-in hybrids, could achieve
significant GHG savings.
• The plan should include
specific requirements for automakers to sell hundreds of thousands of
zero-emission vehicles annually by 2020.
6. Regional
Transportation-Related Greenhouse Gas Targets (p. 47)
• The Plan should do more than
just “encourage” local city and county climate action plans. This planning
should be required.
• This need not be an unfunded
mandate: most cities lack funding and expertise to craft adequate climate
plans. CARB should take the lead in devising incentives – carrots and sticks –
and means of financially assisting or persuading cities to comply.
• The Plan should include
stronger measures to reform land use planning in ways that reduce vehicle miles
traveled (VMT). (See Newman and Kenworthy paper on
how one passenger-mile of transit use can reduce 3–7 passenger-miles in a car.)
•
Expand Regional Blueprints already underway.
These should include transit-oriented development, walkable,
bikeable communities, mixed land uses, requiring
Regional Transportation Plans to have strong requirements for reduction of
vehicle miles traveled and more.
• We are concerned with how this
section of the Plan deals with land use measures. The Plan’s land use goals are
not ambitious enough. Targets are too modest. Tools identified to cope with the
problem are inadequate. And serious reflection of public health, social and
economic co-benefits of forceful action is lacking.
• SB 375 is insufficient by
itself. Needed also are tools for local
governments to translate GHG reduction targets into local action.
• The Plan only counts reducing 5
million metric tons (MMT) of carbon equivalent per annum by 2020 from actions
in this sector. This is only about 3% of the total reductions. By comparison,
the Sacramento Area Council of Governments (SACOG) blueprint could reduce
carbon emissions by roughly 1 MMT by 2020, even though SACOG’s region currently
contains no more than 1/15th of California’s population.
•
An April 2007 Cal/EPA report, “Climate Action Team Proposed Early Actions to
Mitigate Climate Change in California, Draft for Public Review,” allotted 18
MMT by 2020 to “regional transportation/smart growth land use measures.”
The methodology CARB used to generate
its current 5 MMT estimate is outdated and flawed.
Ÿ For
a document as important as the AB 32 Scoping Plan, CARB should draw on the
broadest possible range of studies and methodologies available to generate
their estimate of reductions from the land use sector. Instead, they rely on a single study (The UC
Berkeley report) to generate the 5 MMT estimate.
Ÿ The
regional model simulations in the UC Berkeley report are widely acknowledged to
understate the benefits of dense mixed-use development.
Ÿ Even
the author of the UC Berkeley report criticizes the models in her study: “the
results confirm that even improved calibrated travel models are likely to
underestimate VKT [vehicle kilometers traveled] reductions from land use,
transit, and pricing policies. These models simply are not suited for the
policy analysis demands in the era of global climate change.”
Ÿ
Rather than basing their estimate on a
single study, CARB should examine a more recent report from the authors of Growing Cooler, which suggests that
reductions of 11-14 MMTs are possible by 2020 (The Ewing Report).
Ÿ
Unlike the UC Berkeley report, the
Ewing Report is based on actual historical data for a 20-year period
exclusively from California. It is far
more realistic in its projections than a series of regional modeling studies
from different states and nations with widely differing circumstances (as
included in the UC Berkeley report).
• More compact neighborhoods and
less driving are the essence of the EIR for SACOG’s Blueprint scenario. SACOG
plans to devote much less land devoted to urban uses and to cut carbon
emissions while saving farmland – providing public health and economic savings
for households and businesses where less driving is required. Reduction of trips through good neighborhood
design must be a CARB imperative from now on.
CARB must set a higher 2020 target
for land use in order to put California on track for the 2050 target.
Ÿ We
simply can’t afford another 10 years of “business-as-usual” development. If CARB sets a low target for land use, the
result may be 10 more years of sprawl. This will make it impossible to reach
our 2050 target.
Ÿ For
California to achieve its 2050 target, we must achieve VMT reductions of
approximately 10% by 2020 and 20% by 2030.
The current 5 MMT target equates to a 4% VMT reduction by 2020 – less
than half of what is needed to keep California on track.
GHG Reductions from Land
Conservation should be quantified and prioritized
Ÿ In addition to reducing VMT,
smart growth also reduces greenhouse gas emissions by preserving landscapes
that sequester carbon, such as forests, agricultural lands, and oak woodlands. CARB should establish guidelines for
quantifying the emission reduction benefits of preserving these landscapes, and
for mitigating the GHG emissions and loss of sequestration resulting from
conversion.
Ÿ There are a number of
possible mechanisms for implementing this strategy, including SB 375, CEQA, and
Indirect Source Review.
Ÿ Many
of California's carbon-capturing landscapes are outside of regional transportation
metropolitan planning organizations (MPOs), and therefore are not covered by SB
375. CARB should ensure that additional
policy measures are adopted that apply to these rural counties.
Ÿ SB
375 and other land use measures should be coordinated with the Sustainable
Forests measures to avoid duplicative efforts and maximize benefits in both
sectors.
Smart Growth is Good for California's Economy
•
Adopt and require the use of greenhouse performance standards, goals and
metrics for transportation planning and projects. Hold state, regional and
local agencies accountable for meeting these metrics.
