BAC submitted comments on the Draft 2022 Climate Change Scoping Plan focused on several important issues:

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