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Comment 16 for Transportation Comments for the GHG Scoping Plan (sp-transport-ws) - 1st Workshop.


First Name: Walt
Last Name: Seifert
Email Address: saba@sacbike.org
Affiliation: Sacramento Area Bicycle Advocates

Subject: AB 32 Draft Scoping Plan Comments
Comment:
Thanks for the opportunity to make comments.

Section II.  Preliminary recommendation
We strongly urge a adding a recommendation to reduce Vehicle Miles
Traveled (VMT).  We believe it is astonishing such a recommendation
is not included since the direct and ancillary benefits are so
high.  The potential for reduction of GHG emissions from the
transportation sector is great since nearly 40 percent of GHG
emissions come from transportation.  It is the sector responsible
for the biggest share of GHG emissions.  Yet out of the current
469 MMT of CO2 equivalent emissions and the proposed reductions of
169 MMT, only a miniscule amount of reductions (2 MMT) is slated
for the “Local Government Action” measures.  Those 2 MMT are shown
under “local government action” where the community transportation
and community design topics are buried.  

Shifting trips from automobiles to transit, walking and bicycling
offers enormous opportunities to reduce GHG emissions.  California
and the rest of the U.S. currently have a small share of all trips
made by these modes.  Yet in most of the world, including
developed countries in Europe and Asia, the mode shares for
transit, walking and bicycling are competitive with automobile
use.  Higher mode shares for transit, biking and walking are
clearly achievable in California on a very cost-effective basis.

“Funding bicycle facilities and programs can be a cost-effective
means of reducing motor vehicle emissions.”  That’s what the Air
Resources Board Bicycle Fact sheet says. 
(http://www.arb.ca.gov/planning/tsaq/bicycle/factsht.htm)  The
same is certainly true for reducing GHG emissions.

There are also very substantial co-benefits from reducing VMT and
increasing transit and human powered transportation mode shares. 
The benefits include a reduction in traffic congestion, improved
public health, reduced road maintenance and construction costs,
energy savings and environmental benefits.  

The health benefits don’t derive merely from air quality
improvements.  There are benefits from reduced traffic collisions.
 Fewer collisions reduce traffic fatalities, injuries and property
damages.  These costs are estimated to be more than $164B annually
for the U.S.  (AAA Crashes vs. Congestion:  What’s Cost to Society)
 

There are also costs, estimated by the California Department of
Health Services (DHS) to be $21.7 billion annually, associated
with obesity and overweight.  Obesity is linked to diabetes.  Both
these conditions are considered to be epidemics by health care
professionals.  (See the April 2005 study done for DHS, The
Economic Costs Of Physical Inactivity, Obesity, And Overweight In
California Adults: Health Care, Workers’ Compensation, and Lost
Productivity)

Higher levels of physical activity, especially physical activity
integrated with everyday activities such as walking and bicycling
for transportation, are essential to reducing the incidence of
obesity, overweight and diabetes.

Increased physical activity from human powered transportation also
reduces the risks of many other diseases including cardiovascular
disease (heart disease and stroke), some forms of cancer,
Alzheimer’s and more.  Increased physical activity extends life
spans and improves quality of life.    (Editorial, British Medical
Journal, January 2008) 

The environmental benefits of VMT reductions, in addition to the
air quality benefits to human health, include reduction in crop
damage from air pollution, improved water quality (reduction in
oil, brake asbestos dust, etc. in stormwater) and noise reduction.
 Reduction in suburban growth would preserve crop land and green
space and reduce long term energy use.

Section II.A.  State as example.
This section mentions alternative commute options, but does not
specifically address bicycling.  Because of the number of its
facilities and employees, the state can do a great deal to make it
easier to bike commute by providing showers, clothing lockers and
bicycle parking.  The CalEPA headquarters building offers a prime
example of what can be done.  Caltrans is in the process of
creating standards for bike facilities at its offices.  See
http://www.sacbike.org/advocacy/state_bicycle_facilities/ for more
information and the rationale for bicycle facility legislation that
was considered in 2007.  Bicycle facilities could be provided at
new and remodeled state office buildings on an administrative
basis without the need for legislation,

Section II B.  Emission Reduction Measures
The potential for reducing GHG through VMT reduction, and
specifically VMT reduction through an increase in bicycling and
walking, far outweighs the size of a potential reduction from some
other proposed measures, such as from high speed rail.  Increasing
rates bicycling and walking clearly merits it own section in the
list of measures.  There are a wide variety of ways to achieve
increased rates of bicycling and walking.  They include: 
implementing the Complete Streets concept, speed limit policies
and laws, Safe Routes to School programs, increased state and
local bicycle and pedestrian funding and incentives, land use
policy and incentives, parking charges, adding teeth to parking
cash-out law (see Appendix A.), broader implementation of parking
cash-out and education, enforcement and encouragement programs.

