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Comment 671 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameMarjaneh
Last NameMoini
SubjectThe Scoping Plan should be based on Health Equity

Dear Chair Randolph and California Air Resources Board Members,


I am a physician and have taken care of cancer patients in Contra Costa County for over 20 years, responding to clinical manifestations of environmental injustice on a daily basis. That is why I am deeply committed to health equity and that is what I would like to address in this comment letter, as it pertains to the scoping plan. 


After our struggles with COVID-19 pandemic for over 2 years, by now we must all know in our hearts that without public health there is no economic prosperity. Today, with my other colleagues, we have submitted a letter endorsed by 28 health organizations and more than 300 health professionals asking you to prioritize public health over speculated future economic growth and prosperity. Please refer to our letter regarding our specific requests


Please consider these additional comments, 


  1. The health equity evaluation process should be built into the design of the Scoping Plan and completed prior to adoption of the final version of the Scoping Plan. The selection and prioritization of various strategies within the scoping plan must be informed by a robust health equity analysis. Designing a plan and performing a health analysis after the fact is not the same as designing a plan based on the health equity analysis. If the plan is designed based on health equity analyses, you will have the opportunity to intentionally combine elements that collectively would provide maximum health benefit to overburdened communities. That is the only way to truly minimize the social cost. Not only a health equity analysis was not attempted in the process of creating the draft Scoping Plan, the limited health analysis appeared to be an afterthought, it was incomplete and in some aspects provided misleading information. 

  2. Socioeconomic, race/ethnicity, gender and other factors associated with health inequities should be included in the health analyses.

  3. CARB should collect granular, community-level data for mobile and stationary sources and should make every attempt to include any data that is already available in their analysis. It did not appear that CARB made any attempts at incorporating granular data that is already available (e.g. Aclima) in its health impact analysis. The suggestion that CARB “ may consider” to include, instead of “will include” updated health equity data in their final Scoping Plan is unacceptable.

  4.  CARB must prioritize strategies that reduce direct emissions of local criteria air pollutants and hazardous air pollutants. As one of the board members today mentioned, repurposing polluting industries will only increase pollution in impacted communities and result in perpetuating inequities. 

  5. CCS creates public health hazards at every step of the way– capture, transport and storage. CO2 is heavier than air and stays low to the ground at the lung level, therefore CO2 leaks are even more dangerous than methane leaks. The idea that these public health hazards could be regulated are not based on real life experience of impacted communities who live with regulatory failures everyday. Implementation of CCS in California at this time is aspirational, but if CCS was miraculously ever implemented, it would make things worse, not better. As currently practiced, CCS is net additive, releasing into the atmosphere more CO2 than it removes while increasing local air pollution.

  6. California is truly on a dangerous path because in the draft Scoping Plan, CO2 is being framed as a commodity and under the proposed scenario, polluting industries will make profit by polluting (e.g. Biogas & CCS). 

  7. Nearly every one of your decisions has a health impact. Staff and board members must have a clear understanding of the health equity impacts of each strategy and policy. For example VMT reduction is not only beneficial because of reduction in air pollution and associated health harms. Active transport has additional significant health benefits with significant health savings. These savings were ignored when the draft scoping plan was generated and that resulted in limited VMT reduction targets and a less ambitious plan..  

  8. CARB should prioritize community-driven solutions that advance a just transition away from fossil fuels and support regenerative economic sectors while promoting good, family-sustaining wage jobs creation and training pathways for impacted workers. 


California’s climate policies must be good air quality policies and good public health policies while also charting the course for a just transition. Please prioritize public health, account for all pollutants and prioritize the Frontline communities, the lives of our patients, communities and the life of the future generations depend on it.




Marjaneh Moini, MD

Board Member Physicians for Social Responsibility


You can access our letter here:


Original File Name
Date and Time Comment Was Submitted 2022-06-24 23:56:55

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

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