California Air Resources Board

Members of the California Air Resources Board

I am writing to formally oppose the “Drive Forward” Program and the broader regulatory direction that CARB has taken under the authority of Governor Newsom’s executive order banning the sale of internal combustion engine (ICE) vehicles. What CARB is doing is not merely regulatory, it is political, ideological, and fundamentally undemocratic. It is social engineering through administrative power. California deserves visionary leadership, not performative policy, punitive taxation, and ideological overreach masquerading as progress. The regulatory overreach exemplified by CARB is a direct consequence of the most failed political leadership the people of this state has ever been subjected to. California has become hostile to enterprise and innovation and the entire nation's gasoline industry. A multitude of high-profile corporations are simply leaving the state in record numbers (Chevron and Valero) just in the energy space. Instead of fostering growth, this administration through agencies like CARB are choking the economic engine of key industries in all sectors with unneeded social justice ideological mandates, driving businesses, jobs, and driving precious talent elsewhere out of state.

1. CARB Has Exceeded Its Mandate

CARB’s authority exists to enforce laws enacted by the legislature not to make them. The “Drive Forward” initiative and related mandates on vehicle electrification amount to law-making by bureaucracy, using the language of regulation to impose what should be decided through open democratic processes.

By aligning itself with the Governor’s misguided executive order outlawing ICE vehicles, CARB is circumventing both the Legislature and the will of the people. Executive orders cannot compel private citizens to buy specific products or force entire industries to abandon viable technologies. Yet, that is exactly what is happening.
California’s auto policy is now being dictated not by lawmakers or voters, but by unelected regulatory staff and politically appointed officials. This is a textbook example of administrative overreach.

2. Circumvention of the Democratic Process

Although CARB claims to continually hold “public hearings,” there has never been a public referendum on whether California’s citizens wish to outlaw the internal combustion engine, mandate electric vehicles or even continue entertaining the very existence and perpetuation of an agency like CARB. There has been no ballot initiative, no voter consent, and no real democratic debate where citizens could meaningfully decide the future of our own transportation freedom. This sounds like monarchy. The very issue the current administration claims exists at a national level.

Instead, an executive order that can only be intended for internal state operations has been used to reshape markets and lifestyles. This is an end-run around democracy. CARB then implements this order through regulatory action, effectively making the governor’s decree into law. In America, we don't do it this way.

This two-step regulatory maneuver is an executive order followed by administrative enforcement that completely bypasses the legislative and electoral process. It deprives Californians of their most basic political right: to decide for themselves what policies they will live under and what agencies will even administer these policies.

3. The EPA Waiver and the Supremacy Clause

The EPA waiver allowing California to set its own emissions standards was never intended to give one state the power to dictate national energy policy. Yet CARB’s policies, by leveraging this waiver, now effectively set standards for automakers across the entire country.
This practice violates the Supremacy Clause of the U.S. Constitution, which establishes that all federal laws, not state-level regulatory fiat—governs interstate commerce and industrial standards. It is time for the EPA waiver to be revoked permanently. Or at the very least, reexamined to restore balance and prevent a single state from coercing national conformity.

4. Social Justice Has Become Ideological Engineering

CARB has now embedded “social justice frameworks” into virtually every action it takes—whether in transportation, emissions policy, or grant allocation. But this version of “social justice” is not what Dr. Martin Luther King Jr. fought for.

Dr. King’s vision was rooted in equal opportunity, not enforced equal outcomes. He sought fairness under the law—not the manipulation of markets, industries, and freedoms in the name of equity.

The economist Dr. Thomas Sowell, one of America’s greatest thinkers on race, economics, and public policy, has written extensively on this topic. He warns that social justice ideology often replaces evidence-based policy with emotional appeals and central planning. As Sowell observes, “The quest for cosmic justice is not justice at all—it’s the replacement of equality of opportunity with equality of results enforced by power.”
CARB’s use of social justice rhetoric to justify bans, subsidies, and mandates represents precisely the kind of ideological overreach Sowell cautioned against. Policies must be judged by their outcomes, not by their moral branding. Embedding social justice ideology into regulation turns public agencies into instruments of liberal activism, rather than guardians of law.

5. The Climate Science and Economics of Climate Science Are Not Settled

The notion that climate science is “settled” and CARB can “run with it”, as a result, is inconsistent with the principles of scientific inquiry itself. Science evolves through questioning and debate, not decree. The push to eliminate fossil fuels entirely, without regard to innovation in clean combustion or hybrid technologies, is dogma masquerading as policy.
Moreover, electric vehicles remain cost-prohibitive for many Californians. Forcing this transition through regulation disproportionately harms working families, small businesses, and rural communities. This is not environmental justice—it’s economic coercion.

