Comment Log Display

The Need For Immediate Reductions in Short-Lived Pollutants
and
The Adoption of Generic “Early Action” MEASURES


	This is a preface to a much longer document that provides
information on a wide range of policies and measures that could be
adopted to reduce global warming.  The purpose of this preface is
to highlight two major shortcomings of the staff proposals, to
wit:

	First, the measures evaluated seems to be restricted to actions
focused only on the greenhouse gases listed under the Kyoto
Protocol.  Such a narrow approach clearly contravenes AB 32, whose
authors revised the definition of “greenhouse gas” specifically to
assure that short-lived pollutants that cause global warming, such
as black carbon, tropospheric ozone and carbon monoxide, would be
addressed.  Both Senate Pro Tem Perata and Speaker Nunez wrote to
Chairman Sawyer to leave no question that there was awareness  at
the policy level of this coverage.

	Second, the proposals are all narrow in scope and ignore generic
“early action” measures that could influence behavior broadly. 
These would include taxes, feebates, labels, liability regimes and
the like.  While it is understandable that the staff is reluctant
to propose possibly controversial initiatives, excluding generic
measures from even mention is ill conceived, given the
unprecedented risk posed to California and the world by global
warming.

	Taken together, these two qualities of the proposals bespeak an
ignorance of or insensitivity to the rapidly accumulating evidence
that several positive feedbacks are underway, increasing the
likelihood that one or more tipping points will be reached beyond
which the climate under which civilization has evolved will be
irretrievably lost.  The proposal falls far short of the ambition
and vision demonstrated by the legislature’s passage of not only
AB 32 but nearly a dozen other measures designed to construct a
broad-based, muscular response to the threat of global warming. 
The Board would be well advised to review the breadth and depth of
the measures and embrace the sense of urgency and scope evinced by
the legislature.

	I regret that the longer, principal document is in a draft
format.  Unfortunately, the time between the announcement of an
expanded set of proposed early actions and the deadline for
comments did not permit comprehensive revisions and corrections. 
These are now underway and will be submitted when complete.

	Overview of Recommendations

	+ Land based motor vehicles

		* Reconstitute the zero emission vehicle program, if necessary
requiring deployment of advanced technologies in medium- and
heavy-duty applications.

		* Focus on measures to alter landuse and commuting patterns.
	+ Vessels

		* Identify a mechanism for, if necessary, piercing international
maritime regimes to require global elimination of bunker fuel and
adoption of cleaner engines.

	+ Aircraft

		* Assess the contribution of aircraft to the global burden of
black carbon and develop control measures.

	+ Electricity generation and fossil combustion

		* Impose a single output based feebate reflecting source
contributions to global warming and the ill health burden or
multiple fees that do the same, with collected fees being rebated
to non- or low-polluters.

	+ Methane

		* Install anaerobic digesters on all waste lagoons, including
publicly owned treatment works.
		* Install methane gas collection stems on all current or former
waste disposal sites of larger than de minimis size.
		* Impose a “take back” program requiring vendors to collect
product packages and goods, such as tires and appliances, that
have reached the ends of their useful lives.

	+ Black carbon

		* Substitute gasification or other means of waste utilization in
lieu of open burning.
		* Retrofit all trucks serving the ports of Long Beach, Los
Angeles, Oakland, San Francisco and Stockton with control
devices.

	* * *    	Positive Feedbacks that are in Motion

	+ Stratospheric cooling in the Arctic and Antarctic.

	+ Arctic and Antarctic melting.

	+ Tundra and permafrost thawing.

	+ Tropospheric ozone increasing.

	+ Coral bleaching and death.

	+ Phytoplankton declining.

	+ Oceans acidifying.