BAC submitted comments on the Draft 2022 Climate Change Scoping Plan focused on several important issues:
- BAC supports Alternate 3 as the Proposed Scenario, with some modifications, as
it will provide the greatest benefits with the fewest downsides.
- The Proposed Scenario correctly includes bioenergy and renewable hydrogen,
but should include specific recommendations to accelerate their use.
- The Proposed Scenario also correctly includes CCSU as an essential strategy to
reduce emissions quickly and to reach carbon neutrality.
- The Scoping Plan should focus much more on SLCP reductions and other
measures that benefit the climate in the near term.
- Analysis and recommendations should be based on lifecycle emissions rather
than broad generalizations about different technologies, fuels, and strategies.
- The Scoping Plan should focus transportation and vehicle strategies on
opportunities to reduce climate and air pollution in the near term.
- The Scoping Plan should provide a full and accurate assessment of technically
available forest and agricultural waste biomass.