•
Sierra Club recommends fast-tracking regional mass transit infrastructure,
including Bus Rapid Transit programs (especially on existing freeway HOV
lanes).
•
We suggest that mandatory employer parking cashout,
like that implemented by the city of Santa Monica, be added as an additional
measure to evaluate. Employer parking cashout rewards
employees that opt for transit, carpooling, and other smart transit choices.
•
Many other ways to reduce workplace vehicle-miles-traveled (VMT), such as
parking fee increases, telecommuting, etc. that need further study.
•
Sierra Club is pleased with the mention of public education about
transportation.
•
We suggest that increasing public transit services (both bus and rail) be
included among the sector-based methods.
•
Sierra Club supports CARB’s consideration of Pay-As-You-Drive Auto
Insurance. We note a recent study by
Jason E. Bordoff and Pascal J. Noel,
“Pay-As-You-Drive Auto Insurance: A Simple Way to Reduce Driving Related Harms
and Increase Equity"
(www.brookings.edu/~/media/Files/rc/papers/2008/0417_payd_bordoff/0417_payd_bordoff.pdf).
Applied to California, the analysis indicates much larger benefits than
estimated in the Proposed Scoping Plan.
This emission-reduction estimate is about ten times larger than the Plan
states, and the Plan overlooks co-benefits such as congestion reductions, crash
reductions and consumer benefits.
•
Here are a few of the study’s key findings. (The full paper will be posted on
the Bookings Institution website shortly):
- An 8 percent driving reduction for light-duty
vehicles
- VMT decrease by 24 billion miles
- Less fuel consumption by 1.2 billion gallons,
based on 2006 levels.
- Direct annual CO2 reductions of 10.5 million
metric tons
- Lower premiums for drivers; two-thirds of
households would save money.
• CARB should adopt the
Indirect Source Rule (ISR) for carbon dioxide.
In order for ISR to be effective in reducing
VMT, it should discourage developers from building far from existing services
and jobs, and it should encourage close-in development. To this end, the amount
of the fee should be proportional to the VMT, and the computer model used to
compute a project’s emissions should accurately account for the individual
project’s VMT.
As
a means of encouraging green building, reducing energy use, and promoting good
community design measures such as mixed use and walkability,
such an ISR should follow the precedent set by the existing ISR to incorporate
fee reductions for onsite GHG reduction measures. Remaining fees should be used
for projects that reduce GHG as well as criteria pollutants and achieve other
environmental co-benefits.
•
Lawrence Frank’s new study, Reducing
Global Warming and Air Pollution: The Role of Green
Development in California (July 1, 2008, prepared for Environmental Defense
Fund), is very supportive of ISR. ISR is tested and effective.
• Allocation
of State transportation funds: CARB can
exert much more influence on local transportation planning than portrayed in
the October Proposed Scoping Plan. All the local transportation agencies vie
for State transportation funds. Make
those funds contingent on reducing vehicle-miles and carbon dioxide
emissions. Allocations should be weighted
to strongly favor those local transportation agencies that have the highest
population-adjusted reductions in carbon dioxide emissions.
• CARB should prioritize public transit funding:
- The Plan should make it a top priority to invest in and sustain
public transportation and programs to improve transportation efficiency and reduce
congestion.
- When transit is convenient and reliable, people choose to use
it. When Bay Area residents both live and work within ½ mile of transit, 42% of
them ride it to work.
•
CARB should promote efforts to make transportation information available via
cell phones. One low-cost innovation is the introduction of
everything-on-cell-phone transportation info.
Cell phones can coordinate and improve all our existing transportation
equipment with:
- Convenient access to bus and train schedules
and next-bus or next-train real-time arrival times;
- Automatic
payment for train, bus, carpool, taxi, or rideshare (with demand-driven price
adjustments honing in on the best price for minimum vehicle-miles);
- Carpools
or rideshares scheduled weeks, days, hours, or minutes ahead, or even when a
car is parked, or when a car with an empty space is driving by.
- Real-time
ridesharing “buddy selection” (sometimes you want professional peers, sometimes
church buddies, sometimes a muscleman for a tandem bicycle).
Innovative transportation funding
mechanism:
• CARB needs to consider
influencing the means of transportation funding. Consider the roller coaster ride of gasoline
prices and transportation funding income over the past year. Add in the economic mess at both Federal and
State level. California needs a
transportation funding mechanism that provides an incentive to reduce vehicle
miles and decrease carbon emissions.
Such a funding mechanism makes it easier to influence regional planning.
• One suggestion is to consider
auto insurance cost savings. Identify the total amount paid for vehicle
insurance in a benchmark year. Then
split the savings between government and drivers. For example, Californians (including
businesses) paid about $50 billion dollars for vehicle insurance in 2007. If government actions reduce vehicle-miles
traveled (VMT) and accidents per vehicle-mile, the amount spent on vehicle
insurance would decline. An overall
savings of 10% on insurance could provide California $2.5 billion for more
innovative projects.
• For example, in 2008, an
individual might have paid $1,000 for car insurance plus $250 in gasoline taxes
(that help fund transportation infrastructure). In 2015, because people are
using transit, rideshare, etc. to reduce total vehicle miles, the same
individual might pay only $900 for insurance ($800 for the insurance company
and $100 for government transportation funding) and only $150 in gasoline taxes
(because of better fuel efficiency and 20% less vehicle-miles). In this example, the individual saves $200 on
his/her transportation costs while transportation funding remains the same $250
per year per individual. However, much
more of the $250 can be spent on road and bridge maintenance, or buses and
trains, since reduced vehicle-miles mean less funding is needed for new roads .
