Comment Log Display

Evaluation of public health benefits
Thank you for expanding the discussion of health benefits in the
AB 32 Proposed Scoping Plan.  In addition to the air pollution
related health benefits, we encourage you to include the health
benefits and related cost savings from increased physical activity.
 The expected mode shift from driving to human powered
transportation will allow people to integrated physical activity
into their daily routines.  There are significant cost benefits
from the increased levels of physical activity resulting from such
a mode shift.  The recently published report, “Active
Transportation for America” quantifies the cost benefits nationally
based on two possible mode shift scenarios.  This report can be
found at http://www.railstotrails.org/index.html. 

The cost benefit numbers in the “Active Transportation for
America” report are conservative.  The report understates the cost
benefits of a mode shift to more walking and bicycling.  It does
not address pollution related health benefits nor include the cost
savings from a reduction in traffic fatalities, injuries and
property damage.  As we noted earlier, crash costs are estimated to
be more than $164B annually for the U.S.  (AAA Crashes vs.
Congestion:  What’s Cost to Society)  

Regional targets
We continue to believe that emission reductions would be more
likely to be achieved and more appropriated focused, if the plan
included much higher regional land use targets—in the range of
11-14 MMT instead of 2-5 MMT.  The higher targets are achievable
and would help make recently passed SB 375 more effective.

Addressing VMT
We strongly believe the plan should call for specific reductions
in Vehicle Miles Travelled (VMT).  The transportation section is
the largest source of GHG emissions.  Until the recent spike in the
price of gas, VMT has continually increased.  It will be very
difficult to achieve planned emission reductions without directly
addressing the largest source of emissions, establishing a goal for
VMT reductions and policies that directly, rather than indirectly,
relate to that goal.

Long Term Trajectory
The graph of projected greenhouse gas emissions shows emissions
increasing until 2010 and declining thereafter.  In 2010, the
emissions curve turns on a dime and thereafter projected emissions
decline in a continued, very steep downward slope for the next 40
years.  

It is uncertain whether this emission projection is realistic.  It
seems unlikely that emission reductions will exceed what is in the
plan, especially in the first few years.  It certainly is prudent
for the plan to have flexibility and for progress to be closely
monitored.

Since progress in emission reductions may be less than planned, we
recommend that the plan include more tools to reduce transportation
related GHG emissions.  The tools should be developed and agreed
upon in advance so they could be implemented in the short and
mid-term.  Some possible tools include:
	Parking cashout and parking charges
	Requirement for bicycle facilities (showers, lockers and bike
parking) in green buildings
	Expedient implementation of AB 1358, which call for Complete
Streets in the circulation element in general plans
	Implementation of Complete Streets concepts in Prop 1B projects
	Retrofitting of existing streets to make them Complete Streets 
	Safe Routes to School Programs
	Safe Routes to Transit Programs
	Increase in gas taxes
	Carbon fees