Cities Index.
9 20 AM ID 25-1026 – Supplement - Public Comment - Packet_Redacted

Fresno City Council
August 14, 2025

Document
9 20 AM ID 25-1026 – Supplement - Public Comment - Packet_Redacted
Meeting
August 14, 2025
Body
Fresno City Council
Pages
24
Original file
86.0 MB
Text extracted from the city's file for reading and search. Open the original on legistar2.granicus.com. That file is the official record.

According to a 2003 study by the California Air Resources Board, there are over 11.4 million pieces of residential lawn and garden equipment operating throughout the state.

In the South Central Fresno community the emissions from this sector total 12.03 tons per year (TPY) of NOx, 77.53 TPY of VOC and 1.58 TPY of PM2.5. These total emissions contribute 0.66% of the NOx inventory, 2.9% of the VOC inventory, and

0.69% of the PM2.5 inventory.

Figure 4-4: Electric yard equipment helps to reduce emissions near homes and places of business

COMMUNITY CONCERNS AND COMMENTS
Community Steering Committee comments regarding Lawn and Garden equipment included better outreach to inform community members of available incentives and increased incentives for the equipment as well as providing free electric lawn mowers for low income residents.

Additional comments included banning leaf blowers in commercial and residential applications as well as requiring all gas powered equipment to be registered and inspected. The District does not have the authority to regulate the use of leaf blowers or other lawn and garden equipment operating throughout the Valley.

CURRENT CONTROL PROGRAMS
CARB has a SORE program, which includes lawn and garden equipment. In 2020, CARB will consider new standards for small engines to help California meet its goal of reducing smog-forming pollutant emissions from mobile sources by 80 percent in 2031. https://ww2.arb.ca.gov/our-work/programs/small-off-road-engines-sore South Central Fresno Community Emissions Reduction Program September 19, 2019 106 | P a g e
In addition, the District offers incentives to help reduce emissions from gas-powered lawn and garden equipment. The Clean Green Yard Machines (CGYM) program provides funding for the following options:
 The residential CGYM provides rebates for the replacement of an old gaspowered mower with a new electric mower and for the purchase of eligible new electric lawn and garden electric equipment without replacements. To date, this program has replaced over 6,700 lawn mowers with over $1.5 million in funding. http://www.valleyair.org/grants/cgym.htm
 The Commercial CGYM launched in May 2019 and provides funding for the replacement of eligible old gas-powered lawn and garden equipment with battery-powered options for public agencies, private entities, and businesses. http://valleyair.org/grants/cgym-commercial.htm

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
In order to achieve additional emission reductions from the Lawn and Garden category the District will provide enhanced outreach and access to South Central Fresno residents or businesses who would like to participate in our available incentive programs. For the residential program, the District proposes to cover the full cost of an electric lawn mower purchase when replacing an existing gas powered mower.

LG.1: INCENTIVE PROGRAM FOR THE REPLACEMENT OF RESIDENTIAL LAWN

AND GARDEN EQUIPMENT
Overview: The goal of this strategy is to reduce NOx and PM2.5 emissions from residential lawn and garden equipment by replacing existing gas powered units with battery powered zero emission models. Utilizing electric lawn care equipment can provide residents with immediate economic, environmental, and health benefits. The District’s Clean Green Yard Machines program provides incentive funding for the replacement of existing gas powered lawn mower with a new electric model. These incentives range from $100-250 depending on the cost of the new mower. In addition, the District offers incentives up to $50 for the purchase of a new electric lawn mower, edger, trimmer, chainsaw or polesaw without requiring an old piece of equipment to be turned in.

Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2019-2024
Description of Proposed Actions: This strategy will provide South Central Fresno residents with increased incentives for the replacement of residential lawn care equipment utilizing existing District Board-approved criteria, with an increased incentive amount for residents within the community. This measure will increase outreach and South Central Fresno Community Emissions Reduction Program September 19, 2019 107 | P a g e
access to incentive funding while providing rebates up to 100% of the equipment cost of a new electric lawn mower when replacing an existing gas powered model. Residents who do not have an existing piece of equipment to retire would be eligible for incentives up to $50 for the purchase of a new piece of eligible equipment. The goal is to replace 570 gas powered units at an expected cost of $200,000. Estimated emissions reductions associated with this measure include 0.13 tons of PM2.5 and 0.2 tons of NOx.

LG.2: INCENTIVE PROGRAM FOR THE REPLACEMENT OF COMMERCIAL LAWN

AND GARDEN EQUIPMENT
Overview: The goal of this strategy is to reduce NOx and PM2.5 emissions from commercial landscaping operations by replacing existing gas powered equipment with battery powered zero emission models. Advancing clean technology in the area of commercial lawn care can provide meaningful health benefits to San Joaquin Valley residents who are directly impacted and exposed on a daily basis to air pollution generated from lawn care equipment. Emissions from commercial lawn care providers occurs in the South Central Fresno community, directly impacted equipment operators and community residents. The District currently offers a commercial lawn and garden equipment replacement program and provides incentives for the replacement of gas powered equipment with battery operated zero emission technology. These incentives range from $200-$15,000 depending on the equipment type and cost of the new units.

In addition, the program provides incentive funds for additional batteries and chargers to ensure that the equipment is capable of operating for a full day of work.

Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2019-2024
Description of Proposed Actions: This strategy will provide commercial lawn care providers operating in South Central Fresno with enhanced outreach and access to available incentives offered by the District, utilizing Board-approved criteria. The goal of this measure is to replace 60 pieces of commercial grade gas powered lawn and garden equipment at an expected cost of $75,000. Emission reductions associated with this measure will be calculated at a later time.

South Central Fresno Community Emissions Reduction Program September 19, 2019 108 | P a g e

PUBLIC FLEETS

PUBLIC FLEETS IN SOUTH CENTRAL FRESNO
Public agencies, including the City Fresno and Fresno County as well as transit organizations operate a variety of public fleet vehicles within South Central Fresno.

These include a wide variety of light-duty vehicles used for municipal purposes including police vehicles, municipal work vehicles, city and county staff vehicles, etc. These vehicles are typically fueled by conventional gasoline or diesel engines. Emissions from this source category include oxides of nitrogen (NOx) and combustion PM from the internal combustion engines. Mobile sources account for more than 85% of the NOx inventory throughout the Valley.

Figure 4-5: Examples of public fleet vehicles

COMMUNITY CONCERNS AND COMMENTS
Community comments regarding this source category centered on monitoring vehicles for PM2.5 and VOC emissions, continuing to support existing programs, and random SMOG testing.

CURRENT CONTROL PROGRAMS
State and Federal requirements control emissions from passenger vehicles. The Valley Air District does not have jurisdiction over these sources. However, due to the large amount of air pollution that originates from passenger vehicles in the Valley, the District has implemented a suite of programs to reduce pollution from public fleets:
 The District operates the Public Benefit Grants Program. The purpose of this program is to fund the purchase of new electric, plug-in hybrid, or alternative fuel vehicles for public agencies to promote clean air alternative-fuel technologies and the use of low-or zero-emission vehicles in public fleets. This program is currently open and accepting applications on a first-come-first-served basis.  Employer Based Trip Reduction (District Rule 9410) requires large employers to implement measures to encourage employees to take alternative transportation to work through the establishment of an Employer Trip Reduction Implementation Plan (eTRIP).
o An eTRIP is a set of measures that encourages employees to use alternative transportation and ridesharing for their morning and evening commutes.

South Central Fresno Community Emissions Reduction Program September 19, 2019 109 | P a g e
o Each measure contributes to a workplace where it is easier for employees to choose to use ridesharing or alternative
transportation.
o Through this rule, single-occupancy vehicle trips are reduced, thus reducing emissions of oxides of nitrogen (NOx), volatile organic compounds (VOC) and particulate matter (PM).

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
Due to community members’ interest in reducing emissions of criteria pollutants and toxic air contaminants that originate from mobile sources operating in and around the community, the following strategy was developed to reduce emissions associated with the operation of public fleet vehicles.

PF.1: INCENTIVE PROGRAM FOR REPLACING OLDER PUBLIC FLEET VEHICLES

WITH NEW, CLEAN-VEHICLE TECHOLOGY
Overview: To provide increased outreach and access to incentive funding for the replacement of older, higher polluting public fleet vehicles operating within and surrounding South-Central Fresno with new clean vehicle technology.

Replacing older public fleet vehicles is important to reduce the public’s exposure to vehicle emissions including NOx and PM2.5. These pollutants negatively impact human health, especially for sensitive populations such as children. These are new clean vehicle technologies, including plug-in hybrid, battery electric and natural gas that are significantly cleaner than conventionally-powered gasoline and diesel vehicles.

State and Federal requirements control emissions from passenger vehicles. The Valley Air District does not have jurisdiction over these sources. However, due to the large amount of air pollution that originates from passenger vehicles in the Valley, including public fleet vehicles, the District has implemented a suite of programs to reduce pollution from public fleets:
 The Public Benefit Grants Program - http://valleyair.org/grants/publicbenefit.htm.

This program is operated by the District. The purpose of this program is to fund the purchase of new electric, plug-in hybrid, or alternative fuel vehicles for public agencies to promote clean air alternative-fuel technologies and the use of low-or zero-emission vehicles in public fleets. This program is currently open and accepting applications on a first-come-first-served basis.  Employer Based Trip Reduction (District Rule 9410) requires large employers to implement measures to encourage employees to take alternative transportation to work through the establishment of an Employer Trip Reduction Implementation Plan (eTRIP).
o An eTRIP is a set of measures that encourages employees to use alternative transportation and ridesharing for their morning and evening commutes.

South Central Fresno Community Emissions Reduction Program September 19, 2019 110 | P a g e
o Each measure contributes to a workplace where it is easier for employees to choose to use ridesharing or alternative transportation. o Through this rule, single-occupancy vehicle trips are reduced, thus reducing emissions of oxides of nitrogen (NOx), volatile organic compounds (VOC) and particulate matter (PM).

Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2019-2021
Description of Proposed Actions: The goal of this action is to work closely with public agencies, including City of Fresno and Fresno County, to replace vehicles through the District’s Public Benefit Grants Program. This includes increased outreach to public agencies operating vehicles within the community as well as prioritized funding for projects in the community. Depending on the types and cost of vehicles replaced, the proposed funding amount of $8,000,000 would cover the replacement of up to 400 vehicles at an incentive of $20,000 each.

South Central Fresno Community Emissions Reduction Program September 19, 2019 111 | P a g e

EXPOSURE REDUCTION STRATEGIES FOR SENSITIVE

RECEPTORS
Proximity to emission sources can pose health risks for community members, particularly for sensitive groups such as children, the elderly, and those with cardiovascular diseases. Sensitive receptors located in South Central Fresno include schools, daycare facilities, and medical facilities, as shown in the map below. The CARB Blueprint contains suggestions of several measures that can be implemented to reduce exposure to emissions at areas where these sensitive receptors may be particularly vulnerable to exposure, referred as proximity-based goals.

Figure 4-6: Sensitive Receptors in the Community
In discussions about possible exposure reduction measures to implement in the AB 617-selected community, the South Central Fresno Steering Committee placed a high priority on measures that would protect the health of children, including installing advanced filtration systems at schools. Other measures prioritized by the Steering Committee included reducing idling near sensitive receptors, and increasing community member knowledge about actions individuals can take to protect their health.

The Steering Committee also suggested planting trees, installing vegetative barriers at industrial sites and along major roadways, and rerouting trucks off of main through fares. The District has engaged with local government agencies, CARB, and appropriate state agencies that have the authority to implement these strategies.

South Central Fresno Community Emissions Reduction Program September 19, 2019 112 | P a g e
Reducing exposure for sensitive receptors will be accomplished through the implementation of the following measures related to schools, indoor air quality, urban greening, and vegetative barriers.

South Central Fresno Community Emissions Reduction Program September 19, 2019 113 | P a g e

EXPOSURE REDUCTION STRATEGIES FOR SCHOOLS

SCHOOLS IN THE SOUTH CENTRAL FRESNO COMMUNITY
Of the eight public school districts that serve children within the South Central Fresno community boundary, Fresno Unified serves approximately 63% of the 54 active schools in the region. The second- and third-largest districts are the Fresno County Office of Education and Central Unified School District, which serve 13% and 7% of schools respectively. Enlisting the participation and support of the largest districts in the effort to reduce children’s exposure is key to ensuring that benefits are as widespread as possible. Targeting schools located in areas near emissions sources, like Malaga, protects the most vulnerable populations. Each school’s demographics must also be considered: approximately 65% of schools in all districts throughout the boundary serve elementary-aged children. All children, but especially young children, are considered sensitive receptors with respect to air pollution. It is important to prioritize their protection from unhealthy air during their developing years.

COMMUNITY CONCERNS AND COMMENTS
A primary concern expressed by Steering Committee members is to ensure cleaner air both indoors and outdoors for children at school while fully engaging local school districts and parents in clean-air efforts. Although the District lacks the legal authority to appropriate local school districts’ LCAP funding as suggested, it can provide its own incentives to this end. Committee members expressed a desire to prioritize schools in neighborhoods with the highest risk of exposure to pollutants, such as Malaga and Southwest Fresno, and to enlist the cooperation and support of Fresno Unified School District in particular.

CURRENT CONTROL PROGRAMS
The Healthy Air Living (HAL) Schools program empowers participating schools to make informed decisions about outdoor activities based on real-time air quality conditions.

School staff sign up for automated notifications when air quality becomes harmful using the Real-time Air Advisory Network (RAAN) tool, and receive health-protective recommendations for the modification or cancellation of outdoor activities accordingly through the Real-time Outdoor Activity Risk (ROAR) guidelines. The program includes access to resources like anti-idling signs, air quality widgets for school websites, bilingual informational materials, and bilingual educational speakers for students, parents, and staff.

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
Strategies developed to reduce the exposure of children within the community require a twofold approach: increasing enrollment of schools in the HAL School program protects children from exposure to unhealthy outdoor air through the widespread adoption of RAAN and ROAR; further, establishing a new pilot program that offers incentive funds to install advanced air filtration systems in community schools reduces exposure to potentially unhealthy indoor air.

South Central Fresno Community Emissions Reduction Program September 19, 2019 114 | P a g e
SC.1 INCENTIVE PROGRAM TO INSTALL ADVANCED AIR FILTRATION SYSTEMS

IN COMMUNITY SCHOOLS
Overview: The goal of this strategy is to reduce the impact of air pollution on children at schools and daycare facilities. Air filtration reduces the concentration of particulate contaminants from indoor air and is an important component of a school’s Heating Ventilation and Air Conditioning (HVAC) system. Reducing airborne particles (such as PM 2.5) is important because particulate matter negatively impacts human health, especially that of sensitive populations such as children. Older HVAC systems and basic air filtration used in some schools only remove a small fraction of particles in the air that are smaller than 0.3 microns (µm). More efficient HVAC air filters and standalone air cleaners are important for creating healthier air in school classrooms.

Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2019-2024
Description of Proposed Actions: This strategy would provide up to $1,500,000 in incentive funding for schools and daycares in South Central Fresno to install advanced air filtration systems, utilizing existing Community Air Protection Program guidelines.

Proposed funding amounts would provide up to 55 local schools with funding to install HVAC filters with a MERV rating of 14 or greater. Schools with older HVAC systems may receive up to 100% of the cost of approved standalone air cleaner units with HEPA rated filters and a Clean Air Delivery Rate (CADR) appropriate for the classroom size.

Schools that receive high-efficiency HVAC filters may also receive up to 100% of the cost of one (1) set of replacement HVAC filters, and schools that receive standalone air ventilation units may also receive up to 100% of the cost of one (1) set of replacement HEPA filters per unit.

SC.2: REDUCE CHILDREN’S EXPOSURE THROUGH INCREASED ENROLLMENT IN

THE HEALTHY AIR LIVING SCHOOLS PROGRAM
Overview: The goal of this strategy is to reduce children’s exposure to unhealthy air by increasing the enrollment of schools in the Healthy Air Living (HAL) Schools program.

Children are considered sensitive receptors with respect to air pollution because their lungs are developing, they breathe disproportionately more air than adults, and they tend to spend more time exercising outdoors. The Healthy Air Living Schools program asks participating schools to actively monitor local air quality using the Real-time Air Advisory Network (RAAN) and to modify outdoor activities accordingly. This strategy enrolls more schools in the program, effectively reducing the short- and long-term exposure of an increased number of children to harmful air.

Implementing Agency: SJVAPCD
Type of Action: Outreach
South Central Fresno Community Emissions Reduction Program September 19, 2019 115 | P a g e
Implementation: 2019-2024
Description of Proposed Actions: This strategy would seek to enroll all five (5) school districts within the South Central Fresno boundary in the Healthy Air Living Schools program. Participating schools and districts would assign one or more designees to receive automated RAAN notifications when local air conditions become harmful, and would modify, relocate, or cancel outdoor activities such as recess, physical education, practices, and sporting events in accordance with the health-protective Real-time Outdoor Activity Risk (ROAR) guidelines. SJVAPCD representatives would meet with teams of key staff (such as administrators, coaches, nurses, science teachers) from ten (10) schools within the boundary to ensure understanding of and adherence to the program. SJVAPCD representatives would also attend five (5) school community events such as health fairs or parent nights to educate the community about air quality and the HAL Schools program. Related air quality educational materials would be distributed to each district’s Family Services department, community liaison office, or similar for circulation to the public.

South Central Fresno Community Emissions Reduction Program September 19, 2019 116 | P a g e

INDOOR AIR QUALITY
Weatherization measures, such as installing weather-stripping and caulking around windows and doors, can reduce the amount of outdoor air infiltrating into a home and decrease energy costs associated with heating and cooling. However, weatherization has the possibility to have negative impacts on indoor air quality if not accompanied by additional energy upgrades for appliances. Tightening building openings may also have the unintended consequence of allowing contaminants that would otherwise be leaked out of under-weatherized homes to build up to unhealthy levels, including carbon monoxide (CO) from combustion gases and VOCs from consumer products. To address these concerns, a 2010 study was conducted on 514 homes to evaluate the indoor air quality impacts of weatherization performed through the U.S. Department of Energy's (DOE) Weatherization Assistance Program (WAP). Results from the study conclude that, when coupled with other energy efficient upgrades, exposure to CO was reduced4.

Recent programs promoting and incentivizing weatherization have recognized the need to couple residential energy efficiency upgrades with new, efficient appliances. These programs allow the District to work with local partners to bring these residential-level incentives to the community that mitigate exposure to air pollution.

COMMUNITY CONCERNS AND COMMENTS
Community commenters have noted that these weatherization programs already exist.

While the District acknowledges that this funding is not new, the District is committed to establish a new focus on improving indoor air quality by partnering with local agencies.

CURRENT CONTROL PROGRAMS
The District does not fund or regulate weatherization or energy efficiency of homes.

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
Based on the priority placed on reducing exposure to air pollution for sensitive receptors, the following indoor air quality improvement strategies were developed for implementation as a part of the South Central Fresno CERP.

The following is a suggested measure not within the Air District’s jurisdiction to directly implement:

IAQ.1: INCENTIVE PROGRAM FOR WEATHERIZATION AND ENERGY EFFICIENCY Overview: The goal of this strategy is to reduce the impact of and exposure to air pollution on residents within their homes. Weatherization of a home, which can include actions to improve seals around doors and windows, to increase insulation, and to improve air filtration, can reduce penetration of outside pollutants into the home and decrease the overall energy demand for residents. Coupled with solar, the decreased

4 https://www.epa.gov/indoor-air-quality-iaq/protocols-home-energy-upgrades South Central Fresno Community Emissions Reduction Program September 19, 2019 117 | P a g e
energy demands can mean a lot to the community of South Central Fresno, including lower energy bills for low-income households and decreased emissions from natural gas. Without proper weatherization, older homes waste energy, making heating/cooling units work harder to keep your home at a constant temperature, resulting in increased utility costs and emissions.

Implementing Agency: Fresno County Economic Opportunities Commission (Fresno EOC) in partnership with the California Community Services Department (CSD) and the District
Type of Action: Incentives
Implementation: 2019
Description of Proposed Actions: This strategy would provide increased outreach and access to incentive funding for low-income residents in South Central Fresno to receive weatherization services. The California Community Services Department (CSD) empowers and funds local organization partners to provide weatherization and energy service assistance to low-income communities. Fresno EOC, the local partner serving the community of South Central Fresno, provides energy assistance through CSD’s programs to many low-income households in Fresno County each year. The District will work with Fresno EOC to help increase awareness and access for low-income community members to state funding for weatherization programs, including exploring the opportunity for funding air filters for residential use.

Fresno EOC has committed to host a meeting in the South Central Fresno community where residents can learn about available funding for weatherization services and fill out the appropriate forms and applications. Proposed funding amounts could cover up to 100% of the cost of the following weatherization actions:
 Test, repair, or replace refrigerator, water heater, heating/cooling systems, and gas cooking appliances.
 Insulation of walls, ceilings, floors, and attics.
 Weather-stripping, caulking all doors and windows.
 Water heater blankets.
 Carbon monoxide detectors.
 Set-back thermostat.
 Duct testing of heating/cooling systems.

South Central Fresno Community Emissions Reduction Program September 19, 2019 118 | P a g e

URBAN GREENING

URBAN GREENING SOURCES IN SOUTH CENTRAL FRESNO
Urban greening is one way to help improve air quality and public health in addition to enhancing the overall beautification of the community with drought resistant low maintenance greenery. Trees and vegetation help reduce the impacts of heat islands by increasing the amount of shade and cooling the air by evapotranspiration (McPherson, 1994). Careful placement and choice of vegetation will maximize its cooling benefits. Shade provided by trees and other vegetation prevents sunlight from reaching heat-absorbing surfaces such as sidewalks and parking lots, cooling the area by 1 to 9 degrees Fahrenheit. Air quality also benefits from a decrease in energy usage. The less energy used, the fewer power plants running and emitting ozone precursors.5 The total net savings when considering energy, ozone, and PM reduced from vegetation were valued at $210/tree.

Figure 4-7: The Urban Heat Island Effect illustrated (Source: EPA, 1992)

COMMUNITY CONCERNS AND COMMENTS
The steering committees expressed an interest in opportunities for increased urban greening and forestry in the community of South Central Fresno as a strategy to reduce exposure from emissions that occur along local transportation corridors.

CURRENT PROGRAMS
The District Fast Track Action Plan identified Heat Island Mitigation as measure to be implemented with the goal to increase urban forest canopy shading and increase the albedo of structures and pavement. This guidance includes a model resolution and policy statement for use by businesses, government, and organizations who desire to commit to heat island mitigation strategies.

5 http://www.epa.gov/heatisland/resources/pdf/BasicsCompendium.pdf South Central Fresno Community Emissions Reduction Program September 19, 2019 119 | P a g e
Due to the benefits of urban greening, there are several programs available to support urban greening in communities. Below are the ongoing efforts to promote Urban Greening by other agencies, as well as programs committed to be implemented in future State and/or Valley-wide programs.
 California Natural Resources Agency Urban Greening Grant Program:

Consistent with AB 32, the Urban Greening Program will fund projects that reduce greenhouse gases. This program includes urban heat island mitigation projects and energy conservation efforts related to shade tree projects.
 Cal Fire: Through the California Climate Investments (CCI) Urban& Community Forestry Grant Program, CALFIRE works to optimize the benefits of trees and related vegetation through multiple-objective projects as specified in the California Urban Forestry Act of 1978.  Active Transportation Program (ATP): California Department of Transportation (CALTRANS): Urban forestry, such as trees and other vegetation, are significant components of several eligible projects under the ATP, including parks, trails, and safe-routes-to-schools.  California ReLeaf Grants: California ReLeaf seeks and provides passthrough grants to ReLeaf Network Members and other community groups interested in planting and caring for trees in California and offers grant programs through the Social Equity Grant Program and California Arbor Week Grant.
 California Urban Forests Council (CAUFC): As a coalition, CAUFC is dedicated to the expansion and perpetuation of sustainable urban and community forests to enhance the quality of life for all Californians.  Tree Fresno: Tree Fresno has received multiple grants from CalFire to support urban tree planting efforts at Valley parks and campuses.

Non-profit organizations such as One Tree Planted, River Partners, the San Joaquin River Conservancy, the Tree Foundation of Kern, Tree Lodi, and others provide the public the ability to donate to support tree planting and also advocate for the allocation of state and federal funding towards tree planting or replanting in forest, river, and/or urban areas in California.

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
Due to the community’s interest in increased urban greening, the District will be working with other agency partners to bring increased funding for urban greening to the AB 617 selected communities, as further described in the following measure.

South Central Fresno Community Emissions Reduction Program September 19, 2019 120 | P a g e
The following is a suggested measure not within the Air District’s jurisdiction to directly implement:

UG.1 INCREASED URBAN GREENING AND FORESTRY TO IMPROVE AIR

QUALITY
Overview: The goal of this strategy is to improve air quality in the community of South Central Fresno through urban greening and forestry programs. This measure is supported by scientific studies that have shown urban trees and forestry can help with the removal of air pollutants and reduced emissions of volatile organic compounds (VOC’s). The effects of urban trees on fine particulate matter (PM2.5) was modeled for ten U.S. cities, with total annual PM2.5 removal varying from 5.2 tons in Syracuse to

71.1 tons in Atlanta. Overall air quality improvements attributed to urban trees ranged between 0.05% in San Francisco to 0.24% in Atlanta (Nowak, Hirabayashi, Bodine, Hoehn, 2013). Based on a study to assess the effects of urban trees on air quality have found that urban vegetation can attribute to temperature reduction, removal of air pollutants, reduce emission of VOCs, and building energy conservation (United States Department of Agriculture Forest Service, 2002).

The District has long been supportive of the public benefits provided from planting of trees and vegetation. The District’s Fast Track Action Plan, adopted by the Governing Board to reduce ozone pollution in the Valley, identified strategic use of tree and vegetation planting as a potential measure to reduce ozone. There has also been significant efforts at the federal, state, and local levels to promote and increase urban greening and forestry through funding opportunities, programs, and projects.

Jurisdiction Issues: It should be noted that the District has no authority over how agencies allow land under their jurisdiction to be used. These so-called “land-use” decisions, such as whether to allow or require accelerated urban greening efforts, are historically the responsibility, under state law, of cities and counties, or, in some cases, state and federal agencies responsible for transportation corridors, state and federal parks, and other properties. AB 617 does not provide the District with new land-use regulatory authority, so land-use authority remains with cities, counties, and state and federal land-use agencies, as discussed in CARB’s Blueprint (see “Who Has the Authority to Implement Actions?”, page 26 of the Blueprint). However, the District has made available to the responsible agencies the various land-use strategies that have been presented by the Committee for potential inclusion into the CERP for responsible agency’s input and response in the South Central Fresno Community Emissions Reduction Program.

Implementing Agency: City and County, SJVAPCD
Type of Action: Partnership, Incentives
Implementation: 2019-2024
South Central Fresno Community Emissions Reduction Program September 19, 2019 121 | P a g e
Description of Proposed Actions: The goal of this measure is to identify and support efforts to increased urban greening and forestry to improve air quality and overall quality of life for residents in the community of South Central Fresno. This measure would involve efforts to partner, collaborate, and engage with other agencies to fulfil the need for increased urban greening and forestry in the community. The District has begun outreach efforts with Tree Fresno and Releaf California to identify available funding sources to support urban greening projects. The District will consider a funding match to support urban greening projects, contingent on state funding allocations to support new urban greening projects within the AB 617-selected community boundary.

South Central Fresno Community Emissions Reduction Program September 19, 2019 122 | P a g e

VEGETATIVE BARRIERS IN SOUTH CENTRAL FRESNO

BACKGROUND
Vegetative barriers, also known as windbreaks, are composed of one or more rows of trees or shrubs that may be planted in specific areas of concern in order to improve air quality in the immediate area by intercepting airborne particles, dust, chemicals, and odors. Pollutants directly emitted from cars, trucks, and other motor vehicles are found in higher concentrations near major roads. In addition, stationary sources such as industrial facilities, factories, and agricultural operations can also contribute air pollutants to their surrounding areas. While various emission control techniques and programs exist to reduce these pollutants from mobile and stationary sources, vegetative barriers have been shown to be an additional measure to potentially reduce a population’s exposure to air pollution through the interception of airborne particles and the uptake of gaseous pollutants. Examples of vegetative barriers include trees, bushes, shrubs, or a mix of these. Generally, a higher and thicker vegetative barrier with full coverage will result in greater reductions in downwind pollutant concentrations.

In addition to air quality benefits, vegetative barriers can improve aesthetics, increase property values, reduce heat, control surface water runoff, and reduce noise pollution.6 Characteristics of a vegetative barrier that should be considered include the porosity/density of the vegetative barrier, the characteristics of the vegetation during different seasons , leaf surface characteristics, vegetation air emissions (e.g. biogenic VOCs), and the resistance of the vegetative barrier to air pollution. Other considerations include: soil characteristics, availability of water, control of water runoff, maintenance of the vegetative barrier, use of native and non-invasive species, and roadway safety.

Vegetative barriers may also be used with solid barriers to increase mitigation.6 Research is ongoing as to the effectiveness of vegetative barriers in reducing exposure to pollutants, but a recent study has found that vegetative barrier installations may reduce downwind exposure to carbon monoxide and fine particulate matter by at least 23%.7
The US EPA has produced a fact sheet with further information on vegetative barriers, available here: https://19january2017snapshot.epa.gov/sites/production/files/2016- 08/documents/recommendations for constructing roadside vegetation barriers to im prove near-road air quality.pdf

6 Baldauf, R. (2016). Recommendations for Constructing Roadside Vegetation Barriers to Improve Near-Road Air Quality. National Risk Management Laboratory Office of Research and Development, Air Pollution Prevention and Control Division: Washington, DC, USA. 7 Lin, M. Y., Hagler, G., Baldauf, R., Isakov, V., Lin, H. Y., & Khlystov, A. (2016). The effects of vegetation barriers on near-road ultrafine particle number and carbon monoxide concentrations.

Science of the Total Environment, 553, 372-379.

South Central Fresno Community Emissions Reduction Program September 19, 2019 123 | P a g e
Figure 4-8: Vegetative Barrier w/ Solid Barrier on Highway 198, Visalia, CA* Figure 4-9: Vegetative Barrier around Foster Farms, Fresno, CA* *Latest Google Map Information

COMMUNITY CONCERNS AND COMMENTS
The South Central Fresno Steering Committee has identified Vegetative Barriers as a priority for air pollutant mitigation. The committee has expressed the need to enforce existing mitigation plans associated with specific industries. In addition, there is interest in conducting tree planting and “living fence” events.

CURRENT PROGRAMS
The Valley Air District, the City of Fresno, Fresno County, The California Department of Transportation (Caltrans), and other local partners have promoted the use of vegetative barriers for reducing exposure to air pollutants, mitigating the urban heat island effect, and improving aesthetics. The District’s Fast Track Action Plan includes the strategic use of tree and vegetation planting as a potential measure to improve air quality.

Additionally, the Fresno TREES project aims to assess the efficacy of vegetative barriers to reduce near-road pollution exposure, increase vegetative planting in these near-road environments, and help sequester carbon through tree planting.8

8 https://ww2.arb.ca.gov/sites/default/files/2018-06/fresno trees sep.pdf South Central Fresno Community Emissions Reduction Program September 19, 2019 124 | P a g e

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
Based on community interest in vegetative barriers, the following measure was developed for implementation as a part of the South Central Fresno CERP.

The following is a suggested measure not within the Air District’s jurisdiction to directly implement:

VB.1: INCENTIVE PROGRAM FOR THE INSTALLATION OF VEGETATIVE

BARRIERS AROUND/NEAR SOURCES OF CONCERN
Overview: The purpose of this strategy is to provide incentives for the installation of vegetative barriers around/near sources of concern to reduce particulate matter, odor, and other emissions, as feasible. Based on community interest in vegetative barriers, the District will be partnering with other agencies to funnel available grant funding to the community to support the installation of vegetative barriers at/near industrial facilities and along major transportation and goods movement corridors. The District will also work with the National Resources Conservation Service (NRCS) to evaluate the feasibility of installing vegetative barriers near agricultural farms and identify potential additional funding sources.

Jurisdiction Issues: It should be noted that the District has no authority over how agencies allow land under their jurisdiction to be used. These so-called “land-use” decisions, such as whether to allow or require vegetative barriers in specific locations, are historically the responsibility, under state law, of cities and counties, or, in some cases, state and federal agencies responsible for transportation corridors, state and federal parks, and other properties. AB 617 does not provide the District with new landuse regulatory authority, so land-use authority remains with cities, counties, and state and federal land-use agencies, as discussed in CARB’s Blueprint (see “Who Has the Authority to Implement Actions?”, page 26 of the Blueprint). However, the District has made available to the responsible agencies the various land-use strategies that have been presented by the Committee for potential inclusion into the CERP for responsible agency’s input and response in the South Central Fresno Community Emissions Reduction Program.

Implementing Agency: SJVAPCD, CDOT, NRCS, other local partners Type of Action: Partnership, Incentives
Implementation: 2020-2024
Description of Proposed Actions: The District will work closely with the community, City, California Department of Transportation, Natural Resource Conservation Service and others to investigate and identify areas suitable for installation of vegetative barriers.

Type and location of projects will be developed with the input of Steering Committee, and funded as funding sources are identified. The District will consider a funding match of up to $1,000,000 to leverage available state funding allocations for the deployment of vegetative barrier installations within the AB 617-selected community boundary.

South Central Fresno Community Emissions Reduction Program September 19, 2019 125 | P a g e

REDUCING AUTOMOBILE IDLING NEAR SENSITIVE

RECEPTORS

MOBILE EMISSIONS IN SOUTH CENTRAL FRESNO
Even if a vehicle does not move, it still emits pollution if the engine is left on. Idling engines emit volatile organic compounds (VOCs) when running, which react with heat from sunlight to form the gaseous pollutant ozone. They may also emit particulate matter (PM), oxides of nitrogen (NOx) and air toxics like benzene, formaldehyde, and acetaldehyde, all of which can be especially harmful to the health of sensitive populations. Children and seniors are considered sensitive receptors with respect to air pollution and are more likely to suffer adverse health impacts from nearby vehicles idling than healthy adults. Targeting anti-idling outreach to areas commonly serving these sensitive individuals is an important way of reducing exposure.

In South Central Fresno, mobile emissions from on-road vehicles (including light, medium, and heavy duty vehicles) are the most significant source of NOx and air toxics annually. In 2017 alone, vehicles produced 1,103.56 tons of NOx (about 59% of total NOx). Idling contributes to this figure, but is a largely preventable practice.

COMMUNITY CONCERNS AND COMMENTS
In addition to the idling of heavy duty trucks addressed by Strategy HD.6, Steering Committee members expressed concerns about the impacts of emissions from idling automobiles in and around the community. A suggestion from Steering Committee members is that children should be educated about the negative impacts of vehicle idling on health and air quality so that they may encourage their parents to turn their engines off. The Committee also suggested that posted anti-idling signage should be enforced with fines that benefit clean-air efforts in schools. Unfortunately, the District does not have regulatory authority over mobile pollution sources and cannot issue fines for idling.

CURRENT CONTROL PROGRAMS
Although the ability to regulate vehicles lies with State and Federal authorities, the District has implemented many measures to reduce vehicle emissions. These include grant programs providing incentive funds to the public for the purchase of cleaner vehicles (Drive Clean in the San Joaquin), requiring construction and development projects to mitigate emissions produced during the course of construction (Indirect Source Rule), and requiring large employers to encourage their employees to choose alternative transportation to work through the establishment of an Employer Trip Reduction Implementation Plan (eTRIP). However, the preventable problem of idling is best addressed by the Healthy Air Living Schools program. Participating schools receive sets of free bilingual anti-idling signs to post near parent drop-off and pick-up areas, along with educational materials, presentations, and speakers able to address the impacts of idling.

South Central Fresno Community Emissions Reduction Program September 19, 2019 126 | P a g e

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
Due to the interest of community members in reducing emissions of criteria pollutants and toxic air contaminants originating from idling vehicles, the following strategy was developed for inclusion in the CERP. This idle-reduction outreach strategy expands on previous programs by offering anti-idling signage and informational materials to a wider variety of locations that serve sensitive populations in addition to expanding distribution to schools.

IR.1: AUTOMOBILE IDLE-REDUCTION OUTREACH TO REDUCE THE EXPOSURE

OF SENSITVE RECEPTORS TO VEHICLE EMISSIONS
Overview: The goal of this strategy is to reduce the exposure of sensitive individuals to vehicle emissions at locations serving children, seniors, and those with medical conditions. Engines left idling may emit air toxics like benzene, formaldehyde, and acetaldehyde, which can be especially harmful to the health of sensitive populations.

Elevated levels of air toxics and other pollutants can be prevented by encouraging drivers to turn off their engines when parked. It is important to target anti-idling messaging to areas commonly serving sensitive individuals to reduce health impacts on the most vulnerable populations.

Implementing Agency: SJVAPCD
Type of Action: Outreach and Exposure Reduction
Implementation: 2019-2024
Description of Proposed Actions: This strategy would provide and distribute thirty (30) sets of bilingual English and Spanish idle-reduction street signs to be installed in locations that commonly serve sensitive groups throughout the community boundary.

Sites may include the parking lots of schools, child care facilities, libraries, senior centers, parks, nursing homes, medical centers, and pediatric offices. When possible, educational materials or infographics would be provided to each location to explain the importance of reducing idling and its impacts on health and air quality. SJVAPCD representatives would also develop and deliver five (5) presentations about the impacts of vehicle exhaust and related District resources such as incentive funding for cleaner vehicles and school programs that deliver free idle-reduction signs to schools throughout the Valley. Note that idling of heavy duty trucks is proposed to be reduced by Strategy HD.6.

South Central Fresno Community Emissions Reduction Program September 19, 2019 127 | P a g e

COMMUNITY OUTREACH STRATEGIES
The District’s Outreach and Communications team conducts air quality outreach throughout all eight counties of the San Joaquin Valley. The District coordinates events, delivers presentations, responds to the media 24/7, manages social networks, pilots outreach campaigns like the Healthy Air Living (HAL) Schools and Check Before You Burn (CBYB) programs, and connects with the public in multiple languages across any medium. In addition to offering media interviews, taking public calls, partnering with local institutions, and accepting speaking engagements, the District conducts paid advertising and informational campaigns regularly to spread air quality awareness across television, radio, billboards, social media, digital networks, and other venues.

Through the development of innovative tools like RAAN and the Valley Air App, over 8,000 registered users receive automated notifications when the air quality at any location they choose to follow becomes unhealthy, allowing them to make informed decisions about their outdoor activities to limit their own exposure.

COMMUNITY CONCERNS AND COMMENTS
The Committee recommended that the District develop a bilingual app to allow community members to see information from air monitoring equipment deployed as part of the CERP. Real-time air quality data from CERP-specific monitors is available online through the community web page at: http://community.valleyair.org/selectedcommunities/south-central-fresno/air-monitoring/. Additionally, the recently-redesigned Valley Air App allows users to check the air quality at any location using the Real-time Air Advisory Network (RAAN).

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
The Community Air Quality Outreach Strategy goes beyond current outreach efforts to provide community-specific information about local conditions and measures the public can take to protect themselves during episodes of poor air quality through new social media campaigns and workshops hosted in partnership with local civic and community organizations.

The Sharing Clean Air Efforts and How Communities Can Get Involved Strategy further increases awareness of community air quality improvement programs and available incentives by hosting workshops and symposiums with community partners.

O.1: OUTREACH TO INCREASE COMMUNITY AWARENESS AND KNOWLEDGE OF

AIR QUALITY
Overview: The goal of this strategy is to provide additional information to the community about real-time air quality conditions and measures the public can take to protect themselves during episodes of poor air quality. An understanding of what conditions constitute poor air quality, the relative seriousness of a given episode, and any potential health impacts is necessary for the public to make informed decisions about how and when to limit their exposure. It is critical for the public to have widespread knowledge of South Central Fresno Community Emissions Reduction Program September 19, 2019 128 | P a g e
tools available to inform them of real-time conditions, assist with the interpretation of such conditions, and to describe what actions may be taken to protect themselves.

Implementing Agency: SJVAPCD
Type of Action: Outreach
Implementation: 2019-2024
Description of Proposed Actions: This strategy would increase community awareness of available tools to keep informed of real-time changes in air quality through social media campaigns and a series of partner workshops. Social media campaigns would be launched on three platforms: Facebook, Twitter, and Instagram. A partnership with local civic and community organizations would be established to host workshops at locations commonly available to the public such as libraries, schools, and community, health, or recreation centers. Both the social media outreach and live workshops would promote real-time tools such as myRAAN, the Valley Air App, the Real-time Outdoor Activity Risk (ROAR) Guidelines, the wildfire page of the District’s website, as well as information about general air quality education, wildfire smoke impacts, health effects, and similar topics. This strategy would aim to increase myRAAN registrations, Valley Air App downloads, and social media followers among members of the community.

The District will also work with the City of Fresno to explore ways to forward air qualityrelated issues reported through the City’s “FresGo” citizen reporting app directly to the District. With many South Central Fresno residents already familiar with “FresGo,” this strategy, combined with increased outreach about how to use the District’s Valley Air App for reporting these issues, will increase community access to District resources.

Annual Goals for these actions in SC Fresno include:
 Attend/host 4 community meetings to share information  1 community targeted social media campaign
 Circulation of infographics to at least 4 community spaces O.2: OUTREACH TO SHARE CLEAN AIR EFFORTS AND HOW COMMUNITIES CAN

GET INVOLVED
Overview: The goal of this strategy is to increase public awareness of air quality improvement programs currently available through the SJVAPCD. Increased education may lead to more widespread understanding of the air quality challenges faced by both the community and the San Joaquin Valley at large, and greater adoption of the District’s resources, incentive funding, and community engagement. Education is important to empower the public to protect themselves from exposure when possible, to make greater use of District resources and programs, and to encourage community members to adopt practices in their daily lives that help further reduce emissions.

Implementing Agency: SJVAPCD
South Central Fresno Community Emissions Reduction Program September 19, 2019 129 | P a g e
Type of Action: Outreach
Implementation: 2019-2024
Description of Proposed Actions: This strategy would increase awareness of available programs by establishing a series of outreach events within South Central Fresno.

These workshops would be hosted in locations commonly available to the public such as libraries, schools, and community, health, or recreation centers. Topics may rotate to include a wide range of District programs such as Clean Green Yard Machines, Burn Cleaner, Drive Clean in the San Joaquin, Healthy Air Living Schools, and similar topics.

This strategy would also create an annual youth symposium to educate and encourage high school students to share air quality information with their peers, helping to sustain community awareness through future generations.

Annual Goals for these actions in SC Fresno include:
 Attend/host 4 community meetings to share information  1 community targeted social media campaign
O.3: JOINT ADVOCACY FOR CONTINUED/ADDITIONAL FUNDING TO SUPPORT

AIR QUALITY IMPROVEMENT MEASURES
Overview: Continued state funding is key to continued progress addressing community level air pollution and completing the work necessary to engage with the community, monitor emissions, and implement community emission reduction strategies. Over the past three years, the state has provided significant funding for incentive programs to reduce emissions and for completing the work necessary to develop community based emission reduction plans. This funding has largely been from the Greenhouse Gas Reduction Fund that is funded by the Cap and Trade Program. In each of the last two state budgets, the state has allocated $245 million for emission reduction incentives, $50 million for local air district implementation of AB 617, and $10 million for technical assistance grants for community based organizations.

Going forward, there is concern that this funding might be reduced as the Greenhouse Gas Reduction Fund faces additional competition from other non-air quality related state programs. There is no other known funding source to replace this funding if it is lost. To ensure that the goals of the AB 617 legislation are met, CARB, the District, and local communities and other interested parties, must work together to advocate for continued/additional state funding to support the implementation of health protective local measures that reduce community exposure to criteria pollutants and toxic air contaminants.

Implementing Agencies: CARB, SJVAPCD, Local Community Groups Type of Action: Outreach and Advocacy
South Central Fresno Community Emissions Reduction Program September 19, 2019 130 | P a g e
Implementation: Ongoing
Description of Proposed Actions: CARB and the Air District will work with Steering Committee and other interested parties to advocate for additional and continuing funding from the state to implement AB 617 and to fund emission reduction efforts in disadvantaged communities.

South Central Fresno Community Emissions Reduction Program September 19, 2019 131 | P a g e

ADDITIONAL INFORMATION ABOUT REGULATORY

MEASURES TO REDUCE EMISSIONS IN THE COMMUNITY
Due to the nonattainment status of the Valley Air Basin for the criteria pollutants of fine particulate matter and ozone, the District requires that permitted facilities implement the most stringent control measures feasible for implementation to control criteria pollutants and associated precursor emissions. Beyond the regulations and stringent permitting requirements that are already implemented Valley-wide, the following sections detail enhanced regulatory strategies that will be implemented in the AB 617-selected community.

BARCT EXPEDITED SCHEDULE
In addition to community monitoring and emission reduction program requirements, AB 617 requires that air districts located in non-attainment areas perform a Best Available Retrofit Control Technology (BARCT) analysis for all categories of units at facilities subject to the state Cap-and-Trade program. In accordance with AB 617 requirements, the District adopted an expedited schedule for performing further determination of BARCT requirements in December, 2018.

The District utilized an extensive evaluation process to make an initial determination of whether the rules that apply to Cap-and-Trade facilities meet all state BARCT requirements, as mandated by AB 617. While District rules are expected to meet BARCT due to the District’s ongoing extensive regulatory evaluations, the proposed BARCT implementation schedule includes commitments to establish updated BARCT determinations for District rules as required under AB 617. The proposed schedule was prepared through a public process, which included two public workshops. In addition to the BARCT implementation schedule, the District will be proceeding with amending a number of District rules included as commitments in the new 2018 PM2.5 Plan, as discussed earlier in the CERP, that are also subject to the AB 617 BARCT implementation requirement.

In conjunction with District rules applicable to stationary source equipment, under the District’s New Source Review permitting regulation, new facilities or facilities modifying equipment that emit air pollutants greater than 2 pounds per day (lb/day), are subject to stringent emissions control requirements. For each piece of equipment that has the potential to emit over the 2 lb/day threshold, the District requires the use of the best available air pollution control technology (BACT) used to control emissions from similar types of equipment. As part of this BACT analysis, the District determines if cleaner technologies that are not generally used for the equipment being analyzed could be used to further reduce emissions from the proposed equipment. This very stringent requirement ensures that the most effective air pollution control technique is utilized, resulting in the least amount of air pollution possible.

In addition to these stringent requirements on new sources of air pollution, rules adopted in the San Joaquin Valley are regularly analyzed for compliance with the state’s BARCT requirements.

South Central Fresno Community Emissions Reduction Program September 19, 2019 132 | P a g e
Best Available Retrofit Control Technology (BARCT)
Existing stationary sources in non-attainment areas such as the San Joaquin Valley have been subject to BARCT requirements since the 1980s, although some nonattainment areas with market-based criteria pollutant reduction programs were not required to apply BARCT to facilities complying with those market-based programs.

Although AB 617 does not specifically define BARCT, California Health and Safety Code (CH&SC) Section 40406 defines BARCT as follows:

Best Available Retrofit Control Technology (BARCT) is an air emission limit that applies to existing sources and is the maximum degree of reduction achievable, taking into account environmental, energy and economic impacts by each class or category of source.

Unlike other regions in the state, the District has not relied on market-based systems such as South Coast AQMD’s RECLAIM program to achieve regional emissions reductions needed for attainment. Such market-based systems allow sources of pollution to avoid installing BARCT-level controls if regional emissions are reduced at an established rate. This potential path to avoiding installing the best air pollution controls in other air districts was a significant portion of the genesis of this BARCT requirement of AB 617.

In contrast, businesses in the San Joaquin Valley have always had to comply with BARCT in accordance to the implementation schedules established in District rules.

When developing attainment plans or amending prohibitory rules, the District evaluates all applicable sources of emissions for potential strategies to reduce emissions. These evaluations include an exhaustive search of air quality regulations throughout the nation, review of existing emission control technologies, and analysis of advanced emission control technologies that may soon be available, to identify potential technologically and economically feasible emission reduction measures. Through these processes, the District demonstrates on an ongoing basis that District rules meet state and federal emission control requirements, including BARCT and Most Stringent Measures, which exceeds BARCT requirements. Therefore, given the District’s ongoing and extensive work to identify and apply most stringent measures necessary to attain the ever-tightening federal health-based standards under the Clean Air Act, it is anticipated that most if not all District rules satisfy BARCT requirements.

The District recognizes that emission control technologies are continually evolving, and therefore robust and ongoing analysis is necessary to demonstrate that the District’s rules continue to meet BARCT and other requirements on an ongoing basis.

Furthermore, in the context of the 2016 Ozone attainment plan, the recently adopted PM2.5 attainment plan, and upcoming plans, future rule development actions will be required and, in this process, rules that have recently been determined to meet BARCT during this AB 617 analysis may be subject to further analysis to ensure they continue to meet BARCT requirements. Additionally, in those instances where the District is South Central Fresno Community Emissions Reduction Program September 19, 2019 133 | P a g e
made aware of new technology, further case specific and rule specific BARCT determinations may be conducted.

Affected Rules Included in the District’s Expedited BARCT Implementation Schedule As captured in Section 40920.6 of the Health and Safety Code, AB 617 identifies specific requirements for the District to meet when establishing the expedited BARCT implementation schedule. AB 617 requires the schedule to apply to each industrial source that, as of January 1, 2017, was subject to a specified market-based compliance mechanism and give highest priority to those permitted units that have not modified emissions-related permit conditions for the greatest period of time.

Based on information provided by CARB, as of January 1, 2017, 109 facilities within the District were identified as being subject to the state Cap-and-Trade program, a marketbased compliance mechanism adopted by the state board pursuant to subdivision (c) of Section 38562, and therefore AB 617 BARCT requirements. Evaluating the 109 affected facilities, the District identified that approximately 4,500 active permit units are within the scope of this BARCT analysis. From the 4,500 active permit units, the District determined that 32 District rules that apply to specific source categories of equipment were subject to the BARCT analysis required under AB 617.

District staff performed analysis of 32 affected rules and determined that:
 5 rules were superseded by a more stringent rule known to meet BARCT or by a rule subject to further BARCT analysis,
 5 rules were determined to meet Most Stringent Measures (MSM) for NOx, the only relevant pollutant for these affected rules and therefore meet BARCT, and  6 rules were specifically determined to meet BARCT through an extensive rule and source category evaluation that compared our rule requirements with federal and state air quality regulations and with regulations of other air districts in California.
 While the remaining 16 rules likely already meet BARCT due to the District’s ongoing extensive regulatory evaluations and enhancements, the proposed BARCT implementation schedule includes commitments to establish updated BARCT determinations for these rules.

Prioritization Criteria for Expedited BARCT Analysis Schedule Section 40920.6(c)(3) of the Health and Safety Code requires Districts to give highest priority to conduct the BARCT analysis to those rules affecting permitted units that have not modified emissions-related permit conditions for the greatest period of time. To assist in further prioritization, the District also considered local public health, clean air benefits to the surrounding community, and regional air quality and attainment benefits by prioritizing units that emit NOx and are located within communities selected for action under AB 617. In addition, while cost-effectiveness of controls can’t be fully analyzed until each rule is addressed during the development of a BARCT rule, the District also prioritized rules with the greatest number of potentially affected units, which, when coupled to the law’s requirement of prioritizing based on the length of time since the

South Central Fresno Community Emissions Reduction Program September 19, 2019 135 | P a g e
4401 Steam-Enhanced Crude Oil
Production Wells Scheduled 2021 2022
4566 Organic Material Composting
Operations Scheduled 2021 2022
4625 Wastewater Separators Scheduled 2021 2022
4621
Gasoline Transfer Into Stationary
Storage Containers, Delivery
Vessels, and Bulk Plant
Scheduled 2021 2022
4402 Crude Oil Production Sumps Scheduled 2021 2022
4351 Boilers, Steam Generators, and
Process Heaters - Phase 1
Rule
superseded by
more stringent
rules, District
Rules 4305,
4306, and 4320
--- ---
4405
Oxides of Nitrogen Emissions from
Existing Steam Generators Used in
Thermally Enhanced Oil Recovery -
Central and Western Kern County
Fields
Rule
superseded by
more stringent
rules, District
Rules 4305,
4306, and 4320
--- ---
4406 Sulfur Compounds from Oil-Field
Steam Generators - Kern County
Rule
superseded by
more stringent
rules, District
Rules 4305,
4306, and 4320
--- ---
4305 Boilers, Steam Generators, and
Process Heaters - Phase 2
Rule
superseded by
District Rules
4306 and 4320,
more stringent
rules
--- ---
4701 Internal Combustion Engines -
Phase 1
Rule
superseded by
District Rule
4702, a more
stringent rule
--- ---
4309 Dryers, Dehydrators, and Ovens
Rule
determined to
meet BARCT
--- ---
4703 Stationary Gas Turbines
Rule
determined to
meet BARCT
--- ---
4306 Boilers, Steam Generators, and
Process Heaters - Phase 3
Rule
determined to
meet BARCT
--- ---
4307
Boilers, Steam Generators, and
Process Heaters - 2.0 MMBtu/hr to

5.0 MMBtu/hr
Rule
determined to
meet BARCT
--- ---

South Central Fresno Community Emissions Reduction Program September 19, 2019 138 | P a g e
 to identify facilities causing localized health impacts on nearby residents,  to determine facility-wide health risks resulting from the emission of toxic air contaminants,
 to notify nearby residents and businesses of significant risk facilities in their vicinity, and
 to require that significant risk facilities reduce their risks below the level of significance in accordance with the provisions of the “Emissions Inventory Criteria and Guidelines Report” adopted by the Air Resources Board.

District’s Implementation of AB 2588
The District’s implementation of AB 2588, California’s Air Toxics “Hot Spots” Information and Assessment Act, has resulted in major reductions in emissions of air toxics from existing sources in the San Joaquin Valley. Under this right-to-know law, the District has worked with Valley facilities to quantify emissions of air toxics, determine the health risk caused by those emissions, report emissions and any significant risks through written public reports and neighborhood public meetings, and take steps to reduce such risks. As a result of this effort, and the resulting emissions reductions, no Valley facility currently poses a significant risk under this program.

The District’s integrated air toxics program fulfills the state AB 2588 Hot Spots mandates, aimed at quantifying and assessing localized health risk, notifying affected residents, and reducing risk from facilities with high risk caused by air toxic emissions.

In addition, the District’s integrated air toxics program incorporates Airborne Toxic Control Measure (ATCM) regulations promulgated by the Air Resources Board, requiring prescribed control measures for various source categories that cause significant risks at a regional level. Furthermore, the District’s integrated program fulfills federal mandates under Title III of the federal Clean Air Act, requiring Maximum Available Control Technology (MACT) for sources of air toxics.

In addition to the state and federal mandates, the District’s integrated air toxics program also implements the more stringent local permitting and California Environmental Quality Act (CEQA) requirements, specifically to ensure installation of Best Available Control Technology (BACT) for air toxics and that new permits or modifications to existing facilities will not result in a significant increase in health risk to the public.

The District has spent the last two decades implementing a wide variety of methods to reduce toxic air contaminant emissions in the San Joaquin Valley. Based on the latest California Toxics Inventory, only 14% of all air toxics in the San Joaquin Valley are now emitted from stationary sources of pollution under the direct control and regulation of the District, while 52% comes from mobile sources such as cars and trucks, and the remaining 34% is emitted from area-wide sources like road dust, paints, solvents, and other consumer products. Mobile and area-wide sources of emissions are generally under the regulatory authority of the State of California and the federal government.

The District’s integrated approach to addressing and reducing risks from toxic air contaminants has taken three main paths:

South Central Fresno Community Emissions Reduction Program September 19, 2019 139 | P a g e
 Reducing air toxic emissions from existing stationary sources of emissions;  Preventing the creation of new or modified stationary sources of significant risk; and
 Finding creative and cooperative methods of reducing risk from emissions sources that the District does not typically regulate.

In 2015, the District began implementing the state Office of Environmental Health Hazard Assessment’s (OEHHA’s) revised Guidance on Preparation of Health Risk Assessments that was adopted by OEHHA in early March 2015. Following OEHHA revised guidelines, the District began a health risk reassessment of all facilities located in the San Joaquin Valley. The health risk reassessment follows the phased processing schedule outlined in AB 2588, which was originally implemented in the late 80’s and early 90’s. AB 2588 subjected three major categories (or phases) of facilities to the regulation based upon their level of annual emissions.

Reassessment of facilities subject to the AB2588 Hot Spots regulation is a multi-year process with that has started in 2016, following the phases identified below:
 Phase I Facilities (≥ 25 tons emissions per year)
 Phase II Facilities (10 ≤ tons emissions per year < 25)  Phase III Facilities (< 10 tons emissions per year)
 Phase IV Facilities (Industry-wide and agricultural facilities) Prioritizing Facility Health Risks
Based on the emissions inventory, the District is prioritizing each facility’s health risk using complex computerized database and modeling programs. A “prioritization” is a conservative health risk assessment screening analysis, resulting in a facility prioritization score used to determine if a more refined health risk assessment is necessary. As part of this process, very conservative assumptions are utilized, with many safety factors built in to determine the worst-case health risk to possible receptors. The purpose of those safety factors is to ensure that the most sensitive receptors (children, elderly, pregnant women and people with weakened immune systems) are protected. Facilities ranked as high priority are required to perform health risk assessments. The District prioritizes and ranks the health risk posed by the facility as "low", "intermediate", or "high" priority, based on the following:
 Low Priority: Prioritization Score < 1
Facility Exempt from further AB 2588 requirements
 Intermediate Priority: 1 < Prioritization Score < 10
Facility required to provide Update Summary every
four years
 High Priority: Prioritization Score > 10
Facility required to perform a refined Health Risk
South Central Fresno Community Emissions Reduction Program September 19, 2019 140 | P a g e
Assessment
Health Risk Assessment Process
When a facility’s prioritization score exceeds 10, the facility is classified as “High Priority” and a Health Risk Assessment (HRA) is required for the facility, and such facility is required to submit an HRA for District approval. The District and State Office of Environmental Health Hazard Assessment (OEHHA) are required by the Air Toxics "Hot Spots" Act to review each HRA. Risk calculation involves a great deal of uncertainty. The uncertainty arises from lack of data in many areas necessitating the use of assumptions. As part of this process, again, very conservative assumptions are utilized, with many safety factors built in to determine the worst-case risk to possible receptors. The purpose of those safety factors is to ensure that the most sensitive receptors (children, elderly, pregnant women and people with weakened immune systems) are protected. The assumptions used are designed to be health protective in order to avoid underestimating the risk to the public. Therefore, while the actual risk may be much less than the calculated risk, it is very unlikely to be higher than calculated.

