First as a tribal representative I find it offensive that a
tribe would be required to submit comment as a part of the public
process. This substantiates that CARB failed to provide meaning
full consultation government to government for the draft scoping
plan and ask that such consultation as required by CA Executive
Order B-10-11 and ask that CARB work with the Governors
Tribal Advisor to ensure tribes are engaged and provided meaningful
consultation.
Secondly, this draft Scoping Plan mentions tribes less than 6
times. In fact it even claims on page 31 to have received input
from tribes during public meetings in June 2021 but this claims
fails to provide proof or formal comment provided by tribes. This
claim is at minimum disingenuous. In fact it was not until February
of 2022 that a tribal representative, as required by law, to the
EJAC.
Thirdly, this document fails to appropriately consider to
determine the impacts to tribal and rural communities which are
typically operating on isolated utility systems which both
alienates and burdens them disproportionally in meetings state
goals for 2030 and 2045. It also often leaves them out of
opportunities for investment program often due to failing utility
systems. Carbon neutrality is much more difficult for tribal
communities engaged in subsistence life ways.
Finally, with the release of the draft on May 10 there was no
effort to engage tribes and there are no tribal meetings
planned to specifically engage tribes in a meaningful way unless
tribes are expected to participate in public meetings which again
does not meet the expectations of CA Executive Order
B-10-11.
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