Public
Toll Roads:
• Many experts are advocating
tolls to replace fuel taxes. Los Angeles
Metropolitan Transportation Authority plans to converts some high occupancy
vehicle lanes to toll lanes in order to secure Federal grants. The problem with tolls is that government or
private operators have an incentive to increase vehicle-miles in order to
increase the total funds collected. Since private road owner-operators will be
especially resistant to programs that reduce vehicle-miles, perhaps we should
eliminate any private toll roads.
7. Vehicle
Efficiency Measures (p. 29)
•
We support vehicle efficiency measures, such as fuel-efficient tire standards.
8. Goods
Movement (p. 29)
•
We support the ship electrification in ports approved by CARB in 2007.
•
Requiring on-dock electric rail and electric drayage would eliminate all diesel
emissions inside the port.
• We want to know more details of the Plan’s
proposed “Goods Movement Efficiency Measures - System-Wide Efficiency
Improvements,” which CARB has predicted will yield savings of 3.5 tons.
• CARB should work with state transportation
agencies to plan commercially viable electric rail systems that would replace
diesel trucks and trains. That move would also reduce congestion along
California’s highways, potentially lowering total vehicle emissions.
9. Million Solar Roofs
Program (p. 53)
•
We support the Million Solar Roofs Program and its goal of 3,000 megawatts of
solar energy for homes and businesses throughout the state by 2017. We note,
however, that some reforms in program structure and funding may be necessary to
achieve the goal.
10.
Heavy/Medium-Duty Vehicles (p. 53)
•
We support all three proposals for aerodynamic efficiency, hybridization, and
engine efficiency.
• Sierra Club supports CARB’s policies to reduce
emissions from heavy-duty trucks with hybrid engine technology and other
efficiency improvements. This could improve public health by reducing
smog-forming pollution. Sierra Club
urges quick action to address GHG pollution from heavy-duty trucks, reportedly
scheduled for CARB’s December 11 board hearing, when it will take up a measure
to reduce emissions from tractor-trailers operating in California.
•
We request that ARB consider requiring electrification of medium-duty delivery
trucks, as well as other means to reduce emissions in this sector.
11. Industrial
Emissions (p. 56)
•
We support CARB’s plan to require assessment of large industrial sources to
determine whether individual sources within a facility can cost-effectively
reduce GHG emissions and provide other pollution reduction co-benefits.
•
California’s industries (and CARB) could learn from Japan. “According to the
International Energy Agency, based in Paris, Japan consumed half as much energy
per dollar worth of economic activity as the European Union or the United
States, and one-eighth as much as China and India in 2005.” (NY Times, July 4,
2008)
• High efficiency co-generation needs to be
required for all appropriate new energy installations.
12. High Speed
Rail (p. 56)
•
Sierra Club endorsed Proposition 1A and supports construction of a High Speed
Rail system for California.
•
CARB is aware of the ongoing controversy over Altamont and Pacheco Pass routes.
We urge CARB to advise the High Speed Rail Authority on the relative carbon
footprints of competing routes into the Bay Area, and to assess the relative
degrees of cost-effectiveness in reducing carbon when constructed. To the
extent that CARB can bring to bear climate considerations and data on this
choice, the public will be well served.
13. Green
Building Strategy (p. 57)
•
Industry evidence
indicates a disquieting fact: in so-called “green” buildings, we are not
getting advertised energy conservation results owing to improper installation
of energy saving features like insulation, framing and lighting. Poorly installed batt-type
installation can reduce energy reductions as much as 80%. With improper
installation, air leaks occur in the house or building envelope so hot or cold
air enters freely, thus negating any energy savings in cooling or heating
designed in the plans. Some solar panels
are poorly placed. Some reported test data show that supposedly “green”
buildings actually use more energy once in operation than a well-built regular
structure.
•
Apparently, many
contractors don't train employees or give them the time on the job to carefully
check their work, nor do building inspectors find these problems. More
critical is the construction industry in general is not "Performance
Based.” For example, a building can get “green” status without ever proving if
it is indeed saving energy. Without
feedback, the contractors and inspectors don't learn, and the architects never
learn if their plans are actually successful in saving energy.
•
The solution is requiring verification
of building performance before
occupancy. In addition, a building could
get a temporary green building certification but it would not be final until
several years of energy data are collected to prove that the energy reductions
are actually being achieved. Contractors need to train their regular employees
plus have a well-trained supervisor carefully watching their day labor force
implement correct techniques. Building inspectors need to be trained, and they
need to enforce proper construction at every step of the project and on every
building in a project. Awarding any state-level green building certification
should be conditional on demonstrated efficiency.
Absent from
the Scoping Plan is a discussion of existing community preservation and
historic preservation. While green
building is critical for new construction, it should not be used as an excuse
to tear down historic buildings or existing communities. Recognition of community preservation and
related historic preservation should be a part of all landuse
decisions. Since demolition comprises a
significant portion of waste generated in California, community preservation is
the source reduction part of development.
