Comment Log Display

Below are comments from the City of Oakland specific to the Local
Government section of the Draft Scoping Plan. These comments were
also included in the City of Oakland's letter submitted to the
General Comments section of this website.

1. Indirect Source Rules for New Development are Needed
Page 38
We strongly encourage ARB to impose regional indirect source rules
for new residential and commercial development to help foster new
development throughout the state with relatively low embodied
emissions impacts. As we continue to grow as a state, we must
create and commit to development patterns that minimize future GHG
emissions by maximizing use of existing transit and services
infrastructure. 

2. More Emphasis Needed on Land Use & Transportation Demand
While recommended measures associated with improving vehicle fuel
efficiency and reducing the carbon intensity of transportation
fuels are admirable, more emphasis should be placed in the Plan on
fostering reductions in vehicle miles traveled. The State should
seek to actively work with local governments to foster low-carbon
development, and incorporate additional mechanisms into the Plan
to reward development concentrated around existing transit and
service infrastructure. Targets associated with regional and local
land use and transportation could be increased significantly if ARB
is willing to invest sufficient resources in assisting local and
regional agencies with accomplishing better planning and
implementing the transportation and related infrastructure
necessary to enable low-carbon development.

Additionally, waste reduction strategies (referenced in comment #
2 above) such as reducing and reusing materials, and repairing,
refurbishing, and rehabilitating existing products and buildings
to retain their form and function can reduce emissions from
transportation of input feedstocks and finished goods.

3. Distinguish Between Local Government and Regional Land Use
Targets
The Plan should more clearly distinguish between proposed
emissions reduction targets associated with regional land use and
transportation planning and those associated with action by
individual local governments.

4. Clarify Role of and Empower Regional Planning Efforts
The Plan encourages more regional planning involving local
governments to help reduce transportation emissions, and suggests
that “ARB, along with other State agencies, will work with
regional and local governments to develop targets to reduce
greenhouse gas emissions on a regional basis.” The Plan should
offer more detail on how these regional collaborative planning
processes would be convened. The State should provide resources to
enable all parties to engage substantively in these planning
efforts. The State should also empower local governments with a
suite of additional policy tools to foster low-carbon development
in their communities, enabling regional partners to select the
best tools for achieving their low-carbon goals.

5. Encourage Public Transit and Other Transportation Alternatives
The Plan should specifically target increasing implementation of
transit-oriented development, public transit infrastructure, and
use of federal transportation dollars for lowest carbon means of
achieving given transportation goals. Significant investment in
enabling public transit infrastructure will be needed to achieve
our long term GHG emissions reduction goals.

6. Apply Aggressive Standards for Low Carbon Development
While emissions reduction targets might vary by region for total
regional GHG emissions, aggressive statewide targets for emissions
associated with new development should be adopted. The State should
support urban infill development and relatively reward low-carbon
development on a statewide basis through a mix of policy tools and
incentives.

7. Reward Local Actions That Don’t Qualify as Offsets
Page 44
ARB should consider opportunities to encourage and reward local
governments for proactive policy and programmatic actions that
further reduce GHG emissions either locally or globally, but may
not be eligible as saleable offsets under traditional offset
crediting definitions. For example, local governments should be
rewarded for land use plans and development projects that meet
stringent low-carbon criteria (e.g., a metric calculated based on
proximity to transit and services), adopting local building energy
codes requiring increased levels of energy efficiency, and
implementing local waste collection and management programs that
increase waste diversion beyond state targets, reducing landfill
methane and upstream energy use. 

8. Promote Suite of Available Local Government Assistance
Page 31
Local governments should be directed to the wide range of
assistance available to help local governments foster reductions
in GHG emissions. The phrase “such as those developed by the
Institute for Local Government’s California Climate Action
Network” should be replaced with “such as those featured at
” where this ARB web link refers to a list of
resources including but not limited to the Institute’s information.
Resources provided by ICLEI, the Local Government Commission, US
EPA and others are equally valuable to local governments.

9. Acknowledge Leadership of Local Governments
Page 1
A number of local governments in California (including the City of
Oakland) made significant progress during the 1990’s in assessing
GHG emissions in their communities, developing emissions reduction
plans and taking a variety of actions to reduce emissions. The
leadership of these local governments should be acknowledged in
the Plan.