CLFP Comments on CARB’s Proposed GHG Scoping Plan

The California Air Resources Board (CARB) has issued the Agency’s draft proposal for meeting ambitious long-term greenhouse gas (GHG) emissions reductions and a "net-zero” carbon economy by 2045. To meet these goals the 2023 Scoping Plan will rely on technologies such as carbon capture, new fuels such as hydrogen, and electrifying vehicles, homes, and businesses.  Although the food processing industry accounts for less than one percent of statewide GHG emissions, companies in the cap-and-trade program may incur significant compliance costs under the Plan. CLFP filed extensive comments with CARB, and recommended the following general policy goals be incorporated into the Plan:

Avoiding unreasonable increases in consumer costs for essential food items 
The U.S. Bureau of the Census projects that the U.S. population will increase by 40 million by 2040. California is a leading producer in the U.S. of staple food items such as milk, cheese, canned and dehydrated fruit and vegetables, nuts, and poultry products. The firms that produce these products in California are some of the same ones that are in the cap-and-trade program and may face excessive compliance costs if required to achieve emissions reductions beyond the capabilities of current combustion or emissions control technologies. Food costs, especially for low-income consumers, should be a major consideration when CARB crafts compliance pathways and regulations.

 

Ensuring the reliability of the electricity grid and affordable energy costs
CARB is proposing a doubling of the statewide electric load by 2045, and that much of the electricity is to be generated from zero-carbon sources. Given that solar and wind energy systems are intermittent, and that supplies of hydro power may be reduced by climate change-induced drought, achieving those goals may be a tall order. A recent study concluded that "relying only on renewable energy and storage to maintain reliability may be technically feasible, but it would be prohibitively expensive.” 

The California electricity grid is outdated and lacks the capacity and configuration to meet the demands of the broad-scale electrification and distributed generation proposed by CARB. Production of perishable food products cannot tolerate prolonged power outages. A reliable electric grid is critical to manufacturers and CLFP urges CARB to focus on this issue and include all stakeholders when developing and implementing this aspect of the Scoping Plan.

 

Ensuring a reliable and affordable supply of gas for thermal processing
The food processing sector is the second-largest industrial consumer of natural gas in California. It is used for cooking products, operating boilers and dryers, and other uses necessary for making safe and nutritious products. CARB is proposing to phase out the use of fossil gas and replacing it with renewable gas, solar thermal energy, and electricity.  All of these options might already be implemented by most facilities if they were cost-competitive with natural gas, but that is not the case. 

 

Limiting potential GHG emissions and economic leakage 
Food processors tend to operate on small margins and increased compliance costs may render some California processors uncompetitive with processors in other states/countries. Although California is a global leader in the food industry, this is not the only place where fruit, vegetables, and milk can be processed and suppliers in other regions are willing and able to take away market share if given the opportunity. To avoid this, CARB must design regulations that promote economic growth in all sectors of the state’s economy.

 

CLFP will continue to monitor the development of the Scoping Plan, which is scheduled to be brought before the CARB Board for final approval in December.