Upon approval of facility HRA, the District determines the facility’s health risk status, which is classified as a low risk, intermediate risk, high risk, or risk reduction required, based on the following HRA scores:
 Low Risk: HRA cancer risk < 1 in a million, and
HRA total hazard index of < 0.1
(Facility Exempt from further AB 2588 requirements)
 Intermediate Risk: 1 < HRA cancer risk < 10 in a million, or

0.1 < HRA total hazard index < 1.0
(Facility required to provide update summary on a
quadrennial basis)
 High Risk: HRA cancer risk > 10 in a million, or
HRA total hazard index of > 1.0
(Public Notice)
 Risk Reduction Required: HRA cancer risk > 100 in a million cancer, or HRA total hazard index of > 5.0
(Public Notice and Risk Reduction Audit Plan)
Facilities that pose health risks above District action levels are required to submit plans to reduce their risk. The Risk Reduction Audit Plan (RRAP) trigger level for cancer risk is 100 cases per million exposed persons, based on the maximum exposure beyond facility boundaries at a residence or business. The action level (Risk Reduction Audit Plan) for non-cancer risk is a hazard index of 5 at any point beyond the facility boundary where a person could reasonably experience exposure to such a risk.

South Central Fresno Community Emissions Reduction Program September 19, 2019 141 | P a g e
The District's review of completeness of the facility’s RRAP includes a substantive analysis of the emission reduction measures included in the plan, and the ability of those measures to achieve emission reduction goals as quickly as feasible. If the District determines that the RRAP does not meet those requirements, the District shall remand the audit and plan to the facility specifying the deficiencies identified by the District. A facility operator shall submit a RRAP addressing the deficiencies identified by the District within 90 days of receipt of a deficiency notice. An updated prioritization and/or health risk assessment shall be determined based on the approved RRAP.

AB 617 Community Facility Lists with Associated AB 2588 Designations Assembly Bill 617 requires the California Air Resources Board (CARB) and air districts to develop and implement emissions reporting for disadvantaged communities. With the establishment of the selected community boundaries, the District has put into effect a plan to expedite and streamline the AB 2588 reassessments for facilities located within the selected community of South Central Fresno.

Community-Based AB 2588 Reassessments
Based on previous AB 2588 analyses and on the on-going District’s integrated air toxics program, no Valley facilities have been determined to pose significant risk. Therefore, no existing facility(s) have or have been required to prepare a Risk Reduction Audit Plan. However, as mentioned above, the District is currently in the process of reassessing Valley facilities under AB 2588, which includes those in South Central Fresno.

Please refer to Appendix E for further details about the District’s Health Risk Assessment Process, and a table identifying the AB 2588 reassessment status of each facility within the community as of September 9, 2019.

ENFORCEMENT STRATEGIES
To support strategies developed in partnership with community members, District staff have developed several enforcement strategies that will enhance the District’s robust existing enforcement program in the AB 617-selected community. Information about new enforcement measures that apply to a specific source category of concern to the community have been included in the strategy discussion for that source of concern.

These enforcement measures include increased stationary source inspection frequency, increased surveillance to reduce residential burning, free training programs for gasoline dispensing facility operators, and increased enforcement of District rules that control fugitive dust. Further details about all enforcement measures that will apply to South Central Fresno are provided in the CERP Enforcement Plan.

South Central Fresno Community Emissions Reduction Program September 19, 2019 142 | P a g e

STATEWIDE STRATEGIES
This section provided by the California Air Resources Board Overview of California Air Resources Board’s Statewide Actions Community-scale air pollution exposure is caused by many factors, including the cumulative impacts from multiple pollution sources. Effective solutions require multiple strategies at both the statewide and local level to deliver new emissions reductions directly within these communities.

The California Air Resources Board (CARB) has adopted a number of comprehensive air quality and climate plans over the last several years that lay out new emissions reduction strategies. These plans include the State Strategy for the State Implementation Plan,9the California Sustainable Freight Action Plan,10 California’s 2017 Climate Change Scoping Plan,11 and the Short-Lived Climate Pollutants Reduction Strategy,12 along with a suite of incentive programs. The Community Air Protection Blueprint13 further identified additional actions to reduce the air pollution burden in heavily impacted communities throughout the State. Together, these plans provide a foundation for the new actions identified as part of this community emissions reduction program.

This section illustrates CARB’s statewide role in the community emissions reduction program, by broadly describing the regulatory, enforcement, and incentive-based actions CARB has taken to reduce emissions statewide. It also highlights specific foundational CARB actions that address areas of concern identified by the South Central Fresno community.

9 California Air Resources Board, Revised Proposed 2016 State Strategy for the State Implementation Plan, March 7, 2017, available at: www.arb.ca.gov/planning/sip/sip.htm. 10 California Department of Transportation, California Sustainable Freight Action Plan, July 2016, available at: http://www.dot.ca.gov/hq/tpp/offices/ogm/cs_freight_action_plan/theplan.html. 11 California Air Resources Board, California’s 2017 Climate Change Scoping Plan, November 2017, available at: www.arb.ca.gov/cc/scopingplan/scopingplan.htm. 12 California Air Resources Board, Short-Lived Climate Pollutant Reduction Strategy, March 2017, available at: www.arb.ca.gov/cc/shortlived/shortlived.htm. 13 California Air Resources Board, Final Community Air Protection Blueprint for Selecting Communities, Preparing Community Emissions Reduction Programs, Identifying Statewide Strategies, and Conducting Community Air Monitoring, October, 2018, available at: https://ww2.arb.ca.gov/ourwork/programs/Community-Air-Protection-Program.

South Central Fresno Community Emissions Reduction Program September 19, 2019 143 | P a g e

REGULATORY PROGRAMS
Federal, State, and local air quality agencies all work together to reduce emissions. At the federal level, the U.S. Environmental Protection Agency (U.S. EPA) has primary authority to control emissions from certain mobile sources, including sources that are all or partly under federal jurisdiction (e.g., some farm and construction equipment, aircraft, marine vessels, locomotives), which it shares in some cases with air districts and CARB. The U.S. EPA also establishes ambient air quality standards for some air pollutants.

At the State level, CARB is responsible for controlling emissions from mobile sources and consumer products (except where federal law preempts CARB’s authority), controlling toxic emissions from mobile and stationary sources, controlling greenhouse gases from mobile and stationary sources, developing fuel specifications, and coordinating State-level air quality planning strategies with other agencies.

Regionally, air districts are primarily responsible for controlling emissions from stationary and indirect sources (with the exception of consumer products in most cases) through rules and permitting programs within their regions.

CARB regulatory programs are designed to reduce emissions to protect public health, achieve air quality standards, reduce greenhouse gas emissions, and reduce exposure to toxic air contaminants. CARB establishes regulatory requirements for cleaner technologies (both zero and near-zero emissions) and their deployment into the fleet, for cleaner fuels, and to ensure in-use performance. CARB’s regulatory programs are broad – impacting stationary sources, mobile sources, and multiple points within product supply chains from manufacturers to distributors, retailers, and end-users. CARB’s regulations affect cars, trucks, ships, off-road equipment, consumer products, fuels, and stationary sources.

One important and relevant regulatory authority of CARB’s is to adopt measures to reduce emissions of toxic air contaminants from mobile and non-mobile sources, known as Airborne Toxic Control Measures (ATCM).14 These regulatory measures include process requirements, emissions limits, or technology requirements. Additionally, CARB implements the Statewide Air Toxics “Hot Spots” Program15 to address the health risk from toxic air contaminants at individual facilities across the State. The Air Toxics “Hot Spots” Program includes several components to collect emissions data, identify facilities having localized impacts, ascertain health risks, notify nearby residents of significant risks, and reduce those significant risks to acceptable levels.

Under the Air Toxics “Hot Spots” Program, air districts are required to set a threshold for facilities that pose a significant health risk and prioritize facilities for health risk

14 California Health and Safety Code § 39650 et seq.
15 Assembly Bill 2588, Air Toxics "Hot Spots" Information and Assessment Act, Connelly, Statutes of 1987, California Health and Safety Code § 44300 et seq.

South Central Fresno Community Emissions Reduction Program September 19, 2019 144 | P a g e
assessments. Air districts also establish a risk value above which facilities must conduct a risk reduction audit and emissions reduction plan. Facilities must develop these health risk assessments, risk reduction audits, and emission reduction plans.

CARB provides technical guidance to support smaller businesses conducting health risk assessments and developing emissions reduction plans.

Additionally, CARB has pursued enforceable agreements with industry that result in voluntary but enforceable adoption of the cleanest technologies or practices and provide assurance that emissions reductions will be realized. CARB’s agreement with the Union Pacific Railroad Company and BNSF Railway Company to accelerate introduction of cleaner locomotives in the South Coast Air Basin is an example of an enforceable agreement.

For more information on CARB’s Air Toxics “Hot Spots” Program, visit:
https://www.arb.ca.gov/ab2588/ab2588.htm. For more detailed information on CARB’s statewide emissions reduction strategies, see Appendix C of the Community Air Protection Blueprint at: https://ww2.arb.ca.gov/our-work/programs/community-airprotection-program.

ENFORCEMENT PROGRAMS
To achieve the reductions associated with rules and regulations, regulated entities must comply with requirements and technology must function as expected. CARB’s goal, set out in more detail in statute and in its Enforcement Policy, is to achieve comprehensive compliance with every regulation the CARB Governing Board has adopted, and the Enforcement Program finds violations, investigates cases, and resolves cases through either the administrative settlement process, or litigation. CARB’s enforcement efforts encompass a broad spectrum of programs, including certification requirements for vehicles, engines, aftermarket parts, consumer products, and fuels; in-use fleet requirements focused on diesel mobile sources; and greenhouse gas standards for stationary sources.

CARB settlement of enforcement cases can also fund Supplemental Environmental Projects, which are not otherwise required by law or regulation but benefit air quality by reducing emissions, reducing exposure to air pollution, or preventing future air quality violations. 16 Examples of Supplemental Environmental Projects include installation of air filtration systems in schools, increasing services to children with asthma, and school bus and diesel emissions reduction projects.

One critical and relevant enforcement program is CARB’s continued effort to streamline the Truck and Bus Regulation enforcement process.17 This work is closely linked to

16 California Air Resources Board, Supplemental Environmental Project (SEP) Policy (Oct. 4, 2017) available at https://ww2.arb.ca.gov/resources/fact-sheets/supplemental-environmental-projects 17 For more information on the Truck and Bus Regulation, visit:
http://www.arb.ca.gov/msprog/onrdiesel/onrdiesel.htm.

South Central Fresno Community Emissions Reduction Program September 19, 2019 145 | P a g e
implementation of Senate Bill 1,18 which ties truck registration in California to compliance with the Truck and Bus Regulation. Once fully implemented, CARB’s Enforcement Program will identify potential violators through Department of Motor Vehicles’ registrations, notify potential violators, give violators an opportunity to prove compliance, and finally place registration holds on all trucks that do not comply with the regulation. This process is expected to significantly improve the compliance rate with the Truck and Bus Regulation and improve air quality along trucking corridors in California.

For more detailed information on CARB’s Enforcement Programs, visit:
https://www.arb.ca.gov/enf/enf.htm.

INCENTIVE PROGRAMS
CARB operates incentive programs that reduce the costs of developing, purchasing, or operating cleaner technologies. The programs help ensure cleaner cars, trucks, equipment, and facilities are operating in our neighborhoods by driving the development of new, cleaner technologies, and by accelerating their sale and adoption. Specifically, they accelerate the introduction of advanced technology vehicles and equipment, accelerate the turnover of older and higher emitting vehicles and equipment, and increase access to clean vehicles and transportation in disadvantaged communities and lower-income households.

Examples of CARB incentive programs include the Carl Moyer Memorial Air Quality Standards Attainment Program19 (the Community Air Protection Incentives20 are implemented by the air district through this program), Proposition 1B: Goods Movement Emission Reduction Program,21 Funding Agricultural Replacement Measures for Emission Reductions Program,22 and Low Carbon Transportation Investments and Air Quality Improvement Program (which includes the Hybrid and Zero-Emission Truck and

18 California Vehicle Code § 4000.15(a).
19 For more information on the Carl Moyer Memorial Air Quality Standards Attainment Program, visit:
https://www.arb.ca.gov/msprog/moyer/moyer.htm.
20 For more information on the Community Air Protection Incentives, visit:
https://www.arb.ca.gov/msprog/cap/capfunds.htm
21 For more information on the Proposition 1B: Goods Movement Emission Reduction Program, visit:
https://www.arb.ca.gov/bonds/gmbond/gmbond.htm.
22 For more information on the Funding Agricultural Replacement Measures for Emission Reductions Program, visit: https://ww2.arb.ca.gov/our-work/programs/farmer-program.

South Central Fresno Community Emissions Reduction Program September 19, 2019 146 | P a g e
Bus Voucher Incentive Project).23 While CARB is responsible for program oversight, some of these programs are implemented as a partnership with local air districts.

For more information on air pollution incentives, grants, and credit programs, visit:
https://www.arb.ca.gov/ba/fininfo.htm.

CARB ACTIONS RELATED TO THE SOUTH CENTRAL FRESNO COMMUNITY This section highlights CARB actions that specifically relate to the South Central Fresno community. This list should not be interpreted as comprehensive or exhaustive, but rather illustrative of some of the major statewide strategies driving emissions reductions in conjunction with those local level strategies identified in this community emissions reduction program. The full list of CARB foundational strategies can be found in Appendix D and Appendix F of the Community Air Protection Blueprint.24 Real Emissions Assessment Logging System – As part of an on-board diagnostic regulation, a new emissions tracking program for excess smog-related and greenhouse gas emissions (Real Emissions Assessment Logging) will provide CARB with the ability to monitor emissions performance of all vehicles, including medium- and heavy-duty vehicles, allowing regulators to recognize and correct problems faster. For more information on the regulation and the emissions tracking program, visit:
https://ww2.arb.ca.gov/news/carb-gets-real-further-cut-pollution-diesel-and-gasvehicles.

Heavy-Duty On-Road and Off-Road Engine In-Use Testing – CARB is working through a public process to consider implementation of Heavy-Duty On-Road and OffRoad Engine In-Use Testing to use real world screening of heavy-duty trucks and offroad engines operating in selected communities to target heavy-duty in-use compliance testing. Engines emitting above expected levels may be brought into CARB’s in-use compliance program. Non-compliant engines may be recalled and emission mitigation projects could include the deployment of zero emission technology in selected environmental justice communities. For more information, see Appendix F, page F-8, of the Community Air Protection Blueprint.

Reducing Emissions from Oil and Gas Systems – The Short-Lived Climate Pollutant Reduction Strategy establishes a goal of reducing fugitive methane emissions from oil and gas by 40 percent below current levels in 2025 and a minimum 45 percent in 2030,

23 For more information on the Low Carbon Transportation Investments and Air Quality Improvement Program, visit: https://ww2.arb.ca.gov/our-work/programs/low-carbon-transportation-investmentsand-air-quality-improvement-program. 24 California Air Resources Board, Final Community Air Protection Blueprint for Selecting Communities, Preparing Community Emissions Reduction Programs, Identifying Statewide Strategies, and Conducting Community Air Monitoring, October, 2018, available at: https://ww2.arb.ca.gov/ourwork/programs/Community-Air-Protection-Program.

South Central Fresno Community Emissions Reduction Program September 19, 2019 147 | P a g e
and from all other sources by 40 percent in 2030. In addition to California’s comprehensive and stringent emerging framework to reduce methane emissions from oil and gas systems, in 2017 CARB adopted and is now implementing, with the help of the local air districts, a regulation that will reduce fugitive methane emissions by about 44 percent by 2021 from the oil and gas production, processing, and storage sector.

This regulation is also estimated to reduce volatile organic compounds emissions from oil and gas operations statewide by over 3,600 tons per year, and to reduce toxic air contaminant emissions (such as benzene, toluene, ethyl-benzene, and xylenes) by over 100 tons per year statewide from oil and gas operations. For more information on the Short-Lived Climate Pollutant Reduction Strategy, visit:
https://www.arb.ca.gov/cc/shortlived/shortlived.htm. For more information on the Oil and Gas Methane Regulation, visit: https://ww2.arb.ca.gov/resources/fact-sheets/oil-andgas-methane-regulation.

Freight Handbook – CARB is developing a handbook that identifies best practices for the siting, design, construction, and operation of freight facilities to minimize community exposure to air pollution. The handbook is intended to serve as a tool for local governments and community advocates to use in local land use planning and permitting decisions. The handbook will contain recommendations that local governments and freight facility developers, builders, and operators should integrate zero emission operations and technologies, and incorporate supporting infrastructure into project design. When implemented, the recommendations should lead to improved regulatory review processes, increased operational efficiencies, and reduced costs to business.

For more information on the handbook, visit: https://www.arb.ca.gov/gmp/sfti/sfti.htm.

Transport Refrigeration Unit Regulations – Transport refrigeration units congregate at distribution centers and other facilities, resulting in the potential for health risks to those that live and work nearby. CARB is working through a public process to consider new requirements to transition the transport refrigeration units fleet to zero emission operations by requiring both zero emission technology and supporting infrastructure.

For more information on this new regulation, visit: https://ww2.arb.ca.gov/ourwork/programs/transport-refrigeration-unit/new-transport-refrigeration-unit-regulation.

Drayage Truck Regulation Amendments – CARB’s Truck and Bus Regulation requires diesel trucks and buses that operate in California to be upgraded to reduce emissions. CARB’s Drayage Truck Regulation currently requires all drayage trucks to meet or exceed 2007 federal engine standards. Additionally, over the next several years, CARB will be working through a public process to consider amendments to the Drayage Truck Regulation that may transition the drayage fleet to zero emission operations. For more information on the regulation, visit:
https://arb.ca.gov/msprog/onroad/porttruck/porttruck.htm.

Advanced Clean Trucks Regulation – CARB is working through a public process to develop and consider proposals for new approaches and strategies that may transition to zero emission technology those truck fleets that operate in urban centers, have stop and go driving cycles, and are centrally maintained and fueled. District note: CARB South Central Fresno Community Emissions Reduction Program September 19, 2019 148 | P a g e
reports that by 2024, this measure is estimated to reduce 0.01 tons per year of PM2.5,

0.2 tons per year of NOx, and 0.001 tons per year of diesel PM. By 2029, this measure is estimated to reduce 0.1 tons per year of PM2.5, 4.2 tons per year of NOx, and 0.02 tons per year of diesel PM emissions in the community.

For more information on the proposed regulation, visit:
https://ww2.arb.ca.gov/our-work/programs/advanced-clean-truck.

Heavy-Duty Vehicle Inspection and Maintenance – When emissions control systems are not operating correctly, in-use emissions can increase. CARB’s current inspection programs include the roadside Heavy-Duty Vehicle Inspection Program and the fleet Periodic Smoke Inspection Program. These regulations require heavy-duty vehicles operating in California to be inspected for excessive smoke and tampering.

In July 2018, CARB approved amendments to the Heavy-Duty Vehicle Inspection Program and the Periodic Smoke Inspection Program to reduce the smoke opacity limits to levels more appropriate for today’s modern engine technology. CARB is now exploring the development of a more comprehensive heavy-duty inspection and maintenance program which would help ensure all vehicle emissions control systems are adequately maintained throughout the vehicles’ operating lives. District note: CARB reports that by 2024, this measure is estimated to reduce 0.9 tons per year of PM2.5 (diesel PM) and 59 tons per year of NOx. By 2029, this measure is estimated to reduce

1.0 ton per year of PM2.5 (diesel PM) and 72.6 tons per year of NOx emissions in the community.

For more information on existing heavy-duty maintenance programs, visit:
https://www.arb.ca.gov/enf/hdvip/hdvip.htm. For more information on the development of a comprehensive heavy-duty inspection and maintenance program, visit:
https://ww2.arb.ca.gov/our-work/programs/heavy-duty-inspection-and-maintenanceprogram.

Advanced Clean Cars 2 – CARB would consider expanded California-specific standards for new light-duty vehicles, impacting 2026 and later model year vehicles, to increase the number of new zero emission and plug-in hybrid electric vehicles sold in California and increase the stringency of fleet-wide emission standards for greenhouse gases and criteria pollutants. District note: CARB reports that by 2029, this measure is estimated to reduce 0.02 tons per year of PM2.5 and 1.08 tons per year of NOx emissions in the community.

For more information on the Advanced Clean Car Program, visit:
https://ww2.arb.ca.gov/our-work/programs/advanced-clean-cars-program.

Small Off-Road Engines – In 2020, CARB will consider new standards for small offroad engines (SORE), which are spark-ignition engines rated at or below 19 kilowatts and used primarily for lawn, garden, and other outdoor power equipment. District note:

CARB reports that by 2024, this measure is estimated to reduce 1.4 tons per year of South Central Fresno Community Emissions Reduction Program September 19, 2019 149 | P a g e
NOx. By 2029, this measure is estimated to reduce 3.2 tons per year of NOx emissions in the community.

For more information on Small Off-Road Engines, visit: https://ww2.arb.ca.gov/ourwork/programs/small-off-road-engines-sore.

Commercial Cooking Suggested Control Measure – This strategy consists of a twophase process to evaluate California’s current emission reduction requirements for commercial cooking operations that prepare food for human consumption, and if necessary, make improvements to achieve additional reductions in particulate matter 10 microns or less in diameter (PM10), particulate matter 2.5 microns or less in diameter (PM2.5) and volatile organic compound emissions that contribute to ozone formation.

For more information on this measure, see Appendix F, pages F-8 and F-9, of the Community Air Protection Blueprint.

Evaluation and Potential Development of Regulation to Reduce Idling for All Rail Yard Sources – This strategy will require operators to limit idling of all combustion powered vehicles and mobile equipment operating at rail yards and other locations, as well as reducing emissions from stationary locomotive operations (e.g., maintenance, testing). The scope will include both freight and passenger rail activities, in and around intermodal, classification, and maintenance rail yards, at seaports, at warehouses, on sidings, at passenger rail stations, and at maintenance and service locations.

Locomotives with zero emission capability could be exempt, if operators show that zero emission operation is maximized. For more information on this potential regulation, see Appendix F, page F-5, of the Community Air Protection Blueprint.

Evaluation and Potential Development of Regulation to Reduce Emissions for Locomotives not Preempted Under the Clean Air Act – This strategy will require the retrofit, repower, remanufacture, or replacement of freight and passenger locomotives not preempted under the Clean Air Act, beginning in 2025. Locomotives in operation beyond their useful life are typically operated by Class 3 freight railroads, industrial facilities, and passenger railroads, as well as a smaller number run by Class I railroads that can readily transfer those units to other states. Although the activity levels on these locomotives are lower than interstate line-haul and passenger locomotives, locomotives past their useful lives are the oldest and highest emitting (per unit of work performed) in the State. Prioritizing the earliest implementation in communities with high cumulative exposure burdens will be considered as part of this strategy.

As an alternative, CARB could also consider a voluntary agreement with the major railroads to secure greater community health benefits by reducing emissions from interstate locomotives (the dominant source of emissions and community health risk at rail yards), if that agreement was developed in a transparent public process and included clear enforcement provisions. For more information on this potential strategy, see Appendix F, pages F-5 and F-6, of the Community Air Protection Blueprint.

South Central Fresno Community Emissions Reduction Program September 19, 2019 150 | P a g e
Conduct Periodic Supplemental Environmental Projects Outreach – Supplemental Environmental Projects allows penalties collected from settlements to be used for projects that provide air quality benefits within communities throughout the State.

This strategy commits CARB to conducting outreach to impacted communities so CARB staff can identify where funds from Supplemental Environmental Projects can best be applied, and working to match Supplemental Environmental Projects with available settlements that have a common nexus. CARB staff will conduct periodic meetings throughout the State. CARB staff will utilize the ideas received from community members to determine what needs can be met through Supplemental Environmental Projects, and work to put those projects in place. For more information on these measures, see Appendix F, page F-24, of the Community Air Protection Blueprint.

Cargo Handling Equipment Amendment – This strategy will amend the existing Cargo Handling Equipment regulation. This regulation applies to mobile equipment such as yard trucks, rubber-tired gantry cranes, container handlers, and forklifts that operate at ports or intermodal rail yards. The strategy will propose an implementation schedule for new equipment and infrastructure requirements, with a focus on the transition to zero emission operation, and may include provisions for efficiency improvements. For more information on the Cargo Handling Equipment Amendment visit: https://ww2.arb.ca.gov/our-work/programs/cargo-handling-equipment.

Chrome Plating Control Measure Amendments – This strategy will amend the current regulation on chrome plating to further reduce toxic air contaminants at chrome plating facilities. In December 2006, CARB approved the proposed amendments to the Hexavalent Chromium Airborne Toxic Control Measure for Chrome Plating and Chromic Acid Anodizing Operations (Chrome Plating ATCM). The Chrome Plating ATCM requires the use of control technologies and operational practices that reduce hexavalent chromium emissions to their lowest levels. Facilities are subject to hexavalent chromium emission limits based on throughput and distance to sensitive receptors. Certain facilities are required to install add-on air pollution control devices and other facilities can meet the emissions limit through the use of chemical fume suppressants.

CARB staff will amend the existing chrome plating regulation to incorporate provisions to align with the federal chrome plating regulation and consider additional measures to further reduce emissions from chrome plating operations. The amendments will include the prohibition of perfluorooctane sulfonate containing fume suppressants (as required by federal regulation), changes to the surface tension requirements, and other actions to reduce uncontrolled emissions. CARB staff will also evaluate less toxic alternatives to hexavalent chromium and options to phase out perfluorinated chemicals used in fume suppressants. For more information on these measures, see Appendix F, pages F-6 and F-7, of the Community Air Protection Blueprint.

Composite Wood Products Control Measure Amendments – This strategy will amend the CARB Composite Wood Products Airborne Toxic Control Measure (ATCM), South Central Fresno Community Emissions Reduction Program September 19, 2019 151 | P a g e
approved in 2007. The Composite Wood Products ATCM established formaldehyde emission standards for three types of composite wood products (hardwood plywood, particleboard, and medium density fiberboard) and requires that all consumer goods that contain such materials (e.g., flooring, cabinets, furniture) destined for sale in California must comply with the Composite Wood Products ATCM.

CARB staff will amend the existing Airborne Toxic Control Measure to Reduce Formaldehyde Emissions from Composite Wood Products, to obtain additional formaldehyde emission reductions, clarify requirements and applicability, improve enforceability, and align with the U.S. Environmental Protection Agency formaldehyde regulation, where appropriate. (Note: CARB cannot enforce the U.S. Environmental Protection Agency formaldehyde in composite wood regulation, because it was adopted under the Toxic Substances Control Act). For more information on the Composite Wood Products ATCM visit: https://ww2.arb.ca.gov/our-work/programs/compositewood-products-program.

Catalytic Converter Theft Reduction – This strategy consists of a regulation and/or compliance assistance to deter thefts of vehicle catalytic convertors in communities selected for the Community Air Protection Program.

This strategy will include a regulation and/or compliance assistance to reduce theft of vehicle catalytic converters in communities selected through the community identification and selection process. A regulation will require manufacturers to stamp catalytic converters with a vehicle identification number. Compliance assistance would offer free vehicle identification number stamping on converters in communities selected through the community assessment process. This strategy will make it easier for the recycler to identify stolen catalytic converters. For more information on this strategy, see Appendix F, pages F-7 and F-8, of the Community Air Protection Blueprint.

Heavy Duty On-Road and Off-Road Engine In-Use Testing – This strategy will involve real world screening of heavy-duty trucks and off-road engines operating in selected communities to target heavy-duty in-use compliance testing. Engines that are found to be emitting above expected levels will be brought into CARB’s in-use compliance program. Engines found to be in noncompliance will be recalled and emission mitigation projects could include, deployment of zero emission technology in selected environmental justice communities. For more information on this strategy, see Appendix F, page F-8, of the Community Air Protection Blueprint.

South Central Fresno Community Emissions Reduction Program September 19, 2019 155 | P a g e

5. ENFORCEMENT PLAN

5.1 INTRODUCTION
Enforcement of air quality rules and regulations by the San Joaquin Valley Air Pollution Control District (District) and the California Air Resources Board (CARB) is critical to continuing air quality progress and achieving the air quality goals contained in the Valley’s State Implementation Plans. Compliance with federal, state, and local air quality rules and regulations is ensured by operating robust inspection programs along with a full range of educational and compliance assistance programs.

This Enforcement Plan describes the stationary and mobile source enforcement history for the South Central Fresno community. In addition, the plan describes the overall enforcement programs operated by the District and CARB. Based on the analysis of the enforcement history and input from the Community Steering Committee, the Community Emissions Reduction Plan (CERP) includes focused enforcement measures to enhance enforcement and compliance assistance activities within the community in support of the emission reduction commitments in the CERP.

5.2 OVERVIEW OF SAN JOAQUIN VALLEY AIR POLLUTION CONTROL

DISTRICT ENFORCEMENT PROGRAM
The District’s mission is to improve the health and quality of life for all Valley residents through efficient, effective, and entrepreneurial air quality management strategies. The District’s Enforcement Department seeks to aid in achieving this mission through fair, consistent, and comprehensive enforcement utilizing a full suite of enforcement and compliance assistance related activities to ensure compliance with District, state and federal rules and regulations. The program objectives for the Enforcement Department are set forth in federal and state law and the District’s air quality attainment plans. In order to meet these program objectives, District staff perform inspections at approximately 9,200 permitted facilities and at approximately 5,600 agricultural operations, responds to approximately 3,000 public complaints, and verifies emissions reductions at thousands of locations where emission reduction incentive projects have been implemented.

The major functions of the District’s Enforcement Department are as follows:

Inspections of Stationary Sources
The District performs thousands of comprehensive on-site inspections each year to ensure compliance with District requirements. These compliance evaluations are unannounced whenever possible and play a key part to meeting clean air requirements.

The frequency of regular inspections depends on the type of facility. When considering limited resources, priority is given to federal Title V (Major) sources, facilities that emit non-attainment criteria or toxic pollutants, facilities with equipment that is more susceptible to upsets, compliance history of operation, etc. Under this scenario, a chrome plating facility will be inspected more frequently than a back-up, emergency generator which only operates a few hours per year.

South Central Fresno Community Emissions Reduction Program September 19, 2019 156 | P a g e
Compliance inspections are conducted by well-trained District air quality inspectors.

Inspections include a physical inspection of the facility and equipment, a review of operating and monitoring records, and the use of advanced detection equipment, where appropriate, to determine compliance with permitted emission limits. During the inspection, District staff ensures that the equipment is permitted appropriately, and that the facility is operating in compliance with all permit requirements and applicable local, state, and federal regulations. If the facility is determined to be in non-compliance, the inspector issues the facility an enforcement action that requires prompt correction of the issue and generally results in the imposition of a civil penalty.

Complaint Investigations
The District receives thousands of complaints each year for which timely responses and investigations of alleged sources of non-compliance are top priorities. Inspectors are on-call 24 hours per day and use automated voicemail and computer systems to facilitate the timely response to complaints in order to abate potential public nuisances.

Along these same lines, the District added the ability to easily submit complaints, including video and photographs, online and through mobile smartphone applications.

District staff are required to keep the reporting party apprised of the investigation findings until it has been completed. The District provides a bilingual (Spanish-English) telephone complaint line and also has the capability to utilize multilingual translation services, in the field or over the telephone, to ensure that all communities and groups within the Valley are properly served.

Emissions Testing
District inspectors oversee hundreds of third-party emissions tests conducted at stationary sources each year for the purpose of measuring air pollutants and ensuring compliance with established standards. District staff have three main tasks when overseeing source tests at stationary source sites. First they review the source test protocol, submitted by the third party source testing contractor. District staff reviews the protocol to ensure the proper testing will be conducted and that the source test contractor has the proper equipment and certifications to conduct the test. The second task is to witness the test to ensure the source test contractor follows the correct test procedures. Lastly, District staff reviews the source test results to ensure the data is properly reported and to act promptly on any compliance issues related to the testing.

In addition, the District utilizes its monitoring van and portable exhaust gas analyzers to assess the emissions from internal combustion engines, boilers, and other combustion devices to ensure they are operating according to specifications and complying with all permitted and/or rule emission limits.

Gasoline Station Permitting, Inspecting and Testing Program Gasoline stations, in aggregate, are one of the largest potential sources of volatile organic compounds in the Valley. A comprehensive and effective permitting, inspection and testing program is important to ensure the vapor recovery systems operate as designed and the Valley realizes the emission reductions anticipated in Rule 4621 South Central Fresno Community Emissions Reduction Program September 19, 2019 157 | P a g e
(Gasoline Transfer Into Stationary Storage Containers, Delivery Vessels and Bulk Plants) and Rule 4622 (Gasoline Transfer into Motor Vehicle Fuel Tanks).

District staff continues to inspect gasoline station vapor recovery systems on a routine basis looking for torn hoses, damaged nozzles, and missing parts. However, during recent years there have been many changes in vapor recovery technology and state laws such that the simple visual inspections are no longer sufficient. More emphasis is now being placed on performance tests that evaluate gasoline station equipment effectiveness. As a result, the District implemented a gasoline dispensing tester certification and training program to ensure qualified third party contractors are available for operators of this equipment.

Agricultural and Prescribed Burning
Agricultural burning in the San Joaquin Valley is closely regulated by the District.

Legislation is phasing out such activity, but it is still allowed for a few crop types where there are no economically or technologically feasible alternatives to burning available. In accordance with state law, on a daily basis District staff determines when, how much, and where burning can occur.

District staff utilizes a sophisticated Smoke Management System (SMS) to determine the burn status. Air quality and meteorological conditions determine if burning is allowed. The SMS divides the Valley into over 100 zones. Each zone is analyzed and given a burn status and permissible burn acreage allocation. The goal of the SMS is to protect the public and prevent violations of air quality standards.

In order for a farmer to burn, they must first receive a District permit and must receive approval to burn each day they wish to do so. Field staff monitors burning to ensure only authorized materials are burned and that best management practices are followed to minimize smoke impacts to the public.

Prescribed burning by land management agencies is another activity regulated by the District. In accordance with state requirements, the District reviews burn plans, provides burn authorizations, and monitors the fires. District staff also has an ongoing dialogue with Land Management Agencies (LMAs) and other air districts to improve communication and cooperation among all parties when planning fires and while the fires are burning.

State leaders and agencies are recognizing the need for decisive actions to restore California’s forested lands to resiliency. As a result, there was a need to develop potential changes to the District’s policies and procedures to facilitate a more effective use of prescribed burning. Based on this direction, and in collaboration with local LMAs, over the last several years the District has employed more flexible policies to facilitate the use of prescribed burning as a tool to reduce fuel more rapidly. Examples of these efforts include identifying ways to facilitate the more effective use of prescribed burning and other practices as means to reduce the number and severity of future wildfires, supporting federal and state legislation to increase funding for land and forest management, developing a targeted public education campaign regarding wildfires, and South Central Fresno Community Emissions Reduction Program September 19, 2019 158 | P a g e
working with state and federal land managers to formulate new strategies to reduce fuelbuildup and address wildfire emissions.

Wood Burning Heaters and Fireplaces
Further reducing residential wood smoke emissions is a high priority under the District’s 2018 PM2.5 Plan given the significant localized health impacts associated with residential wood smoke. Scientific studies show that prolonged inhalation of wood smoke contributes to lung disease, pulmonary arterial hypertension, and pulmonary heart disease, which can eventually lead to heart failure. District Rule 4901 is designed to improve public health by reducing toxic wood smoke emissions in Valley neighborhoods during the peak PM2.5 winter season (November through February).

Since 2004, the District has had a robust enforcement program for designated wood burning curtailment days to ensure the District is achieving the expected emission reductions as a result of the requirements of the rule. This includes having a significant portion of field staff mandatorily assigned to conduct proactive surveillance in counties with declared wood burning curtailments. The District also conducts surveillance in counties with curtailments on days that District offices are closed and performs periodic night-time surveillance throughout the Check Before You Burn season.

In the District’s ongoing efforts to utilize the latest forms of technology to improve efficiency and effectiveness, the District tested several technologies for nighttime fireplace and wood burning heater enforcement. The District purchased ultra-low light cameras, which has the greatest capacity to capture non-compliance through photographic and video evidence. The use of the cameras are able to clearly document smoke coming from chimneys in extremely low-light conditions in a way that previous technologies used and tested were unable to match.

Compliance Assistance
The District believes in working closely with businesses and residents to assist in achieving compliance with air pollution rules and regulations. The Compliance Assistance program has emphasized an educational approach to help Valley residents and businesses comply with a variety of air pollution regulations. Businesses and individuals throughout the Valley are provided with:
 Individualized Assistance: Personal, one-on-one help is provided to thousands of businesses and individuals to ensure they understand the District’s requirements.
 Compliance Assistance Bulletins: Actively evaluate upcoming rule compliance dates and develop educational materials that are sent to affected groups including, but not limited to, realtors, building departments, contractors, industrial and commercial facilities, farmers, and residents.

South Central Fresno Community Emissions Reduction Program September 19, 2019 159 | P a g e
 Compliance Schools: Training classes provide information on the topics of open burning, gasoline vapor recovery and wood burning fireplaces and wood burning heaters.
 Gasoline Station Tester Training: Ongoing training for contractors is provided for those wishing to perform vapor recovery tests within the District. District rules require testers be certified to ensure there is a qualified pool of contractors from which stakeholders can choose to perform their equipment’s testing.  Asbestos Training: Comprehensive assistance on asbestos regulations is provided to the public, building industry, building departments, fire departments, and realtors. Staff continues to spend considerable time providing one-on-one assistance, in addition to group trainings, to the regulated community. The District has also developed online tools and resources to educate the public on asbestos notification requirements in the Valley.
 Residential Wood Burning Heater Professional Training: Training requirements for qualified individuals (those people having either a certification from the Fireplace Investigation Research and Education, Chimney Safety Institute of America, or the National Fireplace Institute or has documentation demonstrating they are qualified to perform inspections, maintenance and cleaning activities on wood burning heaters) who may be hired to perform inspections of wood burning heaters and pellet stoves to ensure they can be operated in a compliant manner prior for individuals who voluntarily request to register their wood burning heaters and pellet stoves.
 Regulation VIII (Fugitive Dust) Education: Staff organizes and conducts classroom training for all groups required to submit dust control plans for construction activities and provides ongoing training and outreach as needed and as requested.
 Prescribed Burning Outreach: The District meets periodically with the land managers of the USDA Forest Service, National Park Service, US Fish and Wildlife Service, Bureau of Land Management, California Department of Forestry and Fire Protection, and Southern California Edison Company in order to minimize impacts of smoke from prescribed burns and wildfires. Compliance staff participate on the daily calls during fire season to keep abreast of wildfire and prescribed burn activities throughout the area.
 Access to District Policies: District policies are available on the internet for stakeholders to review, comment on, and use to assist them with complying with District requirements. The internet is updated regularly with new or modified policies to ensure availability of current information.

South Central Fresno Community Emissions Reduction Program September 19, 2019 160 | P a g e
Emission Reduction Incentive Program Inspections
To ensure that the emission reduction projects funded by the District’s incentive programs are real and permanent, the District monitors the pre-contract and postcontract performance of grant recipients. Thousands of field inspections are conducted to verify that equipment is appropriately controlled or replaced and that it is adequately maintained and verification that older equipment has been properly disposed of.

Incentive projects requiring compliance inspections include the replacement of older trucks with new less polluting ones, school bus replacements, agricultural pump engine replacements, emissions controls on trucks, and other related control strategies. Each funded project requires a minimum of two initial inspections and several types of projects require ongoing inspections to assure emission reductions are realized for the life of the project.

5.3 SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

ENFORCEMENT HISTORY IN SOUTH CENTRAL FRESNO

COMMUNITY
The District’s enforcement presence within the South Central Fresno community is comprised of many different facets including, but not limited to, performing facility inspections, investigating complaints from the public, investigating breakdowns, and overseeing third-party emissions testing at facilities. Since 2016, the District has conducted inspections of 2,409 equipment units during 1,121 inspections at permitted facilities within the South Central Fresno Community, has received and responded to 239 air quality complaints from the public, and has issued 312 enforcement actions associated with violations of air pollution rules and regulations. A listing of the facilities, inspections, complaints, and enforcement actions can be found in Appendix F.

5.3.1 RESPONSE TO PUBLIC AIR POLLUTION COMPLAINTS
The public plays an important role in protecting public health by reporting local air quality issues that they observe in their communities. Often these complaints serve as the first warning of an air pollution compliance issue that needs to be addressed. The District places the highest priority of responding to complaints from the public and responds to each and every complaint received. In addition, the District operates an “on-call” program to ensure that complaints received outside of normal business hours can be appropriately addressed since air pollution related issues are not bound by normal business hours. The process of responding to a complaint can be unique for each complaint received depending on factors such as whether the issue is currently in progress, whether the issue is a recurring/ongoing issue, the type of source, the time of day, and the number of complaints received about the issue. Figure 5-1 shows the number of complaints received by the District each year since 2016.

South Central Fresno Community Emissions Reduction Program September 19, 2019 161 | P a g e
Figure 5-1: Number of Complaints by Year from 2016-2019 * 2019 data is through April 30, 2019
Based on the resulting complaint investigations, the District confirmed a violation of District rules or regulations and took enforcement action in 47 of the complaints, determined that the issue did not constitute a violation of any federal, state, or local air quality rule in 102 of the complaints, referred 8 complaints to the proper agency with jurisdiction over the issue, and was unable to confirm whether or not a violation occurred in the 82 remaining complaints (at times, the issues associated with public complaints can be transient in nature and the information provided by the reporting party may lack sufficient information to track down and confirm the issue). Of the 47 enforcement actions taken as the result of public complaints, 28 were for illegal residential open burning of waste, 5 were for illegal use of a residential fireplace or outdoor wood burning device, 4 were for fugitive dust related issues, 4 were for permitting/registration related issues, 2 were for excess visible emissions, 2 were for escaped agricultural open burns, 1 was for work practices issues at an automobile coating operation, and 1 was for an illegal commercial/industrial open burn.

Figure 5-2 below details the complaints received by type since 2016. Complaints concerning residential open burning made up 43% of the total complaints received in the community. Complaints regarding residential fireplaces/outdoor wood burning devices and fugitive dust each made of 14% of the complaints received in the community. In total, these three categories made up over 70% of the complaints received.
63 68
80 28
0 10
20 30
40 50
60 70
80 90
2016 2017 2018 2019
Number of Complaints by Year (2016-2019*)
South Central Fresno Community Emissions Reduction Program September 19, 2019 162 | P a g e
Figure 5-2: Number of Complaints by Type from 2016-2019 * 2019 data is through April 30, 2019
The District received and responded to 136 complaints regarding residential open burning and residential fireplace/outdoor wood burning devices during this period. The District confirmed illegal open burning and took enforcement action in 33 of these cases, determined that 35 were not a violation (permissible fireplace burn day or small outdoor cooking fire), and was unable to confirm 68 of the complaints. In addition to the complaints received in these categories, members of the Community Steering Committee have suggested increased outreach/education and enforcement in these categories. The District has included specific enhanced enforcement and outreach/education measures as part of the CERP to reduce the potential for localized air quality impacts associated with failure to comply with District rules pertaining to residential open burning and residential fireplace/outdoor wood burning devices.

Of the 34 fugitive dust complaints received, the District issued an enforcement action in 4 of the cases for various fugitive dust related issues. In 24 of the instances, the District determined that the operation was complying with the District’s Regulation VIII fugitive dust rules and public nuisance rules. In 5 of the instances, the District was unable to confirm the complaint, and the remaining complaint was referred to City of Fresno Code Enforcement. The complaints that led to enforcement actions or were unable to be confirmed were primarily associated with construction/ earthmoving activities or open areas. The District has included specific enhanced enforcement measures as part of the CERP to reduce the potential for localized air quality impacts associated with 2 4
5 5
5 6
6 10
11 15
34 34
102
0 20 40 60 80 100 120
Idling Diesel Trucks
Gasoline Dispensing Facility
Other Open Burn
Permitting / Registration
Commercial / Industrial Open Burning
Agricultural Open Burning
Asbestos
Visible Emissions from Equipment
Other
Odor Nuisance
Fugitive Dust
Residential Fireplace / Outdoor Wood Burning Device
Residential Open Burning
Number of Complaints by Type (2016-2019*)
South Central Fresno Community Emissions Reduction Program September 19, 2019 163 | P a g e
fugitive dust from construction/earthmoving activities and open areas subject to District Regulation VIII. Since 80 percent of the complaints have been received between April and September, these enhanced enforcement efforts will be conducted during the 2nd and 3rd calendar quarters.

The District received 15 odor complaints during this period and determined that none of the complaints resulted in a violation failing under the District’s jurisdiction. Under state law, odors are regulated under public nuisance requirements. To become a violation, an odor must cause “injury, detriment, nuisance, or annoyance” to a considerable number of people or the public. Each of the odor complaints were separate instances from a single party; and therefore, did not rise to the level of a public nuisance under state law. Three of the complaints fell outside of the District’s jurisdiction and were referred to the appropriate agency.

The District received 10 complaints regarding visible emissions from equipment at facilities within the community. The District confirmed and took enforcement action in 1 of the cases. Additionally, the District took enforcement action for an unpermitted piece of equipment as the result of another one of the complaints. The District determined no violation of District rules occurred in 3 of the cases and was unable to confirm whether or not a violation occurred in the remain 5 complaints in this category. Nine of the 10 complaints in this category involved allegations against sources under permit with the District. As discussed below under the District Enforcement Action section, the District has included specific enhanced enforcement measures as part of the CERP to address failure to comply with emission standards at permitted facilities.

The District received 6 complaints regarding agricultural open burning. In 5 of the instances, the District confirmed that the burn in question was conducted under a District authorization for the day in question. However, in 2 of the 5 cases, the burn had escaped containment resulting in the District taking enforcement action for burning impermissible materials as the result of an escaped agricultural burn. The 6th complaint specified was a location that was too vague to conduct an investigation and the reporting party was anonymous and provided no contact information to aid the investigation.

The District received 6 complaints regarding federal asbestos requirements associated with regulated demolitions and renovations. In all of these instances, the District confirmed that the projects were either complying with federal asbestos requirements or were exempt under federal law.

The District received 10 complaints associated with commercial/industrial open burning or other open burning. One of these complaints resulted in enforcement actions for illegal open burning, 4 were exempt from open burning rules (2 cooking fires and 2 religious ceremonial fires), 3 were a spontaneous combustion fires, and in the 2 remaining the District was either unable to locate the burn or the responsible party for the burn. The enhanced enforcement and outreach/education CERP measures for

South Central Fresno Community Emissions Reduction Program September 19, 2019 165 | P a g e
without a permit. The District issued 44 enforcement actions for violations resulting in excess emissions from facilities (not including gas stations). These violations occurred at 24 permitted facilities in the area. The District also issued 18 enforcement actions to gas stations for violations resulting in excess emissions. These violations occurred at 10 gas stations in the area. The District believes that more frequent inspections for these 34 facilities would be prudent to limit the potential for air quality impacts associated with failure to comply with emission standards established by District permit, rule, or regulation. The District has included a specific enhanced enforcement measures as part of the CERP to increase the frequency of inspection to at least twice per calendar year for the next five years or until the facility has 4 consecutive inspections without an emission violation, whichever occurs first.

In addition, the District believes a new pilot training program for conducting selfinspections of equipment at gas stations may help to limit the potential for air quality impacts associated with vapor recovery defects at gasoline dispensing operations.

Accordingly, the District has included a compliance assistance CERP measure to develop a new training program to instruct gas station operators on conducting thorough self-inspections to aid in the identifications and timely repair of system defects. The District will provide the hands on training to each gas station operator in the community.

Figure 5-4: Enforcement Actions by Type from 2016-2019
* 2019 data is through April 30, 201
A review of the data also shows that the District has issued 29 violations for residential open burning, 13 enforcement actions for fireplace/outdoor wood burning heater violations, and 7 enforcement actions for fugitive dust related issued violations. This 1 2
4 7
12 13
18 29
35 35
44 112
0 20 40 60 80 100 120
Commerical Open Burn
Ag Open Burn
Asbestos
Fugitive Dust
Gas Station Certification
Fireplace
Gas Station Equipment Defect
Residential Open Burn
Late Source Testing/Monitoring at Facility
Gas Station Late Testing/Monitoring
Excess Emissions from Facility
Administrative/Recordkeeping/Reporting
Enforcement Actions by Type (2016-2019*)
South Central Fresno Community Emissions Reduction Program September 19, 2019 166 | P a g e
further demonstrates the need to include the aforementioned enhanced enforcement and outreach/education CERP measures.

It should be noted that during this period there were 12 enforcement actions taken against gas stations in the community for failing to comply with various statewide compliance deadlines to upgrade their vapor recovery equipment to meet new certification standards. These deadlines have since passed and the District does not foresee ongoing issues in this category.

5.4 CALIFORNIA AIR RESOURCES BOARD PROGRAM OVERVIEW AND

ENFORCEMENT HISTORY IN SOUTH CENTRAL FRESNO

COMMUNITY
Section 5.4 Provided by the California Air Resources Board The California Air Resources Board (CARB or the Board) enforcement programs cover the vehicles we drive, the diesel engines that power our economy, consumer products that we purchase, and greenhouse gas (GHG) emissions from our industries and activities. The goal of CARB enforcement programs is to achieve comprehensive compliance in every regulation the Board adopts. Through enforcement, we work to bring responsible parties into compliance and in doing so achieve a level playing field across industry so that no company can benefit from non-compliance at the expense of another; and to deter industry from future violations. We take compliance seriously because the success of our programs, and public health protection, depends on it.

CARB applies enforcement programs professionally in accordance with our enforcement policy, which we updated in 2017. We use data and inspections to identify potential non-compliance, and then investigate each case. Once a violation is identified, we notify the responsible party and evaluate what happened. We work with the party to achieve compliance and measure the relevant facts and circumstances of each case, relative to eight factors set in law and described in our enforcement policy, to determine an appropriate penalty. The case is settled when the responsible party has achieved compliance and paid an appropriate penalty. If the case cannot be settled, we work with CARB legal staff to refer the case to California’s Attorney General for litigation.

Field inspectors are a critical component of the diesel enforcement program. The inspectors work across the state to inspect trucks and other equipment for compliance with CARB’s diesel regulations, such as the Heavy-Duty Diesel Vehicle Inspection Program, Drayage Truck, Statewide Truck and Bus, Smart Way, and Transport Refrigeration Unit. Field inspectors also conduct inspections for compliance with In-Use Off-Road and School Bus Idling regulations. CARB inspectors examine heavy-duty vehicles and equipment at numerous locations throughout California, such as at South Central Fresno Community Emissions Reduction Program September 19, 2019 167 | P a g e
California Highway Patrol scale facilities, warehouses, fleet yards, construction sites, random roadside locations, truck stops, rest areas, ports, and rail yards.

In addition, CARB has a Supplemental Environmental Project (SEP) Policy that allows community-based projects to be funded from a portion, up to 50 percent, of the penalties received during settlement of enforcement actions. SEPs can improve public health, reduce pollution, increase environmental compliance, and bring public awareness to neighborhoods most burdened by environmental harm.

5.4.1 CALIFORNIA AIR RESOURCES BOARD THREE YEAR ENFORCEMENT

HISTORY
Heavy-Duty Vehicle Inspection Program (HDVIP): The HDVIP requires heavy-duty trucks and buses to be inspected for excessive smoke and tampering, and engine certification label compliance. Any heavy-duty vehicle traveling in California, including vehicles registered in other states and foreign countries, may be tested. Tests are performed by CARB inspection teams at border crossings, CHP weigh stations, fleet facilities, and randomly selected roadside locations. Owners of trucks and buses found in violation are subject to minimum penalties starting at $300 per violation.

Idling: Idling and opacity inspections are performed to ensure a heavy-duty vehicle (HDV) is compliant with emission standards and is not violating CARB’s Idling regulation. Idling for more than five minutes is prohibited unless the HDV is certified clean idle and the vehicle is more than 100 feet away from a school or restricted area (exceptions apply). Vehicle owners and drivers in violation are subject to minimum penalties starting at $300 per violation and up to $1000 per day.

Off-Road Construction Equipment (off-road regulation): Construction equipment is a major contributor to air pollution, especially when large construction projects are adjacent to neighborhoods. To address this source of air pollution, CARB adopted the nation's first regulation aimed at cleaning up ‘off-road’ construction equipment such as bulldozers, graders, and backhoes. The off-road regulation requires off-road fleets to meet fleet average emission standards and be equipped with Best Available Control Technology (BACT) (a few specific exceptions apply).

SmartWay: The Tractor-Trailer Greenhouse Gas Regulation requires 53-foot or longer dry van or refrigerated van trailers and the tractors that pull them on California highways to use certain equipment that the U.S. Environmental Protection Agency SmartWay program has verified or designated to meet their efficiency standards.

Transport Refrigeration Unit (TRU): Transport Refrigeration Units (TRUs) are refrigeration systems powered by diesel internal combustion engines designed to refrigerate or heat perishable products that are transported in various containers, including semi-trailers, truck vans, shipping containers, and rail cars. Since diesel particulate matter has been identified as a toxic air contaminant, CARB adopted an Airborne Toxic Control Measure (ATCM) for TRUs and TRU generator sets. CARB staff South Central Fresno Community Emissions Reduction Program September 19, 2019 168 | P a g e
inspect TRUs to ensure that the units are meeting labeling and in-use performance standards identified in the TRU regulation.

Drayage: The Drayage Truck Regulation is part of CARB’s ongoing efforts to reduce particulate matter (PM) and oxides of nitrogen (NOx) emissions from diesel-fueled engines and improve air quality associated with goods movement. Heavy-Duty Vehicles that carry goods to or from a port or intermodal facility are required to be equipped with a 2007 or newer model year engine. This requirement becomes stricter in 2023, when Drayage trucks are required to be equipped with a 2010 or newer model year engine, because Drayage trucks will be required to the meet the standards of the Truck and bus regulation.

State-wide Truck and Bus (STB): The State-wide Truck and Bus regulations requires diesel trucks with a Gross Vehicle Weight Rating (GVWR) greater than 14,000 pounds that operate in California to install diesel particulate filters or replace older engines with cleaner engine technology on a schedule based on the model year of the engine and GVWR.

Over the last three years, the California Air Resources Board (CARB) has conducted 1,00825 inspections on Heavy-Duty Vehicles (HDV) within the selected AB 617 South Central Fresno community. These inspections occurred across ten of twelve CARB HDV enforcement programs. The following represents a year-by-year breakdown of enforcement action for CARB HDV programs in the community between 2016 and 2018:

25 Number is preliminary and may change as data is reviewed.

South Central Fresno Community Emissions Reduction Program September 19, 2019 169 | P a g e
Figure 5-5: Enforcement History of Heavy-Duty Diesel Vehicles: South Central Fresno
*Inspections per year are program based and some occur concurrently Preliminary analysis of Heavy-Duty Vehicle program inspections suggests that overall compliance within the South Central Fresno community is high. As seen in Figure 5-6, from 2016-2018, 92.5 percent of Heavy-Duty Vehicle program inspections showed compliance. However, not all Heavy-Duty Vehicle programs have more than a 90 percent compliance rate when averaged over a three-year period. Transport Refrigeration Unit Inspection data show lower compliance. Averaged over three years, Transport Refrigeration Units had about 60 percent compliance.

During this period, 76 citations were issued to Heavy-Duty Vehicles within the community boundary. Further breakdown of the citations data indicates that 49 citations were issued for emission violations and 27 citations were issued for non-emission violations. The difference between emission and non-emission citations is that emission violations further contribute to air pollution while non-emissions violations do not. An example of a non-emission violation would be a truck not complying with labeling requirements. CARB is working to compile information on the resolution of violations issued in South Central Fresno and will provide this data to the community steering committee (CSC) as it becomes available.

Program Inspections
Compliant
Units
Emission
NonEmission
Inspections
Compliant
Units
Emission
NonEmission
Inspections
Compliant
Units
Emission
NonEmission
Diesel
Exhaust Fluid 0 0 0 0 0 0 0 0 0 0 0 0
Emission
Control Label 117 106 0 11 118 112 0 6 27 25 0 2
Smoke
Opacity
115 115 0 0 124 124 0 0 28 28 0 0
Tampering 0 0 0 0 72 68 4 0 28 27 1 0
Idling 14 13 1 0 1 1 0 0 1 1 0 0
Off-Road 1 1 0 0 0 0 0 0 1 0 0 1
Public
Agency and
Utility
1 1 0 0 0 0 0 0 0 0 0 0
Smart Way 3 3 0 0 25 22 3 0 6 4 2 0
Solid Waste
Collection 2 2 0 0 0 0 0 0 2 2 0 0
Transport
Refrigeration
Unit
14 9 4 1 23 14 5 4 6 3 1 2
Drayage 0 0 0 0 0 0 0 0 0 0 0 0
Truck and Bus 129 110 19 0 125 118 7 0 25 23 2 0
Total 396 360 24 12 488 459 19 10 124 113 6 5
Violations Heavy Duty Vehicle Inspection Program2016 Violations 2017 Violations 2018

South Central Fresno Community Emissions Reduction Program September 19, 2019 172 | P a g e
Figure 5-8: Motor Vehicle Fuels Inspections 2016 - 2018

5.4.3 CONSUMER PRODUCTS PROGRAM DESCRIPTIONS
Consumer Products are chemically formulated products used by household and institutional consumers. Some examples are: detergents, cleaning compounds; polishes, floor finishes; cosmetics and personal care products; home, lawn, and garden products; disinfectants and sanitizers; aerosol paints and automotive specialty products.

Consumer Products do NOT include: other paint products, furniture coatings, or architectural coatings. Investigators in the Consumer Products program purchase samples of regulated consumer products from outlets all over California. They inspect product containers for compliance with registration and dating requirements and send selected products to the laboratory for testing.

Composite Wood Products - CARB's Airborne Toxic Control Measure (ATCM) to control formaldehyde emissions from composite wood specifically focuses on three products: hardwood plywood, particleboard, and medium density fiberboard.

Investigators in the Composite Wood Products program purchase samples of regulated products from outlets all over California. They inspect products and packaging for compliance with labeling requirements and send selected products to the laboratory for testing.