6. Fossil Fuels Are Still Essential to Modern Civilization

Fossil fuels have driven human progress for over a century. They have powered industries, enabled mobility, and supported global development. The goal should not be to demonize energy sources but to pursue realistic, market-driven innovation across all technologies. Energy diversity, not regulatory monomania is the path to resilience and prosperity.

7. Electric Vehicle Mandates Hurt Working-Class Californians

EV mandates disproportionately impact rural families, tradespeople, and small business owners, many of whom cannot afford the cost of new electric vehicles or the infrastructure required to support them. These mandates widen inequality under the false banner of justice. That is a social injustice.

8. Restoring the Consent of the Governed

CARB’s policies are being implemented without the consent of the governed. Millions of Californians do not support these mandates, yet they are being forced to bear their economic and personal consequences. Regulatory power must always remain subordinate to the will of the people. The people tell CARB what to do. This is the American ideal.

9. CARB Has Become an Unaccountable Bureaucratic Behemoth

CARB has grown far too large, too insulated, and too expensive. It now employs thousands of people, many of whom are engaged not in air quality enforcement, but in policy-making, marketing, compliance schemes, and ideological program design. This fact alone drains our economy, by funding a bloated, do nothing bureaucratic behemoth. We need this labor to actually produce something useful. Something that contributes to the economy, not takes away.

Phrased another way, this kind of bureaucratic growth serves no productive purpose. It drains public resources, inflates administrative overhead, and burdens taxpayers while producing little measurable benefit to the average Californian.

It is time for a dramatic reduction in the size, scope, and spending of the California Air Resources Board. Cutting this bloated bureaucracy would not only serve the environment better, but it would also provide relief to working-class families who are being over-regulated, over-taxed, and under-represented.

10. Hypocrisy in Electric Vehicle Advocacy and Global Environmental Harm

CARB’s advocacy for Zero Emission Vehicles (ZEVs) reveals a stunning level of hypocrisy when viewed in the context of the global supply chain required to manufacture these vehicles. While claiming environmental virtue, CARB simultaneously supports a system that exports ecological destruction and human suffering to other nations. Where are the social justice advocates? Nowhere to be found.

The raw materials needed for EV batteries—particularly lithium, cobalt, and rare earth metals—are being sourced from countries with absolutely devastating environmental practices and virtually no regulatory oversight.

• In Argentina, vast regions are being scarred by quarter-mile-wide open pit lithium mines, plunging 3,000 to 4,000 feet deep. Satellite imagery of these regions since the rise of California’s EV mandates shows entire ecosystems decimated in the name of “green transportation.”

• Cobalt, a critical component in battery production, is primarily extracted in the Democratic Republic of Congo (DRC), a country marred by systemic child labor, unsafe mining conditions, and widespread exploitation. The DRC’s mining operations are heavily financed and controlled by Chinese state-owned enterprises, entangling California’s energy future with foreign authoritarian interests.

To claim environmental progress while turning a blind eye to child labor, ecological devastation abroad, and geopolitical dependency is not just hypocritical—it is morally indefensible.

ZEVs are not “zero-emission” if their supply chains leave behind a trail of environmental ruin and human exploitation. CARB cannot claim to stand for environmental justice while enabling eco-colonialism and human rights violations abroad.

This policy is not only environmentally regressive—it is ethically bankrupt.

11. CARB’s Legitimacy Depends on the Consent of the Governed

Today, CARB acts as though its authority is self-originating and unaccountable to the citizens whose taxes sustain it and whose freedoms it regulates.

This is a fundamental betrayal of the American principle of consent of the governed. Agencies derive their legitimacy from the people, not from executive orders, political ideology, or administrative inertia. When a public institution ceases to serve the public and begins to serve its own perpetuation or the political will of an extreme liberal regime, it loses its moral and constitutional foundation.

CARB has become an agency with a mind of its own. CARB is acting as a political instrument rather than a neutral public servant. It no longer listens to the people it claims to represent. Instead, it enforces policies conceived in liberal ideological echo chambers, detached from the economic and practical realities of everyday Californians.

Every agency must remember that it is the creation of the governed, not their master. If the people of California no longer recognize CARB as a legitimate steward of environmental policy through these extreme mandates, if it continues to operate as an unaccountable arm of political globalist agendas then the public has the right, and indeed the duty, to demand its dismantlement through legislation, restructuring, or defunding the agency altogether.

CARB’s survival as an institution will depend not on executive mandates or regulatory edicts, but on earning back the trust and consent of the people it was created to serve.

California cannot claim to be the national moral compass while ignoring our nation's democratic principles.

Conclusion

I urge CARB to withdraw the “Drive Forward” Program, abandon the ideological insertion of “social justice frameworks” into all technical regulation, and restore its focus on achievable, lawful, and science-based environmental stewardship.

CARB’s legitimacy depends on its restraint. It must regulate air quality, not human behavior, market outcomes, or political ideology.

Respectfully submitted,
Bascomb Grecian - We Love Fossil Fuels and Internal Combustion Engines