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Comment 3 for Proposed 2022 State Strategy for the State Implementation Plan (statesip22) - Non-Reg.

First NameJane
Last NameSellen
Email Addressjane@pesticidereform.org
AffiliationCalifornians for Pesticide Reform
SubjectSIP Strategy must include SIP-enforceable pesticide emission reduction targets
Comment

Greetings, 

A comment letter from the Californians for Pesticide Reform (CPR) coalition and 51 co-signatories is attached. 

We call on CARB to: 1) Proactively assert its authority to regulate smog-forming emissions from use of pesticides classified as TACs, and 2) Include in the SIP meaningful and enforceable measures to reduce use of pesticides that contribute to VOC emissions. Specifically, we urge CARB to include a commitment to reduce pesticide VOC emissions by 30% by 2030 and by 75% by 2037 from 2020 levels in high pesticide use non-attainment air basins, with a focus on mandatory targets for reduced usage and adoption of agroecological practices. 

At a minimum, if CARB proceeds with the inclusion of the 1,3-D regulation as a measure in the SIP, we ask that CARB exercise their admitted authority to regulate 1,3-D air emissions by setting a SIP-enforceable 1,3-D emissions reduction target. 

Sincerely,

Jane Sellen and Angel Garcia, CPR Co-Directors


Attachment www.arb.ca.gov/lists/com-attach/6-statesip22-AmRRPgBvVWcLYQVa.pdf
Original File NameFINAL 2022 SIP comments sign on letter September 2022.pdf
Date and Time Comment Was Submitted 2022-09-09 09:18:58

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


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