Comment Log Display

Mike Bullock 
mike_bullock@earthlink.net
1800 Bayberry Drive
Oceanside, CA 92054
July 21, 2010

Air Resources Board
1001 I Street
P.O. Box 2815
Sacramento, California 95814
SUBJECT: Comments on the Draft GHG Reductions, Pursuant to Senate
Bill 375
Dear Air Resources Board Chair Mary Nichols and Members of the
Board:
1.0	Introductory Comments
The time for debate has long since passed. The climate science is
clear; we need to achieve significant GHG reductions today if we
are to avert climate disaster in the future.
1.1	AB 32, SB 375, What Science Has Determined, and Current GHG
Levels
AB 32 requires California emissions, from all sources, to be at
1990 levels by 2020. The years after 2020 are covered by a
Governor’s executive order. It calls for emissions to be 80% below
1990 levels, by 2050. These reductions, world wide, would limit GHG
levels to 450 PPM. 
When AB 32 and the executive order were formulated, it was thought
that limiting GHG levels to 450 PPM would provide humanity adequate
safety from catastrophic climate destabilization. However, climate
science now tells us that any level above 350 PPM is dangerous.
Unfortunately, the current level is 390 PPM, higher than it has
been in over a million years.
SB 375 was written to give CARB authority over cars and light-duty
trucks, sometimes referred to as personal driving. This personal
driving is quantified as vehicle miles traveled, or VMTs. Personal
driving is responsible 32% of GHG in California. In San Diego
County, it is responsible for 41%. SB375 calls for CARB to give
each regional government in the state (Metropolitan Planning
Organization, or MPO) GHG reduction targets, for personal driving,
for the years 2020 and 2035.  SB375 requires that CARB give each
MPO their targets by September 30th of this year.
SB375 also calls for an interim “bottoms up” process to produce
CARB draft targets, at this time. That is the primary subject of
this public review process. CARB is to consider what the MPOs
modeled and submitted to CARB as “ambitious but achievable” targets
and then submit draft targets to the MPOs.
1.2	Scoping Plan Observations
AB 32 gives CARB the responsibility of allocating reductions to
the various sectors. In the “Scoping Plan”, adopted in December
2008, on page 17, CARB specified only 5 million tons per year as
the reduction from “Regional Transportation-Related GHG Targets” by
2020. 
The Plan added in a footnote, “This number represents an estimate
of what may be achieved from local land use changes. It is not the
SB 375 regional target. ARB will establish regional targets for
each MPO region following the input of the Regional Targets
Advisory Committee and a public consultation process with MPOs and
other stakeholders per SB 375.
We note that the 5 million tons identified in Table 2 is in
addition to the 31.7 million tons for Light-Duty Vehicle Greenhouse
Gas Standards, including the implement of Pavley I standards and
developing Pavley II standards, plus 15 million tons for the Low
Carbon Fuel Standard.
1.3	Danger in “Bottom Up” Process of Identifying Draft Targets
In modeling “achievable” reductions, MPOs are free to ignore both
the AB 32 legal requirements for reductions and the additional
reductions needed for public health and safety, in light of our
need to get GHG levels down to 350 PPM as soon as possible. Local
politicians on MPO Boards may push for “path-of-least-resistance”
strategies, hoping to sell these strategies to CARB as “aggressive
but achievable”. Since government’s primary responsibility, at all
levels, is public health and safety and since this responsibility
extends from the three branches of state government down to all
boards and agencies (most of which are extensions of the executive
branch), it follows that the final GHG reductions must be based on
what the climate scientists have determined is safe. Such
reductions will significantly exceed those required by AB 32. It is
certainly CARB’s responsibility to address this issue, even if it
is in some other proceeding. Ignoring this issue is demonstrably
criminally negligent, since it will lead to catastrophic climate
destabilization, resulting in a significant die off of the human
population.
1.3	Reducing GHG from Cars and Light-Duty Trucks
There are three things that will reduce GHG from driving. They are
“clean cars”, “clean fuels” and less driving. “Clean cars” includes
the benefits of more efficient gasoline and diesel powered cars,
hybrids, and battery electric vehicles (BEVs). Since some of our
cars will be BEVs, when CARB computes the overall average GHG per
mile of our state’s fleet of cars, it must account for how much of
our electricity is generated from fossil fuels. Most of our
electricity will come from fossil fuels for many years, perhaps
several decades. “Clean fuel” refers to fossil fuel formulated to
have more hydrogen and less carbon, to result in less GHG
emissions. “Clean fuel”, referred to as Low Carbon Fuel Standards
(LCFS), is expected to provide a 10% emission reduction by 2020,
but no more after that. This paper uses the LCFS factor of
nine-tenths for both 2020 and 2035, even though this may be
overestimating reductions in 2035 because the factor is
inappropriate for BEVs and the number of BEVs could become
significant by 2035.
For at least the next decade and perhaps much longer, less driving
will be needed to provide the largest reduction in GHG, relative to
current 2010 levels. However, relative to the SB 375 reference year
of 2005, the “clean car” reduction will provide the largest
decrease in GHG, for the target year of 2020.
These factors can be observed in Figure 1 of an analysis by S.
Winkleman,   based on CalTrans VMT forecast (red line), AB 1493
(“Pavley”, green line), and the Low Carbon Fuel Standard (LCFS,
purple line), compared with the AB 32 target of 1990 levels (light
blue line). This Figure has been placed into this document for
convenience. Note that the dark blue line, which combines all three
factors, shows how the projected increase in VMT overwhelms GHG
savings from cleaner fuels and vehicles. Decreasing VMT is the
objective of SB 375.
2.0	Evaluation of CARB Draft Targets for 2020 
The VMT reductions proposed by CARB for the MPOs, at this time,
are shown in the Table 1.
It is important to note the implications of the Table 1 asterisked
footnote and the fact that this target is per capita. It means that
the calculation of GHG reduction estimates from this number
requires the use of factors to account for population growth, the
Pavley reductions (“Pavley”), and LCFS reductions, as shown below.

