CARB Releases Ambitious Draft Climate Action Plan to Slash Use of Fossil Fuels and Reach Carbon Neutrality by 2045

June 02, 2022

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(California Air Resources Board) Draft of 2022 Climate Change Scoping Plan charts rapid timeline to cut pollution and engage every sector of the world’s fifth largest economy -- The California Air Resources Board (CARB) today released a draft plan that, when final, will guide the state’s transition to a clean energy economy, drastically reduce the use of fossil fuels, achieve carbon neutrality by 2045 or sooner, and significantly clean the state’s air especially in disadvantaged communities disproportionately burdened by persistent pollution.

The draft 2022 Climate Change Scoping Plan is the third update to the state’s initial 2008 Scoping Plan. It identifies a technologically feasible, cost-effective and equity-focused path to achieve carbon neutrality over the next two decades while also assessing the progress the State is making towards reducing its greenhouse gas emissions by at least 40 percent below 1990 levels by 2030.

Release of the draft plan triggers a formal 45-day public comment period. During the 45-day public comment period, the Environmental Justice Advisory Committee may provide additional input on the draft plan. The Board will consider the plan in June and may then provide direction to staff, with an additional period of public comment and engagement prior to the second meeting of the Board in the fall to consider adopting a final draft of the plan.

“The draft Scoping Plan sets out an ambitious vision that advances equity and addresses the existential crisis of our generation with guidance for the concrete steps and actions needed to actually make it work,” said CARB Executive Officer Richard Corey. “When final, it will serve as the actionable plan for a more sustainable California for our children and a model for other industrialized economies around the world as they consider how to make their transition to a clean energy economy that provides health benefits and economic opportunity.”

California is the fifth largest economy on the planet and the draft plan covers every sector. The most significant aspect of the draft plan is the aggressive pace and scale it calls for to reduce our reliance on fossil fuels wherever they are currently used in California. It achieves this goal by building on and accelerating successful approaches to carbon reduction including regulations, incentives, and carbon pricing that have been in place for a decade and a half. At the center of this shift away from fossil fuels is an accelerated transition to zero-emission transportation, phasing out the use of fossil gas used to heat homes and buildings, and providing communities with sustainable options for walking, biking, and public transit so that people do not have to rely on cars. Action in the transportation sector will be buttressed by an acceleration of adding more clean, affordable, and reliable renewable energy to displace fossil-fuel fired electricity generation and scaling up new options such as hydrogen and renewable gas for hard-to-electrify end uses.

This accelerated shift away from petroleum will make California more energy secure, less impacted by volatile global oil price fluctuations, and will deliver significant health benefits to all Californians, especially those in low-income communities of color that are most impacted by air pollution from truck and car traffic and freight delivery.

Achieving California’s goal of carbon neutrality by 2045 or sooner will also require re-envisioning our forests, farmlands and rangelands to ensure that they play as robust a role as possible in reducing emissions and incorporating and storing more carbon. This focus will establish healthier forests that are more resistant to wildfires, and increased health benefits from reduced exposure to wildfire smoke. The plan also makes clear that in order to succeed in balancing remaining carbon output with carbon storage, California will need to go beyond the capacity of our natural and working lands and deploy additional methods of capturing carbon dioxide that include pulling it from industrial smokestacks or drawing it out of the atmosphere itself and then safely and permanently storing it.

These efforts place a priority on ensuring that all these efforts provide benefits to frontline communities most heavily burdened by persistent pollution and who will disproportionately bear the impacts of a warming planet.

The draft 2022 Climate Change Scoping Plan was developed by the California Air Resources Board in an unprecedented process of collaboration and coordination with multiple state agencies. That broad-based coordination lays the foundation for a whole of government approach to future implementation. Development of the plan also included robust public engagement including over a dozen workshops, webinars or public meetings over the past year.

In addition, the draft plan was shaped by recommendations from the Environmental Justice Advisory Committee to ensure that environmental justice and frontline communities are front and center in the state’s efforts to address the climate emergency. The EJAC held 18 meetings and there are some five dozen recommendations of the committee referenced throughout the draft plan. Ongoing collaboration with the EJAC will be essential to ensure that the final plan is as robust as possible.

