CNGVC Provides Public Testimony at Air Resources Board Meeting to Consider Scoping Plan Draft

The California Air Resources Board (CARB) convened a nearly two day meeting last week to review the draft 2022 Scoping Plan Update released for public comment in May. The Scoping Plan is a comprehensive roadmap that lays out the most cost-effective and technologically feasible path for achieving the State’s greenhouse gas reduction goals. CARB is required by law (Assembly Bill 32 (AB 32) – the California Global Warming Solutions Act of 2006 – Chapter 488, Statutes of 2006) to develop then update the Plan at least every five years. The first Plan was created in 2008; this will be the fourth update.

Public comment at the CARB Board Meeting went on for approximately seven hours and included testimony from fleets, community members, industry participants, tribal representatives, utilities and environmental advocates. It was followed the next day by over 4 hours of Board Member deliberation, observations and questions to staff.

In addition to our written comments submitted in collaboration with Natural Gas Vehicles for America (NGVA), CNGVC provided public testimony at the meeting focused on the following themes:

  • Support for the concept outlined in Proposed Scenario No. 3 to achieve carbon neutrality by 2045.
    • We support this Alternative for all the reasons presented by staff in the Draft, which states, in part, “…[it] is more feasible than Alternative 1 and Alternative 2 due to the longer time frame for clean technology and fuel deployment…The additional 10 years for achieving carbon neutrality also allows for technologies to scale and be deployed at lower costs. The Proposed Scenario provides significant health benefits in 2045…and has the least slowing effect on employment and economic growth.”
  • Need to realize near-term emission reductions during the years leading up to the 2045 goal.
    • Infrastructure buildout and the grid reliability needed to support full electrification will take considerable time, yet the Draft Plan lacks a comprehensive strategy for how to realize greater emission reductions today. Therefore, we urged CARB to seize the opportunity to maximize emission reductions in the near-term as well as during the years leading up to the 2045 goal.
  • Include language into Proposed Scenario No. 3 that pursues a strategy to prioritize the rapid phase out of older, higher-emitting diesel trucks.
    • The Draft Plan must simultaneously prioritize near-term and long-term reductions to account for a slower-than-anticipated transportation transition. Therefore, we urged CARB to amend the Draft Plan to include language that not only allows for, but encourages, deployment of the cleanest technology available, like low NOx trucks operated on renewable natural gas (RNG), to achieve near-term reductions if heavy-duty zero-emission trucks are not commercially available.

Board Meeting Discussion
The staff presentation provided an overview of the modeling, analyses, stakeholder feedback and EJAC engagement that ultimately informed the selection of Proposed Scenario No. 3 as their preferred strategy. This alternative uses a broader set of options and better aligns with the Governor’s Executive Order and related statutes.

The Environmental Justice Advisory Committee (EJAC), a group of representatives from communities in the State with the most significant exposure to air pollution, encouraged a more rapid adoption of heavy-duty zero-emission vehicles (ZEV) during their presentation. As a matter of state law under AB 32, EJAC is convened to advise CARB in developing the Scoping Plan and any other pertinent matters necessary for implementing the California Global Warming Solutions Act of 2006. While previously assembled for limited periods of time and purpose, CARB has announced plan to make their existence and engagement permanent.

Additional presentations were also made by invited agency representatives, including Secretary Blumenfeld (California Environmental Protection Agency), Secretary Karen Ross (California Department of Food and Agriculture), and Alice Reynolds (President of the California Public Utilities Commission).

We appreciated the comments made by Board Members Gideon Kracov and Dan Sperling suggesting a role for RNG as a near-term solution in transporation for certain vehicle applications, like waste haulers. We agree that electrification is not possible for all operations, a fact that was acknowledged by Governor Newsom in his Executive Order calling for electrification of all medium- and heavy-duty truck operations by 2045 “where feasible.” Flexibility should be provided so that fleets do not have to forfeit emission reductions by continuing to operate traditional diesel simply because they cannot find a ZEV that is available or operationally viable.

We also agreed with Vice Chair Sandy Berg’s observation that a successful and sustainable transition to economy-wide electrification will hinge on how we implement and execute the strategy. This year’s Scoping Plan is ambitious (as many pointed out at the meeting) and covers a much longer planning horizon than year’s past. It contains equally ambitious timelines, requirements and goals. California policymakers must be thoughtful in their effort to deliver on these promises or risk costly unintended consequences.

We were also intrigued by Board Member Sperling’s suggestion to make the Low Carbon Fuel Standard stronger by increasing the carbon intensity reduction goal from 20 percent to 25 percent by 2030.

You can review all the board materials from last week’s discussion here and access the video recording for both days here.