 Note: to see this reports Tables and Figures, get the file I
emailed to Earl Withycombe yesterday. There are tables and one
important figure. Or email me with your request.

Table 1	Four Largest MPOs
Draft Greenhouse Gas Reduction Targets for 2020
(Percent Reduction in Per Capita Emissions Relative to 2005)*

MPO Regions 2020	Draft Targets
Metropolitan Transportation Commission (MTC)
Sacramento Area Council of Governments (SACOG)
San Diego Association of Governments (SANDAG)
Southern California Association of Governments (SCAG)	
5 - 10%
* Percent reduction numbers do not include emission reductions
expected from Pavley Greenhouse Gas Vehicle Standards and Low
Carbon Fuel Standard measures.
2.1	Adequacy, Compared to AB 32 Reductions
In order to estimate the 2020 outcome of the Table 1 reductions,
the calculation must compare the net effect of above per capita
reduction target, the increase in population, the Pavley reduction,
and the Low Carbon Fuel Standard; with the 2005 levels.  For the
calculation, the following factors apply:
1.	0.95, for the per capita reduction in driving (using the lower,
5% value, from Table 1);
2.	1.196, for the 19.6% projected increase in population (based on
California Dept. of Finance official projections) ;
3.	0.825, for the 82.5%, shown for 2020, on the green “Pavley”
line of Figure 1;
4.	0.90, for the reduction in low-carbon fuel standard (LCFS), as
shown on the purple line of Figure 1.
Multiplying these four factors together results in a factor of
(.95)*(1.196)*(.825)*(.90) = 0.85.
This is a 15% reduction and so it barely passes the reduction that
would be in line with AB 32, which is around 13%, as shown in the
1990 light-blue line on Figure 1, which is also the first yellow
“X” on Figure 1.
Similarly, the 10% value results in factors of
(.9)*(.825)*(.90)*(1.196) = .81. This is a 19% reduction and so it
passes the reduction that would be in line with AB 32, which 13%,
again, as shown in the 1990 light-blue line on Figure 1, which is
also the first yellow “X” on Figure 1.
2.2	Need for “Pavley” and LCFS to Meet AB 32 Reductions
What is needed is a complete picture of what the various factors
are providing and whether or not both “Pavley” and the LCFS are
needed to get the reductions within the AB 32 level. Therefore
Tables 2 through 7 have been computed and appear here.
Table 2	Factors Used to Estimate 2020 GHG Reduction from 2005, 
	With a 5% Driving Reduction, from 2005
 

