Comment Log Display

Dear CARB Members and Staff,

Scope of Document:

I am disappointed in the reduction in scope, from the First Update
to the Climate Change Scoping Plan, Building on the Framework,
(“Update”), which included a section titled “Climate
Stabilization”. The reduction in scope is clear from the subtitle
of this document: “The Proposed Strategy for achieving California’s
2030 Greenhouse Gas Target.” Your are therefore assuming, without
being clear, that the California climate mandate is climate
stabilizing. There are good reasons to believe it is not. Recently
it was stated that starting in 2020, emissions must be cut in half
each decade. This would mean that 2030 emissions must be 50% less
than in 2020; not 40% less. The last Scoping Update faced the
crises squarely in it section on Climate Stabilization. This
proposal covers all of that up by pretending we know the SB 32
target is all we need to worry about. 

Since the state-policy direction that is defined in this document
will have an impact on environmental outcomes, this document is
therefore a project under CEQA law. CEQA requires an analysis of
the environmental impacts in the physical world, not just whether
or not targets set by a law are achieved. Therefore, this document
must do much more than just proposing a strategy to achieve
California’s 2030 greenhouse gas target. An accurate assessment of
humanity’s situation shows that we must achieve climate-stabilizing
targets and that furthermore, measures that go beyond this must
also be implemented. Given our dire situation, it is easy to see
that all proposed greenhouse gas (GHG) reduction measures that are
technologically feasible and cost effective must be adopted.
Limiting the scope to one which might fail to stabilize the climate
at a livable level is unacceptable, for many reasons, including
that it will violate CEQA. 


Crisis Description

On Page ES2, you use the oft-used expressions, “worst-case
scenarios” and (stave off the) “most severe impacts”. However, the
CARB members, who are the decision-makers in this case, deserve a
more straightforward description of what is at stake. Governor
Brown provided this in his comments to the Pope, which he
understood would be quoted all over the world. He said these five
simple words: “humanity must reverse course or face extinction.”
 
As important as that statement is, it was preceded by an equally
important set of words, “the world may already have “gone over the
edge” on global warming.” We trust that you understand exactly what
that statement means. It may be too late to avoid destabilization.
 
We appreciate the information you have provided about the various
environmental degradations we will experience, such as sea-level
rise, on our path to the loss of most forms of life on the planet;
or perhaps it will be on the path to nearly losing most life forms
on the planet. However, nowhere do you state the simple truth that
we are headed towards a devastating collapse of the human
population and that it may be too late to prevent this from
happening. The Board deserves to know this. The general public
deserves to know this.

Target Setting

The current draft says the following:

"  2. Setting the 2030 Statewide Target 

The 2030 target set by SB 32 of 40 percent reduction from 1990
levels by 2030 reflects the same science that informs the agreement
reached in Paris by the 2015 Conference of Parties to the United
Nations Framework Convention on Climate Change (IPCC), aimed at
keeping the global temperature increase below 2 degrees Celsius
(°C). The California 2030 statewide target represents the most
ambitious GHG reduction goal for North America. Based on the
emissions reductions directed by SB 32, the annual 2030 statewide
target emissions level for California is 260 MMTCO2e."

However, that approach is contradicted by your own, “Update”, when
it says the following:

"B. Achieving Climate Stabilization 
Scientific research indicates that an increase in the global
average temperature of 2°C (3.6°F) above pre-industrial levels,
which is only 1.1°C (2.0°F) above present levels, poses severe
risks to natural systems and human health and well-being.
Considering knowledge from the paleo-climate record with changes
currently observed in the Greenland and Antarctic ice sheets, we
can expect substantial sea level rise, 0.4 to 0.8 meters, with
upper end uncertainties approaching one meter above present day
during the 21st Century and continued substantial increase after
2100 even with stringent mitigation of emissions to achieve 2°C
stabilization. Increased climate extremes, already apparent at
present day climate warming (~0.9°C), will no doubt be more severe.
To have a good chance (not a guarantee) of avoiding temperatures
above those levels, studies focused on a goal of stabilizing the
concentration of heat-trapping gases in the atmosphere at or below
the 450 parts per million (ppm) CO2-equivalent (CO2e, a metric that
combines the climate impact of all well-mixed GHGs, such as methane
and nitrous oxide, in terms of CO2). 
The CO2e target is a somewhat approximate threshold, and the exact
level of CO2e is not precisely known because the sensitivity of the
climate system to GHGs has uncertainty. Different models show
slightly different outcomes within this range. An example of a
pre-IPCC assessment study (Meinshausen et al. 2009)15 which has
synthesized many studies on climate sensitivities, concluded that
we would need to stabilize at about 400 ppm CO2e in order to likely
avoid exceeding the 2°C threshold (even at that stabilization
target, there is still about a 20 percent chance of exceeding the
temperature target). Further, a recent paper by an international
team of scientists (Hansen et al. 2013)16 asserts that the widely
accepted target of limiting human-made global climate warming to
2°C above preindustrial levels is likely too high and may subject
future generations and nature to irreparable harm. Recognizing this
fact, the international community agreed in meetings in Cancun in
2012 to review, by 2015, progress to the 2°C target and consider
whether it should be strengthened to a 1.5°C threshold."