Consumer product inspections are an important regulatory tool to improve public health in the community. Consumer products, such as hairsprays, deodorants and flooring, are widely used, but can be sources of toxic air containments (TACs) and volatile organic compounds (VOC) that community members willingly bring into their homes.

In 2018, the California Air Resources Board has conducted approximately 56 inspections within the selected AB617 South Central Fresno community. The following represents a breakdown of enforcement action in the community in 2018:

Figure 5-9: Consumer Products Investigations - 2018
Program Inspections Violations Inspections Violations Inspections Violations Gas 16 0 12 0 9 0
Diesel 4 0 5 0 4 0
Racing 0 0 0 0 0 0
Totals 20 0 17 0 13 0
2016 2017 2018 Program Investigations Compliant units pending results violations Aerosol Coatings 2 2 0 0
Antiperspirant/
deodorant 1 0 1 0
Composite Wood 0 0 0 0
Consumer Products 53 0 53 0

South Central Fresno Community Emissions Reduction Program September 19, 2019 174 | P a g e
An effective complaint should contain as much information and as many details as possible as this helps the inspector in responding to the issue and conducting the investigation. The following information is helpful when filing a complaint:
 Time, date, and location of possible violation; including name of facility if known.  Type of air quality concern. Describe what you see, smell, and feel. o See: smoke, fire, dust falling ash, etc.
o Smell: rotten eggs, gasoline, oil, sweet, sour, smoke, etc. o Feel: burning eyes, throat/nose irritation, breathing problem, headache, etc.
 Is the issue still occurring? If not, when did it occur? Is it recurring? If so when? o Time of day
o Day of week
 Your name and contact information – anonymous complaints can be filed but contact information often helpful in fine tuning the investigation.

To better leverage community involvement, the District and CARB will also assign a dedicated team to work with the Community Steering Committee to follow-up on community concerns, and to conduct community-level compliance assistance, outreach, and education related to compliance and enforcement of local and state rules and regulations. As part of this partnership, the District and CARB will track and report back to the Community Steering Committee on the ongoing enforcement activities within the community to monitor progress in meeting community enforcement measures and to look for innovative strategies to enforcement practices with the goal of increased compliance with air pollution rules and regulations within the community.

5.6 ENFORCEMENT STRATEGIES

5.6.1 DISTRICT ENFORCEMENT STRATEGIES
The District has used the assessment of the three (3) year compliance history in the South Central Fresno community and comments shared by the Community Steering Committee to develop the list of enforcement strategies below which aim to reduce the potential for localized air quality impacts within the South Central Fresno community.

1. Enhanced enforcement of District Rule 4901 (Wood Burning Fireplace and Wood Burning Heaters) mandatory wood burning curtailments:

To limit the potential for localized PM2.5 impacts associated with the failure to comply with mandatory episodic wood burning curtailments, District staff will conduct at least four (4) hours of surveillance within the South Central Fresno community on each declared curtailment day for the next five (5) winter seasons to enhance the enforcement of District Rule 4901. The District will work with the Community Steering Committee to focus surveillance efforts in areas where wood burning is more prevalent.

South Central Fresno Community Emissions Reduction Program September 19, 2019 175 | P a g e

2. Enhanced enforcement of District Rule 4103 (Open Burning) to reduce the illegal open burning of residential waste:

To limit the potential for localized PM2.5 and toxic impacts associated with the illegal open burning of residential waste, District will conduct targeted surveillance efforts within the South Central Fresno community. Building on the District’s existing surveillance and complaint response efforts, the District will conduct additional targeted surveillance efforts in South Central Fresno community at least once per quarter for the next 5 years. The District will work with the Community Steering Committee to focus surveillance efforts in areas where illegal residential open burning has historically occurred.

3. Enhanced inspection frequency of permitted sources:

To limit the potential for localized air quality impacts associated with the failure to comply with emissions standards established by District permit, rule, or regulation, the District will increase the frequency of inspection at each facility that has had an emission violation over the past three (3) years. These facilities will be inspected at least twice per calendar year for the next five (5) years or until the facility has 4 consecutive inspections without an emission violation, whichever occurs first.

4. Enhanced enforcement of fugitive dust requirements
To limit the potential for localized air quality impacts associated with fugitive dust from construction/earthmoving activities and open areas subject to District Regulation VIII, the District will conduct targeted surveillance efforts within the South Central Fresno community. Building on the District’s existing surveillance and complaint response efforts, the District will conduct at least one targeted enforcement effort within the South Central Fresno community during both the 2nd and 3rd quarter for the next five (5) years.

5. Pilot training program for conducting self-inspections at gas stations:

To limit the potential for air quality impacts associated with vapor recovery defects at gasoline dispensing stations, the District will develop a pilot training program to instruct gas station operators on conducting thorough self-inspections of the vapor recovery systems at their stations to aid in the identification and timely repair of vapor recovery system defects. The District will provide this hands-on training to each gas station operator in the community.

6. Enhanced enforcement of the state’s heavy-duty vehicle anti-idling regulation:

To limit the potential for localized PM2.5 and toxic air quality impacts associated with failure to comply with the state’s heavy-duty vehicle anti-idling regulation, the District will partner with CARB to conduct additional targeted anti-idling enforcement efforts in South Central Fresno community at least once per quarter for the next 5 years.

The District and CARB will work with the Community Steering Committee to identify heavy-duty vehicle idling “hot spots,” especially those near schools, to aid in focusing the enforcement efforts.

South Central Fresno Community Emissions Reduction Program September 19, 2019 176 | P a g e

7. Report back to the Community Steering Committee on Enforcement Activities:

The District will track and provide an annual report to the Community Steering Committee to summarize the District enforcement efforts within the community and to monitor progress in implementing community enforcement measures and meeting enforcement goals.

8. Coordinate with other agencies
The District will seek opportunities to coordinate with other agencies within the South Central Fresno community to address multimedia compliance issues as they arise.

9. Update enforcement strategies as appropriate
The District committed to evaluating the results of ongoing compliance activities within the South Central Fresno community and moving forward will work with the Community Steering Committee to update measures as appropriate.

5.6.2 CARB ENFORCEMENT STRATEGIES
CARB acknowledges that the high compliance rates identified in the enforcement history may not necessarily reflect compliance across the community. In cases where enhanced enforcement activities uncover non-compliance issues, CARB’s goal will be to achieve the same or higher compliance rates as observed in the three-year history. CARB staff will also work closely with the community steering committee, the Air District, and other agencies (e.g. City of Fresno) to address gaps in the enforcement of mobile sources and seek opportunities to close these gaps.

To support achieving these goals, CARB is committed to enhancing enforcement activities within South Central Fresno by utilizing the following tools:
 An assessment of the enforcement history data
 Targeting areas that may require additional enforcement with guidance from the community steering committee
CARB will utilize current regulations and enforcement programs across all sources CARB regulates to target areas of non-compliance within the South Central Fresno community.

Listed below are CARB’s enforcement strategies to help improve air quality in the South Central Fresno community:

1. Increase the frequency of compliance inspections with guidance from the community steering committee:

CARB will collaborate with the South Central Fresno community steering committee to actively enhance enforcement activities. This will be done through a combination of improved complaint reporting, more focused inspections, and report-back meetings to update the community steering committee on both the status of inspections and to obtain additional areas of mobile source concern.

CARB will work with the steering committee to meet annually in order to prioritize enforcement strategies and identify possible locations where non-compliant South Central Fresno Community Emissions Reduction Program September 19, 2019 177 | P a g e
vehicles are present. CARB will additionally report to the community the number of inspections performed, mapped locations of the enforcement, and the number of citations and/or Notices of Violations issued.

As of July 2019, the community steering committee has guided CARB staff to focus enforcement efforts in the following areas:
a. HDV near Jensen Ave, North Ave, American Ave and Central Ave b. Idling HDV near schools and residential areas

2. Achieve Compliance with the Truck and Bus Regulation via Senate Bill 1:

In April 2017, the Governor signed Senate Bill 1 (SB 1) into law which included a provision that, beginning in 2020, a vehicle must demonstrate compliance with the STB regulation before it can be registered with the Department of Motor Vehicles (DMV). Beginning in 2020, the DMV, in conjunction with data provided by CARB, will deny vehicle registration to non-compliant HDVs based on the model year of the HDV.

Figure 5-10: Truck and Bus Regulation Engine Requirements Timeline

3. Provide Annual Report of Enforcement Activities
CARB’s enforcement division will provide an annual report to the CSC to update and summarize CARB’s enforcement activities within the community.

4. Coordinate with other agencies
CARB will seek opportunities to coordinate with other agencies with enforcement authority in South Central Fresno. One such opportunity could be CARB staff working with the City of Fresno to provide truck idling signage in areas where community members observe trucks idling.

South Central Fresno Community Emissions Reduction Program September 19, 2019 178 | P a g e

5. Enhance CARB’s Data Management Practices
CARB is committed to enhancing the quality of enforcement data for the South Central Fresno community. Moving forward, CARB will maintain the location of enforcement activity and received complaints to provide the community steering committee with the most accurate data available. CARB has recently completed a visualization tool that makes CARB enforcement data more transparent and available. The tool can be accessed online by visiting
https://webmaps.arb.ca.gov/edvs/.

6. Provide in-person community specific training
CARB will develop and implement a new program that will be offered to the South Central Fresno community. Information will cover topics like the fundamentals of enforcement, how the enforcement process works, instructions on filing a thorough complaint, and what to expect from the enforcement process after filing a complaint. Through this program, community members will be able to better support CARB or air district enforcement processes. CARB may also develop online trainings in the future.

7. Update enforcement strategies as applicable
CARB staff are committed to updating enforcement strategies as requested by the community steering committee, if said strategies are enforceable by CARB staff or if CARB can reasonably accommodate the request (e.g., additional enforcement training for idling vehicles).

South Central Fresno Community Emissions Reduction Program September 19, 2019 179 | P a g e

6. METRICS TO TRACK PROGRESS

6.1 METRICS TO TRACK PROGRESS IN ANNUAL REPORTS
Identifying metrics to track progress is critical for both the public and implementing agencies to understand whether the CERP is achieving heath-based air quality objectives. AB 617 requires that the community emissions reduction program result in emissions reductions, which can be demonstrated based on monitoring or other data.

Per CARB guidance, community emissions reduction programs must identify and describe how progress on achieving emission reductions for specific categories of sources will be tracked on an annual basis, and track emissions for any pollutant that has an identified emissions reduction target.

For annual reporting, the District will report on the emission reductions achieved and progress towards meeting individual emissions reduction targets for each pollutant.

For each incentive-based emission reduction measure, the District will include information about dollar amounts invested and number of projects implemented in the community.

For proximity-based goals, the District will report on the following factors:
 Number of schools registered for the District’s HAL Schools Program  Number of schools with advanced filtration systems installed, and number of classrooms with room filtration units installed at each school  Number of educational events held related to health-protective measures for the public
 Number of facilities that have installed vegetative barriers as a result of District outreach and partnership programs
 Footage of vegetative barrier installed along roads or train routes as a result of District outreach and partnership programs
For compliance goals, the following metrics will be reported on annually:
 Inspections conducted including type, date, and location.  Notices of violations issued including date, recipient, and regulation cited  Number of complaints received by type and their resolution  Percentage of notices of violations/notices to comply that have been resolved The District will report annually on the status of rules and regulations adopted that impact the community of South Central Fresno. For strategies in partnership with other agencies, the District will report on the number of interactions with city and county governments to address local exposure to air pollution. In addition to the measures committed to be implemented as a part of the CERP, the District will continue to implement existing incentive programs and will report on incentive projects deployed in and around the community, and associated emissions reductions. Finally, annual reports will include metrics to track additional co-benefits, such as trainings, outreach, workforce development, or technical capacity-building, including the number of public meetings held in the community and number of people in attendance.

South Central Fresno Community Emissions Reduction Program September 19, 2019 186 | P a g e

7. CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)

PROJECT REVIEW
According to Section 15061 (b)(3) of the California Environmental Quality Act (CEQA) Guidelines, a project is exempt from CEQA if, “the activity is covered by the common sense rule that CEQA applies only to projects which have the potential for causing a significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA.” Since the Project will result in an air quality benefit to the community, the Project is not expected to result in a significant impact under CEQA.

As such, the common sense exemption applies.

In addition, this Project is an action taken by a regulatory agency, the San Joaquin Valley Air District, as authorized by state law for the protection and betterment of air quality in the San Joaquin Valley. CEQA Guidelines §15308 provides a categorical exemption for “actions taken by regulatory agencies, as authorized by state or local ordinance, to assure the maintenance, restoration, enhancement, or protection of the environment where the regulatory process involves procedures for protection of the environment. Construction activities and relaxation of standards allowing environmental degradation are not included in this exemption.” No construction activities or relaxation of standards are included in this project. As such, for this additional reason, the District finds that the project is exempt from CEQA.

Pursuant to Section 15062 of the CEQA Guidelines, the District will file a Notice of Exemption upon Governing Board approval of the Project.

Attachment L

i
Table of Contents
Table of Contents ........................................................................................................................ i List of Figures........................................................................................................................... vii List of Tables .............................................................................................................................. x List of Appendices .................................................................................................................... xii Abbreviations........................................................................................................................... xiii Executive Summary................................................................................................................... 1 The Scoping Plan Process ..................................................................................................... 5 Ensuring Equity and Affordability........................................................................................... 7 Energy and Technology Transitions...................................................................................... 8 Cost-Effective Solutions Available Today.............................................................................. 9 Continue with a Portfolio Approach ...................................................................................... 10 Conclusion............................................................................................................................ 11 Post-adoption of the Scoping Plan ....................................................................................... 11 Chapter 1: Introduction ............................................................................................................ 13 Severity of Climate Change Impacts .................................................................................... 15 Wildfires ............................................................................................................................ 15 Drought ............................................................................................................................. 17 Extreme Heat.................................................................................................................... 19 Imperative To Act ................................................................................................................. 21 Consequences of Further Warming .................................................................................. 21 Scoping Plan Overview ........................................................................................................ 23 Previous Scoping Plans .................................................................................................... 23 Overview of this Scoping Plan .......................................................................................... 24 Principles That Inform Our Approach to Addressing the Climate Challenge........................ 25 Unprecedented Investments in a Sustainable Future........................................................ 25 Centering Equity................................................................................................................ 27 Role of the Environmental Justice Advisory Committee ................................................. 29 Partnering with Tribes..................................................................................................... 30 Maximizing Air Quality and Health Benefits....................................................................... 32 Economic Resilience......................................................................................................... 34 Partnering Across Government ......................................................................................... 35 Partnering with the Private Sector..................................................................................... 35 Supporting Innovation ....................................................................................................... 37 Engagement with Partners to Develop, Coordinate, and Export Policies .......................... 38 Working Toward Carbon Neutrality ................................................................................... 41 Supporting Healthy and Resilient Lands ........................................................................... 42 Maintaining the Focus on Methane and Short-Lived Climate Pollutants ........................... 42 Process for Developing the Scoping Plan ......................................................................... 44 Guidance from the Administration and Legislature ......................................................... 44 Consideration of Relevant State Plans and Regulations ................................................ 53 Input from Partners and Stakeholders ............................................................................ 54 Emissions Data That Inform the Scoping Plan..................................................................... 54 Greenhouse Gas Emissions.............................................................................................. 54 Natural and Working Lands............................................................................................... 57 Black Carbon..................................................................................................................... 60 Tracking Life-Cycle and Out-of-State Emissions............................................................... 60 Tracking Progress ............................................................................................................. 61 Chapter 2: The Scoping Plan Scenario ........................................................................................... 63 Scenarios for the AB 32 GHG Inventory Sectors ................................................................. 63 Scenarios for Natural and Working Lands ........................................................................... 65 Evaluation of Scoping Plan Alternatives .............................................................................. 67 ii
iii
NWL Scoping Plan Alternatives............................................................................................ 67 Scoping Plan Scenario......................................................................................................... 70 AB 32 GHG Inventory Sectors .......................................................................................... 70 Natural and Working Lands............................................................................................... 79 Strategies for Carbon Removal and Sequestration .............................................................. 83 The Role of Carbon Capture and Sequestration ............................................................... 84 The Role of Natural and Working Lands Emissions and Sequestration............................ 89 The Role for Carbon Dioxide Removal (Direct Air Capture).............................................. 91 Carbon Dioxide Removal and Capture Targets for 2030 and 2045 .................................. 94 Scenario Uncertainty............................................................................................................ 97 Greenhouse Gas Emissions Modeling.............................................................................. 97 Implementation ................................................................................................................. 98 Targeted Evaluations for the Scoping Plan: Oil and Gas Extraction and Refining...............100 Oil and Gas Extraction .....................................................................................................101 Petroleum Refining...........................................................................................................106 Progress Toward Achieving the Accelerated 2030 Target ..................................................108 Cap-and-Trade Program Update .....................................................................................112 Chapter 3: Economic and Health Evaluations ........................................................................118 Economic Analysis ..............................................................................................................118 Estimated Direct Costs.....................................................................................................119 AB 32 GHG Inventory Sectors......................................................................................120 Natural and Working Lands ..........................................................................................121 Economy and Employment ..............................................................................................123 AB 32 GHG Inventory Sectors......................................................................................123 Natural and Working Lands ..........................................................................................127 Health Analysis ................................................................................................................128 AB 32 GHG Inventory Sectors......................................................................................129 iv
Natural and Working Lands ..........................................................................................133 AB 197 Measure Analysis ...................................................................................................135 Estimated Emissions Reductions.....................................................................................136 AB 32 GHG Inventory Sectors......................................................................................136 Natural and Working Lands ..........................................................................................139 Estimated Health Endpoints.............................................................................................140 AB 32 GHG Inventory Sectors......................................................................................140 Natural and Working Lands ..........................................................................................146 Estimated Social Cost......................................................................................................148 AB 32 GHG Inventory Sectors......................................................................................150 Natural and Working Lands ..........................................................................................151 Social Costs of GHGs in Relation to Cost-Effectiveness ..............................................153 Estimated Cost per Metric Ton.........................................................................................153 AB 32 GHG Inventory Sectors......................................................................................154 Natural and Working Lands ..........................................................................................155 Climate Vulnerability Metric.................................................................................................157 Public Health .......................................................................................................................160 Health Analysis Overview ................................................................................................160 Health Analysis Components...........................................................................................162 Social and Environmental Determinants of Health Inequities..............................................164 Environmental Determinants of Health Inequities.........................................................166 Climate Vulnerabilities......................................................................................................169 Summary of the Qualitative Health Analysis ....................................................................171 Heat Impacts.................................................................................................................172 Wildfires and Smoke.....................................................................................................172 Children’s Health and Development .............................................................................172 Economic Security........................................................................................................173 v
Food Security................................................................................................................173 Mobility and Physical Activity........................................................................................173 Affordable Housing .......................................................................................................174 Urban Greening ............................................................................................................174 No Action Scenario (Reference) ...................................................................................174 Take Action Scenario....................................................................................................175 Summary of Health Benefits .........................................................................................177 Environmental Analysis .......................................................................................................180 Chapter 4: Key Sectors...........................................................................................................182 Transportation Sustainability ...............................................................................................184 Sector Transition..............................................................................................................185 Technology ...................................................................................................................185 Strategies for Achieving Success ..............................................................................187 Fuels.............................................................................................................................189 Strategies for Achieving Success ..............................................................................191 Vehicle Miles Traveled..................................................................................................192 Strategies for Achieving Success ..............................................................................194 Clean Electricity Grid...........................................................................................................195 Sector Transition..............................................................................................................199 Strategies for Achieving Success ..............................................................................205 Sustainable Manufacturing and Buildings ...........................................................................206 Sector Transition..............................................................................................................207 Industry.........................................................................................................................207 Strategies for Achieving Success ..............................................................................210 Buildings .......................................................................................................................211 Strategies for Achieving Success ..............................................................................214 Carbon Dioxide Removal and Capture................................................................................216 vi
Sector Transition..............................................................................................................220 Strategies for Achieving Success ..............................................................................221 Short-Lived Climate Pollutants (Non-Combustion Gases)...................................................222 Methane...........................................................................................................................225 Hydrofluorocarbons..........................................................................................................227 Anthropogenic Black Carbon ...........................................................................................229 Sector Transition..............................................................................................................230 Methane........................................................................................................................230 Dairy and Livestock Methane........................................................................................231 Strategies for Achieving Success ..............................................................................232 Landfill Methane ...........................................................................................................233 Strategies for Achieving Success ..............................................................................234 Upstream Oil and Gas Methane Reduction ..................................................................235 Strategies for Achieving Success ..............................................................................236 Hydrofluorocarbons ......................................................................................................237 Strategies for Achieving Success ..............................................................................239 Anthropogenic Black Carbon ........................................................................................240 Strategies for Achieving Success ..............................................................................240 Natural and Working Lands.................................................................................................241 Landscapes......................................................................................................................243 Trends of Carbon on Landscapes....................................................................................245 Goals and Accelerating Nature-Based Solutions .............................................................246 Strategies for Achieving Success: Crosscutting Items for all NWL ...............................249 Forests, Shrublands, and Chaparral.............................................................................250 Strategies for Achieving Success ..............................................................................252 Grasslands....................................................................................................................252 Strategies for Achieving Success ..............................................................................253 vii
Croplands .....................................................................................................................254 Strategies for Achieving Success ..............................................................................255 Wetlands.......................................................................................................................257 Strategies for Achieving Success ..............................................................................257 Developed Lands..........................................................................................................258 Strategies for Achieving Success ..............................................................................259 Sparsely Vegetated Lands............................................................................................260 Strategies for Achieving Success ..............................................................................260 Additional Management Strategies ..................................................................................261 Considerations..............................................................................................................261 Additional NWL Actions and Strategies ........................................................................263 Chapter 5: Challenge Accepted..............................................................................................265 State-level Action ................................................................................................................265 Regulations and Programmatic Development..................................................................266 Incentive Programs ..........................................................................................................266 Local Action.........................................................................................................................267 Local Climate Action Planning and Permitting .................................................................268 Unlocking CEQA Mitigation for Local Success.................................................................270 Communities and Environmental Justice ............................................................................271 Academic Institutions and the Private Sector......................................................................277 Individuals ...........................................................................................................................279 List of Figures
Figure 1-1: California total and per capita GHG emissions...................................................... 14 Figure 1-2: The real costs of inaction....................................................................................... 23 Figure 1-3: Comprehensive California climate change investments........................................ 26 viii
Figure 1-4: California climate investments cumulative outcomes, ............................................ 29
Figure 1-5: Carbon neutrality: Balancing the net flux of GHG emissions from all sources and sinks ........................................................................................................................................ 42 Figure 1-6: Short-lived climate pollutant impacts ..................................................................... 43 Figure 1-7: 2019 State GHG emission contributions by GHG.................................................. 55 Figure 1-8: 2019 State GHG emission contributions by Scoping Plan sector.......................... 56 Figure 1-9: Carbon stocks in natural and working lands (MMT carbon) .................................. 58 Figure 1-10: Changes in carbon stock by landscape type ....................................................... 59 Figure 2-1: Reference and Scoping Plan Scenario GHG emissions........................................ 71 Figure 2-2: Forms of carbon removal and sequestration considered in this Scoping Plan ...... 84 Figure 2-3: Petroleum refining emissions with and without carbon capture and sequestration 88 Figure 2-4: Comparison of the Scoping Plan Scenario (NWL) with existing research ............. 90 Figure 2-5: Residual emissions in 2022, 2030, and 2045 for the Scoping Plan Scenario........ 92 Figure 2-6: Oil and gas extraction sector GHG emissions in 2022 and 2045 when activity is phased down with in-state fuel demand..................................................................................102 Figure 2-7: California in-state crude oil production .................................................................103 Figure 2-8: Crude oil imports by transportation type...............................................................104 Figure 2-9: Petroleum refining sector GHG emissions in 2022 and 2045 (with and without CCS) when activity is phased down with fuel demand .....................................................................107 Figure 2-10: Impact of delayed implementation on 2030 GHG emissions..............................111 Figure 3-1: Projected California gross state product (left) and employment growth (right) from 2021 to 2035 and 2045...........................................................................................................119 Figure 3-2: Cost and savings relative to the growing California economy for the Scoping Plan Scenario in 2035 and 2045 (AB 32 GHG Inventory sectors) ..................................................121 Figure 3-3: Gross state product (left) and employment (right) relative to a growing California economy for the Scoping Plan Scenario in 2035 and 2045 (AB 32 GHG Inventory sectors)..124 Figure 3-4: Illustration of NOx emission reductions from current levels for the Reference Scenario and the Scoping Plan Scenario (AB 32 GHG Inventory sectors).............................130 ix
Figure 3-5: Difference in annual average PM2.5 (µg/m3) in the Scoping Plan scenario relative to the Reference scenario in 2045 (AB 32 GHG Inventory sectors) ...........................................131 Figure 3-6: Total health benefits estimated from air quality improvements in the Scoping Plan Scenario (AB 32 GHG Inventory sectors)...............................................................................132 Figure 3-7: Disadvantaged community health benefits relative to the Reference Scenario for the Scoping Plan Scenario (AB 32 GHG Inventory sectors).........................................................133 Figure 3-8: Total average annual health benefits relative to the Reference Scenario for the Scoping Plan Scenario (NWL)................................................................................................134 Figure 3-9: Categories of climate change impacts on human welfare included in the Climate Vulnerability Metric. ................................................................................................................158 Figure 3-10: Combined impacts of climate change in 2050 under a moderate emissions scenario; damages as share of 2019 tract income (%) ..........................................................................159 Figure 3-11: Scoping Plan outcome and the path to health improvements.............................163 Figure 3-12: Least and most impacted neighborhoods from CalEnviroScreen.......................165 Figure 3-13: Top sources of PM2.5 and their contribution to PM2.5 exposures by race and in disadvantaged communities ...................................................................................................168 Figure 3-14: Quantified health benefits of active transportation from increased physical activity ...............................................................................................................................................177 Figure 4-1: Transition of on-road vehicle sales to ZEV technology in the Scoping Plan Scenario ...............................................................................................................................................186 Figure 4-2: Transportation fuel mix in 2022, 2030, and 2045 in the Scoping Plan Scenario ..190 Figure 4-3: 2021 total system electric generation (based on GWh)........................................196 Figure 4-4: Electricity supply trend by resource for a California summer day, July 2022.......199 Figure 4-5: Projected new electricity resources needed by 2045 in the Scoping Plan Scenario ...............................................................................................................................................203 Figure 4-6: Electric loads in 2022, 2030 and 2045 for the Scoping Plan Scenario .................204 Figure 4-7: Final energy demand in industrial manufacturing (left) and in oil and gas extraction and petroleum refining (right) in 2022, 2030, and 2045 in the Scoping Plan Scenario ...........208 Figure 4-8: Final energy demand in buildings in 2022, 2030, and 2045 in the Scoping Plan Scenario .................................................................................................................................213 Figure 4-9: Residential space heating appliance sales in the Scoping Plan Scenario............214 x
Figure 4-10: Carbon management infrastructure....................................................................217 Figure 4-11: Expected progress toward SB 1383 targeted emissions reductions by 2030 through strategies currently in place....................................................................................................224 Figure 4-12: Sources of California methane emissions (2019)...............................................226 Figure 4-13: Sources of hydrofluorocarbon (HFC) emissions (2019) .....................................229 Figure 4-14: Sources of anthropogenic black carbon (preliminary 2017 estimates; AR5 100-yr GWP 900)...............................................................................................................................230 Figure 4-15: Methane emissions in 2022, 2030, and 2045 in the Scoping Plan Scenario .....231 Figure 4-16: Degradable carbon deposited in landfills............................................................234 Figure 4-17: Hydrofluorocarbon emissions in 2022, 2030, and 2045 in the Scoping Plan Scenario ...............................................................................................................................................237 Figure 4-18: Potential emissions from refrigerants in existing equipment...............................239 Figure 4-19: Remaining non-combustion emissions in 2022, 2030, and 2045 in the Scoping Plan Scenario .................................................................................................................................241 Figure 4-20: Acreage of burned wildland vegetation area ......................................................242 Figure 4-21: Forest (left) and shrubland (right) carbon stocks by 2045,..................................251 Figure 4-22: Grassland carbon stocks by 2045 ......................................................................253 Figure 4-23: Cumulative CO2e emissions from annual croplands in 2045..............................255 Figure 4-24: Cumulative CO2e emissions from Delta wetlands by 2045.................................257 Figure 4-25: Carbon stocks in urban forests by 2045 .............................................................259 Figure 4-26: Carbon stocks in sparsely vegetated lands by 2045 ..........................................260 List of Tables
Table 1-1: Major climate legislation and executive orders enacted since the 2017 Scoping Plan ................................................................................................................................................ 45 Table 2-1: Actions for the Scoping Plan Scenario: AB 32 GHG Inventory sectors .................. 72 Table 2-2: Actions for the Scoping Plan Scenario: NWL sectors............................................. 80 xi
Table 2-3: GHG emissions and removals needed to achieve carbon neutrality and meet the 20 MMTCO2 removal and capture target in 2030 and the 100 MMTCO2 removal and capture target in 2045..................................................................................................................................... 96 Table 2-4: Estimates of 2030 GHG emissions........................................................................109 Table 2-5: Comparison of 2017 Scoping Plan and two Reference Scenarios ........................116 Table 3-1: Cost and savings relative to a growing California economy for the Scoping Plan Scenario (NWL)......................................................................................................................122 Table 3-2: Income Impacts by California household income group in 2035 and 2045 for the Scoping Plan Scenario (AB 32 GHG Inventory Sectors) ........................................................125 Table 3-3: Percentage of households in each race/ethnicity category by household income group ...............................................................................................................................................127 Table 3-4: Gross state product and employment relative to a growing California economy for the Scoping Plan Scenario in 2035 / 2045 (NWL) ........................................................................128 Table 3-5: Estimated GHG and criteria pollutant emission reductions relative to the Reference Scenario for the Scoping Plan Scenario in 2035/2045 (AB 32 GHG Inventory sectors) .........138 Table 3-6: Estimated average annual GHG and criteria pollutant emission reductions relative to the Reference Scenario for the Scoping Plan Scenario from 2025–2045 (NWL)....................140 Table 3-7: Estimated avoided incidence of mortality, cardiovascular and respiratory disease onset, work loss days and hospital admissions relative to the Reference Scenario for the Scoping Plan Scenario (AB 32 GHG Inventory sectors) .......................................................................143 Table 3-8: Estimated average annual avoided incidence of hospital admissions, emergency room visits, and mortality relative to the Reference Scenario for the Scoping Plan Scenario resulting from forest, shrubland, and grassland wildfire emissions (NWL)..............................148 Table 3-9: Estimated social cost (avoided economic damages) of measures considered in the Scoping Plan Scenario (AB 32 GHG Inventory sectors) .........................................................151 Table 3-10: Estimated social cost (avoided economic damages) of measures considered in the Scoping Plan Scenario (NWL)................................................................................................152 Table 3-11: Estimated cost per metric ton of reduced CO2e relative to the Reference Scenario for measures considered in the Scoping Plan Scenario (AB 32 GHG Inventory sectors) .......155 Table 3-12: Estimated average cost per metric ton of reduced CO2e relative to the Reference Scenario for measures considered in the Scoping Plan Scenario (NWL)...............................156 Table 3-13: Examples of vulnerable groups due to socioeconomic, environmental, developmental, and climate change factors............................................................................171 xii
Table 3-14: Scoping Plan directional benefits for health co-benefit areas (heat, affordable housing, food security, economic security, and urban greening)............................................178 Table 3-15: Scoping Plan directional benefits for health co-benefit areas (traffic pollution, wildfire, and active transportation) .......................................................................................................179 Table 4-1: Scoping Plan modeled target for NWL, based on increasing action on NWL .......247 List of Appendices
Appendix A. Public Process
Appendix B. Final Environmental Analysis
Appendix C. AB 197 Measure Analysis
Appendix D. Local Actions
Appendix E. Sustainable and Equitable Communities
Appendix F. Building Decarbonization
Appendix G. Public Health
Appendix H. AB 32 GHG Inventory Sector Modeling
Appendix I. Natural and Working Lands Technical Support Document Appendix J. Uncertainty Analysis
Appendix K. Climate Vulnerability Metric
xiii
Abbreviations
°F Fahrenheit
°C Celsius
AB Assembly Bill
AQMD Air Quality Management District
AR5 IPCC Fifth Assessment Report
BECCS bioenergy with carbon capture and storage
CAISO California Independent System Operator
CalEPA California Environmental Protection Agency
CalGEM California Geologic Energy Management Division
CalSTA California State Transportation Agency
CAP climate action plan
CARB California Air Resources Board
CCR California Code of Regulations
CCS carbon capture and sequestration
CCUS carbon capture, utilization, and storage
CDFA California Department of Food and Agriculture
CDPH California Department of Public Health
CDR carbon dioxide removal
CE common era
CEC California Energy Commission
CEQA California Environmental Quality Act
CES CalEnviroScreen
CH4 methane
CMAQ Community Multiscale Air Quality
CNRA California Natural Resources Agency
CO2 carbon dioxide
COPD chronic obstructive pulmonary disease
xiv
CORE Clean Off-Road Equipment
CPUC California Public Utilities Commission
CVM Climate Vulnerability Metric
DAC direct air capture
DPR Department of Pesticide Regulation
Draft EA Draft Environmental Analysis for this Scoping Plan EA Environmental Analysis
ED emergency department
EIA U.S. Energy Information Administration
EJ environmental justice
EJ Advisory Committee Environmental Justice Advisory Committee EO executive order
EV electric vehicle
F-gas fluorinated gas
FCEV fuel cell electric vehicle
GCF Governors’ Climate and Forests Task Force
GDP gross domestic product
GHG greenhouse gas
GSP gross state product
GW gigawatt
GWh gigawatt-hour
GWP global warming potential
HDV heavy-duty vehicle
HD ZEV heavy-duty zero-emission vehicle
HFC hydrofluorocarbon
IBank Infrastructure and Economic Development Bank
ICE internal combustion engine
IPCC Intergovernmental Panel on Climate Change
xv
IPT incidence-per-ton
IWG Interagency Working Group
LCFS low-carbon fuel standard
LDV light-duty vehicle
MDV medium-duty vehicle
MMT million metric tons
MMTCO2e million metric tons of carbon dioxide equivalent MOU memorandum of understanding
MRR Mandatory Reporting of GHG Emissions
MTCO2e metric tons of carbon dioxide equivalent
MW megawatt
N2O nitrous oxide
NEMS National Energy Systems Model
NF3 nitrogen trifluoride
NOAA National Oceanic and Atmospheric Administration
NOx nitrogen oxides
NRDC National Resources Defense Council
NWL Natural and Working Lands
OEHHA Office of Environmental Health Hazard Assessment
OGV Ocean-Going Vessel
OPR Governor’s Office of Planning and Research
OTC once-through cooled
PFC perfluorocarbon
PHMSA Pipelines and Hazardous Materials Safety Administration PM particulate matter
PM2.5 fine particulate matter
PPP public-private partnership
RFS renewable fuel standard
xvi
ROG reactive organic gases
RPS Renewables Portfolio Standard
SB Senate Bill
SC-CH4 social cost of methane
SC-CO2 social cost of carbon
SC-GHG social cost of greenhouse gases
SC-N2O social cost of nitrous oxide
SF6 sulfur hexafluoride
SGIP Self-Generation Incentive Program
SLCP short-lived climate pollutant
TSD Technical Support Document
UC University of California
UCLA University of California, Los Angeles
UNFCCC United Nations Framework Convention on Climate Change U.S. EPA United States Environmental Protection Agency
VMT vehicle miles traveled
WUI wildland-urban interface
ZEV zero-emission vehicle
1 Executive Summary
This Scoping Plan lays out the sector-by-sector roadmap for California, the world’s fifth1 largest economy, to achieve carbon neutrality by 2045 or earlier, outlining a technologically feasible, costeffective, and equity-focused path to achieve the state’s climate target. This is a challenging but necessary goal to minimize the impacts of climate change. There have been three previous Scoping Plans. Previous plans have focused on specific greenhouse gas (GHG) reduction targets for our industrial, energy, and transportation sectors — first to meet 1990 levels by 2020, then to meet the more aggressive target of 40 percent below 1990 levels by 2030. This plan, addressing recent legislation and direction from Governor Newsom, extends and expands upon these earlier plans with a target of reducing anthropogenic emissions to 85 percent below 1990 levels by 2045. This plan also takes the unprecedented step of adding carbon neutrality as a science-based guide and touchstone for California’s climate work. The plan outlines how carbon neutrality can be achieved by taking bold steps to reduce GHGs to meet the anthropogenic emissions target and by expanding actions to capture and store carbon through the state’s natural and working lands and using a variety of mechanical approaches.

What this means for California is an ambitious and aggressive approach to decarbonize every sector of the economy, setting us on course for a more equitable and sustainable future in the face of humanity’s greatest existential threat, and ensuring that those who benefit from this transformation include communities hardest hit by climate impacts and the ongoing pollution from the use of fossil fuels. The combustion of fossil fuels has polluted our air — particularly in low-income communities and communities of color — for far too long and is the root cause of climate change.

This Scoping Plan helps us chart the path to a future where race and class are no longer predictors of disproportionate burdens from harmful air pollution and climate impacts.

The major element of this unprecedented transformation is the aggressive reduction of fossil fuels wherever they are currently used in California, building on and accelerating carbon reduction programs that have been in place for a decade and a half. That means rapidly moving to zeroemission transportation; electrifying the cars, buses, trains, and trucks that now constitute California’s single largest source of planet-warming pollution. It also means phasing out the use of fossil gas used for heating our homes and buildings. It means clamping down on chemicals and refrigerants that are thousands of times more powerful at trapping heat than carbon dioxide (CO2 ).

It means providing our communities with sustainable options for walking, biking, and public transit to reduce reliance on cars and their associated expenses. It means continuing to build out the solar arrays, wind turbine capacity, and other resources that provide clean, renewable energy to displace fossil-fuel fired electrical generation. It also means scaling up new options such as renewable hydrogen for hard-to-electrify end uses and biomethane where needed. Successfully achieving the outcomes called for in this Scoping Plan would reduce demand for liquid petroleum by 94 percent 1 In October 2022, California was poised to become the world’s fourth largest economy.

and total fossil fuel by 86 percent in 2045 relative to 2022.2 Despite these world-leading efforts, some amount of residual emissions will remain from hard-to-abate industries such as cement, internal combustion vehicles still on the road, and other sources of GHGs, including high global warming chemicals used as refrigerants.

The plan addresses these remaining emissions by re-envisioning our natural and working lands — forests, shrublands/chaparral, croplands, wetlands, and other lands — to ensure they play as robust a role as possible in incorporating and storing more carbon in the trees, plants, soil, and wetlands that cover 90 percent of the state’s 105 million acres while also thriving as a healthy ecosystem. Modeling indicates that natural and working lands will not, on their own, provide enough sequestration and storage to address the residual emissions. For that reason, it is necessary to research, develop, and deploy additional methods of capturing CO2 that include pulling it from the
smokestacks of facilities, or drawing it out of the atmosphere itself and then safely and permanently utilizing and storing it, as called for in recent legislation. Carbon removal also will be necessary to achieve net negative emissions to address historical GHGs already in the atmosphere.

This is a plan that aims to shatter the carbon status quo and take action to achieve a vision of California with a cleaner, more sustainable environment and thriving economy for our children. This ambitious plan will serve as a model for other partners around the world as they consider how to make their transition. As we have so often in the past, California can continue to serve as a leader in innovation that has produced not only the fifth largest economy on the planet, but ultimately one of the most energy-efficient economies, with a track record of demonstrating the ability to decouple economic growth from carbon pollution. This plan also builds upon current and previous environmental justice efforts to integrate environmental justice directly into the plan, to ensure that all communities can reap the benefits of this transformational plan. Specifically, this plan identifies a path to keep California on track to meet its SB 32 GHG reduction target of at least 40 percent below 1990 emissions by 2030.
2 See CARB's energy demand reductions.
3 • Identifies a technologically feasible, cost-effective path to achieve carbon neutrality by 2045 and a reduction in anthropogenic emissions by 85 percent below 1990 levels. • Focuses on strategies for reducing California’s dependency on petroleum to provide consumers with clean energy options that address climate change, improve air quality, and support economic growth and clean sector jobs.
• Integrates equity and protecting California’s most impacted communities as driving principles throughout the document.
• Incorporates the contribution of natural and working lands (NWL) to the state’s GHG emissions, as well as their role in achieving carbon neutrality. • Relies on the most up-to-date science, including the need to deploy all viable tools to address the existential threat that climate change presents, including carbon capture and sequestration, as well as direct air capture.
• Evaluates the substantial health and economic benefits of taking action. • Identifies key implementation actions to ensure success. 3 IPCC. 2021. Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change. [Masson-Delmotte, V., P. Zhai, A. Pirani, S. L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L. Goldfarb, M. I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J. B. R. Matthews, T. K. Maycock, T. Waterfield, O. Yelekçi, R. Yu, and B. Zhou (eds.)]. Cambridge University Press.

In Press.
4 IPCC. 2018. Global Warming of 1.5°C. World Meteorological Organization. Geneva, Switzerland. 32 pp. 5 IPCC. 2021. Climate change widespread, rapid, and intensifying – IPCC. August. 6 United Nations. 2021. IPCC report: ‘Code red’ for human driven global heating, warns UN chief. August 9.

The path forward is informed by robust science. The recent Sixth Assessment Report (AR6) of the Intergovernmental Panel on Climate Change (IPCC) summarizes the latest scientific consensus on climate change. It finds that atmospheric concentrations of CO2 have increased by 50 percent
since the industrial revolution and continue to increase at a rate of two parts per million each year.3 By the 2030s, and no later than 2040, the world will exceed 1.5°C warming unless there is drastic action. While every tenth of a degree matters — every incremental increase in warming brings additional negative impacts — climate-related risks to human health, livelihoods, and biodiversity are projected to increase further under 2°C warming, compared to 1.5°C.4 For example, at 1.5°C
of global warming, we would experience increasing heat waves, longer warm seasons, and shorter cold seasons, but at 2°C of global warming, heat extremes would more often reach critical tolerance thresholds for human health and agriculture.5
We are already seeing unprecedented climate change
impacts, such as continued sea level rise, that are “irreversible” for centuries to millennia, and we are dangerously close to hitting 1.5°C in the near term.6
To avoid climate catastrophe and remain below

1.5°C with limited or no overshoot of that threshold, global net anthropogenic CO2 emissions need
to reach net zero by 2050.
4 It has been 16 years since the Global Warming Solutions Act of 2006 was passed and signed into law.

In 2017, the second update to the Assembly Bill (AB) 32 Climate Change Scoping Plan7 (2017 Scoping
Plan) laid out a cost-effective and technologically feasible path to achieve the 2030 GHG reduction target. At the time, many characterized the plan and the AB 32 target as unachievable, citing that it would lead to massive business and job loss, and excessive costs. Those predictions proved to be incorrect as California achieved its AB 32 target years ahead of schedule, all the while growing our economy, with the state distinguishing itself as a hub for green technology investment. This Scoping Plan draws on a decade and a half of proven successes and additional new approaches to provide a balanced and aggressive course of effective actions to achieve carbon neutrality in 2045, if not before, in addition to the 2030 goal.

California’s economy is projected to grow vigorously in the coming years and decades. In 2045, under a Reference Scenario, the gross state product would be $5.1 trillion, nearly $2 trillion more than in 2021, and allow growth that would add hundreds of thousands of jobs. Under the Scoping Plan scenario, impacts to economic and job growth would be negligible in both 2035 and 2045, while delivering $199 billion of benefits in the form of reduced hospitalizations, asthma cases, and lost work and school days due to the cleaner air supported by this plan. This should come as no surprise given the tremendous growth of California’s economy since the Great Recession of 2007–2009, even as the state has taken drastic measures to lower emissions. As noted, the savings associated with ambitious climate action are extensive, both in terms of avoided climate impacts and health costs. As described in Chapter 1, the health costs of climate and air pollution in the U.S. are well over $800 billion today and will continue to grow in the coming years8
without robust action. Similarly, the costs of delayed or insufficient climate action could cost the U.S. upwards of $14.5 trillion over the next 50 years.9 We can
either take action now or pay the cost of inaction, both now and later.

We cannot take on this unprecedented challenge alone. Collaboration with the federal government, other U.S. states, and other jurisdictions around the world will continue to be fundamental for California to succeed in achieving its climate targets, especially as the pace of our efforts increases in the coming years. We believe this collaboration and coordination also creates a race to the top, encouraging and enabling other jurisdictions to achieve climate and air quality goals as well, and often providing lessons for national action.

One example of fruitful collaboration is California’s longstanding vehicle emissions standards programs, which have repeatedly been freely adopted by other states, consistent with the federal Clean Air Act. California’s programs frequently pioneer more rigorous standards or new technologies — such as the now-standard catalytic converter and the rules that led directly to the nation-leading numbers of zero-emission vehicles on our roads today. From initial standards for cars 7 CARB. 2017. California's 2017 Climate Change Scoping Plan. 8 Alwis, D. D., and V. S. Limaye. No date. The Costs of Inaction: The Economic Burden of Fossil Fuels and Climate Change on Health in the United States. NRDC, The Medical Society Consortium on Climate and Health, and WHPCA. 9 Deloitte. 2022. The Turning Point: A New Economic Climate in the United States.

and trucks decades ago to the world-leading Advanced Clean Trucks program currently helping to electrify heavy-duty vehicles, this partnership continues to offer regulatory options and spread innovative technologies. A major example of future work is the Advanced Clean Cars II program, which lays out California’s legally binding path to achieving 100 percent zero emission vehicle (ZEV) sales in 2035.10 The California Air Resources Board (CARB) continues to work closely with many other states that also see zero-emission vehicles as critical to their climate and public health goals and expects many states to choose to adopt this regulation as well. This partnership with other states also creates market certainty for automakers, which in turn helps to ensure that California consumers have access to a variety of ZEVs at multiple price points.

The Scoping Plan Process
Four scenarios were extensively modeled to develop this Scoping Plan, with the objective of informing the most viable path to remain on track to achieve our 2030 GHG reduction target: a reduction in anthropogenic emissions by 85% below 1990 levels and carbon neutrality by 2045.

All four have their merits and are informed by stakeholder input. The scenario ultimately chosen as the basis of this Scoping Plan is the alternative that most closely aligns with existing statute and Executive Orders. It was selected because it best achieves the balance of cost-effectiveness, health benefits, and technological feasibility.

For the first time, this Scoping Plan includes modeling and quantification of GHG emissions and carbon sequestration in natural and working lands (NWL). To date, the focus has been only on reducing the emissions of GHGs from our transportation, energy, and industrial sectors. The state’s 2020 and 2030 GHG reductions targets only include these sources, as they are the primary drivers of climate change and disproportionate harmful air pollution in our vulnerable communities. This Scoping Plan, through the lens of carbon neutrality, expands the scope to more meaningfully consider how our NWL contribute to our long-term climate goals. For the first time, new and cuttingedge modeling tools allow us to estimate the quantitative ability of our forests and other landscapes to remove and store carbon under different scenarios. These cutting-edge tools were developed through a stakeholder process and in coordination with other agencies for the purpose of this update and will continue to be refined over time and made available to others seeking to do similar work. 10 Executive Department. State of California. Executive Order N-79-20. 6 As recent data and Scoping Plan modeling shows, our NWL also can act as a source of emissions, principally in the form of wildfires. California’s forests are experiencing a deadly combination of drought and heat combined with a century of misguided fire suppression management. Scoping Plan modeling shows that, at this time and until our forests reach a balance through appropriate treatments, California’s NWL will act as a net source of emissions, not a sink. As such, the Scoping Plan includes policy direction and actions intended to quickly move the sector toward being a net sink and a more natural state, where wildfires will continue to be an important part of the healthy forest cycle but not at the intensity and frequency observed in recent years.

Development of this Scoping Plan also includes careful consideration of, and coordination with, other state agencies, consistent with Governor Gavin Newsom’s whole-of-government approach to tackling climate change. State agency plans and regulations, including the SB 100 Joint Agency Report,11 State Implementation Plan, Climate Action Plan for Transportation Infrastructure,12 AB 74 Studies on Vehicle Emissions and Fuel Demand and Supply,13,14,15 Short-Lived Climate Pollutant Strategy (SLCP Strategy),16 CARB’s Achieving Carbon Neutrality Report,17 Climate Smart Lands Strategy,18 Natural Working Land Implementation Plan,19 and the California Climate Insurance Report:

Protecting Communities, Preserving Nature, and Building Resiliency,20 among others, provided critical inputs and data points for this plan. This Scoping Plan is the product of work by multiple agencies across the Administration, including dozens of public workshops and years of rigorous analysis and economic modeling by California’s leading institutions. This cooperation on planning lays the foundation for even closer coordination among and between state agencies to put the plan into effect.

The plan is also the product of tireless efforts of, and recommendations from, the AB 32 Environmental Justice Advisory Committee (EJ Advisory Committee). The EJ Advisory Committee, created by statute, plays a critical role to inform the development of each Scoping Plan and helps to ensure environmental justice is integrated throughout the plan. CARB reconvened the EJ Advisory Committee in early 2021 to advise on the development of this Scoping Plan. In their advisory role, the EJ Advisory Committee has worked together to provide inputs to CARB to inform the development of scenarios and the associated modeling. And in April 2022, the EJ Advisory Committee provided draft preliminary recommendations in advance of the Draft 2022 Scoping Plan to help ensure the draft plan meaningfully addresses environmental justice. The CARB Board and EJ Advisory Committee held a joint board hearing on September 1, 2022, where the EJ Advisory Committee presented their final recommendations on the Scoping Plan. Over five dozen of the recommendations are reflected in the Scoping Plan. Going forward, as this plan is ultimately acted on by the Board, ongoing input from the EJ Advisory Committee will be essential to address environmental justice and achieve the ambitious vision outlined in the plan throughout its implementation in the coming years.
11 California Public Utilities Commission (CPUC), California Energy Commission (CEC), and CARB. 2021. SB 100 Joint Agency Report.
12 California State Transportation Agency (CalSTA). 2021. Climate Action Plan for Transportation Infrastructure. 13 California Environmental Protection Agency (CalEPA). 2021. Carbon Neutrality Studies. 14 Brown, A. L., et. al. 2021. Driving California’s Transportation Emissions to Zero. University of California Institute of Transportation Studies.
15 Deschenes, O. 2021. Enhancing equity while eliminating emissions in California’s supply of transportation fuels.

University of California Santa Barbara.
16 CARB. Short-Lived Climate Pollutants.
17 Energy and Environmental Economics, Inc. 2020. Achieving Carbon Neutrality in California: PATHWAYS Scenarios Developed for the California Air Resources Board. October. 18 California Natural Resources Agency (CNRA). 2021. Draft Climate Smart Lands Strategy. 19 CARB. 2019. Draft California 2030 Natural and Working Lands Climate Change Implementation Plan. 20 California Department of Insurance. 2021. Protecting Communities, Preserving Nature, and Building Resiliency. 7 Importantly, per legislative direction, the Scoping Plan development includes modeling and analyses of emissions, economics, air quality, health, jobs, and public health. This work is important to inform the discussion around trade-offs and how to balance the various legislative direction in identifying a path to achieve the state’s climate goals. The technical work serves as a backdrop to what this means to Californian’s daily lives — to how they will work, play, and live as we act to eliminate fossil fuel combustion and achieve the many public health and environmental benefits that will result from that action.

Ensuring Equity and Affordability
The state has a long history of public health and environmental protection. However racist and discriminatory practices such as redlining have resulted in low-income communities and communities of color being disproportionately exposed to health hazards and pollution burdens.21 These communities are often located adjacent to major roadways and large stationary sources that not only emit GHGs, but also harmful localized air pollution. The plan delivers on the promise to transform the way we move, live, and work by nearly eliminating our dependence on fossil fuels. It includes effective actions to move with all possible speed to clean energy, zero-emission cars and trucks, energy-efficient homes, sustainable agriculture, and resilient NWL. And it prioritizes working with the communities most impacted to ensure that these strategies address their needs.

An important part of our equity consideration is ensuring the transition to a zero-emission economy is affordable and accessible, and that it uplifts disadvantaged, low-income communities and communities of color. Some aspects of the transition will have associated costs (e.g., escalating efforts to retrofit existing homes and businesses to support electric appliances and vehicles and increased costs of insurance). The state must ensure that these costs do not disproportionately burden consumers. In addition, the state has an important role to play in providing financial incentives, especially to low-income consumers, to allow for uptake of clean technologies. The Department of Community Services and Development’s Low Income Weatherization Program is a prime example of this approach, enabling low-income Californians to be part of the zero-emission transition, all while lowering energy bills. The program provides low-income households with solar 21 CalEPA. 2021. Pollution and Prejudice: Redlining and Environmental Injustice in California. August 16. 8 photovoltaic systems and energy efficiency upgrades at no cost to residents, helping cushion the impact of climate change on vulnerable communities.

With this Scoping Plan, the state also adds another tool to help identify and close climate change impact gaps that will emerge over time. As California invests in climate mitigation and adaptation, it is essential to understand the relative impact of climate change across the state’s diverse communities. We know not all communities are equally resilient in the face of climate impacts due to persisting health and opportunity gaps. We also know that a global metric such as the Social Cost of Carbon cannot adequately capture the incremental additional impact faced by overly burdened communities. The Climate Vulnerability Metric (CVM) is specifically focused on quantifying the community-level impacts of a warming climate on human welfare.

Energy and Technology Transitions
To support the transformation needed, we must build the clean energy production and distribution infrastructure for a carbon-neutral future. The solution will have to include transitioning existing energy production and transmission infrastructure to produce zero-carbon electricity and hydrogen, and utilizing biogas resulting from wildfire management or landfill and dairy operations, among other substitutes. In almost all sectors, electrification will play an important role. That means that the grid will need to grow at unprecedented rates and ensure reliability, affordability, and resiliency through the next two decades and beyond. It also means we need to keep all options on the table, as it will take time to fully grow the electricity grid to be the backbone for a decarbonized economy. We also know that electrification is not possible in all situations. As such, this plan systematically evaluates and identifies feasible clean energy and technology options that will bring both near-term air quality benefits and deliver on longer-term climate goals.

This transition will not happen overnight. It will take time and planning to ensure a smooth transition of existing energy infrastructure and deployment of new clean technology. And while this Scoping Plan has the longest planning horizon of any Scoping Plan to date, this 25-year horizon is still relatively short in terms of transforming California’s economy. We must avoid making choices that will lead to stranded assets and incorporate new technologies that emerge over time. Importantly, given the pace at which we must transition away from fossil fuels, we absolutely must identify and address market and implementation barriers to be successful. The scale of transition includes adding four times the solar and wind capacity by 2045 and about 1,700 times the amount of current hydrogen supply.

As we transition our energy systems, we must also rapidly deploy the clean technologies that rely on a decarbonized grid. As called for in Executive Order N-79-20, all new passenger vehicles sold in California will be zero-emission by 2035, and all other fleets will have transitioned to zero-emission as fully possible by 2045. This means the percentage of fossil fuel combustion vehicles will continue to rapidly decrease, becoming a fading vision of the past. Successful implementation of this Executive

Order (EO) and other zero-emission priorities will have to be attractive to consumers. As an example, electric and hydrogen transportation refueling must be readily accessible, and active transportation and clean transit options must be cheaper and more convenient than driving.

Cost-Effective Solutions Available Today
Ultimately, to achieve our climate goals, urgent efforts are needed to slash GHG emissions.

Fortunately, cost-effective solutions are available to do so in many cases. In short, this plan relies on existing technologies — it does not require major technological breakthroughs that are highly uncertain.

For example, targeted action to reduce methane emissions can be achieved at low or negative cost, and with significant near-term climate and public health benefits. In many cases, renewable energy and energy storage are cheaper than polluting alternatives, and are already firmly part of our business-as-usual approach; modeling related to the most recent integrated resource planning process at the California Public Utilities Commission (CPUC) has shown that scenarios associated with the best emissions outcomes had the lowest average rates. As another example, research from Energy Innovation shows that the U.S. can achieve 100 percent zero-carbon power by 2035 without increasing customer costs.22
The same is either already true, or soon to be true, for zero-emission vehicles as well. Myriad studies show cost parity for light-duty and heavy-duty ZEVs being achieved by mid-decade or shortly thereafter. A carbon neutrality study conducted by the University of California (UC) Institute of Transportation Studies and funded by the California Environmental Protection Agency (CalEPA) shows that achieving carbon neutrality in the transportation sector will save Californians $167 billion through 2045.23 Similar research from the Goldman School of Public Policy at UC Berkeley finds that achieving 100 percent light-duty ZEV sales nationwide would save consumers $2.7 trillion through 2050; equivalent to $1,000 per household, per year, for 30 years.24 22 Phadke, A. et al. 2020. “Illustrative Pathways to 100 Percent Zero Carbon Power by 2035 Without Increasing Customer Costs, Energy Innovation.” September.
23 Brown, A. L., et al. 2021. Driving California’s Transportation Emissions. 24 Goldman School of Public Policy. 2021. 2035: The Report: Transportation. UC Berkeley. April. 10 2022 Scoping Plan for Achieving Carbon Neutrality: Executive Summary Many of these outcomes are a direct result of California’s vision and policy development to advance clean energy and climate solutions, including through the Renewables Portfolio Standard, Advanced Clean Cars II regulations, SLCP Reduction Strategy, and others. While the world collectively has not yet fully deployed clean energy and climate solutions at the scale needed to adequately address climate change, California has made tremendous progress — even since the last Scoping Plan update in 2017. Continued ambition, leadership, and climate policy development from California will help the state achieve the scale of emissions reductions needed from technologies and strategies that are already cost-effective or close to it today, and will move additional technologies and strategies to that point in the near future. Achieving those outcomes and reducing costs for the entire array of climate solutions needed to achieve carbon neutrality and then maintain net-negative emissions will prove the true measure of California’s success. This will enable California to not just meet our own climate targets, but to ultimately develop the replicable solutions that can scale globally to address global warming.

Continue with a Portfolio Approach
Over the past decade and a half, the state has undertaken a successful three-pronged approach to reducing GHGs: incentives, regulations, and carbon pricing. The 2017 Scoping Plan leveraged existing programs such as the Renewables Portfolio Standard, Advanced Clean Cars, Low Carbon Fuel Standard, Short-lived Climate Pollutant Strategy, mobile source measures to achieve federal air quality targets, and a Cap-and-Trade Program, among others, to lay out a technologically feasible and cost-effective path to achieve the 2030 GHG reduction target. When looking toward the 2045 climate goals and the deeper GHG reductions needed across the AB 32 GHG Inventory sectors, all of the existing programs must be evaluated and, as necessary, strengthened to support the rapid production and deployment of clean technology and energy, as well as the increased pace and scale of actions on our natural and working lands.