Adaptive reuse of buildings either in place or by relocation should be
discussed either in the Green Building section or under landuse
as well as linked to the Recycling and Waste section.
14. Recycling
and Waste (p. 62-63 and Vol. 1 Supporting Documents and Measure Detail p. C-158
to C-164)
While
significantly improved from the first version, CARB’s scoping plan should
highlight even more aggressively the powerful carbon reduction potential of
zero waste and extended producer responsibility: first, reducing waste by
design in manufacturing process, then reusing, recycling or composting
products. We suggest that the findings of the new report "Stop Trashing
the Climate," released June 5, 2008, (http://www.stoptrashingtheclimate.org/)
be considered for the Scoping Plan. The
report, by GAIA with the Institute for Self Reliance and Eco-Cycle, brings
together information about recycling, plus source reduction, reuse and
composting. Further, it describes how scaling up recycling, reusing materials
and products, and shrinking the size of a community's waste stream can greatly
reduce greenhouse gas generation and related climate damage:
"Incinerators
and landfills are relics of an unsustainable past that have no place in our
green economy. The report, "Stop Trashing the Climate" shows that
zero waste -- that is, preventing waste and strengthening recycling and
composting -- is one of the fastest, cheapest and most effective strategies for
confronting global warming."
Carl Pope, Executive Director, Sierra Club
While
it is commendable that Californians are recycling as much as they are, the
statement that existing diversion rate from landfills is 54 percent is a
misleading statistic. The critical
statistic is how much is landfilled today as compared
to the 1990 base year. When the current
disposal tonnages are used, Californians will see that they are landfilling almost the same amount today as they did then.
Per capita waste disposal is down but we are still wasting huge amount of raw
materials. Using the true disposal
figures shows that there is huge opportunity to both reduce what we generate
and increase what we compost, reuse and recycle.
ETAAC
submitted to CARB an excellent set of recommendations for the waste sector but
only some were included in the Plan. We strongly urge CARB to include ALL the
ETAAC recommendations for the waste sector.
We
believe there are many more tons of carbon reductions possible from aggressive
zero waste and extended producer responsibility programs. Our top improvements
to the Plan are:
Inclusion
of specific measures for these actions with emission reduction numbers and
deadlines should be attached to each action.
Landfill
Issues – Organic Wastes, Alternate Daily Cover and Methane Generation and
Collection
Landfill
waste disposal should be phased out by requiring recycling and making
manufacturers responsible for the end-of-life disposition of their products.
Wastes should be separated, particularly organic wastes, for effective
composting and to reduce the risk of generating methane. CARB should explicitly reject carbon credits
for landfill carbon sequestration.
Alternative Daily Cover (ADC) that uses green waste or wood waste should
not be given recycling credits or counted as recycling. This actually
de-incentivizes diversion of green waste into composting and methane energy
capture.
While
CARB’s plan supports separation of organic and compostable materials CARB’s
suggestion to capture and utilize landfill methane gas should not be construed
as support for continued dumping of green waste into landfills. Landfill
capture of methane is far less efficient than what is possible with green waste
separation. This is especially crucial given that methane is a far more potent
greenhouse gas than carbon dioxide. Some
research shows that attempts to capture and convert landfill gas to energy
(LFGTE) actually can cause more emissions than just flaring the gas under
certain conditions. In addition, the
common assumption that “the majority of methane gas that escapes the landfill
can be flared and converted to CO2” may not be valid in many cases. A common default or “blanket” assumption that
75 percent landfill gas collection rate may be invalid and is under review by CARB. The International Panel on Climate Change
(IPCC) states that some landfill sites may have less efficient or only partial
gas extraction systems, and there are fugitive emissions from landfilled waste prior to and after the implementation of
active gas extraction; therefore estimates of lifetime recovery efficiencies
may be as low as 20%.” The International
Council for Local Environmental Initiatives agrees with the IPCC: “a default
estimate of the recovery efficiency should be 20%.”
To
operate LFGTE economically, landfill operators must increase the concentration
of methane in landfill gas significantly while degrading the efficiency of gas
collection systems by leaving the cap off longer, replacing vertical collection
wells with flexible horizontal pipes, and decreasing vacuum pressure. This may result in increasing net overall
GHG emissions, instead of reducing them.
CARB’s
underlying assumption is that methane gas has a global warming factor of 21
(i.e. 21 times more potent than CO2).
But that is the relative harm over 100 years. The short-term harm (important when
considering the tipping point when global warming reaches a point of no return)
is much greater. Over a 10-20-year
period, it is estimated that the relative harm of methane gas is 72-90 times
greater than CO@ due to methane’s unique properties. All this indicates CARB
should exercise considerable caution in making LFGTE assumptions and
recommendations.
High
Recycling / Zero Waste and Market Development
• CARB’s plan should stipulate mandatory commercial recycling (even with
recycling markets at their current bottom, because credit problems are the
issue, not lack of markets). Infrastructure exists in California to
handle all the materials collected, and in most cases, mandatory commercial
recycling will not require local governments to modify existing collection
contracts. It should require the state to mandate collection or ban the landfilling of paper, metal and certain plastics, as well
as green waste.
It has been almost twenty years
since California signed AB 939 into law.
