Comment Log Display

Comment Log Display

Below is the comment you selected to display.
Comment 339 for General Comments for the GHG Scoping Plan (sp-general-ws) - 1st Workshop.


First Name: Bonnie
Last Name: Holmes-Gen
Email Address: bhgen@alac.org
Affiliation: American Lung Association of California

Subject: AB 32 Draft Scoping Plan Comments
Comment:



August 18, 2008


Mary Nichols, Chairman
California Air Resources Board
1001 I Street
Sacramento, CA 95812

Dear Chairman Nichols:

Re: American Lung Association of California Recommendations On
Draft Global Warming Solutions Act Scoping Plan 

The American Lung Association of California appreciates the
California Air Resources Board’s (CARB) tremendous dedication and
effort to develop the draft Scoping Plan as a key step forward
toward implementing AB 32 and creating a more sustainable energy
economy.  Without dramatic changes in our society and economy to
reduce global warming, California’s already severe pollution
problems will only get worse and health costs will continue to
climb higher.  While the draft plan represents an important first
step, we are urging the board to incorporate strengthening changes
to substantially boost air quality, greenhouse gas reduction and
public health benefits.

The public health crisis in California caused by the state’s
dependence on polluting petroleum fuels is a key reason why we
must move forward quickly with the strongest possible greenhouse
gas reduction measures. Moving away from petroleum fuels through
strategies to clean up vehicles and fuels, change land use
patterns, and promote alternative transportation modes and other
greenhouse gas reduction strategies will not only help achieve the
state’s 2020 and 2050 targets, but will also provide tremendous
co-benefits by attacking California’s smog and toxic air pollution
problems.  With asthma at epidemic levels and thousands of
premature deaths, hospitalizations and illnesses caused by air
pollution each year, California must take strong action.  

The American Lung Association appreciates that the draft scoping
plan incorporates some strong elements.  We are pleased to see a
significant commitment to renewable power production in California
through the inclusion of a goal of achieving 33 percent of the
state’s power through renewable sources.  We are also pleased that
that the plan has a strong foundation in regulatory approaches that
provide the most certainty with regard to achieving greenhouse gas
emission reductions and providing the most accountability to the
public.  However, additional measures must be incorporated to
significantly strengthen the plan.

As we have commented during the public hearings on the scoping
plan, we strongly believe that protection of public health should
be the key criteria to evaluate the various policy tools and
strategies that are part of the scoping plan, as well as the
broader implementation efforts under AB 32.  In order to give
priority consideration to public health, the board must ensure
that the plan:  

1)	Places a high priority on measures that can achieve the
greatest public health benefits and measures that can provide
early reductions and improve air quality in communities already
suffering from high levels of exposure to smog and toxic pollution
from ports, goods movement, agricultural and industrial polluters
and other hot spots.
2)	Contributes to faster progress toward meeting state and federal
clean air commitments for smog and particle pollution, and includes
no elements that allow for backsliding on achievement of state and
federal air quality standards.
3)	Maximizes the air quality and public health co-benefits of all
regulations and strategies for greenhouse gas reduction included
in the plan.
4)	Meets all requirements of AB 32 (Nunez/Pavley) for analysis of
air quality impacts and impacts to disadvantaged communities.

We urge the board to adopt the following specific changes in the
plan to ensure the plan meets the above criteria:

Public Health Analysis and Benefits

Establish a formal process for public health review and input into
the scoping plan.  We appreciate that CARB intends to publish an
appendix outlining the public health impacts and benefits of the
plan and believe this is an extremely important step.  In order to
be effective, the analysis must estimate the statewide and local
impacts of both regulatory and market-based measures included in
the plan, especially with regard to environmental justice
communities.  However, we believe that CARB needs to also
establish a formal and ongoing process to review the priorities
and overall public health impacts and implications of the scoping
plan throughout its development and implementation as well as
reviewing individual measures. We believe it is important for CARB
to include representatives of key state and local public health
agencies and organizations in this process.

The scoping plan must provide local public health protections. 
Many communities in California, in particular low-income
communities and communities of color, live in close proximity to
multiple sources of pollution, including ports, goods movement,
agricultural and industrial pollution sources and experience
higher health impacts. The plan must not only prevent
disproportionate impacts or creation of “hot spots”of pollution as
required by AB 32, but must also provide benefits to local
communities such as additional resources and mitigation measures
to speed up air quality progress.




