Comment Log Display

COMMENTS ON AB 32 PROPOSED SCOPING PLAN,
SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008


6. Regional Transportation-Related Greenhouse Gas Targets (p. 47)

•  The Plan should do more than just “encourage” local city and
county climate action plans. This planning should be required. 

•  This need not be an unfunded mandate: most cities lack funding
and expertise to craft adequate climate plans. CARB should take the
lead in devising incentives – carrots and sticks – and means of
financially assisting or persuading cities to comply.

•  The Plan should include stronger measures to reform land use
planning in ways that reduce vehicle miles traveled (VMT). (See
Newman and Kenworthy paper on how one passenger-mile of transit use
can reduce 3–7 passenger-miles in a car.) 

• Expand Regional Blueprints already underway.  These should
include transit-oriented development, walkable, bikeable
communities, mixed land uses, requiring Regional Transportation
Plans to have strong requirements for reduction of vehicle miles
traveled and more.

•  We are concerned with how this section of the Plan deals with
land use measures. The Plan’s land use goals are not ambitious
enough. Targets are too modest. Tools identified to cope with the
problem are inadequate. And serious reflection of public health,
social and economic co-benefits of forceful action is lacking.

•  SB 375 is insufficient by itself.  Needed also are tools for
local governments to translate GHG reduction targets into local
action.

•  The Plan only counts reducing 5 million metric tons (MMT) of
carbon equivalent per annum by 2020 from actions in this sector.
This is only about 3% of the total reductions. By comparison, the
Sacramento Area Council of Governments (SACOG) blueprint could
reduce carbon emissions by roughly 1 MMT by 2020, even though
SACOG’s region currently contains no more than 1/15th of
California’s population.

• An April 2007 Cal/EPA report, “Climate Action Team Proposed
Early Actions to Mitigate Climate Change in California, Draft for
Public Review,” allotted 18 MMT by 2020 to “regional
transportation/smart growth land use measures.”

The methodology CARB used to generate its current 5 MMT estimate
is outdated and flawed.
?	For a document as important as the AB 32 Scoping Plan, CARB
should draw on the broadest possible range of studies and
methodologies available to generate their estimate of reductions
from the land use sector.  Instead, they rely on a single study
(The UC Berkeley report) to generate the 5 MMT estimate. 
?	The regional model simulations in the UC Berkeley report are
widely acknowledged to understate the benefits of dense mixed-use
development.
?	Even the author of the UC Berkeley report criticizes the models
in her study: “the results confirm that even improved calibrated
travel models are likely to underestimate VKT [vehicle kilometers
traveled] reductions from land use, transit, and pricing policies.
These models simply are not suited for the policy analysis demands
in the era of global climate change.”
?	Rather than basing their estimate on a single study, CARB should
examine a more recent report from the authors of Growing Cooler,
which suggests that reductions of 11-14 MMTs are possible by 2020
(The Ewing Report).
?	Unlike the UC Berkeley report, the Ewing Report is based on
actual historical data for a 20-year period exclusively from
California.  It is far more realistic in its projections than a
series of regional modeling studies from different states and
nations with widely differing circumstances (as included in the UC
Berkeley report). 

•  More compact neighborhoods and less driving are the essence of
the EIR for SACOG’s Blueprint scenario. SACOG plans to devote much
less land devoted to urban uses and to cut carbon emissions while
saving farmland – providing public health and economic savings for
households and businesses where less driving is required. 
Reduction of trips through good neighborhood design must be a CARB
imperative from now on.

CARB must set a higher 2020 target for land use in order to put
California on track for the 2050 target.

?	We simply can’t afford another 10 years of “business-as-usual”
development.  If CARB sets a low target for land use, the result
may be 10 more years of sprawl. This will make it impossible to
reach our 2050 target. 
?	For California to achieve its 2050 target, we must achieve VMT
reductions of approximately 10% by 2020 and 20% by 2030.  The
current 5 MMT target equates to a 4% VMT reduction by 2020 – less
than half of what is needed to keep California on track.

