Comment Log Display

The Environmental Council of Sacramento (ECOS) applauds
California’s efforts to reduce greenhouse gas (GHG) emissions. 
However, we remain extremely concerned that the AB 32 Scoping Plan
in its current iteration fails to outline a sufficiently aggressive
target for reducing GHG emissions via "smart growth" related
changes in transportation and land use planning.  ECOS feels
strongly that the CA Air Resources Board (CARB) must increase the
goal for GHG emissions reductions achieved via smart growth land
use and transportation planning from the current proposed 5 Million
Mega Tons (MMT) to somewhere in the range of 11-14 MMT per year.

A target of 11-14 MMT is achievable and would translate to a very
modest reduction in driving by the year 2020 of less than four
miles per day per licensed driver.  If CARB sets a lower target
(e.g., something in the range of 5 MMT), the result will be greatly
expanded “greenfield” development and more road and highway
expansions and new construction.  This kind of business-as-usual
approach to planning will make it impossible to reach the 2050
targets established by AB 32.  For California to achieve the
critical goals of AB 32, we must see reductions in vehicle miles
traveled (VMT) 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.

In addition to setting a more aggressive target for GHG
reductions, CARB should highlight the importance of prioritizing
new and expanded funding for pedestrian, bike, and transit
facilities.  Getting Californians out of our cars will require a
paradigm shift in transportation options and behaviors.  This means
“complete streets” throughout our urbanized areas and greatly
expanded funding for transit operations and maintenance.  The
Scoping Plan needs to emphasize these priorities so that local
governments will appropriately update and modify their plans and
impose necessary requirements on new projects.

Finally, the Scoping Plan needs to address equity, environmental
justice and public health.  CARB should ensure that AB 32
implementation includes goals for improving public health and
enhancing the equity of our metropolitan areas through smarter
coordinated transportation and land use planning.  Again, a clear
signal from CARB will help spur local governments to better address
these issues through local planning documents and project funding
allocations.

Thank you for your attention.  Please do not hesitate to contact
us with any questions.

Sincerely,
Graham Brownstein
Executive Director, ECOS