2022 Climate Plan

Policy Engagement Overview

In drafting the 2022 Scoping Plan, the California Air Resources Board (CARB) offered many opportunities for public input between June 2021 and October 2022. Given the broad range of climate proposals in the plan, companies and industry groups engaged on various proposals including power sector decarbonization targets and building electrification incentives.

InfluenceMap notes the following trends in the leadup to the release of the draft plan in May 2022:

• The American Clean Power Association (ACP) demonstrated positive positions and urged policymakers to support more ambitious near-term targets.

• California utilities Edison International, Pacific Gas & Electric (PG&E), and Sempra all engaged frequently on the plan and offered some positive and some negative positions. For example, Edison International subsidiary Southern California Edison (SCE) advocated for more ambitious near-term building electrification measures, yet PG&E appeared unsupportive of ZEV targets and took unclear positions on timelines for phasing out fossil fuels. Sempra subsidiary SoCalGas questioned the feasibility of achieving a 100% ZEV by 2035 target, among other positions. The utilities occasionally submitted joint comments with the Joint Utilities Group (JUG), which seemed to advocate for a continued role for fossil gas without placing clear condition on CCS or methane abatement measures.

• Several companies pushed back on fossil fuel reductions and ZEV targets, including Valero and Phillips 66.

• Industry associations Airlines for America, California Chamber of Commerce (CalChamber) and Western States Petroleum Association (WSPA) demonstrated negative positions, with WSPA suggesting that CARB would be acting beyond its legal boundary if it included oil reduction mandates in the final climate plan.

In May 2022, CARB released the Draft 2022 Scoping Plan. The proposed decarbonization scenarios, or Alternatives, offered different pathways toward carbon neutrality. Alternatives 1 and 2 set carbon neutrality targets for 2035. Alternatives 3 and 4 set carbon neutrality targets for 2045, with Alternative 4 proposing a slower rate of clean technology deployment and a larger role on CO2 removal. CARB selected Alternative 3 as the Proposed Scenario. Many companies and industry groups engaged with a range of positions, with examples below:

• A few industry groups demonstrated strong positive positions, with ACP, Advanced Energy United and Solar Energy Industries Association advocating for CARB to pursue a more ambitious plan than the Proposed Scenario and opposing provisions in the draft that allowed for additional new fossil gas capacity.

• Several companies took positive positions, with RWE advocating for CARB to support a more ambitious power sector decarbonization target. In a joint letter, DSM North America, Salesforce, and Unilever appeared to support a 2045 pathway and advocated for CARB to prioritize near-term direct emissions reduction targets.

• California utilities continued to demonstrate a range of positions across the public input period. SCE demonstrated more positive positions than PG&E and Sempra, especially in regards to building and transport electrification. PG&E advocated for greater use of carbon capture without clarifying its position on the long-term role of fossil fuels, and SoCalGas appeared to push for weaker transport electrification targets. All three utilities submitted joint comments that supported the Alternative 3 decarbonization pathway while emphasizing reliability and affordability concerns with sector-level electrification proposals.

• Phillips 66 maintained its negative positioning, pushing back on both ZEV targets and limits on petroleum production.

• Airlines for America, CalChamber and WSPA continued to advocate for less ambitious decarbonization pathways and pushed back on proposed mandates toward reducing fossil fuel production. The National Federation of Independent Business demonstrated strong negative positions, characterizing the plan as a set of “devastating regulations that will push for zero carbon emissions by 2045 or even sooner.”