Comment Log Display

I commend CalARB for the AB617 plan, and especially for drawing out
subtleties that will become major policy issues within several
years.

My comments on the Concept Paper focus on two issues. These are
VIII.D, Data Communication and Accessibility; and V, Identification
and Selection of Communities.

Re: VIII.D Data Communication and Accessibility
The Concept Paper indicates that CARB will "democratize data
collection, display and intrepretation"(p22). The implementation of
an army of low-cost monitors would certainly help with this
endeavor. Yet the AQ-SPEC's results indicate that no low-cost
monitor meets FRM or FEM standards at present. However, the monies
offered by the AB617 could be the progenitor of a new norm for
democratic visual presentation of environmental data. Could AirNow
data be posted on local screens in CAMP neighborhoods until more
geographically high resolution data is available?

Another way in which the implementation of the Community Air
Monitoring Plans could "enhance the accessibility and usability of
data and tools" is to strive to offer contract opportunities to
more than a handful of air quality monitoring service providers.
Generally speaking, a "secular" data access plan for the AB617
Community pollution is the environmental data equivalent of net
neutrality and anti-trust legislation. An oligopolistic supply
market- that is one in which four or fewer companies hold the
majority of market share- is commonly understood to have far less
incentive to lower costs to end customers. The progress of the
industry is encouraged by a larger number of entrants. Moreover, it
would be encouraging if data is made accessible online to the
general public at the same temporal resolution that the company
reading the data and porting it to BAAQMD and CalARB has.

Re: V. Identification and Selection of Communities
Regarding issue V. Identification and Selection of Communities, the
author is concerned with geographical boundaries for affected
communities. It is certain that those communities that have been
robustly represented in Environmental Justice circles in California
will self-identify to the Community Air Protection Program.

It is encouraging to see that West Oakland, the Bayview-Hunter's
Point, and Brawley in the Imperial Valley have developed strong
leadership. Would it be possible to extend the geographical
designations of disadvantaged communities adjacent to these areas,
when political demarcations are narrower than geographical
boundaries? The Visitacion Valley in San Francisco and the
immediately adjacent eastern edge of Daly City comes to mind. The
Midway Village housing project, a Superfund site built on a former
PG&E facility, is no more than three-tens of a mile from Daly
City's northern border with San Francisco. Perhaps the CAMP project
boundaries might be extended to include such areas, on consultation
with the Measurements division of the local AQMDs.

Thank you to Cal-ARB for leading where dozens of other states will
follow.