First Name | Edward |
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Last Name | Mainland |
Email Address | emainland@comcast.net |
Affiliation | Sierra Club California |
Subject | Sierra Club Comment on Public Health and Environmental Justice |
Comment | COMMENTS ON AB 32 PROPOSED SCOPING PLAN, SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008 D. Public Health and Environmental Justice Issues Must Be Addressed ? The Proposed Scoping Plan has failed to adequately respond to concerns raised by the EJAC and public health community. ? CARB should adopt the EJAC's recommendations to increase the 2020 target for land use, invest in public transit in low-income communities, and create incentives for local governments to reduce their emissions. ? The public health analysis should include specific data about public health impacts associated with community design, including impacts on obesity, chronic disease and public safety. ? CARB should ensure that the public health community has an ongoing, formal role in shaping AB 32 policy. Sierra Club supports the following text recommended for insertion into the Plan by the Coalition for Clean Air and other California organizations. • ARB will adopt a cumulative impacts assessment method within a year or prior to the adoption of AB 32 related market-based regulation and identify communities “already impacted by air pollution” cumulatively to ensure uniformity and consistency among the state, air districts and other local governments so that communities identified as impacted by one agency do not get categorized differently by another; • ARB will evaluate the potential negative impacts (if any) of all subsequent AB 32 regulations in these communities prior to their adoption and incorporate safeguards; • ARB will design the market mechanism compliance protocols to achieve maximum emission reduction and co-benefits in the most disadvantaged communities by including incentives and restrictions; and • ARB will initiate a public process within three months to determine and recommend the percentage of resources generated through AB 32 related auction and fee revenues that can be directed to assist in adaptation and emission reduction measures for those communities and small businesses most disadvantaged by climate change or air pollution impacts. |
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Date and Time Comment Was Submitted | 2008-11-19 19:18:23 |
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