We recently submitted a second set of comments to the California Air Resources Board on its 2017 Climate Change Scoping Plan Update. These comments build on those we submitted in December to ARB on the discussion draft of the scoping plan.
We commend the ARB for improvements to the January draft from the December discussion draft, including the use of the Social Cost of Carbon and the plan’s thorough economic analysis. We also make recommendation for how ARB can improve the plan’s economic analysis to best achieve the goals laid out in the Board’s statutory mandate and address some core concerns raised by environmental justice advocates. Specifically, we recommend that ARB assess the economic effects of methane emissions using the Social Cost of Methane and monetize co-benefits of greenhouse gas reduction measures, including in the planned regional analysis.