Comment Log Display

Valley Clean Air Now Comments on the 
Aliso Canyon Methane Leak Climate Impacts Mitigation Program

Thank you for the opportunity to comment on the Aliso Canyon
Methane Leak Climate Impacts Mitigation Program (referred to below
as Draft Plan).

Valley Clean Air Now (Valley CAN) strongly supports the overall
direction and proposed framework for this proposed mitigation plan
and its targeting of both direct reductions of methane and other
Short-Lived Climate Pollutants (SLCP) as well as related
co-benefits, as summarized on Page 8 of the Draft Plan:

Specifically, the program should prioritize or otherwise encourage
emission-reduction projects that: 
•	Involve substantial direct and indirect reductions in emissions
of SLCPs, especially methane; 
•	Enhance the sustainability of the State’s energy infrastructure,
by decreasing reliance on fossil fuels or otherwise;
•	Address the interests of disadvantaged California communities and
communities directly impacted by the leak; or 
•	Provide other significant and demonstrable environmental,
economic, and public health co-benefits. 
•	These additional factors reflect priorities, rather than
essential elements. Not every project would have to fulfill each of
these additional criteria to be eligible for inclusion within the
Aliso Canyon mitigation program. That said, projects that satisfy
one or more of these criteria would represent especially attractive
candidates for inclusion within the program. 

In addition, we support these statements:

Serve valuable complementary roles by producing near-term emissions
reductions, yielding co-benefits of their own, including in
communities most directly affected by the Aliso Canyon leak, and
ensuring the realization of other programmatic objectives.

As well as:

Affected communities may represent optimal settings for pilot
programs or other investments that will contribute toward a more
sustainable energy infrastructure.

Valley Clean Air Now (Valley CAN) believes that the approach
outlined in the Draft Plan creates the opportunity to build an
organizing program in CalEnviroScreen 2.0-designated disadvantaged
communities throughout the affected region to deliver
community-level projects with quantifiable methane and SLCP
reductions as well as associated criteria pollutant and public
health co-benefits.  Valley CAN feels that the Draft Plan creates
ideal conditions for effective pilots in disadvantaged communities
to reduce GHGs including SLCP as well as maximize criteria
pollutant emissions and public health benefits.

Valley CAN requests that staff give serious consideration to
including a program category to target high-emitting vehicles in
disadvantaged communities.  We believe that a program to reduce or
eliminate emissions by repairing and retiring high-emitting, likely
unregistered older vehicles in disadvantaged communities fits well
within CARB’s stated strategy in the Draft Plan of creating
quantifiable reductions in STCP quickly, with the opportunity to
create related co-benefits with criteria pollutant reductions and
public health:
Program should prioritize or otherwise encourage emission-reduction
projects that: 
•	Generating significant environmental and economic co-benefits,
including benefits to public health and reduced reliance on fossil
fuels;
•	Conferring co-benefits upon disadvantaged communities and
communities directly impacted by the leak, and incorporating
avenues for engagement by these communities in the program
development and implementation process;
•	Facilitating participation by other stakeholders, with the public
being given the opportunity to provide meaningful input toward the
program’s ongoing process,
•	Allowing for ongoing monitoring and verification of program
implementation and progress.
•	An inclusive program development process being followed by a
well-supervised and transparent implementation phase

Background
Valley CAN is a 501c3 focused on quantifiable and unique emissions
reductions in the San Joaquin Valley.  We manage the GGRF-funded
Enhanced Fleet Modernization Program Plus-Up on behalf of the San
Joaquin Valley Air Pollution Control District and CARB.

Valley CAN serves 12,000 customers annually at 26 Tune In & Tune Up
smog repair events throughout the San Joaquin Valley.  94% of Tune
In & Tune Up customers live in disadvantaged communities as defined
by CalEnviroScreen 2.0, with a vast majority residing in low-income
households.  45% of vehicles at Tune In & Tune Up events are
unregistered, many of which have driven 10,000 miles or more since
their registration expired and 25,000 miles since passing their
last smog check.  


Tune In & Tune Up continues to be driven by the support and the
input of community stakeholders.  Our outreach and organizing is a
continual collaboration with nearly 100 community-based
organizations throughout the San Joaquin Valley.  These
organizations participate directly in operating the event, with
dozens of members helping with directing traffic, translating, and
preparing and serving lunch for customers.  The program would not
be successful without the deep input from diverse communities that
we have incorporated into the program process. 

