Category Archives: ARB

My take on the ARB Scoping Plan

What did I really think of the Scoping Plan? I skimmed it, really read the sections I was more interested in. I was mildly surprised that they think they can make huge reductions with low-hanging fruit, but I have no gut feeling for the scope of carbon emissions. They ran actual models and will show you their calculations and having no internal way to judge their predictions, I am inclined to believe them. I thought a couple other things.

When the first draft Scoping Plan came out, a predominant theme in the public comments was that the land use section and the agriculture section were too weak. Neither required enough emission reduction, both sectors got off too easy*. I laughed and laughed. Of course they did. That was foreordained. Edward Tufte says that any product looks like the entity that produced it. The California state government wrote the Scoping Plan, and the Scoping Plan looks just like the state government. All the little sectors divided out just like departments, with weak control over land use and agriculture.

The other thing I thought was that the Scoping Plan missed an opportunity. They laid out the reasonable sectors and asked people, hundreds of people, to say what you could do to reduce emissions in each sector. To my knowledge, what they never did was ask for any other kind of thought. If there is more out there, they’ll never hear about it that way.

And there is more out there. A very conspicuous example is that eating less meat and dairy will result in emissions reductions**, especially in California, which is a cattle and dairy state. But that gets no mention in the Scoping Plan. I thought the Air Board should have had a chapter called “Longshots, Crazytalk and Taboo”. They could have said up front that none of them would be mandatory in the first round of the Scoping Plan, so let loose! Who knows what they would have gotten. Who knows what the signal to noise ratio would be. But the cost of holding public meetings is pretty low, so if one or two ideas panned out, it would be worth it. The other thing that could happen is that it could flush some taboo ideas (an advertising campaign to reduce meat consumption) in a non-threatening way. It would have prepared the conversation for next time. But they never prompted people, “tell us something crazy, but might work”, and so no one did. We didn’t hear any new ideas in this round of the Scoping Plan (besides the idea of the plan itself), so I don’t know what is in the hopper for the next round, when the low-hanging fruit is gone.

*There are reasons, of course. Land use and agriculture aren’t point sources for carbon emissions, and Air Board staff wanted quantifiable amounts that they target with regulation. They didn’t feel the very first Scoping Plan could address diffuse, landscape size, hard to measure, hard to control carbon emissions. They thought they could get enough gains in the other sectors to meet their target. They knew the legislature was about to address land use. They figured they could work on the problem for a few years and come back to it in the next Scoping Plan. I’m sure they will.

**California grows feed for dairy and beef cattle. It takes energy at the pumps to move and apply water to the feed crops. It takes gas or diesel to tend and harvest the crops and move the feed. Dairies and CAFO’s are large sources of methane. Moving the meat takes gas or diesel. Reducing the amount of meat in our diet cuts down on all of those emissions very quickly, within a season.

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I, for one…

The California Air Resources Board* is likely to approve the AB 32 Scoping Plan today, which makes it as good a day as any to open this blog. You can watch Air Board meetings here.   What does that mean, that the Air Board is adopting the AB32 Scoping Plan?

Well, the Air Board is an executive agency, part of the California EPA. It reports to the governor. The Air Board is a board of political appointees. Actual people sit on this board and decide things. Used to be they decided things about air pollution, but that mission was expanded to include greenhouse gas emissions, including carbon dioxide.

AB 32 was a piece of legislation signed in 2006. It gives California until 2020 to cut carbon emissions to 1990 levels. It put the Air Board in charge of carbon and greenhouse gas emissions, which pretty much means they’re in charge of everything everywhere. It was a very broad grant of authority to the Air Board. So what will the Air Board do as the boss of everything?

Well, they tell us that in the Scoping Plan. The Air Board just spent two years writing a Scoping Plan. They held meetings and meetings and meetings. They drafted chapters, one for each sector of the economy. They ran models and did calculations and figured out how each sector was going to reduce greenhouse gases and by how much. They released a draft, took public comment, and then released a very similar next draft.

The measures in this first Scoping Plan are pretty much the low hanging fruit. These are measures that are concentrated (kinda like point-sources) and quantifiable. They are efficiency improvements, taking up slack. The Air Board thinks that many of these measures will be profitable for many sectors, have quick pay-back periods. Industry groups aren’t convinced. So how will they make all these emission reductions happen?

Two ways. Once the Scoping Plan is adopted, the Air Board will spend the next five years writing regulations that make the measures in the Scoping Plan law. For every measure in the Scoping Plan, Air Board staff has to craft detailed regulations, setting thresholds and deadlines, defining who does what and who has to spend money to comply. This is where the real battles will be. The Air Board has worked so damn hard, full speed ahead for two whole years to get the general outlines worked out. This gives them the ability to work even harder the next few years, turning those outlines into specific regulations that everyone will hate.

The other intriguing way that the Air Board will reduce carbon emissions is that they are setting up a cap-and-trade system. Do I need to tell you what that is? Just in case. A cap and trade system means that you set a cap, a fixed amount, on all the carbon (or greenhouse gas) emissions in the state. That’s the ‘cap’ part. There is a pool of allowable carbon emissions, and if you are a refinery who wants to emit carbon, you better own some of that pool. You can buy a piece of that pool from the Air Board; they will sell it to you at auction. Or, you could buy some of the right to emit carbon from your buddy, who also bought some at the auction. You could buy it from a stranger. That’s the trade part.

Then you could think to yourself. Self, is it cheaper for me to fix my smokestack so that I don’t emit as much carbon or is it cheaper for me to buy the right to emit more carbon? Or, you might think, I bought a lot of the right to emit carbon at that auction. But if I fixed my smokestack, I could sell some of that ability to emit, recoup the money it cost me to fix my smokestack and MAKE BIG MONEY. Economists (and real people too) think that a cap-and-trade system finds the most cost-efficient way to get from the emissions we have now to the emissions level set by the cap. It may still cost money (or be profitable, depending on how much wasting costs now), but market theory says that all those people making individual decisions about buying and selling emissions rights versus improving their factories is the cheapest way to achieve the emissions reduction.

In the next five years, the Air Board will implement the Scoping Plan, forcing carbon emissions reductions through regulation and through cap-and-trade.  (The cap-and-trade system won’t just be for California.  California is doing it with seven other western states and western Canada.)  In five years, another version of Scoping Plan is due, one that sets the next level of winching down emissions.

So that’s the story for today. The Air Board is about to adopt the AB 32 Scoping Plan. Now you know what that means.




*People call the California Air Resources Board the Air Board, or Aye-Are-Bee, or CARB, one word, interchangeably.

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