GHG Reductions from Land Conservation should be quantified and
prioritized

?	In addition to reducing VMT, smart growth also reduces
greenhouse gas emissions by preserving landscapes that sequester
carbon, such as forests, agricultural lands, and oak woodlands.
CARB should establish guidelines for quantifying the emission
reduction benefits of preserving these landscapes, and for
mitigating the GHG emissions and loss of sequestration resulting
from conversion. 
?	There are a number of possible mechanisms for implementing this
strategy, including SB 375, CEQA, and Indirect Source Review.
?	Many of California's carbon-capturing landscapes are outside of
regional transportation metropolitan planning organizations (MPOs),
and therefore are not covered by SB 375.  CARB should ensure that
additional policy measures are adopted that apply to these rural
counties.
?	SB 375 and other land use measures should be coordinated with
the Sustainable Forests measures to avoid duplicative efforts and
maximize benefits in both sectors.

Smart Growth is Good for California's Economy

•	Smart growth is a net economic benefit for California, according
to a recent analysis by Stanford University's Jim Sweeney.
•	Californians want and need to live closer to jobs and public
transportation choices – because smart growth will free them from
high gas prices.  The cost of driving a mile in the U.S. nearly
doubled between 2002 and 2007.
•	The Sacramento Region (SACOG) estimates their smart growth
blueprint will save $16 billion in infrastructure costs by 2030.

• Adopt and require the use of greenhouse performance standards,
goals and metrics for transportation planning and projects. Hold
state, regional and local agencies accountable for meeting these
metrics.

• Sierra Club recommends fast-tracking regional mass transit
infrastructure, including Bus Rapid Transit programs (especially on
existing freeway HOV lanes).

• We suggest that mandatory employer parking cashout, like that
implemented by the city of Santa Monica, be added as an additional
measure to evaluate. Employer parking cashout rewards employees
that opt for transit, carpooling, and other smart transit choices.

• Many other ways to reduce workplace vehicle-miles-traveled
(VMT), such as parking fee increases, telecommuting, etc. that need
further study.

• Sierra Club is pleased with the mention of public education
about transportation.

• We suggest that increasing public transit services (both bus and
rail) be included among the sector-based methods.

• Sierra Club supports CARB’s consideration of Pay-As-You-Drive
Auto Insurance.  We note a recent study by Jason E. Bordoff and
Pascal J. Noel, “Pay-As-You-Drive Auto Insurance: A Simple Way to
Reduce Driving Related Harms and Increase Equity"
(www.brookings.edu/~/media/Files/rc/papers/2008/0417_payd_bordoff/0417_payd_bordoff.pdf).
Applied to California, the analysis indicates much larger benefits
than estimated in the Proposed Scoping Plan.  This
emission-reduction estimate is about ten times larger than the Plan
states, and the Plan overlooks co-benefits such as congestion
reductions, crash reductions and consumer benefits.

• Here are a few of the study’s key findings. (The full paper will
be posted on the Bookings Institution website shortly):
-  An 8 percent driving reduction for light-duty vehicles
-  VMT decrease by 24 billion miles
-  Less fuel consumption by 1.2 billion gallons, based on 2006
levels.
-  Direct annual CO2 reductions of 10.5 million metric tons
-  Lower premiums for drivers; two-thirds of households would save
money.

•  CARB should adopt the Indirect Source Rule (ISR) for carbon
dioxide.
•	The indirect source rule, already in effect in the San Joaquin
Valley for air pollution, is a proven policy tool that helps
developers and planners calculate and mitigate the impacts of
projects. 
•	ISR creates a local revenue fund to help local governments
implement Climate Action Plans.
•	Rural non-MPO counties are excluded from SB 375, so ISR would be
the only tool that rural counties can use to address the GHG
impacts of land use. 

 In order for ISR to be effective in reducing VMT, it should
discourage developers from building far from existing services and
jobs, and it should encourage close-in development. To this end,
the amount of the fee should be proportional to the VMT, and the
computer model used to compute a project’s emissions should
accurately account for the individual project’s VMT. 

