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