Comment Log Display

Dear CARB members,

Thank you for your hard and innovative work on this Final Scoping
Plan for AB32. I hope that you will adopt the following suggestions
in order to further improve the plan and reduce California's
greenhouse gas (GHG) emissions by 2050. These comments are based on
   research and analysis supported by Transform (formerly the
Transportation and Land Use Coalition), to which I belong. As a
second-generation California native born in Redwood City, I have
witnessed many decades of sprawl and increasing congestion in the
Bay Area during my 56 years. I strongly urge you to adopt more
stringent GHG reduction goals for 2020, especially in reducing
urban sprawl and creating more walkable, livable cities.  

The proposed AB32 Final Scoping Plan is a big improvement over the
June draft plan, but more stringent smart growth/compact growth
standards need to be implemented now in order to meet AB 32's 2050
carbon emissions goals.  
 
On October 15th, the California Air Resources Board (CARB)
unveiled its final recommendations for reducing greenhouse gas
emissions under AB32 (the Global Warming Solutions Act).  The state
has made major progress by doubling the 2020 land use emission
reduction target in this latest draft: the new goal is 5 million
metric tons (MMT) more than twice the 2 MMT goal in the June draft.
The Plan also calls on all local governments to reduce their
emissions by 15% over current levels by 2020. The Plan coordinates
well with SB 375, and defers to SB 375 in establishing regional
targets. 

Still, a more ambitious goal is needed, and a more diverse and
accurate suite of analytical tools should be utilized to reach that
goal. 
 
CARB should set a land use goal for 2020 of 11-14 MMT and send a
clear signal that new communities should be walkable, affordable,
and have great transportation choices. A September 2008 scientific
analysis by Dr. Reid Ewing and Dr. Arthur C. Nelson, authors of
Growing Cooler, the definitive scholarly text on urban development
and climate change, finds that a target of 11-14 MMT a year is
achievable under policies that California is already contemplating.
(The Ewing Report is available at www.climateplan.org.) 

A target of 11-14 MMT translates to a very modest reduction in
driving in 2020 – less than four miles per day per licensed driver.
Regions around California have already adopted plans that will
reduce GHGs by 7.1 MMT by 2020, according to Stanford University's
Jim Sweeney. 
 
CARB must set a higher 2020 target for land use in order to put
California on track to meet the 2050 target. We cannot afford
another 10 years of business-as-usual development. If CARB sets a
low 2020 target for land use, the resulting 10 more years of sprawl
will make it impossible to reach our 2050 target. (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. 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.)
 
The methodology CARB used to generate their current 5MMT estimate
is not sufficiently accurate or broadly based as one might hope,
given the gravity of the problem. Unfortunately, CARB drew on only
one UC Berkeley report to generate its estimate of reductions and
develop the 5 MMT goal for 2020. 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.”) 
 
CARB should base its estimate on more than one source and examine
a more recent 
report from the authors of Growing Cooler, which suggests that
reductions of 11-14 MMT are possible by 2020 (The Ewing Report).
The Ewing Report is based on California data for a 20-year
historical period, and is far more realistic in its projections
than the UC Berkeley report's series of regional modeling studies
based on data from different states and nations with widely
differing circumstances.  
 
CARB should also adopt a statewide 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.  
An ISR creates a local revenue fund to help local governments
implement Climate Action Plans. Rural non-metropolitan (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.
 
 
Investing in and sustaining public transportation systems should
also be a top priority in the final AB 32 Scoping Plan, in order 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 1⁄2 mile of
transit, 42% of them ride it to work.  
  
In addition to reducing vehicle miles traveled (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 MPOs, and are therefore 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 forestry measures to avoid duplicative efforts and
maximize benefits in both sectors. 
 
The Final Scoping Plan has failed to adequately respond to
concerns raised by the EJAC and public health community. CARB
should adopt the EJAC's recommendations to increase the 2020 target
for land use, invest in public transit in low-income communities,
and create incentives for local governments to reduce their
emissions. The public health analysis should include specific data
about public health impacts associated with community design,
including impacts on obesity, chronic disease and public safety.
CARB should ensure that the public health community has an ongoing,
formal role in shaping AB 32 policy. 
 
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.

Thank you again for your efforts to reduce global warming
statewide. I hope you will adopt these and other suggestions in
order to make reaching the 2050 climate change goals a reality.

Respectfully submitted,

Jon Spangler
1037 San Antonio Avenue
Alameda, CA 94501-3963