As a means of encouraging green building, reducing energy use, and
promoting good community design measures such as mixed use and
walkability, such an ISR should follow the precedent set by the
existing ISR to incorporate fee reductions for onsite GHG reduction
measures. Remaining fees should be used for projects that reduce
GHG as well as criteria pollutants and achieve other environmental
co-benefits.

• Lawrence Frank’s new study, Reducing Global Warming and Air
Pollution: The Role of Green Development in California (July 1,
2008, prepared for Environmental Defense Fund), is very supportive
of ISR. ISR is tested and effective.

• Allocation of State transportation funds:  CARB can exert much
more influence on local transportation planning than portrayed in
the October Proposed Scoping Plan. All the local transportation
agencies vie for State transportation funds.  Make those funds
contingent on reducing vehicle-miles and carbon dioxide emissions. 
Allocations should be weighted to strongly favor those local
transportation agencies that have the highest population-adjusted
reductions in carbon dioxide emissions.

•  CARB should prioritize public transit funding:
- The Plan should make it a top priority to invest in and sustain
public transportation and programs to improve transportation
efficiency and reduce congestion. 
- When transit is convenient and reliable, people choose to use
it. When Bay Area residents both live and work within ½ mile of
transit, 42% of them ride it to work. 

• CARB should promote efforts to make transportation information
available via cell phones. One low-cost innovation is the
introduction of everything-on-cell-phone transportation info.  Cell
phones can coordinate and improve all our existing transportation
equipment with:
 - Convenient access to bus and train schedules and next-bus or
next-train real-time arrival times;
- Automatic payment for train, bus, carpool, taxi, or rideshare
(with demand-driven price adjustments honing in on the best price
for minimum vehicle-miles);
- Carpools or rideshares scheduled weeks, days, hours, or minutes
ahead, or even when a car is parked, or when a car with an empty
space is driving by.
- Real-time ridesharing “buddy selection” (sometimes you want
professional peers, sometimes church buddies, sometimes a muscleman
for a tandem bicycle).

Innovative transportation funding mechanism:

•  CARB needs to consider influencing the means of transportation
funding.  Consider the roller coaster ride of gasoline prices and
transportation funding income over the past year.  Add in the
economic mess at both Federal and State level.  California needs a
transportation funding mechanism that provides an incentive to
reduce vehicle miles and decrease carbon emissions.  Such a funding
mechanism makes it easier to influence regional planning. 

•  One suggestion is to consider auto insurance cost savings.
Identify the total amount paid for vehicle insurance in a benchmark
year.  Then split the savings between government and drivers.  For
example, Californians (including businesses) paid about $50 billion
dollars for vehicle insurance in 2007.  If government actions
reduce vehicle-miles traveled (VMT) and accidents per vehicle-mile,
the amount spent on vehicle insurance would decline.  An overall
savings of 10% on insurance could provide California $2.5 billion
for more innovative projects. 

•  For example, in 2008, an individual might have paid $1,000 for
car insurance plus $250 in gasoline taxes (that help fund
transportation infrastructure). In 2015, because people are using
transit, rideshare, etc. to reduce total vehicle miles, the same
individual might pay only $900 for insurance ($800 for the
insurance company and $100 for government transportation funding)
and only $150 in gasoline taxes (because of better fuel efficiency
and 20% less vehicle-miles).  In this example, the individual saves
$200 on his/her transportation costs while transportation funding
remains the same $250 per year per individual.  However, much more
of the $250 can be spent on road and bridge maintenance, or buses
and trains, since reduced vehicle-miles mean less funding is needed
for new roads .

Public Toll Roads:

•  Many experts are advocating tolls to replace fuel taxes.  Los
Angeles Metropolitan Transportation Authority plans to converts
some high occupancy vehicle lanes to toll lanes in order to secure
Federal grants.  The problem with tolls is that government or
private operators have an incentive to increase vehicle-miles in
order to increase the total funds collected. Since private road
owner-operators will be especially resistant to programs that
reduce vehicle-miles, perhaps we should eliminate any private toll
roads.