Comment Log Display

Note that detailed comments are posted as a PDF attachment.

In June, the ARB released a draft scoping plan to identify and
assess strategies to achieve the goals of AB 32.  The scoping plan
does not, however, consider public health when analyzing
alternatives or assessing strategies. 

By thinking about public health during design, ARB may be able to
increase the net benefits to the people of the State and cost
effectiveness overall.  Major actions to reduce greenhouse
emissions and transition to cleaner and more sustainable energy
can produce health benefits.  

The ARB could incorporate public health in seven areas:  

1.  Incorporate public health into policy objectives -- 
The plan should consider advancement of public health in the
analysis and selection of strategies.  Public health benefits have
considerable value.  Strategies that also maximize health benefits
could increase cost effectiveness because they achieve greater
gains (more benefit per cost expended).

2.  Focus on energy solutions as much as pollution control --
The solutions to climate change depend as much on the creation of
new energy and conservation technologies as on pollution control. 
These deserve more emphasis, particularly in terms of incentives. 

3.  Recognize the role of communities -- 
The interrelated factors of community design, location of
facilities and transportation, activity patterns, and quality of
the built environment are decided at the local level and
profoundly affect greenhouse emissions and public health.

4.  Allocate resources to help adaptation to on-going change for
the vulnerable -- 
The plan should provide a way to allocate resources to help
vulnerable communities and individuals adapt to change that is
occurring. 

5.  Enhance and support the capacity of the people to take
voluntary actions -- 
The plan should consider how to empower and support individual,
voluntary actions by people to reduce emissions and energy
demand.

6.  Emphasize post-combustion technologies --
The plan should emphasize moving beyond combustion to adopt clean
and sustainable renewable energy sources that avoid the emissions
and health concerns inherent to combustion.

7.  Provide assessment of “cap and trade” and other economic
incentives -- 
The plan should provide an assessment of public health issues
embedded in choice of “cap and trade” strategies and their
variants, compared to other approaches.

The initial suggestions herein could be developed further in
consultation with experts and stakeholders in the relevant areas. 
Much is known about how to advance public health in the areas
discussed here.