First Name | Curtis |
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Last Name | Moore |
Email Address | camoore@erols.com |
Affiliation | |
Subject | Comments on AB 32 "early action" measures |
Comment | The Need For Immediate Reductions in Short-Lived Pollutants and The Adoption of Generic “Early Action” MEASURES This is a preface to a much longer document that provides information on a wide range of policies and measures that could be adopted to reduce global warming. The purpose of this preface is to highlight two major shortcomings of the staff proposals, to wit: First, the measures evaluated seems to be restricted to actions focused only on the greenhouse gases listed under the Kyoto Protocol. Such a narrow approach clearly contravenes AB 32, whose authors revised the definition of “greenhouse gas” specifically to assure that short-lived pollutants that cause global warming, such as black carbon, tropospheric ozone and carbon monoxide, would be addressed. Both Senate Pro Tem Perata and Speaker Nunez wrote to Chairman Sawyer to leave no question that there was awareness at the policy level of this coverage. Second, the proposals are all narrow in scope and ignore generic “early action” measures that could influence behavior broadly. These would include taxes, feebates, labels, liability regimes and the like. While it is understandable that the staff is reluctant to propose possibly controversial initiatives, excluding generic measures from even mention is ill conceived, given the unprecedented risk posed to California and the world by global warming. Taken together, these two qualities of the proposals bespeak an ignorance of or insensitivity to the rapidly accumulating evidence that several positive feedbacks are underway, increasing the likelihood that one or more tipping points will be reached beyond which the climate under which civilization has evolved will be irretrievably lost. The proposal falls far short of the ambition and vision demonstrated by the legislature’s passage of not only AB 32 but nearly a dozen other measures designed to construct a broad-based, muscular response to the threat of global warming. The Board would be well advised to review the breadth and depth of the measures and embrace the sense of urgency and scope evinced by the legislature. I regret that the longer, principal document is in a draft format. Unfortunately, the time between the announcement of an expanded set of proposed early actions and the deadline for comments did not permit comprehensive revisions and corrections. These are now underway and will be submitted when complete. Overview of Recommendations + Land based motor vehicles * Reconstitute the zero emission vehicle program, if necessary requiring deployment of advanced technologies in medium- and heavy-duty applications. * Focus on measures to alter landuse and commuting patterns. + Vessels * Identify a mechanism for, if necessary, piercing international maritime regimes to require global elimination of bunker fuel and adoption of cleaner engines. + Aircraft * Assess the contribution of aircraft to the global burden of black carbon and develop control measures. + Electricity generation and fossil combustion * Impose a single output based feebate reflecting source contributions to global warming and the ill health burden or multiple fees that do the same, with collected fees being rebated to non- or low-polluters. + Methane * Install anaerobic digesters on all waste lagoons, including publicly owned treatment works. * Install methane gas collection stems on all current or former waste disposal sites of larger than de minimis size. * Impose a “take back” program requiring vendors to collect product packages and goods, such as tires and appliances, that have reached the ends of their useful lives. + Black carbon * Substitute gasification or other means of waste utilization in lieu of open burning. * Retrofit all trucks serving the ports of Long Beach, Los Angeles, Oakland, San Francisco and Stockton with control devices. * * * Positive Feedbacks that are in Motion + Stratospheric cooling in the Arctic and Antarctic. + Arctic and Antarctic melting. + Tundra and permafrost thawing. + Tropospheric ozone increasing. + Coral bleaching and death. + Phytoplankton declining. + Oceans acidifying. |
Attachment | www.arb.ca.gov/lists/ccea2/46-total_09.06.07.pdf |
Original File Name | Total 09.06.07.pdf |
Date and Time Comment Was Submitted | 2007-09-24 14:03:34 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.