Comment Log Display

November 20, 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.  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.

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.  This mitigation strategy
would provide substantial health co-benefits to Californians, and
as a result, provide health-related savings.

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.  Obesity has reached epidemic proportions
and is a significant factor in rising health costs. In 2000, the
estimated national costs attributable to obesity amounted to $118
billion.

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 provides access
to public transit.   When people live in compact, mixed-use
communities they drive 30% less that those who live in sprawling
suburban developments.  Strengthening this component of the
mitigation strategy will not only improve public health through
increased physical activity, but because of health cost savings,
provide an economic co-benefit as well.

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,

Jennifer Miller, PhD
On behalf of Partnership for the Public’s Health