As a public health physician, I am deeply
concerned that the scenario selected by staff is not sufficiently
ambitious in addressing the climate health emergency; Scenario 3
focuses on the longest time horizon under consideration and offers
fewer overall health benefits than rejected scenarios.
· The health analysis is limited in scope
and incomplete. Health advocates have long called on CARB to use a
more comprehensive health analysis in developing this and previous
scoping plans. We are confident that doing so would have led
to a more ambitious draft, and urge the Board to rectify this
omission.
· The proposal fails to optimize near-term
health and equity benefits of climate policies . To do so the Board
should place more emphasis on near-term direct emissions reduction
strategies and reduce reliance on costly and unproven technologies
removal that may worsen toxics exposures for frontline
communities.
· If the Board chooses to include
significant reliance on CCS in the final plan, it is imperative
that you also incorporate meaningful safeguards to protect
community health and to prohibit the use of CCS to extend the life
of fossil fuel infrastructure or to expand extraction or production
of fossil fuesl.
· There is a critical gap between intention
and action steps to building healthy, sustainable communities for
all Californians. I urge that the plan incorporate clear
accountability measures to ensure state agency alignment of
transportation funding with climate and health
goals.
Thank you for the
opportunity to comment, and I look forward to working with
you to create a more ambitious, health-protective
and
equitable
final scoping plan.