Table 3	Results of Combining Factors to Estimate 2020 GHG
	Reductions, With a 5% Driving Reduction from 2005
 

Table 4	Percent Reductions from Combining Factors to Estimate
2020
	GHG Reductions, With a 5% Driving Reduction from 2005
 

Table 5	Factors Used to Estimate 2020 GHG Reduction from 2005,
	With a 10% Driving Reduction, from 2005
 

Table 6	Results of Combining Factors to Estimate 2020 GHG
	Reductions, With a 10% Driving Reduction from 2005
 

Table 7	Percent Reductions from Combining Factors to Estimate
2020
	GHG Reductions, With a 10% Driving Reduction from 2005
 
It is therefore shown that both “Pavley” and the LCFS are needed
to meet the AB 32 standards by 2020. This is true for both the -5%
and the -10% reductions in VMT.
2.3	Conclusions Regarding 2020 Reductions, AB 32, & Reductions for
Safety
For the 5% reduction, the following conclusions can be drawn. Both
“Pavley” and the LCFS are needed to meet the AB 32 reduction.
Assuming that both “Pavley” and the LCFS stay on track out to the
year of 2020; there is still only a 2.6% margin, with respect to
the AB 32 reductions. Since AB 32 is inadequate for the
industrialized countries, when compared to the world-wide
reductions needed to protect humanity from a catastrophic climate
destabilization, the proposed reduction of 5% should probably be
viewed as morally indefensible.
For the 10% reduction, the following conclusions can be drawn.
Both “Pavley” and the LCFS are still needed to meet the AB 32
reduction. Assuming that both “Pavley” and the LCFS stay on track
out to the year of 2020; there is a 7.1% margin, with respect to
the AB 32 reduction. Since AB 32 is inadequate for the
industrialized countries, when compared to the world-wide
reductions needed to protect humanity from a catastrophic climate
destabilization, the proposed reduction of 10% might still be
morally indefensible.
3.0	Evaluation of CARB Draft Targets for 2035 
Only the largest value shown, -19%, will be considered, for
reasons that will become obvious, if it is not already obvious to
the reader. Table 14 shows the proposed targets for the four
largest MPOs in California.

Table 14	Four Largest MPOs
Placeholder Greenhouse Gas Reduction Targets for 2035
(Percent Reduction in Per Capita Emissions Relative to 2005)*


MPO Regions	2035
Placeholder
Targets
Metropolitan Transportation Commission (MTC)	3-12%
Sacramento Area Council of Governments (SACOG)	13-17%
San Diego Association of Governments (SANDAG)	5-19%
Southern California Association of Governments (SCAG)	3-12%

* Percent reduction numbers do not include emission reductions
expected from Pavley Greenhouse Gas Vehicle Standards and Low
Carbon Fuel Standard measures.

