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Comments to California Air Resources Board on 2030 Target Scoping Plan Draft

This summer, California extended its greenhouse gas emissions reduction program to 2030 with two companion bills. The legislation modifies how the Air Resources Board (ARB), the state agency responsible for regulating air pollution, should assess proposed policy measures and prioritize goals in designing regulations. ARB staff released a preliminary draft of the scoping plan for how to meet the new 2030 targets in early December and is expected to release a second draft for comment in mid-January. We submitted comments on the December draft, making recommendations on how to structure the scoping plan’s economic analysis to best achieve the goals laid out in ARB’s new mandate.

Our comments are intended to guide ARB in its use of the “social cost of greenhouse gases,” which must be used for planning purposes under ARB’s new mandate. We recommend that ARB use the federal social costs of carbon, methane and nitrous oxide estimates that are in line with the best available science and economics. We also recommended that ARB incorporate benefit-cost analysis into the scoping plan to account for the avoided social costs of the greenhouse gas emissions reduction program.