The California Air Resources Board (ARB) will hold meetings to update the public on the development of the Cap-and-Trade Adaptive Management Process*, which is intended to address unanticipated adverse air quality impacts that could result from the Cap-and-Trade program. ARB staff will provide a summary of the draft proposed process and invite public comment.
We suggest this deserves a great deal of critical public comment. (See QUESTIONS below.) Cap-and-trade is an inadequate measure for protecting public health while reducing greenhouse gases (GHG). It privileges long-term global effects over near-term improvements to local air quality. Well-crafted and just regulatory policy can achieve both goals simultaneously.
Yes, the market mechanism can work—witness the success of the Acid Rain Program in cutting power plant emissions in the Midwest in the 1990s. But cap-and-trade authorized under AB32, aimed at reducing GHG emissions to 1990 levels by 2020, works much more slowly than would direct regulation of individual sources of pollution. And while deep-pocketed refinery owners buy allowances to pollute up to their permitted limits, the health of local communities will continue to suffer. Asthma rates along the refinery corridor are up to four times higher than in other parts of Contra Costa County. Air pollution kills an estimated 2,000 to 3,000 Bay Area residents each year.
For these reasons, local environmental groups spearheaded by Citizens for a Better Environment have been calling for numeric limits on criteria, toxic and greenhouse gas emissions from refineries. These limits, set for each refinery, would cap emissions below their currently permitted levels, limiting them to no more than the highest level of the last three years. The limits would stop refinery expansions designed to process increasing amounts of “dirty” crude such as tar sands. If permitted, processing these crude oils would dramatically increase GHGs and toxic co-pollutants, including particulate matter. Pulmonary diseases and cancers would likewise increase.
The ARB argues against local limits. It claims they are not "cost-effective," will not reduce GHG emissions statewide, will cause emissions to rise outside of local jurisdictions (lowered Bay Area emissions would mean higher emissions elsewhere), and will shift business activity outside of our area.
Cap-and-trade accounts for about 23% of the total program for cutting GHG emissions statewide. The remainder is addressed by clean fuel programs, incentives for electrification, energy conservation standards, and more. But in fenceline communities, refinery-related activities reveal their harmful impacts in health statistics. And let's not forget: 100% of our breathing draws from the air around us.
Here are a few questions you may put to Air Board staff at this meeting:
• What are “capped” emission levels relative to actual historical emissions?
• Why are the “capped” emission levels not revealed to the public for comparison to reported emissions?
• It was leaked that Shell was allowed to "offset" real emissions by "preserving" a Michigan forest. How does preserving trees in another part of the world help local residents escape the effects of toxic pollution?
• Can Cap-and-Trade quickly cut emissions when the current auction price for credits is only $12/ton? Economists who analyze carbon pricing programs contend that a price of $50 - $100/ton is needed to effectively drive down emissions.
(Thanks to our friends at 350BayArea for suggesting these questions.)
Read more (LA Times) about the controversy and contradictions inherent in California's fledgling Cap-and-Trade system.
Notice of four ARB workshops (Sacramento, Los Angeles, Fresno, San Pablo). Includes locations, links to webcast, and meeting times and locations.
Meeting agendas, staff presentations and other related material distributed prior to meetings. They will be posted on ARB's Adaptive Management website.
* “Adaptive management is a process of information gathering, review and analysis, and response that promotes flexible public agency decision-making. This process is appropriate where complex systems are involved, where the effects of an agency's actions might play out over an extended period of time."
- California Air Resources Board
1 Alvarado Sq
San Pablo, CA 94806
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