For 2035 it is necessary to extrapolate the Governor’s Executive
Order target, which is Figure 1’s yellow line, out to year 2035. It
is 0.87 in 2020 and it is 0.64 in 2030. Therefore, in year 2035, it
will be
0.64 + [(.64 - .87)/(2030-2020)] * (2035-2030) = 0.525
Likewise, for 2035 it is necessary to extrapolate “Pavley”, the
green line, out to year 2035. It is 0.82 in 2020 and it is 0.73 in
2030. Therefore, in year 2035 it will be 
0.73 + [(.73 - .82)/(2030-2020)] * (2035-2030) = 0.685
For the calculation, the following factors apply:
1.	0.81, for the per capita reduction in driving, using the 19%
reduction from Table 14;
2.	1.402, for the 40.2% projected increase in population (based on
California Dept. of Finance official projections) ;
3.	0.685, from the above-computed extrapolation of the green
“Pavley” line of Figure 1;
4.	0.90, for the reduction in low-carbon fuel standard (LCFS), as
shown on the purple line of Figure 1.
Multiplying these four factors together results in a factor of
(.81)*(1.402)*(.685)*(.90) = 0.700.
This is a 30.0% reduction, which is not even close to the required
AB 32 reduction value of 47.5%, from the above-computed
extrapolation of the Governor’s Executive Order target fraction of
.525.
This is a significant failure and indicates that neither the MPOs
nor CARB are taking their climate crisis responsibilities
seriously. It should be noted that although there is a chance that
the Pavley reduction slope could be increased by a “Pavley 2”
slope, it is also true that a poor economy and/or pure political
“push back” could result in the current Pavley reduction slope
becoming unobtainable sometime before 2035, such that the projected
Pavley reduction factor of .685 would not be obtained. The
forecasted “Pavley” reduction target depends on a certain level of
fleet turnover, which has recently slowed down because of the
recession.  Thus we may not be able to depend on “Pavley”.
Tables 15, 16, and 17 provide a complete picture of what the
various factors are and how they fail to achieve the AB 32
reductions.
Table 15	Factors Used to Estimate 2035 GHG Reduction from 2005,
	With a 19% Driving Reduction, from 2005
 


Table 16	Results of Combining Factors to Estimate 2035 GHG
	Reductions, With a 19% Driving Reduction from 2005
 

Table 17	Percent Reductions from Combining Factors to Estimate
2035
	GHG Reductions, With a 19% Driving Reduction from 2005
 

4.0	What 2035 Reduction Will Meet “AB 32” (Governor’s Executive
Order) Reductions 
The EXCEL spreadsheets that produced Tables 15, 16, and 17 were
copied onto another sheet and then the VMT Per Capita Reduction
value was increased by an integer amount until the net 2035 result
was within the AB 32 target value. The result was -40 percent. The
effect of the various factors is shown in Tables 18, 19, and 20.
Table 18	Factors Used to Estimate 2035 GHG Reduction from 2005,
	With a 40% Driving Reduction, from 2005
 
5.0	A Correct and Reasonable, Science-Driven “AB 32” Reduction 
The Section 4 result of a 40% per-capita VMT reduction, required
to meet the AB 32 target for year 2035, is a reasonable starting
point. Given the uncertainty of the Pavley reduction by 2035 and
the fact that climate scientists have shown that we need large
reductions soon and need to be essentially off fossil fuels by
2050, a more reasonable reduction value for 2035 is a 50%
reduction.
Results from this assertion are shown in Tables 21, 22, and 23.

Table 19	Results of Combining Factors to Estimate 2035 GHG
	Reductions, With a 40% Driving Reduction from 2005
 

Table 20	Percent Reductions from Combining Factors to Estimate
2035
	GHG Reductions, With a 40% Driving Reduction from 2005
 

Table 21	Factors Used to Estimate 2035 GHG Reduction from 2005,
	With a 50% Driving Reduction, from 2005
 

Table 22	Results of Combining Factors to Estimate 2035 GHG
	Reductions, With a 50% Driving Reduction from 2005
 

Table 23	Percent Reductions from Combining Factors to Estimate
2035
	GHG Reductions, With a 50% Driving Reduction from 2005
 
