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Chairwoman Nichols and CARB Board Members:

We strongly urge the board to clearly address land use planning
and zoning issues as part of your final adopted scoping plan.
Southern California regional transporation planning agencies and
local jurisdictions have traditionally ignored air quality and
greenhouse emission issues as part of their development planning
processes. We would like to see the following issues addressed in
your final scoping plan: 

Global warming is the challenge of our generation. Meeting this
challenge requires fundamental changes in the way we plan and
develop, and redevelop our communities. 

CARB should raise the land use planning GHG reduction target in
the AB 32 Scoping Plan from 5 million metric tons of C02 equivalent
(MMT) to 11-14 MMT. As shown by the analysis of Dr. Reid Ewing and
Dr. Arthur C. Nelson, the 5 MMT target is based upon models that
are widely acknowledged to underestimate the benefits of dense,
mixed-use development, while the higher target is achievable with
policies California is already considering. In addition to GHG
reduction goals, we believe that CARB should include mandates that
local planning efforts result in substantial reductions in overall
Vehicle Mile Trips (VMTs) in each region affected by the CARB's
final plan. 

Setting a higher target for the land use planning sector will
signal to the world that refining traditional land use planning and
development patterns is a high priority in the fight against global
warming. Conversely, a low target will send the signal that
business-as-usual sprawl development should continue, and that land
use planning reform is a low priority for California. 

A higher target must be coupled with a commitment to provide
federal and state financial resources, technical assistance, and
other support to help regions, local governments, and
transportation agencies achieve the target.  

Thank you for considering these comments.