Comment Log Display

August 4, 2008

Mary Nichols
Chair, California Air Resources Board
Sacramento, CA 95814

RE: Climate Change Draft Scoping Plan

Dear Chair Nichols:

The City of Roseville is pleased to submit the following comments
on the California Air Resources Board (ARB) Draft Scoping Plan
(Scoping Plan).  We appreciate the scale and scope of this effort,
and recognize that local governments will have an important role in
meeting the mandates of AB 32.  

The City of Roseville is proud to be the first city in the
Sacramento region to adopt the Sacramento Area Council of
Governments (SACOG) Implementation Strategies to Achieve Blueprint
Project Objectives, in 2005. Roseville also received the SACOG
Blueprint Excellence Award, and the League of California Cities
Helen Putnam Award for Planning and Environmental projects, for
the City of Roseville Blueprint Implementation Strategies. 
Additionally the City is proactively complying with AB 32,
finalizing the City’s operational inventory and exploring funding
opportunities for preparation of a Climate Action Plan.  The City
has already implemented a number of sustainable programs,
including:

•	A Citywide “Green Team” develops innovative programs and
policies to address land use and green building, utilities, green
energy, transportation, public outreach, and recycling.
•	Energy Efficiency Incentive and Rebate Programs (including
photovoltaic and efficient appliance rebates)
•	Innovative recycling programs (the first city in the region with
a Styrofoam recycling program)
•	City of Roseville General Plan has been updated to address
Global Climate Change, and identify existing policies that reduce
greenhouse gas emissions
•	The City’s BEST Homes program utilizes rooftop solar electric
generation technology, high energy efficiency, water efficiency
and shade trees as a standard feature in homes. Through BEST
Homes, Roseville Electric offers developers up to $8,600 in
rebates for each participating dwelling unit. In fiscal year
2007/2008 over 20% of new home permits participated in the
program.

These and many other programs to help us meet the challenge of
reducing greenhouse gases while being fiscally and environmentally
responsible are documented in the City’s Sustainability Initiatives
Report (attached)


General Comments

Local government must retain clear land use authority
We are concerned that ARB has received numerous comments, both
written and verbal, from environmental interests and other parties
requesting more emphasis on land use control in the Scoping Plan. 
We urge you to equally consider the input of local governments, as
the entities that actually process development projects from start
to finish, and negotiate all of the associated complexities, on a
daily basis.  As a City that is actively implementing the
Blueprint principles, the reality is that the process is not
simple or quick.  Local governments know the needs, goals and
limitations of their individual jurisdictions and regions, and
must remain empowered to implement programs that best meet their
unique situations.  Diminishing land use authority would detract
from the ability of local governments to meet those local goals
and needs, and would in all likelihood stymie rather than
facilitate Blueprint development.

The State should provide incentives, not penalties
The Scoping Plan recognizes that many cities, such as Roseville,
are progressive and already moving in the direction of AB 32
compliance.  The Scoping Plan identifies “Community Design” as an
area for which local governments must account for environmental
impacts associated with project siting and design.  While local
governments can influence development design to a certain extent,
the reality is that developers will only build projects that will
be purchased by willing customers and that are profitable.   In
order to effect the desired change, incentives must be provided to
the development community.   Moreover, it is impractical to suggest
that levying fees on new development or utilities will achieve the
desired ends, as it would drive up the cost of development, and be
a disincentive to investments in innovative design.

Regional targets should be flexible
There are a multitude of forces to which local governments must
respond in their own ways.  These include the Regional Housing
Needs Allocation (RHNA) requirements, the extent of greenfield
opportunities and build out in each community, the pace of new
development as dictated by the economy, and many other factors. 
The City of Roseville is not opposed to the proposed concept of a
regional target; however we are concerned about the potential
implications if regions are unable to meet targets should they be
made mandatory.  Mandatory targets do not recognize the
variability of conditions among local jurisdictions and should not
be required as part of the Scoping Plan.

The City’s programs illustrate the success of the incentive-based
approach.  The City’s recent “Cash for Grass” program, to help
property owners convert from grass to a water-efficient landscape,
demonstrated the overwhelming public interest and desire for these
programs; there was not adequate funding to meet the demand.  

Infrastructure funding must be provided
The Scoping Plan does not identify a funding source to provide for
the recommended “increased emphasis on urban infill development.”
This is essential for local governments given the infrastructure
costs often associated with redevelopment projects.  Infill and
redevelopment projects could also provide opportunities for
development-oriented incentives such as relief from CEQA
mitigation requirements, exemption from state agency review fees,
shortened comment periods, etc. 

Thank you again for the opportunity to submit these comments for
the public record. If you have any questions, or would like
additional information about actions being taken in the City of
Roseville, please do not hesitate to contact Terri Shirhall, in
the Planning and Redevelopment Department, at (916) 774-5422.

Sincerely,

 
Jim Gray
Mayor