Emissions Reduction Opportunities
Valley CAN has long believed, and has confirmed with our program
results, that older vehicles in disadvantaged community census
tracts are a disproportionate air quality impact within these
overimpacted areas.  Specifically, vehicles older than 1996
registered within a disadvantaged community ZIP code are a
significant but under-reported emissions problem throughout the San
Joaquin Valley and Southern California.  These two regions are
likely home to more of these vehicles than any other part of the
U.S.

The opportunity for the Draft Plan is that a significant percentage
of these vehicles are unregistered and thus are outside of the
state’s air quality models.  Reducing emissions from these dirtiest
vehicles is additional and unique.

The bulk of the emissions from gross polluting vehicles are the
criteria pollutants NOx, HC, and CO.  However, the State
Implementation Plan shows higher-than-statewide-average emission
levels for CH4, SOx, ROG, NO, and PM from pre-1996 vehicles.  

In addition to the emissions modelled in the SIP, it is reasonable
to assume that these older vehicles are among the most likely to
have leaks and/or failure of the Freon system.  According to the
United Nations Environment Programme, Mobile Air Conditioning is
the second largest source of hydrofluorocarbon (HFC) emissions at
24%, representing a full half of the total of Residential,
Commercial & Industrial Air Conditioning & Refrigeration HFC
emissions at 47%.

Given the high rate of unregistered vehicles within this category,
it is difficult to estimate the true extent of the problem. 
However, rough estimates can be done with existing numbers:
•	2.8MM pre-1996 vehicles in California
o	1.6MM in San Joaquin Valley and greater LA area
o	20% of these older cars are likely high emitters
o	20+% are likely unregistered
•	Therefore, there are roughly 320,000 “problem” cars on the road
in the San Joaquin Valley and greater LA area that are a priority
to repair, retire or replace.


Solution
In keeping with a strategy that is very well presented in the Draft
Plan:

Projects in this sphere would sponsor or otherwise promote enhanced
energy-efficiency measures and the targeted replacement of fossil
fuels with renewable energy resources, especially in the
transportation, commercial, and residential sectors. These projects
could include incentive programs, sponsored infrastructure
installations, equipment purchases, and other efforts to promote
the adoption and utilization of less energy-intensive systems and
devices, including those powered by renewable energy resources.
Projects within this category could have several co-benefits, among
them, reducing reliance on gas storage by reducing peak gas and
electric demand in communities that have historically relied on the
Aliso Canyon storage facility. 
These projects also could produce transformative benefits either by
auditioning new technologies and processes, or by placing
emission-reducing innovations on more secure footing. In addition,
while mitigation projects in the agriculture and waste sectors may
take time to start generating emission reductions, projects
designed to enhance energy efficiency could yield returns more
quickly, thereby ensuring continuing momentum for the mitigation
program. 
Valley CAN believes that the expansion of a community-based program
to repair, retire or replace the highest emitting vehicles in the
most severely disadvantaged areas with the worst air quality in the
nation would be among the fastest and most cost-effective means of
building a delivery network within disadvantaged communities while
achieving quantifiable and additional STCP and criteria pollutant
reductions.  

Creating a consistent pipeline of these older high-emitting
vehicles will require continuous community organizing in
disadvantaged communities that are most likely to have these
high-emitting older vehicles. These targeted residents could attend
a series of events within their region where qualified low-income
motorists are offered a complete set of smog solutions:
-	Smog repairs 
-	Vehicle retirement
-	Vehicle replacement (via EFMP and EFMP Plus-Up)
-	Additional energy efficiency, health care, carbon reduction
programs can be offered by disadvantaged community benefit
providers

Community Co-Benefits
The initial organizing for the vehicle program could expand scope
to deliver additional neighborhood- and household level programs
including:
-	Appliance retrofit and replacement
-	Other residential and commercial energy-efficiency programs
-	Vehicle replacement, including individual or fleets
-	Gas network and appliance safety upgrades
-	Sustainable transportation infrastructure
-	Coordination with all other federal, state, local, and regional
utility disadvantaged community and low-income assistance programs,
in order to deliver the broadest potential benefits to qualified
households.

Geographic Target
The greater LA area and the San Joaquin Valley have a
disproportionate percentage of the older, likely high-emitting cars
in the nation.  SoCalGas has service territory in both of these air
basins, which share the worst air quality in the U.S., so it could
make sense to include at least the southern San Joaquin Valley as
well as the greater L.A. area.   

Thank you again for the opportunity to provide comments.  Please
don’t hesitate to contact me if you need any additional
information.  

Sincerely,

Tom Knox
Executive Director
(916) 273-8886
tom.knox@valleycan.org