Comment Log Display

December 9, 2008

Chair Mary Nichols
California Air Resources Board
1001 “I” Street 
P.O. Box 2815 
Sacramento, CA 95812

Dear Chair Nichols, Board Members, and Staff:
     
The Regional Transportation Planning Agencies (RTPAs) appreciate
the opportunity to comment on the California Air Resources Board’s
(CARB) Proposed AB 32 Climate Change Scoping Plan. California’s 43
RTPAs seek to ensure that transportation projects can be
successfully implemented that provide the multiple benefits of
economic development, improving quality of life and meeting state
and federal environmental goals.  

While mindful of the previous comments submitted by the RTPAs on
August 13th, we would like to bring to your attention to these
additional comments for inclusion in the Proposed Scoping Plan.

•	Support the securitization of existing funding levels of state
transit funding and dedicate new sources to accommodate modal
shift.  While the Proposed Scoping Plan’s overall policy goals
support and encourage a shift toward more transit-oriented
communities and acknowledges the necessity of a secure source of
transit funding, it fails to acknowledge the state’s continued raid
of transit funding to balance the budget.  A significant state role
in transit funding is critical to meeting the statutory goals of AB
32 and SB 375 and the need to protect such funding sources should
to be acknowledged in the plan.  Additionally, the plan should
acknowledge that a modal shift will place a greater burden on
transit systems necessitating a dedicated, secure and sustainable
funding source to accommodate this shift.

•	Credit for emission reductions achieved through bond funded
projects should belong to the local implementing entity. Local
jurisdictions are contributing the majority of funding for these
transportation projects through local matching funds, in addition
to other expenditures for planning, environmental reviews, and
engineering.  Assigning credit of GHG emission reductions achieved
through these projects entirely to the state ignores the role of
local agencies in implementing these emission reducing projects and
decreases the ability to reach regional GHG targets. The regional
transportation plans analyze the cumulative impact of all land use
decisions and transportation projects based upon overall
anticipated funding without regard to the funding source and
separating out specific projects requires an analysis of what would
happen without those projects but must include how the funding that
went to those projects would otherwise be spent. Accordingly this
policy is unworkable if applied to regional transportation
planning. We ask that this be clarified. If this does apply to
regional transportation planning, the Plan should consider the
option of crediting GHG reductions proportionally based upon the
funding contribution of each entity. 

The RTPAs look forward to partnering with CARB on implementation
of plan. RTPAs representing different areas of the state should be
included as key representatives on the Regional Targets Advisory
Committee to ensure integrated implementation of the Scoping Plan
with the SB 375 process.  Through this partnership, the RTPAs hope
that a workable framework can be developed whereby the goals of AB
32 and SB 375 can be successfully met and transportation agencies
can continue implementing transportation projects efficiently and
effectively. Please contact Timothy Papandreou at (213) 922-2281 or
Wendy Villa of OCTA at 714-560-5595 if you have any questions. 

Sincerely,

Rachel Moriconi
Moderator 2008/09
California Regional Transportation Planning Agencies