Comment Log Display

February 21, 2008
 
 
Mary Nichols, Chair
Air Resources Board
California Air Resources Board
1001 "I" Street
P.O. Box 2815 
Sacramento, CA 95812
 
Re: Proposition 1B Goods Movement Emission Reduction Program
 
Dear Ms. Nichols:
 
I was pleased when the Governor declared his unhappiness last year
with the
proposed 2024 attainment date for the 24-hour ozone standard in
the San
Joaquin Valley. I was pleased when you and your colleagues on the
board
declared last November that, while 2024 may be the legally
approvable date,
you believed 2017 to be the proper target date for attainment and
that CARB
would commit its weight to the achievement of that goal.
Unfortunately, the CARB staff recommendations for target corridor
allocations under the Goods Movement Emission Reduction Program
(GMERP) show
no evidence of this commitment.
 
As you know, mobile sources are by far the largest contributor to
the
Valley?s Ozone problems, representing about 85% of ozone
emissions, with
goods movement emissions being the largest single source. The
September 19
Staff Draft Concepts for Implementation states that ??trucks are
the
dominant source of health risk from goods movement in most
impacted
communities.? The staff recommendations on funding targets by
source
category accordingly allocate 76% of the bond monies to truck
retrofits and
replacements.  CARB EMFAC data shows there is more truck VMT in
the San
Joaquin Valley than in any of the other major trade corridors.
Indeed, 45%
of the truck VMT occurs in the Valley, while the next highest
number is 35%
in the South Coast. Yet your staff recommends that 55% of the
funding be
allocated to the South Coast, while only 25% is allocated to the
Central
Valley, to be shared between the San Joaquin Valley and the
Sacramento
non-attainment zone.
 
I recognize the complexity of coming up with a fair and equitable
allocation
method, but the staff recommendations are so far from being
remotely fair as
to require your personal intervention. I am not proposing
different
allocation criteria than those selected by your staff, but I am
respectfully
requesting that they be applied and weighted properly.
 
* The emissions reductions needed to bring the Valley into
attainment of the
24-hour ozone standard by 2017 must be included in the calculation
under the
?SIP Needs? criteria. The San Joaquin Valley is the only trade
corridor that
has a target date for 24-hr ozone attainment within the time
horizon of the
bond measure. It may not be a legally binding commitment, but it
is our hope
that the CARB board was sincere in stating its intention to lend
its weight
to the 2017 target date.
* The ?Goods Movement Emissions? criterion should be applied based
on the
latest official inventory numbers ? those that CARB has asked the
air
districts to use for their SIP plans ? not some new inventory
numbers that
have been subjected to no public vetting process and that appear,
at first
glance, to be seriously flawed.
* Population figures should be normalized using per capita
exposure to goods
movement emissions. There is nothing in the bond measure nor in
the
implementing statute that suggests that raw population numbers are
a fair
basis for this allocation. Chapter 3.2, Section (b) (1) states
that that
CARB should give ??priority to emission reduction projects that
achieve the
earliest possible reduction of health risk in communities with the
highest
health risks from goods movement facilities.? Certainly the port
areas meet
this criterion, but so do the residents of the Valley, 71% of whom
reside
within five miles of Highway 99 or Interstate 5, with those in the
lowest
socio-economic groups living in closest proximity to these
heavily
trafficked good movement corridors.
 
Calculations made by the San Joaquin Valley Air Pollution Control
District
show that when these considerations are applied to the allocation
criteria
chosen by the CARB staff, the Valley is deserving of a minimum
allocation of
37% of the bond funds. While CARB staff has indicated that ?the
San Joaquin
Valley with high through-truck and rail traffic will benefit from
projects
administered by agencies in other corridors,? there is no
guarantee of that
in the guidelines proposed by staff.  I respectfully request that
the target
allocations be adjusted to assure the Central Valley a minimum
allocation of
37% of the bond funds.
 
Thank you for your consideration of our concerns.
 
 
Sincerely,
 Teresa Flores
 
 
 
Cc: Governor Arnold Schwarzenegger
       CalEPA Secretary Linda Adams
       CARB Board Members
       Mr. James Goldstene, CARB
       Mr. Seyed Sadredin, San Joaquin Valley Air District