Comment Log Display

Graduate Student, San Diego State University
November 13, 2008
RE: Comments on Climate Change Proposed Scoping Plan
Dear Chair Nichols and Members of the California Air Resources
Board:
We commend the California Air Resources Board (CARB) for its
groundbreaking efforts to develop a
comprehensive plan to reduce greenhouse gas emissions, and we are
very pleased to see that the final
version of the Scoping Plan is a significant improvement over the
earlier draft.
We applaud the plan’s greater emphasis on the role of land use
planning and local government efforts in
meeting the greenhouse gas reduction goals:
• The new plan more than doubles the goal for emission reductions
from the land use sector
(from just 2 million metric tons to 5).
• The plan also calls on local governments to reduce their
emission by 15% over projected
2020 emission levels.
We also greatly appreciate the inclusion of the California
Department of Public Health (CDPH) as the
newest member of the Climate Action Team (CAT).
But before the Board adopts the final plan, we urge you to take
the following actions to maximize the
public health benefits of the Scoping Plan and protect vulnerable
and low-income communities.
1. Establish a formal role for public health in the implementation
of AB 32 regulatory and
market strategies.
While CARB has tremendous expertise and knowledge about the air
quality benefits of global
warming strategies, there is a strong need for a broader range of
information on health impacts
and health benefits of mitigation strategies. It is important that
the Scoping Plan include a clear
commitment from the Board to reach out to the broad range of
health constituencies.
.
We ask that you direct staff to come back within three months with
recommendations for
establishing a formal process to include state and local public
health agencies and organizations
in the development and review of all proposed greenhouse gas
reduction measures, including
proposed regulatory and market mechanisms, so that they can
provide input and analysis of the
broad range of health benefits and concerns related to those
measures.
2. Ensure protection for already over-impacted communities.
Mitigation strategies, such as cap-and-trade programs or siting of
new “green” facilities, must not
exacerbate already existing health inequities in low-income
communities. Such communities are
already unequally burdened by extremely poor environmental
conditions and poor health. This
plan must include adequate safeguards for these communities. [
Insert specific information about
your community and how it is already burdened by poor air quality.
] The Board must insure that
each measure included in the Scoping Plan will not only assist
statewide greenhouse gas
reduction goals but will also improve conditions in local
communities. This means that the
measures must both prevent creation of localized pollution “hot
spots” and demonstrate the
ability to achieve real improvements in air quality and health
conditions in all communities in the
state.
2
We ask that you establish additional measures in the Scoping Plan
to identify and ensure
protection of vulnerable and low-income communities and prevent
any backsliding on air quality
protections. This includes directing CARB staff to do the
following:
a. Establish within one year a cumulative impacts screening
protocol to identify those
communities most impacted by air pollution;
b. Design regulator and market-based compliance mechanisms to
achieve maximum
emission reductions and co-benefits in these communities; and
c. Initiate a public process to determine how resources generated
through
implementation of AB 32 measures can be allocated to minimize
adverse health
impacts and create climate resiliency in our most vulnerable
communities.
3. Set a higher target for greenhouse gas reductions from the land
use sector.
The current target of 5 million metric tons (MMT) does not keep us
on track for achieving our
2050 greenhouse gas reduction goals. We need to reduce vehicle
miles traveled (VMT) by 10%
by 2020, but the current 5 MMT target equates to only a 4%
reduction in VMT. By assigning
only minimal emission reduction targets to land use and transit
policies, CARB misses a critical
opportunity to spur meaningful change in the built environment to
mitigate climate change and
improve the public’s health.
Requiring better land use and transportation planning will reduce
greenhouse gas emissions,
improve air quality and physical activity levels, and reduce
obesity-related illnesses such as
diabetes and cardiovascular disease. Twenty-five percent of all
development on the ground in
2020 will have been built between 2010 and 2020. This presents a
tremendous opportunity to
improve the design of new development so that it allows people to
choose alternatives to driving
and provide access to public transit. When transit is convenient
and reliable people use it: 42%
of Bay Area residents who live within ˝ mile of public transit use
it to get to work. When people
live in compact, mixed-use communities they drive 30% less that
those who live in sprawling
suburban developments.
CARB should increase the goal for emissions reductions due to
smart land use planning to 11 –
14 MMT. This would send an important signal to create communities
that enable people to get
our of their cars and walk, bike, or take public transit—improving
their own health while
improving the health of the planet.
Thank you for considering these suggestions.
Sincerely,
Lianne Dillon
Masters of Public Health Graduate Student, San Diego State
University