The IEMAC makes a number of recommendations in its 2023 annual report, covering greenhouse gas accounting, affordability, market links with other jurisdictions, and subsurface carbon management.
IEMAC’s recommendations are based on the backdrop that, while emissions are on a downward trend, California is not on track to hit its emission reduction targets in 2030.
First, IEMAC recommends adjustments to the methodology employed by CARB in accounting for emissions. It noted several methodological concerns.
- Among other things, IEMAC notes that CARB should reevaluate the calculation of biogenic CO₂ emissions as this could encourage certain mitigation measures notwithstanding controversy over whether biogenic CO₂ ought to be treated differently from fossil CO₂.
- IEMAC recommends changes in the treatment of land sector emissions and removals, which are presently excluded from California’s GHG inventory, but in light of recent wildfire seasons comprise a significant source of CO₂.
- IEMAC recommends the adjustment of the 1990 statutory emissions baseline, since CARB recently shifted to using MRR data as the primary source for the GHG Inventory; this change was viewed as improving data accuracy but also had the effect of retrospectively lowering historical emission estimates. The IEMAC recommended that this change underscores the need to review and possibly adjust the 1990 baseline to maintain policy stringency.
Second, IEMAC addresses concerns about policy equity in the climate transition.
- IEMAC emphasize that vulnerable Californians bear the brunt of these climate impacts, and that the transition to a zero-emission economy must be both affordable and equitable, particularly benefiting disadvantaged communities. It notes that current approaches, such as raising electricity prices to fund wildfire mitigation, disproportionately affect low-income households.
- It argues for a shift towards more cost-effective strategies, advocating for the role of California’s greenhouse gas (GHG) emissions market. It stresses the market’s flexibility in promoting least-cost abatement strategies compared to rigid regulations, potentially lowering overall mitigation costs. IEMAC also recommends tighter regulations and adjustments to allowance supply as part updates to the market.
Third, IEMAC encourages California to share its policies. It argues that while California emits a small fraction of global greenhouse gases, its policies and technologies have a disproportionate impact due to their potential for replication and adoption beyond state borders.
- It cites examples like California’s cap-and-trade system, which was linked early with Quebec’s through the Western Climate Initiative (WCI), demonstrating the potential for collaborative emission reductions across regions.
- It advocates for expanding these linkages, particularly with Washington State’s recently passed Climate Commitment Act, which mirrors California’s.
- They argue that expansion actually improves efficiency by reducing administrative costs and stabilizing business costs across a larger market.