The challenge before us requires us to keep all tools on the table. Given the climate mitigation cobenefits, critical actions to deliver near-term air quality benefits, such as those included in the State Implementation Plan to achieve the federal air quality standards, are incorporated into this Scoping Plan, as are new legislative mandates to decarbonize the electricity and cement sectors. And, if additional gaps are identified, new programs and policies must be developed and implemented to 11 ensure all sectors are on track to reduce emissions. Opportunities to leverage these programs to address ongoing air quality disparities must also be considered, along with targeted environmental justice policies such as the AB 617 Community Air Protection Program and the investments made possible through the California Climate Investments Program.

Conclusion
California has never undertaken such a comprehensive, far-reaching, and transformative approach to fighting climate change as that called for in this plan. Once implemented, it will place every aspect of how we live, work, play, and travel in California on a more sustainable footing, with a focus on directly benefitting those communities already most burdened by pollution. This comprehensive approach reflects how climate change is already changing life in California. We have all experienced the impacts of devastating wildfires, extreme heat, and drought. Despite much progress, California still has some of the worst air pollution in the nation, especially in the San Joaquin Valley and the Los Angeles Basin, which is driven by the continued use of fossil fuel-powered trucks and cars.

This Scoping Plan provides a solution; a way forward and a vision of a California where we can and will address those impacts. This plan is fundamentally based on hope. It is a hope grounded in experience and science that we can fundamentally improve the California we leave to future generations. The plan is built on the legacy of effective actions and on the conviction that we can effectively marshal the combined capabilities of California — from state, regional, tribal, and local governments to industry to our research institutions, and most importantly, to the nearly 40 million Californians who will benefit from the actions laid out in the plan. It addresses the challenge of our generation by laying out a pathway and guideposts for action across three decades. But the Scoping Plan is only that: a plan. The hard work — and hopeful work — is putting its recommendations into action. And there is no time to waste.

Post-adoption of the Scoping Plan
As with previous Scoping Plans, CARB Board approval is the beginning of the next phase of climate action. Specifically, approval of this plan catalyzes a number of efforts, including the development of new regulations as well as amendments to strengthen regulations and programs already in place, not just at CARB but across state agencies. The unprecedented rate of transition will also require the identification and removal of market and implementation barriers to the production and deployment of clean technology and energy. All of these actions and more will be needed if we are to achieve our climate goals.
,
This page intentionally left blank
13 Chapter 1: Introduction
“The debate is over around climate change. Just come to the state of California.

Observe it with your own eyes.”
- California Governor Gavin Newsom in September 2020 after surveying the devastation caused by catastrophic wildfires
The impacts of climate change are no longer a distant threat on the horizon—they are right here, right now, with a growing intensity that is adversely affecting our communities and our environment, here in California and across the globe. The science that, decades ago, predicted the impacts we are currently experiencing is even stronger today and unambiguously tells us what we must do to limit irreversible damage: we must act with renewed commitment and focus to do more and do it sooner. That science is indisputable.

Unless we increase ambition, we will be faced with more fire, more drought, more temperature extremes, and deadly, choking air pollution. The future of our state—our communities, economy, and ecosystems—is inextricably tied to the way we respond in this decade and the partnerships we forge along the way.

The impacts of climate change fall most heavily on frontline communities that bear the brunt of extreme heat, drought, wildfires, and other effects. Low-income communities and communities of color are also disproportionately impacted by fossil fuel combustionrelated air pollution and related health problems. The continued phaseout of fossil fuel combustion will advance both climate and air quality goals and will deliver the greatest health benefits to the most impacted communities.

As it has responded to this climate crisis, California has established itself as a global leader in science-based, public health-focused climate change mitigation and air quality control. The California Legislature has worked with both Republican and Democratic governors to advance action on public health and environmental protections—and California has made progress on addressing climate change during periods of both Republican and Democratic federal administrations. Since the passage of Assembly Bill 32 (AB 32) (Núñez and Pavley, Chapter 488, Statutes of 2006), California has developed bold, creative, and durable policy solutions to protect our environment and public health, all while growing our economy. In fact, California met the target established in AB 32—a return of greenhouse gas (GHG) emissions to 1990 levels by 2020—years ahead of schedule, even as the state established itself as the one of the largest economies in the world. As Figure 1-1 below shows, California’s emissions and economic growth have continued to decouple, and California is now the fifth largest economy in the world. 14 Figure 1-1: California total and per capita GHG emissions25 Recognizing both California’s early successes in achieving GHG emissions reductions while growing the economy, as well as the worsening impacts of climate change, our governors and legislators have continued to enact ambitious goals. California’s unwavering commitment to address climate change is based on indisputable science and data. This commitment is also informed by our collective efforts to address environmental justice and advance racial equity, such that race will no longer be a predictor for disproportionate environmental burdens faced by low-income communities and communities of color. As the Office of Environmental Health Hazard Assessment’s 25 Due to the global pandemic, 2020 is an outlier year and should not be considered indicative of a trend; emissions are likely to increase as economies recover from the impacts of the pandemic. -50%
-30%
-10%
10%
30%
50%
70%
2000 2020
Percent change since 2000
Gross State Product (GSP)
Population
GHG Emissions
GHG Emissions per Capita
GHG Emissions per GSP
15 (OEHHA’s) recent analysis of race/ethnicity and air pollution vulnerability and CalEnviroScreen 4.0 scores demonstrate, much work remains to be done.26 Many of California’s environmental policies have served as models for similar policies in other U.S. states, and at national and international levels. Moving forward, California will continue its pursuit of collaborations and advocacy for action to address climate change at all levels of government. While California is responsible for just one percent of global GHG emissions, and we must do our part, we also play an important role in exporting both political will and technical solutions to address the climate crisis globally.

Today, we have a chance to re-envision California’s future and set the state on a path to be carbon neutral no later than 2045 while advancing equity, addressing environmental justice, and continuing to grow our economy. This Scoping Plan provides a roadmap outlining key policies we can implement to achieve our climate goals while improving the health and welfare of Californians and addressing disparities in health outcomes to create a more equitable future. It will enable us to turn the corner in our efforts to protect and preserve our critical natural and public resources, all while providing unparalleled opportunities for clean, pollution-free economic growth.

Severity of Climate Change Impacts
With the increasing severity and frequency of drought, wildfire, extreme heat, and other impacts, Californians just have to look out their windows to know that climate change is real and rapidly getting worse. The impacts we thought we would see in the decades to come are happening now. We must act decisively to both reduce our GHG emissions and build resilience to these impacts for ourselves, future generations, and our iconic landscapes.

Wildfires
Of the twenty largest wildfires ever recorded in California, nine occurred in 2020 and 2021.

The worst wildfire season in California’s recorded history was in 2018, with over 24,226 structures damaged or destroyed and over 100 lives lost. The largest wildfire season ever recorded in state history was in 2020, where more than 4.3 million acres burned, albeit at different intensity and with varying ecological impacts, and over 112 million metric tons of 26 OEHHA and CalEPA. 2021. Analysis of Race/Ethnicity and CalEnviroScreen 4.0 Scores. https://oehha.ca.gov/media/downloads/calenviroscreen/document/calenviroscreen40raceanalysisf2021.p df.
16 carbon dioxide (CO2) emitted into the atmosphere.27 The economic damage of these fires was estimated to be over $10 billion in property damage and over $2 billion in fire suppression costs.28 The Camp Fire, which destroyed much of Paradise, California, was the world’s costliest natural disaster in 2018, with overall damages of $16.5 billion.29 It was also the deadliest fire in California history, with 85 civilian fatalities. Wildfires have always been part of California’s natural ecology and will continue to be. However, changes to the state’s climate and precipitation expands the footprint of wildfire threat, severity, and intensity, with one quarter of California—more than 25 million acres—now classified as being under very high or extreme fire threat.30 The impacts of wildfire smoke have been linked to respiratory infections, cardiac arrests, low birth weight, mental health conditions, and exacerbated asthma and chronic obstructive pulmonary disease.31 In 2020, with all of California covered by wildfire smoke for over 45 days—and 36 counties for at least 90 days—maximum fine particulate (PM2.5) levels persisted in the “hazardous” range of the Air Quality Index for weeks in several areas of the state.32,33
Catastrophic wildfire damages extend beyond human health and the economy. The Castle Fire in 2020 and the KNP Complex and Windy Fires in 2021 led to the loss of an unprecedented number of giant sequoias: an estimated 13 to 19 percent of the giant 27 CARB. 2020. Public Comment Draft Greenhouse Gas Emissions of Contemporary Wildfire, Prescribed Fire, and Forest Management Activities.
https://ww3.arb.ca.gov/cc/inventory/pubs/ca ghg wildfire forestmanagement.pdf. 28 News18. 2021. San Francisco Bay Area Receives its First Wildfire Warning of 2021, After California Concludes its Driest Year. https://www.news18.com/news/buzz/san-francisco-bay-area-receives-its-firstwildfire-warning-of-2021-after-california-concludes-its-driest-year-3722897.html. 29 Munich RE. 2019. Extreme Storms, Wildfires and Droughts Cause Heavy Nat Cat Losses In 2018. https://www.munichre.com/en/company/media-relations/media-information-and-corporate-news/mediainformation/2019/2019-01-08-extreme-storms-wildfires-and-droughts-cause-heavy-nat-cat-losses-in2018.html#-1808457171. 30 CARB. No date. Wildfires. https://ww2.arb.ca.gov/our-work/programs/wildfires/about. 31 Reid, C. E., M. Brauer, F. H. Johnston, M. Jerrett, J. R. Balmes, and C. T. Elliott. 2016. “Critical Review of Health Impacts of Wildfire Smoke Exposure.” Environmental Health Perspectives http://dx.doi.org/10.1289/ehp.1409277. 32 Vargo J. A. 2020 (updated in 2021 using the NOAA Hazard Mapping System). “Time Series of Potential US Wildland Fire Smoke Exposures.” Frontiers in Public Health https://doi.org/10.3389/fpubh.2020.00126. 33 CalFire. 2020 Fire Siege Report. https://www.fire.ca.gov/media/hsviuuv3/cal-fire-2020-fire-siege.pdf. 17 sequoia population in the Sierra Nevada. An iconic species, giant sequoias are the largest trees on earth, with exceptional longevity outside of climate extremes.34,35 It is clear that we must take drastic measures to prepare for future wildfires, which is why California invested $2.7 billion in wildfire resilience from fiscal years 2020 to 2023. The exponential increase in funding launched more than 552 wildfire resilience projects in less than a year, and CAL FIRE met its 2025 goal of treating 100,000 acres a full three years ahead of schedule. Since Fiscal Year 2019–20, treatment work has significantly increased, and CAL FIRE has averaged 100,000 acres treated each fiscal year.

Although we are making progress, we have a lot more work to do in order to achieve our goal of treating one million acres annually by 2025. The Governor’s Wildfire and Forest Resilience Strategy details 99 actions needed to address the key drivers of catastrophic wildfires, ramp up the pace and scale of forest management, and make threatened communities more resilient to catastrophic fires. It is also important to note that natural wildfire cycles are a part of a sustainable forest ecosystem and will continue to play a role in a healthy forests’ future. We should not expect wildfires to cease, but we must manage our lands to address catastrophic wildfires that result from buildup of carbon stocks due to our interventions to suppress wildfires and from climate change resulting from fossil fuel combustion.

Drought
Drought is a recurring feature of the California climate that has been intensified by increasingly warmer average temperatures. Anthropogenic climate trends have exacerbated drought conditions; human-caused climate change accounts for 19 percent of drought severity and 42 percent of the soil moisture deficit in this region since 2000.

The governor declared a drought state of emergency in October 2021, and as of September 2022, 94 percent of California was in severe drought, and 99.8 percent36 of the state was in at least moderate drought. The first three months of 2022 were the driest January, February, and March on record in California.37 The harsh drought conditions affecting California are part of a larger megadrought—a drought lasting more than two 34 Shive, K., C. Brigham, T. Caprio, and P. Hardwick. 2021. 2021 Fire Season Impacts to Giant Sequoias.

The Nature Conservancy and National Park Service. https://www.nps.gov/articles/000/2021-fire-seasonimpacts-to-giant-sequoias.htm. 35 Shive, K. L., A. Wuenschel, L. J. Hardlund, S. Morris, M. D. Meyer, and S. M. Hood. 2022. “Ancient Trees and Modern Wildfires: Declining Resilience to Wildfire in the Highly Fire-adapted Giant Sequoia.” Forest Ecology and Management 511, 120110. https://doi.org/10.1016/j.foreco.2022.120110. 36 Drought.gov. California. National Oceanic and Atmospheric Administration (NOAA) and the National Integrated Drought Information System. https://www.drought.gov/states/california. 37 Drought.ca.gov. September 26, 2022. California Drought Update. https://drought.ca.gov/media/2022/09/Weekly-CA-Drought-Update-09262022-FINAL.pdf. 18 decades—that has been ongoing in the Southwestern region of North America since 2000. The past 22 years have been the region’s driest period since at least 800 CE.38 While large urban water districts with diversified sources of water supply have maintained water deliveries to customers through the drought, hundreds of individual well owners and some small water systems have suffered disruption. The state is providing funding for water system consolidation and modernization projects in small communities, emergency repairs and replacements for dry wells, and bottled and hauled water deliveries. A 2021 law requires small suppliers to create drought contingency plans.

During the drought of the last three years the state has delivered emergency drinking water assistance to nearly 10,000 households and 150 water systems.

California agriculture is responsible for more than half of all U.S. domestic fruit and vegetable production, and in 2021 drought resulted in the fallowing of nearly 400,000 acres of fields.39 Direct crop revenue losses were approximately $962 million, and total economic impacts were more than $1.7 billion, with over 14,000 full- and parttime job losses.40 During the 2011–2017 drought, California’s agricultural industry suffered at least $5 billion in losses.41 The 2022–23 budget includes $100 million to support agricultural water conservation practices, provide on-farm technical assistance, and provide direct relief to small farm operators.

Though native California species are adapted to drought, human engineering has altered most streams and wetlands in the state, making drought increasingly stressful to fish and wildlife. The state has conducted hundreds of fish and amphibian rescues in this drought to move creatures from diminished habitat, upgraded hatcheries, and boosted hatchery production, and has hauled millions of young hatchery salmon to San Francisco Bay to avoid adverse river conditions. State biologists monitor dozens of streams statewide and have negotiated voluntary agreements with landowners and water users to improve stream flows and temperatures.

California has started to implement major policies to build resilience to combat drought— such as the Sustainable Groundwater Management Act of 2014, the governor’s Water Resilience Portfolio (2020), the governor’s Water and Supply Strategy (August 2022), and 38 Williams, A. P., B. I. Cook, and J. E. Smerdon. 2022. “Rapid Intensification of The Emerging Southwestern North American Megadrought in 2020–2021.” Nature Climate Change https://doi.org/10.1038/s41558-022-01290-z. 39 Medellín-Azuara, J. 2022. Economic Impacts of the 2021 Drought on California Agriculture. University of California Merced. https://wsm.ucmerced.edu/wp-content/uploads/2022/02/2021-Drought-ImpactAssessment_20210224.pdf. 40 Medellín-Azuara. Economic Impacts of the 2021 Drought. 41 National Resources Defense Council (NRDC). 2019. Climate Change and Health in California. Issue Brief. https://www.nrdc.org/sites/default/files/climate-change-health-impacts-california-ib.pdf. 19 new standards for indoor, outdoor, and industrial water use. However, it is crucial that we take further actions to minimize the impacts of drought in the years to come.

Extreme Heat
California’s hottest summer on record was 2021.42 Death Valley recorded the world’s highest reliably measured temperature (130°F) in July 2021, breaking its own record (129°F) from summer 2020.43 Meanwhile, Fresno also broke one of its own records, with 64 days over 100°F in 2021.44 This is part of a trend: the daily maximum average temperature, an indicator of extreme temperature shifts, is expected to rise 4.4°F–5.8°F by 2050 and 5.6°F–8.8°F by 2100.45 Heat waves that result in public health impacts are also projected to worsen throughout the state. By 2050, these heat-related health events are projected to last two weeks longer in the Central Valley and occur four to ten times more often in the Northern Sierra region.46
Heat ranks among the deadliest of all climate hazards in California, and heat waves in cities are projected to cause two to three times more heat-related deaths by midcentury.47 Climate vulnerable communities48 will experience the worst of these effects, as heat risk is associated and correlated with physical, social, political, and economic factors.

Aging populations, infants and children, pregnant people, and people with chronic illness are especially sensitive to heat exposure.49,50 Combining these characteristics and existing health inequities with additional factors such as poverty, linguistic isolation, 42 NOAA. 2022. Climate at a Glance. https://www.ncdc.noaa.gov/cag/statewide/timeseries/4/tavg/3/8/1895-2021?base prd=true&firstbaseyear=1901&lastbaseyear=2000. 43 Masters, J. 2021. Death Valley, California, breaks the all-time world heat record for the second year in a row. Yale Climate Connections. https://yaleclimateconnections.org/2021/07/death-valley-californiabreaks-the-all-time-world-heat-record-for-the-second-year-in-a-row/. 44 NOAA. Climate Data Online Search. Accessed on 16 March 2022. https://www.ncdc.noaa.gov/cdoweb/search. 45 Governor’s Office of Planning and Research (OPR), CEC, and CNRA. 2018. California’s Fourth Climate Change Assessment. Page 23. https://www.energy.ca.gov/sites/default/files/2019-11/Statewide ReportsSUM-CCCA4-2018-013 Statewide Summary Report ADA.pdf. 46 OPR, CEC, and CNRA. California’s Fourth Climate Change Assessment - Statewide Summary Report. https://www.energy.ca.gov/sites/default/files/2019-11/Statewide Reports-SUM-CCCA4-2018- 013 Statewide Summary Report ADA.pdf. 47 Ostro, B., S. Rauch, and S. Green. 2011. “Quantifying the health impacts of future changes in temperature in California.” National Library of Medicine. https://pubmed.ncbi.nlm.nih.gov/21975126/. 48 CARB. Priority Populations. California Climate Investments. https://www.caclimateinvestments.ca.gov/priority-populations. 49 Basu, R. 2009. “High Ambient Temperature and Mortality: A Review of Epidemiologic Studies from 2001 to 2008.” National Library of Medicine. https://pubmed.ncbi.nlm.nih.gov/19758453/. 50 Basu, R., and B. Malig. 2011. “High Ambient Temperature and Mortality in California: Exploring the Roles of Age, Disease, and Mortality Displacement.” National Library of Medicine. https://pubmed.ncbi.nlm.nih.gov/21981982/.
20 housing insecurity, and the legacy of racist redlining practices, can put individuals at a disproportionately high risk of heat-related illness and death.51,52 Rising temperatures will also speed up smog-forming chemical reactions, leading to worse asthma, reduced lung function, cardiac arrest, and cognitive decline. African American, American Indian/Alaskan Native, and Puerto Rican Californians are particularly sensitive to smog, as they are between 28.6 and 132.5 percent more likely to be diagnosed with asthma than white Californians.53
In addition to the dangers to public health, California’s September 2022 heat wave is particularly illustrative of how more frequent extreme heat strains the state’s infrastructure we depend on to adapt to a changing climate. For example, as all-time high temperature records were broken in Sacramento, San Jose, Santa Rosa and Fairfield, electricity demand for air conditioning threatened to overwhelm the state power supply.54 California has taken major steps to protect communities from the impacts of extreme heat.

Our recent budgets invest $800 million to cool our schools and neighborhoods, including projects to reduce urban overheating. The Extreme Heat Action Plan, released in April 2022, outlines the all-of-government approach California is taking to reduce urgent risks and build long-term resilience to the impacts of extreme heat. In September 2022, Governor Newsom signed multiple bills addressing extreme heat, including AB 2238 (Rivas, Chapter 264, Statutes of 2022), which will create the nation’s first extreme heat advance warning and ranking system to better prepare communities ahead of heat waves. The Administration is committed to addressing extreme heat, but we still have a lot of work to do.

Wildfires, drought, and extreme heat are some of the most pronounced climate impacts California is experiencing, but they are not the only ones. Sea level rise, rising ocean temperatures, ocean acidification, and inland flooding are also already having devastating impacts on our communities, ecosystems, and economy, and will continue to do so in the years and decades to come. The decisions and actions that we take today will determine how strongly we will feel the impacts of climate change in the future. 51 Hoffman, J. S., V. Shandas, and N. Pendleton. 2020. “The Effects of Historical Housing Policies on Resident Exposure to Intra-Urban Heat: A Study of 108 US Urban Areas.” MDPI. https://www.mdpi.com/2225-1154/8/1/12/htm. 52 U.S. Climate Resilience Toolkit. No date. Heat and Social Inequity in the United States. https://toolkit.climate.gov/tool/heat-and-social-inequity-united-states. 53 NRDC. 2019. Climate Change and Health. Issue Brief. https://www.nrdc.org/sites/default/files/climatechange-health-impacts-california-ib.pdf. 54 Samenow, Jason. 2022. No September on record in the West has seen a heat wave like this. The Washington Post. September 9. https://www.washingtonpost.com/climateenvironment/2022/09/08/western-heatwave-records-california-climate/. 21 Imperative To Act
Consequences of Further Warming
The Intergovernmental Panel on Climate Change (IPCC) Sixth Assessment Report (AR6) found that it will not be possible to keep global warming within the threshold of 1.5oC to avoid the most severe impacts of climate change unless we make immediate and largescale reductions in GHG emissions. It finds that atmospheric concentrations of CO2 have increased by 50 percent since the industrial revolution, and that they continue to increase at a rate of two parts per million each year.55 Without immediate action, the world will exceed 1.5oC (or 2.7oF) warming by the 2030s, and no later than 2040.

While every tenth of a degree matters—every incremental increase in warming brings additional negative impacts—climate-related risks to human health, livelihoods, and biodiversity are projected to increase further under 2oC (or 3.6oF) warming, compared to

1.5oC.56 To remain below 1.5oC with limited or no overshoot of that threshold, global net anthropogenic CO2 emissions need to be cut by about half by 2030 and reach net-zero by 2050.

If we fail to make rapid changes, we may not be able to limit global warming to 2oC,57 and the consequences of inaction would be catastrophic. Our planet is already 1.2oC warmer than pre-industrial times due to human-induced warming, and many impacts we are already experiencing, such as sea level rise, are “irreversible” for centuries to millennia.58 Californians with the fewest resources, who are disproportionately low-income communities and communities of color, are the most vulnerable to the impacts of climate change. While the human costs associated with health impacts can never be fully monetized, a recent report finds that the health costs of climate and air pollution in the U.S. are well over $800 billion today and will continue to grow in the coming years.59 55 IPCC. 2021. Climate Change 2021: The Physical Science Basis. https://www.ipcc.ch/report/ar6/wg1/. 56 IPCC. 2018. Special Report: Global Warming of 1.5°C. World Meteorological Organization. https://www.ipcc.ch/sr15/. 57 IPCC. 2021. Summary for Policymakers. In: Climate Change 2021: The Physical Science Basis.

Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte, V., P. Zhai, A. Pirani, S. L. Connors, C. Péan, S. Berger, N. Caud, Y.

Chen, L. Goldfarb, M. I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J. B. R. Matthews, T. K. Maycock, T.

Waterfield, O. Yelekçi, R. Yu, and B. Zhou (eds.)]. In Press. https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC AR6 WGI SPM final.pdf. 58 United Nations. 2021. IPCC report: ‘Code red.’ https://news.un.org/en/story/2021/08/1097362#:~:text=%27Code%20red%20for%20humanity%27&text= We%20are%20at%20imminent%20risk,%2C%20to%20keep%201.5%20alive.%22. 59 Alwis, D. D., and V. S. Limaye. No date. The Costs of Inaction. https://www.nrdc.org/sites/default/files/costs-inaction-burden-health-report.pdf. 22 Any delays in action or insufficient action are a threat to public health and the environment. The impacts to our economy would be devastating as well. While not specific to California, a 2022 report from Deloitte Economics Institute finds that failing to take sufficient action to reduce emissions could result in economic losses to the U.S. of more than $14.5 trillion over the next 50 years.60 On a hopeful note, however, the report finds that if the country invests now and in the coming years in a net-zero economy, $3 trillion could be added to the economy over the next 50 years. The U.S. annual gross domestic product (GDP) would be 2.5 percent higher in 2070 in this fast-action scenario than in the delayed action scenario. The lessons for California from these analyses are clear: invest now or pay the price later. As shown in Figure 1-2, inaction can lead to negative consequences for individuals, communities, the economy, and society as a whole. As discussed later, Governor Newsom and the Legislature have accepted this imperative and made significant investments in climate action. This Scoping Plan combined with the historic investments and policy direction from the governor and Legislature, will result in unprecedented action to address the climate crisis. 60 Deloitte. 2022. The Turning Point.
https://www2.deloitte.com/content/dam/Deloitte/us/Documents/about-deloitte/us-the-turning-point-a-neweconomic-climate-in-the-united-states-january2022.pdf?id=us:2el:3dp:wsjspon:awa:WSJSBJ:2021:WSJFY22. 23 Figure 1-2: The real costs of inaction61
Scoping Plan Overview
Previous Scoping Plans
The Scoping Plan is a strategy the California Air Resources Board (CARB) develops and updates at least one every five years, as required by AB 32. It lays out the transformations needed across our society and economy to reduce emissions and reach our climate targets. This Scoping Plan is the third update to the original plan that was adopted in 2008. The initial Scoping Plan laid out a path to achieve the AB 32 2020 limit of returning to 1990 levels of GHG emissions, a reduction of approximately 15 percent below business as usual.62 The 2008 Scoping Plan included a mix of incentives, regulations, and carbon pricing, laying out the portfolio approach to addressing climate change and clearly making the case for using multiple tools to meet California’s GHG targets. The 2013 Scoping Plan assessed progress toward achieving the 2020 limit and made the case for addressing 61 Katowice, P. 2018. Health benefits far outweigh the costs of meeting climate change goals. WHO. https://www.who.int/news/item/05-12-2018-health-benefits-far-outweigh-the-costs-of-meeting-climatechange-goals. 62 CARB. 2008. Climate Change Scoping Plan. https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/document/adopted scoping plan.pdf. 24 short-lived climate pollutants (SLCPs).63 The most recent update, the 2017 Scoping Plan,64 also assessed the progress toward achieving the 2020 limit and provided a technologically feasible and cost-effective path to achieving the Senate Bill 32 (SB 32, Pavley, Chapter 249, Statutes of 2016) target of reducing GHGs by at least 40 percent below 1990 levels by 2030.

Overview of this Scoping Plan
It is paramount that we continue to build on California’s success by taking effective actions and doubling down on implementation of the strategies outlined here. As such, this Scoping Plan builds on and integrates efforts already underway to reduce the state’s GHG, criteria pollutant, and toxic air contaminant emissions by identifying the clean technologies and fuels that should be phased in as the state transitions away from combustion of fossil fuels. By selecting and pursuing a sustainable and clean economic path, the state will continue to successfully execute existing programs, work to eliminate air pollution inequities, demonstrate the coupling of economic growth and environmental progress, and enhance new opportunities for engagement within the state to address and prepare for climate change.

The 2022 Scoping Plan for Achieving Carbon Neutrality (Scoping Plan) is the most comprehensive and far-reaching Scoping Plan developed to date. It identifies a technologically feasible and cost-effective path to achieve carbon neutrality by 2045 while also assessing the progress California is making toward reducing its GHG emissions by at least 40 percent below 1990 levels by 2030, as called for in SB 32 and laid out in the 2017 Scoping Plan.65 The 2030 target is an interim but important stepping stone along the critical path to the broader goal of deep decarbonization by 2045. Modeling for this Scoping Plan shows that this decade must be one of transformation on a scale never seen before to set us up for success in 2045.

The relatively longer path assessed in this Scoping Plan incorporates, coordinates, and leverages many existing and ongoing efforts to reduce GHGs and air pollution, while identifying new clean technologies and energy. Given the focus on carbon neutrality, this Scoping Plan also includes discussion for the first time of the Natural and Working Lands (NWL) sectors as both sources of emissions and carbon sinks. Chapter 2 of this document 63 CARB. 2014. First Update to the Climate Change Scoping Plan. https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/2013_update/first_update_climate_chang e_scoping_plan.pdf. 64 CARB. 2017. California’s 2017 Climate Change Scoping Plan. https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping plan 2017.pdf. 65 CARB. 2017. California’s 2017 Climate Change Scoping Plan. https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping plan 2017.pdf. 25 includes a description of a suite of specific actions to drastically reduce GHGs across all sectors. Chapter 3 provides the air quality and economic evaluations of the actions.

Chapter 4 provides a broader description of the many actions needed across all sectors to achieve carbon neutrality. Chapter 5 provides an overview of the next steps and partnerships needed to implement this Scoping Plan. Guided by legislative direction, the actions identified in this Scoping Plan reduce overall GHG emissions in California and deliver policy signals that will continue to drive investment and certainty in a low carbon economy. This Scoping Plan builds upon the successful framework established by the Initial Scoping Plan and subsequent updates while identifying new, technologically feasible, and cost-effective strategies.

Principles That Inform Our Approach to Addressing the
Climate Challenge
California has decades of experience addressing the climate challenge. Through this experience, and based on extensive engagement with stakeholders through our regulatory and program development processes, we have developed a set of principles to inform our approach.

Unprecedented Investments in a Sustainable Future
The scale of transformation needed over this decade to avoid the worst impacts of climate change and meet our ambitious climate goals is extraordinary. This is why Governor Newsom and the Legislature invested over $15 billion in climate action through the 2021– 2022 California Comeback Plan, and why the 2022–2023 budget marks the beginning of the California Climate Commitment—the governor’s multi-year plan to invest $54 billion in climate action. The enacted budgets (Figure 1-3) and the California Climate Commitment represent investments of a historic scale and will advance precisely the type of all-of-government approaches necessary to create the whole-of-society changes described in this Scoping Plan that will enable us to avert the worst impacts of climate change.
26 Figure 1-3: Comprehensive California climate change investments The California Climate Commitment includes the following game-changing elements:
• $10 billion for zero-emission vehicles (ZEVs), including $1.5 billion for electric school buses to protect students’ health and $3 billion to build an accessible charging network. ZEV investments will particularly focus on programs such as heavy-duty vehicle and port electrification that will reduce emissions and protect public health in low-income communities.
• $2.1 billion for clean energy investments, such as long duration storage, offshore wind, green hydrogen,66 and industrial decarbonization. • $13.8 billion for programs that reduce emissions from the transportation sector, such as improving public transportation while also funding walking, biking, and adaptation projects.
• Over $720 million for California’s higher education institutions and research that will support the next generation of climate innovations. 66 For the purposes of this Scoping Plan, “renewable hydrogen” and “green hydrogen” are interchangeable and are not limited to only electrolytic hydrogen produced from renewables. 27 • Nearly $1 billion to build sustainable, affordable housing and over $1 billion to help low-income Californians realize energy cost savings through building decarbonization.
• Nearly $9 billion for wildfire risk reduction, drought mitigation, extreme heat resilience, and nature-based solutions.

These investments are incredibly important in the context of this Scoping Plan in that they accompany and help support implementation of the many policies and regulations that will continue to be necessary to achieve our 2030 and carbon neutrality targets. In addition, these incentive programs jump-start emission reduction strategies for priority sectors, sources, and technologies, leveraging private-sector investment and building sustainable, growing markets for clean and efficient technologies. Many of California’s incentive programs work in concert with federal and other state programs to drive emission reductions. As an example, as California pushes to move to 100% sales of new zero emission-vehicles, including plug-in hybrid vehicles, the Newsom Administration continues to invest heavily in incentive programs that allow families, communities, and businesses to choose zero-emission vehicles. This is done while simultaneously working with the federal government, other states, and jurisdictions around the world to align policies, regulations, and incentives, creating market certainty for the automakers that serve our markets.

Centering Equity
Prioritizing equity is just as important as the magnitude of the climate investments California is making. Addressing climate change and advancing our equity and economic opportunity goals cannot be decoupled. In line with the governor’s Executive Order67 to take additional actions to embed equity analysis and considerations, this plan works to center equity by addressing disparities for historically underserved and marginalized communities. California strives to ensure that our climate and air research, regulations, investments, and plans include provisions that specifically address and advance equity.

This includes reducing and eliminating air pollution disparities, removing barriers that can prevent frontline communities from accessing benefits, lowering costs for low-income Californians, and promoting high-quality jobs. CARB’s incentive programs regularly surpass their mandated equity targets, and CARB has incorporated equity-focused provisions in our research, planning, and regulatory efforts. For instance, statute requires that a minimum of 35 percent of California Climate Investments benefit low-income households along with disadvantaged and low-income communities (referred to as priority 67 Executive Department. State of California. 2022. Executive Order N-16-22. GSS 9320 2- 20220912152941 (ca.gov).
28 populations). However, 48 percent—over $5.4 billion—of implemented California Climate Investments project funding is benefiting priority populations, greatly exceeding the statutory minimums (see Figure 1-4). Senate Bill 535 (De León, Chapter 830, Statutes of 2012) and AB 1550 (Gomez, Chapter 369, Statutes of 2016) direct state and local agencies to make significant investments using auction proceeds to assist California’s most vulnerable communities. Under these laws, a minimum of 25 percent of the total investments are required to be located within and provide benefits to disadvantaged communities, and at least 10 percent of the total investments must benefit low-income communities and households. Moving forward, the state will continue to devote a greater share of incentive funding to priority populations, with the light-duty vehicle incentive program as just one example. We can simultaneously confront the climate crisis and build a more resilient, just, and equitable future for all communities. 29 Figure 1-4: California climate investments cumulative outcomes68,69 Role of the Environmental Justice Advisory Committee
To inform the development of the Scoping Plan, AB 32 calls for the convening of an Environmental Justice Advisory Committee (EJ Advisory Committee) to advise CARB in developing the Scoping Plan, and any other pertinent matter in implementing AB 32. It requires that the Committee be comprised of representatives from communities with the most significant exposure to air pollution, including communities with minority populations and/or low-income populations. On January 25, 2007, CARB appointed the first 68 CARB. 2022. California Climate Investments program implements $10.5 billion in greenhouse gasreducing programs, expected to reduce 76 million metric tons of emissions. April 11. https://ww2.arb.ca.gov/news/california-climate-investments-program-implements-105-billion-greenhousegas-reducing-projects. 69 SB 535 and AB 1550 require investments located in and benefiting low-income communities and households, which are termed priority populations. Disadvantaged communities are currently defined by CalEPA as the top 25 percent of communities experiencing disproportionate amounts of pollution, environmental degradation, and socioeconomic and public health conditions according to the Office of Environmental Health Hazard Assessment’s CalEnviroScreen tool, plus certain additional communities including federally recognized Tribal Lands. Low-income communities and households are defined by statute as those with incomes either at or below 80 percent of the statewide median or below a threshold designated as low-income by the Department of Housing and Community Development. 30 Environmental Justice Advisory Committee to advise it on the Initial Scoping Plan and other climate change programs.

For this Scoping Plan, CARB reconvened the EJ Advisory Committee in May 2021. The committee is currently comprised of 14 environmental justice and disadvantaged community representatives, including the EJ Advisory Committee’s first tribal representative, who was appointed in February 2022. In October 2021, the EJ Advisory Committee formally created eight workgroups. These workgroups are a space for EJ Advisory Committee members to better understand specific sectors of the Scoping Plan and to assist the EJ Advisory Committee in the development of recommendations on this Scoping Plan. In December 2021, the EJ Advisory Committee provided scenario input responses to help shape the modeling for this Scoping Plan. In February 2022, San Joaquin Valley EJ Advisory Committee members hosted their first community workshop, with over 100 attendees. In March 2022, the CARB Board held a joint public meeting with the EJ Advisory Committee to discuss their draft preliminary recommendations for this Scoping Plan. In June 2022, over 165 attendees participated in a statewide community workshop held by EJ Advisory Committee members. The full schedule of EJ Advisory Committee Meetings and meeting materials are available on CARB’s website.70 This Scoping Plan includes references where EJ Advisory Committee Final Recommendations71 are included in the document. The final recommendations were discussed at a joint CARB and EJ Advisory Committee Hearing on September 1, 2022.

The integration of environmental justice is critical to ensure that certain communities are not left behind. The AB 32 EJ Advisory Committee provided recommendations on September 30 in advance of the final Scoping Plan. There are footnotes to indicate where there is alignment between the AB 32 EJ Advisory Committee’s recommendations and this Scoping Plan. While the language in the text may not fully incorporate the specific EJ Advisory Committee’s recommendation, the footnotes do acknowledge the places in the text where there is general alignment with the spirit of the EJ Advisory Committee’s recommendation.

Partnering with Tribes
70 CARB. Environmental Justice Advisory Committee Meetings and Events. https://ww2.arb.ca.gov/environmental-justice-advisory-committee-meetings-and-events. 71 Environmental Justice Advisory Committee. September 30, 2022. 2022 Scoping Plan Recommendations.
https://ww2.arb.ca.gov/sites/default/files/barcu/board/books/2022/090122/finalejacrecs.pdf. 31 There are 109 federally recognized tribes and over 60 non-federally recognized tribes in California. 72 In 2011, Governor Brown issued Executive Order B-10-11, recognizing and reaffirming the inherent right of tribes to exercise sovereign authority over their members and territory and directing state agencies to engage in government-to-government consultation with tribe and to work to develop partnerships and consensus. 73 In 2019,
Governor Newsom issued Executive Order N-15-19, which acknowledges and apologizes on behalf of the state for the historical “violence, exploitation, dispossession and the attempted destruction of tribal communities.”74 Establishing partnerships with tribal leaders to incorporate their priorities, traditional expertise, and knowledge will be important to achieving California’s climate goals. The Scoping Plan includes actions that tribal partners can voluntarily implement for sources under their jurisdiction (e.g., transitioning to zero emission fleets, installing infrastructure and control technologies, conducting climate smart land management). The Scoping Plan also uplifts the importance of having our tribal partners help guide actions that may impact tribal cultural resources and of benefitting from tribal input.

We also need alignment between state and local partners and tribes on actions related to land-use decisions. This means respecting and reinforcing tribal sovereignty and selfdetermination. As tribes do not always draw clear lines between the “natural” and “cultural” resources of a place, taking a holistic perspective will result in positive impacts in ability to address the complex issues of land management and regulatory undertakings.

Tribes have an intimate and historical knowledge of places and should be engaged early on to inform planning and future management related to activities that may impact tribal resources and areas including potential funding opportunities, technical assistance, and capacity building, where appropriate. Additionally, tribes should be involved in the identification of their own significant resources and areas of use. As decisions are made related to Scoping Plan undertakings, agencies should recognize and appropriately consider cultural resources and management from the beginning, not as an afterthought; and consider how the project could impact tribes.
72 These numbers are subject to change depending on determinations made by the Bureau of Indian Affairs (BIA) and the Native American Heritage Commission (NAHC). Please consult the most current Federal Register for a list of federally recognized tribes and the NAHC for a list of non-federally recognized tribes in California. As of the date of the Scoping Plan, the current list for federally recognized tribes is located at 87 Fed. Reg. 4636 (Jan. 28, 2022). 73 Executive Order B-10-11. https://www.ca.gov/archive/gov39/2011/09/19/news17223/index.html#:~:text=EXECUTIVE%20ORDER% 20B-10-
11%20Published%3A%20Sep%2019%2C%202011%20WHEREAS,and%20affirmed%20in%20state%20 and%20federal%20law%3B%20and. 74 Executive Order N-15-19. https://tribalaffairs.ca.gov/wp-content/uploads/sites/10/2020/02/ExecutiveOrder-N-15-19.pdf. 32 Finally, to the extent allowed by law, traditional ecological knowledge and culturally sensitive information should be protected, as this is information that may not be common knowledge and may not be known outside the tribe, as each tribe is unique and influenced by its local environment and cultural practices. Protection of this information will help foster productive relationships with tribes and should be included as part of the process.

CARB and other agencies should continue to foster relationships with tribal partners.

Maximizing Air Quality and Health Benefits
The state has over 50 years of experience successfully cleaning the air in California by addressing criteria pollutants and toxic air contaminants from mobile and stationary sources. CARB has been a leader in measuring, evaluating, and reducing sources of air pollution that impact public health. Its air pollution programs have been adapted for national programs and emulated in other countries. Significant progress has been made in reducing diesel particulate matter (PM), which is a designated toxic air contaminant, and many other hazardous air pollutants. CARB partners with local air districts to address stationary source emissions and adopts and implements state-level regulations to address sources of criteria and toxic air pollution, including mobile sources. CARB also collaborates with federal agencies to address air pollution from sources primarily under federal jurisdiction. In many instances, actions to reduce fossil fuel combustion and achieve federal air quality standards also help to reduce GHG emissions.

However, air pollution disparities still exist, and more must be done to ensure the most vulnerable populations have safe air to breathe. California must continue to evaluate opportunities to harmonize our climate and air quality programs through innovative policymaking and by building on existing programs like the Low Carbon Fuel Standard (LCFS) and Community Air Protection Program. The LCFS includes a provision that allows electric utilities to opt-in and generate residential electric vehicle (EV) charging credits, where some of the revenues are invested back into rebate programs that address air quality and climate pollution.75 The Community Air Protection Program76 is the first of its kind in the country and brings together diverse stakeholders, including CARB, local air districts, and residents of environmental justice communities to increase local air monitoring and develop community-led plans to improve air quality in the communities most impacted by air pollution.

This Scoping Plan identifies actions that will deliver near-term air quality benefits to communities with the highest exposures and provide long-term GHG benefits. Many of the actions in this Scoping Plan are key elements of the 2022 State Strategy for the State 75 CARB. LCFS Utility Rebate Programs. https://ww2.arb.ca.gov/resources/documents/lcfs-utility-rebateprograms. 76 CARB. Community Air Protection Program. https://ww2.arb.ca.gov/capp. 33 Implementation Plan to meet federal air quality standards,77 which has a primary focus of reducing harmful air pollution and achieving federal air quality targets. California’s approach of leveraging air quality and GHG policies together has yielded results. A 2022 report by the Office of Environmental Health and Hazard Assessment (OEHHA)78 that evaluated GHG and harmful air pollution emissions from the heavy-duty vehicle (HDV) and large stationary source sectors found declines in emissions in both sectors, with the greatest declines in disadvantaged communities. Both sectors are subject to state GHG and air quality policies, in addition to federal and local rules on harmful air pollution.

Because of historically racist and discriminatory practices such as redlining, both types of sources are disproportionately located adjacent to vulnerable communities, which are predominantly communities of color.
79 The key findings from the OEHHA report are as
follows:
• Both HDVs and facilities subject to the Cap-and-Trade Program have reduced emissions of co-pollutants, with HDVs showing a clearer downward trend when compared to stationary sources. These emission reductions have major health benefits, including a reduction in premature pollution-related deaths. • The greatest beneficiaries of reduced emissions from both HDVs and facilities subject to the Cap-and-Trade Program have been in communities of color and in disadvantaged communities in California, as identified by CalEnviroScreen (CES).

This has reduced the emission gap between disadvantaged and nondisadvantaged communities, but a wide gap still remains. • The transition to zero-emission HDVs will expedite further emissions reductions. • While the progress observed is encouraging, inequities persist, and federal, state, and local climate and air quality programs must do more to reduce emissions of GHGs and co-pollutants to reduce the burden of emissions on disadvantaged communities and communities of color.

It will take all tools at all levels of government, with robust enforcement, to ensure that vulnerable communities continue to see improvements in air quality until no disparities exist in air pollution across the state.
77 CARB. 2022 State Strategy for the State Implementation Plan. https://ww2.arb.ca.gov/resources/documents/2022-state-strategy-state-implementation-plan-2022-statesip-strategy. 78 OEHHA. 2022. Impacts of Greenhouse Gas Emission Limits within Disadvantaged Communities:

Progress Toward Reducing Inequities. https://oehha.ca.gov/environmental-justice/report/ab32-benefits. 79 CalEPA. 2021. Pollution and Prejudice. https://storymaps.arcgis.com/stories/f167b251809c43778a2f9f040f43d2f5. 34 Economic Resilience
The state’s efforts to tackle the climate crisis will create economic and workforce development opportunities in the clean energy economy in communities across the state.

Transitioning existing skills and expanding workforce training opportunities in climaterelated fields are critical for reducing harmful emissions and supporting workers in transitioning to new, high-quality jobs. The Administration’s recent budgets acknowledge the challenges facing workers in industries most affected by the state’s response to climate change—especially those in the fossil fuel industry. It will invest $1 billion in regional partnerships and economic diversification to create new jobs and support a local tax base and workforce transition and development once opportunities are identified. It also will invest in safety nets to protect, and support impacted communities as part of the transition to a carbon neutral economy. Specifically, the Community Economic Resilience Fund Program80 (CERF) supports communities and regional groups in producing regional roadmaps for economic recovery and transition that prioritize the creation of accessible, high-quality jobs in sustainable industries. The budget investments create the opportunity to future-proof and increase economic resilience in the face of more frequent climate impacts and shifting economic conditions. For these investments and implementation of the Scoping Plan to be successful in supporting the transition to a carbon neutral economy, workers and affected communities must be included in ongoing dialogue to ensure a high-road transition for regional economies.

That state also recognizes it can play a more direct role in supporting a sustainable work force through its incentive programs. In 2021, Assembly Bill 680 (AB 680) (Burke, Chapter 746, Statutes of 2021) was signed into law, requiring CARB to work with the California Labor and Workforce Development Agency to update the Funding Guidelines to include new workforce standards. CARB’s Funding Guidelines currently include requirements for administering agencies to, wherever possible, foster job creation within California, provide employment opportunities or job training tied to employment, and target these opportunities to priority populations. The Funding Guidelines also recommend administering agencies prioritize investments in projects that directly support jobs or a job training and placement program, and that they report the estimated employment benefits and employment outcomes for projects that meet specified criteria. These new requirements apply to agencies administering certain California Climate Investments 80 Office of Planning and Research. Community Economic Resilience Fund. https://opr.ca.gov/economicdevelopment/cerf/. 35 programs that receive continuous appropriations from the Greenhouse Gas Reduction Fund and fall into the following six categories of standards:
• fair and responsible employer standards,
• inclusive procurement policies,
• prevailing wage for construction work,
• community workforce agreements for construction projects over one million dollars,
• preference for projects with educational institutions or training programs, and • creation of high-quality jobs. CARB will be updating the Funding Guidelines through a public process over the next year to operationalize these new requirements.

Partnering Across Government
The Scoping Plan is an actionable plan to identify and align programs and policies to achieve California’s climate targets. To realize the outcomes and deliver results in any Scoping Plan, action is critical. For this Scoping Plan, there are also actions that rely on our federal partners to take on sources primarily under their jurisdiction (such as aviation, and federally owned/managed lands) while they also continue to develop national programs for GHG reductions. The federal government is already taking major steps to advance these types of programs. The Inflation Reduction Act of 202281 includes $369 billion for domestic energy production and manufacturing and is expected to lead to U.S.

GHG emission reductions of roughly 40 percent by 2030. Direct incentives will include those for clean vehicles and ENERGY STAR appliances, as well as improving transportation and clean energy in underserved communities.

We also need our local partners to align on actions related to land-use decisions that support sustainable, resilient, low-carbon communities and permitting for clean energy production facilities and infrastructure; diversion of organics from landfills; and other climate-related projects. State agencies also should use the Scoping Plan to review and update their own programs and policies to support the actions identified in this Scoping Plan. Importantly, the Scoping Plan also can serve as a resource as the Legislature considers new legislative direction and funding to support the state’s path to carbon neutrality and continue action to address near-term air pollution disparities.

Partnering with the Private Sector
Government cannot achieve our climate targets alone. The scale of investment needed requires both private-sector investment and partnerships with philanthropies. Public 81 Pub.L. No. 117-169 (August 16, 2022).
36 sector dollars, accompanied by strong and steady policy signals, must be a catalyst for deeper and broader investments by the private sector in both reducing emissions and building the resilience of our communities. Governor Newsom is committed to working collaboratively with businesses, including small businesses, to deploy the technologies, capital, and ingenuity that are hallmarks of the private sector.

California structures our climate policies and regulations to create market signals and certainty that spur private sector investment. For example, the Governor’s Executive Order on Zero-Emission Vehicles82 set 2035 as the target year for 100 percent zeroemission vehicle sales, creating a time horizon that allows automakers to scale up zeroemission fleets and sending a clear signal to the companies and utilities that would deploy charging infrastructure. The Executive Order has been followed by development and adoption of the Advanced Clean Cars II regulation. CARB convened auto manufacturers, environmental justice groups, labor organizations, and many other stakeholders to provide input into development of the regulation in a robust and transparent manner; again, with the aim of providing certainty for producers and consumers.

California also pursues public-private partnerships (PPP) as a mechanism to advance our collective climate goals. We know these vehicles can be effective at increasing the impact of public sector dollars and helpful in moving markets in a direction aligned with state policy. A new PPP the Administration is advancing is the Climate Catalyst Revolving Loan Fund, housed at the state’s Infrastructure and Economic Development Bank (IBank). The fund offers a range of financial instruments—including flexible credit and credit support— to help bridge financing gaps currently preventing advanced climate solutions from scaling in the marketplace. The Catalyst Fund’s initial areas of investment include forest biomass management and utilization (unlocking innovation to reduce wildfire threats), climate-smart agriculture, and clean energy transmission. The fund leverages public sector investments by mobilizing private finance for shovel-ready projects that are stuck in the deployment phase. As such, IBank is ideally positioned as the state’s all-purpose “Green Bank,” with increasing connection to federal financing programs such as US DOE’s Loan Programs Office and the United States Environmental Protection Agency’s (U.S. EPA) Greenhouse Gas Reduction Fund.

The Catalyst Fund builds from existing IBank financing programs that are themselves increasingly focused on the climate imperative. The IBank’s Infrastructure State Revolving Fund provides supportive capital to climate-aligned projects promoted by local governments and certain nonprofit entities, and will be refining its criteria and market outreach strategies to increase its level of service. IBank’s bonds program has supported 82 Executive Department. State of California. Executive Order N-79-20. https://www.gov.ca.gov/wpcontent/uploads/2020/09/9.23.20-EO-N-79-20-Climate.pdf. 37 multiple large environmental projects, including more than $2 billion in “green bonds,” and is poised to help expand access to the state’s deep and liquid bond capital market. Within IBank’s Small Business Finance Center, the new Climate Tech Loan Guarantee program encourages commercial banks to back climate-focused small businesses, leveraging federal capital to insure a portion of the private bank’s loan. And through IBank’s Expanding Venture Capital Access Fund program, the state is promoting greater diversity in the venture capital community, including climate equity and climate justice.

All of these financing programs exist to leverage private capital in support of the state’s climate goals, and to partner with state policy agencies driving the transition. IBank will also continue to collaborate closely with the State Treasurer’s Office in its provision of capital support to climate solutions, ensuring that funding flows to programs best positioned to deliver success. This partnership of public and private capital, responsive to and in communication with the climate policy community, will ensure that California gets the maximum possible benefit from its allocation of scarce resources.

Supporting Innovation
Reaching our ambitious, deep decarbonization goals will require continued technological innovation. Investment in research, development, and deployment of clean technologies has never been more critical. Sending clear and sustained market and policy signals will encourage large and small companies alike to pursue innovation that can be scaled up and deployed here and beyond our borders. The full suite of AB 32 policies83 has touched nearly every sector of California’s economy and spurred technology innovation in the state, including the growth of technology developers, manufacturers, processors, and assemblers in many areas. Specifically, AB 32 policies and programs support both the supply side and the demand side to build new markets in California. On the supply side, AB 32 policies support businesses to demonstrate and refine technologies, and to help establish critical supply chains. On the demand side, AB 32 policies and programs provide outreach, education, and incentives—as well as disincentives—to motivate everyone from consumers to institutional purchasers to utility planners to adopt new, climate smart technologies. Innovations resulting directly from the state’s climate policies include the following:
• In the past 10 years, a growing market for heavy-duty zero-emission vehicles (HD ZEVs) was established in California, and this market now represents the largest single share of North American supply and demand for HD ZEVs. Vehicle 83 CARB. Climate Change Programs. https://ww2.arb.ca.gov/our-work/topics/climate-change. 38 and component manufacturers are making long-term investments to develop and produce HD ZEVs within California.
• Total consumption of renewable diesel in the California LCFS market has skyrocketed from approximately 1.8 million gallons in 2011 to nearly 589 million gallons in 2020. The LCFS is a key driver of market development for renewable diesel and its coproducts. While the federal renewable fuel standard (RFS) and blenders tax credit also benefit producers, an analysis of their respective contributions to market development, and interviews with industry representatives and independent experts, point to LCFS as a more important factor in market development, at least in recent years.
• In the past five years, a market for small-scale energy storage in California was created where none previously existed. As of 2020, 185 megawatts (MW) of smallscale energy storage projects have been interconnected to the grid. The significant increase in deployment in the last five years is a result of the Self-Generation Incentive Program (SGIP), which significantly reduces the upfront costs to purchase and install small-scale energy storage devices, and of growing customer interest in disaster resiliency in the face of increasing risk from wildfire and related utility outages. These systems have already provided disaster resiliency benefits for residential and non-residential customers.

We have seen how quickly market barriers can be overcome in response to strong policy signals, as occurred in the solar panel and electric vehicle battery space. Governmentstated priorities have a significant role in guiding private and public research, development, and deployment. This Scoping Plan unequivocally puts the marker down on the need for innovation to continue in non-combustion technologies, clean energy, CO2 removal options, and alternatives for SLCPs. The five-year update to the Scoping Plan allows for a periodic evaluation of new tools to add to the state’s toolkit.

Engagement with Partners to Develop, Coordinate, and Export Policies
California works closely with other states, tribal governments, the federal government, and international jurisdictions to identify the most effective strategies and methods to reduce GHGs, manage GHG control programs, and facilitate the development of integrated and cost-effective regional, national, and international GHG reduction programs. For example, the state’s Cap-and-Trade Program has been linked with Québec’s since 2014, and CARB staff regularly engage with jurisdictions throughout the world on the design features of our Cap-and-Trade Program through memoranda of understanding (MOUs) and venues such as the International Climate Action 39 Partnership.84 Low carbon fuel mandates similar to California’s LCFS have been adopted by the U.S. EPA and by other jurisdictions, including Oregon, Washington, British Columbia, the European Union, and the United Kingdom. Many other jurisdictions from Japan to New Zealand, Australia, and the European Commission also continue to seek information and technical experience on our LCFS. California has and will continue to share information and encourage ambitious emissions reductions with interested jurisdictions, with a focus on China, India, Mexico, Canada, and the European Union.

California’s early action to reduce super-pollutants such as methane and other SLCPs was reaffirmed by the 2021 Global Methane Pledge signed by the U.S. and over 100 other countries at the 26th Conference of the Parties to the United Nations Framework Convention on Climate Change (UNFCCC).85
In addition, under the Clean Air Act, the federal government is authorized to allow California to set more stringent vehicle emissions regulations than federal standards.

California’s goals and regulations to transition to 100 percent sales of new zero-emission passenger vehicles by 2035 (including plug-in hybrid vehicles), to drayage trucks by 2035, and other trucks and buses where feasible by 2045 are being emulated by partner states across the U.S. and in jurisdictions around the world. CARB’s Advanced Clean Cars II regulation, 86 which codifies these targets, was approved in August 2022, and already at least four other states have announced their plans to adopt this regulation. Earlier in June 2020 CARB adopted the Advanced Clean Truck regulation, which requires truck manufacturers to meet increasing sale targets of zero-emission trucks in California through 2035. Since adoption, at least five other states—20 percent of the U.S. truck market—have adopted this regulation. These kinds of coordinated policies help signal to vehicle manufacturers a widespread and growing demand for zero-emissions technology, which in turn helps scale production and lower costs for consumers.

With the Mexican Secretariat for Environment and Natural Resources (SEMARNAT), California has engaged in a technical exchange on clean vehicle policies and helped to establish Mexico’s Emissions Trading System (being piloted in 2022). A 2019 MOU signed between California and Environment and Climate Change Canada enables indepth collaboration on policies and programs to decarbonize vehicles, engines, and fuels.

This partnership has led to tangible emissions reductions, from aligning vehicle emissions targets and policies to collaborating on emissions testing and research critical to enforcing 84 International Carbon Action Partnership (ICAP). Homepage. https://icapcarbonaction.com/en?msclkid=dac30cb7b4f511ec94ccd0f1ae323e98. 85 Global Methane Pledge. Homepage. https://www.globalmethanepledge.org/. 86 Cal. Code Regs., tit. 13, §§ 1900,1961.2, 1961.3, 1962.2, 1962.3, 1962.4, 1962.5, 1962.6, 1962.7, 1962.8, 1965, 1968.2, 1969, 1976, 1978, 2037, 2038, 2112, 2139, 2140, 2147, and 2903; and Test Procedures located here: https://ww2.arb.ca.gov/rulemaking/2022/advanced-clean-cars-ii. 40 emissions limits for vehicle manufactures. At the national level, China has looked to California for cutting-edge requirements for car diagnostics and policies that promote zero-emissions vehicles. At a local level, Beijing has adopted California’s vehicle emissions standards and several other progressive environmental regulations. California will continue and renew such efforts across China, including through a 2022 MOU signed with China’s Ministry of Ecology and Environment.

Between 2021 and 2023, California also will serve as president of the Transport Decarbonisation Alliance, a global network of countries, regions, cities, and companies that come together to share experiences and technical expertise, and to increase the ambition and accelerate the deployment of targeted transportation decarbonization policies across freight, electric vehicle infrastructure, and active mobility. Throughout its presidency, California will focus its leadership on decarbonizing the cross-jurisdiction network of medium- and heavy-duty vehicles, both to ensure cleaner air in freightadjacent communities and to stem the effects of climate change.

Over the years, California has also asserted the importance of and supported the ongoing efforts of state and local clean air and climate leadership. Through our participation in the Pacific Coast Collaborative alongside British Columbia, Washington, and Oregon,87 the Under2 Coalition,88 the U.S. Climate Alliance,89 the International ZEV Alliance,90 the Transportation Decarbonisation Alliance, and many more organizations, California has and will continue to build climate partnerships with state and local governments.

