Comment Log Display

The Coalition for Clean Air (CCA) supports a 2030 Target Scoping
Plan that will ensure California meets its 2030 climate change
mitigation goal, while also maximizing opportunities to address
long-standing environmental injustices in communities faced with
high levels of pollution and social vulnerabilities to pollution.
We believe these outcomes can be best achieved by a suite of
measures that prioritize a reduction in greenhouse gas emissions
directly at mobile and large stationary sources, and supplemented
by an emissions tax system that covers greenhouse gases as well as
criteria air pollutants and toxic air contaminants. We appreciate
that the 2030 Target Scoping Plan Update Discussion Draft
(Discussion Draft) considers several of these issues, and
emphasizes the transportation sector which is the largest source of
climate-disrupting and health-damaging pollution in California.

CCA favors a carbon tax over cap-and-trade as the State’s carbon
pricing mechanism, because of concerns that emissions-trading
programs do not mitigate localized pollution burdens adequately and
could exacerbate pollution hotspots. While we recognize the
challenges involved in designing and implementing an emissions tax,
we urge the Air Resources Board (ARB) to make the following
revisions so that references to a carbon tax in the Proposed 2030
Target Scoping Plan (Proposed Plan) present a more accurate
description of this policy option and a fairer comparison with
cap-and-trade. For instance, the Proposed Plan should clearly state
that a carbon tax could generate revenue for climate mitigation
programs and projects just as a potential post-2020 cap-and-trade
program would – and likewise, carbon tax revenue could be deposited
into the Greenhouse Gas Reduction Fund and adhere to state laws (SB
535 and AB 1550) regarding equitable climate investments in and
benefiting disadvantaged and low-income communities. The Proposed
Plan should also discuss how a cap on emissions, or other
environmental integrity mechanisms, could accompany a carbon tax in
order to address the issue of uncertainty in emission reductions.
Furthermore, CCA requests ARB to consider in the Proposed Plan the
benefits and challenges associated with expanding a carbon pricing
mechanism to include air pollutants. We believe a broad tax
proposal that covers both greenhouse gases and air pollutants would
help achieve deep reductions in emissions needed to meet federal,
health-based air quality standards and generate revenues for
incentive funding at the scale required to transform California’s
transportation, industrial, and energy sectors. If cap-and-trade
were to be extended post-2020, CCA would support and strongly urge
ARB to institute all of the potential changes to the program
mentioned in the Discussion Draft (page 91) so that communities
living near large sources of emissions have greater assurances of
lower pollution burdens and improved air quality.

The Transportation Sustainability section in the Discussion Draft
includes several important measures that should be pursued. CCA
supports establishing a strong target of 100 percent zero-emission
vehicle (ZEV) sales facilitated by well-designed regulations and
complementary incentive funding. We have and continue to support
specific measures identified in the Discussion Draft, such as
sustained incentives for consumers, dealer incentives, and free or
low-cost electricity that will help to accelerate the sale of ZEVs
in California and make ZEV ownership more desirable to consumers.

We also appreciate the attention paid to increasing ZEV penetration
in the medium- and heavy-duty vehicle sector, because of the
multiple environmental, public health, social justice, and economic
benefits that would result from a transition to a more sustainable
freight system. Goods movement in California must be addressed more
aggressively due to the severe environmental injustices associated
with freight transportation, which is projected to grow
considerably in the coming years. CCA recognizes ARB’s efforts to
improve data collection at freight hubs and facilities, and
recommends including a proposal in the Proposed Plan to establish
aggressive targets for ZEV penetration in freight vocations in the
near term as more information is available. The interaction between
on-road vehicles and freight infrastructure is also important to
address, and the examples provided under the “Sustainable Freight
Goals” (page 52) are useful in showing how these elements can be
aligned toward a low carbon transportation system. In addition, ARB
should consider expanding the support and assistance available to
local and regional governments (under “Known Commitments-Vibrant
Communities and Landscapes,” page 55) to include planning and
implementation of widespread transportation electrification
infrastructure – an element likely to be incorporated into the
updated Regional Transportation Plan (RTP) Guidelines in January
2017.

CCA agrees with the three main “Clean Fuel Goals” listed in
Discussion Draft that are aimed at reducing emissions from
transportation fuels, and recommends adding Renewable Diesel to the
second point about development and deployment of low carbon fuels.
We also support implementation of the known commitments for cleaner
fuels, namely increasing the stringency of the Low Carbon Fuel
Standard. In addition, CCA strongly urges ARB to begin development
of the potential new clean fuel measures, and a Low Emission Diesel
Standard in particular. This measure is urgently needed in order to
make significant progress in the near-term on climate, air quality,
and public health, while zero-emission technologies are developed
for the heaviest-duty trucks and equipment types for which a
zero-emission alternative does not yet exist. Lastly, we recommend
broadening the discussion of cross-sector interactions with respect
to transportation fuels to include environmental justice, though we
understand the emphasis on the consequences for greenhouse gas
emissions. To be specific, CCA believes policymakers should
safeguard against a concentration of Natural Gas and other fueling
depots (even if the fuels are low carbon) in disadvantaged
communities, which would lead to increased truck traffic and
attendant problems in areas already facing high cumulative
environmental impacts.

As stated in our November 2016 comment letter, CCA is a strong
supporter of the Refinery Measure and other potential new measures
to reduce emissions from the Industrial sector. We support
implementation of the main strategies described in this section of
the Discussion Draft that focus on addressing emissions generated
by fuel combustion, such as greater deployment of fuel cells that
are renewably powered and requirements for Best Available Retrofit
Control Technology at large stationary sources. Fluorinated gases,
or F-gases, are also critically important to control, especially
given that this is the fastest-growing greenhouse gas and with an
extremely high global warming potential. A regulatory measure,
coupled with a sustained incentive program, is needed and should be
pursued to replace F-gases in air conditioning and refrigeration
systems across the food processing and transport and building
sectors of the economy.

Lastly, CCA agrees with and supports the Environmental Justice
Advisory Committee’s recommendation to begin planning for a just
transition for incumbent workers in fossil fuel industries. Over
time, these workers are likely to face a greater risk of
unemployment due to changes in business operations or reductions in
output to meet climate and clean air obligations. In addition to
issues of fairness and equity, a just transition could yield
environmental benefits if incumbent workers’ accumulated knowledge
and skills are leveraged in closely related occupations and
industries that are aligned with a low carbon economy. California
has proven that environmental protection and economic growth can be
coupled and with great success on both fronts, and now is the time
to ensure this extends to employment and people’s livelihoods.

Sincerely,
Shrayas Jatkar
Policy Associate
Coalition for Clean Air