Submitted Comment Name Valerie Ventre-Hutton Affiliation 350 Bay Area Action Subject SB 905 Implementation: Health and Safety Code Section 39741.1(a)(1) Message With dozens of CCUS projects already seeking permits in California, it is critical that CARB design, implement, enforce strong protections for front-line communities as mandated by SB 905. One of CARB’s most critical charges under SB 905 is cited under Health and Safety Code Section 39741.1(a)(1), CARB must “[e]valuate the efficacy, safety, and viability of CCUS and CDR technologies and facilitate the capture and sequestration of carbon dioxide from these technologies, where appropriate.” This section of the Code directs CARB to facilitate deployment of CCUS technologies. However, CARB is not directed to deploy CCUS wherever possible, or to sequester a certain quantity of carbon. Rather, CARB is charged with facilitating deployment “where appropriate” after due consideration of the various ‘technologies and applications’ efficacy, safety, and viability. Our organization, 350 Bay Area Action, views carbon capture, use, and storage (CCUS) technologies as a dangerous distraction from the only viable path forward on climate: phasing out fossil fuels and replacing them with clean renewables–wind, solar, and storage. Nonetheless, we accept CARB’s mandate to facilitate deployment of those technologies as a reality of SB 905 even if we strongly disagree as a matter of policy. To that end, we agree with conducting a thorough evaluation of the “efficacy, safety, and viability” of the various technologies and applications, and only deploying CCUS where appropriate. We also ask that in its rule-making and implementation of those rules, CARB confine CCUS at most to truly hard-to-decarbonize sectors like cement, and rule out CCUS in the energy and fuels sectors. File Upload (i.e., Attachments): N/A N/A
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