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Comment 39 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameRobert
Last NameGould
AffiliationSF Bay PSR
SubjectComments on Draft CARB Climate Change Scoping Plan

CARB Scoping Plan Testimony; June 23, 2022


Robert M. Gould, MD (311 Douglass Street, SF CA 94114)


My name is Dr. Robert M. Gould. Over the last decade I’ve been an Associate Adjunct Professor in the Program on Reproductive Health and the Environment (PRHE) at the UCSF School of Medicine. I’m submitting this testimony in my role as President of the San Francisco Bay Area Chapter of Physicians for Social Responsibility (PSR), representing hundreds of health professionals and students, who seek to protect the health of our patients and communities, who are increasingly threatened by our rapidly advancing climate emergency and the serious health impacts of fossil fuel extraction, including severe pollution of air, water and land. All of our concerns are underscored by the recently released assessment by the Intergovernmental Panel on Climate Change that is unequivocal in its call for urgent action to ensure an energy-efficient and fossil-free future.


Examples of our health and climate crisis in California include our horrific wildfires, flooding, mudslides and unprecedented heat waves. And with unrelenting COVID, we’ve witnessed the special toll on our poor and communities of color who are chronically exposed to dangerous air pollution from our continued use of fossil fuels.

We believe that CARB should greatly improve its draft 2022 Scoping Plan to better reflect the urgency of the climate crisis, and to make sure is clearly framed by health and equity concerns that specifically and most expeditiously address the needs of our most overburdened communities.

As such,we strongly urge you to:

1.    Plan for a full, coordinated phase out of fossil fuels, with targets for oil refining by 2045 and oil and gas extraction by 2035 (and including at least a 3200-foot setback from homes, schools, hospitals and other sensitive receptors).

2.    Transition to clean, non-polluting zero-emission electric grid by 2035. 

3.    Develop an equitable pathway to building decarbonization retrofits in addition to mandating building electrification in new construction. Phase out sales of new gas appliances by 2030 and ensure a full decommissioning of the gas distribution system by 2045. 

4.    Accelerate and scale up investments in clean vehicles and mass transit. Plan for 100% zero emission transit buses and drayage trucks by 2030 and 100% zero emission medium- and heavy-duty truck sales by 2035. Plan for 30% reduction in vehicle mile traveled (VMT) by 2035, and incorporate health cost savings from VMT reduction (increased physical activity) in your cost analysis. 

5.    Eliminate reliance on climate policy dead ends, such as expensive, risky and unproven carbon capture, storage and utilization (CCUS) and Carbon Capture and Storage (CCS) which introduce a new set of public health hazards. 

6.    Prioritize strategies that lead to urgent direct emission reductions rather than relying on ‘carbon neutrality’ based on projections of unrealistic levels of direct air capturein 2045.

7.    Implement a just transition for every worker, and community, to ensure a healthy and sustainable future for all.

In addition to the foregoing, there is an imperative need for a health equity evaluation process to be specifically integrated into the design of, and completed prior to adoption of the Scoping Plan, with the resultant health equity analysis being a key tool to inform the selection and prioritization of the various strategies being considered. We believe that additional health analyses must be conducted in the implementation of each separate strategy, and that CARB must ensure that actual health outcomes are monitored and evaluated in this process. Quantitative analyses should be conducted whenever feasible, but lack of quantitative data should not become an excuse for neglecting robust and comprehensive health equity analysis.

These steps, in line with policies promulgated by the American Medical Association (AMA), American Public Health Association and numerous health specialty societies urging swift climate action, can contribute significantly towards assuring the security, health and survival of our children and grandchildren by helping avert the catastrophic health consequences of global warming that now threaten all human civilization.






Original File Name6-23-22 SF Bay PSR CARB Comments Robert Gould.pdf
Date and Time Comment Was Submitted 2022-06-23 10:30:12

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.

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