The draft Scoping Plan evaluated four potential scenarios for achieving carbon neutrality, all of which will also achieve the 2030 goal of reducing GHG emissions 40% below 1990 levels. Two of those scenarios would achieve carbon neutrality by 2035; the other two by 2045. Through extensive modeling to determine future policy impacts on health and the economy CARB staff concluded that Scenario 3 provided the most economically and technologically feasible route to carbon neutrality, including providing equity-based solutions focused on affordability and job preservation. Scenario 3 aligns with all applicable statues and Executive Orders while deploying a broad portfolio of existing and emerging fossil fuel alternatives and clean technologies. It also provides a feasible timeline to develop the infrastructure and technology needed, especially the rapid build-out of renewable energy, and a lower overall cost of implementation with minimal impact on the economy. It will achieve an approximately 90% reduction in petroleum usage by 2045, and reduces greenhouse gas emissions 80% by 2050, another state target.

The draft Scoping Plan also reviews California’s existing climate programs, such as the Low Carbon Fuel Standard, Cap-and-Trade and the Renewables Portfolio Standard, among others. The draft Plan explains how these programs have been changed since the last Scoping Plan in 2017 and outlines other programs and actions needed to achieve a low-carbon economy.

Draft Scoping Plan

Additional Materials

More Information

Biofuels remain heavily subsidized, even as environmentalists turn against them -- Government regulators consider biofuels an integral part of cutting greenhouse gas emissions. A growing number of environmentalists and academics are challenging that idea. (Courthouse News Service)

Clean Fuels Alliance America (Clean Fuels)1 and California Advanced Biofuels Alliance (CABA)2 appreciate the opportunity to provide comments on the California Air Resources Board's (CARB) 2022 Scoping Plan Update (Scoping Plan). (Clean Fuels Alliance American and California Advanced Biofuels Alliance)

California Released a Bold Climate Plan, but Critics Say It Will Harm Vulnerable Communities and Undermine Its Goals -- Environmental justice and climate advocacy groups say the draft plan relies too heavily on carbon capture and could increase pollution in low-income neighborhoods. (Inside Climate News)

Excerpt from Clean Fuels Alliance American and California Advanced Biofuels Alliance: ... Further, the biodiesel, renewable
diesel, and sustainable aviation fuel supplied to the state by our California and national members are collectively the single largest source of GHG reductions in the Low Carbon Fuel Standard (LCFS), providing nearly half (44-45%) of the carbon reductions), more than any other fuel including electricity. Our fuels have grown to the point where fully a third (33.3%) of each gallon of diesel fuel consumed in the state in 2021 consisted of our industry's low-carbon fuels.

Our sustainable replacements for petroleum diesel have been a major factor in driving California's continuing large scale transformation of transportation from petroleum based toward a carbon neutral system. More to the point, our liquid diesel replacement fuels remain
the only viable, large-scale alternatives to petroleum for the next several decades in the most difficult-to-decarbonize sectors: heavy duty on- and off-road, marine, rail, and aviation.

Support for Alternative 3
We support the CARB staff's move away from the "one-size-fits-all" approaches in Alternatives 1 and 2, a move which recognizes not just the infeasibility of those approaches but also the extreme costs associated with them. While it could do considerably more to push for
alternative fuels besides electricity and hydrogen, the staff’s recommended Alternative 3 provides a pathway for the continued important role that biodiesel (BD), renewable diesel (RD), and sustainable aviation fuel (SAF) must play in California’s efforts to decarbonize
transportation.

We continue to reiterate3 that staff’s modeling should include a scenario aiming toward complete displacement of petroleum diesel by the 2035-2045 timeframe. This would entail producing in and importing into California about 3.4 billion gallons of renewable diesel and
biodiesel, a goal which is entirely feasible given the billions of gallons of RD production capacity in the U.S. due to come online in the next several years and the existing 2.5 billion gallon BD capacity.

To this end, we recommend that CARB staff initiate the next LCFS rulemaking immediately after adoption of the Scoping Plan and, within that rulemaking:

1. Adopt a more aggressive 30% carbon intensity (CI) reduction target for the LCFS by 2030 (as compared to the current 20% target), and a minimum a 37% CI reduction target by 2035. This would help the state achieve carbon neutrality by 2045 or sooner and harmonize the California LCFS program with the targets currently being considered by the Oregon Department of Environmental Quality for its analogous Clean Fuel Program;

and

2. Update the lifecycle assessment (LCA) science underpinning the LCFS. The current LCFS relies on lifecycle data which is not only more than a decade old but also has been shown with real-world experience and recent scientific work by Purdue University, Argonne National Laboratory, and other academic papers to grossly overestimate lifecycle emissions of a number of key alternative, low-carbon fuels like biodiesel, renewable diesel, and SAF.