The percent margin below the AB 32 target is 9.3% (56.8-47.5).
This corresponds to being nearly off carbon fuels by 2050, which is
needed.
6.0	SCS Strategies that Can Do the Job
The MPO calculations and their implied requests, for no more than
a 10% reduction in per capita driving by 2020 and no more than 19%
by 2035, indicates that the MPOs are not seriously considering the
root causes of the car-oriented California lifestyle that are
caused by widespread government policies. SANDAG has never allowed
such an in-depth process, let alone authorized it. 
The exception is zoning to reduce sprawl. Incremental improvements
in zoning, referred to as support for “smart growth”, are taking
place. Over time and to the extent the economy supports growth,
this will yield driving reductions. However, fundamental changes in
parking policy and road-use pricing, which are both related to the
issue of congestion and freeway expansion, are never discussed in
any depth. This oversight is reducing our chances of getting the
strategies that will bring down rates of driving on the scale that
is needed, for California to fully live up to its global warming
responsibility and in a way that is equitable to all.
6.1	Road Use Fee Pricing Systems 
A San Diego County newspaper, the North County Times (NCT), in a
February 9, 2009 article, reported that the Chair of the California
Transportation Commission (CTC) wrote that the gas tax currently
contributes nothing to road construction and only provides half of
the money needed annually for repairs: 
http://www.nctimes.com/articles/2009/02/09/news/columnists/downey/z8591536f3e7332da882575510076fa1e.txt.
A Canadian company, Skymeter, is designing and installing a
variable and comprehensive road-use fee pricing system, in the
Netherlands by 2014 and in Denmark by 2016. The charge per mile
will vary by such things as model of car, road, time of day, and
congestion level. In 2005, the gas tax in the Netherlands was
equivalent to $3.50 per gallon. However, with the advent of the new
system, the Netherlands will eliminate the gas tax. Nevertheless,
the Netherlands estimates that the GHG from driving will drop by
10%. Note that such a system could easily charge a price of zero
cents per mile for a low-income driver. Our current system of a gas
tax has no such capability. Skymeter will program the
navigational-unit-like box so that no travel information is stored,
to protect driver privacy.
On July 11th 2009, the California Nevada Regional Conservation
Committee (CNRCC) of the Sierra Club California passed a resolution
supporting a “Comprehensive Road Use Fee Pricing System”. This
paper can be provided upon request.
The CNRCC resolution is supported by a 10-Page “Reference
Document” that outlines the principles and conditions of a road-use
fee pricing system that would conform to Sierra Club values. It has
an example of a road-use fee structure that supports the listed
principles. Useful background information is also provided.
On November 14th, the Environmental Caucus of the California
Democratic Party (CDP) passed a 1-page resolution in support of a
“Comprehensive Road-Use Fee Pricing System”. This one-page
resolution contains the following words.
THEREFORE, BE IT RESOLVED, that the California Democratic Party*
supports a state-funded study of a design of a road-use fee pricing
system that (1) would pay for all road-use costs including the
environmental and health costs caused by driving, (2) could still
include a fuel tax or fee, (3) would mitigate impacts on low-income
users and protect privacy, (4) would include congestion pricing
when that technology becomes feasible, (5) would keep the per-mile
price incentive to drive energy-efficient cars at least as large as
it is with today’s fuel excise tax, and (6) could be accompanied by
tax reductions sized to achieve either net-revenue neutrality or
near-net-revenue neutrality.
*Not true because the resolution failed in the CDP Resolution
Committee
The Nevada Department of Transportation is taking comments on a
proposal for a VMT fee to replace their gas tax, as shown at
http://www.vmtfeenv.com/.
The 2010 Platform of the California Democratic Party (at
http://www.cadem.org/atf/cf/%7BBF9D7366-E5A7-41C3-8E3F-E06FB835FCCE%7D/Platform2010CDP_FINAL_June.pdf),
inspired in part by the 1-page resolution identified above,
contains that following bullet:
•	Work for equitable and environmentally sound road and parking
use
Using sales taxes, property taxes, income taxes, and other general
taxes pay for services that make it artificially cheap to drive is
unjust to citizens that drive less than average. There is no reason
why government should adopt policies that increase driving and
economically discriminate against those that telecommute, walk,
bike, car pool, or use transit; the unconstitutionality of the
current system is plain to see.
Considering all of this information, CARB has a responsibility to
notify the Governor and our legislative leaders that our state has
good reasons to implement a comprehensive and variable road-use fee
pricing system. There is probably no reason to reinvent the wheel.