The first key statement, taken from those words, is the following,
with emphasis added:

"An example of a pre-IPCC assessment study (Meinshausen et al.
2009)15 which has synthesized many studies on climate
sensitivities, concluded that we would need to stabilize at about
400 ppm CO2e in order to likely avoid exceeding the 2°C threshold
(even at that stabilization target, there is still about a 20
percent chance of exceeding the temperature target)."

Of course the problem is that we have already exceeded 400 PPM.

The second key statement is this, again with emphasis added:

"Further, a recent paper by an international team of scientists
(Hansen et al. 2013) asserts that the widely accepted target of
limiting human-made global climate warming to 2°C above
preindustrial levels is likely too high and may subject future
generations and nature to irreparable harm."

Given that we may already be going over 2 degrees Celsius and that
we should not be going over 1.5 degree Celsius, and based on some
of my own independent analysis, I believe that the 2030 target
should probably be 80% (not 40%) below the 1990 level by 2030. This
is equivalent to saying the Governor’s Executive Order S-3-05
target, for year 2050, needs to be achieved 20 years sooner. If you
believe that the SB 32 target is climate-stabilizing, in the sense
that if it was achieved by the entire industrial world then planet
earth would not experience climate destabilization; then that needs
to be stated, along with your reasoning as to why the key
statements I have just presented, from the Update, can be ignored.

SB 375 Targets

As part of this scoping plan, CARB needs to develop a set of
enforceable measures that will cause cars and light-duty trucks
(LDVs, the SB 375 emitters) to achieve climate-stabilizing targets.
This special treatment for LDVs is warranted by the amount of GHG
they emit and the complex nature of the inherent trade-off between
fleet efficiency and per-capita driving.
 
From the 2016 California Democratic Party (CDP) Platform:

•	Demand Regional Transportation Plan driving-reduction targets,
shown by science to support climate stabilization

To do that, the target-year, fleet efficiency must be known. The
California Democratic Party understands this, as shown by the
following, also from the 2016 California Democratic Party (CDP)
Platform:

•	Demand a state plan showing how cars and light-duty trucks can
hit climate-stabilizing targets, by defining enforceable measures
to achieve the needed
1.	fleet efficiency and 
2.	per-capita driving.

I have attached a plan that does exactly that. It was peer-reviewed
by the Air and Waste Management Association. It would serve as an
example that could help you prepare such a plan.

Under CEQA, you have a responsibility to have such plan, as part of
this Scoping Plan effort. That way, the Board Members can decide if
they want to vote approval of a plan that would achieve a
climate-stabilizing target. Furthermore, CARB should assign SB 375
targets to the MPOs that support such a plan. The target assignment
is critically important and is also a project under CEQA. It has
been said, and I believe that it is true, that having no plan to
succeed is actually having a plan to fail. Failing will,
considering this under CEQA law (cumulative effects), result in the
loss of most life forms on our planet, including our own species.

The assigning of targets is a discretionary project under CEQA and
so you must follow CEQA law in assigning SB 375 targets.

By the way, for the most part, our extinction will be brought about
by a loss of habitat, meaning that we will starve to death.
Low-income citizens will starve first; billionaires will starve
last. Loss of most life forms on the planet is a very severe
environmental impact. Some would say it is unacceptable.

