if you recall, the governor also stated that we should achieve an 80 percent reduction from 2050 business as usual, but this was clearly not the focus of the present plan--either because of the obvious difficulty of achieving that target in the face of population pressures. they mention it only a couple times, once explicitly mentioning that trees are the way to go: "Forests are unique in that planting trees today will maximize their sequestration capacity in 20 to 50 years. As a result, near-term investments in activities such as planting trees will help us reach our 2020 target, but will play a greater role in reaching our 2050 goals" (p. 27). another choice 2050 reference is to improving urban forms (p. 33).
we knew that CARB would probably recommend a cap and trade system. we knew they'd also blend in regulations, since that's obviously their specialty. we got both of these things. regs come in the form of an increasing commitment to energy efficiency, an expansion of the renewables portfolio standard (to 33 percent), the implementation the various transport measures (pavley, LCFS). the cap and trade should be linkable with the western climate initiative. this is sensible, although it's unclear whether there are future plans to join the EU or other schemes. their accounting of GHGs for 2020 is pretty stylized. observe their table 4 which shows the envisioned sectoral responsibilities for reductions. (note to CARB: keep your sector names constant. cf. table 4 and figure 2.)
so transport is responsible for a huge chunk of the reductions. (that means i'm employable.) that's a straight up 30 percent reduction envisioned from that sector. exactly proportional to the total reduction required. a similar proportion is envisioned in electricity while commercial and residential and industry require comparably fewer reductions. however, if cheap reductions are available in those sectors, we'll get at them with a cap and trade scheme.
here's where things get a little funny. that 30 percent transport reduction is substantial. how do they hope to achieve it? they're coming almost entirely from the low carbon fuel standard and pavley (increasing fuel economy). (i should also note here that i'm a little suspicious of their 2020 projections in general--it's possible that they've severely underestimated. details of their modeling are to be released in an appendix to the draft plan at some future date. using EMFAC, transport emissions grow ~120 percent times over the period 1990-2020, whereas here it only shows a growth of 26 percent. smoke and mirrors?)
i suppose that as long as the cap is set properly (although, the transportation weirdness indicates that their overall projection might be completely off) we don't have much to worry about. but they should be more upfront then about what they think their regs are capable of.
additionally bizarre is a complete absence of measures which seek to change behavior. the implicit assumption is that technological change (the largest portion of which--pavley--actually lowers the per-mile cost of driving) will meet transport's share of reductions. then contrast it with language included in the plan:
"Beyond including vehicle efficiency improvements and lowering vehicle miles traveled, the State is reducing the carbon intensity of motor fuels consumed in California" (emphasis added, p. 25). woah, woah, woah. nowhere else in the report do they mention lowering VMT except briefly when then talk about fee-based reductions where they specifically mention congestion pricing, per-mile insurance premiums. they estimate reductions from these, but do not talk about them on the same level as the tech measures and do not include them in their accounting. this could be do to different schools of thought at CARB. it might also be that their 2020 transport estimate is deflated and they realize that much more than pavley/LCFS will be needed to mitigate to the extent required.
it's also a indicative of a larger philosophical problem. nowhere do they mention the idea that climate change is fundamentally a problem of consumption. this is exemplified in the following quotation: "Buildings are the second largest contributor to California’s greenhouse gas emissions" (p.22). or, our inhabitation of buildings leads to their weighing in as the second largest contributor. our heating and cooling of buildings, to be correct. these building emissions don't come from nowhere!
then when they do address behavior, its only in terms of tech. choices: "The same dynamic of changing individual behavior will drive California’s pioneering effort to reduce greenhouse gas emissions. As more people choose to drive low greenhouse gas emitting vehicles, the auto manufacturers will respond with more models and more intensive research. Regulations requiring auto manufacturers to provide these cars will complement the market demand" (p. 65). ok, so we want to reduce VMT, but our individual behavior change is limited to picking a new car?
other confusions they'll need to elaborate on:
- using fees as well as cap and trade (p. 41). i'm pretty sure this makes no sense at all, and maybe they're talking about using fees instead of cap and trade. if that's the case, they should clarify. any fee-based reductions could come instead from lowering the cap, which acts as a de facto fee.
- "Allowing offset projects from outside California to count for compliance under AB 32 could reduce the amount of reductions occurring within the state, and which would reduce the local economic, environmental and public health co-benefits from GHG emission reduction" (p. 44). right, but so does including california in a WCI cap and trade such that california's cap would only determine the initial allocation and not the actual amount of reductions achieved in the state. why apply this logic here and not there?
i'm not convinced that just because CARB's numbers add up that they are an accurate reflection of reality. to me the draft plan opens up a lot more questions than it answers.