Comment Log Display

February 23, 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,

Suzanne Bertz-Rosa