California also recognized the need to address the substantial emissions caused by the deforestation and degradation of tropical and other forests, and continues its work alongside other subnational governments as part of the Governors’ Climate and Forests Task Force (GCF).91 Founded in 2008, there are currently 39 GCF members, including states and provinces in Brazil, Colombia, Ecuador, Indonesia, Ivory Coast, Mexico, Nigeria, Peru, Spain, and the United States—all of whom are considering or operating programs to reduce emissions from deforestation, land-use, and rural development, and to benefit local and indigenous communities. CARB’s California Tropical Forest Standard provides a rigorous methodology to assess jurisdiction-scale programs that reduce deforestation and to incentivize responsible action and investment.92 The standard 87 Pacific Coast Collaborative. Homepage. https://pacificcoastcollaborative.org/. 88 Under2 Coalition. Homepage. https://www.theclimategroup.org/under2-coalition. 89 United States Climate Alliance (USCA). Homepage. https://www.usclimatealliance.org/. 90 ZEV Alliance. Homepage. Accelerating the Adoption of Zero-Emission Vehicles. https://zevalliance.org/. 91 Governors’ Climate and Forests Task Force. University of Colorado Boulder: Colorado Law. https://www.gcftf.org/. 92 CARB. California Tropical Forest Standard. https://ww2.arb.ca.gov/our-work/programs/californiatropical-forest-standard. 41 provides a strong signal to value the preservation of tropical forests over continued destructive activities such as oil exploration and extraction and ensures rigorous social and environmental safeguards for indigenous peoples and local communities.

Working Toward Carbon Neutrality
To date, California and many other regions have focused on reducing GHG emissions from the industrial, energy, and transportation sectors. As defined in statute, the state’s 2020 and 2030 targets include all in-state sources of GHG emissions—and those emissions associated with imported power that is consumed in the state. By moving to a framework of carbon neutrality, the scope for accounting is expanded to include all sources and sinks. As such, carbon neutrality is achieved when the GHG fluxes are at equilibrium—when sources equal sinks. Figure 1-5 depicts the sources included in the AB 32 GHG Inventory and the new sources and sinks added in this Scoping Plan under the framework of carbon neutrality. Natural and working lands are able to sequester carbon and therefore play an increasingly important role in this framework. However, modeling for this plan shows that carbon sequestration in our natural and working lands alone will be insufficient to achieve carbon neutrality no later than 2045. Therefore, this plan also considers the role of carbon capture and sequestration, as well as biological and mechanical carbon sequestration processes that are included in the IPCC Sixth Assessment Report,93 as necessary tools for climate change mitigation. 93 IPCC. 2021. Climate Change 2021: The Physical Science Basis. https://www.ipcc.ch/report/ar6/wg1/. 42 Figure 1-5: Carbon neutrality: Balancing the net flux of GHG emissions from all sources and sinks
Supporting Healthy and Resilient Lands
Our natural and working lands are an important piece in California’s fight to achieve carbon neutrality and build resilience to the impacts of climate change. Healthy land can sequester and store atmospheric carbon dioxide in forests, grasslands, soils, and wetlands. Healthy lands can also reduce emissions of powerful short-lived climate pollutants, limit the release of future GHG emissions, protect people and nature from the impacts of climate change, and build our resilience to future climate risks. Unhealthy lands have the opposite effect—they release more GHGs than they store and are more vulnerable to future climate change impacts. Through climate smart land management that focuses on supporting healthy living systems, we can support our carbon neutrality goals, reduce emissions, advance sequestration, and support healthy and more climateresilient lands.

Maintaining the Focus on Methane and Short-Lived Climate Pollutants
Given the urgency of climate change, the often-disproportional impacts already being felt by underserved populations across California and the world, and the need to rapidly decarbonize and avoid climate tipping points as identified in the most recent IPCC assessment, efforts to reduce short-lived climate pollutants are especially important.

SLCPs include methane (CH4), black carbon (soot), and fluorinated gases (F-gases, 43 including hydrofluorocarbons, or HFCs), and they are among the most harmful pollutants to both human health and the global climate. SLCPs are more potent than CO2 in terms of their impact on climate change (and subsequently, global warming) and have a much shorter lifetime in the atmosphere than CO2 does. That means they have an outsized impact on climate change in the near term—they are responsible for up to 45 percent of current climate forcing. It also means that targeted efforts to reduce short-lived climate pollutant emissions can provide outsized climate and health benefits, within weeks to about a decade (see Figure 1-6).

Figure 1-6: Short-lived climate pollutant impacts94
California has been a leader in addressing SLCP emissions. As part of the 2014 Scoping Plan,95 CARB committed to developing a dedicated strategy to reduce SLCP emissions. 94 Climate and Clean Air Coalition. Short-Lived Climate Pollutants (SLCPs). https://www.ccacoalition.org/en/content/short-lived-climate-pollutants-slcps. 95 CARB. 2014. First Update. https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/2013 update/first update climate chang e scoping plan.pdf.
44 The resulting SLCP Reduction Strategy,96 adopted by CARB in 2017, implements targets codified in SB 1383 (Lara, Chapter 395, Statutes of 2016) to reduce methane and HFC emissions by 40 percent by 2030 and anthropogenic black carbon emissions by 50 percent. California worked with several other states through the U.S. Climate Alliance to establish a similar goal to reduce SLCP emissions in line with the requirements of the Paris Agreement,97 identifying the potential to reduce SCLPs by 40 to 50 percent by 2030 across the U.S. Climate Alliance.98
Process for Developing the Scoping Plan
This Scoping Plan was developed in coordination with the Governor’s Office and state agencies, in accordance with direction from the Chair and Members of CARB, through engagement with the Legislature, with advice from the EJ Advisory Committee, in consultation with tribes, and with open and transparent opportunities for stakeholders and the public to engage in workshops and other meetings. Appendix A (Public Process) includes details of the public workshops, and Chapter 5 includes details of the EJ Advisory Committee’s role in the Scoping Plan update process.

Guidance from the Administration and Legislature
This Scoping Plan reflects existing and recent direction in the Governor’s Executive Orders and Statutes. Table 1-1 provides a summary of major climate legislation and executive orders issued since the adoption of the 2017 Scoping Plan. 96 CARB. 2017. Short-Lived Climate Pollutant Reduction Strategy. https://ww2.arb.ca.gov/sites/default/files/2020-07/final_SLCP_strategy.pdf. 97 UNFCCC. 2015. Paris Agreement. https://unfccc.int/sites/default/files/english_paris_agreement.pdf. 98 USCA. 2018. From SLCP Challenge to Action: A Roadmap for Reducing Short-Lived Climate Pollutants to Meet the Goals of the Paris Agreement. http://www.usclimatealliance.org/slcp-challenge-to-action.

54 CARB’s Achieving Carbon Neutrality Report,106 Climate Smart Strategy,107 and draft Natural and Working Lands Implementation Plan,108 among others.

Input from Partners and Stakeholders
CARB also collaborated with other state agencies, held consultations with tribes, and solicited comments and feedback from affected stakeholders, including labor organizations and the public. The process to update the Scoping Plan began with kickoff workshops in early June 2021,109 followed by over a dozen public workshops, including engagement with tribes,110 and featured a series of EJ Advisory Committee and environmental justice community meetings.111 The June 2021 workshop and several others were a joint agency effort, as there are many agencies with direct authority or jurisdiction over different sectors of the economy. Consultation with agencies also included bi-weekly, monthly, and weekly meetings.

During the summer of 2022 CARB held three community listening sessions, hosted by the CARB Chair and Board, in communities around the state, along with one virtual community listening session and one tribal listening session specifically for tribes. Many tribes provided written feedback, which was incorporated into this Scoping Plan. In addition, CARB respects tribal sovereignty and also engaged in a consultation campaign with tribes, which resulted in government-to-government consultations, and this Scoping Plan is reflective of this process.112
Emissions Data That Inform the Scoping Plan
Greenhouse Gas Emissions
AB 32 includes which GHGs are to be regulated, reduced, and included in the state’s targets and goals. That list includes seven GHGs: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), hydrofluorocarbons (HFCs), 106 Energy and Environmental Economics, Inc. 2020. Achieving Carbon Neutrality. https://ww2.arb.ca.gov/sites/default/files/2020-10/e3 cn final report oct2020 0.pdf. 107 CNRA. 2022. Natural and Working Lands Climate Smart Strategy. https://resources.ca.gov/Initiatives/Expanding-Nature-Based-Solutions. 108 CARB. 2019. Draft California 2030 Natural and Working Lands Climate Change Implementation Plan. https://ww2.arb.ca.gov/resources/documents/nwl-implementation-draft. 109 Appendix A (Public Process). 110 CARB. Scoping Plan Meetings & Workshops. https://ww2.arb.ca.gov/our-work/programs/ab-32- climate-change-scoping-plan/scoping-plan-meetings-workshops. 111 CARB. Environmental Justice Advisory Committee Meetings and Events. https://ww2.arb.ca.gov/environmental-justice-advisory-committee-meetings-and-events. 112 CARB. 2018. Tribal Consultation Policy. October. https://www.arb.ca.gov/regact/nonreg/2018/california air resources board tribal consultation policy.pdf.

57 accredited third-party verification body. More information on MRR emissions reports can be found at CARB’s Mandatory Greenhouse Gas Emissions Reporting website.115 All data sources used to develop the GHG Emission Inventory are listed in CARB’s inventory supporting documentation.116
Natural and Working Lands
For natural and working lands, the 2018 ecosystem carbon inventory (NWL Inventory)117 shows there are approximately 5,340 million metric tons (MMT) of carbon in the carbon pools118 (reservoirs of carbon that have the ability to both take in and release carbon) that CARB has quantified (see Figure 1-9). For purposes of comparison, 5,340 MMT of ecosystem carbon stock is equivalent to 19,600 MMT of atmospheric CO2. Forests and shrublands contain the majority of California’s carbon stock because they cover the majority of California’s landscape and have the highest carbon density of any land cover type. All other land categories combined comprise over 35 percent of California’s total acreage, but only 15 percent of carbon stocks. Roughly half of the 5,340 MMT of carbon resides in soils and half in plant biomass.

115 CARB. Mandatory Greenhouse Gas Emissions Reporting. https://ww2.arb.ca.gov/ourwork/programs/mandatory-greenhouse-gas-emissions-reporting. 116 CARB. Current California GHG Emission Inventory Data. www.arb.ca.gov/cc/inventory/data/data.htm. 117 CARB. 2018. An Inventory of Ecosystem Carbon in California’s Natural and Working Lands. https://ww3.arb.ca.gov/cc/inventory/pubs/nwl inventory.pdf. 118 “Carbon pools” are Above-Ground Live Biomass (boles, stems, and foliage in shrubs, trees, grasses, and herbaceous vegetation), Below-Ground Live Biomass (roots in shrubs, trees, grasses, and herbaceous vegetation), Dead Organic Matter (standing or downed dead wood and litter), Harvested Wood Products (all wood and bark material that leaves harvest sites regardless of whether it is eventually incorporated into merchandisable products), and Soil Organic Matter (organic carbon in the top 30 centimeters of soil).
58 Figure 1-9: Carbon stocks in natural and working lands (MMT carbon) In addition to providing an estimate of the ecosystem carbon that exists on California’s landscape, the NWL Inventory also shows how those carbon stocks are changing (see Figure 1-10). The inventory attributes stock change to human activity, such as land use change, or to disturbances, such as wildfire. CARB’s inventory shows these lands were a source of GHG emissions from 2001 to 2011, releasing more carbon than they stored, and then they returned to be a slight carbon sink from 2012 to 2014. These trends highlight the interannual and interdecadal variability of lands and their ability to be both a source and a sink of carbon.
59 Figure 1-10: Changes in carbon stock by landscape type For natural and working lands, California’s inventory is also based on IPCC methods for tracking ecosystem carbon over time, providing for comparability with other national and subnational inventories and carbon accounting. As such, the NWL Inventory is an important tool for tracking both carbon stock changes in California over time and the impacts that interventions such as those identified in this Scoping Plan, actions identified in the Climate Smart Land Strategy, and others have on NWL carbon stocks.

All data sources used to develop the NWL Inventory are listed in the technical support documentation at CARB’s California Natural & Working Lands Inventory website.119 119 CARB. California Natural & Working Lands Inventory. https://ww2.arb.ca.gov/nwl-inventory. 60 Black Carbon
In addition, CARB has developed a statewide emission inventory for black carbon in support of the SLCP Strategy. The inventory is reported in two categories: non-forestry (anthropogenic) sources and forestry sources.120 The black carbon inventory is calculated using existing PM2.5 emission inventories combined with speciation profiles that define the fraction of PM2.5 that is black carbon. The black carbon inventory helps support implementation of the SLCP Strategy, but it is not part of California’s GHG Inventory that tracks progress toward the state’s climate targets under AB 32 or SB 32. The state’s major anthropogenic sources of black carbon include off-road transportation, on-road transportation, residential wood burning, fuel combustion, and industrial processes.

CARB estimated 2017 black carbon emissions to be approximately 8 MTCO2e.121 The majority of anthropogenic sources come from transportation—specifically, heavy-duty vehicles. The share of black carbon emissions from transportation is dropping rapidly and is expected to continue to do so between now and 2030 as a result of California’s air quality programs. The remaining black carbon emissions will come largely from woodstoves/fireplaces, off-road applications, and industrial/commercial combustion. The forestry category includes non-agricultural prescribed burning and wildfire emissions.

Tracking Life-Cycle and Out-of-State Emissions
In recent years there has been increased interest in the embedded carbon in products, also known as life-cycle emissions. A life-cycle accounting framework refers to all of the GHG emissions generated from the sourcing, production, and transportation of products to an endpoint. In doing such assessments for a product, emissions may be associated with sourced materials and production activity outside a jurisdiction’s borders. While lifecycle emissions can provide a more comprehensive picture of the emissions associated with the goods we consume and ongoing demand, life-cycle inventories are inconsistent with IPCC standards, as they would result in double counting of emissions across jurisdictions. Other countries and regions do produce their own inventory reports consistent with IPCC methods and are taking action to reduce emissions within their jurisdictions. In addition, jurisdictions often lack legal authority to regulate sources outside of their borders. Finally, it is difficult to obtain accurate data for sources and production activities outside of a region’s border that would impact the accuracy of such an inventory.

For these reasons, the inventory used in the Scoping Plan does not use a life-cycle 120 SB 1383. https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201520160SB1383. 121 This is a preliminary estimate developed for this Scoping Plan. Official Black Carbon emissions estimates are provided in the SLCP inventory here: https://ww2.arb.ca.gov/ghg-slcp-inventory. 61 approach and remains consistent with international accounting standards and consistent with how other countries and regions track emissions within their jurisdictions.

However, GHG mitigation action may cross geographic borders as part of subnational and international collaboration, or as a natural result of implementation of regional policies. In addition to the state’s existing GHG inventory, CARB will develop an accounting framework that reflects the benefits of our policies accruing outside of the state. This accounting framework will be important to better understand the true impact of the state’s policies on what is emitted into the atmosphere. For example, the LCFS incentivizes GHG reductions along the entire supply chain for the production and delivery of transportation fuel imported for use in the state. However, our inventory only captures the change in emissions from the tailpipe of when that fuel is used in California and does not capture any GHG reductions that occur in the production process if the fuel is produced out of state.

Natural and working lands forestry actions are another example, where California’s policies are inspiring forest management actions in other states that result in increased permanent carbon sequestration. California’s NWL inventory does not capture the increased carbon stocks resulting from forestry projects happening outside of California, and the CO2 removals resulting from these projects are not applied in either CARB’s NWL inventory or CARB’s AB 32 GHG Emissions Inventory. For GHG reductions outside of the state to be attributed to our programs, those reductions must be real, quantifiable, verifiable, and permanent.

It also will be important to avoid any double counting (including claims to those reductions by other jurisdictions) and to transparently indicate whether any extra-jurisdictional emissions reductions might be included in another region’s inventory. CARB is collaborating with other jurisdictions to ensure GHG accounting rules are consistent with international best practices, as robust accounting rules instill confidence in the reductions claimed and maintain support for joint action across jurisdictions. The policy goals of consistency and transparency are critical as we work together with other jurisdictions on our parallel paths to achieve our GHG targets with real benefits to the atmosphere.

Tracking Progress
Historically, the AB 32 GHG Inventory has been the primary metric to track progress toward achieving climate targets.122 However, we must now deploy clean technology at unprecedented rates. The emissions modeling underpinning this Scoping Plan and 122 Starting with the 2022 Edition of the AB 32 GHG inventory, the inventory development now relies more directly on the annually reported and third-party verified emissions from the Regulation for the Mandatory Reporting of Greenhouse Gas Emissions.
62 targets for clean technology in statute can serve as leading indicators across the economy on how our actions compare to the pace of action needed to be on track to achieve carbon neutrality. The California Climate Dashboard123 was launched in 2022 and provides highlevel metrics for clean energy production and technology deployment. Statistics such as the deployment of zero emission vehicles and clean electricity generation are just some of the examples of metrics across the economy that can be tracked, in addition to GHG emissions, to understand if the state is on track to meet its climate goals. A key indicator to track will be building of new energy infrastructure and deployment of clean technology as evaluated in the uncertainty analysis in Chapter 2. CARB will coordinate with state agencies to establish and make public similar metrics across all economic sectors to help provide transparency on the state’s progress in deploying clean technology at the pace and scale needed to achieve carbon neutrality no later than 2045. 123 CalEPA. California Climate Dashboard. https://calepa.ca.gov/climate-dashboard/. 63 Chapter 2: The Scoping Plan Scenario
This chapter describes the Scoping Plan Scenario, which for the first time includes sources in both the AB 32 GHG Inventory and Natural and Working Lands (NWL). It begins with a short description of the alternatives evaluated. Four scenarios for the AB 32 GHG Inventory and NWL were considered separately and helped to inform the Scoping Plan Scenario. Each of the alternatives were considered in terms of the important criteria and priorities that the state’s comprehensive climate action must deliver, including the need for GHG reductions that are not only technologically feasible and cost-effective, but also can deliver health and economic benefits for the state. All the scenarios were set against what is called the Reference Scenario—that is, what the GHG emissions would look like if we did nothing at all beyond the existing policies that are required and already in place to achieve the 2030 target of at least 40 percent below 1990 levels, or those expected with no new actions in the NWL sector. For this Scoping Plan, two sets of modeling tools were used to evaluate the AB 32 GHG Inventory and NWL sectors because no single model can assess both AB 32 sectors and NWL together. As a result, two different sets of scenarios were developed for each sector type. While this chapter breaks out discussion separately for the two sector types, the Scoping Plan Scenario reflects the combined actions across both sectors by choosing an alternative from each sector type. The modeling provides point estimates; however, that does not imply precision. As discussed in the uncertainty section, several types of uncertainties are associated with any outcomes projected by the modeling results. There will be ranges of estimates associated with each point that are not shown in the graphs or results.

Scenarios for the AB 32 GHG Inventory Sectors
The Reference Scenario for the AB 32 GHG Inventory sectors shows continuing but modest GHG reductions beyond 2030 that level off toward mid-century. The comprehensive analysis of all four alternatives indicates that the Scoping Plan Scenario is the best choice to achieve California’s climate and clean air goals while balancing the legislative direction on prioritizing direct emissions reductions, reducing anthropogenic emissions by at least 85 percent by 2045, being technologically feasible, and being costeffective. It also protects public health, provides a solid foundation for continued economic growth, and drastically reduces the state’s dependence on fossil fuel combustion and does not disproportionately impact disadvantaged communities. Each of the alternative scenarios was the product of a process of development informed by public input, the 64 governor,124 CARB, legislative direction, and input by the EJ Advisory Committee.125,126 Future updates to the Scoping Plan may consider new clean technologies and fuels beyond those included in this Scoping Plan.

The four scenarios evaluated shared many similarities. They each embodied the following characteristics:
• Drastic reduction in fossil fuel dependence, with some remaining in-state demand for fossil fuels for aviation, marine, and locomotion applications, and for fossil gas for buildings and industry
• Ambitious deployment of efficient non-combustion technologies such as zero emission vehicles and heat pumps
• Rapid growth in the production and distribution of clean energy such as zero carbon electricity and hydrogen
• Progressive phasedown of fossil fuel production and distribution activities as part of the transition to clean energy
• Remaining emissions of fugitive SLCPs such as refrigerants and fugitive methane • Strong consumer adoption of clean technology and fuel options • Removal of remaining CO2 emissions to achieve carbon neutrality • Some reliance on carbon capture and sequestration (CCS) While the four scenarios had a lot in common, they also had some differences:
• Year in which carbon neutrality is achieved (2035 or 2045) • Rate of deployment of clean technology and production and distribution of zero carbon energy
• Remaining amount of demand for fossil energy in the year carbon neutrality is achieved
• Constraints on technology and fuels deployed in certain sectors • Consumer adoption rates of clean technologies and fuels • Degree of reliance on CO2 removal
• Degree of reliance on CCS
124 Newsom, Gavin. July 22, 2022. Letter from Governor Newsom to CARB Chair Liane Randolph.

Retrieved from https://www.gov.ca.gov/wp-content/uploads/2022/07/07.22.2022-Governors-Letter-toCARB.pdf. 125 EJ Advisory Committee. December 2, 2021. EJ Advisory Committee Responses for the CARB Scenario Inputs. https://ww2.arb.ca.gov/sites/default/files/2021- 12/EJAC%20Final%20Responses%20to%20CARB%20Scenario%20Inputs_12_2_21.pdf. 126 CARB. January 25, 2022. Update on PATHWAYS Scenario Modeling Assumptions. https://ww2.arb.ca.gov/sites/default/files/2022-
01/Scenario%20Slides%20for%20Jan25%20EJAC%20Mtg 01242022.pdf. 65 The summary below provides an overview of the alternatives designed and considered for the energy and industrial sectors in this update. Full details of each scenario considered can be found in the Draft 2022 Scoping Plan Update Scoping Plan Scenario (modeling scenario Alternative 3 from the Draft):
carbon neutrality by 2045, deploy a broad portfolio of existing and emerging fossil fuel alternatives and clean technologies, and align with statutes, Executive Orders, Board direction, and direction from the governor
Alternative 1: carbon neutrality by 2035, nearly complete phaseout of all combustion, limited reliance on carbon capture and sequestration and engineered carbon removal, and restricted applications for biomass-derived fuels Alternative 2: carbon neutrality by 2035 and aggressive deployment of a full suite of technology and energy options, including engineered carbon removal Alternative 4: carbon neutrality by 2045, deployment of a broad portfolio of existing and emerging fossil fuel alternatives, slower deployment and adoption rates than the Scoping Plan Scenario, and a higher reliance on CO2 removal Other considerations for the AB 32 GHG Inventory sectors include the following:
• To what extent does an alternative meet the statewide targets and any sector targets, and also deliver clean air benefits (especially in the near term) to address ongoing healthy air disparities, prioritize reductions for mobile and large stationary sources, and emphasize continued investment in disadvantaged communities? • Does an alternative support California in building on efforts to collaborate with other jurisdictions and include exportable policies based on robust science? • Does an alternative provide for compliance options and a cost-effective approach to reduce GHG emissions?
• Does the alternative present a realistic and ambitious path forward consistent with statute and science, and support economic opportunities, particularly in anticipated growth sectors?
Scenarios for Natural and Working Lands
For the natural and working lands sector, the Reference Scenario shows that NWL will continue to emit GHGs and lose carbon stocks into the future as the combined effects of past unhealthy management practices and climate change impact our lands. Relative to the Reference Scenario, the four NWL scenarios represent different scales of land management on seven landscapes (forests, shrublands/chaparral, grasslands, croplands, developed lands, wetlands, and sparsely vegetated lands) to support carbon neutrality.
66 The analysis of the four NWL scenarios shows that the Scoping Plan Scenario is the preferred choice because it prioritizes sustainable land management to sequester carbon over the long term, GHG and air pollution reductions, ecosystem health and resilience, and implementation and technological feasibility and cost-effectiveness. The Scoping Plan Scenario reduces catastrophic wildfire risk to the state; increases the health and resilience of California’s forests, shrublands, and grasslands; increases soil health; and protects, restores, and enhances California’s natural and working lands for future generations. The Scoping Plan Scenario takes into consideration the priority landscapes and nature-based strategies identified in California’s Climate Smart Strategy127 and reflects the state’s priorities to manage lands in ways that support the multiple benefits they provide. The Scoping Plan Scenario, as well as each of the alternative NWL scenarios, were informed by input from other agencies, the public, and the EJ Advisory Committee. Additional landscapes and land management activities will be added and evaluated in future Scoping Plan updates and in response to AB 1757.

Each of the NWL scenarios have several similarities, including the following:
• Prioritizing NWL management actions on forests, shrublands, grasslands, croplands, developed lands, wetlands, and sparsely vegetated lands. These actions can reduce GHG emissions from these lands, protect ecosystems against future climate change, protect communities, and enhance the ecosystem benefits they provide to nature and society.
• Exploring the potential impacts of different levels of NWL management actions that are designed to achieve the objective associated with each scenario. • Analyzing the carbon impacts of land management actions, climate change, wildfire, and water use on California’s diverse natural and working lands through 2045.

There are also differences across the four NWL scenarios. These include:
• The level of NWL management actions taken on each landscape, such as varying the acres of healthy soils practices for croplands.
• The types of NWL management actions taken on each landscape, such as prescribed burning or thinning for forests, grasslands, and shrublands. 127 CNRA. 2022. Natural and Working Lands Climate Smart Strategy. https://resources.ca.gov/- /media/CNRA-Website/Files/Initiatives/Expanding-Nature-Based-Solutions/CNRA-Report-2022--- Final Accessible Compressed.pdf.
67 The summary below provides an overview of the alternatives designed and considered for the NWL sectors in this Scoping Plan. Full details of each scenario considered can be found in the Draft 2022 Scoping Plan Update.

Scoping Plan Scenario (NWL Alternative 3 from the Draft): land management activities that prioritize restoration and enhancement of ecosystem functions to improve resilience to climate change impacts, including more stable carbon stocks NWL Alternative 1: land management activities that prioritize short term carbon stocks in our forests and through increased climate smart agricultural practices on croplands
NWL Alternative 2: land management activities representative of California’s current commitments and plans
NWL Alternative 4: land management activities that prioritize reducing catastrophic wildfires in forests, shrublands, and grasslands Evaluation of Scoping Plan Alternatives
CARB staff solicited feedback from topical experts, affected stakeholders, and the EJ Advisory Committee, including a tribal representative, at public meetings to assemble input assumptions for four carbon neutrality scenarios to model using PATHWAYS.

Revisions to the Draft Scoping Plan were informed by direction in statute, the Governor’s Executive Orders, public comments, and the recommendations of the EJ Advisory Committee. The three alternative scenarios were designed to explore the potential speed, magnitude, and impacts of transitioning California’s energy demand away from fossil fuels. The modeling assumptions listed below identify the primary fossil fuel alternative that is commercially available and technically feasible for widespread use by 2045 for each sector. CARB assumes that any energy demand that remains after the alternative technology or fuel is applied—such as on-road internal combustion engines, industrial processes, and gas use in existing buildings that have not yet decarbonized—will continue to be met by fossil fuels, resulting in residual GHG emissions.

NWL Scoping Plan Alternatives
For the NWL sectors, staff significantly expanded the scale of the scientific analysis for NWL from previous Scoping Plan efforts. CARB staff utilized modeling tools for this expanded analysis to assess both the carbon and other ecological, public health, and economic outcomes of management actions on forests, shrublands, grasslands, croplands, developed lands, wetlands, and sparsely vegetated lands. CARB staff aligned the scenarios with both the landscape types and actions identified in other efforts called for in Governor Newsom’s Executive Order N-82-20 (e.g., California’s Climate Smart Strategy and Pathways to 30x30). As part of this Scoping Plan, CARB staff modeled as many of the management actions identified in the Natural and Working Lands Climate 68 Smart Strategy as were feasible. The management actions that were included in the model were selected because of the State of California’s previous work to quantify these actions’ impacts. It was not feasible to model every land management strategy for NWL, and so it is possible that larger volumes of sequestration (e.g., in soils or in oceans) could result from additional non-modeled activities. California’s Natural and Working Lands Climate Smart Strategy includes a more comprehensive listing of priority nature-based solutions and management actions. It is important to note that the absence of a particular management action or its climate benefit in the modeling is not an indication of its importance or potential contributions toward meeting the target or toward supporting the carbon neutrality target for California.

Forests: Management strategies were modeled for forests: biological/chemical/ herbaceous treatments (e.g., herbicide application), clearcut, various timber harvests (e.g., variable retention, seed tree / shelterwood, selection harvesting), mastication, other mechanical treatments (e.g., piling of dead material, understory thinning), prescribed burning, and thinning. Avoided land conversion to another land use was also included in the modeling. Wildfire was modeled and is responsive to management strategies and climate conditions.

Shrublands and chaparral: Management strategies were modeled for shrublands and chaparral: biological/chemical/herbaceous treatments, prescribed burning, mechanical treatment (e.g., mastication, crushing, mowing, piling), and avoided conversion from shrubland to another land use. Wildfire was modeled and is responsive to management strategies and climate conditions.

Grasslands: Management strategies were modeled for grasslands:
biological/chemical/herbaceous treatments, prescribed burning, and avoided land conversion from grasslands to another land use. Wildfire was modeled and is responsive to management strategies and climate conditions.

Croplands: Management strategies were modeled for row crops: cover cropping, no till, reduced till, compost amendment, transition to organic128 farming, avoided conversion of annual crop agricultural land through easements, establishing riparian forest buffers, alley cropping, establishing windbreaks/shelterbelts, establishing tree and shrubs in croplands, and establishing hedgerows. For perennial crops, windbreaks/shelterbelts, hedgerows, conversion from annual crops to perennial crops, and avoided conversion to other land uses were modeled.
128 Note: N2O reductions from decreases in synthetic fertilizer application in organic farming were not modeled.
69 Developed lands: Management strategies were modeled for developed lands:

Increasing tree canopy cover through planting trees and improved management of existing trees, and removing vegetation surrounding structures in accordance with the CAL FIRE Defensible Space PRC 4291.

Wetlands: Management strategies were modeled for wetlands: Restoring wetlands through submerging cultivated land in the Sacramento-San Joaquin Delta and avoided land conversion in the Sacramento-San Joaquin Delta.

Sparsely vegetated lands: Management strategies were modeled for sparsely vegetated lands: Avoided conversion of sparsely vegetated lands to another land use. 70 Scoping Plan Scenario
The Scoping Plan Scenario achieves GHG emission reductions that exceed the levels expected based on existing policies represented in the Reference Scenario, keeping California on track to achieve the SB 32 GHG reduction target for 2030 and become carbon neutral no later than 2045. Actions that reduce GHG emissions and transition AB 32 GHG Inventory sources away from fossil fuel combustion affect each economic sector.

Actions that lead to improved carbon stocks affect each landscape.

AB 32 GHG Inventory Sectors
The AB 32 GHG Inventory Sector Reference scenario is the forecasted statewide GHG emissions through mid-century, with existing policies and programs but without any further action to reduce GHGs beyond those needed to achieve the 2030 limit. The Reference Scenario was developed based on other projections of business-as-usual conditions. Sources of data and policies included are:
• California Energy Demand Forecast129
• The two transportation carbon neutrality studies required by AB 74130 • The Mobile Source Strategy131
• SB 100 60 percent Renewables Portfolio Standard
• A Low Carbon Fuel Standard carbon intensity reduction target of 20 percent Policies that are under study or design, such the Advanced Clean Fleets regulation, are not included. The Reference Scenario reflects current trends and expected performance of policies identified in the 2017 Scoping Plan—some of which are performing better (such as the RPS and LCFS) and others that may not meet expectations (such as vehicle miles traveled [VMT] reductions and methane capture). Figure 2-1 provides the modeling results for a Reference Scenario for the AB 32 GHG Inventory sectors compared to the Scoping Plan Scenario.
129 California Energy Commission (CEC). 2020. 2019 Integrated Energy Policy Report. https://www.energy.ca.gov/data-reports/reports/integrated-energy-policy-report/2019-integrated-energypolicy-report. 130 Brown et al. 2021. Driving California’s Transportation Emissions. https://escholarship.org/uc/item/3np3p2t0 and Deschenes et al. 2021. Enhancing equity. https://zenodo.org/record/4707966#.Yl72RNrMKUn. 131 CARB. 2021. 2020 Mobile Source Strategy. https://ww2.arb.ca.gov/sites/default/files/2021- 12/2020 Mobile Source Strategy.pdf.
71 Figure 2-1: Reference and Scoping Plan Scenario GHG emissions132 The Scoping Plan Scenario is summarized in Table 2-1. The table shows the types of technologies and energy needed to drastically reduce GHG emissions from the AB 32 Inventory sectors. It also includes references to relevant statutes and Executive Orders, although it is not comprehensive of all existing new authorities for directing or supporting the actions described. Each action is expected to both reduce GHGs and help improve air quality, primarily by transitioning away from combustion of fossil fuels. The Scoping Plan Scenario achieves the AB 1279 target of 85 percent below 1990 levels by 2045 and identifies a need to accelerate the 2030 target to 48 percent below 1990 levels. 132 The drop in emissions in 2045 reflects both the need to achieve an 85% reduction below 1990 levels in anthropogenic emissions per AB 1279 and Governor Newsom’s request for a 100 MMT CO2e carbon removal and capture target in 2045. This was modeled by extending CCS to electric sector emissions. 0 50
100
150
200
250
300
350
400
450
2021 2024 2027 2030 2033 2036 2039 2042 2045
GHG Emissions (MMT CO2e)
Reference Scenario Scoping Plan Scenario

84 on the options available to capture and sequester carbon. Carbon removal and sequestration will be an essential tool to achieve carbon neutrality, and the modeling clearly shows there is no path to carbon neutrality without carbon removal and sequestration. Governor Newsom also recognized the importance of CO2 removal strategies and directed CARB to establish CO2 removal and carbon capture targets of 20 MMTCO2 and 100 MMTCO2 by 2030 and 2045, respectively, as well as signing 2022 legislation on carbon removal and sequestration, including: AB 1279, SB 905, SB 1137, and AB 1757. Carbon removal and sequestration can take different forms. Figure 2-2 illustrates the types of carbon removal and sequestration included in this Scoping Plan.

There are numerous other carbon removal options undergoing research, development, and pilot deployment. As these options mature and new approaches emerge, they can be considered in future Scoping Plan updates.

Figure 2-2: Forms of carbon removal and sequestration considered in this Scoping Plan
The Role of Carbon Capture and Sequestration
Carbon capture and sequestration (CCS) will be a necessary tool to reduce GHG emissions and mitigate climate change while minimizing leakage and minimizing emissions where no technological alternatives may exist. CCS is a process by which large amounts of CO2 are captured, compressed, transported, and sequestered. CCS projects are paired with a source of emissions, as the CCS project captures CO2 as it leaves a facility’s smokestack. CCS projects are often paired with large GHG-emitting facilities such as energy, manufacturing, or fuel production facilities. The sequestration component 85 of CCS includes CO2 injection into geologic formations (such as depleted oil and gas reservoirs and saline formations), as well as use in industrial materials (e.g., concrete).

CCS is distinct from biological sequestration, which is typically accomplished through NWL management and conservation practices that enhance the storage of carbon or reduce CO2 emissions with nature-based approaches. CCS is also distinct from mechanical CO2 removal technologies, where CO2 is removed directly from the atmosphere using mechanical and/or chemical processes.

CARB adopted a CCS Protocol in 2018 as part of amendments to the Low Carbon Fuel Standard.138 At this time, no CCS projects have been implemented or have generated any credits under that protocol. However, CCS projects have been implemented elsewhere since the 1970s, largely on coal-fired power plants, with over two dozen projects operational around the world. Over 100 are at the stages of advanced or early development and are expanding beyond coal-fired plants to fossil gas, fuel production, and electricity generation facilities.139 CCS projects are in development for addressing emissions from fuel, gas, energy production, and chemical production. As of November 2019, more than half of global large-scale CCS facilities (representing approximately 22 MMTCO2/yr in capacity140) were in the U.S., mostly as a result of sustained governmental support for these technologies.141 This support includes the federal 45Q tax credit for CCS142,143 and research and deployment grants from federal agencies.144, 145 California’s deep sedimentary rock formations in the Central Valley represent world-class 138 CARB. 2022. Carbon Capture & Sequestration. https://ww2.arb.ca.gov/our-work/programs/carboncapture-sequestration. 139 Global CCS Institute. 2021. Global Status of CCS 2021. https://www.globalccsinstitute.com/wpcontent/uploads/2021/11/Global-Status-of-CCS-2021-Global-CCS-Institute-1121.pdf. 140 IHS Markit. August 2021. Carbon Removal Potential: An Overview. https://ww2.arb.ca.gov/sites/default/files/2021-
08/ihsmarkit presentation sp engineeredcarbonremoval august2021.pdf. 141 Beck, Lee. 2019. Carbon capture and storage in the USA: The role of US innovation leadership in climate-technology commercialization. https://academic.oup.com/ce/article/4/1/2/5686277. 142 Congressional Research Service. 2021. Carbon Storage Requirements in the 45Q Tax Credit.

IF11639. https://crsreports.congress.gov/product/pdf/IF/IF11639. 143 The Inflation Reduction Act of August 2022 expands and enhances the 45 Q tax credit for CCS. Pub.L.

No. 117-169 (August 16, 2022). 144 U.S. Department of Energy. 2020. U.S. Department of Energy Announces $131 Million for CCUS Technologies. https://www.energy.gov/articles/us-department-energy-announces-131-million-ccustechnologies. 145 U.S. Department of Energy. 2021. Funding Opportunity Announcement 2515, Carbon Capture R&D for Natural Gas and Industrial Point Sources, and Front-End Engineering Design Studies for Carbon Capture Systems at Industrial Facilities and Natural Gas Plants. https://www.energy.gov/fecm/articles/fundingopportunity-announcement-2515-carbon-capture-rd-natural-gas-and-industrial. 86 CO2 storage sites that would meet the highest standards, with storage capacities of at least 17 billion tons of CO2.
146,147
In this Scoping Plan, CCS is included to address emissions from limited sectors, including electricity generation, cement production facilities, and refineries, to ensure anthropogenic emissions are reduced by at least 85 percent below 1990 levels in 2045, as directed in AB 1279. While the modeling outputs show CCS not being applied to the electricity sector until 2045, CCS could be implemented earlier on the electricity sector with a similar ramp up over time as that for refineries and cement plants. An earlier application of CCS in the electricity sector would yield additional reductions in years prior to 2045. In addition, CCS can support hydrogen production until such time as there is sufficient renewable power for electrolysis and an abundant water source.

Cement plants have emissions associated with combustion and process-related activities. Combustion emissions account for approximately 40 percent of the total emissions at cement plants. The remaining emissions are related to process-related activities. Due to the high heat content needed to produce cement, there is currently no technically feasible alternative to combustion. SB 596 calls for a 40 percent reduction in GHG intensity in cement emissions from 2019 levels by 2035, and then net zero emissions by 2045. To meet in-state demand, the state relies on cement both produced in state and imported. There are seven cement plants operating in California.148 To minimize emissions leakage and address emissions from cement plants, the Scoping Plan Scenario includes CCS for cement plants. Additional reductions will need to be pursued and considered as part of implementation of SB 596, which calls for CARB to develop a comprehensive strategy by July 1, 2023, for the state’s cement sector to achieve net-zero emissions of GHGs associated with cement used within the state as soon as possible, but no later than December 31, 2045. This effort began in the summer of 2022 and included sector specific workshops.

Even with implementation of EO N-79-20, and despite all of the ambitious efforts in the Scoping Plan Scenario, there will remain some demand for petroleum fuels for legacy vehicles on road applications, and in aviation, rail, and marine applications. Petroleum refineries will need to implement technology to decarbonize their operations and reduce their emissions. This Scoping Plan also assumes CCS at petroleum refineries as one of those potential strategies. Currently, there are seventeen petroleum refineries operating 146 For comparison purposes, California’s emitted 418.2 million metric tons of CO2e in 2019. 147 Lawrence Livermore National Laboratory. 2020. Getting to Neutral: Options for Negative Carbon Emissions in California. Revision 1. https://wwwgs.llnl.gov/content/assets/docs/energy/Getting to Neutral.pdf. 148 CARB. Mandatory GHG Reporting – Reported Emissions. https://ww2.arb.ca.gov/mrr-data 87 in the state.149 On the supply side, the modeling assumes all in-state demand is met through some very limited refining activities in California. Figure 2-3 shows the emissions from the refining sector with and without CCS. If CCS is not deployed, the emissions would be directly emitted into the atmosphere, and CO2 removal by NWL or direct air capture would need to increase to compensate for the sector’s emissions.

Refineries can have a variety of point sources that emit CO2—such as steam methane reformers for producing hydrogen, combined heat and power units, and catalytic crackers—that are best suited for CCS. Each configuration of a refinery can be unique to its footprint, onsite operations, and the types of crude oils processed. There are newer technologies with smaller footprints150 that can be deployed in modular configurations to capture CO2 in space-constrained and multiple-point-source facilities such as refineries.

CCS can provide a path to reducing GHG emissions from these facilities to meet petroleum demand while avoiding leakage and until such time as some refineries can be transitioned to produce clean energy to support the transition away from fossil fuels.

While the Scoping Plan modeled deployment of CCS on refineries and identifies significant emissions reductions that can be achieved, the refineries in California are large and complex. The actual deployment of CCS at these facilities as modeled in the Scoping Plan is uncertain. It will be important to closely monitor the evolution of CCS deployment in the refinery sector and, in the next Scoping Plan update, to evaluate the progress toward use in this sector to determine whether the projected reductions will be achieved. 149 CARB. Mandatory GHG Reporting. https://ww2.arb.ca.gov/mrr-data. 150 Carbon Clean. Modular Carbon Capture Systems for Industry. https://www.carbonclean.com/modularsystems?hsLang=en. 88 Figure 2-3: Petroleum refining emissions with and without carbon capture and sequestration
This Scoping Plan also calls for accelerating the transition from combustion of fossil fuels to hydrogen. Hydrogen can be produced through electrolysis with renewable electricity or through steam methane reformation of biomethane. There is a high degree of uncertainty around the availability of solar to support both electrification of existing sectors and the production of hydrogen through electrolysis. Producing hydrogen required under the Scoping Plan Scenario with electrolysis would require about 10 gigawatts (GW)151 of additional solar capacity. If steam methane reformation is paired with CCS, the hydrogen produced could potentially be low carbon. Additionally, the biomethane used to generate hydrogen could be sourced from gasification of forest or agricultural waste resulting from forest management and other NWL management practices, which could also lead to net negative carbon outcomes. Steam methane reformation paired with CCS can thus ensure a rapid transition to hydrogen and increase hydrogen availability until such time as 151 The Draft Scoping Plan included an estimate for solar capacity (40 GW) to support only electrolysis to produce all hydrogen in the Proposed Scenario. The Scoping Plan now includes steam methane reformation of biomethane and biomass gasification with CCS to produce hydrogen, along with electrolysis from off-grid solar. See Appendix H (AB 32 GHG Inventory Sector Modeling) for additional details.
0 5
10 15
20 25
30 35
2021 2024 2027 2030 2033 2036 2039 2042 2045
GHG Emissions (MMT CO2e)
Reference Scenario
Scoping Plan Scenario
Scoping Plan Scenario (no CCS)
89 electrolysis with renewables can meet the ongoing need, assuming there is also sufficient water supply. Additional background and next steps for CCS can be found in Chapter 4.

The EJ Advisory Committee has raised multiple concerns related to the inclusion of CCS and mechanical CDR in the Scoping Plan. Concerns range from potential negative health and air quality impacts in communities from operation of facilities utilizing CCS that continue to emit other emissions, to safety concerns related to potential leaks, to the viability of the current technology. Additionally, the EJ Advisory Committee has policy concerns about the strategy and wants to ensure that engineered carbon removal is not used as a substitute for strategies to achieve emissions reductions onsite and that it does not result in delays in phasing out fossil fuel use. Given these and other concerns and the importance of building public awareness, CARB recognizes the need for a multistakeholder process including other state, federal, and local agencies; tribes; independent experts; and community residents to further understand and address community concerns related to CCS. CARB hosted a CCS Symposium with U.S. EPA Region 9 and the Stanford Doerr School of Sustainability to discuss some of these critical issues with community members and other participants. As CARB begins the process of implementing SB 905 in 2023, that will provide an opportunity for further engagement.

In the context of CCS deployment, the Council of Environmental Quality (CEQ) also highlighted the need to further assess and quantify potential impacts on local criteria air pollutants and other emissions resulting from carbon capture retrofits at industrial facilities in response to concerns regarding potential cumulative emissions from single and/or multiple sources.152 An October 2020 Stanford report153 discussed how the potential postcombustion capture for CO2 could also reduce emissions of criteria air pollutant emissions from certain facilities. Exploring these potential outcomes will be important to ensure deployment of CCS does not exacerbate air pollution impacts in communities and maximizes any air pollution benefits. The need for these types of evaluations is also included in SB 905.

The Role of Natural and Working Lands Emissions and
Sequestration
California’s NWL assessments highlight the importance of increasing the pace and scale of NWL actions to ensure that our ecosystems are better equipped to withstand future climate change so they continue to provide the benefits that nature and society depend 152 Carbon Capture, Utilization, and Sequestration Guidance. 87 Fed. Reg. 8808 (Feb. 16, 2022), 2022- 03205.pdf (govinfo.gov). 153 Stanford Center for Carbon Storage. 2020. An Action Plan for Carbon Capture and Storage in California:

Opportunities, Challenges, and Solutions. October. https://sccs.stanford.edu/ccs-in-ca/full-reportform?msclkid=6f9177f6c57811ecbebc473e75203b21.

91 increase carbon stocks from the Reference Scenario trajectory, reduce GHG emissions from lands, and improve ecosystem and public health. This effort is the most comprehensive scientific effort taken by any government to include NWL within its overall climate strategy. Even so, we know that uncertainty exists about future climate and economic forces and the impacts they may have on our ecosystems, so it is important that the state take decisive and aggressive action to improve and diversify ecosystem structures and management.

The effects of climate change, including increased drought, wildfire, and extreme heat, play a significant role in determining the future of California’s carbon stocks. And while management actions will help to reduce the impact that climate change will have on California, it is clear from the analysis that NWL sinks and sources are highly variable from year to year, and short time frames do not adequately demonstrate the impact that climate and management are having on ecosystems. For the purposes of climate planning, therefore, it is best to focus on carbon stock changes over longer periods rather than focusing on sequestration or emissions on shorter time frames. The Scoping Plan Scenario is estimated to result in additional NWL emissions of 7 million metric tons of carbon dioxide equivalent (MMTCO2e) annually from 2025–2045. The Reference Scenario is estimated to result in annual emissions of 9 MMTCO2e over the same time period, and so the Scoping Plan Scenario slows the rate of emissions and provides an approximate 2 MMTCO2e in additional annual sequestration relative to the Reference Scenario. Because NWL are projected to be a net emissions source, the annual NWL emissions of approximately 7 MMTCO2e from the Scoping Plan Scenario will need to be compensated by additional CO2 removal approaches to ensure California can achieve carbon neutrality by 2045.

The Role for Carbon Dioxide Removal (Direct Air Capture) Even if anthropogenic emissions are reduced to at least 85 percent below 1990 levels by 2045 as called for by AB 1279, there will still be residual emissions in the AB 32 GHG Inventory sectors in 2045 that must be addressed in order to achieve the California’s carbon neutrality target. Figure 2-5 includes the emissions by sector for the AB 32 GHG Inventory Sectors in 2022, 2030, and 2045 for the Scoping Plan Scenario.

93 option that involves rapid mineralization of CO2 at the Earth’s surface is called mineral carbonation.156 As is the case with CCS, mechanical CDR technologies will need governmental or other incentive support to overcome technology and market barriers. In the United States, the U.S. Department of Energy announced financing specifically for DAC in March 2020157 and March 2021.158 Additionally, almost $9 billion in CCS support was included in the $ 1 trillion Infrastructure Investment and Jobs Act of 2021.159 This includes funding to establish four DAC hubs. The Inflation Reduction Act of 2022160 increases the value of the 45Q tax credit to USD 85 per metric ton of CO2 captured and stored in geologic formations from some industrial applications and USD 180 per metric ton for DAC with storage in geologic formations. In 2021, there were approximately 19 DAC facilities globally.161
Ultimately, the role for mechanical CDR will depend on the success of reducing emissions directly at the source in the AB 32 GHG Inventory sectors and the ability of the NWL to sequester carbon. However, mechanical CDR also provides an opportunity to not just achieve carbon neutrality, but also remove legacy GHG emissions from the atmosphere.

As such, increased deployment of DAC can help achieve net negative emissions. This would further help avoid the most damaging impacts of climate change. While the federal incentives for DAC provide some support for this technology, the only California program that recognizes this technology is the LCFS program. Permitting must also happen across different levels of government and across multiple state agencies. Energy availability must also be addressed if DAC is to be implemented in remote areas. Additional information and next steps on DAC can be found in Chapter 4. 156 The National Academies Press. 2018. Direct Air Capture and Mineral Carbonation Approaches for Carbon Dioxide Removal and Reliable Sequestration: Proceedings of a Workshop–in Brief. https://nap.nationalacademies.org/catalog/25132/direct-air-capture-and-mineral-carbonation-approachesfor-carbon-dioxide-removal-and-reliablesequestration#:~:text=National%20Academies%20of%20Sciences%2C%20Engineering%2C%20and%20 Medicine%3B%20Division,concentrate%20carbon%20dioxide%20%28CO%202%29%20from%20ambien t%20air. 157 U.S. Department of Energy. 2020. Department of Energy to Provide $22 Million for Research on Capturing Carbon Dioxide from Air. https://www.energy.gov/articles/department-energy-provide-22- million-research-capturing-carbon-dioxide-air. 158 U.S. Department of Energy. 2021. DOE Invests $24 Million to Advance Transformational Air Pollution Capture. https://www.energy.gov/articles/doe-invests-24-million-advance-transformational-air-pollutioncapture. 159 Pub.L. No. 117-58 (November 15, 2021). https://www.congress.gov/bill/117th-congress/housebill/3684/text. 160 Pub.L. No. 117-169 (August 16, 2022). https://www.congress.gov/bill/117th-congress/housebill/5376/text. 161 International Energy Agency (IEA). 2022. Direct Air Capture – Analysis. https://www.iea.org/reports/direct-air-capture.
94 Carbon Dioxide Removal and Capture Targets for 2030 and 2045 Recognizing the importance of CO2 removal, Governor Newsom and the Legislature identified the need for targets to send policy and regulatory signals to pilot, deploy, and scale action for those efforts. Governor Newsom requested that CARB set a CO2 removal and capture target of 20 MMT for 2030 and 100 MMT for 2045, first prioritizing sequestration in NWL. And while this Scoping Plan prioritizes and recommends significant increased climate-smart action on all NWL to support carbon neutrality and healthy and resilient lands, the modeling indicates that, across all NWL, lands will be a net source of emissions when accounting for both carbon sequestration and GHG (CO2, CH4, and N2O) emissions from lands.

Some landscapes, however, are projected to have a net increase in carbon stocks under the Scoping Plan Scenario between 2025 and 2045 relative to the reference case, indicating that NWL actions can help California achieve Governor Newsom’s CO2 removal targets. Carbon stocks in urban forests and grasslands are projected to increase relative to historical levels from implementation of the 2022 Scoping Plan. To support the governor’s CO2 removal targets, CARB estimates that lands would contribute an average of 1.5 MMT of CO2 removals each year between 2025 and 2045. Any carbon sequestration contributions from lands need to reflect both long-term storage and an overall net increase in carbon stocks over time to ensure these NWL actions are contributing toward California’s achievement and maintenance of carbon neutrality over time.

CARB will work to update and revise these estimates as part of implementation of AB 1757, which was signed by the governor in September 2022 and requires that CARB and the California Natural Resources Agency (CNRA) work with an expert advisory committee to determine an ambitious range of carbon sequestration targets by January 1, 2024, for the years 2030, 2038, and 2045.

For the AB 32 GHG Inventory sectors, the Scoping Plan Scenario modeling indicates that the scenario would meet or exceed the 2030 SB 32 target through GHG reduction policies without the need for CDR. CDR will, however, be necessary to increase ambition for an accelerated 2030 target and in increasing amounts over the following decades to achieve carbon neutrality by 2045.162 Given the likelihood of NWL to be a net source of emissions, and the need for CDR to compensate for residual emissions to achieve carbon neutrality 162 The modeled scenarios assume that residual emissions will be compensated using DAC technologies by including the direct cost in terms of dollars per ton CO2 removed. The energy source for DAC is not modeled, but renewable electricity and/or hydrogen produced from electrolysis are zero carbon options consistent with the carbon neutrality targets in this Scoping Plan. 95 by 2045, California will need increasing deployment of mechanical CDR over the coming decades. In the immediate future, scaling nature-based CDR approaches also can help to provide some CO2 removal quickly while mechanical CDR is scaled up between now and 2045. Table 2-3 provides estimates of CO2 removal and capture needed in 2030163 and 2045.
163 As identified in Chapter 1, SB 27 (Skinner, Chapter 237, Statues of 2021) directed CARB to “establish carbon dioxide removal targets for 2030 and beyond” as part of this Scoping Plan. CARB is establishing these targets to satisfy both the requirements of SB 27 and the directive from Governor Newsom to establish CO2 removal targets for 2030 and 2045.

97 right approach to a sustainable forestry sector. In contrast in 2045, the reductions from programs and policies are estimated to reduce emissions by 169 MMTCO2e from business as usual.

The 2030 target for engineered CDR also provides a near term milestone for California and can serve as an important marker for progress in deploying CDR to support California’s carbon neutrality goal. Preliminary estimates indicate that, globally, capacity from already announced projects will range from about 2 million metric tons per year (MMTCO2/y) to 8 MMTCO2/y from bioenergy paired with CCS, and from about 2,000 metric tons per year (MTCO2/y) to 1 MMTCO2/y from DACs by 2027,166 which indicates that California’s 2030 target is an ambitious, but achievable, goal.

Scenario Uncertainty
Greenhouse Gas Emissions Modeling
Several types of uncertainty are important to understand in both forecasting future emissions and estimating the benefits of emission reduction actions. In developing this Scoping Plan we forecasted a reference scenario and estimated the GHG emissions outcome of the AB 32 GHG Inventory sectors using the PATHWAYS167 model. Inherent in the reference scenario modeling is the expectation that many of the existing programs will continue in their current form, and that the expected drivers for GHG emissions, such as energy demand, population growth, and economic growth, will match our current projections.

However, there is also the expectation that each of the policies included and implemented to achieve the 2030 target in the 2017 Scoping Plan will deliver their exact outcomes. It is unlikely the future will precisely match our projections, and this will lead to uncertainty in the forecast. For example, we never could have foreseen and forecasted economic and emissions impacts related to the extended disruptions from the COVID-19 pandemic.

Thus, the single “reference” or “forecast” line should be understood to represent one possible future in a range of possible predictions. For this Scoping Plan, PATHWAYS utilized inputs that reflect technically feasible levels of deployment or adoption of low- or zero-carbon fuels and technologies. Each of the input assumptions provided to PATHWAYS has some uncertainty, which also contributes to uncertainty in the resulting reference scenario.
166 IHS Markit. August 2021. Carbon Removal Potential. https://ww2.arb.ca.gov/sites/default/files/2021- 08/ihsmarkit presentation sp engineeredcarbonremoval august2021.pdf. 167 See Appendix H (AB 32 GHG Inventory Sector Modeling). 98 Similarly, for the NWL modeling, CARB used a mix of individual modeling tools168 to estimate the carbon and other ecological, public health, and economic outcomes. The Reference scenario assumes that the level of land management actions that occurred between 2001 and 2014 for forests, shrublands, grasslands, croplands, developed lands, wetlands, and sparsely vegetated lands continues into the future. Alternative scenarios assessed the effect of increasing levels of management actions from the reference scenario beginning in 2025. There is a great deal of uncertainty about exactly how lands are currently managed, and a larger uncertainty about how they may be managed in the future. For NWL, it is unlikely that the future will precisely match the carbon stock outcomes CARB has projected, particularly given the uncertainties around current and future land management and the effects climate change will have on our lands. For any modeling exercise these uncertainties exist; however, this modeling effort brings together the best available science, data, and models to quantify the impact our actions may have on the landscape under an unknown future.

Implementation
As this Scoping Plan is designed to chart a path to achieving carbon neutrality, additional work will be required to fully design and implement any policies and actions identified in this plan. During the subsequent development of policies, the Legislature, CARB, and other state agencies will learn more about the technologies and their costs, as well as how each industry works, as a more comprehensive evaluation is conducted in coordination with stakeholders, including community engagement. Significant areas of uncertainty include permitting wait times169 and local ordinances that might limit or slow the build-out of utility scale renewables.170,171 In another example, times to reach commercial operations for solar projects after securing an interconnection agreement also have increased in recent years, to 3.5 to 5.5 years.172 The level of natural and working lands climate action identified in this Scoping Plan is ambitious. Achieving the level of action needed to result in the quantified carbon, 168 See Appendix I (Natural and Working Lands Technical Support Document). 169 CEC. 2021. SB 100 Joint Agency Report. https://www.energy.ca.gov/sb100#anchor report. 170 Roth, Sammy. 2019. “California’s San Bernardino County slams the brakes on big solar projects.” Los Angeles Times. https://www.latimes.com/business/la-fi-san-bernardino-solar-renewable-energy20190228- story.html?fbclid=IwAR2qHGq3bahHme6SFErLsnyFi9UPIfBHIhvnOh3dU3OM7kUTMcEqYfN3pQA. 171 Chediak, Mark. 2021. “California NIMBYs Threaten Biden’s Clean Energy Goals.” BNN Bloomberg. https://www.bnnbloomberg.ca/california-nimbys-threaten-biden-s-clean-energy-goals1.1634351?msclkid=668c9ae9c11311ec92e34035ea157ad4. 172 Rand, Joseph, et al. 2022. Queued Up: Characteristics of Power Plants Seeking Transmission Interconnection as of the End of 2021. Power Point Presentation. Lawrence Berkeley National Laboratory. https://emp.lbl.gov/sites/default/files/queued up 2021 04-13-2022.pdf. 99 emissions, health, and economic outcomes within this Scoping Plan requires coordination, investment, and partnerships across all levels of government and sectors of the economy. It is possible that not all of the actions at the identified level will begin in 2025. This uncertainty will result in diminished levels of beneficial outcomes quantified in the Scoping Plan Scenario. The levels of NWL action identified in this Scoping Plan represent CARB’s assessment of the pace and scale of action needed to achieve the carbon stock targets and CO2 removal targets identified in this Scoping Plan.

