Comment Log Display

Mary Nichols, Chairperson
California Air Resources Board 
1001 I Street 
Sacramento, CA 95814 
CC: Clerk of the Board 

Re: AB 32 Scoping Plan Comments 

March 10, 2017 

Dear Chairperson Nichols and Members of the Board, 

The Public Health Alliance of Southern California is a coalition of
9 local health departments. Collectively, the members have
statutory responsibility for the public health of 60% of
California’s population. We strive to prevent the conditions that
cause poor health, well before residents must visit the doctor’s
office. The prestigious British medical journal, the Lancet, has
identified climate change as the biggest global health threat of
the 21st century”. As public health professionals charged with
protecting and promoting the health of the population, the Alliance
is particularly committed to addressing the disproportionate health
impacts of climate change on vulnerable populations.
 
The Alliance strongly supports the leadership that the California
Air Resources Board (CARB) has taken in developing the proposed
2030 Scoping Plan. This plan represents an unmatched opportunity to
protect California residents from the health impacts of Climate
Change. To achieve this goal, and maximize the health benefits of
the plan, we recommend that CARB: 

1.	Evaluate the health impacts of Scoping Plan measures and
scenarios in both the plan document and Environmental Impact
Report, and
2.	Integrate clear and ambitious Vehicle Miles Traveled (VMT)
Reduction targets from the SB 375 target-setting process into the
Scoping Plan.

       A rationale to support each recommendation is provided as
follows:

Recommendation #1: Evaluate the health impacts of Scoping Plan
measures and scenarios in both the plan document, and Environmental
Impact Report (EIR): 

We are pleased that CARB has included high-level health and equity
discussions in the 2030 Scoping Plan. Although these statements
provide a good general overview of the connections between health
and the scoping plan, this overview does not currently analyze
specific health impacts of the differing strategies and scenarios.
It is also missing an analysis on the relative contributions of
both health benefits and impacts as they affect population
sub-groups. Because of the significance of the Scoping Plan as a
guidance document, we urge you to fund an independent 

contractor with experience in comprehensive analysis of health
impacts of programs and policies to conduct a health equity
assessment of the strategies and alternatives in the Scoping Plan. 
This study should assess the expected magnitude and distribution of
health costs and benefits for each strategy. It should include
projected changes to physical and mental health resulting from the
strategies proposed in the scoping plan, including land use and
transportation patterns, green infrastructure, energy efficiency,
building design, and air quality. It is also fundamentally
important that the analysis assess the distributional impacts and
benefits of strategies and scenarios in different sub-groups of
California’s population.

A strong, independent analysis of public health impacts of the
Scoping Plan is important in fulfilling statutory requirements. AB
197 stipulates that CARB consider the social costs, including
impacts to public health, of emissions reduction measures included
in this scoping plan. Additionally, CEQA states that public
projects that may cause substantial adverse effects on human
beings, either directly or indirectly, must prepare an
Environmental Analysis (EA) that discusses health and safety
problems caused by the physical changes. The Scoping Plan EA should
consider the full range of potential health impacts, assess the
cumulative impacts of these health effects, and analyze the likely
distribution of potential impacts among population sub-groups. As
written, the scoping plan section on Public Health (III.C, page 76)
is primarily a qualitative description, and does not provide goals
and policies. As a result, the EA lacks clear health impacts in the
Mandatory Findings section page 171. 

To fulfill AB 197 and CEQA requirements, a stronger health analysis
should be included. The Alliance will be happy to serve in an
advisory role, assisting CARB’s contractor in identifying the
parameters of these health analyses. We would also recommend that
CARB routinely include a comprehensive health impact analysis on
future scoping plans due to the significant reach and impact on
public health. We believe this critical information will provide
CARB and the public with a clearer sense of the health and equity
benefits and impacts to aid in more informed decision-making. 


Recommendation #2: Integrate clear and ambitious VMT Reduction
targets from the SB 375 target-setting process into the Scoping
Plan.

The Scoping Plan notes that VMT reductions are necessary to achieve
the 2030 target, and includes reductions in the proposed scenario.
The Plan further notes that these reductions will come from
stronger SB 375 targets, as well as additional strategies
identified in the Appendix C: Vibrant Communities and Landscapes
and Potential VMT Measures document. Prior research indicates that
Greenhouse Gas (GHG) reduction strategies that replace car trips
with active transportation and transit use deliver extremely strong
health co-benefits.  These strategies must be a key piece of
California’s climate change efforts. 

The Scoping Plan however, does not appear to set specific targets
for VMT reductions for either of these programs. We recommend that
CARB set ambitious targets for both SB 375 and for Appendix
C—strong enough to meet our climate goals—and clearly spell out
these targets in the Scoping Plan document. 
Additionally, we recommend that the Scoping Plan include additional
detail regarding the steps that will be necessary to meet these
targets. The plan includes ambitious active transportation goals
(four-fold and nine-fold increases respectively for walking and
biking). We strongly support these goals, and applaud the overall
direction of the strategies included in Appendix C. However,
neither the Scoping Plan nor Appendix C currently provides feasible
strategies to achieve these targets. Stronger policy and funding
commitments with clear implementation actions are needed. 

Similar specificity is needed for SB 375 and Appendix C in the EA.
The EA includes “Increased Stringency of SB 375 2035 Targets for
Sustainable Communities Strategies” as a measure within the project
description. However, the project description does not contain
adequate detail (numerical targets) to accurately determine
environmental impacts. Additionally, while the Plan relies on the
strategies proposed in Appendix C to meeting GHG reduction goals,
these strategies do not appear in the EIR’s project description,
and it is not clear whether they are included in the alternatives
analysis. We encourage the many strong suggestions and strategies
given in Appendices A and C to be clearly integrated into the
Environmental analysis. 

The Public Health Alliance of Southern California is deeply
thankful for your efforts to address climate change and protect the
health of California residents. We are pleased that the State has
affirmed health co-benefits as a clearly stated goal of
California’s climate policy. As such, it is our recommendation that
all plans and policy documents should analyze health cost/benefit
as a matter of course, and use this analysis to inform the
resulting decision-making. 

Thank you for your leadership on this issue, and your consideration
of our recommendations. We look forward to continued work with you
to ensure a sustainable and healthy future for our state. 

Sincerely, 
Tracy Delaney,Ph.D., R.D., Alliance Executive Director
Selfa Saucedo, MPH, Alliance Co-Chair
S. Michael Johnson, MPH, Alliance Co-Chair