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First, let me help you see the context of my ideas. CARB needs to
implement its CA Official Plan to support climate stabilization
(your Scoping Plan), as legislated in SB 32 and AB 32. Currently
all municipal governments and all environmental NGOs are doing
their very best to ignore your CA Official Plan, even though AG
Harris's 2011 letter to SANDAG stated that this should not be done
and subsequent court rulings agreed with the now-ignored AG letter.
The 2030 requirement (SB 32) is deadly serious. AG Harris stated,
the CARB Scoping Plan can't be ignored because it is about "climate
stabilization" (her phrase, which is the shocking truth), the
"objective of CEQA". 

The derivation of the CARB Scoping Plan is not shown but the
requirements and mitigation measures are. With no math shown, I can
only guess about the role of the LCFS. But my guess is that you
(CARB Staff) are pushing the LCFS because otherwise the Scoping
Plan would need to have an even larger reduction in per-capita VMT
by 2030. This is about 2030 (SB 32), just like the work of the UN's
IPCC. 

The Scoping Plan now states we need a 25% reduction in VMT by 2030,
with respect to 2018. The mitigation measures to accomplish this
are to double transit service, price parking use (a new system is
needed because no one has extra money and we are very car-centric),
and price lane use (again, sophistication is needed.) Pricing
creates a dial that can be turned to reduce driving.  It sounds
like the CARB Staff needs to "dial back" on the LCFS and "dial up"
the pricing measures. 

There are many co-benefits of reducing VMT.

I would love to advise you on how to implement the needed pricing
measures. 

mike_bullock@earthlink.net

Highest regards,

Mike Bullock
1800 Bayberry Drive
Oceanside, CA 92054
760 421 9482

Former California Democratic Party Delegate, 76th Assembly District
(author of 2 adopted resolutions and 5 Platform changes)
Former Elected (now Associate) Member of the San Diego County
Democratic Party Central Committee (author of 5 adopted
resolutions)

Final title before leaving Aerospace: Senior Staff Systems
Engineer

Air and Waste Management Association published and presented
papers:
Author, The Development of California Light-Duty Vehicle (LDV)
Requirements to Support Climate Stabilization: Fleet-Emission Rates
& Per-Capita Driving 
Author, A Climate-Killing Regional Transportation Plan Winds Up in
Court: Background and Remedies
Co-author, A Plan to Efficiently and Conveniently Unbundle Car
Parking Cost

Quotes from the Secretary General of the UN:

1.)	We have a Code Red Climate Emergency.
2.)	We are solidly on a path to an unlivable planet.
3.)	We are driving towards Climate Hell with our foot on the
accelerator.
4.)	We are dangerously close to the point of no return.