Comment Log Display

The Coalition for Clean Air was an early supporter of the Global
Warming Solutions Act of 2006 (AB 32, Nuñez-Pavley) and has been
actively involved in its implementation. We continue to strongly
support the law as a meaningful response by the largest state in
the U.S. to the grave threat of rapid changes in our planet’s
climate. We believe that AB 32 has been mostly successful so far,
and we’re pleased to hear ARB’s projection that the state is on
target to meet the 2020 requirement. We need to continue that
progress in order to meet the 2030 and 2050 goals.

The Scoping Plan Update should continue policies that have been
successful and strengthen them. SB 350 (de León, 2015) requires
strengthening of renewable electricity and building efficiency
standards and promotes transportation electrification. ARB should
also establish more aggressive standards in other areas.

The SPU should promote the rapid transformation of California’s
transportation sector to zero emission technologies As noted in the
Vision for Clean Air document in 2012 – California’s transportation
sector needs to move rapidly toward zero and near-zero emission
technologies to achieve federal health-protective clean air
standards and California’s climate change goals. This transition
needs to encompass passenger vehicles, the freight 
 sector, and low carbon fuels as well as smarter growth strategies
to reduce pollution, improve air quality and provide Californians
with healthier mobility options. 
Elements of transportation sector planning should include:
Increasing transit ridership and reducing GHG emissions by
targeting funds to operate increased levels of transit service and
implementing fare reduction strategies that incentivize greater
transit utilization. 
Strengthening the LCFS, which is proving successful in diversifying
California’s transportation fuel mix. 
Maintaining momentum in vehicle efficiency improvements beyond 2025
and achieving the Zero Emission Vehicle program targets. 
Providing clear direction on the rapid development and deployment
of advanced zero- and near-zero emission technologies in the medium
and heavy duty sectors. Zero emission buses and the Sustainable
Freight Action Plan are critical to cutting greenhouse gases, black
carbon and local diesel particulate pollution impacts. 

A critical element of transitioning the transportation sector must
be to provide clean air benefits to communities most disadvantaged
by air pollution and toxic hot spots such as freeways, port
traffic, rail yards and distribution centers.
ARB should also adopt regulatory standards to reduce emissions from
industrial sources, including refineries.

ARB should seriously consider Concepts 2 and 3, as clear and firm
regulatory standards have been the most effective tool for reducing
emissions and driving technological innovation, the two most
important results of AB 32. In fact, we would support a combination
of Concepts 2 and 3 which embraces emission-reducing standards for
both the transportation and industrial sectors.
The choice of an alternative should include consideration of which
concept better advances environmental justice by reducing pollution
in the communities that are most burdened by it.


If ARB decides to continue the cap-and-trade program, virtually all
of the pollution allowances should be auctioned off, as recommended
by the expert economists who advised ARB on establishing the
program, rather than given away to big polluters. Instead of
rewarding early action on the part of industry to plan, invest, and
innovate to reduce its pollution, free allocation only rewards
stalling, delay, and obstruction of necessary cleanup. ARB should
ensure allowance value is put to use where it can be certain it
will benefit all Californians and help achieve the goals of AB 32.