Comment Log Display

Public Health Implications of AB 32 Alternative Mitigation Policy
Proposals   

Thank you for the opportunity to comment on the October draft of
the Scoping Plan for the California Global Warming Solutions Act of
2006.  It is critically important to reduce greenhouse emissions
and build a clean and sustainable energy system that can support
the economy without destroying the global environment.  I deeply
appreciate the diligent efforts of the staff to address these
complex issues.
  
The plan represents a portfolio of policy proposals.  My focus is
on assessment of their public health implications.  The October
revision reflects greater recognition of the importance of engaging
the public and coordinating efforts with local governments,
especially on issues related to the built environment, land use,
and transportation and their implications.  These are important
improvements.

What the Air Resources Board still needs to do is to discuss the
relative merits of the available policy alternatives. 

 Alternatives under consideration would be expected to vary with
regard to their public health impacts.  Consideration of the
differences in public health impacts would inform the Board’s
deliberations.  Moreover, public health benefits also have economic
benefits that would be relevant to selection of cost effective
measures.

Some reasons that alternatives might differ in their public health
impacts are:

•	Actions that reduce CO2 emissions but retain combustion
technologies will generally have fewer public health benefits than
those that eliminate combustion and resulting co-pollutants.  

•	Actions that reduce combustion or invest in clean and
sustainable technologies or create other environmental benefits in
proximity to populations, particularly vulnerable populations and
communities, will have greater public health benefits than those
that do not.

•	Actions that build clean and sustainable energy infrastructure
and energy security for communities will have greater public health
benefits than those that merely reduce emissions.

•	Actions that reduce greenhouse emissions by improvements to the
built environment can also address important environmentally
mediated conditions such as diabetes and obesity so would have
public health benefits beyond reductions in air pollution.

•	Actions that enhance the ability of the public to participate
and contribute to solutions are more likely to reflect the public
interest and so promote public health than those that do not.  

If the Board is going to adopt the policy strategies as presented,
it might consider commissioning a comparative review of the public
health and overall public benefits of policy alternatives to be
completed before regulations are adopted.  In addition, the Board
may wish to consider directing the staff to set up means to track
the implementation of policy measures to allow on-going, objective
determination of whether the strategies are achieving the policy
aims of the statute.  

The State of California is critical to the development of a just
and sustainable model for how to address climate change and lead a
conversion to a new energy system.  As Governor Schwarzenegger
points out, California leads the world.  The best model California
could present would reduce emissions while promoting public health,
democracy, and civic engagement; protect and enhance vulnerable
communities; and build the clean and sustainable energy system that
we need for the future.  

Thank you for your consideration of these comments.  Details are
in the attachment.