Transportation and Land Use

Boost  greenhouse gas emission reductions from transportation and
land use sectors.  Transportation is the largest contributor to
global warming and air pollution in California, representing 38%
of greenhouse gas emissions and over 80% of nitrogen oxide
emissions that contribute to smog and particulate pollution.  Cars
and light trucks make up the majority of the greenhouse gas
emissions from the transportation sector.  The state must commit
to stronger transportation measures to meet the 2020 target and to
lay the groundwork for the more challenging 2050 greenhouse gas
reduction target.

Set a  higher bar for reduction of vehicle miles travelled or
“VMT.”
With current growth and development patterns, VMT is expected to
increase by 70% over the next 30 years.  This level of growth in
vehicle use would cancel out progress made in reducing greenhouse
gas emissions through introduction of cleaner vehicles and fuels.
The plan’s current goal of achieving 2 million metric tons of
greenhouse gas reductions from VMT reduction is far too low.  The
state should set a higher goal of at least 10 million metric tons
and provide the leadership and support to help local governments
change land use and transportation patterns to achieve the goal.

Establish strong regional greenhouse gas reduction targets:  The
best way to ensure that local governments make the changes
necessary in land use and transportation planning to support
compact and more efficient development patterns and reduced VMT is
to establish strong regional targets for greenhouse gas reduction. 
These regional targets must include a mechanism to hold cities and
counties accountable for achieving their share of emission
reductions. 

Include measures to expand public transportation systems: 
Expanding California’s public transportation system, providing
full funding of public transportation in the state budget this
year and providing consistent ongoing funding are critical
measures to promote reduced need for driving.  An increased
emphasis on public transit is important to support local and
regional agency efforts to change transportation and land use
plans in order to emphasize smart growth strategies. 
Unfortunately, the current draft makes little mention of public
transit.

Include indirect source rules as well as additional measures to
reduce vehicle trips:  Communities across the state can benefit
from using indirect source rules to ensure that the greenhouse gas
and air pollution emissions from developments are calculated and
mitigated.  This is another strategy to promote compact
development patterns, transportation options such as walking and
bicycling, less driving and healthier, more livable communities. 

Accelerate efforts to introduce zero emission vehicles:  CARB
should establish more aggressive goals for introducing new pure
zero emission vehicles such as battery electric vehicles and fuel
cell vehicles into the vehicle fleet, especially in the 2015 -2020
timeframe. CARB should also establish requirements for automakers
to expand use of electric drive technologies across the new
vehicle fleet, including conventional hybrid and plug-in hybrid
technologies, in new vehicles.


Market Mechanisms

Take a cautious and slow approach to market-based measures:  CARB
should approach market-based measures cautiously, limit their use
and apply appropriate safeguards to maximize air quality and
health benefits.  Measures should be carefully designed to provide
real, quantifiable and surplus reductions, maximize criteria air
pollutant co-benefits, provide near-term benefits to local
communities in terms of emission reductions and mitigation funds,
limit use of offsets, include a strong enforcement program and
ensure that pollution sources pay for emission allocations rather
than allowing free distribution.  Any cap and trade program
adopted by CARB must include, from the start, a requirement for
pollution sources to pay for all emission allocations through an
auction with the revenues applied toward public interest
projects.

CARB should also be very cautious about linking to other state or
regional cap and trade programs such as the Western Climate
Initiative (WCI).  While we appreciate the value of developing
regional approaches to reducing greenhouse gas emissions,
California should not accept weaker cap and trade or offset
requirements in order to join a regional market. Before
considering linkage with other programs including WCI, CARB should
ensure that these programs contain strong safeguards, including
those listed above.

Offsets must be limited to avoid reduction of air quality and
community benefits:
In order to achieve AB 32 goals, California will have to drive
development and implementation of new, innovative clean
technologies that can achieve the maximum level greenhouse gas
reduction. We are tremendously concerned that offsets, especially
those generated outside of the state, will reduce the incentive
for California’s industries to transition to less carbon intensive
manufacturing and production technologies.  If offsets are going to
be allowed, they should be limited to a small percentage of a
facility’s greenhouse gas reduction requirements.  In addition,
CARB needs to address how offsets would be evaluated and monitored
on an ongoing basis to ensure they are real, verifiable, permanent
and surplus.

