The scoop on the Scoping Plan: California’s plan relies too heavily on emerging technologies (Part 3)

This post was co-authored by Caroline Jones, analyst for U.S. Climate, and Katie Schneer, High Meadows fellow for subnational climate policy.


Photo credit: pexels

In May, the California Air Resources Board released the draft 2022 Climate Change Scoping Plan, a roadmap that will guide the state toward meeting its 2030 emissions target and achieving net-zero emissions no later than 2045. This four-part series will unpack several key aspects of the plan and evaluate whether they raise California’s climate ambition to the levels needed to protect communities from the worst climate impacts.

While California already has most of the tools it needs to meet its climate goals, there are still hard-to-tackle areas of the economy – like industry – that will demand new climate solutions not yet widely available on the market. This is where newer technologies like hydrogen and carbon capture & sequestration (CCS) may help address those emissions. Carbon dioxide removal (CDR) is another solution needed to address legacy carbon pollution in the atmosphere, but all of these approaches need more innovation investment now to reach scale safely, affordably and reliably.

Currently, CARB is over-relying on these emerging solutions for critical emission reductions and removals in California’s Draft Climate Change Scoping Plan, rather than maximizing proven solutions we have right now – like reducing more pollution from the power and transportation sectors, and tightening the state’s cap on emissions. As a result, this strategy leaves reductions in climate pollution that can and should be achieved this decade up to chance. And as we’ve explained in Part 1 and Part 2 of this series, near-term ambition is essential for minimizing the most devastating climate damages in the long run, like wildfires and droughts.

An analogy from… football

To help understand how CARB should strategize the deployment of proven solutions and strategies with newer, emerging ones, think about this football analogy (yes, football!) for the draft Scoping Plan:

Imagine you’re a football coach in the state championship game – it’s now or never to defeat climate change. You’re going to put your star players out on the field – that is, your proven technologies and strategies like clean energy and electric cars, trucks and buses – because they are going to maximize points on the board, aka pollution cuts. A smart coach doesn’t expect their freshman benchwarmers – emerging technologies like CDR and hydrogen – to bring home the win right now because they still need more training and practice. But as they get better – as the cost of these technologies falls with innovation and our understanding of their performance and potential risks improves – they could be important for the team’s success down the line. However, we don’t know exactly what that role looks like yet. Do you roll the dice on new talent that has big potential if you work with them and train them right, or rely on the first string to deliver the points you need right now?

The bottom line: You do what you can to maximize your star players, that is, your proven technologies and strategies, first. California’s Scoping Plan could be getting more pollution reductions from its existing star players like pushing for a cleaner power sector, more zero-emission medium- and heavy-duty vehicles, and a stronger cap on emissions. Instead, it relies too heavily on emerging technologies like hydrogen, CCS and CDR to score important points down the line, when we need those guaranteed points right now.

Importantly, newer players like hydrogen, CCS and CDR shouldn’t be written off, but we don’t know yet how reliable – or scalable – they’ll be on the playing field. They need more practice (research, development and demonstration) before we should confidently rely on them for securing cuts in pollution we need to guarantee.

Here is how the Scoping Plan frames these new technologies and what should change.


Hydrogen has potential as a decarbonization strategy in certain hard-to-abate sectors like heavy industry, global shipping and aviation. The draft Scoping Plan recognizes this, but also envisions deploying hydrogen in light-duty passenger transportation, which should instead be electrified. Using green hydrogen in passenger vehicles would require much greater quantities of renewable energy — perhaps as much as two to five times as much renewable energy according to internal EDF analysis — than direct electrification of light duty transportation.

The climate impact of hydrogen is another critical consideration. Soon-to-be published EDF research found that if hydrogen leaks are not fully accounted for then many of the climate benefits of even green hydrogen could be eroded. EDF’s findings point out that carbon dioxide is not the only important climate pollutant to worry about when it comes to hydrogen generation, especially when it’s not produced with renewable energy. Hydrogen itself can be an indirect greenhouse gas that causes warming, and when hydrogen comes from natural gas, it brings significant risk of methane emissions contributing to the overall climate warming effects of fossil fuel-based hydrogen.

Hydrogen, as the smallest molecule in the world, is very difficult to contain and is prone to leaking into the atmosphere through the entire value chain. The risk for leakage increases the more hydrogen has to travel from production to end-use location. Assessing and minimizing leakage risk is crucial to the successful deployment of hydrogen infrastructure in California’s policy. In order to prevent leakage, hydrogen infrastructure needs to be ready to contain the molecule at the design phase. Because the climate impacts of this type of hydrogen production are potentially significant, fossil-generated hydrogen should not be considered a climate solution in this Scoping Plan. The Scoping Plan must be clear that hydrogen should be prioritized only for hard-to-decarbonize sectors, and only where leakage can be assessed and prevented. 

Carbon dioxide removal (CDR)

Carbon dioxide removal approaches leverage lands, oceans, and/or technologies like direct air capture (DAC) remove legacy pollution from the atmosphere and counterbalance emissions in hard-to-abate sectors. Even if everything were zero-emission today, we have already emitted so much pollution that the atmosphere will continue to warm, so we have to remove greenhouse gasses that are already in the atmosphere. However, CDR should not be a substitute for significant reductions at a pollution source. CARB should focus on maximizing reductions and only rely on CDR for those emissions which absolutely cannot be abated.

The draft Scoping Plan relies heavily on CDR deployment – potentially to an even greater extent than was modeled in 2020 when CARB began exploring pathways to net-zero emissions, and certainly greater than was contemplated by the legislature last session in AB 1395. E3’s modeling shows that California will reduce their direct emissions from pollution sources levels by 78% below the 1990 baseline by 2045, relying on CDR to compensate for the remaining 22% of emissions. While the scale of the climate pollution in our atmosphere is concerning, the Scoping Plan absolutely should not rely on CDR as an alternative to near-term emission reductions, especially from sources that have a significant impact on communities overburdened by pollution.

CARB should re-consider the amount of CDR assumed in the Scoping Plan and scale that back closer to the 10% level assumed in AB 1395, which was based on CARB’s 2020 carbon neutrality report.

Carbon capture and sequestration (CCS)

Carbon capture and sequestration (CCS) has been under development and deployed for years, but only at a small scale. This process captures carbon dioxide from industrial processes and fossil fuel plants and permanently stores it underground. While CCS will likely be necessary in hard-to-decarbonize sectors like cement, it should not be seen as a tool to contribute to fossil fuel production.

The Scoping Plan assumes a significant deployment of CCS, including in fossil fuel refining. Assuming that carbon capture technology will be massively scaled up could result in delaying or failing to ramp down fossil fuel production and consumption, which would actually set back progress in addressing climate change.

Back to the football analogy: CARB, this is how you write a championship-winning climate plan: You prioritize your proven, star players who can score big now over new, promising players who need more practice. Emerging technologies will have roles to play in achieving California’s climate goals, but they’re carrying the team in a way they might not be prepared for. The rookies in this analogy, hydrogen, CCS and CDR have a place on the team – but we need to make sure they are ready to take the field, play as a team and put points on the board.

In the final installment of our “Scoop on the Scoping Plan” series, we’ll unpack what the draft plan outlines for the transportation sector, California’s largest source of climate pollution. Read the first two parts of our series on near-term ambition and the role of California’s cap & trade program, and building an affordable, clean and safe energy system.

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