Since that time, businesses and institutions have had ample time to
implement commercial recycling, and yet these sectors still generate more than
half of what is disposed of in our landfills.
The time for voluntary action is over.
CARB needs to show the political will to truly reduce greenhouse gases
by mandating commercial recycling for all materials where even negative value
markets exist.
Composting,
reuse and recycling facilities should be included in local government critical
infrastructure plans along with water and sewage treatment plants. All are necessary for a community to be
sustainable. In many cases regional compost,
reuse and recycling facilities are an alternative to each community having
their own set of zero waste operations.
However, cities should be encouraged to locate facilities close to the
point of generation, especially composting operations, so as to reduce
transportation-related energy consumption and to allow residents and businesses
to use their own compost locally rather than shipping in finished compost. We encourage cities to landbank
for critical infrastructure projects like compost facilities.
•
We propose statewide installation of “Resource Recovery Parks” to include
facilities for reusing, recycling, composting, and minimizing the discarding of
materials. They can also incorporate facilities for repair services, retail
sales of reclaimed products and landscaping supplies, organically composted
gardens, educational tours, and public amenities. Such a model park currently
operates in the city of Marina in Monterey County.
•
Fees collected from the sale of carbon credits or other greenhouse reduction
financial mechanisms should be made available in the form of grants, loans or
tax credits to private or public composting and reuse or recycling
manufacturing facilities.
•
Successful Zero Waste initiatives require effective outreach and educational
programs. CARB should utilize the legions of young people who are not only are
enthusiastic and care about waste reduction, recycling and global warming but
are also willing to go out and do something about it. CARB should aid these
individuals in helping educate our communities about the issue. Recycling
ambassador programs throughout state and local government agencies should be
instituted so that students and other volunteers can go door-to-door educating
residents about the need for and the benefits of recycling. In addition, new
home owners, apartment dwellers and other residents should receive information
after moving to a new residence that explains to them the recycling policies in
their neighborhood and encourages them to do so. People are willing to do what
it takes to pitch in, but if they have no idea how to do it, they won't even
begin. This type of outreach should be a critical aspect of the CARB plan.
•
Government purchasing power is very powerful. Along with existing
Environmentally Preferred Programs, a new program discouraging the purchase of
single use disposable items and encouraging refillables and reusables
needs to be implemented.
•
CARB is to be commended for stipulating “lifecycle tracking” of manufactured
products, giving priority to reusables and locally
manufactured items.
Conversion
Technology
Sierra
Club Policy does not support incineration of mixed solid waste. The Club is reviewing options of recovering
energy from source-separated parts of the solid waste stream, e.g., restaurant
cooking oil, sewage sludge, and food waste.
However, burning or converting a material to a different state can
require more energy than the energy recovered.
Further, conversion technology facilities require significant
investments of funds, public and private and dedicated waste streams and can
discourage the development of reuse or recycled markets for those same
materials. Developing new products from waste materials creates more jobs than
burning or “converting” those materials.
So like landfill gas, we recommend the use of the Precautionary
Principle before embarking on new conversion facility development.
15.
Sustainable Forests (p. 27)
To the extent
that there is an increased focus on using forest biomass to generate
electricity, it is important that biomass utilization not lead to adverse
forest management practices. It makes sense to utilize the material
created from community protection efforts, or incidental to an otherwise lawful
harvest, but we should not allow biomass production to impact important habitat
areas, including riparian areas, late seral forests, or other sensitive
habitats.
16. Water (p.
65)
• We support a public goods
charge for funding investments in water efficiency that will lead to reductions
in greenhouse gases.
• We are pleased that CARB staff
calls for a 20% reduction in water use, but disappointed that agricultural
water use is not included among the efficiency targets. Agricultural water use
accounts for more than three quarters of the state’s total water use.
• Moving, treating, heating, and desalting water consumes energy. Producing energy consumes water. Some innovative ideas to reduce water
consumption:
- Installation
of smart water meters:
Install smart radio protocol meters (aka Advanced Metering
Infrastructure (AMI)) and an associated remotely adjustable pressure reduction
valve to municipal and industrial water users and similarly smart meters with
appropriate transmission technology to agriculture. AMI allows leak detection and can also
provide the same differentiation between domestic and irrigation water use as
two separate meters. Single-family
dwelling water price could depend on water use.
The associated valves could be authorized by customers to reduce the
pressure, should they be at risk of excessive use of water for the month
(financial penalty). (A phone call or
web entry would allow customers to draw on “rollover” or “banked” gallons or
even to “sell” their banked gallons to others.)
The smart water meters could communicate with the smart electric and
smart gas meters to quickly calculate the actual energy savings of a solar hot
water heater. The pair could
automatically adjust the energy savings for a change in family size causing a
change in water use.
Local water agencies may conserve on water storage infrastructure
with the AMI meters. Should the agency’s
water be needed to fight a fire or should a pipe failure or earthquake
interrupt supply, the agency can ration water use. For example, if calculations suggest homes
need to reduce use to 100 gallons per day, the agency can turn off the water
for each home when the home use reaches 100 gallons each day.
Ask the California State Water Resources Board, the Public
Utilities Commission, and the California Air Resources Board to
coordinate. Southern California Edison
is installing AMI to relay real-time data and possibly control use. Local water agencies could contract with or
coordinate with electric utilities to relay water use and control-valve
communications.