We are also extremely concerned about the direction provided in
the current draft of the scoping plan regarding offsets The
current proposal implies that sources in a cap and trade program
would be able to cover 100 percent of their required (cap and
trade) emission reductions by purchasing offsets rather than
reducing emissions.  This would be completely unacceptable from a
public health perspective.  If CARB does pursue an offsets
program, we urge CARB to ensure that companies can only count
offsets toward meeting a small percentage (less than 10%) of the
required emission reductions.

Direct revenues to public interest programs, including
community-level mitigation efforts.
CARB should ensure that additional state revenues raised through
greenhouse gas fees or cap and trade programs are directed to
assist global warming mitigation and adaptation efforts including
energy efficiency, especially in environmental justice
communities.  We also join the Coalition For Clean Air and other
organizations in recommending that a fixed percentage of revenues
from market-based programs should be directed toward the
establishment of a “community benefits fund” to assist communities
suffering from disproportionate air pollution impacts.

Goods Movement

Incorporate stronger measures to reduce greenhouse gases from
goods movement.
We believe there are significant opportunities for CARB to
accelerate reductions of greenhouse gases from the goods movement
sector, which is responsible for 20% of greenhouse gas emissions
in the transportation sector as well as substantial adverse air
quality and health impacts to communities near ports, railyards
and other goods movement facilities.  The serious health impacts
and projected tremendous increase in goods movement activity at
the ports calls for a greater level of effort to reduce criteria
pollutant, toxics and greenhouse gas emissions.  The opportunities
range from electrifying vehicles, vessels and equipment such as
switching locomotives, trucks, yard hostlers and tugs and
increasing on-dock rail for more efficient container transport to
incorporating efficiency measures and low carbon technologies into
new port projects and developing more efficient containers and
freight handling and operations at ports.  We urge CARB to
increase the scoping plan’s commitment to reducing emissions from
goods movement measures to assist in efforts to meet both short
and long-term greenhouse gas reduction targets.

Industrial Sector

Strengthen regulatory requirements on industrial pollution.
CARB should include in the scoping plan additional strong
regulatory measures to reduce greenhouse gas emissions in the
industrial sector, such as petroleum refineries, power plants, and
cement plants.  Industrial sources account for 20% of the state’s
greenhouse gas emissions and also contribute significantly to
local and statewide air quality problems.  We believe the state
should not rely solely on market measures to reduce emissions from
this sector.  Furthermore, additional regulatory measures on these
types of facilities will provide important air quality and health
benefits to the communities where they are located.

Energy

Maintain a strong commitment to a 33% renewable portfolio standard
(RPS) Since electricity makes up 23% of greenhouse gas emissions in
California, pursuing renewable energy sources is extremely
important.  We strongly support CARB’s commitment to a 33% RPS.  
Both investor-owned and publicly-owned utilities must invest in
more renewable energy sources, including wind, solar, and
geothermal resources. Increased use of renewables will decrease
California’s reliance on fossil fuels and reduce greenhouse gas
emissions from the energy producing sector.

Public Outreach and Education

A strong outreach and education program is critical to the success
of the state’s greenhouse gas reduction efforts.  We urge CARB to
adopt a comprehensive public outreach and education program to
assist in the AB 32 implementation effort and to seek formal input
and assistance from the public health community in developing this
program. The state can build on highly successful social marketing
campaigns to reduce tobacco use as well as programs it has
previously established such as “Spare the Air” and “Flex Your
Power” campaigns.

In conclusion, the American Lung Association appreciates CARB’s
effort to date on this groundbreaking state greenhouse gas plan
and looks forward to continue working with you to ensure the plan
is strong, health protective, and provides a solid framework for
success in reaching the state’s 2020 and 2050 goals. 

Sincerely,

Bonnie Holmes-Gen
Senior Policy Director

Linda Weiner
Director, Air Quality Advocacy and Outreach



Attachment: www.arb.ca.gov/lists/sp-general-ws/575-alac_comments_august_18_final.doc

Original File Name: ALAC comments August 18 Final.doc

Date and Time Comment Was Submitted: 2008-08-19 08:28:22



If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.


Board Comments Home

preload