AB32 draft scoping plan

yesterday, the california air resources board (CARB) released the draft scoping plan detailing their plan to achieve the goal of 1990 emissions by 2020 (a 30 percent reduction from business as usual). the sort of bottom line: "...estimates [from economic models] indicated that the overall savings from improved efficiency and developing alternatives to petroleum will on the whole outweigh the costs. This balance is largely driven by current high energy costs and the degree to which measures increase energy efficiency throughout the economy and move California toward alternatives to fossil fuels" (p. 52).

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:

1. 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.
   
2. "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?

on the EJ side, apart from mentioning that the EJAC's input will be taken to heart in coming up with the final plan on a number of issues (e.g. LCFS), they mention the possible use of revenue to achieve AB32's EJ goals (p. 46). CARB is seeking comments on how the revenues should be used. additionally, NOx, VOC, and PM emissions should decrease statewide, contributing to improved public health. a number of other sort of public health and co-benefits questions are raised, but they only state that analyses are ongoing.

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.

EJAC conference call

So, I just listened in on the EJAC conference call. It wasn't too noteworthy, but I did take some notes and thought that I'd send them on to you to sort of solidify my thoughts. I should also note that they were going to produce a summary of the call and I imagine that'll be available sometime soon.

The purpose of the call was to discuss the public health implications of AB32. I got the sense that the folks on the call thought that the scoping plan was not going to adequately address the issue of public health. Here's where my skeptical radar kind of turned on--the default assumption should be that the public health implications of AB32 are going to be marginal, but there were a couple people on the call that seemed to have no clear idea about the ways in which the health impacts of climate change might be different from the health impacts of air pollution. One for example started going off about asthma risk, presumably under the assumption that there was some link…

I think one thing that might be going on is that the EJ community feels that they've been thrown a bone--namely the language used in AB32 to prevent disproportionate impacts and the hype and funding associated with implementing the bill--and they don't want to squander the opportunity to address the issues that they've been working on for decades in some cases. For example, one thing that was addressed was disparities in access to public health facilities (clinics, testing, etc.). I have no doubt that EJ communities do have lower access to these resources, but I have no idea what this has to do with climate change legislation, or how CARB can possibly work to address this.

This became the final of three questions/general comments they wanted to pose to CARB. The first two were reasonable:

1. Policy tools and policy scenarios (scoping plan will apparently include five scenarios: fully regulatory, fully fee-based, three trading). Which is/are best from a public health standpoint? Choose it/them or at least make sure the worst is not chosen.
2. Cumulative impacts. Recognizing that there are existing health issues in many areas, when you lay the preferred policy tools/scenarios on top of them, does the decision change?
3. Ensure that avoided health costs are valued and ensure that existing gaps in public health infrastructure are addressed.
   

As you can see, the third is a little vague. This was admitted on the call. As I said, I don't see how AB32 is the appropriate tool with which to address the third. At any rate, this was the meat of the conversation. A final point was to set up an additional committee--public health oversight committee or something similar--to ensure that these issues are addressed in the scoping plan. They envisioned a two-tiered scheme where the first would include a couple EJAC members, someone from CalEPA and CARB combined with a second tied composed of public health professionals that would actually carry out analysis in support of the first tier's goals (or something).

Doesn't seem like a bad idea in principle, but I think (and you do as well?) that the interesting EJ concerns should be economics-related and not public health related when it comes to climate change. I'd guess that an "economic health" committee would be far more valuable in this context.

o canada

today, stephane dion (canadian leader of the official opposition) unveiled plans for a revenue-neutral carbon tax. i shit you not--it's here--go look!

the great thing is not just that it's an obviously sensible policy (that energy policy wonks have known about for decades and decades, but we won't worry about that now), not that the liberals actually have a chance to implement it. no, neither of those things. the best part is that the comments on the cbc news site are overwhelmingly positive. people understand that the tax would reward those who innovate in terms of energy efficiency and conservation. it's so much easier to understand than a cap and trade system. i _love_ that canadians can propose this but that any mention of tax in the US throws everyone into a shit-fit.

ah, a great day to be canadian. this may actually convince me to vote liberal (i usually go NDP) in the next general.

[edit: so, it seems that the highest rated comments are positive, but there are still a ton of haperite cranks that are up in arms over the plan. still, given recent experiences with carbon taxation in quebec and bc, this would appear to be a positive development. i think the concept of a revenue-neutral shift should be elucidated more clearly.]

just one more from mike davis

i can't resist:

The city is our ark in which we might survive the environmental turmoil of the next century. Genuinely urban cities are the most environmentally efficient form of existing with nature that we possess because they can substitute public luxury for private or household consumption. They can square the circle between environmental sustainability and a decent standard of living. I mean, however big your library is or vast your swimming pool, it'll never be the same as the New York Public Library or a great public pool. No mansion, no San Simeon, will ever be the equivalent of Central Park or Broadway.

i suppose the difference is that you have to share the public pool and the library. the extent to which individuals are willing to turn more towards shared spaces and amenities will largely dictate how the circle is squared.

los angeles/new blog

wowow. i was just pointed to bldg blog (h/t: jason). seems like there’s a lot of great writing about los angeles, and even a mike davis interview. stoked!

davis is right on about pretty much everything. redefining the issue of overpopulation as one of consumption:

If you look at a city like Los Angeles, and its extreme dependence on regional infrastructure, the question of whether certain cities become monstrously over-sized has less to do with the number of people living there, than with how they consume, whether they reuse and recycle resources, whether they share public space. So I wouldn’t say that a city like Khartoum is an impossible city; that has much more to do with the nature of private consumption.

and then:

People talk about environmental footprints, but the environmental footprints of different groups who make up a population tend to differ dramatically. In California, for instance, within the right-wing of the Sierra Club, and amongst anti-immigrant groups, there’s this belief that a huge tide of immigration from Mexico is destroying the environment, and that all these immigrants are actually responsible for the congestion and the pollution – but that's absurd. Nobody has a smaller environmental footprint, or tends to use public space more intensely, than Latin American immigrants. The real problem is white guys in golf carts out on the hundred and ten golf courses in the Coachella Valley. In other words, one retired white guy my age may be using up a resource base ten, twenty, thirty times the size of a young chicana trying to raise her family in a small apartment in the city.

i'm reminded of an anti-immigrant professor at sdsu who apparently takes his classes down to the canyons in san diego where migrant workers live to show them the "environmental degradation" they cause. which exhibits, as davis points out, a profound ignorance of where "environmental" impacts actually originate.

this all ties back to jenny price's piece thirteen ways of seeing nature in LA that discusses how cities like boulder, co are able to exist (propped up by material flows from industrial areas like los angeles). these writers are truly great for trying to actually get to the root causes of modern problems.