- Implement “Pay as You Save”
utility programs for water conservation, too:
By including water savings
in “pay as you save” programs, utilities
could provide energy efficient appliances, solar water heaters,
insulation, solar energy systems, co-generation furnace replacements, long-haul tractor conversions to
electric-natural gas hybrids etc.
Utility customers would pay for the equipment over time, via their
utility bills with no up-front payment, no debt obligation, no credit checks,
and no liens needed. Utilities can guarantee that the customers’ monthly
utility bills will be less than before the installation of the energy and water
saving technologies. Because the arrangement is attached to a property
and not a person, even renters can benefit.
• Include greenhouse gas
emissions credits for water savings:
Allow greenhouse gas emissions credits for the water purveyor
based on a calculation that includes greenhouse gas emissions from the
customer’s side of the water meter.
17.
Agriculture (p. 66)
•
Sierra Club remains extremely disappointed with the Plan’s low expectations for
agriculture. The initial Plan only mentioned 1 potential MMT equivalent of GHG
reduction from methane capture at large dairies while the state’s GHG inventory
shows 13 MMT equivalent of methane emissions from
manure management and enteric fermentation. Agriculture contributes about half
of California’s methane emissions, but is far from contributing its share of
reductions under the current Plan. This is especially serious considering that
conventional models of methane underestimate its effect. The CEC’s inventory
used a GWP of 21, revised upward from the early figure of only 11. The figure
used by CEC lags behind current science, as the newest figures show a 100-year
GWP of 25. However, there are major
questions around using a 100-year GWP when CH4 is only resident in the
atmosphere for about 8 years. The 20-year GWP, which has currently been
upgraded to over 70, would be more appropriate,. If a
20-year GWP is applied, methane would be seen to contribute 17% of the state’s
greenhouse gas impact rather than the “official” 2004 figure of 5.7%. If
shorter term timeframes are examined, which match the 8 year residency of
methane, then the role of methane would be much
greater. In addition, one NASA scientist has evidence that methane may be twice
as powerful as IPCC assumes. Thus, methane may represent even more of a threat
in human induced global warming. The flip side is that its short residence in
the atmosphere may also represent a great opportunity to lower GHGs rapidly.
This could be amplified by the fact that, unlike carbon emissions, the vast
majority of anthropogenic methane emissions can apparently be rapidly absorbed
by sinks. Tackling the global methane problem—compared to CO2— is thus a
relatively rapidly achievable goal, and a state like California could
contribute disproportionate benefits that might have truly global significance.
• Studies have shown significant
methane emissions from bovine digestion, which raises the question of whether a
carbon tax should be applied to dairy products, such as beef and milk.
• In Department of
Conservation’s study of greenhouse gas emissions associated with conversion of
agricultural land to urban uses, both direct and indirect emissions should be
considered. Promoting more compact, efficient, transit-oriented urban
development will not only reduce greenhouse gas emissions from vehicle travel
but also conserve agricultural land by minimizing conversion to urban use.
•
The Plan should reference and encourage CDFA’s development of a strategic plan
for agriculture. Efforts to minimize conversion of prime farmland will be
helped if agricultural enterprises now on the land maintain profitability and
sustainability.
•
The Plan should emphasize that linking good land use with local food systems
can reduce transportation-related emissions, provide a premium for farmers
selling locally, and even improve access to healthier foods.
•
State and local governments could increase access to local foods, for example,
by direct investments, incentives and public-private partnerships to develop
needed local foods system infrastructure.
•
Joint action by the Department of Food & Agriculture and CARB could
significantly increase the amount of locally produced food consumed in the
state – thus reducing more emissions from transportation. CDFA and CARB could
work together to track and measure “food miles traveled” and seek ways to cut
distances from food to producer. Cutting down on transport of agricultural
products from agriculture areas to other parts of the state would lessen GHG.
•
The Plan should address urban agricultural issues, such as:
a) What funding can the state supply to assist municipalities in
supporting urban agriculture?
b) What focus can CARB bring on removing barriers to urban
agriculture? CARB and CDFA could work together to: find useable land for
community gardens, inventories of such land; test for toxicity; reach out to
potential urban gardeners; recast city regulations in favor of urban orchards,
edible landscaping, local composting, and rooftop gardens; and provide more UC
Master Gardener training and technical assistance?
c) Could CARB facilitate funding of local offices in each
municipality to inventory potentially available state-owned lands and mobilize
local community gardeners and organizers?
•
Many studies by California scientists and others throughout the world have
shown how organically grown crops have significantly lowered GHG emissions,
from non-use of nitrate fertilizers, retention of carbon in soils, and other
means.
