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Dear Chair Nichols and Members of the California Air Resources
Board:

I commend your leadership in working with many stakeholders to put
together a ground-breaking and visionary plan for reducing
greenhouse gas emissions – and consequently improving health
conditions – throughout the state of California.  I am writing
today to highlight specifically the potential impact of Climate
Change Draft Scoping Plan on achieving health equity and ask that
you take my recommendations into consideration as you move toward
a final plan. 

Health inequities are pervasive in Alameda County and across
California.  Studies reveal that these inequitable health outcomes
are not adequately explained by genetics, access to health care, or
risk behaviors, but instead are to a large extent the result of
profoundly adverse social and environmental conditions.  An
examination of West Oakland, a community situated alongside the
Port of Oakland and between two freeways, I-880 and I-580,
illustrated this point.

Residents living West Oakland can expect to die, on average, more
than a decade before residents of the Oakland Hills and,
appallingly, this gap may be increasing.  It is clear that one of
the underlying causes of this disturbingly large health disparity
is the extremely high rates of environmentally-linked disease in
West Oakland.  People living in West Oakland breathe in 3 times
more diesel particles than other Bay Area residents. As a result
of the exposure, West Oakland residents experience high rates of
diseases such as cancer and asthma.  As demonstrated in the West
Oakland Health Risk Assessment, West Oakland residents experience
2.5 times greater lifetime risk of cancer than Bay Area residents
in general and 80% of this excess cancer risk is attributed to
diesel trucks.  They have the highest rates of asthma
hospitalization in the county – 2.3 times the average – and West
Oakland children under five years of age have emergency department
visits rates due to asthma nearly three times the county average. 


The asthma rates among children are particularly alarming. Asthma
is a chronic disease that can lead to irreversible changes in the
architecture of the airways in the lungs.  The irreversibility of
these lung changes is one of the prime reasons that preventing
asthma in children by reducing exposure to environmental triggers
such as diesel is so critical to avoiding a life plagued by
chronic disease.  Additionally, asthma places a burden on the
respiratory muscles and heart, therefore potentially exacerbating
heart disease, producing heart failure and ultimately increasing
the likelihood of heart attacks, the number one killer of West
Oakland residents. 

The impact of the concentration of environmental hazards in West
Oakland is particularly devastating to residents’ health because
of their social vulnerability.  Due to high poverty levels and the
prevalence of other psycho-social stressors, as well as a lack of
access to healthcare, West Oakland residents are already at risk
for poor health outcomes.  Additionally, there is increasing
recognition that multiple hazards interact and have a cumulative
impact on residents.  

It is because of the extent and urgency of the health problems
plaguing West Oakland and the many other similar communities in
Alameda County and across the state that we urge you to consider
our feedback on the Climate Change Draft Scoping Plan.  

1.	Ensure protection for already over-impacted communities.  
Equity should be at the fore-front of all aspects of the plan, but
most importantly, it must be central to measures that have the
highest potential for inequitable implementation.  As detailed in
the draft scoping plan, California is joining the Western Climate
Initiative and plans to implement cap-and-trade and carbon offset
programs.  I have several concerns regarding implementation of
this plan and its impacts on low-income communities and
communities of color, including those in Alameda County. 
Mitigation strategies such as cap-and-trade or offset programs
must not exacerbate already existing health inequities in
low-income communities.  As demonstrated, such communities are
already unequally burdened by extremely poor environmental
conditions and poor health.  The final plan must include adequate
safeguards for these communities, such as:
•	Provisions to prevent “leakage”, such as local emissions caps
(in addition to regional caps), to ensure that high-impact
communities do not experience increased emissions levels while
other communities see improvements. 
•	Re-allocation of funds collected through pollution permits, so
that high-impact communities benefit from the pollution permits
sold in their areas.
•	Technical assistance to ensure that small businesses, especially
minority and women owned businesses, are able to reduce emissions
without undue financial strain. 
•	Ensure offset activities take place in local “environmental
justice communities,” such as tree-planting in areas currently
without adequate green space.