The Scoping Plan Scenario identifies that 2.3 million acres of forests, shrubland, and grassland management annually would achieve substantial levels of fire emissions reductions and the concomitant health and economics benefits. Currently, 1 million acres of forest treatment annually is the joint federal and state government goal (500,000 acres each). This target of one million acres annually by 2025 is for the purposes of increasing forest health and wildfire resilience in the near term, whereas the 2.3 million acre target is what the Scoping Plan modeling shows would be needed to realize the carbon stock target called for in this Scoping Plan by 2045. By identifying 2.3 million acres of climate action annually in forests, shrublands, and grasslands, this Scoping Plan emphasizes the importance of that 1 million acre annual goal as a milestone on the way to even more action and improved fire and air quality outcomes. The modeling indicates that substantial improvements to statewide fire emissions will occur at levels of action greater than 1 million acres per year. If these levels of action do not occur starting in 2025, the Scoping Plan has quantified climate benefits that will still occur, but to a lesser extent. In terms of fire emissions, compared to the Reference Scenario, 2.3 million acres of forest, shrubland and grassland management will result in a 10% reduction in wildfire emissions. At 1 million acres per year, this decreases to a 2.5% reduction. If 1 million acres per year is also not accomplished, then the emissions and health benefits are even lower.

Climate action in other NWL sectors also generates many co-benefits. Climate action identified in this Scoping Plan is aimed at not only fighting climate change but also improving air quality and public health. The climate action identified in the agricultural sector, for example, should result in decreased pesticide and synthetic fertilizer use. This decrease of synthetic chemical use in agriculture across California also should result in improved public health, especially for communities that work and live in and around agricultural lands. However, as with the forestry sector, the benefits of climate action in agricultural lands and in any other land are dependent on how much implementation takes place. Ramping up increased healthy soils practices and increasing organic agriculture in California will require continued and sustained implementation by private industry and public agencies. For example, achieving the carbon stock outcomes for the annual crops called for in this Scoping Plan would require deployment and maintenance of healthy soils practices on 80,000 additional acres of croplands in California every year between 2025 and 2045. For context, CDFA’s Healthy Soils Program, which is an incentive program 100
supporting healthy soils practices, took almost four years of sustained funding to achieve approximately 50,000 acres total under healthy soils practices.173 Given the uncertainty around the modeling assumptions, and performance uncertainty as specific policies are fully designed and implemented, estimates associated with the Scoping Plan Scenario are certain to be different than what is ultimately implemented.

One way to mitigate for this is to develop policies that can adapt and increase certainty in GHG emissions reductions. Periodic reviews of progress toward achieving the 2030 target and longer term deeper decarbonization, as well as performance of specific policies, also provide opportunities for the state to consider any changes to ensure we remain on course to achieve the 2030 target and carbon neutrality. The need for this periodic review process was anticipated in AB 32, as it calls for updates to the Scoping Plan at least once every five years. For this Scoping Plan, the metrics provided on the rate of deployment of clean fuels and technologies, along with the annual AB 32 GHG Inventory, provide additional information that can be used to assess progress on sectors and aggregate emissions. This is also true of CARB’s NWL carbon inventory. An uncertainty analysis for achieving an accelerated 2030 target is provided toward the end of this chapter.

Targeted Evaluations for the Scoping Plan: Oil and Gas
Extraction and Refining
To achieve California’s air quality and climate goals, we must end our dependence on petroleum. This will not happen overnight. There are about 28 million combustion engine heavy- and light-duty trucks and passenger vehicles in California, and these are almost always replaced at their end of life. The ZEV Executive Order (EO N-79-20) calls for 100 percent new ZEV car sales beginning in 2035 and a 100 percent ZEV medium- and heavy-duty fleet sales by 2045 where feasible. The result is an ongoing, albeit shrinking, pool of vehicles that will continue to require petroleum fuels. To avoid leakage, as called for in AB 32, and to meet that remaining demand for petroleum fuel, a complete phaseout of oil and gas extraction and refining is not possible by 2045. This Scoping Plan assumes a phasedown in both oil and gas extraction as well as petroleum refining in line with the reduction in demand for in-state on-road petroleum fuel demand. Since the transportation sector is the largest source of GHG emissions and harmful local air pollution, we must continue to research and invest in efforts to deploy zero emissions technologies and clean fuels, and to reduce VMT. An assessment of ongoing progress and efforts to reduce 173 California Department of Food and Agriculture. 2021. Incentives Program 2017–2020 Summary by the Numbers.
https://www.cdfa.ca.gov/oefi/healthysoils/docs/HSP Incentives program level data funded projects.pdf. 101
demand for petroleum fuels and of opportunities to phase down oil and gas extraction and refining will be included in the next Scoping Plan update.

In addition to supplying in-state demand, California is a net exporter of gasoline, diesel, and jet fuel. California pipelines supply the Nevada and Arizona regions174 with approximately 87 million barrels gasoline equivalent of refined products annually.175 California pipelines deliver approximately 85% of Nevada’s and 40% of Arizona’s refined product. Most finished fuels flowing from California to Nevada and Arizona are currently produced by California refineries. To manage the phasedown of oil and gas extraction and petroleum refining in California, exports of finished fuels must be considered and factored into that process, in addition to the declining in-state demand. The authorities and considerations related to supply and demand of petroleum fuels span federal, state, and local agencies. If supply of fossil fuels is to decline along with demand, a multi-agency discussion is needed to systematically evaluate and plan for the transition to ensure that it is equitable.

This inter-agency work should also consider related topics, such as the following:
• Direct and indirect job and economic impacts
• Demand for other liquid fuel types such as renewable fuels, and expected volumes
• Legal considerations
• Public health benefits
• Demand and supply strategies for petroleum fuels, including how to avoid short term supply constraints that may impact low-income consumers Some of these topics were also discussed as part of two studies176 supported by the California Environmental Protection Agency, which can serve as a starting point for a working group to analyze these questions and develop policy recommendations.

Oil and Gas Extraction
On April 23, 2021,177 Governor Newsom directed CARB to evaluate the phaseout of oil and gas extraction no later than 2045 as part of this Scoping Plan. As noted above, this Scoping Plan still has some California demand for finished fossil fuels (gasoline, diesel, 174 CEC. August 2021. A Primer on California’s Pipeline Infrastructure. Petroleum Watch. https://www.energy.ca.gov/sites/default/files/2021-08/August Petroleum Watch ADA.pdf. 175 CEC. March 2020. Petroleum Watch. https://www.energy.ca.gov/sites/default/files/2020- 03/March_2020_Petroleum_Watch.pdf. 176 CalEPA. 2021. Carbon Neutrality Studies: https://calepa.ca.gov/climate/carbon-neutrality-studies/. 177 Governor Newsom. April 23, 2021. Governor Newsom Takes Action to Phase Out Oil Extraction in California. Press Release. https://www.gov.ca.gov/2021/04/23/governor-newsom-takes-action-to-phaseout-oil-extraction-in-california/.

103
According to California Energy Commission (CEC) data used in Figure 2-7, the total oil extracted in California peaked at 402 million barrels in 1986. Since then, California crude oil production has decreased by an average of 6 million barrels per year, to about 200 million barrels in 2020. This steadily decreasing production of crude in California is expected to continue as the state’s oil fields deplete.

Figure 2-7: California in-state crude oil production178 A UC Santa Barbara report estimated that, under business-as-usual conditions, California oil field production would decrease to 97 million barrels in 2045.179 The business-as-usual model assumed no additional regulations limiting oil extraction in California.

Any crude oil demand by California refineries not met by California crude oil will be met by marine imports of Alaskan and foreign crude.180 As shown in Figure 2-8, approximately 99 percent of crude imports into California are delivered by marine transportation. The 178 CEC. No date. Oil Supply Sources to California Refineries. Accessed April 21, 2022. https://www.energy.ca.gov/data-reports/energy-almanac/californias-petroleum-market/oil-supply-sourcescalifornia-refineries. 179 University of California, Santa Barbara. 2021. Enhancing Equity While Eliminating Emissions in California’s Supply of Transportation Fuels.
180 CEC. 2020. Petroleum Watch: How Petroleum Products Move. March. https://www.energy.ca.gov/sites/default/files/2020-03/March 2020 Petroleum Watch.pdf, and CEC. 2020. Petroleum Watch: What Types of Crude Oil Do California Refineries Process? February. https://www.energy.ca.gov/sites/default/files/2020-02/2020-02 Petroleum Watch ADA 0.pdf. 0 50,000
100,000
150,000
200,000
250,000
300,000
350,000
400,000
450,000
1982 1992 2002 2012 2022
California in-state crude oil
production (thousands of barrels)

105
California refineries import a variety of crude oils to meet refinery needs. California petroleum refineries are generally designed to process relatively heavy crude relative to other U.S. refineries. In 2018, crude inputs to California refineries had an average American Petroleum Institute (API) gravity of 26.18 and an average sulfur content of

1.64 percent. Processing significantly lighter or heavier crude blends would require significant changes to a refinery.184 Most crude imported from Alaska and the Middle East is relatively light (API gravity > 30) compared to California crude (API gravity < 20).185 If California crude production is insufficient to meet the demand at California refineries, then California refineries will need access to a similarly heavy source of crude so that the average API gravity of crude remains within their established operating window. South American crude oil imports into California are the heaviest relative to other regions, and therefore they may be the most likely to replace decreased California crude oil supply.186 In summary, the modeling indicates that demand for petroleum will persist due to legacy fleets that will not be replaced until end of life. The modeling also shows what the GHG emissions reductions would be if oil and gas extraction activities were phased down in line with the reduction of in-state petroleum demand. Trend data shows that oil and gas extraction already has been on the decline and will continue to decline. It is possible to anticipate the likely regions and types of crude that would be imported to meet in-state petroleum demand if in-state extraction was fully phased out by 2045. Importantly, activity at the ports would increase, and new infrastructure would be needed to store and deliver crude to in-state refineries. And while GHG emissions from this sector would go to zero in our AB 32 GHG Inventory with a full phaseout, emissions related to the production and transport of crude to California might increase elsewhere, resulting in emissions leakage.

As the state continues to reduce demand for petroleum, efforts to protect public health for communities located near oil and gas extraction sites must also continue. In October 2021, Governor Newsom directed action to prevent new oil drilling near communities and 184 CEC. 2020. Petroleum Watch: What Types of Crude? February. https://www.energy.ca.gov/sites/default/files/2020-02/2020-02_Petroleum_Watch_ADA_0.pdf. 185 CEC. 2020. Petroleum Watch: What Types of Crude? February. https://www.energy.ca.gov/sites/default/files/2020-02/2020-02 Petroleum Watch ADA 0.pdf. 186 CEC. 2020. Petroleum Watch: What Types of Crude? February. https://www.energy.ca.gov/sites/default/files/2020-02/2020-02 Petroleum Watch ADA 0.pdf. 106
expand health protections.187,188 In 2022, the Legislature passed, and the governor signed, SB 1137 to protect communities from existing and any new oil and gas extraction activities through 3,200 foot setbacks.

Petroleum Refining
In the Scoping Plan Scenario CARB modeled a phasedown of refining activity in line with petroleum demand. Meeting petroleum demand means sufficient availability of finished fuel (gasoline, diesel, and jet fuel). Crude is processed at in-state refineries to produce finished fuel. In response to stakeholder requests,189 this evaluation focuses on the Scoping Plan Scenario, but with an evaluation of a complete phasedown of refinery operations in state.

The Scoping Plan Scenario results in California petroleum refining emissions of

4.5 MMTCO2e in 2045; a reduction of approximately 85 percent relative to 2022 levels, which is in line with the decline in in-state finished fuel demand.190 Emissions from refining can be reduced further through the application of CCS technology, as shown in Figure 2-

9. If in-state refining is phased down to zero and the demand for the finished fuels produced by that refining persists, imported finished fuels may be needed to meet the remaining in-state demand.191 The current data shows unmet demand for liquid petroleum transportation fuels would most likely be met by marine imports. A CEC report notes, “The only way for California to receive large amounts of crude and refined products is by marine.”192
187 Office of Governor Gavin Newsom. 2021. California Moves to Prevent New Oil Drilling Near Communities, Expand Health Protections. https://www.gov.ca.gov/2021/10/21/california-moves-toprevent-new-oil-drilling-near-communities-expand-health-protections2/?msclkid=6c0da86bc58e11ecb81cf596d4d8a735. 188 California Department of Conservation Geologic Energy Management Division. October 2021. Draft Rule for Protection of Communities and Workers from Health and Safety Impacts from Oil and Gas Production Operations. https://www.conservation.ca.gov/calgem/Pages/PublicHealth.aspx?msclkid=45660232cf2511ecb1c56119097e3b0c. 189 California Environmental Justice Alliance. October 22, 2021. Comment on 2022 Scoping Plan Update - Scenario Inputs Technical Workshop. https://www.arb.ca.gov/lists/com-attach/68-sp22-inputs-wsWzhdPlI5AjACW1Qx.pdf. 190 This reduction in demand does not assume any need for ongoing operations to support exports to neighboring states.
191 If demand assumes an ongoing need to support exports to neighboring states, the residual demand would require a five-fold increase in finished fuel imports. 192 CEC. 2020. Petroleum Watch: How Petroleum Products Move. March. https://www.energy.ca.gov/sites/default/files/2020-03/March 2020 Petroleum Watch.pdf.

108
If refining ceased in California, the rail and marine deliveries currently needed to support both refining processes and the export of waste products, such as petroleum coke, would cease.

In summary, the modeling indicates that demand for petroleum will persist through 2045.

The modeling also shows what the GHG emissions reductions would be if refining activities were phased down in line with the reduction in in-state petroleum demand. CCS can further reduce emissions for this sector. Importantly, activity at the ports would increase, and new infrastructure would be needed to store and deliver finished fuel across the state, if in-state refining were fully phased down by 2045. And while GHG emissions from this sector would go to zero in our AB 32 GHG Inventory with a full phaseout, emissions related to the refining and transport of finished fuel to California might increase elsewhere, resulting in emissions leakage.

Progress Toward Achieving the Accelerated 2030 Target
The 2017 Scoping Plan laid out a path to achieving the SB 32 target of at least a 40 percent reduction of GHG emissions below 1990 levels by 2030 that focused on reducing emissions in the state and was technologically feasible and cost-effective, reflecting statutory direction. Many of the programs to achieve the 2030 target increased in stringency beginning January 1, 2021. However, the 2030 target must be increased to help achieve the deeper reductions needed to meet the state’s statutory carbon neutrality target specified in AB 1279 and Executive Order B-55-18.

Starting in 2020 and extending into 2022, the COVID-19 pandemic impacts reverberated across the globe in a multitude of ways, including the devastating loss of millions of lives.

The pandemic also had a significant impact on GHG emissions by virtue of its impact on global economies and lifestyle changes for Californians, with extended work and school disruptions. Thus, assessing our progress toward meeting our SB 32 target is confounded by the unprecedented nature of the pandemic. Nevertheless, an assessment of progress toward the 2030 target is critical, in particular the accelerated 2030 target called for in this Scoping Plan, since achieving the accelerated 2030 target would make the state well positioned to achieve its carbon neutrality goals and bring critical near-term air quality benefits to address historical and ongoing disparities in access to healthy air. Because there is only one year of data available for this decade, the analysis takes a prospective look using projected emissions over the remainder of this decade.

Estimating GHG emissions in 2030 requires projecting the effect of policies or measures that are currently deployed and undergoing implementation. Table 2-4 shows three distinct estimates of GHG emissions in 2030 that were created at different times and used different modeling approaches.

110
It is important to note that incentives, carbon pricing, and regulations all can result in similar types of responses including, but not limited to:
• Build-out of clean energy and infrastructure
• Deployment of clean technology
• Reduced demand for fossil energy
• Efficiency improvements
As such, the uncertainty analysis discussion focuses on implementation (technology and infrastructure deployment), and not any specific programs or policies. It is successful implementation that must ultimately happen for emissions reductions to be realized.

The uncertainty analysis described in Appendix J (Uncertainty Analysis) quantifies the impact of delayed permitting and building of renewable generation and transmission in the power sector and delayed adoption of ZEVs across all vehicle fleets in the transportation sector. The Reference Scenario (Rhodium) estimates emissions in 2030 to be 324 MMTCO2e. A five-year delay in renewable capacity would increase emissions by 8 percent in 2030 (25 MMTCO2e) relative to the Reference Scenario. If similar delays in clean energy production and deployment occur in other sectors, a larger increase in emissions relative to the reference scenario would be expected, jeopardizing the state’s ability to achieve the 2030 target. Similarly, a delay in consumer adoption of zero emission vehicles (LDV, MDV, HDV) would increase emissions by 6 percent in 2030 (19 MMTCO2e) relative to the Reference Scenario. Delays in transitioning to electric equipment and appliances in homes and businesses would also lead to increased emissions in 2030. Figure 2-10 illustrates the impact on projected emissions in 2030 associated with delayed renewable capacity and delayed transportation vehicle electrification.

112
Cap-and-Trade Program Update
Since the adoption of the first Scoping Plan in 2008, carbon pricing in the form of a Capand-Trade Program has been part of the portfolio to achieve the state’s GHG reduction targets, and it will remain critical as we work toward carbon neutrality. This section provides an update on the program and its role in achieving the 2030 target.

The Cap-and-Trade Program first came into effect in 2012, under AB 32, and included declining allowance caps through 2020. In 2017, AB 398196 was passed by a supermajority in the Legislature and included prescriptive direction on the design of the program from 2021 through 2030. The AB 398 Cap-and-Trade Program came into effect on January 1, 2021, and it included the following changes:
• Doubling of stringency with an annual cap decline of 4 percent per year from 2021– 2030
• AB 398 price ceiling
• AB 398 redesigned allowance price containment reserve with two tiers • AB 398 100 percent leakage assistance factor for industry • AB 398 lower offset limits: Usage limit cut from 8 percent to 4 percent, and half of offsets must provide direct benefits to California
The reduction in the role of offsets in the program was in recognition of ongoing concerns raised by environmental justice advocates regarding the ability of companies to use offsets for compliance instead of investing in actions on site to reduce GHG emissions that could also potentially reduce criteria or toxic emissions.197,198 Note that data show the relationship between facility emissions of GHGs and co-pollutants is highly variable by sector and pollutant.199 Changes to the allowance price containment reserve and the addition of the price ceiling were included to ensure protections against price spikes in the program, while the changes to the leakage assistance factors were to ensure the maximum protection against leakage in the program. The original design of the program included an auction floor price that increases by 5 percent plus inflation each year, and 196 Assembly Bill 398 (Garcia, Chapter 135, Stats. of 2017). California Global Warming Solutions Act of 2006: market-based compliance mechanisms: fire prevention fees: sales and use tax manufacturing exemption. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180AB398. 197 OEHHA. 2022. Impacts of Greenhouse Gas Emission Limits Within Disadvantaged Communities. https://oehha.ca.gov/media/downloads/environmental-justice/impactsofghgpoliciesreport020322.pdf. 198 The OEHHA report also found that companies that use the most offsets often own the facilities that contribute to local PM2.5 exposure. However, there was no causal relationship found to indicate that implementation of the Cap-and-Trade Program was contributing to increases in local air pollution. Also see: CARB. FAQ Cap-and-Trade Program. https://ww2.arb.ca.gov/resources/documents/faq-cap-andtrade-program. 199 OEHHA. 2022. Impacts of Greenhouse Gas Emission Limits Within Disadvantaged Communities. https://oehha.ca.gov/media/downloads/environmental-justice/impactsofghgpoliciesreport020322.pdf. 113
that escalation factor is retained in the post-2020 program and is also applied to the allowance price containment reserve and price ceiling. These features, combined with the self-ratcheting mechanism for unsold allowances at auctions,200 help to ensure the program is able to handle periods of high and low demand for allowances while continuing to ensure a steadily increasing price signal for regulated entities to invest in GHG reduction technologies.

As a result of achieving the 2020 target several years earlier than mandated by law, there are unused allowances in circulation. CARB estimated the amount to be approximately 310 million allowances after the conclusion of the third compliance period (2018–2020).201 AB 398 had also called for a similar analysis, which was completed in 2018.202 This bank represents approximately 5 percent of the total number of vintage 2013–2030 allowances issued within the joint market. This bank of allowances can only remain banked if yearover-year the covered emissions are declining by 14 MMT. If the annual decline in actual emissions is less than 14 MMT, regulated entities will need to use the banked allowances to cover their compliance obligations. It is likely that the existing bank of 310 million allowances will be needed over the early part of this decade and will be exhausted by the end of the decade. During the same period, prices for allowances will continue to increase at least 5 percent plus inflation year-over-year, sending a steadily increasing price signal to spur investment in onsite reductions for covered entities.

With the passage of AB 1279, the state has a statutory target to achieve carbon neutrality no later than 2045. This Scoping Plan demonstrates that planning on a longer time frame for the new carbon neutrality target means we must accelerate our near-term ambition for 2030 in order to be on track to achieve our longer-term target. CARB will use the modeling for this Scoping Plan to assess what changes may be warranted to the Cap-and-Trade or other programs to ensure we are on track to achieve an accelerated 2030 target. Since the original adoption of the Cap-and-Trade regulation, the program has been amended eight times through a robust public process. Moreover, then-California Environmental Protection Agency Secretary Jared Blumenfeld testified at a Senate hearing in 2022 that CARB will report back to the Legislature by the end of 2023 on the status of the allowance supply with any suggestions on legislative changes to ensure the number of allowances 200 The self-ratcheting mechanism temporarily removes unsold allowances from the market until either sufficient demand manifests for two consecutive auctions and they are incrementally reintroduced at future auctions, or they are permanently removed from general circulation if demand remains low. 201 CARB. 2022. BR 18-51 Cap-and-Trade Allowance Report. Attachment A. https://ww2.arb.ca.gov/sites/default/files/cap-and-trade/Allowance%20Report_Reso18_51.pdf. 202 CARB. 2018. Staff Report: Initial Statement of Reasons: Proposed Amendments to the Cap on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms Regulation. September 4. https://www.arb.ca.gov/regact/2018/capandtrade18/ct18398.pdf? ga=2.134288305.1735610122.1664813 952-1100516233.1657841496.
114
is appropriate to help the state achieve its 2030 target of at least 40% below 1990 levels.

As part of that status update, CARB will also provide information on any potential program changes that may be needed to allowance supply to help achieve an accelerated target for 2030 identified in this Scoping Plan as necessary to achieve carbon neutrality no later than 2045. Engaging in this process in 2023 will allow for the consideration of this Scoping Plan, inclusion of additional data points for the second year of operation of the AB 398- designed program (which only came into force in January 2021), and an opportunity to hold public workshops.

It is also worth noting that the COVID-19 pandemic had significant impacts on economic activity in California and elsewhere.203 Emissions were significantly lower in 2020 due to the impacts of the global pandemic. There is an expectation that emissions will increase as the economy recovers and behaviors continue to shift from the impacts of the ongoing pandemic. As a result, 2020 should be regarded as an outlier in the emissions trends.

This scenario of increasing emissions is similar to what happened in the first compliance period for Cap-and-Trade, where the state economy was recovering from the Great Recession and does not correlate to a problem with the structure of this program or other programs that cover emissions related to the manufacturing or transportation sectors. In any assessment of this and other programs, it is essential to consider external factors such as economic activity and availability of zero carbon energy such as hydropower, among others.

To better understand the role of the Cap-and-Trade Program in achieving the 2030 target, Table 2-5 compares the 2030 GHG emissions estimates from the three reference scenarios described in Table 2-4. The 2017 Scoping Plan projection is from the PATHWAYS model for the Scoping Plan Scenario approved by the Board in late 2017. It excludes the contribution of the Cap-and-Trade Program, without any consideration of uncertainty factors (i.e., a characterization of the uncertainty that a given GHG reduction measure included in the 2017 Scoping Plan will actually achieve the GHG reductions it is projected to deliver). The Reference Scenario represents what GHG emissions would look like if we did nothing beyond the existing policies that are required and already in place to achieve the 2030 target; this scenario is based on the recent PATHWAYS modeling, excluding the contribution of the Cap-and-Trade Program, and without any consideration of uncertainty factors. It indicates that GHG emissions will be lower over this decade than originally projected when the 2017 Scoping Plan was approved. The 203 CARB. November 4, 2021. Mandatory Greenhouse Gas Reporting - 2020 Emissions Year Frequently Asked Questions. https://www.arb.ca.gov/cc/reporting/ghg-rep/reporteddata/2020mrrfaqs.pdf? ga=2.264251343.1760432228.1650736660-1644197524.1577749754. 115
Reference Scenario (Rhodium) which also does not include uncertainty bounds, is the modeling used for the uncertainty analysis above.

Importantly, PATHWAYS is not able to explicitly model a carbon pricing policy, and therefore the Cap-and-Trade Program is not represented in the 2017 Scoping Plan or the Reference Scenario. Carbon pricing is included in RHG-NEMS, which reflects state and federal policies included in the U.S. Energy Information Administration (EIA) Annual Energy Outlook 2022 and the National Energy Systems Model (NEMS), which is the basis for RHG-NEMS.204
As detailed in EIA’s documentation, California’s Cap-and-Trade Program is represented through increased energy prices, which flow across economic sectors.205 However, many of the emissions covered by the California Cap-and-Trade Program are not energy- and fuel-related emissions. Given that, the energy systems model RHG-NEMS was used to model the impact of California Cap-and-Trade on the energy system. However, RHGNEMS does not explicitly model the entire program, which includes non-energy related emissions from the industrial, agricultural, waste, and transportation sectors. 204 U.S. EIA. 2022. Summary of Legislation and Regulations Included in the Annual Energy Outlook 2022.

March. https://www.eia.gov/outlooks/aeo/assumptions/pdf/summary.pdf. 205 U.S. EIA. 2022. Electricity Market Module. https://www.eia.gov/outlooks/aeo/assumptions/pdf/electricity.pdf.

117
Regardless of the uncertainty and differences in the models, it is clear additional GHG reductions must happen over this decade to achieve an accelerated 2030 target. This will require an evaluation of all major programs to assess the need to increase their stringency between now and 2030. As the actual reductions from non-Cap-and-Trade Program measures increase, California will be less reliant on the Cap-and-Trade Program to “fill the gap” to meet an accelerated 2030 reduction target. For example, CARB is developing a proposal to increase the stringency of the LCFS program for 2030, the recently adopted Advanced Clean Cars ll regulation is more stringent than modeled for the 2030 40 percent target in the 2017 Scoping Plan, and SB 596 requires specific reductions in the cement sector over this decade and beyond. However, we also know we are not on track to achieve the VMT reduction called for in the 2017 Scoping Plan and will need to double down to achieve the even more ambitious target called for in the Scoping Plan Scenario.

Also, we will need additional actions over the coming years to reduce short-lived climate pollutants to meet the emission reductions called for in SB 1383.

Collectively, any additional legislation or prescriptive policies for sectors, delays in successful implementation of non-Cap-and-Trade programs and policies, increases in incentive program funding, and delays in economic recovery from the pandemic will continue to affect the role the Cap-and-Trade Program will need to play over this decade to meet the state’s GHG reduction obligations. In summary, the Cap-and-Trade Program must continue to be able to scale across a range of possibilities. With passage of AB 1279 and the need to accelerate the 2030 target, CARB will initiate a public process to utilize the modeling results from this Scoping Plan, specifically the Scoping Plan Scenario, to evaluate and potentially propose changes to the design of the Program, including the annual caps. This process will ensure that the Program supports an increased ambition for 2030 while retaining the ability to scale as other factors, such as changing economic conditions and implementation of non Cap-and-Trade programs, impact the actual emissions at the sources covered by the Program. Any changes to the Program must continue to support a well-designed system that continues to send a steadily increasing price signal, minimizes for leakage, reduces emissions in the covered sectors toward the state’s targets, is cost-effective and technologically feasible, and avoids energy rate spikes. Importantly, the Program should support air quality benefits, especially in overly burdened communities, and not exacerbate existing air quality disparities. 118
Chapter 3: Economic and Health
Evaluations
This chapter provides two approaches for quantifying the economic and health outcomes of the Scoping Plan Scenario. One approach is to consider the combined impact of all measures207 in a scenario. The other approach is required by AB 197, where each measure within a scenario is evaluated independently. In addition to these two evaluation approaches, this chapter also includes a discussion of the Public Health implications for the Scoping Plan Scenario, an overview of the Climate Vulnerability Metric, and the Environmental Analysis conducted in accord with the California Environmental Quality Act (CEQA).

It is important to note that all of the analyses in this chapter use a variety of data sources, but because the modeling is economy-wide at the state level, none of them produce community specific detail outputs. The AB 32 GHG Inventory Sector analysis relies on PATHWAYS data at the state level that is proportionally applied across all regions of the state to translate changes in state level fuel combustion to local level changes. The NWL analysis similarly utilizes a variety of data sources and a suite of models that produce data that are scaled up to the statewide level.

All of the models, except the Wildland Urban Interface (WUI) defensible space model, which is conducted at the county level, create aspatial projections that are not applicable at the community level.

Economic Analysis
As part of the process to develop this Scoping Plan, alternative scenarios that transition energy needs away from fossil fuels and achieve carbon neutrality no later than 2045 were developed.

Alternative scenarios that assess the impact of different land management strategies on carbon stocks in NWL were also developed. These alternatives are described in Appendix C (AB 197 Measure Analysis). The following sections describe the Scoping Plan Scenario in terms of direct cost, the economy, employment, and health outcomes.208
207 AB 197 calls for the evaluation of “measures.” This Scoping Plan treats each action and its variants on stringency as measures for the purposes of this chapter. Appendix C (AB 197 Measure Analysis) lists the measures and corresponding modeling assumptions for each alternative and the Scoping Plan Scenario.

The modeling assumptions for the Scoping Plan Scenario are summarized in Table 2-1. 208 For the Draft 2022 Scoping Plan Update, achieving carbon neutrality in 2035 and 2045 was evaluated. The AB 32 GHG Inventory sector direct cost, the economy, employment, and health outcomes were assessed in those years. Similarly, the Scoping Plan Scenario assessments that are presented in this chapter were made for years 2035 and 2045.
119
The California economy is growing, and it is projected to continue to grow about 2 percent each year, from $3.2 trillion in 2021 to $5.1 trillion in 2045, as shown in Figure 3-1. Similarly, employment in California is anticipated to grow 0.7 percent per year, from 23.5 million jobs in 2021 to 27.7 million jobs in 2045. It is in this context, termed the Reference Scenario, that CARB evaluates the Scoping Plan Scenario in terms of its impact on economic growth and employment.

The projections shown in Figure 3-1 were produced by CARB to evaluate the incremental impact of regulations.

Figure 3-1: Projected California gross state product (left) and employment growth (right) from 2021 to 2035 and 2045
Transitioning away from fossil fuels to alternatives and increasing action on NWL will affect employment opportunities, household spending, businesses, and other economic aspects of our lives. Sectors expected to see growth include renewable electricity and hydrogen production, while other sectors may shrink. The deployment of clean technology may require higher upfront costs for things like heat pumps and induction stoves, but those could be offset by energy efficiency savings. Employment and economic development in NWL-related industries and sectors are expected to increase as land management actions increase, especially for the Forestry sector (in which a significant increase is called for under the Scoping Plan Scenario).

The net impact of these actions on employment and jobs is presented in this chapter.

Estimated Direct Costs
One key metric is the direct cost, or net investment, reflecting any savings that result from actions. Similar approaches were used to estimate direct costs for the AB 32 GHG Inventory sectors and for the NWL, as described in this section.
0 1,000
2,000
3,000
4,000
5,000
6,000
2021 2035 2045
Billion 2021$
Source: California Air Resources Board
20 21
22 23
24 25
26 27
28 29
30 2021 2035 2045
Million Jobs
120
AB 32 GHG Inventory Sectors
Transitioning away from fossil fuels requires investment in new equipment and infrastructure throughout the economy. It involves developing the capacity to produce fuels and electricity from renewable sources rather than producing fossil energy. This transition also takes time. One approach is to eliminate combustion of fossil fuels by replacing all equipment in a specified year.

Another approach is to establish a future point at which all sales of new equipment rely on alternative energy sources and allow the transition to occur over time as equipment is replaced upon its end of life.

To evaluate the investment required through 2045, the PATHWAYS model was used to represent equipment stock and its turnover to non-fossil fuel alternatives over time. The annualized, incremental cost of infrastructure in excess of the annualized cost of the Reference Scenario209 was computed for each year from 2022 through 2045. These costs were computed by first taking the absolute cost in each year—which includes both new equipment investment and also expenditures on energy, operations, and maintenance in each year—and then levelizing the costs (in the same way car or house payments are annualized or spread out over time) to arrive at an annualized cost. Fuel savings, and resulting cost savings, associated with changing energy demand—from gasoline to electricity for vehicles, for example—are included as a result of this methodology. Carbon dioxide removal includes DAC technology powered primarily by off-grid solar, BECCS to produce hydrogen or other fuels, and NWL sequestration, as discussed in Chapter 2.210
Figure 3-2 shows the stock investment cost, fuel/efficiency savings, and CDR cost. The Scoping Plan Scenario allows end-of-life transition of equipment. The cost of investing in new equipment is partially offset by savings associated with efficiency gains and reduced demand for fuels like gasoline. This is particularly relevant in the transportation sector, which leads to the majority of savings in 2045 in the Scoping Plan Scenario, which models near complete electrification of transport relying only on end-of-life replacement of vehicles. Appendix H (AB 32 GHG Inventory Sector Modeling) includes additional detail on direct costs in each sector and how costs change over time.
209 The Reference Scenario described in Chapter 2 and in Appendix H (AB 32 GHG Inventory Sector Modeling) was the basis for the direct cost comparison.
210 The energy source for DAC is not modeled, but renewable electricity and/or hydrogen produced from electrolysis are zero-carbon options consistent with the carbon neutrality targets in this Scoping Plan. The economic analysis associated the investment in DAC with the solar industry for consistency with the carbon neutrality targets.

123
Economy and Employment
Two different models were used to estimate the overall impact that investing in a transition away from fossil fuels and in our NWL may have on the growing California economy. The transition away from fossil fuels was evaluated using the IMPLAN economic analysis model. The NWL investments were evaluated using the REMI PI+ economic model. These models provide similar outputs relative to the same economic and employment forecasts used to develop a Reference Scenario for use in each model.

AB 32 GHG Inventory Sectors
To estimate the overall impact that investing in a transition away from fossil fuels may have on the California economy, CARB used the IMPLAN model. Additional detail regarding the model, assumptions, and methodology are included in Appendix H (AB 32 GHG Inventory Sector Modeling). The IMPLAN model is a multisector representation of private industries in the U.S. economy that maps economic relationships across industries, households, and governments.

This model translates direct costs and savings associated with transitioning away from fossil fuels with indirect effects such as wages, purchases of goods and services, business tax impacts, and supply chain effects. In addition, the induced effects of household purchases, local and import purchases, wages paid, and household tax impacts are estimated. This comprehensive assessment of the interactions between capital investment in fossil fuel alternatives and household purchases provides an indication of the response of the California economy to the Scoping Plan Scenario.

The Scoping Plan Scenario results in a small impact on the Gross State Product (GSP) and employment relative to the Reference Scenario, as shown in Figure 3-3. Economic growth is largely unaffected by the Scoping Plan Scenario in 2035 and slowed by 0.1 percent in 2045.

Employment growth is also slowed a small amount, 0.4 percent in 2035 and in 2045, and employment still grows. Assuming annual growth rates of 0.7 percent means there would be more than 193,000 additional jobs in 2045.

126
In addition to income level, there is likely to be an impact to California personal income that varies based on race/ethnicity.214 Table 3-3 shows the percentage of households within each income group based on eight race/ethnicity categories identified in the American Community Survey 2021. As shown in Table 3-2, households in lower income groups are anticipated to see negative impacts, while households in higher income groups are anticipated to see positive impacts from the Scoping Plan Scenario in both 2035 and 2045. Because more than 60% of households in the race/ethnicity categories of Hispanic, Black alone, Native Hawaiian (HI) or Pacific Islander, American Indian or Alaskan Native, Other, and Two or More make less than $100,000 per year, these populations generally are likely to experience reduced income. White and Asian households will generally experience both increased and decreased income because these households are distributed more evenly across all four income groups.

The state recognizes the need to ensure that accessibility to clean technology and energy do not further exacerbate health and opportunity gaps for low-income households and communities of color. The Climate Change Investments program exceeds the statutory minimums to invest in projects to benefit disadvantaged communities.215 Utilities implement programs for reduced energy bills for qualifying low-income customers.216 There are also resources for waste and water bills that leverage federal funds.217 CARB also coordinated with the CPUC to ensure that the Climate Credit218 funded from the sale of Cap-and-Trade allowances provided to utilities on behalf of ratepayers is credited equally to households and not based on how much energy is used. These are just a few examples of how the state is designing and implementing programs to avoid increasing existing disparities. The state must continue to find ways to relieve economic burdens on low-income households.
214 The number of households in each bracket and the race/ethnicity categories are from American Community Survey 2021 results. Population changes through 2035 and 2045 are not forecast. U.S. Census Bureau. 2021.

Household Income. California. https://data.census.gov/cedsci/table?q=california%20income. 215 CARB. Priority Populations — California Climate Investments. https://www.caclimateinvestments.ca.gov/priority-populations. 216 CPUC. CARE/FERA Program. https://www.cpuc.ca.gov/lowincomerates/. 217 California Department of Community Services and Development. Low Income Household Water Assistance Program. https:/www.csd.ca.gov/lihwap. 218 CPUC. California Climate Credit - FAQ. https://www.cpuc.ca.gov/industries-and-topics/naturalgas/greenhouse-gas-cap-and-trade-program/california-climate-credit/california-climate-credit---faq.

129
AB 32 GHG Inventory Sectors
To assess health impacts for the AB 32 GHG Inventory sectors, an integrated modeling approach was used to quantify and value the air pollution-related public health benefits of the Scoping Plan Scenario relative to the Reference Scenario. Additional details about the models, assumptions, and methodology are included in Appendix H (AB 32 GHG Inventory Sector Modeling). Using output from the PATHWAYS model, projections of pollutant emissions to 2045 were developed for stationary, area, and mobile source emissions using a detailed base year CARB pollutant emissions inventory. Further, the emissions are processed, including for where and when they occur in California, using the Sparse Matrix Operator Kernels Emissions (SMOKE) model. For example, on-road vehicle emissions were allocated along existing roadways, and refining emissions were assigned to the locations of existing refineries. It should be noted that the emissions projections represent statewide average reductions associated with high-level assumptions about alternative fuels and technologies. For example, emissions occurring from refineries to produce liquid fuels are reduced in line with petroleum demand. This reduction is applied equally to all refineries in the Scoping Plan Scenario and does not specify individual facility responses to changing demand. Similarly, the Scoping Plan Scenario does not specify which refineries transition to biofuel production or where new electricity generation facilities are built.

Next, emission changes were translated into impacts on atmospheric pollution levels, including ground-level ozone and PM2.5, via an advanced photochemical air quality model called the Community Multiscale Air Quality (CMAQ) model, which accounts for atmospheric chemistry and transport. A comprehensive assessment of how pollutant concentrations are impacted throughout the year was achieved by simulating all months in 2035 and 2045 for the Scoping Plan Scenario.219 Health benefits were estimated using the U.S. EPA’s environmental Benefits Mapping and Analysis Program (BenMAP) model to translate pollutant changes into avoided incidence of mortality, hospital admissions, emergency room visits, and other outcomes as a result of reduced exposure to ozone and PM2.5. These outcomes are associated with an economic value in order to aggregate health impacts.

The Scoping Plan Scenario shows a substantial reduction in pollutant emissions relative to the Reference Scenario, including NOx, PM2.5, and ROG. Reductions in NOx are shown in Figure 3-4. Even under a business-as-usual trajectory, emissions are reduced from present levels by 26 percent in 2045 in the Reference Scenario, demonstrating the impact of current regulations and trends in energy sectors. The Scoping Plan Scenario further reduces NOx 219 This annual approach differs from the episodic modeling approach applied to the Proposed Scenario and Alternatives in the Draft 2022 Scoping Plan Update. Appendix H (AB 32 GHG Inventory Sector Modeling) describes both approaches.

131
Figure 3-5: Difference in annual average PM2.5 (µg/m3
) in the Scoping Plan scenario
relative to the Reference scenario in 2045 (AB 32 GHG Inventory sectors) Notable health benefits representing the economic value of the avoided incidence of health effects are associated with the Scoping Plan Scenario. In total, the benefits reach $78 billion in 2035 and $199 billion in 2045, as shown in Figure 3-6. Populations in Southern California benefit the most due to preexisting air quality challenges, significant emission sources and activity, and the presence of a large, dense urban population. Additional details regarding the health impact assessment are provided in Appendix H (AB 32 GHG Inventory Sector Modeling).

134
Figure 3-8: Total average annual health benefits relative to the Reference Scenario for the Scoping Plan Scenario (NWL)
As health impacts analyzed here are driven by wildfire emissions, the health benefits for the Scoping Plan Scenario are directly related to the amount of forest, shrubland, and grassland management action. These management actions reduce vegetation fuels and, as a result, wildfire activity. The Scoping Plan Scenario increases the amount of these management actions, reducing wildfire emissions and avoiding incidence of emission-related health effects. The health benefits, or economic value of the avoided incidence of health effects, correspondingly increase with an increasing management implementation rate. Additional details are included in Appendix I (NWL Technical Support Document).

Estimated health benefits do not include the direct impact of wildfires on injuries, deaths, or mental health, nor the indirect costs of lost ecosystem benefits to wildfire. Additional direct health costs may result from wildfire that would likely increase the health benefits from increased forest, shrubland, and grassland management to reduce wildfire activity. Nonetheless, the conservative health benefits under the Scoping Plan Scenario are estimated to be $3.1 billion per year relative to the Reference Scenario for all NWL actions identified in the Scoping Plan Scenario.

3.1 0.0

0.5 1.0

1.5 2.0

2.5 3.0

3.5 Scoping Plan Scenario
Billion 2021$/Year
135
AB 197 Measure Analysis
This section provides estimates for information associated with GHG emissions reduction measures evaluated in this Scoping Plan.221 These estimates, which were developed as part of the process for meeting the requirements of AB 197 (E. Garcia, Chapter 250, Statutes of 2016), provide information on the relative impacts of the evaluated measures when compared to each other. To support the design of a suite of policies that result in GHG reductions, air quality co-benefits, and cost-effective measures, it is important to understand if a measure will increase or reduce criteria pollutants or toxic air contaminant emissions, or if increasing stringency at additional costs yields few additional GHG reductions. To this end, AB 197 requires the following for each potential emissions reduction measure evaluated in any Scoping Plan update:
• The range of projected GHG emissions reductions that result from the measure; • The range of projected criteria pollutant emission reductions that result from the measure; and
• The cost-effectiveness, including avoided social costs, of the measure.

The following sections describe the evaluation of measures for the AB 32 GHG Inventory sectors and NWL. For the purposes of this Scoping Plan, the identified emissions reduction measures for the analysis required by AB 197 are actions grouped by sectors where several policies and programs are expected to overlap. This approach reflects the most granular feasible analysis given the modeling tools available,
222 the overlap and interaction effects among policies and incentive programs, the longer planning horizon used for this Scoping Plan compared to previous efforts, and the scale of transition needed to achieve carbon neutrality. To implement this Scoping Plan, dozens of individual regulations, policies, and incentive programs are anticipated that work together to drive down emissions across all economic sectors and support actions.

Every specific policy or incentive program that could contribute to the deployment of clean technology and energy called for in this plan may overlap in ways that make it infeasible to tease out those policies and programs’ individual effects with any reasonable degree of certainty. For example, in the transportation sector, deploying ZEVs and reducing driving demand may be achieved through a combination of the implementation of new or existing regulations, fuels programs, incentive programs, and VMT reduction initiatives that can each contribute to reductions in emissions for the sector. It is not feasible to isolate each sub action from each other at this time in terms of the share of contribution to total reductions. The estimated emission 221 AB 197 calls for the evaluation of “emission reduction measures.” This Scoping Plan treats each action and its variants on stringency as emission reduction measures for the purposes of this chapter. Appendix C (AB 197 Measure Analysis) lists the measures and corresponding modeling assumptions for each alternative. 222 See Appendix H (AB 32 GHG Inventory Sector Modeling and Appendix I (NWL Technical Support Document). 136
reductions, health endpoints, and costs by measure for the Scoping Plan Scenario are presented in this chapter, and the corresponding estimates for the Proposed Scenario and Alternatives 1, 2, and 4 are included in Appendix C (AB 197 Measure Analysis).

Because many of the measures and underlying assumptions interact with each other, isolating the GHG emission reductions, corresponding changes to fuel combustion, and associated cost of an individual measure is analytically challenging. Each measure is evaluated by examining the change in fuel combustion, cost, and emissions associated with just that measure using the PATHWAYS model. The difference between the Scoping Plan Scenario and the Reference Scenario is estimated for each measure. Starting from the Scoping Plan Scenario, the modeling assumptions for an individual measure are reverted to the Reference Scenario values, resulting in GHG reductions, changes to fuel combustion, and costs (or savings). This approach does not reflect interactions between sectors in PATHWAYS that influence the results for each complete alternative, presented earlier. As such, the values associated with each measure should not be added to obtain an overall scenario estimate.

To arrive at the 2045 target for NWL, CARB modeled the ecological impact that climate smart land-based management strategies (suites of on-the-ground actions, or treatments, that are used across the landscape to manipulate an ecosystem) will have on ecosystem carbon; and whenever possible, additional co-benefits from those actions. The Scoping Plan Scenario incorporates a set of land management actions at varying scales of implementation for each land type to achieve the GHG emission reductions. Each land type, and its associated management actions, was considered a measure for this analysis. For modeling individual landscapes and management actions, CARB used a suite of models. The complexity of these models varies by land type, depending on the existing science, data, and availability of existing models to use.

Appendix I (NWL Technical Support Document) provides detailed modeling assumptions for each NWL type. The estimated emission reductions, health endpoints, and costs by measure under the Scoping Plan Scenario for each NWL type are presented in this chapter, and the corresponding estimates for the Proposed Scenario and NWL Alternatives 1, 2, and 4 are included in Appendix C (AB 197 Measure Analysis).

Estimated Emissions Reductions
Both GHG emissions reductions and emissions of criteria air pollutants were evaluated for the AB 32 GHG Inventory sectors and for NWL. The methods and results are described in this section.

AB 32 GHG Inventory Sectors
In the absence of having direct modeling results for criteria pollutant estimates from PATHWAYS, CARB estimated criteria pollutant emissions impacts by using changes in fuel combustion in units of exajoules from PATHWAYS and emission factors in units of tons per exajoule to estimate the change in emissions in tons per year. Emission factors from a variety 137
of sources for each sector were utilized, including but not limited to CARB’s mobile source emissions models,223 U.S. EPA’s AP 42 Emissions Factors,224 and the South Coast Air Quality Management District’s (AQMD’s) District Rules.225 These emission factors were applied to fuel burn change by fuel type, sector, equipment type, and process, where applicable. Statewide annual average emissions were estimated for three criteria pollutants: NOx, PM2.5, and ROG.

Table 3-5 provides the estimated GHG and criteria pollutant emission reductions for the measures in the Scoping Plan Scenario in 2035 and 2045. The other alternatives are presented in Appendix C (AB 197 Measure Analysis). Based on the estimates below, these measures are expected to provide air quality benefits. The estimates provided in this chapter and Appendix C (AB 197 Measure Analysis) are appropriate for comparing across alternatives considered for the development of this Scoping Plan, but they are not precise estimates. 223 CARB. MSEI - Modeling Tools. https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissionsinventory/msei-modeling-tools. 224 U.S EPA. AP-42: Compilation of Air Emissions Factors. https://www.epa.gov/air-emissions-factors-andquantification/ap-42-compilation-air-emissions-factors. 225 South Coast AQMD. South Coast AQMD Rule Book. https://www.aqmd.gov/home/rulescompliance/rules/scaqmd-rule-book.

139
associated with changes to air pollutants. Biomethane combustion is captured in measures that reduce combustion of fossil gas, such as decarbonizing industrial energy supply and buildings.

Natural and Working Lands
NWL ecosystems naturally vary between being a source and a sink for carbon over time. The NWL ecosystem carbon stock changes projected through mid-century by the suite of models were used to estimate net emissions or emissions reductions relative to the Reference Scenario.

These changes in carbon stocks were affected by projected climate change, the implementation of management actions under the various scenarios, land conversion, and (for forests, shrublands, grasslands) wildfire. Each NWL type was evaluated, and an overview of all NWL is presented in Table 3-6. More detailed results for each NWL type can be found in Appendix C (AB 197 Measure Analysis).

141
EPA.226,227,228,229 Under the IPT methodology, changes in emissions are approximately proportional to the resulting changes in health outcomes. IPT factors are derived by calculating the number of health outcomes associated with exposure to PM2.5 for a baseline scenario using measured ambient concentrations and dividing that number by the emissions of PM2.5 or a precursor. To estimate the reduction in health outcomes, the emission reductions are multiplied by the IPT factor. For future years, the number of outcomes is adjusted to account for population growth. IPT factors were computed for the two types of PM2.5: primary PM2.5 and secondary PM2.5 of ammonium nitrate aerosol formed from precursors.

For this AB 197 analysis, CARB calculated the health benefits associated with the five key measures that are represented by changes to fuel combustion. The health benefits associated with emission reductions for the Scoping Plan Scenario were estimated for each air basin and then aggregated for the entire state of California. CARB assumed that the statewide emission reductions distribution among the air basins is proportional to the baseline emissions in that air basin.

Calculated health endpoints include premature mortality, cardiovascular emergency department (ED) visits, acute myocardial infarction, respiratory ED visits, lung cancer incidence, asthma onset, asthma symptoms, work loss days, hospitalizations due to cardiopulmonary illnesses, hospitalizations due to respiratory illnesses, hospital admissions for Alzheimer’s disease, and hospital admissions for Parkinson’s disease.230,231,232 These health endpoints were calculated using the IPT method for estimated emission reductions. Table 3-7 compares the health benefits of emission reductions associated with each measure for the Scoping Plan Scenario in the year 226 CARB. CARB’s Methodology for Estimating the Health Effects of Air Pollution. Retrieved February 9, 2021. https://ww2.arb.ca.gov/resources/documents/carbs-methodology-estimating-health-effects-air-pollution. 227 Fann, N., C. M. Fulcher, and B. J. Hubbell. 2019. “The influence of location, source, and emission type in estimates of the human health benefits of reducing a ton of air pollution.” Air Quality, Atmosphere & Health 2:169– 176. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2770129/. 228 Fann, N., K. R. Baker, and C. M. Fulcher. 2012. “Characterizing the PM2.5-related health benefits of emission reductions for 17 industrial, area and mobile emission sectors across the U.S.” Environ Int. 49:141–51. November

15. https://www.sciencedirect.com/science/article/pii/S0160412012001985. 229 Fann, N., K. Baker, E. Chan, A. Eyth, A. Macpherson, E. Miller, and J. Snyder. 2018. “Assessing Human Health PM2.5 and Ozone Impacts from U.S. Oil and Natural Gas Sector Emissions in 2025.” Environ. Sci. Technol. 52 (15), 8095–8103. https://pubs.acs.org/doi/abs/10.1021/acs.est.8b02050. 230 CARB. CARB’s Methodology. https://ww2.arb.ca.gov/resources/documents/carbs-methodology-estimatinghealth-effects-air-pollution. 231 CARB. 2022. Updated Health Endpoints in CARB’s Health Benefits Methodology. Evaluating New Health Endpoints for Use in CARB’s Health Analyses. 232 Cardio-pulmonary mortality, hospitalizations due to cardiopulmonary illnesses, and hospital admissions due to respiratory illnesses endpoints utilize studies documented in CARB’s methodology document. For future assessments, CARB will use more recent studies to estimate cardiovascular hospital admissions and respiratory hospital admissions, as documented in CARB’s updated health endpoints memo. 142
specified (2035 or 2045). The other alternatives are presented in Appendix C (AB 197 Measure Analysis).

146
The measures related to reducing non-combustion emissions and compensating for remaining emissions do not include changes to fuel combustion and therefore are not associated with changes to air pollutants or health endpoints. Biomethane combustion is captured in measures that reduce combustion of fossil gas, such as decarbonizing industrial energy supply and buildings.

Although the estimated health outcomes presented are based on a well-established methodology, they are subject to uncertainty. For instance, future population estimates are subject to increasing uncertainty as they are projected further into the future, and baseline incidence rates can experience year-to-year variation. Also, the relationship between changes in pollutant concentrations and changes in pollutant or precursor emissions is assumed to be approximately proportional.

In addition, emissions are reported at an air basin level and do not capture local variations.

These estimates also do not account for impacts from global climate change, such as temperature rise, and are only based on the scenarios in this Scoping Plan.

The fuel changes for each AB 197 measure are estimated based on the impact of each measure compared to the Reference Scenario for the years 2035 and 2045. Therefore, aggregating the effect of each measure would overestimate the impacts of the Scoping Plan Scenario because the implementation of each measure would affect the level of benefits of the other measures. This measure-by-measure analysis uses a different methodology for calculating health endpoints than does the health analysis for the complete Scoping Plan Scenario provided earlier.

Natural and Working Lands
Implementation of NWL management strategies to mitigate and adapt to climate change will result in both environmental and health benefits. This section provides information about the potential health benefits of measures evaluated for the Scoping Plan Scenario.

For this analysis, health benefit estimates were focused on increases or decreases to PM2.5 resulting from wildfire emissions on forests, shrublands, and grasslands.233 Other health benefits resulting from NWL management actions in the Scoping Plan Scenario are not quantified here but are important for all Californians. This includes, but is not limited to, reductions in exposure to synthetic pesticides when switching to organic agricultural systems, improvements in shade availability and mental health with increasing urban forest cover, improved mental health from opportunities for recreation in resilient and healthy environments, and protection from floods and rising sea levels. 233 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, N11, N14. finalejacrecs.pdf (arb.ca.gov).
147
These examples are by no means exhaustive, as our natural and working lands provide immense health benefits to everyone.

For this analysis, CARB used the PM2.5 emissions in Table 3-6 to understand potential health impacts. This information should be used to understand the relative health endpoints of the various measures and should not be taken as absolute estimates of health outcomes of this Scoping Plan statewide or within a specific community. The IPT methodology was used to calculate health endpoints, similar to the AB 32 GHG Inventory Sector analysis. CARB calculated the annual health endpoints associated with the wildfire emissions changes resulting from the implementation of management strategies on forests, shrublands, and grasslands under each alternative. The annual health endpoints associated with emission reductions for the Scoping Plan Scenario were estimated for the entire state. Calculated health endpoints include emissions-caused mortality, hospital admittance, and emergency room visits from asthma; hospital admittance from chronic obstructive pulmonary disease; and emergency room visits from respiratory and cardiovascular outcomes. Table 3-8 compares the average annual health endpoints of wildfire emission reductions associated with the Scoping Plan Scenario over the period 2025–2045. The other alternatives are presented in Appendix C (AB 197 Measure Analysis).

149
of the gas in question by one metric ton.234 Many of these damages from GHG emissions today will affect economic outcomes throughout the next several centuries.

In 2008, federal agencies began incorporating SC-CO2 estimates into the analysis of their regulatory actions. U.S. EPA has used various models and discount rates to determine the value of future impacts. Generally, these models begin with assumptions to predict economic activity over time, along with projected GHG emissions. The modeled emissions are input into a model of the global climate system, which then translates into estimates of surface temperature, sea level rise, and other impacts. These outputs are used to estimate economic damages per ton of GHG emitted in a given year in the future.

Since the models are calculating the present value of future damages, a discount rate is applied. For example, the SC-CO2 for the year 2045 represents the value of climate change damages from a release of CO2 in 2045 discounted back to today. The present value is significantly affected by the discount rate used; a higher discount rate results in a lower present value. For example, in 2021 dollars the SC-CO2 in 2045 is $31 using a 5 percent discount rate, $88 using a 3 percent discount rate, and $122 using a 2.5 percent discount rate. Additional detail is included in Appendix C (AB 197 Measure Analysis).

The 2017 Scoping Plan utilized SC-CO2 and SC-CH4 Obama Administration-era values developed by the Council of Economic Advisors and the Office of Management and Budget-convened Interagency Working Group on the Social Cost of Greenhouse Gases (IWG)235 to consider the social costs of actions to reduce GHG emissions. The Biden Administration reinstated these values in February 2021,236 after they had been rescinded and significantly revised by the Trump Administration. The reinstatement was considered an interim step, and the Biden Administration also reconvened the IWG to continue its work to evaluate and incorporate the latest climate science and economic research and 234 U.S. Government. Interagency Working Group on Social Cost of Greenhouse Gases. February 2021.

Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide – Interim Estimates under Executive Order 13990. https://www.whitehouse.gov/wpcontent/uploads/2021/02/TechnicalSupportDocument SocialCostofCarbonMethaneNitrousOxide.pdf 235 Originally titled the “Interagency Working Group on the Social Cost of Carbon,” the IWG was renamed in 2016. 82 Fed. Reg. 16093, 16095-96 (Mar. 28, 2017). https://www.govinfo.gov/content/pkg/FR-2017- 03-31/pdf/2017-06576.pdf. 236 Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis, Executive Order 13990 (Jan. 20, 2021), 86 Fed. Reg. 7037 (Jan. 25, 2021). https://www.energy.gov/sites/default/files/2021/02/f83/eo-13990-protecting-public-health-environmentrestoring.pdf. IWG, Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990 (February 2021), https://www.whitehouse.gov/wpcontent/uploads/2021/02/TechnicalSupportDocument SocialCostofCarbonMethaneNitrousOxide.pdf See also, The White House. 2021. A Return to Science: Evidence-Based Estimates of the Benefits of Reducing Climate Pollution. https://www.whitehouse.gov/cea/written-materials/2021/02/26/a-return-toscience-evidence-based-estimates-of-the-benefits-of-reducing-climate-pollution/. 150
respond to the National Academies’ recommendations from 2017 as it develops a more complete revision of the estimates.

