Comment Log Display

July 25, 2008

California Air Resources Board: 

I am a member of the Safe Routes to School National Partnership,
writing to submit comments on the California Air Resources Board’s
(ARB) draft scoping plan for AB32, which is being designed to
reduce greenhouse gas emissions in the State of California to1990
levels by the year 2020. 

My comments focus on the transportation sector, which accounts for
approximately 38% of greenhouse gas emissions in the State of
California. While we are pleased that the ARB asks for the
development of regional plans that will document and reduce
greenhouse gas emissions (GHG) emissions, we feel that your target
for land use, (2 million metric tons) is quite low, as this
represents less than 1% of the overall GHG emissions reductions.
This land use target is not at all proportionate to its share of
GHG emissions within the transportation sector. 

The Partnership is particularly interested in having the scoping
plan be amended to include a specific focus related to schools
which play a major role in how communities are designed, and how
local traffic is generated, with its corresponding vehicle miles
traveled (VMT) and carbon emissions. 

1) Land Use and VMT: name of organization asks that you increase
requirements in the scoping plan for GHG reductions through the
land use sector, and make tracking vehicles miles (VMT) traveled
and targets associated with VMT reductions a requirement through
new regional land use targets. We also ask for you to require that
regional transportation agencies include school siting and Safe
Routes to School as components of their GHG reduction plans, and
create an enforcement mechanism around these GHG reduction plans.


2) Safe Routes to School: We further ask that ARB include Safe
Routes to School infrastructure and non-infrastructure programs in
the section of the scoping plan titled “public education and
programs to reduce vehicle miles traveled” so that the program can
be expanded to all elementary and middle schools in California.
Include a sentence about your organization’s work with Safe Routes
to School and any data you might have generated related to mode
shift. The Safe Routes to School National Partnership has
calculated that if every school in the state currently operated a
Safe Routes to School program that this could annually reduce
468,156 tons of CO2, and create an annual reduction of
1,099,357,028 VMT through school trips alone. Safe Routes to
School programs should be funded from cap and trade allowance
allocations or other new revenue sources committed to reducing CO2
emissions at a rate of $90 million/year which will be matched
through federal and local funding. The state should also require
VMT reduction targets related to SRTS in the regional land use
plans. 

3) School Siting: In addition, ARB should work with the California
Department of Education (CDE) on the revision of their school
siting requirements (Title 5) which are being updated now to
ensure that CDE is encouraging neighborhood schools, and
specifically mention the importance of school siting and
neighborhood schools within the final Scoping Plan. The National
Household Travel Survey indicates that only 42% of school trips
are one mile or less in California. As we are building and
rebuilding more schools in this state, it will be important to
ensure that these new schools are neighborhood schools, where
children can safety walk and bicycle as walking and bicycling to
school decreases dramatically as residents are located further
from schools. 

Safe Routes to School and school siting are important issues to
include within the scoping plan both for funding allocations
through the cap and trade program, and as requirements for the
regional target plans. 

The State of California should not focus only on technological
solutions to reduce GHG emissions. Without improved land use,
increased VMT will prevent us from achieving the 2020 emissions
reduction goals. Additionally, funding school-oriented programs
that promote walking and bicycling will have co-benefits such as
improved land use, healthy lifestyles and reducing obesity-related
illnesses that are exacerbated due to a lack of opportunities for
safe physical activity. 

Thank you for your careful consideration of our comments. 

Sincerely, 

Chris Davis