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Comment 323 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameLinda
Last NameRudolph
AffiliationPublic Health Institute
SubjectScoping Plan and Health Analysis

I am Dr. Linda Rudolph, a physician and formerly Deputy Director in the California Department of Public Health.


Climate change is the greatest health threat of this century. Thank you for this ambitious plan to address the climate health emergency, especially a commitment to no new gas power plants in California, targets to phase out gas power plants, a planning process for phasing down oil extraction and refining, and doubling statewide VMT reduction targets.


Many climate solutions have immediate and significant health benefits, others may cause adverse health consequences that perpetuate or exacerbate harm in overburdened communities.  Board Resolution 17-46 previously directed the CARB Executive Officer, quote, “to better integrate health analysis broadly into the design and implementation of the State's climate change programs with the goal of maximizing health benefits.”  Unfortunately, a comprehensive health analysis was not integrated into the development of the scoping plan before you.  


Without a comprehensive health analysis, the Board cannot be informed nor consider how various scenarios and strategies impact health. For example, the Board has not assessed the potentially significant adverse health equity impacts and costs of carbon capture, dairy digesters, or low carbon fuels.


I ask you to incorporate into today’s resolution a commitment to contract with independent public health professionals with expertise in climate, health, and equity to conduct comprehensive public health equity analyses to inform the implementation of this Scoping Plan and development of the next one. This contract should be implemented – along with a process for active input from a broad spectrum of health and environmental justice experts - as quickly as possible in early 2023. This is the only way the Board and its sister agencies can make informed policy and program decisions that optimize health benefits and minimize adverse health consequences of the scoping plan.


Thank you.

Original File Name
Date and Time Comment Was Submitted 2022-12-15 09:50:16

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