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Comment 44 for Transportation Comments for the GHG Scoping Plan (sp-transport-ws) - 1st Workshop.


First Name: Pat
Last Name: Flanagan
Email Address: paflanagan29@verizon.net
Affiliation: The Mojave Desert Land Trust

Subject: ORV Emissions
Comment:
The Mojave Desert Land Trust (the Land Trust) appreciates the
commitment shown by the Air Quality Board to develop a
comprehensive approach to address climate change. However, from
our prospective gained conserving land that protects ecosystem
functioning in the Mojave Desert, the omission of off-highway
vehicles emission control from the transportation plan is a
serious oversight. 

Off-highway vehicles produce significant greenhouse gases. 
According to Fuel to Burn: The Climate and Public Health
Implications of Off-Road Vehicle Pollution in California, prepared
by the Center for Biological Diversity and the Clean Air
Initiative, a project of the American Lung Association of San
Diego and Imperial County, off-highway vehicles emit more than
230,000 metric tons – or 500 million pounds—of carbon dioxide into
the atmosphere each year. This is equivalent to the amount of
gasoline used by 1.5 million car trips from San Francisco to Los
Angeles.

California Air Resources Board research finds that off-highway
vehicles and all-terrain vehicles produce 118 times as much
smog-forming pollutants as do modern automobiles on a per-mile
basis. California has among the poorest air quality in the nation
and is home to 13 of 20 counties nationwide most at risk to
adverse health impacts from smog. In Imperial County one of the
most popular off-highway vehicles recreation destinations in the
state, air pollution contributes to the high rate of asthma,
bronchitis, pneumonia, and allergies in this region, especially
among children younger than 14 years old. 

Joshua Tree National Park experiences the highest ozone pollution
level of any Park in the country. Both Joshua Tree and its
neighbor to the north, the Mojave National Preserve post alerts
warning travelers and staff of the severity of health threats from
poor air quality. Research indicates that unless current trends
change, climate change may eliminate 90% of Joshua trees from its
namesake park by the end of this century while automobile
pollutants promote the growth of invasive weeks and grasses, which
contribute to wildland fires. 

The mandate to reduce greenhouse gas emissions by the Global
Warming Solutions Act applies to all gas sources, including
off-highway vehicles. It is the responsibility of California to
ensure that emissions from this source are reduced at the same
pace as other sources. The Land Trust concurs with the authors of
Fuel to Burn that, at a minimum, emissions from off-road vehicles
should be reduced to at least 1990 levels by 2020 with further
reductions to 80 percent below 1990 levels by 2050.

Thank you for this opportunity to comment. We appreciate you
website – it is a very effective tool for commenting.

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Date and Time Comment Was Submitted: 2008-08-01 12:27:37



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