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AB 32 (2006) set greenhouse gas reduction goals and mandates that
CARB create a plan and implement rules to achieve “real,
quantifiable, cost-effective reductions of GHGs.” Executive Order
S-20-06 emphasizes this.  AB 32, specifically required CARB to
prepare and approve a scoping plan for achieving the maximum
technologically feasible and cost-effective reductions in GHG
emissions from sources or categories of sources of GHGs by 2020
(Health and Safety Code [HSC] Section 38561).  A major goal was to
protect disadvantaged communities from project that further burden
them.  A sample project within the plan is implementation of
high-speed rail (“HSR”) as a GHG reduction measure, estimating a
2020 reduction of 1 million metric tons of CO2 equivalent (MMT
CO2e). 
 
HSR is a perfect example of why your proposed regulations will not
work.  CARB is distributing money to High Speed Rail Authority
toward its joint federal/state HSR project now and in prior years. 
AB 2020 is looking to meet reduction goals by certain deadlines. 
CARB’s adopted plan says 1 million metric tons by 2020 hoping HSR
will help achieve that.  Federal EPA is concerned with major
federal projects that pollute the air, particularly in areas of
non-attainment and those that affect disadvantaged communities.
 
During all the CARB plan deadlines, HSR is and will be a net
polluter in the San Joaquin Valley air basin.  HSR’s first 24 mile
construction section in the Madera to Fresno project area will
generate 140.84 TONS if harmful air pollutants: 8.04 tons of
ROG/VOC, 118.19 tons of NOx and 14.61 tons of PM/o (pm2.5).   The
majority of HSR construction will occur in the San Joaquin Valley
air basin, which is in a status of NON-ATTAINMENT for federal Clean
Air Act standards for ozone and its precursors NOx and VOCs
(extreme nonattainment) and PM2.5.  The Valley’s residence incur
DMV fees to pay the non-attainment penalties.  The HSR
Fresno-Bakersfield section project alone is supposed to move 22
million tons of dirt.  This will exacerbate this PM2.5 Hot Spot and
the asthma from which our population suffers.  It will also
generate additional Valley Fever problems in an area suffering
greatly from this disease lodged in dirt spores that will become
the harmful particulates the residents will ingest.
 
Our local Air Board has made great progress in reductions, but has
accomplished nearly everything it can and is now focusing on things
like commercial interests that charbroil meat.  These are the small
things left to be accomplished while HSR’s project that is getting
credit for reducing greenhouse gas emissions 20-30 years from now
is presenting and for the next 20-30 years going to be dumping tons
of emissions into our air.  This seems so backwards.  If this is
the extent of your enforcement and monitoring, it surely will not
accomplish your goals. 
 
Your regulations need to set strict standards and have a
comprehensive review committee and enforcement division.  The
process must be competitive so that the proposed projects that have
the most impact on the project and the lowest cost should be
granted.  Serious monitoring of the projects should occur to be
sure the goals are being achieved.  Serious penalties should be
imposed for failure to achieve.  Finally, projects that help
disadvantaged communities should be given priority.  You should
revisit your rules with these goals in mind and remember the AB 32
goal is to achieve “real, quantifiable, cost-effective reductions
of GHGs.”   Please extend your comment period and visit some of the
disadvantaged, non-attainment areas in the Central Valley.