Comment Log Display

COMMENTS ON AB 32 PROPOSED SCOPING PLAN,
SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008

D.	Public Health and Environmental Justice Issues Must Be
Addressed

?	The Proposed Scoping Plan has failed to adequately respond to
concerns raised by the EJAC and public health community.
?	CARB should adopt the EJAC's recommendations to increase the
2020 target for land use, invest in public transit in low-income
communities, and create incentives for local governments to reduce
their emissions.
?	The public health analysis should include specific data about
public health impacts associated with community design, including
impacts on obesity, chronic disease and public safety.
?	CARB should ensure that the public health community has an
ongoing, formal role in shaping AB 32 policy.

Sierra Club supports the following text recommended for insertion
into the Plan by the Coalition for Clean Air and other California
organizations.

•  ARB will adopt a cumulative impacts assessment method within a
year or prior to the adoption of AB 32 related market-based
regulation and identify communities “already impacted by air
pollution” cumulatively to ensure uniformity and consistency among
the state, air districts and other local governments so that
communities identified as impacted by one agency do not get
categorized differently by another;

•  ARB will evaluate the potential negative impacts (if any) of
all subsequent AB 32 regulations in these communities prior to
their adoption and incorporate safeguards; 

•  ARB will design the market mechanism compliance protocols to
achieve maximum emission reduction and co-benefits in the most
disadvantaged communities by including incentives and restrictions;
and

•  ARB will initiate a public process within three months to
determine and recommend the percentage of resources generated
through AB 32 related auction and fee revenues that can be directed
to assist in adaptation and emission reduction measures for those
communities and small businesses most disadvantaged by climate
change or air pollution impacts.