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Comment 3 for State Government Comments for the GHG Scoping Plan (sp-stategov-ws) - 1st Workshop.


First Name: Steven
Last Name: Goetz
Email Address: sgoet@cd.cccounty.us
Affiliation: Contra Costa County

Subject: State Government
Comment:
A key element of the Scoping Plan is implementation of existing
State laws and policies.  This element needs to go beyond clean
car standards, goods movement measures, and the Low Carbon Fuel
Standard. 

Appendix C refers to a strategy for locating State facilities
based on the State’s planning priorities as embodied in Chapter
1016 - Statues of 2002.  Construction of prisons, court
facilities, colleges, universities, water storage and conveyance
facilities, state office buildings, elementary and secondary
schools as approved by the State Architect, all have significant
influence on the land use policies, development pressures and
travel behavior at the local level.  This law requires each
Governor’s Budget to include a 5-year infrastructure plan.  The
Governor is also required to prepare and maintain the State
Environmental Goals and Policy Report (EGPR).  State agencies are
to show how their project in the infrastructure plan are
consistent with the EGPR.

The public outreach and educational component of the Scoping Plan
needs to make these documents more visible so the public can
understand the sound environmental planning behind the capital
facilities supported by each State budget.  Has a greenhouse
emission reduction goal been included in the EGPR?  Is the State
measuring and tracking compliance with this statute?  Has
preparation and maintenance of these documents been acknowledged
in applicable State administrative manuals?  Should development of
the EGPR and the infrastructure plan be coordinated with the
activities of the Governor’s Strategic Growth Council? Can a copy
of the most recent infrastructure plan and EGPR be made available
for review by the public and local jurisdictions and other
interested stakeholders?

Future GHG reduction efforts for State facilities should be
expanded to include a review of the management of parking spaces
owned or leased by the State.  The Contra Costa County Climate
Action Team is evaluating the feasibility of establishing a user
fee for parking spaces owned or leased by the County and
allocating any surplus revenue to incentives for use of commute
alternatives.  User fees would eliminate any subsidy that may
exist for motorists who do not pay for the cost of the parking
they use.  Any revenue in excess of the cost to provide the
parking could be used to provide improvements to transit service
or made available to employees to help pay for their commuting
costs.  There is a substantial body of studies that shows parking
charges can significantly influence commuter behavior.  This
strategy should be coordinated with potential future efforts
listed under “employee practices” on page C-178, and other
relevant state regulations such as Executive Order D-73-8 which
requires State agencies to implement a transportation management
program designed to result in an annual reduction in the number of
commute trips by State employees.

The description of proposed measures to address “the State’s
Carbon Shadow”, which begins on page C-179 needs more detail in
the following areas:
•	The State’s standards for the design of school and medical
facilities currently emphasize requirements for buildings and
support facilities.  Equal emphasis is needed on requirements for
site selection and the siting of these facilities in the community
to ensure convenient access by transit, walking or bicycling.  The
criteria used by the State for awarding funding for facility
construction should place greater weighting of facility siting in
the community and transportation criteria.  Some of these
recommendations were in the report submitted by the Land Use
Subgroup of the Climate Action Team (LUSCAT) but do not appear in
the Scoping Plan.
•	The standards adopted by the State Fire Marshall need to be
evaluated for their impact on GHG emissions and community design. 
The current requirements for fire access roads are based on
operation of a standard multi-purpose fire/paramedic vehicle. 
These standards should encourage flexibility to allow the use of
smaller vehicles that are compatible with more pedestrian-oriented
street construction.
•	The Air Resources Board (ARB) needs to improve its
administration of the parking cashout program, Chapter 554 -
Statutes of 1992. This law requires certain employers who provide
subsidized parking for their employees to offer a cash allowance
in lieu of a parking space.  Parking cashout offers the
opportunity to reduce GHG emissions by reducing commute trips. The
ARB is the agency authorized by the Legislature to interpret and
administer the parking cash-out law.  Their administrative efforts
have been limited to preparation of an informational guide to help
employers determine whether they are subject to the requirements
of the law.  This “self-implementing” approach by the ARB has
resulted in few employers offering a parking cash-out program to
their employees.  As the appropriate regulatory authority the ARB
should, in consultation with affected stakeholders, revise its
administrative efforts to increase participation among employers
and advise cities and counties on conditions they can impose on
new development to expand the application of this statute on
employers (e.g. require project sponsors to prepare CC&Rs for the
project to ensure parking and building leases are unbundled and
that financial compensation to affected occupants is provided as
required by applicable state law) 

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2008-08-01 16:34:35



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