California YIMBY wishes to submit the following formal
comments regarding CARB's Draft 2022 Scoping Plan Update. We
commend CARB’s analysis and encourage the Air Board to use
existing SB 32 authority to preempt local restrictions at
inextricable odds with California’s climate
mandate.
California YIMBY is a statewide issue advocacy and
policy non-profit focused on ending the housing shortage and
affordability crisis. Our 80,000 members live in every corner of
the state, and are active in supporting reforms that will make
California a more affordable, equitable, and sustainable place to
live. You may read more about California YIMBY
at <https://cayimby.org/>.
The number one source of greenhouse gas pollution
in California is the transportation sector. The State Legislature
and the Air Board have adopted several strategies to reduce this
pollution, namely: The low-carbon fuel standard; the zero-emissions
vehicles program; and land use reforms, along with transit and
complete streets investments, to reduce vehicle miles traveled
(VMT).
In subsequent updates to its efforts in these areas,
CARB staff have found that this three-pronged approach is necessary
to achieve the state’s climate goals; it is not possible to
reduce ambition on any of the three and hit the state's targets. At
the same time, the State has acknowledged that progress on the
zero-emissions vehicle strategy is behind
schedule, making the VMT reduction strategy more urgent and
important.
For that reason, we would like to commend CARB for
acknowledging the need to reduce vehicle miles traveled (VMT) in
its Draft 2022 Scoping Plan Update. CARB also deserves recognition
for drawing a clear connection between land use patterns and VMT,
particularly in Appendices D and E of the draft scoping plan
update. As CARB notes, greater urban density puts more Californians
within walking or biking distance of daily necessities, reducing
the need for regular car trips. Additionally, building robust
public transit infrastructure is more viable in dense areas, where
it can serve a greater number of riders. The public transit and
active transportation projects that greater density makes possible
are critical to reducing VMT.
But although CARB has correctly diagnosed the key
challenges to meeting California's climate goals, its proposed
solutions are strangely disconnected from the problems it
identifies. In its current form, the Draft 2022 Scoping Plan Update
does not provide the state with many tools to reduce
VMT—other than asking for city and county governments to make
it a priority. Instead, the draft scoping plan update relies
heavily on carbon sequestration to reach state climate
goals.
California YIMBY supports experimentation with
innovative ways of reducing carbon emissions, and we view carbon
sequestration as a promising mitigation tool. However, heavy
dependence on carbon sequestration would be a mistake. No country
or state has attempted to deploy this technology at a large
scale. Carbon sequestration's feasibility at scale remains
unproven; the state would be taking a major risk if it made the
success or failure of its climate mitigation plan hinge on making
it work — particularly given that failure is an existential
threat.
The draft scoping plan update's heavy dependence on
carbon sequestration is particularly striking because CARB leaves
so many other sustainability tools—particularly tools that
would reduce VMT—untouched. Given CARB's acknowledgment that
VMT is the largest contributor to emissions statewide, one would
expect CARB to emphasize VMT reduction more than speculative,
unproven policy interventions.
California YIMBY urges CARB to shift their emphasis from
carbon sequestration to proven solutions that directly address the
issue of VMT. CARB mentions several of those solutions in Appendix
D; they include waiving parking requirements for some projects,
building on infill sites, and relaxing zoning restrictions that
prevent the development of dense neighborhoods. Recent history
tells us that many localities will not take these actions unless
the state compels them to do so. This leads to a collective action
problem that threatens to prevent California from achieving its
climate goals.
Instead of leaving the power to maintain unsustainable
VMT levels to the discretion of local governments, CARB should use
its existing authority to promulgate land use regulations. AB 32
and SB 32 grant CARB broad authority to adopt regulations
aimed at "[achieving] the maximum technologically feasible and
cost-effective greenhouse gas emission reductions." To date, the
Air Board has not used this authority to preempt local land use
regulations, much less to encourage the development of denser
cities and transportation networks that don't place the private
automobile at their center. We believe it should.
Reducing VMT and increasing urban density would lead to
significant benefits for California over and above helping the
state meet its climate goals. These additional benefits
include:
-
Reducing building sector emissions. Single-unit
housing is the default housing typology in jurisdictions that
prohibit denser, multi-family “infill.” Single-unit
homes are more energy-intensive. Legalizing multi-family housing
can reduce energy demand by 27 -
47%.
-
Affordability. Removing limits on urban density in the central areas of
California cities would allow for the construction of more housing.
The addition of more housing supply would help to drive down costs
and end California's housing affordability crisis.
-
Traffic safety. Thousands of Californians die in traffic
collisions every year. Reducing VMT would necessarily reduce the
incidence of fatal car collisions. Additionally, research shows
that urban density is closely associated with fewer traffic
deaths.
-
Productivity gains. Greater urban density has been found to increase
economic productivity. As California becomes denser, it is
therefore likely to become more economically
prosperous.
Additionally, it should be noted that CARB could impose
land use regulations at no cost to the state's general fund through
its current authority as conferred by SB 32. Conversely, although
the cost of carbon sequestration is likely to decline in the near
future, deploying the technology at scale would still require
significant state investment. Given that California faces a structural deficit in future budget
years, it make sense for the state to prioritize cost-neutral
approaches to curbing emissions.
Just as reducing VMT and increasing urban density
carries major benefits, failing to do so would result in
significant costs. The greatest of those costs is that the state
would likely fall short of its climate goals. Additionally, traffic
deaths and housing costs would remain unconscionably high, and the
state would continue to lose out on unrealized economic
gains. If the state relies on carbon sequestration to meet
its climate goals, there is also the risk that the state will
eventually discover it has spent precious time and resources on an
approach that is infeasible at scale. Given the existential nature
of the climate crisis, the state cannot afford that
risk.
With the balance of these potential costs and benefits
in mind, we urge CARB to use its existing authority under AB 32
and SB 32 to preempt local restrictions on development where those
restrictions conflict with the state's climate goals—for
example, where local governments make it illegal to build
multifamily housing near public transit. If CARB disagrees with
California YIMBY's interpretation of existing statute, it should
clarify what powers it believes AB 32 and SB 32 grant the Air
Board, and consider asking the legislature for additional statutory
authority to regulate land use.
CARB and the state have a remarkable opportunity to meet
our shared climate goals while enriching California in innumerable
other ways. We believe that ignoring this opportunity in favor of
speculative, unproven approaches to climate mitigation would be a
mistake.
We appreciate having the opportunity to submit this
comment and look forward to working with CARB to achieve our
housing, climate, and clean transportation goals.
Regards,
Brian Hanlon
President & CEO
California YIMBY
Ned Resnikoff
Policy Director
California YIMBY
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