Comment Log Display

Please adopt Highway Speed Limit Reductions to 55 MPH as an
extremely cost effective early implementation strategy based on
the evaluation below against the published ARB Early
Implementation Strategy Criteria.

1. Whether the strategy can be adopted by ARB in calendar year
2009 or earlier: YES

2. Whether the strategy can be legally effective by January 1,
2010:   YES, Highway Speed are set by State Legislature in VEHICLE
CODE SECTION 22348-22366

3. Whether the strategy relies on readily available mature
technologies or options that have already been successfully
demonstrated at an acceptable cost:  YES, REDUCING SPEED LIMITS
WAS DEMONSTRATED IN 1977 IN RESPONSE TO A WORLD OIL PRICE SHOCK;
REDUCING LIMITS WOULD REQUIRE AN AMMENDMENT TO STATE LAW, REVISION
OF SPEED LIMITS SIGNS; DRIVER EDUCATION; AND ENFORCEMENT

4. Whether the potential lifecycle GHG emission reductions are of
sufficient magnitude to warrant the resources required to adopt
and implement a regulation: YES; SPEED LIMIT REDUCTIONS ARE HIGHLY
COST EFFECTIVE; ACCORDING TO FEDERAL DATA ON SPEED AND FUEL ECONOMY
RESERACHED AND PUBLISHED BY OAK RIDGE NATIONAL LABORATORIES,
(http://www-cta.ornl.gov/data/index.shtml)A REDUCTION IN SPEED
FROM 70 TO 55 RESULTS IN AN AVERAGE 17% IMPROVEMENT IN FUEL
ECONOMY IN TERMS OF MILES PER GALLON; POTENTIALLY THIS TRANSLATES
INTO BILLIONS OF GALLONS OF FUEL SAVED AND TENS OF BILLIONS OF
TONS OF CARBON DIOXIDE EMMISIONS PREVENTED

5. Whether the strategy can be developed and implemented with
available resources. YES

6. The potential for adverse impacts on criteria or toxic
emissions:  HIGHWAY SPEED LIMIT REDUCTIONS WOULD REDUCE CRITERIA
AIR POLLUTANT EMISSIONS

7. The potential for disproportionate impacts on low-income
communities or other
disadvantaged sectors: WILL HAVE BENEFITS TO LOW INCOME
COMMUNITIES DISPROPORTIONATELY IMPACTED BY AIR POLLUTANTS; COSTS
TO LOW INCOME COMMUNITIES WILL BE LESS BECAUSE  OF REDUCED VEHICLE
OWNERSHIP AND DRIVING BEHAVIOR AMONG THIS ECONOMIC GROUP

8. The potential for disproportionate impacts on small businesses:
UNKNOWN

9. Significant loss of benefits due to leakage: NO

10. Coordination opportunities with related actions that may have
been taken or are planned by other entities including local
agencies, the U.S. EPA, and international agencies such as the
European Commission. INCORPORATED INTO EU POLICY AGENDA; CAN BE
REPLICATED IN OTHER STATES

Thank you

Rajiv Bhatia,MD,MPH
Director, Environmental Health
San Francisco California