It is important to note that the models used to produce SC-GHG estimates do not include all of the important physical, ecological, and economic impacts of climate change recognized in the climate literature. There are additional costs to society, including the costs associated with changes in co-pollutants and costs that cannot be included due to modeling and data limitations. The IWG has stated that the range of the interim SC-GHG estimates likely underestimates societal damages from GHG emissions.237 The revised estimates were originally slated to be released in early 2022 but were stalled.238 CARB staff is applying the interim values presented in the IWG February 2021 Technical Support Document (TSD), which reflect the best available science in the estimation of the socioeconomic impacts of GHGs.
239 This Scoping Plan utilizes the TSD standardized
range of discount rates, from 2.5 to 5 percent, to represent varying valuation of future damages.

AB 32 GHG Inventory Sectors
Table 3-9 presents the estimated social cost, in terms of avoided economic damages, for each measure of the Scoping Plan Scenario. For each measure, Table 3-9 includes the range of the SC-CO2 and SC-CH4 that results from the GHG emissions reductions in 2035 and 2045 at 2.5 and 5 percent discount rates. Additional background on the SC-GHG and methodology for calculating the SC-CO2 and SC-CH4 estimates in this Scoping Plan, as well as estimates for the alternatives, are provided in Appendix C (AB 197 Measure Analysis).
237 Interagency Working Group on Social Cost of Greenhouse Gases. 2021. Technical Support Document. https://www.whitehouse.gov/wpcontent/uploads/2021/02/TechnicalSupportDocument SocialCostofCarbonMethaneNitrousOxide.pdf 238 See Louisiana v. Biden (W.D. La. 2022) 585 F.Supp.3d 840, stayed pending review (5th Cir. Mar. 16, 2022) 2022 WL 866282. A federal district court ruling issued in early February 2022 had granted a preliminary injunction blocking the Biden Administration from using the interim IWG SC-GHG estimates.

However, a federal appeals court overturned the lower court’s preliminary injunction in March 2022, which allows the Biden Administration to continue using the policy as legal proceedings continue. CARB will continue to monitor the litigation. However, the federal action does not prohibit CARB from using social cost of carbon and CARB will use the best available science regardless of politics. A separate federal appeals court upheld the Biden administration’s use of the IWG SC-GHG estimates in October 2022.

Missouri v. Biden (8th Cir. 2022) ____ F.4th ____. 239 Interagency Working Group on Social Cost of Greenhouse Gases. 2021. Technical Support Document. https://www.whitehouse.gov/wpcontent/uploads/2021/02/TechnicalSupportDocument SocialCostofCarbonMethaneNitrousOxide.pdf

153
Social Costs of GHGs in Relation to Cost-Effectiveness
AB 32 includes a requirement that rules and regulations “achieve the maximum technologically feasible and cost-effective” greenhouse gas emissions reductions.240 Under AB 32, cost-effectiveness means the relative cost per metric ton of various GHG reduction strategies,241 which is the traditional cost metric associated with emission control. In contrast, the SC-CO2, SC-CH4, and social cost of nitrous oxide (SC-N2O), because they are estimates of the cost to society of additional GHG emissions, can be used to estimate of the economic benefits of reducing emissions, but do not take into account the cost of the actions that must be taken to achieve those GHG emissions reductions.

There may be technologies or policies that do not appear to be cost-effective when compared to the SC-CO2, SC-CH4, and SC-N2O associated with GHG reductions.

However, these technologies or policies may result in other benefits that are not reflected in the IWG social costs. Examples include the evaluation of social diversification of the portfolio of transportation fuels (a goal outlined in the Low Carbon Fuel Standard) and reductions in criteria pollutant emissions from power plants (as in the Renewables Portfolio Standard). Additionally, costs for new technology may be higher early on in a technology’s development cycle and may drop over time as use of the technology is scaled up.

Estimated Cost per Metric Ton
AB 197 requires an estimation of the cost-effectiveness of the measures evaluated for this Scoping Plan. The cost (or savings)242 per metric ton of CO2e reduced for each measure is one metric for comparing the performance of the measures. Additional factors beyond the cost per metric ton that could be considered include continuity with existing laws and policies, implementation feasibility, contribution to fuel diversity and technology transformation goals, and health and other benefits to California. These considerations are not reflected in the cost per metric ton estimates presented below. It is important to understand the relative cost-effectiveness of individual measures as presented in this section. However, the economic analysis presented earlier in this chapter, in Appendix H 240 AB 32 Air pollution: greenhouse gases: California Global Warming Solutions Act of 2006. (AB 32, Nuñez, Chapter 488, Statutes of 2006).
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=200520060AB32. 241 Health & Saf. Code § 38505(d). 242 Similarly, to the direct costs reported earlier, the cost per metric ton of a measure reflects the stock costs and any fuel or efficiency savings associated with a measure divided by the GHG emission reduction achieved by the measure. Costs are reported as positive values, and savings are reported as negative values.
154
(AB 32 GHG Inventory Sector Modeling), and in Appendix I (NWL Technical Support Document) provides a more comprehensive analysis of how the Scoping Plan Scenario and alternative scenarios affect the state’s economy and jobs.

AB 32 GHG Inventory Sectors
The cost per metric ton for the AB 32 GHG Inventory sectors was computed for each measure independently relative to the Reference Scenario using the sensitivity calculations based on PATHWAYS and RESOLVE outputs. The difference in the annualized cost between the Scoping Plan Scenario and the Reference Scenario was computed for each measure in 2035 and in 2045. The incremental cost was divided by the incremental GHG emissions impact to calculate the cost per metric ton in each year.

To capture the fuel and GHG impacts of investments made from 2022 through 2035, or from 2022 through 2045, CARB computed an average annual cost per metric ton. The incremental cost in each year was averaged over the period. This value is divided by the corresponding annual, incremental GHG impact averaged over the same period.

The cost metric includes the annualized incremental cost of energy infrastructure, such as zero-emission vehicles, electric appliances, and required revenue to support all electric assets. A residual value for equipment such as vehicles or appliances that are retired early is included. The annual fuel cost or avoided fuel cost that results from efficiency improvements or changes to demand for fuels associated with transitioning to alternative fuels is included. Not included in this cost metric are costs that represent transfers within the state, such as incentive payments for early retirement of equipment.

It is important to note that this cost per metric ton does not represent an expected market price value for carbon mitigation associated with these measures. In addition, the values do not capture fuel savings or GHG reductions associated with the full economic lifetime of measures that have been implemented by the target date of 2035 or 2045 but whose impacts extend beyond the target date.

Table 3-11 includes the cost per metric ton and annual average cost per metric ton estimates for the Scoping Plan Scenario. The other alternatives are presented in Appendix C (AB 197 Measure Analysis). Measures that are relatively less costly in 2035 or 2045 are also less costly over the extended period. As noted earlier, incremental costs of new vehicles are generally offset by gains in efficiency and avoided fuel consumption resulting in negative cost per metric ton.

157
Climate Vulnerability Metric
As California invests in climate mitigation and adaptation, it is essential to understand that the relative impact of climate change will vary across the state’s communities. Due to persisting health and opportunity gaps, not all communities are equally resilient in the face of climate impacts. A global metric such as the Social Cost of Carbon cannot adequately capture the incremental additional economic impact faced by overly burdened communities. The Climate Vulnerability Metric (CVM) is specifically focused on quantifying the community-level impacts of a warming climate on human welfare and the additional costs. Additional details and results are included in Appendix K (Climate Vulnerability Metric).

The CVM aggregates the impacts of climate change that can be quantified at the census tract level using robust and currently available research. The CVM includes the projected impacts of climate change on human welfare across four categories (hours worked, household energy costs, human mortality, and flood-related property damage) through midcentury. The CVM identifies nine components of the four climate impacts as shown in Figure 3-9 and aggregates the data to generate a total CVM result for each census tract.

To ensure that the CVM represents the diversity of California communities, it is reported as the aggregate monetized impact of climate change as a percentage of census tractspecific incomes.243 For example, a CVM value of 3 implies that by 2050, a census tract is projected to experience human welfare impacts of climate change that amount to 3% of annual income in that tract.
243 Per capita income in 2019 for census tracts across California ranges from $633 to $176,388, with a median of $32,181 ($2019). Source: American Community Survey. 158
Figure 3-9: Categories of climate change impacts on human welfare included in the Climate Vulnerability Metric.

The CVM shows that climate change will have highly unequal impacts across California.

While some southeastern regions of California are estimated to suffer damages that exceed 5% of annual income, other high-elevation northeastern regions of California are estimated to see benefits of up to 10%. Some low-lying urban areas, such as the San Francisco Bay Area, are estimated to be particularly vulnerable, while much of the Central Valley is estimated to suffer at least moderate economic damages relative to the rest of the state. It is important to note that the CVM does not set a threshold for vulnerability.

Instead, it shows relative impacts across census tracts. The CVM is limited to the impacts that can currently be quantified at the census tract level. 159
Figure 3-10: Combined impacts of climate change in 2050 under a moderate emissions scenario; damages as share of 2019 tract income (%) By providing information about how climate vulnerability varies across California (Figure 3-10), the CVM results can be used to direct resources to enhance resiliency in the state’s 160
most vulnerable communities based on the specific impacts, such as heat or flooding, they are experiencing. The CVM may be used in combination with existing screening tools, such as CalEnviroScreen 4.0, to identify communities that face environmental and health hazards that contribute to disproportionate economic impacts in addition to climate vulnerability. The CVM can become an essential source of information to implement this Scoping Plan and build a more resilient, just, and equitable future for all communities.

Public Health
Health Analysis Overview
This section focuses on a broader evaluation of public health and climate change.

Science demonstrates that taking action to address climate change presents one of the most significant opportunities to improve public health outcomes.244 Transitioning to clean energy and technology and improving land and ecosystem management will lead to a much healthier future. Many actions to reduce GHG emissions also have health cobenefits that can improve the health and well-being of populations across the state, as well as address climate change. This section and the accompanying Appendix G (Public Health) provide a qualitative analysis of health benefits to accompany the quantitative health analysis included in this chapter, in Appendix C (AB 197 Measure Analysis), and in Appendix H (AB 32 GHG Inventory Sector Modeling). Together the qualitative and quantitative analyses of benefits are demonstrating the many ways that climate action and health improvements go hand in hand.

Climate change can lead to a wide range of direct health impacts such as increased heatrelated illnesses (i.e., heat exhaustion and heat stroke), and injuries and deaths from extreme weather events or disasters (e.g., severe storms, flooding, wildfires). Indirect impacts include:
• more air pollution-related exacerbations of cardiovascular and respiratory diseases (e.g., due to increased smog, wildfire smoke)
• increased vector-borne and fungal diseases due to changes in the distribution and geographic range of disease-carrying species (e.g., mosquitoes, ticks, fungi in dust)
• negative nutritional consequences related to decreases in agricultural food yields • stress and mental trauma due to extreme weather-related catastrophes • anxiety, depression, and other mental health impacts associated with gradual changes in the climate (e.g., prolonged drought or temperature shifts affecting jobs and industries) that result in unemployment and income loss 244 Watts, N., W. N. Adger, P. Agnolucci, et al. 2015. “Health and climate change: Policy responses to protect public health.” Lancet 386, 1861–1914.
161
• residential displacement and home loss (e.g., sea level rise impacting coastal communities)
Wildfires and wildfire smoke are one area where we have already seen and expect to see even further drastic impacts on the health of Californians. According to CalFire, since 1932 the top eight largest wildfires in California have occurred in the past five years (2017–2022), with 151 deaths due directly to fires during that period.245 Researchers estimate that wildfire smoke during fall 2020 may have led to as many as 3,000 excess deaths, with at least 95% of Californians suffering unhealthy levels of particle pollution due to wildfires in 2020.246 Continued climate change is projected to further increase smoke exposure from wildfires through the end of the century.247 Wildfires also create a high-risk environment for outdoor workers, including agricultural workers. While the direct medical and physical health impacts are often most noticeable, the psychological impacts can develop and persist well after the event. Estimates indicate that 20%–65% of survivors of extreme weather events have mental health issues following the event.248 Extreme heat, drought, and associated worsened air quality impacts are among the most serious climate-related exposures affecting the health of Californians. Numerous studies find a wide range of adverse health effects accompanying extreme heat, including heat stroke and adverse birth outcomes, and find that extreme heat can harm most body systems. Climate change exacerbates air pollution problems that cause difficulty breathing and can lead to serious illness and death in many parts of California. Increasing temperatures cause increases in ozone and other pollution concentrations, including for California’s most polluted regions, and heighten health risks for the vulnerable and marginalized populations living in these areas.249 In 2020, there were 157 ozone polluted days across Los Angeles, Orange, Riverside, and San Bernardino Counties—the most days since 1997. In addition, particulate matter exposure is a heightened problem during 245 California Department of Forestry and Fire Protection (CAL FIRE). “Stats and Events.” Cal Fire Department of Forestry and Fire Protection, https://www.fire.ca.gov/stats-events/. 246 G-FEED. 2020. Indirect mortality from recent wildfires in CA. http://www.g-feed.com/2020/09/indirectmortality-from-recent.html. 247 M. D. Hurteau, A. L. Westerling, C. Wiedinmyer, and B. P. Bryant. 2014. “Projected effects of climate and development on California wildfire emissions through 2100.” Environ. Sci. Technol. 48, 2298–2304. 248 American Public Health Association. 2019. Addressing the Impacts of Climate Change on Mental Health and Well-Being. Policy No: 20196. https://www.apha.org/policies-and-advocacy/public-healthpolicy-statements/policy-database/2020/01/13/addressing-the-impacts-of-climate-change-on-mentalhealth-and-well-being. 249 American Lung Association. State of the Air 2021. https://www.lung.org/research/sota. 162
droughts, which are expected to increase over this century.250,251 Worse air quality leads to illnesses, emergency room visits, and hospitalizations for chronic health conditions, including chronic obstructive pulmonary disease (COPD), asthma, chronic bronchitis, and other respiratory and cardiovascular conditions, as well as increased risk for respiratory infections, which all result in greater health costs to the state.252,253,254 These and other climate-related health impacts are discussed in more detail in Appendix G (Public Health).

Health Analysis Components
This Scoping Plan health analysis focuses on the contrast between a California that is still dependent on a fossil fuel-based economy and a California that is transitioned to a carbon-neutral, clean energy future. This qualitative analysis evaluates and demonstrates the broad range of benefits of a dramatic reduction in fossil fuels by 2045 combined with healthier ecosystem management, comparing health outcomes for a “no-action” scenario (Reference) to a “take-action” decarbonization scenario. As this is a qualitative analysis, it looks more broadly at the public health benefits of a drastic reduction in fossil fuel combustion. While this analysis provides scientific evidence for Scoping Plan benefits based on achieving carbon neutrality by 2045, it does not analyze a specific scenario.

The key areas of focus for the analysis are: heat impacts, children’s health and development, economic security, food security, mobility and physical activity, urban greening, wildfires and smoke impacts, and housing affordability. For each area of focus, the analysis covers the scientific evidence and compares expected health effects between the Reference and decarbonization scenarios. This analysis looks at the major health outcomes, provides directional effects for each health outcome, and where possible provides information on the strength and scale of health impacts. Some areas include quantitative information where tools are available to measure health outcomes.

While the analysis is focused on health outcomes statewide, it also includes discussion 250 Cvijanovic, I., B. D. Santer, C. Bonfils, et al. 2017. “Future Loss of Arctic Sea-ice Cover Could Drive a Substantial Decrease in California’s Rainfall.” 8 Nat. Commun. 1947. https://doi.org/10.1038/s41467-017- 01907-4. 251 Williams, A. P., R. Seager, J. T. Abatzoglou, B. I. Cook, J. E. Smerdon, and E. R. Cook. 2015. “Contribution of anthropogenic warming to California drought during 2012–2014.” Geophysical Research Letters 42(16), 6819–6828. 252 Romley, J. A., A. Hackbarth, and D. P. Goldman. 2010. Cost and Health Consequences of Air Pollution in California. Santa Monica, California. RAND Corp. https://www.rand.org/pubs/research briefs/RB9501.html. 253 Wang, M., C. P. Aaron, J. Madrigano, E. A. Hoffman, E. Angelini, J. Yang, A. Laine, et al. 2019. “Association between long-term exposure to ambient air pollution and change in quantitatively assessed emphysema and lung function.” JAMA 322(6), 546–556. 254 Inserro, A. 2018.“Air Pollution Linked to Lung Infections, Especially in Young Children.” Am. J.

Managed Care (May 6). https://www.ajmc.com/view/air-pollution-linked-to-lung-infections-especially-inyoung-children.

164
Social and Environmental Determinants of Health Inequities Communities across the state do not experience exposure to pollution sources and the resulting effects equally. Low-income communities and communities of color (including Black, Latino and Indigenous communities) consistently experience significantly higher rates of pollution and adverse health conditions than others due to factors including historic marginalization rooted in systemic racism. As shown in Figure 3-12, the most impacted neighborhoods according to CalEnviroScreen (CES) are home to very high percentages of people of color while the least impacted neighborhoods are predominantly white. Recent findings show that Black Californians have 19% higher PM2.5 exposure from vehicle emissions than the state average, and the census tracts with the highest PM2.5 pollution burden from vehicle emissions have a high proportion of people of color.255 Air pollutant emissions from mobile sources have disproportionate impacts on low-income communities and communities of color due to their proximity.256 Diesel-fueled vehicles traveling on California’s freeways and major roads expose nearby residents to pollution that is linked to lung cancer, hospitalizations and emergency department visits for chronic heart and lung disease, and premature death.257,258 A combination of historical and social inequities are evident in communities of color disproportionately living close to freeways and other major sources of vehicle pollution. Environmental exposures and contaminants are one component of a broader set of social, economic, and environmental factors that can amplify health conditions, and the combination of all these factors can compound the health effects of individual exposures. This broader set of community factors can be referred to as “cumulative impacts.” In addition, specific populations are more sensitive to pollution and face greater susceptibility. This includes young children, older adults, and individuals with existing health conditions.
255 Reichmuth, D. 2019. Inequitable exposure to air pollution from vehicles in California. https://www.ucsusa.org/resources/inequitable-exposure-air-pollution-vehicles-california-2019. 256 CARB. 2017. California’s 2017 climate change scoping plan. https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf. 257 CARB. 2020. Overview: Diesel exhaust & health. https://ww2.arb.ca.gov/resources/overview-dieselexhaust-and-health. 258 Kagawa, J. 2002. “Health effects of diesel exhaust emissions—a mixture of air pollutants of worldwide concern.” Toxicology 181–182:349–353.
165
Figure 3-12: Least and most impacted neighborhoods from CalEnviroScreen259 Social Determinants of Health Inequities
The physical and mental health of individuals and communities is shaped, to a great extent, by the social, economic, and environmental circumstances in which people live, work, play, and learn. According to the World Health Organization, these same circumstances—or social determinants of health—are “mostly responsible for health inequities: the unfair and avoidable differences in health status seen within and between countries.” In fact, a strong body of research demonstrates that more than 50 percent of long-term health outcomes are the result of social determinants affecting an individual.260 Race/ethnicity and socioeconomic status, for example, have been found to amplify impacts from long- and short-term environmental exposures for several health outcomes, 259 The figure represents the top and bottom decile scoring of CalEnviroScreen census tracts for pollution burden. This chart is modified from Figure 2. Race in the Least and Most Impacted Census Tracts of CalEnviroScreen 4.0 in the Office of Environmental Health Hazard Assessment, California Environmental Protection Agency. Analysis of Race/Ethnicity and CalEnviroScreen 4.0 Scores. 2021. https://oehha.ca.gov/media/downloads/calenviroscreen/document/calenviroscreen40raceanalysisf2021.p df. 260 California Department of Public Health (CDPH). 2015. The Portrait of Promise: The California Statewide Plan to Promote Health and Mental Health Equity. A Report to the Legislature and the People of California by the Office of Health Equity. Sacramento, California. California Department of Public Health, Office of Health Equity.
166
such as mortality and birth outcomes.261,262,263,264 Social factors combine in low-income communities and communities of color to create levels of toxic chronic stress and limit opportunities for healthy food and healthy lifestyles. Social factors also can cause health disparities through psychosocial pathways such as discrimination and social exclusion.265 While the importance of social determinants is well known, measuring the specific and cumulative impacts of social determinants is challenging.

There are several important tools to evaluate and map cumulative impacts and factors contributing to the results of historical practices such as redlining, and these tools have been used for air quality and climate planning, community protection, and investments.

CalEnviroScreen is a tool that maps cumulative pollution burdens and vulnerabilities on a statewide basis and ranks census tracts based on environmental, exposure, population, and socioeconomic indicators. An analysis using CES shows a direct, persistent relationship between exposure to environmental burdens and socioeconomic and health vulnerabilities affecting communities of color and historical redlining practices. OEHHA has evaluated health impacts of certain climate change policies on disadvantaged communities and communities of color utilizing CES rankings.266 The Healthy Places Index (HPI) maps indicators that affect life expectancy on a statewide basis. In the future, these and other tools can be helpful to prioritizing investments and informing implementation efforts for GHG emission reductions policies.

Environmental Determinants of Health Inequities
Communities with large percentages of Black and other socially vulnerable and marginalized groups are disproportionately located near pollution sources, such as traffic 261 O’Neill, M. S., M. Jerrett, I. Kawachi, J. I. Levy, A. J. Cohen, N. Gouveia, et al. 2003. “Health, wealth, and air pollution: Advancing theory and methods.” Environ Health Perspect. 111 (16): 1861–70. 262 Ponce, N. A., K. J. Hoggatt, M. Wilhelm, and B. Ritz. 2005. “Preterm birth: The interaction of trafficrelated air pollution with economic hardship in Los Angeles neighborhoods.” Am J Epidemiol. 162 (2):
140–8. 263 Morello-Frosch, R., B. Jesdale, J. Sadd, and M. Pastor. 2010. “Ambient air pollution exposure and fullterm birth weight in California.” Environ Health. 9: 44. 264 Finkelstein, M. M., M. Jerrett, P. DeLuca, N. Finkelstein, D. K. Verma, K. Chapman, et al. 2003. “Relation between income, air pollution, and mortality: A cohort study.” CMAJ. 169 (5): 397–402. 265 Clougherty, J., and L. Kubzansky. 2009. “A framework for examining social stress and susceptibility in air pollution and respiratory health.” Environ Health Perspect. 117 ( 9 ): 1351–8. 266 OEHHA. 2022. Impacts of Greenhouse Gas Emission Limits Within Disadvantaged Communities. https://oehha.ca.gov/media/downloads/environmental-justice//impactsofghgpoliciesreport020322.pdf. 167
and freight facilities, industrial facilities, and hazardous waste sites.267,268,269,270 Research shows large disparities in exposure to pollution between white and non-white populations in California, and between low-income and communities of color (Figure 3-13). The research also shows Black and Latino populations experience significantly greater air pollution impacts than white populations in California.271 Additionally, Native Americans are disproportionately impacted by air pollution with high rates of exposure to industrial, diesel, and residential pollution sources and higher rates of diseases linked to air pollution.
272, 273
267 Mohai. P., P. M. Lanz, J. Morenoff, J. S. House, and R. P. Mero. 2009. “Racial and socioeconomic disparities in residential proximity to polluting industrial facilities: Evidence from the Americans’ Changing Lives Study.” Am J Public Health. 99 (Suppl 3): S649–56. 268 Mohai, P., and R. Saha. 2007. “Racial inequality in the distribution of hazardous waste: A national-level reassessment.” Soc Probl. 54 (3): 343–70. 269 Morello-Frosch, R., M. Pastor, C. Porras, and J. Sadd. 2002. “Environmental justice and regional inequality in southern California: Implications for future research.” Environ Health Perspect. 110 (Suppl 2):
149–54. 270 Gunier, R. B., A. Hertz, J. von Behren, and P. Reynolds. 2003. “Traffic density in California:

Socioeconomic and ethnic differences among potentially exposed children. J Expo Anal Environ Epidemiol. 13 (3): 240–6. 271 Apte, J. S., S. E. Chambliss, C. W. Tessum, and J. D. Marshall. 2019. A Method to Prioritize Sources for Reducing High PM2.5 Exposures in Environmental Justice Communities in California. CARB Research Contract Number 17RD006. 272 Indigenous People and Air Pollution in the United States. A Report from the National Tribal Air Association and Moms Clean Air Force. 2021. https://7vv611.a2cdn1.secureserver.net/wpcontent/uploads/2021/04/indigenousairpollution_041421.pdf 273 National Tribal Air Association. 2022. Status of Tribal Air Report. Pg. 66. https://7vv611.a2cdn1.secureserver.net/wp-content/uploads/2022/10/2022-NTAA-Status-of-Tribal-AirReport.pdf. 168
Figure 3-13: Top sources of PM2.5 and their contribution to PM2.5 exposures by race and in disadvantaged communities
These disparities in exposure to pollution sources generate health inequities.

Communities located near major roadways are at increased risk of asthma attacks and other respiratory and cardiac effects. Studies consistently show that mobile source pollution exposure near major roadways or freight sources contributes to and exacerbates asthma, impairs lung function, and increases cardiovascular mortality.274 The exposure to mixtures of gaseous and particulate pollutants in mobile sources (including PM, NOx, and benzene) is associated with higher rates of heart attacks, strokes, lung cancer, autism, and dementia.275
Environmental hazards found in communities also can include exposures to toxic substances and emissions, as well as occupational exposures. Due to historical inequities, under-resourced communities and communities of color are often located close to sources of toxic pollution, including chrome platers; metal recycling facilities; oil and gas operations; agricultural burning; railyards; facilities transporting, managing, or disposing of hazardous waste; and areas impacted by pesticides, among others. Some populations may be at increased risk of exposure to pollutants, both at work and home.

Children are more susceptible to environmental pollutants for many reasons, including the ongoing development of their nervous, immune, digestive, and other bodily systems.

Moreover, children eat more food, drink more fluids, and breathe more air relative to their 274 U.S. Environmental Protection Agency website. How Mobile Source Pollution Effects Your Health. https://www.epa.gov/mobile-source-pollution/how-mobile-source-pollution-affects-your-health. 275 USC Environmental Health Centers. 2018. Living Near Busy Roads or Traffic Pollution. https://envhealthcenters.usc.edu/wp-content/uploads/2016/10/living-near-bus 19696172.pdf. 169
body weight, as compared to adults.276 Exposure to high levels of air pollutants, including indoor air pollutants, increases the risk of respiratory infections, heart disease, and asthma.277 Children living in low-income communities near industrial operations, rail yards, and heavily trafficked freeways and streets in urban areas are at especially high risk of chronic respiratory conditions. Black children are four times more likely to be hospitalized for asthma compared with white children, and urban Black and Latino children are two to six times more likely to die from asthma than white children. 278 Native
American children also experience more impacts from asthma and Native American children, along with Black children, have the highest prevalence of asthma.279 For older adults, increased vulnerability is linked to respiratory, cardiovascular, and immune systems weakened by aging.280 Preexisting health conditions interact with environmental pollutants to enhance risks of adverse health outcomes.281,282 The recent COVID-19 pandemic has highlighted the heightened vulnerability of older adults as well as communities of color to respiratory disease, as hospital admissions and mortality data linked to COVID-19 cases for these groups have been higher than other groups.

Research has also underscored the important link between COVID-19 mortality and morbidity and air pollution, demonstrating significantly higher mortality and morbidity for COVID-19 in areas of elevated PM2.5 pollution.

Climate Vulnerabilities
Climate change is expected to exacerbate the existing disparities of health conditions and worsen climate vulnerability, which is the degree to which natural systems and people or 276 Blaisdell, R. J. Air Toxics Hot Spots Program Risk Assessment Guidelines. 2012. Technical Support Document for Exposure Assessment and Stochastic Analysis. Oakland, California: California Environmental Protection Agency, Office of Environmental Health Hazard Assessment. August. 277 Woodruff, T. J., D. A. Axelrad, A. D. Kyle, O. Nweke, and G. G. Miller. 2003. America’s Children and the Environment: Measures of Contaminants, Body Burdens, and Illness. 2nd ed. Washington, D.C.:

United States Environmental Protection Agency. February. 278 California Department of Public Health. Asthma Inequities in California Children. 2021. https://www.cdph.ca.gov/Programs/CCDPHP/DEODC/EHIB/CPE/CDPH%20Document%20Library/CA A sthma Inequities Children 2021-Infographic.pdf. 279 Meng, Y., S. H. Babey, T. A. Hastert, and E. Brown. 2007. California’s Racial and Ethnic Minorities More Adversely Affected by Asthma. UCLA: Center for Health Policy Research. Retrieved from https://escholarship.org/uc/item/4k45v3xt. 280 Sandström, T., A. J. Frew, M. Svartengren, and G. Viegi. 2003. “The need for a focus on air pollution research in the elderly.” Eur Respir J Suppl. 40: 92s–5s. 281 Zanobetti, A., and J. Schwartz. 2001. “Are diabetics more susceptible to the health effects of airborne particles?” Am J Respir Crit Care Med. 164 (5): 831–3.
https://www.atsjournals.org/doi/pdf/10.1164/ajrccm.164.5.2012039. 282 Zanobetti, A., J. Schwartz, and D. Gold. 2000. “Are there sensitive subgroups for the effects of airborne particles?” Environ Health Perspect. 108 (9): 841–5. 170
communities are at risk of experiencing the negative impacts of climate change.283 A report from the California Climate Change Center warned that the impacts of climate change will likely create especially heavy burdens on low-income and other vulnerable populations: “Without proactive policies to address these equity concerns, climate change will likely reinforce and amplify current as well as future socioeconomic disparities, leaving low-income, minority, and politically marginalized groups with fewer economic opportunities and more environmental and health burdens.”284 In the U.S. Environmental Protection Agency’s “Climate Change and Social Vulnerability in the United States: A Focus on Six Impacts,”285 investigators analyzed risks of six primary climate change impacts disproportionately affecting communities across income, educational attainment, race/ethnicity, and age groups. Four socially vulnerable populations—low income, communities of color, no high school diploma, and age 65 and older—were identified as having a higher likelihood of experiencing the greatest impacts of a changing climate (according to the projected 2°C of global warming or 50 centimeters of global sea level rise). Disproportionate impacts were projected for climate events, including air quality, extreme temperature, coastal flooding, and other impacts, leading to increased risk of health and other adverse outcomes. The study projected significant health impacts for low-income communities, certain racial and ethnic subgroups, and those with lower educational attainment.

Several climate vulnerability tools have been developed or are under development to better understand and map areas at higher risk of climate impacts. The Climate Change and Health Vulnerability Indicators (CCHVIs) for California helps state and local health officials prepare for and reduce adverse health impacts due to a changing climate.286 For example, Los Angeles County shows higher than state average climate vulnerability overall, particularly for those who are linguistically isolated (more than twice the state average).

In summary, there are many environmental, social, individual, and economic factors affecting health and equity in California and contributing to worsening health outcomes from climate change impacts. This section and Appendix G (Public Health) reference a substantial and growing body of research documenting the different social and 283 OPR. 2018. Defining Vulnerable Communities in the Context of Climate Adaptation. https://opr.ca.gov/docs/20180723-Vulnerable Communities.pdf. 284 Shonkoff, S., R. Morello-Frosch, M. Pastor, and J. Sadd. 2011. “The climate gap: environmental health and equity implications of climate change and mitigation policies in California—A review of the literature.” Climatic Change 109 (Suppl 1): S485–S503. 285 U.S. EPA. 2021. Climate Change and Social Vulnerability in the United States: A Focus on Six Impacts. U.S. Environmental Protection Agency. EPA 430-R-21-003. 286 CDPH. 2022. Climate Change and Health Vulnerability Indicators for California. California Department of Public Health. https://www.cdph.ca.gov/Programs/OHE/Pages/CC-Health-Vulnerability-Indicators.aspx.

172
area, as well as the directional health benefits, are included in the Summary of Health Benefits section of the chapter and covered in more detail in Appendix G (Public Health).

Heat Impacts
Globally, increased GHG concentrations in the atmosphere are causing a continuing increase of the planet’s average temperature. California temperatures have risen since records began in 1895, and the rate of increase is accelerating. Recent heat waves have broken heat records and caused serious illness across the state, and these events are becoming more frequent. Heat waves have a particularly high impact in Southern California, where they have become more intense and longer lasting. In the past two years, Los Angeles recorded 121°F, and the Coachella Valley had its hottest year ever, with temperatures reaching 123°F. Heat island effects in urbanized areas can elevate heat effects and disproportionately affect low-income communities and communities of color. Heat events exacerbate respiratory and cardiac illness and cause emergency room visits to soar. Strategies that reduce the impacts of heat exposure promote improved health outcomes.

Wildfires and Smoke
California’s NWL cover more than 90 percent of California and include rangeland, forests, woodlands, grasslands, and urban green space. They provide biodiversity and ecosystem benefits, including their ability to sequester carbon from the atmosphere. Protecting and managing California’s forests and other natural lands and maintaining their ecosystem health are key practices for maximizing GHG benefits and minimizing negative climate change impacts. Vegetation plays an important role in storing carbon; however, it can also release CO2 back into the atmosphere when it dies or is burned by fires. California’s wildfires are getting worse with increased fire risks, higher frequency of occurrence, larger burn areas, more costly damage, and a longer fire season due to climate change.

Strategies that promote healthy ecosystem management of natural and working lands and increased urban greening promote improved health outcomes. Healthy ecosystems provide many health and environmental benefits and can maximize carbon sequestration.

Children’s Health and Development
There are a wide range of interconnected environmental, social, biological, and community factors associated with climate change that are adversely affecting children’s health. This section focuses on air pollution and near-roadway or traffic pollution as environmental impacts that have a profound effect on children’s health. Children’s bodies and lungs are still developing, and they take in more air per body weight than adults do.

Many low-income communities and communities of color in California experience disproportionately high levels of air pollution, as well as high levels of traffic and freight that impact children. This excess exposure harms children’s development and 173
predisposes them to increased risk of illness throughout their lives. Strategies that reduce air pollution and traffic emissions promote improved health outcomes for children.

Economic Security
Climate change is expected to result in serious adverse socioeconomic effects across many sectors. Economic factors, such as income inequality (among geographic regions), poverty, wealth, debt, unemployment rate, and job security are among the strongest determinants of health. Along the entire income spectrum, higher income is associated with increased life expectancy and improved health outcomes in the United States.

Additionally, economic insecurity and negative health impacts are more pronounced in low-income communities and communities of color. Economic strategies, such as the promotion of clean energy and other green jobs and investments in low-income communities and communities of color, and promoting a transition to high road jobs in economic sectors tied to the current fossil fuel economy, can promote improved health outcomes.
287
Food Security
The food system is under pressure from numerous factors, and climate change is a key concern. Climate change can affect food production and agricultural yield, impact culturally significant plants and animals for Native American tribes, and exacerbate factors that limit food availability, such as supply chain disruption. Food security is defined as stable access to affordable, sufficient food for an active, healthy life. Many Californians routinely experience food insecurity, and while that impacts Californians of all races and groups, low-income communities and communities of color and children are disproportionately affected by food insecurity. Many Native Americans depend on resources from the land, such as animals and plants for consumption and cultural practices. Strategies that promote sustainable agriculture, access to healthy foods, and reduced organic food waste promote improved health outcomes.

Mobility and Physical Activity
Physical activity is one of the most important factors for a healthy lifestyle, and lack of activity increases the risk of chronic illness and premature death. Research shows that regular physical activity improves health in people of all ages by improving heart and lung 287 According to the California Labor and Workforce Development Agency’s High Road Training Partnership program, high road jobs are considered “Quality jobs [that] provide family-sustaining wages, health benefits, a pension, worker advancement opportunities, and collective worker input and are stable, predictable, safe and free of discrimination.” https://cwdb.ca.gov/wpcontent/uploads/sites/43/2020/08/OneSheet Job-Quality ACCESSIBLE.pdf. 174
function, muscle fitness, mental health and brain function, and sleep quality. A sedentary lifestyle contributes to chronic illnesses, including obesity, heart disease, and Type 2 diabetes among other chronic illnesses. Promoting community design that supports sustainable patterns of land use and transportation enables active transportation choices like walking, biking, and public transit over driving, and can significantly increase physical activity, leading to many valuable health benefits.

Affordable Housing
Housing is an important social determinant of health. The stability of housing, housing quality, conditions inside and outside the home, the cost of housing, and the environmental and social characteristics of the places people live all affect health (including energy efficiency and insulation, cooler building material, tree canopy, home size). Housing affordability is a key factor, and this section highlights how housing affordability supports not only improved health but also more sustainable land use and transportation patterns. A lack of affordable housing is increasing commute distances for low-income renters and creating health burdens. Strategies that support sustainable transportation and housing patterns, together with increased housing affordability, promote improved health outcomes.

Urban Greening
Urban Greening is well recognized as an important amenity, but the inherent health benefits are not always well understood. Under-resourced and vulnerable areas consistently show a lack of urban greening and higher percentages of concrete, asphalt, and impervious surfaces. Under-resourced communities have a greater proportion of concrete and heat-trapping surfaces and a lower amount of tree cover in the neighborhoods in which they live. Areas with reduced urban greening have the potential to create areas of higher temperatures as heat is reflected from pavements and buildings.

By contrast, increasing urban greening can provide air pollution buffers and promote physical activity. Strategies that preserve and create urban parks, green space, natural infrastructure, and sustainable agricultural practices support improved physical and mental health outcomes.

No Action Scenario (Reference)
In a no-action scenario, California would remain dependent on fossil fuels and other GHG emitting technologies. Fossil-fuel powered mobile sources including cars, trucks, trains, tractors, and a myriad of other on-road and off-road vehicles and equipment are the largest source of criteria pollutants and toxic air contaminants that directly affect 175
community health and contribute the largest portion of GHG emissions.288 Other key GHG emission sources include buildings, natural and working lands, and power production and industry. The no-action scenario reflects a continued reliance on fossil fuels in mobile and stationary sectors, including buildings. The continued production and use of fossil fuels; ongoing dependence on gasoline and diesel cars, trucks, buses, and equipment; continued releases of short-lived climate pollutants; and decreased emphasis on forest and ecosystem health will impact communities by reducing climate resilience and health benefits. Green space will likely remain at the same levels or degrade, and urban heat islands will likely increase. With continued growth of vehicle miles traveled, physical activity and the accompanying health benefits will not increase.

Exposure to wildfire smoke will increase, and air quality is expected to worsen as rising temperatures will increase levels of harmful air pollution. Jobs and economic security will be affected by the continuing potential for price spikes in fossil fuels, impacts to the economy from climate change, and fewer job opportunities in green technologies such as solar and electric vehicles. Food security in California will decrease due to the effects of accelerating climate impacts to agriculture; and without increased recovery of organic waste, including food products, food security will continue to decline under a no action scenario. All these impacts can be linked to worse health outcomes. Adverse health impacts are often most felt by Black, Latino, Native American, and other people of color and in low-income communities. These groups are affected more intensely by the physical stress of environmental pollution, social inequities, and the psychological stress of extreme weather events and food and economic insecurity.

Take Action Scenario
In the Take Action scenario, California will drastically reduce reliance on fossil fuels for motor vehicles, freight, buildings, electricity, or other sectors. This scenario is not a specific scenario within this Scoping Plan but examines the broad outcomes of actions to achieve carbon neutrality in 2045. Implementation of this Scoping Plan would achieve a transition to ZEVs, with 100% sales of light-duty ZEVs by 2035 and 100% sales of zero emission trucks by 2040, along with 30% VMT reductions below 2019 levels by 2045.

State and local action that supports sustainable land use and transportation patterns and enables more transit and active transportation will lead to substantial health benefits from physical activity, including reduced illness and deaths. 288 CARB. 2022. California Greenhouse Gas Emissions for 2000 to 2020. https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/2000-2020 ghg inventory trends.pdf. 176
The economic benefits of improved health through active transportation can be modeled using the Healthy Mobility Options Tool (HMOT).289 In order to demonstrate the important health and economic benefits of VMT reduction, CARB and CDPH used the HMOT to analyze an illustrative trip reduction scenario for 2050 from the California Transportation Plan (CTP). The CTP has a goal of increasing active modes of travel and transit from the current level of 13 percent to a level of 23 percent of all travel trips. While the CTP goal of 23 percent for active modes of travel is not a VMT reduction target, the scenario increases active transportation through a mix of changes in land use planning for increased transportation options, including increases in biking, walking, and transit use, and it helps to show the health benefits of increased active transportation. By achieving the CTP 2050 goals, nearly 8,000 deaths would be avoided in 2050 alone (see Figure 3- 14), along with significant reductions in chronic diseases. Achieving this would rank among the top public health accomplishments (see Appendix G [Public Health] for additional modeling results and detailed discussion).

The dramatic reduction in fossil fuel combustion, combined with reductions in VMT and freight and traffic emissions projected in this Scoping Plan will significantly reduce air pollution and its associated health impacts on a statewide basis and in communities near freight sources. Coordinated action strategies will emphasize natural and working lands management changes, including healthy forests, increased vegetative cover, and increased organic farming. Wildfire smoke exposure will reduce significantly with healthy ecosystem management strategies. Since many communities in California are disproportionately impacted by high levels of traffic pollution, the reduction in petroleum fueled vehicles will reduce the additional impacts of living or going to school near historically highly polluting sources. Indoor air quality is also likely to improve through a shift to non-fossil fuel appliances. Concerted state and local action to support sustainable land use and transportation patterns can enable more active transportation with health benefits from physical activity.
289 ITHIM California. 2020. Transportation Planning for Health, Equity, and Climate Change. https://skylab.cdph.ca.gov/HealthyMobilityOptionTool-ITHIM/. 177
Figure 3-14: Quantified health benefits of active transportation from increased physical activity
Overall community resilience is expected to increase as physical activity and green space increases—potentially decreasing urban heat islands. Efforts to support VMT reduction will include coordination across state agencies on affordable housing measures. Reduced fossil fuel dependence will reduce economic pressure from wildfires, droughts, and price spikes in fossil fuels, especially as more jurisdictions implement plans with similar actions.

Investment in sustainable agriculture, healthy forests, urban greening, and clean energy technologies will add sustainable jobs and further promote economic security. More sustainable agriculture and food recovery efforts will add to food security. All these impacts can be linked to wide ranging health benefits, including positive respiratory and cardiovascular effects, healthier birth and brain outcomes, improved mental health indicators, improved life expectancy, reductions in chronic illness and cancers, improved children’s health and development, reduced depression, and other benefits. The magnitude of the possible co-benefits is extremely large, especially in areas that are currently the most affected.

Summary of Health Benefits
Below, Tables 3-14 and 3-15 show overall summaries of the directional benefits by co-benefit area estimated for this Scoping Plan. The supporting epidemiological studies used for qualitative or quantitative analysis of each co-benefit area are included in Appendix G (Public Health). Another section of Chapter 3, together with Appendix C (AB 197 Measure Analysis) and Appendix H (AB 32 GHG Inventory Sector Modeling), also includes the quantitative analysis of air pollution related health impacts, including recently added health endpoints for CARB’s ongoing analysis.

180
In summary, the qualitative health analysis of the No-Action versus Take-Action scenarios for this Scoping Plan shows an overwhelming benefit for the state by taking action to move forward to carbon neutrality while continuing efforts to increase health equity and resilience in individual communities. Taking action can improve physical and mental health for adults and children, reduce a range of chronic illnesses, and promote improvements in life expectancy. Development and implementation of actions to achieve the outcomes called for in this Scoping Plan should consider how to engage affected communities in implementation, address the existing health and opportunity gaps, and pursue equitable implementation statewide and locally. This Scoping Plan deployment of clean technology and fuels, together with improved land management, will reduce GHGs and air pollution and create more resilient communities that are better able to prepare for and recover from extreme climate events.

Environmental Analysis
In May 2022, CARB, as the lead agency for the Scoping Plan, released for public review the Draft Environmental Analysis (Draft EA) for this Scoping Plan; it assessed the potential environmental impacts of implementing the Scoping Plan. CARB circulated the Draft EA for public review and comment for a period of 45 days that began on May 10, 2022, and ended on June 24, 2022. CARB held a public hearing on June 23, 2022 to provide the opportunity for public comment. During the review period, written and oral comments were received on the Draft EA. CARB reviewed the comments to identify environmental topics and began preparation of responses to those comments.

After the end of the Draft EA public review period, CARB identified potential revisions to certain aspects of this Scoping Plan that merit revisions to the project description. This new information results from, among other things, revisions to the project description regarding energy sector goals (including offshore wind), revised carbon removal targets, and additional strategies for natural and working lands. CARB released a Recirculated Draft EA for a written public comment period that started September 9, 2022, and ended on October 24, 2022. See Chapter 2 of the Recirculated Draft EA290 for further information regarding the changes. The Recirculated Draft EA assesses the potential for significant adverse and beneficial environmental impacts associated with all proposed actions in this Scoping Plan, and provides a programmatic environmental analysis of the reasonably foreseeable compliance responses that could result from implementation of the Scoping 290 CARB. 2022. Recirculated Draft EA. https://ww2.arb.ca.gov/sites/default/files/2022-09/2022-draft-spappendix-b-draft-ea-recirc.pdf. 181
Plan.291 The Recirculated Draft EA concluded implementation of this Scoping Plan could result in the following:
• Beneficial impacts to: air quality (long-term operational-related) and GHG emissions (short-term construction-related and long-term operational-related) • Less than significant impacts to: energy demand, mineral resources, population and housing, public services, recreation (short-term construction-related), and wildfire (short-term construction-related)
• Potentially significant and unavoidable adverse impacts to: aesthetics, agriculture and forest resources, air quality (construction-related and operational odors), biological resources, cultural resources, geology and soils, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, recreation (long-term operational-related), transportation and traffic, tribal cultural resources, utilities and service systems, and wildfire (long-term operational-related Before the public meeting at which the Board will consider this Scoping Plan Update, CARB will publish the Final EA as Appendix B (Final Environmental Analysis) to this Scoping Plan, along with written responses to timely submitted comments raising significant environmental issues received on the Draft EA and the Recirculated Draft EA, which will be presented to the Board for consideration. 291 The Recirculated Draft EA is available at https://ww2.arb.ca.gov/our-work/programs/ab-32-climatechange-scoping-plan/2022-scoping-plan-documents. 182
Chapter 4: Key Sectors
Chapter 4 provides an overview of the major energy sources and technology in use today, and of alternative clean technology and fuels to support decarbonization based on the latest information available. Every sector of the economy will need to begin to transition in this decade to meet our GHG reduction goals and achieve carbon neutrality no later than 2045. AB 32 requires climate change mitigation policies to be considered in the context of the sector’s contribution to the state’s total GHG emissions. The transportation, electricity (in-state and imported), and industrial sectors are the largest contributors of GHGs in the state and present the largest opportunities for GHG reductions. Actions to reduce fossil fuel combustion in these sectors also can provide critical air pollution reductions in low-income communities and communities of color, which are often located adjacent to these sources. A carbon neutrality framework also elevates the role of CO2 removal through natural and working lands and mechanical capture and storage. Actions that support energy efficiency, reduced VMT, alternative fuels, and renewable power also can provide benefits by reducing both criteria and toxic air pollutants.

What sets this plan apart from previous Scoping Plans is the focus on the accelerated rate of deployment of clean technology and energy within every sector. As a result, specific actions, including accelerated rates of deployment of clean technology and fuels identified within this Scoping Plan, will need to be translated into both new and amended regulations, policies, and incentive programs. State agencies will need to evaluate current authority to align existing policies or develop new ones to achieve outcomes called for in this Scoping Plan. Legislative support may be needed in some cases to ensure authority and funding is sufficient to ensure this Scoping Plan is translatable to action on the ground. Most regulations, or change to existing regulations, ultimately considered by the Board or other state agencies for adoption will be subject to administrative procedure requirements. Accordingly, they must rely on specific subsequent supporting analysis and extensive public processes and consultations with interested tribes to develop and identify appropriate proposals for effective implementation. For example, any proposal to strengthen the LCFS regulations through amendments increasing the stringency of the carbon intensity (CI) targets would be considered on the basis of a public process, including workshops, and focused environmental, economic, and public health analyses.

Policies that ensure economy-wide investment or program decisions that incorporate consideration of GHG emissions are particularly important. As we pursue GHG reduction targets, we must acknowledge the manner in which built and natural environments are connected, how changes in one may impact the other, and how policy choices in one sector can and do impact other sectors. For example, fostering more compact, transportation-efficient development in infill areas and increasing transportation choices with the goal of reducing VMT not only reduces demand for transportation fuel but also requires less energy for buildings and helps to conserve natural and working lands that 183
sequester carbon. Therefore, the multiple and often interwoven actions that reduce VMT both reduce emissions from the transportation sector and support reductions needed in other sectors.

Legislation, such as SB 350292 (De León and Leno, Chapter 457, Statutes of 2015), has recognized the need for CARB, the CEC, and the CPUC to work together to ensure the state’s energy and climate goals are integrated in procurement decisions by load serving entities as part of Integrated Resource Plans. Moving forward, it is especially critical that similar approaches are adopted to break down silos across state agencies to ensure policies and programs are aligned with multiple state priorities outlined in this plan. Finally, supportive legislative direction, such as SB 905 that requires CARB to create the Carbon Capture, Removal, Utilization, and Storage Program, may also benefit emerging areas of policy to provide express agency authority and roles for these nascent efforts, including streamlining of permitting, while ensuring that protections for communities are in place.

Unlike previous Scoping Plans that separated out individual economic sectors, this Scoping Plan approaches decarbonization from two perspectives: (1) managing a phasedown of existing energy sources and technology and (2) ramping up, developing, and deploying alternative clean energy sources and technology over time. This approach supports a more comprehensive consideration of our energy infrastructure, the ability to repurpose existing assets, and the need to build new assets. It also provides multiple metrics beyond just the annual AB 32 GHG Inventory to better enable tracking progress.

For example, it clearly demonstrates the production and distribution rates of specific types of clean energy, such as adding 4.3 GW of utility solar and 2.5 GW of storage year-overyear between now and 2035 to be on track to achieve carbon neutrality no later than 2045, and does the same for technology deployment, such as 11 million ZEVs in 2035.

The sections below include key actions to support success in the necessary transition away from fossil combustion, which is an overriding goal of this plan. The wide array of complementary and supporting actions being contemplated or to be undertaken across state government are detailed here. The broad view of actions described in this chapter thus provides context for the specific deployment of clean technology and fuels identified in the Scoping Plan Scenario described in Chapter 2. Actions identified in this Scoping Plan are based on currently known options and the latest science. As part of future Scoping Plan updates, additional clean technology and fuels may be identified and added to the mix of needed tools to continue to reduce the state’s GHG emissions, support air quality co-benefits, and remove carbon from the atmosphere. 292 California Air Resources Board. SB 350 Electricity Sector Greenhouse Gas Planning Targets. https://ww2.arb.ca.gov/our-work/programs/sb350.
184
Transportation Sustainability
The transportation sector has long relied on liquid petroleum fuels as the primary energy source for internal combustion engine (ICE) vehicles, including cars, trucks, locomotives, marine equipment, and aircraft. Combustion of fossil fuels in vehicles emits significant amounts of GHGs, criteria pollutants, and toxic air contaminants. In 2019, 293 the
transportation sector accounted for approximately 50 percent of statewide GHG emissions294 and thus was by far the single largest source of carbon pollution in the state.

In addition, the transportation sector accounted for over 80 percent of statewide NOx emissions and 30% of fine particulate matter emissions, including toxic diesel particulate matter.295
Communities adjacent to congested roadways, including ports and distribution centers, are exposed to the highest concentration of toxic pollutants from vehicles and equipment consuming fossil fuels, leading to a number of demonstrated health impacts such as respiratory illnesses, higher likelihood of cancer development, and premature death. In addition, communities located near oil extraction operations or crude oil refineries often experience higher exposure to poor air quality. While CARB’s programs, along with local action, have made substantial progress over the past few decades, it is clear that California must transition away from fossil fuels to zero-emission technologies with all possible speed and pursue policies that result in less driving, in order to meet our GHG and air quality targets.

The transportation sector can be divided into three general categories: Technology, Fuels, and Vehicle Miles Traveled.
• Technology refers to the vehicles themselves, as well as the associated refueling infrastructure for those vehicles.
• Fuels refers to the energy source used to power vehicles and the facilities that produce them.
• Vehicle travel is measured as vehicle miles traveled (VMT), and is a product of development patterns and available transportation options. 293 In 2020 the state experienced shelter-in-place orders in response to the COVID-19 pandemic. The orders, and the effects of the pandemic, led to a significant year-over-year decline in transportation emissions in 2020. This means 2019 is likely a more representative year for overall transportation emissions and 2020 a likely outlier in the historical transportation emissions trend data. 294 CARB. 2022. California Greenhouse Gas Emissions for 2000 to 2020. https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/2000-2020_ghg_inventory_trends.pdf. This includes upstream oil extraction and refining emissions. 295 CARB. California Greenhouse Gas Emission Inventory Program. https://ww2.arb.ca.gov/ourwork/programs/ghg-inventory-program. 185

Sector Transition
Technology
Vehicles must transition to zero emission technology to decarbonize the transportation sector. Executive Order N-79-20296 reflects the urgency of transitioning to zero emission vehicles (ZEVs) by establishing target dates for reaching 100 percent ZEV sales or fleet transitions to ZEV technology. The primary ZEV technologies available today are batteryelectric and hydrogen fuel cell electric vehicles (FCEVs), both of which emit zero tailpipe GHGs, criteria pollutants, and toxic air contaminants, as they do not burn fuel. These vehicles are rapidly growing in performance, affordability, and popularity.297 Plug-in hybrid electric vehicles also offer a limited but increasing range of zero emission operation and will play a role in the transition to ZEVs.

Light-duty passenger vehicles consume the majority of gasoline in the state—12.9 billion gallons in 2019298—and are well-suited for transitioning to ZEVs.

EO N-79-20 calls for 100 percent ZEV sales of new light-duty vehicles by 2035, and this target is reflected in this Scoping Plan.299 The Advanced Clean Cars II regulation fulfills the goal in the Executive Order and serves as the primary mechanism to help deploy ZEVs. A number of existing incentive programs also support this transition, including the Clean Cars 4 All Program.300 Heavy-duty trucks are the largest source of diesel particulate matter, a toxic air contaminant that is directly linked to a number of adverse health impacts, and EO N-79-20 also sets targets for transitioning the medium- and heavy-duty fleet to zero emissions: by 2035 for drayage trucks and by 2045 for buses and heavyduty long-haul trucks where feasible. Replacing heavy-duty vehicles with ZEV technology will significantly reduce GHG emissions and diesel PM emissions in low-income communities and communities of color adjacent to ports, distribution centers, and highways. The existing Advanced Clean Trucks regulation, paired with the proposed Advanced Clean Fleets regulation, are designed to transition a significant amount of the 296 Executive Department. State of California. Executive Order N-79-20. https://www.gov.ca.gov/wpcontent/uploads/2020/09/9.23.20-EO-N-79-20-Climate.pdf. 297 CARB. 2021. Public Workshop for Advanced Clean Cars II. May 6. https://ww2.arb.ca.gov/sites/default/files/2021-05/acc2 workshop slides may062021 ac.pdf. 298 CARB. 2022. Fuel Activity for California’s Greenhouse Gas Inventory by Sector and Activity. https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/fuel_activity_inventory_by_sector_all_00-

20.xlsx. 299 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, F1A, with reference to the date at which all new vehicle sales are ZEVs. finalejacrecs.pdf (arb.ca.gov). 300 CARB. Clean Cars 4 All. https://ww2.arb.ca.gov/our-work/programs/clean-cars-4-all. The Clean Vehicle Rebate Project (CVRP) also supports the transition to ZEVs. https://cleanvehiclerebate.org/en. 186
California truck fleet to ZEV technology. As with the LDV sector, a number of incentive programs support this transition, such as the Hybrid and Zero-Emission Truck and Bus Voucher Incentive Project (HVIP).301
Figure 4-1 below illustrates the pace of transition in vehicle technology needed to drastically reduce GHG emissions from vehicles. All vehicle classes reach 100 percent ZEV sales before 2045, with some achieving this well before. The ZEV technology across the vehicle classes is assumed to be primarily battery electric and hydrogen fuel cell (reflecting the primary ZEV technologies available today).302 Figure 4-1: Transition of on-road vehicle sales to ZEV technology in the Scoping Plan Scenario
Today, off-road vehicles also rely heavily on ICE technology. Executive Order N-79-20 sets an off-road equipment target of transitioning the entire fleet to ZEV technology by 2035, where feasible. There is a great need for both investment and innovation in the offroad space in order to develop and commercialize zero emission equipment types that meet or exceed the performance of existing equipment. A number of funding sources currently support this transition, including programs such as FARMER, Carl Moyer, and 301 California HVIP. Hybrid and Zero-Emission Truck and Bus Voucher Incentive Project. https://californiahvip.org/?msclkid=efaf65f2c26f11eca6bdd08ecc323864. 302 The light-duty fleet includes more than 11 million battery electric and hydrogen fuel cell vehicles in 2035 and over 23 million battery electric and hydrogen fuel cell vehicles in 2045. 0%
20%
40%
60%
80%
100%
120%
2020 2025 2030 2035 2040 2045
Percent of Total New Vehicle Sales
LD ZEV Sales Share
MD ZEV Sales Share
HD ZEV Sales Share
187
the Community Air Protection Incentives—as well as Low Carbon Transportation Incentives, including the Clean Off-Road Equipment (CORE) program. In addition, the 2021–22 California budget provided record-high allocations for funding ZEVs, including off-road equipment, and the 2022–23 budget is similarly ambitious.303 Several regulations focused on transitioning to zero emission off-road equipment have recently been adopted or are in the works, and apply to locomotives,304 forklifts, ocean-going vessels at berth,305 commercial harbor craft,306 small off-road engines,307 and more.

Intrastate aviation relies on ICE technology today, but battery-electric and hydrogen fuel cell aviation applications are in development, along with sustainable aviation fuel. The Scoping Plan Scenario includes a transition of 20% of aviation fuel demand to ZEV technologies by 2045 and sustainable aviation fuel for the rest.

Refueling infrastructure is a crucial component of transforming transportation technology.

Electric vehicle chargers and hydrogen refueling stations must become easily accessible for all drivers to support a wholesale transition to ZEV technology. Deployment of ZEV refueling infrastructure is currently supported by a number of existing local and state public funding mechanisms, the new National Electric Vehicle Infrastructure (NEVI) federal funding mechanism, California’s electric utilities, the Electrify America initiative that was established in response the Volkswagen ZEV commitment, and by numerous companies, such as EVgo, ChargePoint, Tesla, Ford, FirstElement Fuel, Chevron, Shell, and Iwatani, who are investing substantial private resources into developing these networks. Private investment in reliable, affordable and ubiquitous refueling infrastructure must drive the transition as the business case for ZEVs continues to strengthen.

