Comment Log Display

The San Francisco Bike Coalition (SFBC) applauds the significant
work that CARB has accomplished in preparing the draft Scoping
Plan.  We appreciate the opportunity to provide comments to this
watershed document.

SFBC enthusiastically supports the overall effort and goals of
this process.  We have paid particular attention to the
recommendations made in the Transportation and Local Government
Actions sections of the Scoping Plan.  In addition, we strongly
support all of the “Other Measures Under Evaluation” for the
transportation sector:  feebates, congestion pricing, pay as you
drive insurance, indirect source rules for new development, and
public education and programs to reduce vehicle travel (p.37-38). 
These measures are essential to meet the aggressive statewide
emission reduction requirements.  While we applaud the inclusion
of these measures, we believe the current emission reduction
estimates are extremely conservative (Table 22, p.40).  We believe
creating a marketplace that values greenhouse gas emissions will
strongly affect consumer behavior and purchases significantly
different than business as usual.  

Using these “other” measures, we see significant potential to
further reduce vehicle miles traveled (VMT) and to integrate land
use and transportation planning (smart growth) to enable and
bolster no- and low-emission transportation options.  We believe
that these two concepts need to be considered together in order to
achieve the greatest possible statewide emissions savings.

We agree that we CARB’s assessment that

“… additional reductions can be achieved by making the connection
between transportation and land use. This scenario reflects an
increased emphasis on urban infill development: more mixed use
communities, improved mobility options, and better designed
suburban environments." (ARB Scoping Plan, p.33)

SFBC recognizes, as does CARB, that many of these planning
decisions are made at the local and regional levels.  However, we
think it is essential that the state demonstrate leadership now in
setting standards for transportation requirements associated with
development (new or infill) and not wait until the next cycle of
planning.  Our experience indicates that people will walk, bike,
and use public transportation in their communities if the options
are available and safe.  But these options require infrastructure
to be developed with these transportation goals at the forefront
rather than taking a distant backseat to automobile
infrastructure.

SFBC works with local and regional entities to advocate for
bicycling as an everyday mode of transportation.  Through this
work, we have seen the number of bicyclists increase substantially
in San Francisco.  Public education, safety and maintenance
classes, continued advocacy, and infrastructure improvement are
all critical elements of increasing the usage of no- and
low-emitting transportation options.  Infrastructure improvements
include development of transportation corridors with bike lanes,
sidewalks, greening of streets, appropriate lighting, vehicle
speed limit reductions, and generally developing streets to be
used by people rather than just automobiles.

In order to truly address the issue of reducing Vehicle Miles
Traveled (VMT), alternatives need to be readily available and
supported.  Further land use and development (new or infill) needs
to support no- or low-emitting transportation options.  California
cannot continue to grow and develop as it has and reach the goals
required by AB32.  While some of this work can be accomplished at
the local and regional level, the state must play an important
role.  Similar to the energy efficiency requirements the state
place on appliance manufacturers and the building trades, we need
to have standards for transportation infrastructure, and indirect
transportation emissions associated with land development (new and
infill).  We encourage action to be taken at the statewide level. 


We strongly support CARB’s efforts to ensure that the California
Environmental Quality Act (CEQA) compliance requirements are
adequate to uphold the intent of the law. We also support
directing of some portion of potential revenues generated from the
emission reduction measures to local governments:

Incentives to local governments – Funding or other incentives to
local governments for well-designed land-use planning and
infrastructure projects can do much to discourage long commutes
and encourage walking, bicycling and use of transit. (p.47-48)

CARB correctly recognizes that measures like Congestion Charging,
PAYD, and indirect source fees have a positive economic benefit
and reduce greenhouse gas emissions.  State government action is
essential for at least most of these measures (congestion charging
and pay-as-you-drive insurance, for instance), and these measures
should be added to the proposed measures rather than included with
those "under consideration".  They will encourage bicycling,
walking, and transit use.  

To further facilitate this transition, CARB should auction 100% of
all greenhouse gas emission allowances under a cap & trade system,
or impose a carbon fee.  For every $1 price per ton (through
either allowance sales or a carbon fee), there will be almost $4
billions dollars in revenue over the 2012-2020 timeframe.  
Funding for transitioning to a cleaner and more efficient future
is the most important priority for use of this revenue. For the
transportation sector share of those resources, priorities should
include bicycle, pedestrian, and transit improvements in addition
to targeting vehicle tailpipe emissions.


We appreciate the opportunity to comment on the Scoping Plan.  We
hope to provide further input into this important process.