The Skymeter system would work fine here in California. The Sierra
Club California analysis can be considered to ensure an
implementation that is both equitable to all and environmentally
sound.
6.2	Unbundling the Cost of Car Parking 
For the vast majority of destinations in California, the cost of
car parking is hidden within other costs. This has serious
consequences. For example, at most places of employment, parking
costs reduce the wages that can be paid to all the employees, even
those that never use the parking. Similarly, at many apartment
complexes, bundled parking costs increase the rent and this is
true, even for families that do not own a car. Bundled parking
costs routinely increase the costs of goods, such as groceries, for
all customers. Again, this is even true for those that do not
drive. Since governments require businesses to provide minimum
levels of parking, they are involved in this economic
discrimination towards those that drive less. 
Driving less is, to some degree, a lifestyle choice. Since
government has no valid reason to encourage driving, the lifestyle
choice of less driving deserves constitutional, or at least legal,
protection from any practices that discriminate against it,
economically. So far, this agency (CARB) has not taken an active
role in pushing vmt and parking pricing.
 On June 22nd (2010), I presented a paper on how parking could be
operated to unbundle parking costs in a way that supports the
sharing of parking. This was at the 101st Conference and Exhibit of
the Air and Waste Management Association, in Calgary, Canada. The
session, Sustainable Land Use and Transportation, included my
paper, A Plan to Efficiently and Conveniently Unbundle Car Parking
Costs, which was well received.
My paper is therefore both peer reviewed and published. I would be
pleased to present this paper to the staff of CARB, in the hopes
that CARB could bring about equitable and environmentally-sound
parking policies to California.
The following points, taken from the paper, apply.
•	Vehicle miles traveled (VMT) are a major cause of global warming
and pollution.
•	California’s Metropolitan Planning Organizations (MPOs) will
need to adopt strategies that reduce vehicle miles traveled (VMT),
in order to meet SB375 GHG reduction targets, to be issued by the
California Air Resources Board in late 2010, for years 2020 and
2035.
•	The appropriate pricing of parking is one of the least costly
tools documented to reduce VMT.
•	New technologies, such as sensors feeding computer-generated
billing, offer the potential to efficiently bill drivers for
parking and alert law enforcement of trespassers.
•	Reformed parking policies can increase fairness, so that, for
example, people who use transit or walk do not have to pay higher
prices or suffer reduced wages, due to parking.
•	Methods to unbundle parking cost are inefficient unless they
support the spontaneous sharing of parking spaces. Shared parking
with unbundled cost would ultimately allow cities to require
significantly less parking.
•	Typical systems of timed parking and metered parking are far
from ideal. Parking has no automated record keeping, so it is
difficult to know where there is too much or too little. 
•	Good policies will eventually let cities turn parking minimums
into parking maximums.
Less land and resources devoted to parking will support mixed use
and make “smart growth” more economically viable. It should
therefore be a key ingredient supporting the MPO’s stated desire to
foster “smart” growth, where “smart” should be defined as “less
VMT”.
 Here is a copy of the abstract of the paper.
The Introduction shows documented driving reductions due to the
pricing of parking. It notes that although the benefits of priced
and shared parking are known, such parking has not been widely
implemented, due to various concerns. It states that a solution,
called “Intelligent Parking,” will overcome some of these concerns,
because it is easy to use and naturally transparent. It asserts
that this description will support a “Request for Proposal” (RFP)
process. Eight background information items are provided, including
how priced parking would help California achieve greenhouse gas
reduction targets. A story demonstrates some of the key features of
Intelligent Parking. Arguments for less parking, shared parking,
and priced parking are made. Barriers to progress are identified.
The fair pricing of parking is described.  New ways to characterize
transportation demand management are presented. Seven goals of
Intelligent Parking are listed. Eleven definitions and concepts,
that together define Intelligent Parking, are described. This
includes a method to compute a baseline price of parking and how to
adjust that price instantaneously to keep the vacancy above 15%
(“Congestion Pricing”). An implementation strategy is described.
This abstract aroused enough interest among those responsible for
A&WMA’s Sustainable Land Use and Parking session that they
requested that I submit a manuscript, which was ultimately selected
to become part of the written Conference Proceedings and for