• The Plan needs to highlight the
greenhouse gas reduction benefits of organic agriculture. The California Energy
Commission Climate Change Research Conference Sacramento, September 10-13, 2007
has five presentations:
http://www.climatechange.ca.gov/events/2007_conference/presentations/index.html
• Data from The Rodale Institute’s
long-running comparison of organic and conventional cropping systems confirm
that organic methods are far more effective at removing the greenhouse gas,
carbon dioxide, from the atmosphere and fixing it as beneficial organic matter
in the soil. See Laura Sayre, 2003
http://www.newfarm.org/depts/NFfield_trials/1003/carbonsequest.shtml
--
Another study shows confirmed ecological virtues of organic farming
www.pnas.org/cgi/reprint/103/12/4522.pdf
http://news-service.stanford.edu/pr/2006/pr-organics-030806.html
D. Public Health and Environmental Justice
Issues Must Be Addressed
l The
Proposed Scoping Plan has failed to adequately respond to concerns raised by
the EJAC and public health community.
l CARB
should adopt the EJAC's recommendations to increase the 2020 target for land
use, invest in public transit in low-income communities, and create incentives
for local governments to reduce their emissions.
l The
public health analysis should include specific data about public health impacts
associated with community design, including impacts on obesity, chronic disease
and public safety.
l CARB
should ensure that the public health community has an ongoing, formal role in
shaping AB 32 policy.
Sierra
Club supports the following text recommended for insertion into the Plan by the
Coalition for Clean Air and other California organizations.
• ARB will adopt a cumulative impacts assessment method
within a year or prior to the adoption of AB 32 related market-based regulation
and identify communities “already impacted by air pollution” cumulatively to
ensure uniformity and consistency among the state, air districts and other
local governments so that communities identified as impacted by one agency do
not get categorized differently by another;
• ARB will
evaluate the potential negative impacts (if any) of all subsequent AB 32
regulations in these communities prior to their adoption and incorporate
safeguards;
• ARB will design
the market mechanism compliance protocols to achieve maximum emission reduction
and co-benefits in the most disadvantaged communities by including incentives
and restrictions; and
• ARB will
initiate a public process within three months to determine and recommend the
percentage of resources generated through AB 32 related auction and fee
revenues that can be directed to assist in adaptation and emission reduction
measures for those communities and small businesses most disadvantaged by
climate change or air pollution impacts.
E. VOLUNTARY EARLY ACTIONS
AND REDUCTIONS (p. 67)
•
We are pleased CARB is studying means to reward voluntary early actions
reductions.
F. USE OF ALLOWANCES AND
REVENUES (p. 69)
•
We support most of the uses listed, particularly those related to environmental
justice, such as “achieving environmental co-benefits.” However, we are not supportive of “direct
refund to consumers,” unless such “refunds” can be tied directly to GHG reductions.
•
Criteria and toxic air pollutants create health risks, and some communities
bear a disproportionate burden from air pollution. We support ideas that
benefit these unfairly impacted communities.
•
Revenues should be prioritized for projects that reduce both GHG emissions and
also provide reductions in air and other pollutants that affect public health.
•
We are pleased that CARB has provided a positive discussion of carbon fees. We
think that the range of $10 and $50/ton would be reasonable; this fee could
start low and gradually increase over time as needed.
• A
$30-per-ton fee on all greenhouse gases would provide revenue of approximately
$12 billion per year, which is less than 1/100th of the California economy.
This money could be restored immediately to the state economy, encouraging
local investment in clean technologies and green jobs, activities with a bright
prospect in a carbon-constrained world. Revenues could also provide rebates for
low-income consumers.
•
We believe that it should be possible to quantify some of the benefits from the
expenditure of the funds on projects that provide considerable GHG emission
reductions. For example, transit operators know increased frequency of service
and lower fares can increase ridership. Recovering waste heat, either to
generate electricity or from generating electricity, has specific value to
commercial and residential utility customers.
•
On carbon pricing, emissions fees should be analyzed along with a
cap-and-auction system, as the Plan proposes. We need the income to fund CO2
reductions.
• Polluters always should have to pay for
cleaning up the damage they cause. Therefore, if a carbon market is
established, all emission allowances should be auctioned. The Plan states (page
16), “These allowances could be freely distributed to capped
firms or auctioned in the trading market.” We are opposed to free distribution
of allowances, since they don’t encourage accountability and provide much less
motivation to reduce GHG emissions.
•
Major emitters should pay for the cost of administering this program.
III.
EVALUATIONS (p. 73)
Specific
economic benefits of energy efficiency and clean energy measures can be
evaluated based upon the sum of:
1) Projected and avoided costs for these
energy supplies,
2)
In-state jobs and manufacturing due to green economic activity,
3)
Federal tax credits benefits and in-state tax revenues,
4)
Export revenues, and
5)
Environmental and public health benefits.
•
CARB’s analysis of public health benefits of transportation efficiency measures
focuses only on respiratory medicine and economic benefits of reducing
respiratory disease. While this analysis provides powerful support for the
Plan’s vehicle and fuel improvements, the Plan overlooks large public health
benefits to other transportation efficiency measures not in the Plan.
•
Public health perils such as obesity, diabetes and heart disease can be reduced
by strategies the Plan should embrace more aggressively. Auto-dependent
neighborhoods make these diseases more common; smart growth and reduced vehicle
miles traveled can help combat them.
•
CARB’s public health analysis needs to address the issue of food security and
“healthy food deserts.” Lacking local healthy food choices, many people must
travel long distances to obtain more healthy fare or rely on expensive, locally
available junk food. Although emissions benefits of better access to healthy
food may be modest, public health benefits can be significant and climate
change policy offers a chance for low-income “food deserts” to get attention.
IV.
