Dear Chair
Randolph and California Air Resources Board Members,
I am a physician and have taken care of cancer patients
in Contra Costa County for over 20 years, responding to
clinical
manifestations of environmental injustice on a daily basis. That is
why I am deeply committed to health equity and that is what I
would like to address in this comment letter, as it pertains to the
scoping plan.
After our struggles with COVID-19 pandemic for over 2
years, by now we must all know in our hearts that without public
health there is no economic prosperity. Today, with my
other colleagues, we have submitted a letter endorsed by 28 health
organizations and more than 300 health professionals asking you to
prioritize
public health over speculated future economic growth and
prosperity. Please refer to our letter regarding our specific requests.
Please consider these additional
comments,
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The health equity
evaluation process should be built into the design of the Scoping
Plan and
completed prior to adoption of the final version of the Scoping
Plan. The
selection
and prioritization of various strategies within the scoping plan
must be informed by a robust health equity analysis. Designing a plan and performing a health
analysis after the fact is not the same as designing a plan based
on the health equity analysis. If the plan is designed based on health
equity analyses, you will have the opportunity to intentionally
combine elements that collectively would provide maximum health
benefit to overburdened communities. That is the only way to truly
minimize the social cost. Not only a health equity analysis was not
attempted in the process of creating the draft Scoping Plan, the
limited health analysis appeared to be an afterthought, it was
incomplete and in some aspects provided misleading
information.
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Socioeconomic,
race/ethnicity, gender and other factors associated with health
inequities should be included in the health analyses.
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CARB should
collect granular, community-level data for mobile and stationary sources
and should make every attempt to include any data that is already
available in their analysis. It did not appear that CARB made any
attempts at incorporating granular data that is already available
(e.g. Aclima) in its health
impact analysis. The suggestion that CARB “ may
consider” to include, instead of “will include”
updated health equity data in their final Scoping Plan is
unacceptable.
-
CARB must prioritize strategies that reduce direct
emissions of local criteria air pollutants and hazardous air
pollutants. As one of the board members today mentioned,
repurposing polluting industries will only increase pollution in
impacted communities and result in perpetuating
inequities.
-
CCS creates public
health hazards at every step of the way– capture,
transport and storage. CO2 is heavier than air and stays low to
the ground at the lung level, therefore CO2 leaks are even more
dangerous than methane leaks. The idea that these public health hazards
could be regulated are not based on real life experience of
impacted communities who live with regulatory failures everyday.
Implementation of CCS in California at this time is
aspirational, but if CCS was miraculously ever implemented, it
would make things worse, not better. As currently
practiced, CCS is net additive, releasing into the atmosphere more
CO2 than it removes while increasing local air
pollution.
-
California is
truly on a dangerous path because in the draft Scoping Plan,
CO2 is
being framed as a commodity and under the proposed scenario, polluting
industries will make profit by polluting (e.g. Biogas &
CCS).
-
Nearly every one
of your decisions has a health impact. Staff and board members must
have a clear
understanding of the health equity impacts of each strategy and
policy. For
example VMT reduction is not only beneficial because of reduction
in air pollution and associated health harms. Active transport has
additional significant health benefits with significant health
savings. These savings were ignored when the draft scoping plan was
generated and that resulted in limited VMT reduction targets and a
less ambitious plan..
-
CARB should
prioritize community-driven solutions that advance a just
transition away from fossil fuels and support regenerative economic
sectors while promoting good, family-sustaining wage jobs creation
and training pathways for impacted workers.
California’s climate policies must be good air
quality policies and good public health policies while also
charting the course for a just transition. Please prioritize
public health, account for all pollutants and prioritize the
Frontline communities, the lives of our patients, communities and
the life of the future generations depend on it.
Sincerely,
Marjaneh Moini, MD
Board Member Physicians for Social
Responsibility
You can access our letter here:
https://docs.google.com/document/d/1B0Y8ap9qwtnlOITcx5KaTsZ1PPOq47b3Kib_IWIPeSw/edit
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