presentation. I hope that it will similarly arouse the interest in
the CARB Board and staff. CARB needs to consider working to execute
the implementation strategy described in A Plan to Efficiently and
Conveniently Unbundle Car Parking Costs. I would be honored to help
in any way possible.
6.3	SANDAG Board’s Failures Regarding Climate Change 
SANDAG’s 2007 RTP, “RTP2030”, called for increasing the number of
freeway lanes by 38%. This would be in a region that already had
one of the highest VMT-per-capita metrics in the state. SANDAG also
supported a sales tax measure, “TRANSNET”, that was advertised as
one that would spend two-thirds of its money on roads and one-third
on transit. However, after it was passed, SANDAG defined all HOV
lanes to be “transit”, thereby significantly reducing the fraction
of money spent on true transit.
 Out of a $57 billion dollar budget for RTP2030, SANDAG budgeted
about 1% for mitigation. This mitigation is split evenly between
“smart growth” incentive money and a Regional Bicycle Plan. They
have published a Smart Growth Incentive Plan, a Smart Growth Design
Guideline, as well as the Regional Bicycle Plan. SANDAG has an
excellent staff. However, the Board does not provide helpful
direction. One obvious direction needed was to adopt a metric of
reducing VMT to decide what “smart growth” should get funding, what
“smart growth” design guidelines should be adopted, and what
bicycle programs should be funded. They were asked repeatedly to
put citizen comments, directed toward the early drafts of these
documents, on line, to be viewed by all. Not doing this made it
easy for the staff to ignore significant public comment and to
instead follow the direction provided by the Board, which seemed to
think that bike money should go mostly for trails and smart-growth
money should go toward beautification projects in areas deemed
suitable for smart growth. If less driving were used as a criteria
for spending money, then funding the League of American Bicyclist’s
class on how to ride a bike in traffic and the development of
equitable and environmentally sound parking policy (good enough to
be politically acceptable), would have been a large part of the
spending. Instead, bicycle education and car-parking policies were
marginalized to the point of being essentially unfunded.
6.4	Putting a Stop to Freeway Expansion
One of the most powerful strategies to reduce GHG would be to stop
expanding freeways. Instead of costing money, it would generate
money. It is well understood that the metric of freeway-lane miles
per square mile of developed land increases an area’s average
car-trip length and thereby increases VMTs. SANDAG is ignoring this
fact and this is probably one of the primary reasons that its 2035
GHG Reduction Target is unacceptably small. When the SANDAG
TRANSNET tax was passed, few voters understood that we were
threatened with a climate catastrophe and that our responsibility
was to drive significantly less. Given our current understanding,
SANDAG has a responsibility to go back to voters with a ballot
measure that reconfigures TRANSNET to be 100% for transit,
bicycles, and pedestrians.
The current freeway-widening project being considered is to widen
I-5 from 8 to either 12 or 14 lanes, from La Jolla to Camp
Pendleton, at a cost of over $4 billion dollars. The DEIR was
released in early July. Caltrans is holding public meetings, where
no member of the public is allowed to speak publicly. It sent
postcard notifications to those living along the route. However,
instead of honestly notifying the recipients of the radical,
land-consuming nature of the proposal, these postcards only refer
to a “managed lane project”. Who would be worried about some plan
to manage lanes? Nowhere on the postcard is there any information
suggesting a wider freeway, a taking of land, a reducing of
property-tax rolls, an increase in noise, an increase in driving,
an increase in air pollution, an increase in GHG or even that there
is any kind of construction project being proposed.
7.0	Conclusions
Targets will have to be more stringent than AB 32 targets if we
are going to fulfill our world leadership responsibility, as
required, to give the world a chance at avoiding climate
destabilization. The 2020 Target of -10% (per-capita from VMT) can
only result in an SB-375 AB 32 reduction if both “Pavley” and the
LCFS factors are used. The 2035 reduction target of -19% would have
to instead be 40% to just meet the AB 32 reductions, and this is
assuming the Pavley reductions continue on the “Pavley 1”
trajectory all the way to 2035. This assumption about “Pavley” may
be overly optimistic. The science-supported 2035 reduction is 50%.

The best, largely overlooked strategies to reduce VMT are a
comprehensive and variable road use fee pricing system, as is being
installed by Skymeter; unbundling the cost of car parking; and
putting a stop to all freeway expansions. I would like to discuss
further a state-wide strategy to unbundle the cost of car parking.
Sincerely yours,
 
Mike Bullock
mike_bullock@earthlink.net
760-754-8025
1800 Bayberry Drive
Oceanside, CA 92054