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Comment 3 for Community Air Protection Program Annual Progress Update (ab6172024progress) - Non-Reg.

First NameAlison
Last NameLaBonte
Email Addressalison@alabonteadvisors.com
AffiliationA la bonte advisors (Alba)
SubjectImplementation funding - process and limits
Comment
As a consultant to a co-lead organization of an AB617 community
selected for Community Emission Reduction Plan (CERP) development,
I have attended several Community Steering Committee (CSC) meetings
in the Bay Area Air Quality Management District's jurisdiction. 

I applaud the process in supporting members from impacted
communities to themselves develop their own CERP. Real action and
follow up on Goals, Objectives, and priority actions named and
ultimately adopted by CARB in the communities' CERPs is critical to
respecting the communities' effort to create the CERP, to maintain
the trust of community in government that CARB is committed to
address harms in frontline communities, and most importantly to
improve the health outcomes of members of AB 617 communities.  At
the most recent Bay View Hunters Point AB617 CSC meeting, we
learned that the Bay Area Air Quality Management District has only
one inspector for all of San Francisco County in their Compliance
and Enforcement Division to conduct on-site inspections. Is this
sufficient to act timely in response to all complaints? Is a
barrier to inspectors on staff availability of funding to these
enforcement agencies?

I am unable to find clear information on the budget authorization
and appropriation amounts, or mention of a process for funding to
support CARB and Air Districts in their commitments to communities
to implement and enforce actions named by the community in the
CERPs. I've reviewed section "Implementing a Community Emissions
Reduction Program." 

On page 85 of the Blueprint 2.0, I can see that "Compliance with
the community emissions reduction program .. including its
implementation, shall be enforceable by the air district and state
board, as applicable." (Health and Safety Code Section 44391.2,
subdivision (c)(8).).

Do the funds for CARB and/or Air District staff to implement and
enforce actions in these CERPs get authorized/appropriated as a
part of the Community Air Protection Program Funding (on page 45 of
blueprint) or as a separate budget line. 

Also, what are the limits to funding for implementation of CERPs.
As CSCs develop their actions, do we need to be cognizant of any
limitation to resources necessary to implement such actions?

Without clear view into a budget process that allows agencies to
receive additional funding for staffing to implement and enforce
actions in CERPs, I'm concerned the resources will be in place to
honor the actions the CSCs put in their CERPs and for this process
to result in meeting emissions reductions targets.

Attachment
Original File Name
Date and Time Comment Was Submitted 2024-07-25 16:41:36

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