On November 16, 2022, the California Air Resources Board ("CARB") finalized its 2022 Scoping Plan (the "Scoping Plan") laying out how California plans to achieve its long-term climate target of carbon neutrality. The State's first climate target was established by the Global Warming Solutions Act of 2006 (the "Act"), which set a target of reducing greenhouse gas emissions to equal 1990 levels by 2020 and required the creation of a climate scoping plan every five years. The Act calls on the Governor to coordinate with CARB on setting emission reduction goals and outlining them in the scoping plan.

California exceeded its original 2020 goal, reducing greenhouse gas emissions to below 1990 levels in 2014 – six years ahead of schedule. The State then passed SB 32 in 2016, which set California's climate goal to a 40% reduction below 1990 levels by 2030. Despite some estimates suggesting that California was not on track to reach its 2030 goal, California reaffirmed its commitment to reducing its greenhouse gas emissions and passed more ambitious legislation in 2022. In September of 2022 California passed AB 1279, which directed CARB to create the Scoping Plan with the set goal to reduce greenhouse gas emissions by 85% from 1990 levels by 2045. This plan serves as a roadmap outlining key policies that California is adopting to dramatically decrease its greenhouse gas emissions. The Scoping Plan is California's latest and most ambitious greenhouse gas reduction action plan.

The Scoping Plan builds on California's previous legislative and gubernatorial commitments and calls for a "three-pronged" approach to reaching the emissions target through utilizing incentives, regulations, and carbon pricing. 1 The stated goal of the Scoping Plan, and California's climate policy in general, is to achieve emissions levels by 2050 that are targeted to prevent the planet from warming above 1.5°C.2 While the Scoping Plan does not itself make regulations or investments, it outlines California's numerous environmental and climate policies in an all-inclusive blueprint on how California will achieve its emissions reduction goals.3

Given California's status as a market leader both nationwide and globally, how California addresses climate change will undoubtedly have an immense impact on the rest of the country. Included in the Scoping Plan is a description of how California's direct investments in green technologies and climate resilience will reduce and mitigate the impacts of climate change.4 Among these are:

  • $13.8 billion for lower-carbon transportation, centered on public transit and improvements to biking and walking infrastructure
  • $10 billion in zero-emission vehicles, with a stated goal of having every new passenger vehicle sold in California be a zero-emission vehicle by 2035
  • $9 billion in both clean energy and drought/wildfire resilience

Designed to be both long-term and comprehensive, the Scoping Plan accounts for unique challenges faced by California's efforts to decarbonize. This is the first of California's scoping plans to include modeling of emissions from wildfires and how natural working lands can be used to sequester carbon.5 The Scoping Plan outlines how California will develop nature-based carbon sinks through activities such as wetland conservation and the promotion of urban forests to offset the expected emissions caused by wildfires.6

Throughout the Scoping Plan, California has consulted with an Environmental Justice Advisory Committee to advise the State on how to remedy historic discrimination and reduce the disproportionate impacts of climate change on disadvantaged communities.7 As part of California's efforts to reduce historic inequities, the state has dedicated itself to providing low-income households with low-to-no cost solar units as well as energy efficiency housing upgrades.8

The Scoping Plan does not intend to fully phase-out all sources of greenhouse gas emissions, noting that fossil fuels will still be required for grid reliability and legacy fleets of fossil fuel consuming vehicles.9 To combat what California views as the need for continued usage of fossil fuels, the Scoping Plan outlines how California will promote carbon capture and sequestration techniques such as mechanical direct air capture of CO2 to reduce the amount of greenhouse gasses in the atmosphere in order to meet its climate goals.10

California is not alone. New York's Climate Action Council approved its own 2022 scoping plan in December. New York has similarly set its climate goal to reductions of greenhouse gas emissions to 85% of 1990 levels by 2050, with an interim goal of a 40% reduction by 2030.11 However, the two states have prioritized different areas in order to achieve their respective goals. California places a heavier emphasis on the use of carbon capture and sequestration technologies to achieve its targeted greenhouse gas emission levels,12 whereas New York's scoping plan places an emphasis on its proposed economy-wide "cap-and-invest" program that would cap emissions across the state and auction allowances that would provide revenue for investments into clean energy and climate reduction strategies.13

By releasing plans dedicated to reducing greenhouse gas emissions by 85% from 1990 levels by 2045, California and other states such as New York are firmly committing to emission levels to limit warming beyond 1.5°C. With major economies strongly backing net-zero initiatives, there is ample opportunity for both new and old industries to adapt and capitalize on this rapid push to mitigate climate change.


1. Id. at 11.

2. Id. at 3-4.

3. See, e.g., id.

4. See id. at 26.

5. See id. at 6.

6. See, e.g., id. at 256-60.

7. See id. at 29.

8. See id. at 8.

9. See id. at 190-202. California plans to phase out the sale of all new non-zero emissions vehicles, see id. at 100, but the Scoping Plan accounts for the use of fossil fuels by vehicles still in use. See id. at 190.

10. See id. at 84-88.

11. See Scoping Plan, N.Y. State Climate Action Council 2 (2022), https://climate.ny.gov/-/media/project/climate/files/NYS-Climate-Action-Council-Final-Scoping-Plan-2022.pdf.

12. See Cal. Air. Res. Bd., 2022 Scoping Plan For Achieving Carbon Neutrality 84-97 (2022), https://ww2.arb.ca.gov/sites/default/files/2022-12/2022-sp.pdf.

13. See Scoping Plan, N.Y. State Climate Action Council 339-49 (2022), https://climate.ny.gov/-/media/project/climate/files/NYS-Climate-Action-Council-Final-Scoping-Plan-2022.pdf.

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