Deep electrification in transportation, especially in the light-duty sector, is important and necessary, but it is many years away in the heavy duty on- and off-road sectors, even by CARB’s own projections. As we have recommended in past comments4,5,6, the state should pursue a parallel strategy of deep electrification and deep decarbonization of existing liquid petroleum fuels.

For the heavy duty sector, completely displacing petroleum diesel (about 3.4 billion gallons) by the 2030-2035 timeframe with low carbon biodiesel and renewable diesel is achievable through setting more stringent LCFS targets, establishing appropriate policy mechanisms to incentivize greater use of such fuels, and eliminating barriers to deeper deployment of biomass-based diesel and other low carbon fuels. For example, heavy duty vehicle fleets can now achieve 100% sustainability -- with little to no additional cost in fuel, fueling infrastructure, or engines/equipment -- through the use of biomass-based, drop-in fuel blends such as R80/B20 (80% renewable diesel, 20% biodiesel). Such a straightforward and immediately achievable step can significantly reduce GHGs, diesel PM, NOx, and other pollutants now and over the next several decades without interfering with the state’s continuing pursuit of electrification, which will take many years or decades. An optimized mix of policies, incentives, and barrier-reduction strategies can accelerate this decarbonization of the onroad and offroad heavy duty vehicle and equipment pool, including marine and rail applications. This would be especially beneficial for environmental justice communities, many of which are located near high-diesel use sites such as ports, railyards, logistics, and freight corridors.7

Conclusion
We applaud and support CARB's efforts to aggressively address climate change, air quality, and environmental justice in a holistic manner through the Scoping Plan Update. Toward that end, we support Alternative 3 but believe it should be more aggressive and seek the complete displacement of petroleum diesel with drop-in, commercially available biodiesel and renewable diesel. This will enable the state to substantially reduce its petroleum dependency while it continues to pursue electrification in heavy duty transportation. We also strongly recommend that staff pursue the next LCFS rulemaking immediately after the Scoping Plan proceeding with the improvements as noted above. READ MORE

1 Clean Fuels (formerly the National Biodiesel Board) is the U.S. trade association representing the entire supply chain for biodiesel, renewable diesel, and sustainable aviation fuel. The name change reflects our embrace of all the products Clean Fuels members and the U.S. industry are producing, which include biodiesel, renewable diesel, sustainable aviation fuel, and Bioheat® fuel for thermal space heating. Our membership includes over 100 farmers, producers, marketers, distributors, and technology providers, and many are members of environmental organizations supportive of state and local initiatives to achieve a sustainable energy future.

2 California Advanced Biofuels Alliance is a not-for-profit trade association promoting the increased use and production of advanced biofuels in California. CABA represents biomass-based diesel (BMBD) feedstock suppliers, producers, distributors, retailers, and fleets on state and federal legislative and regulatory issues.

3 See Clean Fuels-CABA joint letter, dated May 3, 2022, https://www.arb.ca.gov/lists/com-attach/54-sp22-econhealth-ws-TJXPVE1ADICagNc.pdf.

4 See NBB and CABA joint comment letter, dated Jan. 7, 2022, at https://www.arb.ca.gov/lists/com-attach/125-
lcfs-wkshp-dec21-ws-BWsCZlY1U18LbFM9.pdf, accessed May 3, 2022, incorporated herein by reference.

5 See Clean Fuels comment letter, dated March 7, 2022, at https://www.arb.ca.gov/lists/com-attach/14-sp22-
publichealth-ws-UjFcNlA0AjABaQhX.pdf, accessed May 3, 2022, incorporated herein by reference.

6 See Clean Fuels and CABA joint comment letter, dated April 4, 2022, at https://www.arb.ca.gov/lists/comattach/60-sp22-modelresults-ws-UTJSOFYyUGIAaAlW.pdf, accessed May 3, 2022, incorporated herein by reference.

7 See discussion of Trinity Study on the substantial health benefits of reducing diesel PM by switching from
petroleum distillate to biomass-based diesel at multiple sites across the U.S., including four California sites, FN 4 op
cit., at 4-6. READ MORE