ECA has recently signed onto a business coalition letter addressed to the California Air Resources Board (CARB) regarding serious concerns over CARB’s Draft 2022 Scoping Plan Update in attempting to achieve the goals set forth in AB32/SB375 — addressing and mitigating greenhouse gas emissions (GHG) arising from activities in California.

In this letter, the coalition submits that new and ongoing CARB regulations must be soundly justified and obtainable both technologically and financially. Moreover, the regulations must be as commanding or as tempered as the proof and data indicate is best. Furthermore, the evolution and ongoing evaluation of CARB’s policies and regulations should reflect input from all affected stakeholders, including the most affected industries.

The letter in part specifically highlights an aspect of CARB’s policy failure by examining a particular shortcoming in the agency’s analyses put forth in their Update. The fact that the Update analyses is limited to only those activities that take place physically within California’s borders (exempting imported electricity for in-state consumption) misses the bigger picture when considering the GHG impact on industry.

Any and all other activity which is located and transpires in any other relatively GHG-intensive state or nation is ignored in CARB’s analyses. As a consequence, CARB’s approach is to impose increasingly on activities and industry occurring in California in ways that cause the actors and industries to either move or keep their operations outside of California.

An example of this ‘moving the problem elsewhere’ is CARB’s proposed regulation of cement production within California. CARB proposes an eventual standard of GHG neutrality on such in-state cement production irrespective of the costs. CARB now blindly welcomes the importation of cement into California even though it may be produced in Asia using the worst possible GHG causing production methods.

From CARB’s point of view, it does not matter if the cement produced in California were already the world’s most GHG efficient cement. If GHG-intensive imported cement could be moved about within California to its ultimate destination by means of a GHG-free vehicle, then CARB will assume that such imported cement has no GHG associated with its production, application and consumption in California.

Greater in-depth review of these mandates would surely result in superior results for all of us.

By Ray Baca, Executive Director Email: [email protected]