June 23, 2022
Comments to California Air Resources Board on
its Draft
2022 Scoping Plan
Patrice Sutton, MPH, San Francisco Bay
Physicians for Social Responsibility
My name is Patrice Sutton, I am
a public health professional, a collaborating research scientist at
UC San Francisco, and Co-Chair of the Environmental Health
Committee of S.F. Bay Physicians for Social
Responsibility.
As you
know, the
latest Intergovernmental Panel on Climate Change report warns us in
stark terms that it is “now or
never”. Without immediate and deep emissions reductions, it will be
impossible to limit global warming. Your current scoping plan falls
far short from this imperative. We implore CARB to fulfill its
legal mandates by leaving the status quo that permeates your plan,
and that has brought us to this brink, behind.
SF Bay PSR urges you to adopt a
climate action plan that is commensurate with the problem at hand,
that specifically and demonstrably prioritizes public health over a
fossil fuel pathway to certain death, and that specifically
advances health equity and environmental justice. The draft plan includes no public health equity analysis to
systematically and transparently guide the evaluation, selection,
and prioritization of strategies. Rather than calling
for immediate action to reduce pollution,
it relies on expensive and unproven technologies to meet its
emission reduction targets.
To align CARB’s plan
with its goals and legal imperatives CARB should:
- Plan
for NO MORE OIL. Keeping fossil fuels on life
support is antithetical to our survival. Establish the
target of near zero greenhouse gas emissions
by 2035 (starting with at least a 3200
foot setback from homes, schools, hospitals and other sensitive
receptors). Transition to clean, non-polluting zero-emission
electric grid by 2035.
- Plan
for 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.
- Accelerate and
scale up investments in clean vehicles and mass
transit. Accelerate the path to 100% electric
vehicles, alongside a massive expansion of infrastructure for clean
public 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.
- Eliminate reliance
on climate policy dead ends, such as expensive, risky, and
unproven carbon capture, storage and utilization
(CCUS) which introduce a new set of public health
hazards. Prioritize strategies that lead to urgent direct
emission reductions rather than relying on ‘carbon
neutrality’ based on climate policy dead ends
and unrealistic levels of direct air capture in
2045.
- Plan for and
implement a just transition for every
worker, and community.
- Build
a health
equity evaluation process into the design of the Scoping
Plan to inform the selection and prioritization of
strategies. Ensure that actual health outcomes are monitored and
evaluated throughout policy implementation. Address pollution and
related health impacts of its strategies in already overburdened
communities. As above, CARB shall prioritize strategies that reduce
direct emissions and local criteria air pollutants and toxics.
You have the opportunity to support the health and
survival of Californians, and well beyond, given the market signals
your decisions will influence. Please take the leap and forge a
plan that can truly serve as a pathway to survival, health, and
justice for all.
Thank you.
Patrice Sutton, MPH Co-Chair, San Francisco Bay
Physicians for Social Responsibility Environmental Health
Committee 311 Douglass Street San Francisco, CA 94114 415 407 8806
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