
The County of San Diego recently released the final Regional Decarbonization Framework Technical Report, a technical and policy analysis of deep decarbonization in the San Diego region. The Energy Policy Initiative Center (EPIC) authored Chapter 8, which assesses current commitments in Climate Action Plans (CAP) to determine if additional activity would be needed to put the region on a trajectory to meet these goals and to identify opportunities for local jurisdictions in the region to take further action to support the decarbonization pathways.
To this end, EPIC completed three separate but related analyses:
- A review of authority of local governments and agencies to act to influence and regulate greenhouse gas (GHG) emissions, based on a summary of key federal, state, and local agencies, and key legislation and regulation at the federal and state levels to help to clarify the ability of local governments to act to reduce GHG emissions;
- A review of CAPs to identify similarities and differences, determine how often measures are used, relative GHG impact of decarbonization pathways and measures, and integration of social equity considerations; and
- A scenario analysis to estimate the total impact of the GHG reduction commitments in all adopted and pending CAPs and the potential GHG impact of a scenario of applying the best CAP commitments to all jurisdictions.
Based on the results of the above analysis and additional research, EPIC identified opportunities for further local action and regional collaboration in each of the four decarbonization pathways.
Based on our analysis, the following overall key findings emerge. More detailed findings are provided in each section of the report, including findings from the analysis and opportunities for local action and regional collaboration.
- Local Jurisdictions Have Authority to Influence and Regulate GHG Emissions – Local governments can influence and regulate GHG emissions by accelerating state statutory targets and policies, adopting ordinances to go beyond state law, and using unique authority to adopt and implement policies. Local authority comes from both constitutionally derived police power and delegated authority from state statutes. Constitutionally derived police power grants a broad, elastic authority to act where such action is reasonably related to a legitimate government purpose and has a reasonable tendency to promote public health, safety, or the general welfare of the community. It is limited by general state law and state and federal constitutions. The full extent of a local jurisdiction’s police power to regulate GHG emissions is unknown. Delegated authority includes, among other things, analyzing land use environmental impacts and mitigating them, adopting more stringent building codes, building infrastructure, or creating community choice aggregators (CCA) to supply electricity.
- Adopted and Pending CAP Commitments are Insufficient to Reach Decarbonization Goals – Local commitments in adopted CAPs for transportation, electricity, and natural gas GHG reductions contribute a relatively small portion of the total reductions needed to reach net zero GHG emissions in 2035 — about 2 million metric tons CO2e (MMT CO2e), which would leave about 12 MMT CO2 Including the commitments from the City of San Diego draft CAP 2022 in this analysis would yield GHG reductions of about 5 MMT CO2 in 2035, leaving about 8.5 MMT CO2e. Even if the most aggressive CAP measures are applied to all jurisdictions in the region, regardless of whether they have a CAP in place, significant emissions would remain (approximately 7 MMT CO2e in 2035), mostly from natural gas combustion and on-road transportation. Note remaining emissions from other emissions categories also would have to be addressed. Similarly, including the best CAP commitments from the City of San Diego draft CAP 2022 would reduce the amount of remaining emissions to about 5 MMT CO2e in 2035.
- Opportunities Exist for More Jurisdiction to Adopt and Strengthen Existing CAP Measures – Based on the review of CAPs, there is an opportunity for more jurisdictions to adopt CAP measures already adopted by some jurisdictions in the region. Similarly, based on the scenario analysis of the combined GHG impacts of CAP measures, there is an opportunity for most jurisdictions to strengthen their existing CAP measures. While many policy examples exist in our region, there also are other examples from around California and the U.S. of policies that have not been included in CAPs in the region.
- Additional Policies Would be Needed to Decarbonize Transportation and Buildings – Based on adopted CAP commitments, expected GHG reductions in 2035 from measures to reduce vehicle miles traveled (VMT) and increase use of zero-emissions vehicles (ZEV) are insufficient to achieve the level of GHG emissions reductions — mainly from ZEVs outlined in Chapter 3. Local uptake of ZEVs beyond what is expected from state and regional incentives likely would require more local incentives. Similarly, expected GHG reductions in 2035 from building measures in adopted CAPs are insufficient to meet the goals outlined in Chapter 5. In particular, more measures would be needed to electrify existing buildings.
- Opportunities Exist for Regional Collaboration in all Decarbonization Pathways – Regional collaboration could include collecting and tracking data, conducting analysis, providing support to develop and implement policies, and convening stakeholder and working groups to develop regional strategies and monitor progress. Examples exist for regional collaboration, including the Accelerate to Zero (A2Z) project to increase use of ZEVs..
- Additional Work Would be Needed to Integrate Social Equity into Climate Planning – Based on a preliminary review, the integration of social equity in adopted and pending CAPs is limited, inconsistent, and lacks specificity. Additional work would be needed to develop the capacity and tools to understand and address the equity implications of all decarbonization policies in the San Diego region, including data collection and analysis; regional guidance documents; and regional working groups to coordinate, advise, track, and monitor how equity is being addressed in climate planning.
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