June 23,
2022
Liane
Randolph, Chair
California Air Resources Board
Re:
Golden State Gateway Coalition Comments on
California Air Resources Board’s Draft 2022 Scoping
Plan Update
Dear
Chair Randolph and Members of the Board:
On behalf of Golden State Gateway
Coalition, I am writing to express our very serious concerns about
the Draft 2022 Scoping Plan Update (the “Update”) that
is proposed for consideration by the California Air Resources Board
(“CARB”).
The Golden State
Gateway Coalition generally shares the goals of
addressing and mitigating greenhouse gas emissions
(“GHG”) arising from activities in California, and
doing so in ways that improve the lives and well-being of all
Californians and protect and benefit our economy. In addition, we
believe that to achieve AB32/SB375 goals and the best
outcomes:
·
New and ongoing CARB regulations
must be soundly justified and obtainable (technologically,
financially, etc.)
·
CARB’s regulations should
be as commanding or as tempered as the proof and data indicate is
best; and
·
The evolution and ongoing
evaluation of CARB’s policies and regulations should reflect
input from all affected stakeholders, including certainly from the
most affected industries.
While the Update is
well-intentioned, it contains several elements that should be
substantially corrected before the Update is finalized by CARB.
Given the mission of
the Golden State Gateway Coalition, our comments center around
transportation and VMT.
Unfortunately, CARB continues to
champion land use policies aimed at radically reducing per capita
vehicle miles traveled (“VMT”). Indeed, the Update
contains a stated goal of reducing non-commercial, per capita VMT
by some thirty percent (30%) between 2019 and 2045. In short, CARB
aims not to decrease GHG per se, but instead to decrease individual
mobility by nearly one-third, and to do so by mandating sweeping,
concentrated changes in our urban form. Additionally, decrease in commercial per capita
VMT reductions will impede goods movement furthering the supply
chain issues California is currently experiencing.
Since 2010, pursuant to Senate Bill 375
enacted in 2008, CARB has been promoting land use scenarios aimed
at reducing per capita VMT; but no meaningful VMT reductions have
been realized! The state’s VMT initiatives are not working,
but they are killing needed homebuilding
A steadfast reliance on VMT cutting
means that CARB is driving California’s citizens out of
state. Jobs are transitioning and are becoming automated or
offering work from home. California is investing in transit
projects, electrical vehicle charging stations, electrical vehicle
fleet upgrades, etc. Prior to VMT action, CARB should assess the
lifestyle changes and infrastructure investments required before it
enacts VMT mandate. Without the infrastructure investment, lives of
hardworking Californians will be harmed.
CARB’s
Update continues to pursue transportation policies that
the data show is being effectively rejected by overwhelming
percentages of the relevant public.
Consistent with CARB’s wish to
greatly reduce individual mobility and VMT, the Update indicates
CARB’s continuing push to promote (i) mass transit systems
and infrastructure, and (ii) mass-transit-oriented real estate
development and redevelopment; in each case to the exclusion of all
other alternatives (such as new and better roads leading to new
towns). Specifically, the Update calls for a doubling of transit
service coverage and service frequencies by 2030. (Update, Appendix E, p. 13.) All
available data from recent years show, however, that public
utilization of mass transit is both relatively minimal and
generally slipping further. Indeed, per capita mass transit
utilization was trending downward even before the COVID-19 pandemic
decreased such utilization even more – as even SCAG has
recognized. We therefore question the wisdom of CARB’s
determination to keep pouring state funding into mass transit
infrastructure that California’s citizens find to be of
little collective utility.
The Update similarly calls for
substantial additional spending focus on infrastructure for walking
and bicycling, which is connected to CARB’s push toward
relatively dense urban housing. (Update, Appendix E, pp. 6-11.) But
spending on walking and bicycling infrastructure will have no more
than a de minimis impact on the other forms of mobility such as
individual VMT or mass transit, given that less than 2% of all VMTs
involves trip lengths that are short enough to be accomplished by
walking or biking. Furthermore, many citizens have infirmities that
preclude their ability to use such alternatives.
CARB and all state agencies
should be working to provide a balanced mix of new transportation
infrastructure—including mass transit where it would have the
most utility and paths for walking and biking—that recognizes
the need for new roads and lane additions where they would have
utility and allow for additional homebuilding of all
typologies.
We share CARB’s desire to
see continued emissions reduction while maintaining the states
diverse economic vitality, and we know the task is not easy. We
appreciate the staff and board’s diligence in bringing
diverse groups to the table to map out the most effective CARB
Scoping Plan as possible.
Thank you for your consideration of our
letter. If you have any questions, please contact John Musella at
310-717-6622.
Sincerely,
JOHN
MUSELLA
Executive
Director