Comment Log Display

Thank you for the opportunity to comment on the Climate Change
Proposed Scoping Plan dated October 2008.   The City supports the
Air Resources Board’s efforts in implementing AB 32.  Achieving the
reduction of greenhouse gas (GHG) emissions to 1990 levels by year
2020 will require coordinated efforts between the state, regional
and local agencies, private industry and California citizens. 
Local governments are facing enormous challenges guiding
development of our communities and providing effective and
efficient services to our residents given current economic
conditions.  Implementing the GHG emissions targets is necessary
and desirable, but will add to these challenges.   While generally
supportive of the proposals in the Draft Scoping Plan, the City
submits the following comments and concerns:

•	Let SB 375 Work. Although the Scoping Plan acknowledges that the
actual regional transportation-related GHG targets will be set
through the regional process developed in SB 375, many are
advocating that this number be raised. Given the deference the
Scoping Plan gives to the SB 375 process, perhaps such an increase
would largely be symbolic. However, since CARB has ultimate
responsibility for setting the targets, a higher number would
create political pressure for setting higher regional targets,
regardless of the findings of the Regional Targets Advisory
Committee. This is contrary to what SB 375 stands for.

•	No Accounting for Infrastructure Costs. The Scoping Plan does
not analyze the costs of infill infrastructure needed to serve more
compact development patterns. For complex reasons stemming from the
Takings Clause, Mitigation Fee Act, and other laws, local agencies
cannot pay for the infrastructure from developer fees alone. Nor
under Propositions 13 and 218, will they be able to raise
assessment or other revenues. At the very least, CARB should have a
detailed infrastructure feasibility analysis completed before it
engages down this road. Indeed, this is precisely the type of issue
that will be addressed by the Regional Targets Advisory Committee
created by SB 375. CARB should let that process work.

•	Acknowledging Current Economic Uncertainties. CARB must
appropriately balance its climate goals with current economic
uncertainties, which directly affect the feasibility of certain
types of development. Increasing the target will make it more
difficult for compact developments to achieve the California
Environmental Quality Act (CEQA) streamlining contained in SB 375.
As demonstrated by the Governor’s proposed budget recommendations,
such streamlining can have an important economic effect and help
stimulate the economy.