2.	Generate funds for government programs.
Some cap-and-trade models allow polluting companies to recap most
of the financial benefits.  However some models, such as
cap-and-auction, require firms to buy pollution credits directly
from the government, allowing the government to then spend that
money on programs for the public good.  The final Climate Change
Plan must ensure that the system implemented in California allows
the government to collect permit fees.  Additionally, these funds
should be redistributed to create public transit programs, improve
walking and biking options, and compensate communities that
continue to bear the brunt of pollutant emissions.  

3.	Land use and transportation policies must be strengthened.
Creating walkable, bikeable, and transit-oriented communities will
not only help reduce greenhouse gas emissions, but also decrease
California’s obesity and chronic illness rates.  Encouraging
active transport has never been more important than now, the first
time in modern history the next generation is expected to live
lives that are shorter than ours.  Almost one-third of Americans
who commute via public transit meet their daily requirement for
physical activity (30 or more minutes per day) by walking as part
of their daily life, including to and from the transit stop.  By
assigning stronger emission reduction targets to land use and
transit policies, the Final Climate Change Plan can harness a
critical opportunity to spur meaningful change in the built
environment that will mitigate climate change and improve the
public’s health.  

4.	Set strong local greenhouse gas reduction targets.
Local greenhouse gas reduction targets both ensure that low-income
communities do not receive the brunt of emissions while others
benefit from reductions (“leakage”) and encourage local
governments to pursue smarter land use planning that facilitates
walking, biking, and public transit use.  While cities and
counties should have choice regarding how to meet these targets,
they should prioritize measures that improve community health,
especially in vulnerable communities.  The final Climate Change
Plan must provide both financial and technical support to local
governments to achieve these changes.  

5.	Continue and improve public engagement in this process.
Current adverse environmental conditions that disproportionately
impact low income communities of color, and the resulting health
inequities, are too often an indelible reflection of the way
decision-making power is shared with these communities. 
Historical exclusion from decision-making venues has resulted in
communities of color and low-income communities that are
disproportionately burdened by an abundance of environmental
hazards, including toxin-emitting power plants and other sources
of noxious pollution. Decision-makers can begin to correct the ill
health effects of systematic injustice by creating a truly
empowering public process. CARB has already made a tremendous
effort in this regard through this open comment period and the
many community forums for feedback.  We ask that you continue to
create opportunities for meaningful engagement in this process as
it moves forward into implementation and evaluation.  

Thank you for your hard work on this plan and for your
consideration of our comments.  The extreme health threats of
climate change and pollution facing California’s residents are
numerous.  Furthermore, in the U.S., low-income people and people
of color are at particular risk in part because their health is
already disproportionately compromised, they are more likely to be
socially isolated, and they command fewer resources to prepare for
and respond to extreme weather events.  This was seen in the
aftermath of Hurricane Katrina and Rita, as well as in the
week-long Chicago heat wave of 1995, both of which are examples of
extreme weather events that are expected to increase with climate
change.   

As a result, we must all accept the weight of this public health
crisis and use every measure available to ensure that our
decisions reduce health risks to the fullest extent possible.  It
is truly exciting to part of this process as we take bold steps in
ensuring the future of our planet and our communities.  We submit
these comments, and strongly urge you to revise the Climate Change
Scoping Plan accordingly, to ensure that the final product
demonstrates California’s strong commitment to reducing health
inequities at the same time as reducing global warming and
wide-spread health risks.  Thank you again for the opportunity to
comment and please contact us with any questions or concerns.

Sincerely,
 
Sandra Witt, MPH, PhD
Deputy Director of Planning, Policy and Health Equity
Alameda County Public Health Department

Original File Name: AB_32_Alameda_Public_Health_comments.pdf

Date and Time Comment Was Submitted: 2008-08-01 16:56:47