On Dec. 15, the California Air Resources Board (CARB) approved its proposed 2022 Scoping Plan, which identifies policies and actions needed to cut greenhouse gas emissions in the next 20 years. An 85% reduction is the goal to achieve carbon neutrality in 2045.

Only three weeks later, on Jan. 4, the Legislative Analyst’s Office (LAO) found the plan insufficient in its specific recommendations. “The lack of specificity likely will lead to delayed action, as it defaults to state departments to identify necessary implementation steps. This increases the risk that the state will not meet its statutory 2030 GHG goal, much less CARB’s more ambitious target.”

The CARB press release states, “The plan draws on and continues several successful climate programs currently in effect but also stresses the need to radically accelerate and increase their pace and scale …” The new 2045 goals are a shift away from fossil fuels.

Their intent is to reduce fossil fuel consumption (liquid petroleum) to less than one-tenth of current use. That is a 94% reduction in demand. Other goals include reductions of 85% below 1990 levels in greenhouse gas (GHG) emissions and 71% in smog-forming air pollution.

The CARB models also predict creation of 4 million new jobs and a $200 billion savings in health costs if these goals are achieved.

“Now begins the hard work of putting the plan into action. The impacts of climate change in California are personal: We have all been affected by wildfires, years of drought, or record-breaking heat waves,” said CARB Chair Liane Randolph in the release. “Making this plan work is our once-in-a-generation opportunity to change the California our children inherit for the better. To reach carbon neutrality in less than a quarter of a century will require all levels of government, all stakeholders.”

On the way to the 2022 plan’s ambitious GHG goal, it also proposes a 48% reduction of GHG below 1990 levels by 2030. This surpasses the minimum statutory emissions reduction goal of 40% below 1990 levels in 2030.

The updated modeling also includes 3 million climate-friendly homes by 2030 (and 7 million by 2035), 6 million heat pumps deployed by 2030, no new fossil gas capacity in the electricity sector, and 20 gigawatts of offshore wind capacity by 2045, according to CARB.

Recommendations in this plan reflect recent legislation, Gov. Gavin Newsom’s policies as well as proposals from earlier plans. The three previous Scoping Plans focused on specific GHG reduction targets for industrial, energy and transportation sectors — first to meet 1990 levels by 2020, then to meet the more aggressive target of 40% below 1990 levels by 2030.

CARB emphasizes that the major element of this new plan is the aggressive reduction of fossil fuels wherever they are currently used in California. It builds on and accelerates carbon reduction programs that have been in place for a decade and a half.

The path assumes near zero-emissions from the transportation sector, thus compelling an expanding reliance on electric cars, buses, trains and trucks. These vehicles are California’s single largest source of pollution.

It also means phasing out fossil gas used for heating homes and buildings. It means clamping down on chemicals and refrigerants that are thousands of times more powerful at trapping heat than carbon dioxide, according to the plan. In conjunction for less dependence on gasoline cars, more options for walking, biking and public transit will be needed in local neighborhoods.

More non-fossil fuel energy sources, such as solar arrays and wind turbine capacity, will be needed. Other new options such as renewable hydrogen for hard-to-electrify end uses and biomethane will need to become commercially viable.

Despite these world-leading efforts, some 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, CARB noted.

Regardless of the need for these energy saving steps, LAO is suspicious of the cumulative success because CARB’s plan does not identify which specific policies it will implement.

“For example, the plan is unclear regarding how much the state will rely on financial incentives, sector-specific regulatory programs or cap-and-trade. Rather, the plan’s estimated reductions are driven primarily by assumptions CARB developed by CARB, without specifying how those assumed outcomes might be achieved,” the LAO report stated. “The lack of focus on policy options is a missed opportunity that has important ramifications for California’s overall GHG reduction efforts.

Delayed actions are more likely in such an ambiguous situation. Multiple state agencies must identify for themselves what are the necessary implementation steps that they will pursue. Consequently, the LAO sees a risk that the state will not meet the CARB’s ambitious target. Uncoordinated policy changes in a relatively short period of time could be costlier and even disruptive for private businesses and households.

In its conclusion, the LAO recommended that the Legislature seek more information from the administration about the policies it plans to implement to achieve GHG targets, including potential changes to the cap and trade program that make it more consistent with the state’s 2030 goals.

Specifically, the LAO recommended that CARB submit a report that clarifies its plan for reducing GHG emissions to meet 2030 goals. This should go to the Legislature by July 31, 2023.

“As part of this report, CARB should identify new or expanded policies that would be used to meet both the statutory goal and the Scoping Plan goal, including the role that it expects cap and trade to play. The report should also include additional details about the estimated emission reductions, air pollution reductions, distributional impacts, and cost effectiveness of each of those policies,” the LAO concluded. “We recognize that specifying the details of every policy and conducting a thorough analysis of each policy might not be feasible by July 2023. However, given the available resources at CARB, we think providing a significant amount of additional detail and analysis is both reasonable to expect and valuable for legislative decision making.”