IMPLEMENTATION: Putting the Plan into Action (p. 99)
A. Personal
Action (p. 100)
We are pleased that the Proposed Scoping Plan
includes Personal Action as an important strategy for curbing GHG emissions. It
calls for the “active participation of the people of California” including “the
voluntary commitment and involvement of millions of individuals and
households.”
To encourage this voluntary commitment and
involvement, we propose that CARB track on the Internet the effect of individual and family actions
on lowering greenhouse gas emissions. A
statewide electronic registry could record the results of their actions and
report back via graphics and numbers the mounting total of emissions curbed.
Without such a measurement, individuals and families
will lower their carbon footprint alone, receiving little or no feedback.
However, if they anticipate positive feedback,
people will be much more likely to act. They will know for sure that their
actions are having a positive effect. Knowing they’ve made a concrete
contribution will motivate them to do even more, and to urge their friends and
family to participate. This approach would also utilize the latest motivational
research, which indicates that if people believe “everybody is doing it,” they
are much more likely to do it.
By providing evidence of the effectiveness of
individual actions, a public electronic measurement would furnish a way to turn
fear of the effects of global warming into positive action. It will help
eliminate feelings of helplessness in the face of a global problem.
Public measurement of voluntary actions would also
draw individuals and families into the overall effort that CARB proposes in the
Scoping Plan. Their experience will give them the feeling of “buying in.” That
will build their interest in learning about and supporting CARB’s efforts and those of industry,
transportation, agriculture, and other sectors.
By feeling part of a community statewide effort, they would become
interested in and supportive of the steps being taken in other sectors – for
example, government land use changes to reduce vehicle travel, etc.
Technology exists that would allow individuals and
families who choose some of the actions recommended by CARB to receive positive
feedback on their actions.
CARB
should create a website where individuals and families could record the changes
they’re making in home insulation, windows, appliances, roof color, shading,
compact fluorescents, recycling, reducing vehicle travel, and other
emissions-curbing activities. Statewide tallies exist of some of these measures
taken by large commercial installations. A tally of personal individual and
family measures taken could also be created.
A mountain of data on individual solar (PV and DHW) installations
already exists.
Lucid
Design Group for example, a California company, provides buildings with an
interactive website and touch-screen kiosk display that makes resource use of
energy, saving of money, and offset of emissions visible and easily
understandable. That technology might
be adapted for use in tracking individual and family contributions.
Furthermore, tracking progress in curbing individual
or family emissions would be fun, like following a sports team. It will be like
checking the stock market, except that this measure will always go up. It will give families a game to play
CARB
should put in staff time to develop this project. Private partners might be
interested in developing appropriate technology and a business model.
Watching the numbers or a thermometer-like graphic
rise by logging on to a public website would create a sense of the community pulling
together. We shouldn’t underestimate the power of such feelings. People have
yearnings to take part in idealistic national efforts and the feelings of
solidarity such efforts create can be strong. Think of everyone pulling
together in World War II and the public enthusiasm for and interest in the 2008
presidential election. Surely there’s no statewide effort healthier or more
universally beneficial than saving energy, switching to renewables and reducing
vehicle travel.
We would feel like we’re all in this together –
which we are.
B. Public Outreach and
Education (p. 100)
•
All four strategies are excellent.
•
Funding is needed for training teachers in the climate change curriculum.
•
The Plan should include detailed public awareness campaigns, with budgets
(funded by carbon fees), that will be used to involve the public in all aspects
of the Plan.
•
Successful implementation of California’s historic global warming law will
require a program that is open and transparent to the public, including
performance and compliance tracking information of all components accessible
via the Internet.
C. Implementation of the
Plan (p. 104)
D. Tracking and Measuring
Progress (p. 107)
• We are supportive of the measures proposed
for tracking progress.
E. Enforcement (p. 109)
• Sierra Club agrees that enforcement is a
critical component of AB 32 implementation. CARB will need to significantly
bulk up its enforcement resources to meet this challenge. In addition, the
scoping plan should explain the route for enforcing emission reduction measures
taken by other agencies outside CARB to hold those agencies accountable for assuring
the realization of emission reduction measures assigned to them.
• We support the measures
proposed for enforcement, especially including engaging local Air Quality
Districts in tracking emissions from local facilities.
• We would support allocating some
program funding to these Air Quality Districts to support their increased
duties under AB 32.
F. State and Local
Permitting Considerations (p. 110)
• We support including state and
local permitting considerations in the AB 32 implementation strategies.
• We would support allocating some
program funding to the entities involved to support their increased duties
under AB 32.
G. Role of Local Air
Districts (p. 111)
• Sierra Club would support allocating
some program funding to Air Quality Districts to support their increased duties
under AB 32.
H. Program Funding (p. 112)
•
We support the measures proposed for program funding, including collection of
fees.
V. A VISION
FOR THE FUTURE (p. 113)
• We support collaboration with
key partners, as long as it doesn’t dilute the effectiveness and speed of
implementation. California needs to stand up for a high standard of GHG
reductions, not sink to the “lowest common denominator.”
• We applaud the planned
expansion of research by California’s universities to develop innovative
solutions to all aspects of the plan, but we cannot wait for the “perfect
technologies.”
(For further detail on Sierra Club
California’s positions, see:
http://www.sierraclubcalifornia.org/globalwarming.html.)
Respectfully
Submitted,
Bill
Magavern
Director,
Sierra Club California