Comment Log Display

Comments on Economic & Health Analysis for CARB Scoping Plan

Thanks for the opportunity to expand on oral comments offered
during the webinar. It's difficult to do this as a single context,
since I have observed and commented during several previous (and
one subsequent) meetings, and see that a recommendation has already
been made, apparently based on the models used in this one. We are
promised that the full scoping plan will include other parameters,
yet economics seems to be a major driver in decision-making on how
actions to address climate change are prioritized.

The choice of Option 3 in 2045 appears to have been recommended
because it is the cheapest option relative to health benefits, as
narrowly assessed. Many of my age will be gone by then, and our
children, grandchildren, and generations beyond will bear the
weight of our reluctance to sacrifice for and invest in their
future, as well as that of many other species that inhabit this
shared planet. Here are some specific critiques, categorized:

The Industrial Model
Economic costs and health "benefits" present a narrow frame and odd
combination. They address monetary costs and avoidance of costs,
but not costs of damage from climate change, or of benefits of
other climate strategies proposed. In the workshop these were
dismissed as "qualitative concerns" that would be addressed
elsewhere. The emphasis, described as being statute-driven, was on
direct reduction of quantifiable emissions. Solutions presented
were centralized, large-scale, capital intensive, and highly
technical. This approach carries a likelihood of continued upward
migration of wealth. The presenter stated explicitly that consumers
would bear the costs, while failing to address other adverse
consequences to those of us not positioned to buy our way out of
the harms of a warming planet.

Health Costs
Perhaps because the studies were under CARB's auspices
(grant-funded?), these models were broad in scope, with limited
granularity, yet very limited in focus: reduction in emissions, the
first primarily from transportation and other fossil fuel use, the
second addressing the health risks of catastrophic fires and
various approaches to forest management. These were deemed
"well-researched;" everything else was, apparently, considered
qualitative. Surely there must be data available on morbidity and
mortality from heat stress (e.g. Portland, BC), and other unusual
weather extremes (e.g. Texas). Health and social costs are
demonstrated to correlate, yet inequity in who will bear the costs
was barely mentioned. Plus, of course, the omission of evaluation
of impacts pesticides, the known detrimental environmental and
health effects of which have been relegated as qualitative due to
lack of investment in research.
Social Costs
Presented with no parameters and no data as to what was or will be
considered, this was a quick "invest today, get payback in the
future" recommendation for Option 3 out of 4, winnowed down from 8
options in the first presentation. There are already many social
costs to Business as Usual (BAU), and planetary warming is likely
to exacerbate them: housing, workforce training, food costs and
access, limits to mobility, climate refugees, just to name a few.
Many EJAC comments and questions revolved around social costs and
all were poorly answered. 

Natural and Working Lands (NWL)
Not a single recommendation from CARB's EJAC subcommittee on
scoping was incorporated, or even mentioned. Yet in the economics
presentation, agriculture was graphed, without explanation, as
bearing a large proportion of the costs ascribed to mitigation
measures. Early in this webinar, ag was referenced as an emissions
source, also without explanation, aside from discussion of ozone
and PM2.5s from forest fires.

Various scenarios for forest management were addressed as they
related to health costs. The NWL presenter at least had the decency
to apologize for the limitations of his presentation. He addressed,
in passing, the costs and labor-intensive nature of managing
forests, both urban and rural. (At this point in our history, it
would be disingenuous to call our remaining rural forests
"natural.") The catastrophic dangers of forest fires were reduced
to smoke, and the addition of urban forests was framed as an
alternative to aggressive forest management; both options were
deemed costly implement and maintain. 

To combat global warming, we need restoration of our forests to
health by managing undergrowth that creates unnatural fire risks,
by eliminating even-aged single species reforestation, and by
preserving old growth, among other conservation methods. This can
be done without wide use of herbicides.

In urban and suburban areas, augmenting tree cover, more parks and
green spaces, and community gardens all have direct cooling
effects, the potential to sequester carbon, and add value and
health to neighborhoods, as long as methods used limit harmful
chemicals and attend to soil health.

Pesticide reduction, conversion to organic farming, and
regenerative practices in agriculture have been demonstrated to
increase carbon capture and soil restoration, practices that have
been effective far longer than removal and storage of carbon by the
relatively untested mechanical, energy-intensive methods relied on
in alternatives presented. To emphasize the latter, and to discount
the former, tilts the process heavily toward increasing, not
reducing, environmental injustice. 

The Distributive Model
CARB's scoping plan is mandated to incorporate ways to promote
environmental justice. This means looking beyond industrial methods
based on direct extraction and reduction of carbon by industrial
means. We need to know who will be most impacted, both by measures
proposed, and by damages from failure to act quickly and equitably.
In whose neighborhoods, and on whose land will renewable energy
installations be installed? Where would plants to extract carbon be
placed, and under whose feet would it be stored? If cap and trade
is continued, who bears the brunt of trade-offs? These are
sovereignty and quality of life concerns that cannot be reduced to
dollars and cents.

In the economic realm, income inequality must be considered. For
example, in order to increase capacity for labor-intensive
solutions in forestry, farming, and restoration of natural and
working lands, both urban and rural, workers must receive
appropriate training and a living wage. Use of technology to
develop alternative energy sources, increase the efficiency of
transportation and distribution services, and track progress toward
climate goals should be income leveling, not an excuse for widening
the gap. 

Decentralization of production of food, and some goods and
services, will reduce transportation costs and build in resiliency
during such events as pandemics and climate emergencies. Energy
systems must also be decentralized, increasing rooftop solar in
urban areas, forming community-based power coops with collaborative
grids, and developing accessible, fossil-fuel free, public
transportation.

Restoration-based, Not Consumption-based
Finally, reduced consumption of some products (e.g., plastics,
appliances, tech, and vehicles, all built for frequent replacement,
limited recycling, and difficult disposal), restoration of
biodiversity, and honoring the functions of the natural world are
essential to reduce human climate impacts. 2045 is too late. The
line between quantitative and qualitative impacts is not a solid
boundary. For California to show real leadership, the final scoping
plan must project this final vision more elegantly, holistically,
and justly. Perhaps these issues will be addressed in the final
scoping plan. If so, why are choices of options already being made?
Our future is about qualitative choices. This is not just about
money. 

Kathleen Kilpatrick, RN, MN, NP, PHN, CSN
Retired School Nurse, PVUSD