Strategies for Achieving Success
• Achieve 100 percent ZEV sales of light-duty vehicles by 2035308 and mediumheavy-duty vehicles by 2040. • Achieve a 20% zero emission target for the aviation sector. 303 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, F1C. CARB and the Administration are committed to increasing focus on transportation equity investment as was reflected in the governor’s 2022–23 budget. finalejacrecs.pdf (arb.ca.gov). 304 CARB. Reducing Rail Emissions in California. https://ww2.arb.ca.gov/our-work/programs/reducing-railemissions-california. 305 CARB. Ocean-Going Vessels At Berth Regulation. https://ww2.arb.ca.gov/our-work/programs/oceangoing-vessels-berth-regulation. 306 CARB. CARB passes amendments to commercial harbor craft regulation. https://ww2.arb.ca.gov/news/carb-passes-amendments-commercial-harbor-craft-regulation. 307 CARB. Small Off-Road Engines (SORE). https://ww2.arb.ca.gov/our-work/programs/small-off-roadengines-sore. 308 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, F1A. finalejacrecs.pdf (arb.ca.gov).
188
• Develop a rapid and robust network of ZEV refueling infrastructure to support the needed transition to ZEVs.
• Ensure that the transition to ZEV technology is affordable for low-income households and communities of color, and meets the needs of communities and small businesses.309
• Prioritize incentive funding for heavy-duty ZEV technology deployment in regions of the state with the highest concentrations of harmful criteria and toxic air contaminant emissions.310
• Promote private investment in the transition to ZEV technology, undergirded by regulatory certainty such as infrastructure credits in the Low Carbon Fuel Standard for hydrogen and electricity311 and hydrogen station grants from the CEC’s Clean Transportation Program312 pursuant to Executive Order B-48-18.313 • Evaluate and continue to offer incentives similar to those through FARMER,314 Carl Moyer,315 the Clean Fuel Reward Program,316 the Community Air Protection Program,
317 and Low Carbon Transportation,318 including CORE.319 Where feasible, prioritize and increase funding for clean transportation equity programs.320
• Continue and accelerate funding support for zero emission vehicles and refueling infrastructure through 2030 to ensure the rapid transformation of the transportation sector.
309 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, NF6, in the context of communities. finalejacrecs.pdf (arb.ca.gov). 310 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, NF7. finalejacrecs.pdf (arb.ca.gov). 311 CARB. LCFS ZEV Infrastructure Crediting. https://ww2.arb.ca.gov/resources/documents/lcfs-zevinfrastructure-crediting. 312 CEC. Clean Transportation Program. https://www.energy.ca.gov/programs-and-topics/programs/cleantransportation-program. 313 EO B-48-18 calls for 200 hydrogen refueling stations by 2025. https://www.library.ca.gov/wpcontent/uploads/GovernmentPublications/executive-order-proclamation/39-B-48-18.pdf. 314 CARB. FARMER program. https://ww2.arb.ca.gov/our-work/programs/farmer-program. 315 CARB. Carl Moyer program. https://ww2.arb.ca.gov/our-work/programs/carl-moyer-memorial-airquality-standards-attainment-program. 316 California Clean Fuel Reward Program. https://cleanfuelreward.com/. 317 CARB. Community Air Protection Program. https://ww2.arb.ca.gov/capp. 318 CARB. Low Carbon Transportation Investments and Air Quality Improvement Program. https://ww2.arb.ca.gov/our-work/programs/low-carbon-transportation-investments-and-air-qualityimprovement-program. 319 Clean Off-Road Equipment (CORE) Voucher Incentive Program. https://californiacore.org/. 320 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, F1C. finalejacrecs.pdf (arb.ca.gov).
189
• Evaluate and align with this Scoping Plan relevant CARB policies such as Advanced Clean Cars II,321 Innovative Clean Transit,322 Zero Emission Airport Shuttle,323 California Phase 2 GHG Standards,324 Advanced Clean Trucks, Advanced Clean Fleets, Zero Emission Forklifts,325 In-use Locomotives,326 the OffRoad Zero-Emission Targeted Manufacturer rule, Clean Off-Road Fleet Recognition Program, In-use Off-Road Diesel-Fueled Fleets Regulation,327 Commercial Harbor Craft,328 Off-Road Zero-Emission Targeted Manufacturer rule, Clean Off-Road Fleet Recognition Program, Amendments to the In-use Off-Road Diesel-Fueled Fleets Regulation,
329 carbon pricing through the Cap-and-Trade
Program,330 and the Low Carbon Fuel Standard.331
• Identify and address permitting and market barriers to successful rapid ZEV technology deployment while protecting public health and the environment.

Fuels
Transitioning away from conventional ICE vehicles is part of the solution, but we must ensure that an adequate supply of zero-carbon alternative fuel and distribution is available to power these vehicles. Electricity and hydrogen are currently the primary fuels for ZEVs, 321 CARB. Advanced Clean Cars Program. https://ww2.arb.ca.gov/our-work/programs/advanced-cleancars-program. Cal. Code Regs., tit. 13, §§ 1900, 1961.2, 1961.3, 1961.4, 1962.2, 1962.3, 1962.4, 1962.5, 1962.6, 1962.7, 1962.8, 1965, 1968.2, 1969, 1976, 1978, 2037, 2038, 2112, 2139, 2140, 2147, 2317, 2903.
322 CARB. Innovative Clean Transit. https://ww2.arb.ca.gov/our-work/programs/innovative-clean-transit.

Cal. Code Regs., tit. 13, §§ 2023—2023.11. 323 CARB. Zero-Emission Airport Shuttle. https://ww2.arb.ca.gov/our-work/programs/zero-emissionairport-shuttle. Cal. Code Regs., tit. 17, §§ 95690.1—95690.8. 324 CARB. California Phase 2 Greenhouse Gas Standards. https://ww2.arb.ca.gov/ourwork/programs/greenhouse-gas-standards-medium-and-heavy-duty-engines-and-vehicles/phase2. Cal.

Code Regs., tit. 13, §§ 1956.8 and 2036; and Cal. Code Regs., tit. 17, §§ 95301, 95302, 95303, and 95663. 325 CARB. Zero-Emission Forklifts. https://ww2.arb.ca.gov/our-work/programs/zero-emission-forklifts. Cal.

Code Regs., tit. 17, §§ 95690.1—95690.8. 326 CARB. Reducing Rail Emissions. https://ww2.arb.ca.gov/our-work/programs/reducing-rail-emissionscalifornia. Proposed Cal. Code Regs., tit. 13, §§ 2478—2478.16. 327 CARB. In-use Off-Road Diesel-Fueled Fleets Regulation. https://ww2.arb.ca.gov/ourwork/programs/use-road-diesel-fueled-fleets-regulation. Cal. Code Regs., tit. 13, §§ 2449, 2449.1, 2449.2.
328 CARB. Commercial Harbor Craft. https://ww2.arb.ca.gov/our-work/programs/commercial-harbor-craft.

Cal. Code Regs., tit. 13, § 2299.5.
329 CARB. In-use Off-Road Diesel-Fueled Fleets Regulation. https://ww2.arb.ca.gov/ourwork/programs/use-road-diesel-fueled-fleets-regulation. 330 CARB. Cap-and-Trade Program. https://ww2.arb.ca.gov/our-work/programs/cap-and-trade-program.

Cal. Code Regs., tit. 17, §§ 95801 et seq. 331 CARB. Low Carbon Fuel Standard. https://ww2.arb.ca.gov/our-work/programs/low-carbon-fuelstandard. Cal. Code Regs., tit. 17, §§ 95480 et seq.

191
alternatives and has fostered a growing alternative fuel market. Partially as a result of the powerful market signals from the LCFS, fuels like renewable diesel, sustainable aviation fuel, biomethane, and electricity have all gained significant market shares and continue to displace gasoline and diesel in both on- and off-road vehicles. In addition, Executive Order N-79-20 calls on state agencies to support the transition of existing fuel production facilities away from fossil fuels and directs that this transition also protect and support workers, public health, safety, and the environment. In line with this direction, existing refineries could be repurposed to produce sustainable aviation fuel, renewable diesel, and hydrogen. This trend has already begun, and continuing to develop fuel production capacity in-state to support the energy transition while making the most efficient use of existing assets is critical to avoiding emissions leakage. If fuel demand persists after fuel production facilities have ceased operations, fuel demand will have to be met through imports.

As we transition or build new energy production facilities and infrastructure, it will be important to ensure low-income communities, tribes, and communities of color do not experience increases in existing air pollution disparities and continue to experience a reduction in the air pollution disparities that exist today. California must use the best available science to ensure that raw materials used to produce transportation fuels do not incentivize feedstocks with little to no GHG reductions from a life cycle perspective. A dramatic increase in alternative fuel production must not come at the expense of global deforestation, unsustainable land conversion, or adverse food supply impacts, to name a few examples. CARB will continue to monitor scientific findings on these topics to ensure that California policies, such as the LCFS, send the appropriate market signals and do not result in unintended consequences.333
Strategies for Achieving Success
• Accelerate the reduction and replacement of fossil fuel production and consumption in California.334
• Incentivize private investment in new zero-carbon fuel production in California. • Incentivize the transition of existing fuel production and distribution assets to support deployment of low- and zero-carbon fuels while protecting public health and the environment.
• Invest in the infrastructure to support reliable refueling for transportation such as electricity and hydrogen refueling.
333 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, F1E. finalejacrecs.pdf (arb.ca.gov). 334 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, F3. finalejacrecs.pdf (arb.ca.gov).
192
• Evaluate and propose, as needed, changes to strengthen the Cap-and-Trade Program.
• Initiate a public process focused on options to increase the stringency and scope of the LCFS:
o Evaluate and propose accelerated carbon intensity targets pre-2030 for LCFS.
o Evaluate and propose further declines in LCFS post-2030 carbon intensity targets to align with this 2022 Scoping Plan.
o Consider integrating opt-in sectors into the program. o Provide capacity credits for hydrogen and electricity for heavy-duty fueling. • Monitor for and ensure that raw materials used to produce low-carbon fuels or technologies do not result in unintended consequences.335 Vehicle Miles Traveled
Transforming the transportation sector goes beyond phasing out combustion technology and producing cleaner fuels. Managing total demand for transportation energy by reducing the miles people need to drive on a daily basis is also critical as the state aims for a sustainable transportation sector in a carbon neutral economy. Though GHG emissions are declining due to cleaner vehicles and fuels, rising VMT can offset the effective benefits of adopted regulations.

Even under full implementation of Executive Order N-79-20 and CARB’s Advanced Clean Cars II Regulations, with 100 percent ZEV sales in the light-duty vehicle sector by 2035, a significant portion of passenger vehicles will still rely on ICE technology, as demonstrated in Figure 4-2 above. Accordingly, VMT reductions will play an indispensable role in reducing overall transportation energy demand and achieving the state’s climate, air quality, and equity goals. After a significant pandemic-induced reduction in VMT during 2020, passenger VMT has steadily climbed back up and is now closing in on pre-pandemic levels.336 Driving alone with no passengers remains the primary mode of travel in California, amounting to 75 percent of the mode share for daily commute trips. Conversely, the transit industry, which was significantly impacted during 335 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, F1E. finalejacrecs.pdf (arb.ca.gov). 336 U.S. Department of Transportation. 2021. December 2021 Traffic Volume Trends. Figure 3 - Seasonally Adjusted Vehicle Miles Traveled by Month.
https://www.fhwa.dot.gov/policyinformation/travel monitoring/21dectvt/figure3.cfm. 193
the lockdown months, and has struggled to recover; ridership only averages two-thirds of pre-pandemic levels,337 338 and service levels also lag behind.

Sustained VMT reductions have been difficult to achieve for much of the past decade, in large part due to entrenched transportation, land use, and housing policies and practices.

Specifically, historic decision-making favoring single-occupancy vehicle travel has shaped development patterns and transportation policy, generating further growth in driving (and making transit, biking and walking less viable alternatives). These policies have also reinforced long-standing racial and economic injustices that leave people with little choice but to spend significant time and money commuting long distances, placing a disproportionate burden on low-income Californians, who pay the highest proportion of their wages on housing and transportation. While CARB has included VMT reduction targets and strategies in the Scoping Plan and appendices, these targets are not regulatory requirements, but would inform future planning processes. CARB is not setting regulatory limits on VMT in the 2022 Scoping Plan; the authority to reduce VMT largely lies with state, regional, and local transportation, land use, and housing agencies, along with the Legislature and its budgeting choices.

Appendix E (Sustainable and Equitable Communities) elaborates on reasons for reducing VMT and identifies a series of policies that, if implemented by various responsible authorities, could help to achieve the recommended VMT reduction trajectory included in this Scoping Plan (and related mode share increases for transit and active transportation).

These policies aim to advance four strategic objectives:

1. Align current and future funding for transportation infrastructure with the state’s climate goals, preventing new state-funded projects from inducing significant VMT growth and supporting an ambitious expansion of transit service and other multimodal alternatives.

2. Move funding for transportation beyond the gasoline and diesel taxes and implement fuel-agnostic pricing strategies that accomplish more productive uses of the roadway network and generate revenues to further improve transit and other multimodal alternatives.

3. Deploy autonomous vehicles, ride-hailing services, and other new mobility options toward high passenger-occupancy and low VMT-impact service models that complement transit and ensure equitable access for priority populations.

4. Encourage future housing production and multi-use development in infill locations and other areas in ways that make future trip origins and destinations 337 U.S. Government Accountability Office. January 25, 2022. During COVID-19, Road Fatalities Increased and Transit Ridership Dipped. https://www.gao.gov/blog/during-covid-19-road-fatalitiesincreased-and-transit-ridership-dipped. 338 American Public Transportation Association. APTA - Ridership Trends. https://transitapp.com/APTA. 194
closer together and create more viable environments for transit, walking, and biking.

The pace of change to reduce VMT must be accelerated. Certainly, structural reform will be challenging, but California has demonstrated time and again that it possesses the collective leadership and commitment to break away from ideas that no longer represent Californians’ values and their aspirations for the many generations to come.

Strategies for Achieving Success
• Achieve a per capita VMT reduction of at least 25 percent below 2019 levels by 2030 and 30 percent below 2019 levels by 2045. 339
• Reimagine new roadway projects that decrease VMT in a way that meets community needs and reduces the need to drive.
• Invest in making public transit a viable alternative to driving by increasing affordability, reliability, coverage, service frequency, and consumer experience.340 • Implement equitable roadway pricing strategies based on local context and need, reallocating revenues to improve transit, bicycling, and other sustainable transportation choices.341
• Expand and complete planned networks of high-quality active transportation infrastructure.342
• Channel the deployment of autonomous vehicles, ride-hailing services, and other new mobility options toward high passenger-occupancy and low VMT-impact service models that complement transit and ensure equitable access for priority populations.
• Streamline access to public transportation through programs such as the California Integrated Travel Project.
• Ensure alignment of land use, housing, transportation, and conservation planning in adopted regional plans, such as regional transportation plans (RTP)/ sustainable communities strategies (SCS), regional housing needs assessments (RHNA), and local plans (e.g., general plans, zoning, and local transportation plans), and develop tools to support implementation of these plans. 339 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, F1D. finalejacrecs.pdf (arb.ca.gov). 340 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, F1D. finalejacrecs.pdf (arb.ca.gov). 341 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, F1D. finalejacrecs.pdf (arb.ca.gov). 342 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, F1F. finalejacrecs.pdf (arb.ca.gov).
195
• Accelerate infill development and housing production at all affordability levels in transportation-efficient places, with a focus on housing for lower-income residents.

Clean Electricity Grid
Much of the state’s success to date in reducing GHGs is due to decarbonization of the electricity sector as a result of the RPS, SB 100 implementation, and the Cap-and-Trade Program. Moving forward, a clean, affordable, and reliable electricity grid will serve as a backbone to support deep decarbonization across California’s economy. Under this Scoping Plan, the role of electricity in powering the economy will grow in almost every sector.

In 2021, 70 percent of California electricity demand was served by in-state power plants totaling about 82 GW, with the rest coming from out-of-state imports.343 Additionally, approximately 8 GW of customer solar photovoltaic capacity has been installed to date to help with in-state demand.344 Figure 4-3 shows the breakdown of in-state and imported sources of electricity.
343 CEC. 2021. Electric Generation Capacity and Energy. Data available at:
https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/electric-generationcapacity-and-energy and CEC. 2021. Total System Electric Generation. Data available at:
https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/2021-total-systemelectric-generation. Capacity values are nameplate capacity from sources 1 MW and larger. 344 CEC. 2021. SB 100 Joint Agency Report Summary: Achieving 100% Clean Electricity in California, An Initial Assessment. 10. https://www.energy.ca.gov/publications/2021/2021-sb-100-joint-agency-reportachieving-100-percent-clean-electricity.

197
same time, the state continues to rapidly expand deployment of clean energy generation and storage resources and plan for increased electrification.348 This is critical to reducing GHG emissions and addressing the long-term impacts of climate change.

Climate change is causing unprecedented stress on California’s energy system—driving high demand and constraining supply. Heat, drought, and wildfires can both reduce electricity supply from reductions in hydropower generation and impacts on generation and transmission performance, and increase demand, especially in the evening hours when solar generation is declining.

California has experienced three straight years of energy reliability challenges, including a multi-day extreme heat event across the western United States with temperatures up to 20 degrees above normal in California, resulting in rotating outages in August 2020. In 2021, heat waves in June prompted a Grid Warning and the onset of emergency conditions, and the Bootleg Fire caused the loss of one transmission line, reducing import capability by 3,000 megawatts into the California Independent System Operator (CAISO) balancing authority area. And from August 31–September 9, 2022, a 10-day extreme heat event resulted in an unprecedented, sustained period of high peak loads in the CAISO system, averaging 47,000 MW and maxing at an all-time record of over 52,000 MW on September 6. The Western region also hit its record peak load on September 6, at 167.5 GW.

Reliable electricity service was maintained throughout the 10-day September 2022 heat wave in spite of the record breaking load levels. Factors that contributed to this outcome include the installation of over 3,500 MW of lithium-ion battery storage since summer 2020, enhanced coordination and communication within and outside of California, engagement with customer groups and other stakeholders, state actions to reduce load during critical times, and the additional capacity provided through the Strategic Reliability Reserve and other new state programs authorized in the 2022 Budget to provide load reduction and support the grid in extreme events. CEC, CPUC, CAISO, and the California Department of Water Resources will continue to build out strategies to enhance reliability in light of the increasing and compounding impacts of climate change on the electricity system.
348 In June 2021, the CPUC adopted D.21-06-035 directing procurement of 11,500 MW of new capacity between 2023 and 2026 to ensure systemwide electric reliability as Diablo Canyon and several OTC facilities retire. It requires that, out of the 11,500 MW, 2,500 MW must be from zero-emission resources.

Additionally, 2,000 MW must be long lead-time resources, with at least 1,000 MW of long-duration storage and 1,000 MW of firm capacity with zero on-site emissions or that qualifies under the RPS eligibility requirements.
198
While the electricity sector is using less fossil fuel due to increasing amounts of renewables,349 existing fossil gas generation will continue to play a critical role in grid reliability until other clean, dispatchable alternatives can be deployed at scale. The integration of greater amounts of variable renewable generation resources350 is changing power system planning and operations, and system operators need resources with flexible attributes to balance shifting supply and demand.

High levels of solar generation can lead to instances of oversupply during the middle of the day, when the sun is brightest.351 In the evening hours, as the sun is setting, solar generation declines to zero and customers with solar generation shift back to the electric grid. In hot weather, customer demand remains high well into the summer evening period to power air conditioning, which can lead to reliability challenges. 352
Figure 4-4 shows the energy sources used throughout one summer day in July.

Renewable energy is consistent during the middle of the day, but it cannot meet all of the evening demand in the gray area. As illustrated in the figure, fossil gas generation is currently a resource that is typically ramped up to meet this evening demand as solar production begins to drop and electrical loads increase To help address this challenge, resource installations that pair solar with batteries, as well as a greater amount of battery build-out, are coming online currently and over the next five years. Nevertheless, the state’s electricity grid is expected to be stressed further in the coming years by heat waves, drought, wildfires, and the growing intermittent power supply from renewables.

California must accelerate deployment of diverse clean energy resources to maintain reliability and affordability in the face of climate change. 349 CARB. 2022. California Greenhouse Gas Emissions for 2000 to 2020. https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/2000-2020 ghg inventory trends.pdf. 350 A variable renewable generation resource is a renewable source of electricity that is non-dispatchable due to its fluctuating nature and only produces electricity when weather conditions are right, such as when the sun is shining or the wind is blowing. Renewable resources that can be controlled and are dispatchable include geothermal, biomass, and dam-based hydroelectric power. 351 Brightness is used colloquially here; solar energy depends on insolation (e.g., sun-hours), which is the measurement of cumulative solar energy that reaches an area over a period of time. 352 CAISO, CPUC, and CEC. 2021. Final Root Cause Analysis: Mid-August 2020 Extreme Heat Wave. http://www.caiso.com/Documents/Final-Root-Cause-Analysis-Mid-August-2020-Extreme-Heat-Wave.pdf.

200
SB 100’s policy framework to require renewable and zero-carbon resources to supply 90 percent of all retail electricity sales by 2035 and 95 percent of all electricity retail sales by 2040; the governor has asked the CEC to establish a planning goal of at least 20 GW of offshore wind by 2045; and the governor directed that state agencies plan for an energy transition that avoids the need for new fossil gas capacity to meet California’s long-term energy goals.356 In addition to grid-level resources, state efforts have supported rapid growth of the distributed solar industry through key actions like the California Solar Initiative (SB 1, Murray, Chapter 132, Statues of 2006).357 Steps to commercialize microgrids powered by clean resources358 are also being examined as part of SB 1339 (Stern, Chapter 566, Statutes of 2018).359
California also continues to advance its appliance and building energy efficiency standards to reduce growth in electricity consumption and meet the SB 350 goal to double statewide energy efficiency savings in electricity and fossil gas end uses360 by 2030. In 2018, the CEC adopted a building energy efficiency code requiring most new homes to have solar photovoltaic systems361 (or be powered by a solar array nearby) starting January 1, 2020. In 2019, California reached the milestone of 1 million solar rooftop installations.

Increased transportation and building electrification and continued policy commitment to behind-the-meter solar and storage will continue to drive growth of microgrids and other distributed energy resources (DER).362 The CPUC’s High-DER proceeding is examining how to prepare the electric grid for a high DER future by determining how to integrate 356 Newsom, Gavin. July 22, 2022. Letter from Governor Newsom to CARB Chair Liane Randolph. https://www.gov.ca.gov/wp-content/uploads/2022/07/07.22.2022-Governors-Letter-to-CARB.pdf. 357 More information on the program, which closed in 2016, can be found on the CPUC website, including annual program assessment reports, at: https://www.cpuc.ca.gov/industries-and-topics/electricalenergy/demand-side-management/california-solar-initiative. 358 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, In part (NF2, NF13). finalejacrecs.pdf (arb.ca.gov). 359 CPUC. Resiliency and Microgrids. https://www.cpuc.ca.gov/industries-and-topics/electricalenergy/infrastructure/resiliency-and-microgrids. 360 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, NF1, ES1. finalejacrecs.pdf (arb.ca.gov). 361 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, NF2. finalejacrecs.pdf (arb.ca.gov). 362 Distributed energy resources include rooftop solar and other distributed renewable generation resources, energy storage, electric vehicles, time variant and dynamic electric rates, flexible load management, demand response, and energy efficiency technologies. 201
millions of DERs within the distribution grid to maximize societal and ratepayer benefits from DERs while ensuring grid reliability and affordable rates.363 SB 350 also aims to connect long-term planning for electricity needs with the state’s climate targets. This is primarily accomplished through CARB’s establishment of 2030 GHG emissions targets for the electricity sector in general and for each electricity provider, which inform the CPUC and publicly owned utilities’ integrated resource planning. A GHG planning target range of 30 to 53 MMTCO2e—informed by the 2017 Scoping Plan—was originally developed and adopted by CARB in 2018. In its 2021 IRP planning cycle, the CPUC adopted a 38 MMT GHG target for the electricity sector in 2030, which drops to 35 MMT in 2032.364
The Scoping Plan Scenario incorporates SB 350’s energy efficiency doubling goal, aligns with the CPUC’s IRP 2030 GHG target and latest GHG emissions benchmarks through 2035,365 the governor’s 20 GW offshore wind and no new gas generation366 goals, and SB 100’s 2030 RPS and 2045 zero-carbon retail sales targets to reduce dependence on fossil fuels in the electricity sector by transitioning substantial energy demand to renewable and zero-carbon resources.367 As described in Chapter 2, CCS is applied in limited sectors, including on 16.7 MMT of CO2 from existing fossil gas electricity generation in 2045, to ensure the state achieves the 85 percent reduction in anthropogenic emissions required by AB 1279. Continued transition to renewable and 363 The High-DER proceeding is one of four “anchor” proceedings in the CPUC’s DER Action Plan 2.0 and is within the Action Plan’s infrastructure track. Information on the High-DER proceeding is available at:
https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/infrastructure/distribution-planning. The Action Plan can be accessed at: https://www.cpuc.ca.gov/about-cpuc/divisions/energy-division/der-actionplan. 364 The February 10, 2022, Decision 22-02-004 by the CPUC adopts the 2021 Preferred System Plan, completing the 2019–21 IRP cycle.
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M451/K412/451412947.PDF. The Decision requires load serving entities to submit plans in the next IRP cycle detailing how they will meet their proportionate share of a 30 MMT electric sector target, as well as a 38 MMT GHG target. 365 June 15, 2022, Administrative Law Judge’s Ruling for 2022 integrated resource plan filings specifies the need for GHG targets to plan for in 2035 to continue progress toward the 2045 goal. The ruling proposes a straight-line projection from the GHG planning target for 2030. Corresponding to the adopted Preferred System Plan in D.22-02-004, 38 MMT in 2030 leads to a target of 30 MMT in 2035. https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M485/K625/485625915.PDF. 366 The governor’s July 22, 2022, letter specifies no new gas generation but does not place any constraints on existing gas resources. Therefore, for purposes of RESOLVE electricity sector modeling, existing gas capacity is an available resource that is able to be reduced over time based on announced retirements or if selected for retirement by the model. 367 CARB. 2021. PATHWAYS Scenario Modeling: 2022 Scoping Plan Update – Attachment B: Generation Technologies to be included in Modeling. https://ww2.arb.ca.gov/sites/default/files/2021- 12/Revised 2022SP ScenarioAssumptions 15Dec.pdf.
202
zero-carbon electricity resources will enable electricity to become a zero-carbon substitute for fossil fuels across the economy.

Figure 4-5 shows the modeled resource capacity to meet the SB 100 retail sales target.368 Energy efficiency moderates some of the need for additional electricity generation.

However, that is quickly surpassed by growing electricity demand of 26 percent by 2030 and 76 percent by 2045 compared to today (2022) from increased population and electrification of other sectors, as shown in Figure 4-6. The estimated resource build needed to meet this level of demand amounts to approximately 72 GW of utility solar369 and 37 GW of battery storage by 2045. Annual build rates (over the 2022–2035 period) for the Scoping Plan Scenario will need to increase by about 60 percent and over 700 percent for utility solar and battery storage, respectively, compared to historic maximum rates.370 To reach the 2045 target, the state will need to quadruple its current level of wind and solar capacity. This does not include capacity associated with hydrogen production nor mechanical CDR, which was modeled off-grid; assuming hydrogen production via electrolysis, this would roughly be equivalent to an additional 10 GW371 of solar generation needed in 2045, and an additional 64 GW of solar generation for direct air capture in 2045. The scale of solar and battery build rates needed could be reduced through the commercialization of new zero-carbon technologies.
368 SB 846 requires that load-serving entities exclude energy, capacity, or any attribute from the Diablo Canyon power plant in their resource plans. The Scoping Plan Scenario excludes energy, capacity, or any attribute from the Diablo Canyon power plant after the prior planned retirement date of 2025. 369 The amount of additional customer solar included in the Scoping Plan Scenario is 29,208 MW by 2045. 370 E3. 2022. CARB Scoping Plan: AB32 Source Emissions Final Modeling Results. PowerPoint. https://ww2.arb.ca.gov/sites/default/files/2022-11/SP22-MODELING-RESULTS-E3-PPT.pdf. Build rates are from EIA data historical builds in the 2011–2021 time frame. 371 The estimate does not include hydrogen production assumed to be produced with bioenergy with carbon capture and storage (BECCS) and steam methane reforming (SMR).

205
also can be supported through increased coordination and markets in the interconnected western power grid; this is already helping to better integrate renewables.375 Strategies for Achieving Success
• Use long-term planning processes (Integrated Energy Policy Report, IRP, CAISO Transmission Planning Process, AB 32 Climate Change Scoping Plan) to support grid reliability and expansion of renewable and zero-carbon resource and infrastructure deployment.
• Complete systemwide and local reliability assessments across CAISO and other balancing authority areas, using realistic assumptions for land use, build rates, statewide and distribution system level constraints, and energy needs. Such assessments should be completed before state agencies update their electricity sector GHG targets.
• Prioritize actions to mitigate impacts to electricity reliability and affordability and provide sufficient flexibility in the state’s decarbonization roadmap for adjustments as may be needed.
• Facilitate long lead-time resource development through the IRP and the SB 100 interagency process and through technology development and demonstration funding376 that includes resources such as long-duration energy storage and hydrogen production.
• Continue coordination between energy agencies and energy proceedings to maximize opportunities for demand response.
• Continue to explore the benefits of regional markets to enhance decarbonization, reliability, and affordability.
• Address resource build-out challenges, including permitting, interconnection, and transmission network upgrades.
• Explore new financing mechanisms and rate designs to address affordability.377 • Per SB 350, double statewide energy efficiency savings in electricity and fossil gas end uses by 2030, through a combination of energy efficiency and fuel substitution actions.378
• Per SB 100 and SB 1020, achieve 90 percent, 95 percent, and 100 percent 375 CEC. 2021. 2021 SB 100 Joint Agency Report – Achieving 100 Percent Clean Electricity in California:

An Initial Assessment. Publication Number: CEC-200-2021-001. 376 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, ES2. The committee recommendation speaks specifically to offshore wind production. finalejacrecs.pdf (arb.ca.gov). 377 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, NF30. finalejacrecs.pdf (arb.ca.gov). 378 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, NF1, NF2. finalejacrecs.pdf (arb.ca.gov).
206
renewable and zero-carbon retail sales by 2035, 2040, and 2045, respectively. • Evaluate and propose, as needed, changes to strengthen the Cap-and-Trade Program.
• Target programs and incentives to support and improve access to renewable and zero-carbon energy projects (e.g., rooftop solar, community owned or controlled solar or wind, battery storage, and microgrids) for communities most at need, including frontline, low-income, rural, and indigenous communities.379 • Prioritize public investments in zero-carbon energy projects to first benefit the most overly burdened communities affected by pollution, climate impacts, and poverty.380
Sustainable Manufacturing and Buildings
Fossil gas is the primary gaseous fossil fuel used to produce heat at industrial facilities, as well as in residential and commercial buildings. In buildings, space and water heating, cooking, and clothes drying all rely on gaseous fuels today. Industrial processes that require heat for conventional boilers and other processes also rely on gaseous fuels.

Refineries rely on fossil gas and other gaseous fossil fuels, like liquefied petroleum gas and refinery fuel gas, and fossil gas is also used to generate electricity, as discussed earlier.

Gaseous fossil fuel use can be displaced by four primary alternatives: zero-carbon electricity, solar thermal heat, hydrogen, and biogas/biomethane. Displacing gaseous fossil fuel use can yield indoor air quality benefits, protect public health and property from unexpected fossil gas leaks, and reduce short-lived climate pollutants, which are many times more potent in affecting climate change than CO2. The Scoping Plan Scenario reduces dependence on fossil gas in the industrial and building sectors by transitioning substantial energy demand to alternative fuels. Reducing fossil gas combustion also will help toward achieving our air quality and equity goals by reducing pollution in neighboring areas and communities. In addition, reduced dependence on gasoline and diesel in the transportation sector diminishes the need for gaseous fossil fuels to support oil and gas production and petroleum refining operations as those are phased down relative to the demand.
379 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, NF2, NF9, NF11, NF12, NF13. finalejacrecs.pdf (arb.ca.gov). 380 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, NF14. finalejacrecs.pdf (arb.ca.gov).
207
Sector Transition
Industry
California’s industrial sector contributes significantly to the state’s economy, with a total output from manufacturing in 2019 of $324 billion (10.4 percent of the state total)381 and employment of 1,222,000 manufacturing jobs (7.6 percent of the total state workforce).382 California industry includes a diverse range of facilities, including cement plants, refineries, glass manufacturers, oil and gas producers, paper manufacturers, mining operations, metal processors, and food processors. Combustion of fossil gas, other gaseous fossil fuels, and solid fossil fuels provide energy to meet three broad industry needs: electricity, steam, and process heat. Non-combustion emissions result from fugitive emissions and from the chemical transformations inherent to some manufacturing processes. About 20 percent of the GHG emissions from the industrial sector are noncombustion emissions.

Decarbonizing industrial facilities depends upon displacing fossil fuel use with a mix of electrification, solar thermal heat, biomethane, low- or zero-carbon hydrogen, and other low-carbon fuels to provide energy for heat and reduce combustion emissions. Emissions also can be reduced by implementing energy efficiency measures and using substitute raw materials that can reduce energy demand and some process emissions. Some remaining combustion emissions and some non-combustion CO2 emissions can be captured and sequestered. The strategy employed will depend on the industrial subsector and the specific processes utilized in production. The left side of Figure 4-7 illustrates the fuels used to meet industrial manufacturing energy demand in 2020. Industrial manufacturing energy demand needs to transition to the fuel mix shown for 2035 and 2045. The right side of Figure 4-7 illustrates the fuel mix needed to meet the energy demand of oil and gas extraction and petroleum refining operations for the same years.

Energy demand in this portion of the industrial sector declines along with decreased demand for gasoline and diesel in the transportation sector. In both figures there is a continuing demand for fossil gas due to lack of non-combustion technologically feasible or cost-effective alternatives for certain industrial sectors. Policies that support decarbonization strategies like electrification, use of renewable energy, and transition to alternative fuels are needed.
381 National Association of Manufacturers (NAM). 2021 California Manufacturing Facts. https://www.nam.org/state-manufacturing-data/2021-california-manufacturing-facts/. 382 NAM. 2021 California Manufacturing Facts. https://www.nam.org/state-manufacturing-data/2021- california-manufacturing-facts/.

209
California, most projects to electrify a fossil gas-powered industrial process will face operating cost barriers and potential reliability concerns. Microgrids powered by renewable resources and with battery storage are emerging as a key enabler of electrification and decarbonization at industrial facilities.

There are fewer commercially available and economically viable electrification options to replace industrial processes that require higher-temperature heat. For these processes, onsite combustion may continue to be needed, and decarbonization will require fuel substitution to hydrogen,384 biomethane, or other low-carbon fuels. Fuel substitution and continued combustion will require monitoring and mitigation of any potential air quality impacts, especially in low-income and communities of color which already face disproportionate air pollution burdens. Industries in California with high heat needs include steel forging, glass manufacturing, and industries with calcination processes, such as manufacturing lime and cement.

Onsite emissions from cement manufacturing derive from two main sources: (1) fuel combustion to heat the kiln to a very high temperature and (2) process CO2 emissions from the chemical transformation of limestone. Over 60 percent of emissions from the sector are process emissions unrelated to fuel use, and most emissions related to fuel use are from coal and petroleum coke combustion. Process emissions from cement manufacturing are significant and will continue even if the sector were to operate using only zero-carbon fuels; thus carbon capture and use/sequestration will be a likely component of any strategy to fully decarbonize cement manufacturing. There are additional opportunities to reduce GHG emissions from cement manufacturing via the combination of fuel-switching to low-carbon fuels (e.g., biomethane, municipal solid waste, biochar), increased blending of non-clinker materials, and efficiency improvements. High technological and economic barriers exist to electrifying kiln process heat at cement plants, as clinker production requires temperatures in excess of 1,500°C.

There are potential decarbonization opportunities throughout the value chain of cement use, including in cement manufacturing, concrete mixing, and construction practices.385 SB 596 (Becker, Chapter 246, Statutes of 2021), which was signed by Governor Newsom in September 2021, requires CARB to develop a comprehensive strategy for cement use in California to achieve a GHG intensity 40 percent below 2019 levels by 2035, and netzero emissions by 2045. 384 Griffiths, Steve, Benjamin K. Sovacool, Jinsoo Kim, Morgan Bazilian, and Joao M. Uratani. 2021. “Industrial decarbonization via hydrogen: A critical and systematic review of developments, sociotechnical systems and policy options.” Energy Research & Social Science 80. 102208, ISSN 2214-6296. https://doi.org/10.1016/j.erss.2021.102208. 385 California Nevada Cement Association. Achieving Carbon Neutrality in the California Cement Industry. https://cncement.org/attaining-carbon-neutrality.
210
Oil and gas extraction and refining make up over half of California’s industrial GHG emissions. Reduced demand for transportation fossil fuels corresponds to reduced supply of fossil gas and other gaseous fossil fuels for refineries to produce these fuels. Some refining operations will continue to operate to produce fossil fuel for the remaining transportation energy demands, along with renewable diesel and sustainable aviation fuel, as discussed in the Transportation Sustainability section of this chapter.

Across industrial subsectors and processes, California facilities also could realize significant reductions in GHG emissions and energy-related costs by implementing advanced energy efficiency projects and tools.386 While enhanced operation and maintenance practices are typical at industrial facilities, additional strategic energy management practices offer greater efficiency gains by focusing on setting goals, tracking progress, and reporting results.

Strategies for Achieving Success
• Maximize air quality benefits using the best available control technologies for stationary sources in communities most in need, including frontline, low-income, disadvantaged, rural, and tribal communities.387
• Prioritize alternative fuel transitions first in communities most in need, including frontline, low-income, disadvantaged, rural, and tribal communities.388 • Invest in research and development and pilot projects to identify options to reduce materials and process emissions along with energy emissions in California’s industrial manufacturing facilities, leveraging programs like the CEC’s Electric Program Investment Charge (EPIC).389
• Evaluate and propose, as needed, changes to strengthen the Cap-and-Trade Program.
• Support electrification with changes to industrial rate structures. • Develop infrastructure for CCS and hydrogen production to reduce GHG emissions where cost-effective and technologically feasible non-combustion alternatives are not available.
• Implement SB 905.
386 Therkelsen, Peter, Aimee McKane, Ridah Sabouini, and Tracy Evans. 2013. Assessing the Costs and Benefits of the Superior Energy Performance Program. U.S Department of Energy. https://www.osti.gov/servlets/purl/1165470. 387 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, JT14. finalejacrecs.pdf (arb.ca.gov). 388 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, JT15. finalejacrecs.pdf (arb.ca.gov). 389 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, M20. finalejacrecs.pdf (arb.ca.gov).
211
• Establish markets for low-carbon products and recycled materials using Buy Clean California Act and other mechanisms relying on robust data • Develop a net-zero cement strategy to meet SB 596 targets for the GHG intensity of cement use in California.
• Continue to leverage energy-efficiency programs, including the U.S. DOE’s ENERGY STAR program,390 U.S. DOE’s Superior Energy Performance program,391 and ISO 50001.392
• Evaluate and continue to offer incentives to install energy efficiency and renewable energy technologies through programs such as CPUC decisions as part of rulemaking R.19-09-009393 and the CEC’s Food Production Investment Program (FPIP) and EPIC programs.394
• Leverage low-carbon hydrogen programs, including the Bipartisan Infrastructure Law, for regional hydrogen hubs, hydrogen electrolysis, and hydrogen manufacturing and recycling.
• Evaluate the role of hydrogen in meeting GHG emission reductions, including policy recommendations regarding the use of hydrogen in California as required by SB 1075.
• Address cost barriers to promote low-carbon fuels for hard-to-electrify industrial applications.

Buildings
Buildings have cross-sector interactions that influence our public health and well-being and affect land use and transportation patterns, energy use, water use, and indoor and outdoor environments.395 There are about 14 million existing homes and over 7.5 billion square feet of existing commercial buildings396 in California. Fossil gas supplies about half of the energy consumed by end uses in these buildings. In addition to GHG emissions, fossil gas usage in buildings also produces CO2, NOx, PM2.5, and 390 ENERGY STAR. ENERGY STAR Guidelines for Energy Management. https://www.energystar.gov/buildings/tools-and-resources/energy-star-guidelines-energy-management. 391 Energy.gov. Superior Energy Performance 50001. https://www.energy.gov/eere/amo/superior-energyperformance. 392 ISO. ISO 50001 Energy Management. https://www.iso.org/iso-50001-energy-management.html. 393 CPUC. January 14, 2021. CPUC Adopts Strategies to Help Facilitate Commercialization of Microgrids Statewide. https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M360/K370/360370887.PDF. 394 Bailey, Stephanie, David Erne, and Michael Gravely. 2021. Final 2020 Integrated Energy Policy Report Update, Volume II: The Role of Microgrids in California’s Clean and Resilient Energy Future, Lessons Learned From the California Energy Commission’s Research. California Energy Commission. Publication Number: CEC-100-2020-001-V2-CMF. 395 See Appendix F (Building Decarbonization). 396 CEC. 2021. California Building Decarbonization Assessment. https://efiling.energy.ca.gov/GetDocument.aspx?tn=239311&DocumentContentId=72767. 212
formaldehyde.397 Each year, about 120,000 new homes398 and more than 100 millionsquare feet399 of commercial buildings are newly constructed across California. These new buildings will represent between a third to half of the total building stock by midcentury.

Achieving carbon neutrality must include transitioning away from fossil gas in residential and commercial buildings, and will rely primarily on advancing energy efficiency while replacing gas appliances with non-combustion alternatives. This transition must include the goal of trimming back the existing gas infrastructure so pockets of gas-fueled residential and commercial buildings do not require ongoing maintenance of the entire limb for gas delivery. Blending low-carbon fuels such as hydrogen and biomethane into the pipeline further displaces fossil gas. Pipeline safety and reliability must be evaluated to accommodate low-carbon fuels. Figure 4-8 illustrates the energy Californians use in buildings at present compared with the Scoping Plan Scenario, which introduces alternatives to fossil gas. In that scenario almost 90 percent of energy demand is electrified by 2045, and the remaining energy demand is met with combustion of hydrogen, biomethane, and fossil gas.
397 Zhu, Yifang, et al. 2020. Effects of Residential Gas Appliances on Indoor and Outdoor Air Quality and Public Health in California. UCLA Fielding School of Public Health Department of Environmental Health Sciences.
398 Construction Industry Research Board. 2018. Annual Building Permit Summary. http://www.cirbreport.org. 399 Delforge, Pierre. August 11, 2021. California Forging Ahead on Zero Emission Buildings. Blog. NRDC. https://www.nrdc.org/experts/pierre-delforge/california-forging-ahead-zero-emission-buildings.

215
with other critically needed renovation efforts to ensure that buildings support human health and are climate- and weather-resistant.401 • End fossil gas infrastructure expansion for newly constructed buildings.402 • Evaluate and propose, as needed, changes to strengthen the Cap-and-Trade Program.
• Strengthen California’s building standards to support zero-emission new construction.
• Develop building performance standards for existing buildings. • Adopt a zero-emission standard for new space and water heaters sold in California beginning in 2030, as specified in the 2022 State Strategy for the State Implementation Plan.
• Expand use of low-GWP refrigerants within buildings.
• Support electrification with changes to utility rate structures and by promoting load management programs.
• Increase funding for incentive programs and expand financing assistance programs focused on existing buildings and appliance replacements. • Expand consumer education efforts to raise awareness and stimulate the adoption of decarbonized buildings and appliances, especially in vulnerable communities. • Implement biomethane procurement targets for investor-owned utilities as specified in SB 1440 (Hueso, Chapter 739, Statutes of 2018) to reduce GHG emissions in remaining pipeline gas and reduce methane emissions from organic waste.
401 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, NF23, NF24, NF25, NF26, NF28. finalejacrecs.pdf (arb.ca.gov). 402 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, NF22. finalejacrecs.pdf (arb.ca.gov).
216
Carbon Dioxide Removal and Capture
Climate Change 2022: Mitigation of Climate Change,403 a report by the IPCC released in early 2022, states “The deployment of CDR to counterbalance hard-to-abate residual emissions is unavoidable if net zero CO2 or GHG emissions are to be achieved. The scale and timing of deployment will depend on the trajectories of gross emission reductions in different sectors. Upscaling the deployment of CDR depends on developing effective approaches to address feasibility and sustainability constraints especially at large scales.” In line with that report, this Scoping Plan considers CDR as a complement to technologically feasible and cost-effective GHG emissions mitigation, and the size of its role will depend on the degree of success in reducing GHG emissions at the source across the economy. 404 The modeling shows that emissions from the AB 32 GHG Inventory sources will continue to persist even if all fossil related combustion emissions are phased out. These residual emissions must be compensated for to achieve carbon neutrality. Options for CDR include both sequestration in natural and working lands and mechanical approaches like direct air capture. Chapter 2 provides estimates on how much CO2 removal is possible by our natural and working lands and how much must be removed by mechanical CDR.

CCS, which is carbon capture from anthropogenic point sources, is described in Chapter 2 and involves capturing carbon from a smokestack of an emitting facility. Direct air capture, on the other hand, captures carbon directly from the atmosphere. Direct air capture technologies, unlike CCS, are not associated with any particular point source.

For this section, carbon management refers to the capture, movement, and sequestration of CO2 through mechanical solutions for both capture at point sources and direct removal from the atmosphere through direct air capture.405 Enabling policies and regulations across each of these steps are necessary for individual projects, and on a broader scale, for delivering reductions in support of the state’s carbon neutrality and long-term carbonnegative goals. Figure 4-10 provides a graphic of the typical carbon management infrastructure.
403 IPCC. 2022. Climate Change 2022: Mitigation of Climate Change. https://www.ipcc.ch/report/sixthassessment-report-working-group-3/. 404 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, F4.7. finalejacrecs.pdf (arb.ca.gov). 405 CDR through natural and working lands is discussed in Chapter 2 and later in this chapter. 217
Figure 4-10: Carbon management infrastructure
Carbon dioxide removal directly from the atmosphere itself refers to a suite of carbon negative technologies that can be used to draw down ongoing and historical carbon emissions already in the atmosphere. Some CO2 removal technologies leverage the abilities of both natural photosynthesis and mechanical removal by using biomass wastes as inputs to make low- or zero-carbon energy or fuels, all while capturing and storing produced CO2.

Captured CO2 from point sources or from the atmosphere is permanently stored in specialized geologic formations, typically half a mile or more underground. A recent Stanford University study estimated the state’s commercial storage potential is nearly 70,000 million metric tons of CO2, even when excluding oil and gas reservoirs.406 California is well-positioned because few other places on the West Coast are suitable for 406 Stanford Center for Carbon Storage. Opportunities and Challenges for CCS in California. https://sccs.stanford.edu/california-projects/opportunities-and-challenges-for-CCS-in-California. 218
geologic storage at scale. To inform discussion around CO2 removal, CARB held two fullday workshops exploring the types of options for carbon capture and geologic storage and utilization in products.407,408,409
The modeling results provided in Chapter 2 demonstrate the targeted need for CCS on large facilities such as refineries and cement. The CCS numbers do not include the potential additional applications for producing hydrogen with biomethane, other manufacturing, electricity, or other bioenergy. If CCS is not deployed, those emissions would be released directly into the atmosphere and instead need to be addressed through CDR to achieve carbon neutrality. Although a study finds California has 76 existing electricity and industrial facilities that are suitable candidates for CCS retrofit,410 this Scoping Plan proposes a targeted role for this technology such that it would only be used to address sectors where non-combustion options are not technologically feasible or costeffective at this time, to the extent needed to achieve the 85 percent reduction in anthropogenic emissions as called for in AB 1279. In future updates to the Scoping Plan, there may be additional options for technologically feasible or cost-effective technologies that may be deployed, which would further reduce the need for CCS and CDR except in situations to address historical GHG emissions.

Recognizing the need for carbon capture and utilization sequestration and removal, the Legislature passed, and the governor signed, SB 905. It includes several key requirements in the development of the state’s Carbon Capture Removal, Utilization, and Storage Program. The following is a summary of the work to be completed to establish and administer this program. Many of these steps will address the need to evaluate the safety and efficacy of actions to support carbon removal, sequestration, and transfer via pipelines. Note that not all of these actions are under CARB’s authority. • Review technology to evaluate efficacy, safety, viability of CCUS/CDR methodologies.
• Develop monitoring and reporting requirements and schedules. • Develop a unified permit application.
• Develop financial responsibility requirements.
• Develop a centralized public database for project status. 407 CARB. December 11, 2019. Carbon Neutrality Meetings & Workshops. https://ww2.arb.ca.gov/ourwork/programs/carbon-neutrality/carbon-neutrality-meetings-workshops. 408 CARB. August 2, 2021 Scoping Plan Meetings & Workshops. https://ww2.arb.ca.gov/ourwork/programs/ab-32-climate-change-scoping-plan/scoping-plan-meetings-workshops. 409 Carbon utilization refers to the use of captured carbon to produce products such as plastics and concrete.
410 Glenwright, Kara. 2020. Roadmap for carbon capture and storage in California. Precourt Institute for Energy. https://earth.stanford.edu/news/roadmap-carbon-capture-and-storage-california#gs.ysj78q. 219
• Consult with CNRA on pore space requirements as CNRA develops a framework for pore space governing agreements.
• Establish a Geologic Carbon Sequestration Group to identify suitable injection well locations, subsurface monitoring, and potential hazards that may require suspension of injection.

SB 905 also has requirements for project developers such as to develop monitoring plans and to avoid any adverse health and environmental impacts at the carbon capture location—or mitigation of unavoidable impacts as required under existing requirements.

For the site of injection, there are requirements for site stability, monitoring, and reporting plans. SB 905 also bans CCS with enhanced oil recovery in California and prohibits the transfer of CO2 via pipeline until the U.S. Department of Transportation’s Pipelines and Hazardous Materials Safety Administration (PHMSA) completes its current rulemaking to update existing CO2 pipeline safety requirements.

An often-cited example of pipeline concerns involves a CO2 pipeline in Mississippi. On February 22, 2020, a CO2 pipeline operated by Denbury Gulf Coast Pipelines LLC (Denbury) ruptured in proximity to the community of Satartia, Mississippi. The rupture followed heavy rains that resulted in a landslide, creating excessive axial strain on a pipeline weld (DOT 2022). The combination of weather and topography resulted in a slower dissipation of the gas. The pipeline was also carrying hydrogen sulfide, a flammable and toxic gas. The pipeline failed on a steep embankment, which had recently subsided. Heavy rains are believed to have led to a landslide, which created axial strain on the pipeline and resulted in a full circumferential girth weld failure. The PHMSA investigation also revealed several contributing factors to the accident, including but not limited to: Denbury not addressing the risks of geohazards in its plans and procedures, underestimating the potential affected areas that could be impacted by a release in its CO2 dispersion model, and not notifying local responders to advise them of a potential failure.

As the Satartia example highlights, appropriate pipeline safety and environmental standards in California are critical to minimize any risks from CO2 transport in the future.

As such, SB 905 also tasks CNRA, in consultation with the Public Utilities Commission, to, no later than February 1, 2023, provide a proposal to the Legislature to establish a state framework and standards for the design, operation, siting, and maintenance of intrastate pipelines carrying CO2 fluids of varying composition and phase to minimize the risk posed to public and environmental health and safety. The recommended framework shall be designed to minimize risk to public health and environmental health and safety, to the extent feasible. Because SB 905 prohibits the transfer of CO2 via pipeline until the PHMSA completes its current rulemaking to update existing CO2 pipeline safety requirements, CCS or CDR projects that would require a pipeline to transfer CO2 are not feasible at this time within California.
220
Ultimately, and in accordance with SB 905, the merits of each CCS or CDR project must be evaluated on a case-by-case basis.411 Deployment of CCS and CDR could support skilled jobs and workforces, including those in traditional fossil energy communities. Other co-benefits could include criteria air pollutant reductions and water production. It will be important to design projects that do not exacerbate community health impacts, include early and ongoing community engagement, and are in compliance with local, state, and federal public health and environmental protection laws. It also should be noted that, as these types of projects are an emerging area of governance, additional coordination and discussion will be needed among the various levels of authorities involved. SB 905 has already initiated this process by assigning specific agencies with tasks related to their expertise and authority.

Chapter 2 includes a more detailed discussion about the proposed role of CO2 removal in this Scoping Plan.

Sector Transition
State,412 national,413,414 and global decarbonization analyses415 indicate a significant role for carbon management infrastructure, yet relatively few projects are operational. Around the world, about two dozen large CCS projects are capturing tens of millions of metric tons of CO2 each year, with about a dozen operating in the United States.416 The vast majority of capacity is at industrial facilities, such as ethanol and fertilizer plants, that would otherwise vent nearly pure CO2 into the atmosphere as a by-product of normal, non-combustion processes. Future research, development, and demonstration projects must refine and commercialize capture systems for more complex applications, especially 411 AB 32 EJ Advisory Committee. 2022 Scoping Plan Recommendations, F4.5. finalejacrecs.pdf (arb.ca.gov). 412 E3. October 2020. Achieving Carbon Neutrality in California Report: Final Presentation. https://ww2.arb.ca.gov/sites/default/files/2020-10/e3 cn final presentation oct2020 2.pdf. 413 World Resources Institute. January 31, 2020. CarbonShot: Federal Policy Options for Carbon Removal in the United States. Working paper. https://www.wri.org/research/carbonshot-federal-policy-optionscarbon-removal-united-states. 414 C2ES. No date. Getting to Zero: A U.S. Climate Agenda — Center for Climate and Energy Solutions. https://www.c2es.org/getting-to-zero-a-u-s-climate-agenda-report/. 415 IPCC. Mitigation Pathways Compatible with 1.5°C in the Context of Sustainable Development. Chapter

2. https://www.ipcc.ch/sr15/chapter/chapter-2/. All analyzed pathways limiting warming to 1.5°C with no or limited overshoot use CDR to some extent to neutralize emissions from sources for which no mitigation measures have been identified and, in most cases, also to achieve net negative emissions to return global warming to 1.5°C following a peak (high confidence). The longer the delay in reducing CO2 emissions toward zero, the larger the likelihood of exceeding 1.5°C, and the heavier the implied reliance on net negative emissions after mid-century to return warming to 1.5°C (high confidence). 416 Congressional Research Service. 2021. Carbon Capture and Sequestration (CCS) in the United States. R44902.
https://crsreports.congress.gov/product/pdf/R/R44902?msclkid=e45e0012c25911ec8085ca575cb61e82. 221
for those with limited decarbonization options. It has only been in the last few years that attention has seriously turned to mechanical CDR. As new information and modeling on climate change have been made available, the science has become clearer that avoiding the most catastrophic impacts of climate change requires both reducing emissions and deploying mechanical CDR.

California is paving a path forward on a science-based carbon management infrastructure policy that can serve as an example for other jurisdictions. The LCFS, which reduces the carbon intensity of transportation fuels, includes a protocol for select carbon management projects to become certified and generate LCFS credits.417 CCS is not a new concept or technology. Twenty years of CCS testing show it is a safe and reliable tool.418 As mentioned in Chapter 2, while no new CCS projects have been implemented or generated any credits under the CARB CCS protocol, CCS projects have been implemented elsewhere since the 1970s. Moreover, there has been a U.S. Department of Energy CCS research program underway for more than two decades. These all form a foundation of information for future efforts. Certified projects must successfully demonstrate adherence to rigorous pre-construction, operational, and site closure standards designed to strengthen environmental performance, as described in CARB’s CCS Protocol. The protocol is designed to layer on top of existing federal carbon sequestration regulations designed to protect the environment. The protocol would need to be reevaluated if CCS were to be more broadly applied across sectors beyond transportation fuel production.

Direct air capture and carbon mineralization have high potential capacity for removing carbon, but direct air capture is currently limited by high cost. Carbon mineralization may also have high potential for removing carbon from the atmosphere, but understanding of the technology is still limited.419 Direct air capture could also be deployed at higher rates to remove legacy GHG emissions from the atmosphere. Chapter 2 contains additional information on the current status of CCS and mechanical CDR projects globally, as well as federal support of such technologies.

Strategies for Achieving Success
• Implement SB 905.
417 CARB. 2018. Carbon Capture and Sequestration Protocol under the Low Carbon Fuel Standard.

August 13. https://ww2.arb.ca.gov/sites/default/files/2020-03/CCS Protocol Under LCFS 8-13- 18_ada.pdf. 418 National Energy Technology Laboratory. Permanence and Safety of CCS. https://netl.doe.gov/coal/carbon-storage/faqs/permanence-safety. 419 Aines, Roger. No date. Options for Removing CO2 from California’s Air. Lawrence Livermore National Laboratory. https://ww2.arb.ca.gov/sites/default/files/2021- 08/llnl presentation sp engineeredcarbonremoval august2021.pdf. 222
• Convene a multi-agency Carbon Capture and Sequestration Group comprised of federal, state, and local agencies to engage with environmental justice advocates, tribes, academics, researchers, and community representatives to identify the current status, concerns, and outstanding questions concerning CCS, and develop a process to engage with communities to understand specific concerns and consider guardrails to ensure safe and effective deployment of CCS.420 • Iteratively update the CARB CCS Protocol with the best available science and implementation experience.
• Incorporate CCS into other sectors and programs beyond transportation where cost-effective and technologically feasible options are not currently available and to achieve the 85 percent reduction in anthropogenic sources below 1990 levels as called for in AB 1279.
• Evaluate and propose, as appropriate, financing mechanisms and incentives to address market barriers for CCS and CDR.
• Evaluate and propose, as appropriate, the role for CCS in cement decarbonization (SB 596) and as part of hydrogen production pathways (SB 1075). • Support carbon management infrastructure projects through core CEC research, development, and demonstration (RD&D) programs.
• Continue to explore carbon capture applications for producing or leveraging zerocarbon power for reliability needs as part of SB 100. • Consider carbon capture infrastructure when developing hydrogen roadmaps and strategy, especially for non-electrolysis hydrogen production. • Evaluate and streamline permitting barriers to project implementation while protecting public health and the environment.
• Explore options for how local air quality benefits can be achieved when CCS is deployed.
• Explore opportunities for CCS and CDR developers to leverage existing infrastructure, including subsurface infrastructure.
• Explore permitting options to allow for scaling the number of sources at carbon sequestration hubs.

← All documents from this meeting