Comment Log Display

-- 4R Gandkids Campaign --
Save Our Water Ventura
4666 Vanderbilt Court
Ventura, CA 93003-1929
B4R.Grandkids@gmail.com
805.633.1061

January 29, 2017

California Air Resources Board
1001 "I" Street
Sacramento, CA 95814


Re: Public comment regarding THE FLAWED AND INADEQUATE 2017 CLIMATE
CHANGE SCOPING PLAN UPDATE  - THE PROPOSED STRATEGY FOR ACHIEVING
CALIFORNIA'S 2030 GREENHOUSE GAS TARGET


Dear Sirs:

Everyone agrees that climate change and greenhouse gases are a
serious problem. AB32 and SB32 were necessary to enable some hope
for our future generations. However, the proposed strategy for
achieving the 2030 target is flawed and inadequate. It should not
be approved unless changes are made to the plan.

The flaws and inadequacies are as follows:

1. Although AB32 was passed many years ago, no one at the local
level (city council level) is paying attention to GGE objectives.
Numerical objectives for each county and city are not published
regularly on city and county websites. In fact, a look at the
state's ten year history of GGE emissions shows that total emission
have flat lined for the LAST FIVE YEARS. CARB has failed to publish
local and regional data, to keep it current, and to make that data
readily available to the public. Failure to provide specific
quantifiable state, county and city data has created a constant
moving target -- which has led to business as usual. Quantifiable
data is needed in order to increase public involvement and
participation.

2. CARB has increased the probability of failure by allowing
"business as usual" adjustments during CEQA reviews when
calculating GGE compliance. This failure was discussed in the
California Supreme Court's (S217763) 2015 review of Newhall Land
and Farming's project for a new community of 58,000 residents. As
you will recall the CEQA review by the California 

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Page 2 0f 2 -- Spraggins to CARB

Department of Fish and Wildlife concluded that there would be no
significant impact of GGE from the proposed new community of 58,000
residents. Our belief is that this kind of CEQA outcome
demonstrates that CARB scoping has been a failure. Calculating GGE
savings using "business as usual" adjustments defeats the intent of
AB/SB32.

3. The Scoping Plan does not allow local communities to make their
own decisions on how to reach objectives. For example, Appendix B
("Local Actions") simply provides a list of things to do with
regard to development projects. There is no guarantee that
compliance with this list will result in a 40% reduction in GGE. 

4. The Scoping Plan's macro economic model is flawed because it
does not adequately consider micro economic impacts across various
sectors of the population. The model considers environmental
justice for low income groups, but it does not adequately consider
what will happen to California's middle class families,
particularly those who work in the "non-unionized" private sector.
The model simply is provided to show that the measures will be
neutral from the standpoint of tax collection. There are going to
be winners and losers. The public needs more clarification of what
looks like a zero-sum game.

5. The omission of population growth control is a major failure.
The scoping plan does not include the possibility GGE compliance by
means of population control by limiting growth in over populated
local communities. There is no mention of limiting foreign
immigration, no mention of any need for birth control programs.
There is no mention of the need to eliminate the RHNA requirements.
Thus, GGE savings will be substantially negated by population
growth. 

6. An adequate Scoping Plan must recognize the following Three
Rules of Neo-Sustainability: 1) Environmental Primacy; 2) Systems
Thinking; 3) Limits to Growth.

7. The proposed Scoping Plan is an "open barn door" designed to
accommodate lobbyists, a door which will allow "business as usual",
and the objectives of AB32/SB32 will never be achieved unless the
above deficits are corrected.


Respectfully,



Charles Spraggins, Chair
4R Grandkids Campaign
SaveOurWaterVentura.org