Section II. B. 3.  Energy efficiency
Mandatory bicycle facilities (showers, clothing lockers and
bicycle parking) should be specifically cited and included in
green building standards.  For example, currently bicycle
facilities are only an option in LEED standards.  That option
should be made a requirement for all office, commercial and
residential buildings above a certain size.

Section II. B. 12.  Local government actions
A far greater reduction in GHG emissions should be expected from
local government actions.  This section could be made part of a
broader and more ambitious VMT reduction section.

Section II. C. 2.  Carbon Fees
Carbon fees should take priority over a cap and trade program. 
Fees are simple.  They can be phased in easily and can be made
revenue neutral.  They are quicker to implement.  They are
guaranteed to be effective.  Fees are more predictable, equitable
and comprehensive. 

Cap and trade programs are inherently more complicated and their
success is less certain based on actual European Union experience.
Cap and trade programs are easier to manipulate in an unfair
manner.

See:  Climate Change: Caps vs. Taxes
http://www.aei.org/publications/filter.all,pubID.26286/pub_detail.asp

Section III Analysis:  Costs and Benefits
The analysis fails to take into consideration the non-air quality
health benefits mentioned above.  There is also no consideration
of the congestion benefits of reduced VMT.  Congestion costs are
described in the Texas Transportation Institute’s Urban Mobility
Report.  The dollar value of congestion and health benefits, plus
the environmental and road construction savings, is very
substantial and should be calculated and included.  



Appendix A
Parking cash-out law with suggested amendments. 


Text of Parking Cash-Out Law

§ 43845.  Parking cash-out program.   California Health and Safety
Code.
(a) In any air basin designated as a nonattainment area pursuant
to Section 39608, each employer of 50 persons or more who provides
a parking subsidy to employees, shall offer a parking cash-out
program.  “Parking cash-out program” means an employer-funded
program under which an employer offers to provide a cash allowance
to an employee equivalent to the parking subsidy that the employer
would otherwise pay to provide the employee with a parking space.
(b) A parking cash-out program may include a requirement that
employee participants certify that they will comply with
guidelines established by the employer designed to avoid
neighborhood parking problems, with a provision that employees not
complying with the guidelines will no longer be eligible for the
parking cash-out program.
(c) As used in this section, the following terms have the
following meanings:
(1) “Employee” means an employee of an employer subject to this
section.
(2) “Parking subsidy” means the difference between the
out-of-pocket amount paid by an employer on a regular basis in
order to secure the availability of an employee parking space not
owned by the employer and the price, if any, charged to an
employee for use of that space.
(d) Subdivision (a) does not apply to any employer who, on or
before January 1, 1993, has leased employee parking, until the
expiration of that lease or unless the lease permits the employer
to reduce, without penalty, the number of parking spaces subject
to the lease.
(e) It is the intent of the Legislature, in enacting this section,
that the cash-out requirements apply only to employers who can
reduce, without penalty, the number of paid parking spaces they
maintain for the use of their employees and instead provide their
employees the cash-out option described in this section.

Suggested amendments (f) and (g)
(f)  Effective January 1, 2010, the penalty for an employer who
fails to offer a parking cash-out program required by Section
43845 is $1,000 per month in which the required program is not
offered.
(g)  An employer who fails to offer a parking cash-out program
required by Section 43845 must, retroactive to January 1, 2010,
pay employees a cash allowance equivalent to the parking subsidies
that the employees did not take.  The retroactive cash allowance
shall be no larger than the cash allowance the employees would
have received had the employer complied with Section 43845.


Related Provisions

Sections 17202 and 24343.5, California Revenue & Taxation Code. 
Specifies that costs related to a parking cash-out program may be
deducted as business expenses for employers.

Section 17090, California Revenue & Taxation Code.  States that
the cash allowance given to employees must be included in gross
income subject to state income and payroll taxes (except any
portion used for ridesharing purposes).

Sections 65088.1, 65089, and 65089.3, California Government Code. 
Requires (1) congestion management agencies to consider parking
cash-out when developing and updating the trip reduction and
travel demand elements of their congestion management plans, and
(2) requires cities or counties to grant appropriate reductions in
parking requirements to new and existing commercial developments if
they offer parking cash-out programs.

Uncodified language:

The Legislature hereby finds and declares all of the following:
(a) Existing local, state, and federal policies tend to encourage
the provision of subsidized parking by employers.
(b) Subsidized parking creates a strong incentive for employees to
commute to work in a single occupancy vehicle.
(c) Commuting in a single occupancy vehicle contributes to traffic
congestion and air pollution.
(d) In Los Angeles and Orange Counties, more than 90 percent of
the commuters receive free worksite parking, but less than 10
percent of employers provide an employee ridesharing or transit
benefit.

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2008-07-21 16:47:36



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