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Comment 42 for Short-Lived Climate Pollutant Draft Strategy (slcpdraftstrategy-ws) - 1st Workshop.
First Name: Sarah
Last Name: Aird
Email Address: sarah@pesticidereform.org
Affiliation: Californians for Pesticide Reform
Subject: Add action on SO2F2 to the strategy
Comment:
On behalf of the 190+ member organizations of the statewide coalition Californians for Pesticide Reform, I wish to express the coalition's concern over the notable absence of any proposed action on the toxic fluorinated gas sulfuric fluoride. Specifically, we are troubled by the dismissive relegation of this known GHG to a single paragraph on p.57 of the draft document. By CARB's own admission, it has been well known for six years that SO2F2 is a high GWP gas, and yet it has yet to be added to ARB's GHG inventory. SO2F2 is now in increasing use as a replacement for the ozone-depleting pesticide methyl bromide, which is being phased out under the Montreal Protocol. California uses an astonishing 50% of global consumption of this health-harming fumigant. As the draft strategy document acknowledges, if it were correctly categorized as a GHG, it would singlehandedly increase California's total F-gas inventory by 25%. It is simply not good enough to sweep this acknowledged GHG under the rug. CPR calls on ARB to revise their draft to include a plan to phase out the use of this harmful pesticide, and to make a commitment to a serious study of alternatives. Sincerely, Sarah Aird Acting Executive Director, Californians for Pesticide Reform
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Date and Time Comment Was Submitted: 2015-10-29 16:24:43
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