Center for Progressive Reform Comments to California: Adopt More Ambitious Carbon Neutrality Plan

The Center for Progressive Reform has joined close to 1,000 organizations and individuals in providing comments on California's long-awaited plan for achieving carbon neutrality, the Draft 2022 Scoping Plan Update (Draft Plan). Gov. Gavin Newsom gave the California Air Resources Board (CARB), the state agency tasked with coordinating the plan, a daunting challenge: achieving carbon neutrality by 2045 at the latest.

Our comments conclude that the state should (1) be more ambitious, (2) more explicitly achieve multiple objectives, including environmental justice, and (3) develop a supplemental plan that more specifically outlines the policy tools the state will employ to achieve its objectives.

Reduce Reliance on Fossil Fuels More Quickly

The Draft Plan's 2045 timeline — spanning more than two decades — will perpetuate fossil fuel use and associated pollution. The plan proposes deadlines for ending the sale of fossil-fuel based goods, like trucks, cars, and appliances, but assumes that, once sold, these products can continue to be used until the end of their useful lives. The plan also establishes a slow pace for electrifying industry, in many cases expecting zero transition by 2030.

Our comments argue that more aggressive measures to reduce reliance on fossil fuels would accelerate the timeline for achieving carbon neutrality and improve public health more quickly, particularly for communities of color that tend to experience disproportionate harm. For example, setting a deadline banning the continued use of diesel trucks would alleviate toxic diesel emissions, and intensive investment in appliance retrofits would reduce indoor natural gas emissions.

More concerted requirements for industry, coupled with financial support if needed to prevent companies from shifting production (and associated emissions) elsewhere, would likewise more quickly reduce fossil fuel use and improve air quality for the marginalized communities often co-located with industry.

By halting the use, not just the sale, of fossil-fuel dependent goods and by accelerating industrial reductions, the state could more quickly become carbon neutral and achieve the environmental and health benefits of a rapid transition.

Seek a Holistic Post-Carbon Vision

Although CARB's task is to detail a plan for achieving carbon neutrality, carbon reductions will not occur in a vacuum. The transition will touch many aspects of the economy, the environment, and people's lives. CARB acknowledges this reality, but, as our comments observe, the Draft Plan could do more to define an integrated vision for a carbon-neutral economy and could detail the cross-agency coordination that will be necessary to achieve multiple objectives.

For example, we note that, although the Draft Plan includes multiple references to environmental justice, the plan does not specify how the transition will lead to pollution reductions where they are most needed. In addition, we point out that the plan does little to address how phasing out fossil fuels will affect the fate of fossil-fuel-dependent workers and communities and how the state will develop new "high-road" opportunities for those at risk of being left behind.

Invest in the Future

Our comments highlight the massive investments that will be needed to accomplish an equitable clean energy transition and observe that the Draft Plan could more explicitly identify costs and explain the need for dedicated revenue.

The private sector alone will not accomplish a comprehensive clean energy transition. Low-income individuals, small businesses, and some industry and agricultural entities will require creative long-term financing mechanisms and subsidies. Without this public investment, the state cannot achieve carbon neutrality. Moreover, because past mechanisms for distributing government dollars may not be appropriate for the type and scale of needed public investment, the state should work with stakeholders to assess new models to equitably and efficiently invest in the future.

Develop a Supplemental Policy Plan

The Draft Plan sets sector-specific goals based on technological and economic parameters and lists existing laws and programs that will contribute to, but not achieve, the state's goals. Although the plan provides a laundry list of possible strategies for achieving reductions, it does not identify which mechanisms it will deploy, deferring such specification to the implementation process.

Recognizing that CARB is unable to provide a higher level of specificity in this plan, our comments stress the need for a supplemental plan that more concretely identifies proposed policy mechanisms, including the relative roles for further planning processes, regulations, incentives, investments, and cap-and-trade within and across sectors. A supplemental policy plan would provide a holistic assessment of policy options and their interrelationships, in contrast to CARB's current approach, which delays policy choices and risks piecemeal and fragmented policy initiatives.

A more detailed policy plan should integrate CARB's stated environmental justice goals and demonstrate specific standards for achieving environmental benefits. The Environmental Justice Advisory Committee, which is convened to advise CARB on each scoping plan update, should play a vital role in developing the plan and ensuring widespread public outreach and participation.

Sector-Specific Recommendations

In addition to its cross-cutting comments, we provided detailed sector-specific recommendations. They advocate for faster reductions in fossil-fuel uses, benefits for marginalized communities, and prioritizing pollution reductions in the transportation, buildings, and industrial sectors. Looking ahead to the mechanisms for reducing emissions, the comments call for direct emission reductions wherever possible, with limited reliance on carbon removal and on cap-and-trade.

California has started on its path to carbon neutrality. Our comments are intended to maximize the benefits and minimize the harms that could emerge from the state's ambitious undertaking.