LDVs and Enforceable Measures to Achieve the Needed Driving
Reduction

I appreciate your Section IV-C, Transportation Sustainability. I
have made a case for your preparing a plan showing how cars and
light-duty trucks (LDVs) can achieve climate-stabilizing targets.
Your Section IV-C makes the point that making the needed changes
will provide significant improvements in health. I also support
your call for “the integration of electrified rail and transit to
improve reliability and travel times, increase active
transportation such as walking and bicycling, encourage use of
streets for multiple modes of transportation, improve freight
efficiency and infrastructure development, and shift demand to low
carbon modes”.

All categories of transportation will have to achieve the needed
GHG reductions.
 
However, I must stand firm on my request for a specific LDV plan,
to ensure success for the biggest GHG-emitting category.
My understanding matches yours when you state the following:

"VMT reductions are necessary to achieve the 2030 target and must
be part of any strategy evaluated in this plan."
 
And also:

"Stronger SB 375 GHG reduction targets will enable the State to
make significant progress"

Again, all of this will be made clear with an LDV plan, which will
quantify this and, most importantly, identify the specific
enforceable measures. For example, the one such plan I know of
proposes keeping the Corporate Average Fuel Efficiency (CAFÉ)
standards, but having them only apply to internal combustion engine
(ICE) LDVs. Then, in addition to the CAFÉ standard for ICEs, car
manufacturers would need to sell a specified fraction of ZEV
vehicles. Such a scheme would need to also allow buying credits
from a company that is able to exceed the specified fraction, such
as Tesla. Some manufacturers may want to continue to focus on the
ICE market. However, the ICE market would, by law, dwindle down to
be quite small by 2025 or so. It is important to provide clarity to
the manufacturers of LDVs.
 
A plan for LDVs would need to develop a set of enforceable measures
to reduce driving. The following sections show some of the primary
enforceable measures, along with estimates for the reduction in
per-capita driving they would achieve, from the SB 375 base year of
2005 to the target year of 2030.

1.)	Reallocate Funds Earmarked for Highway Expansion to Transit and
Consider Transit-Design Upgrades (3%)

For example, San Diego County has a sales tax measure called
“TransNet”, which allocates one-third for highway expansion,
one-third for transit, and one-third for road maintenance. It has a
provision that allows for a reallocation of funds, if supported by
at least two-thirds of SANDAG Board members, including a so-called
weighted vote, where governments are given a portion of 100 votes,
proportional to their population. This enforceable measure is to
direct SANDAG to reallocate its TransNet amount, earmarked for
highway expansion, to transit and to order similar reallocations
throughout California.

This money could be used to fund additional transit systems; fund
improved transit operations; and/or fund the redesign and
implementation of that redesign of existing transit systems. The
redesign could include electrification and automation or even
upgrading to a completely different technology.

2.)	A Comprehensive Road-Use Fee Pricing, Collection, and Payout
System to Unbundle the Cost of Operating Roads (7.5%)

Comprehensive means that pricing would be set to cover all costs
(including road maintenance and externalities such as harm to the
environment and health); that privacy and the interests of
low-income drivers doing necessary driving would be protected; that
the incentive to drive fuel-efficient cars would be at least as
large as it is under the current fuels excise tax; and, as good
technology becomes available, that congestion pricing is
implemented to protect critical driving from congestion.

The words "payout" and "unbundle" mean that some of the money
collected would go to people that are losing money under the
current system. For example, the estimate of increased health cost
due to LDV-caused air pollution would be the basis for a transfer
of funds to reduce health-care costs.
 
User fees (gas taxes and tolls) are not enough to cover road costs
and California is not properly maintaining its roads. Besides this,
the improved mileage of the ICEs and the large number of ZEVs
needed mean that gas tax revenues will drop precipitously.

This system could probably be implemented in less than 5 years and
efforts should start now and make use of the data generated by the
soon-completing Road Use Charge (RUC) pilot project that was
implemented under SB 1077.

3.)	Either Literally, or More Commonly, Effectively, Unbundle the
Cost of Car Parking (7.5%)

Unbundling or, effectively unbundling, the cost of car parking
throughout California is conservatively estimated to decrease
driving by 7.5%. “Effectively unbundling parking” means installing
a pricing, collection, and payout system that removes 100% of the
unfairness and environmental harm of bundling the cost (at
apartments, stores, or rail stations, for example) or of bundling
the benefit (at work or schools, for example) of parking. It should
be noted that parking is often very expensive to provide and people
pay for its use in hidden ways, such as receiving a reduced wage,
paying an increased rent or paying an increased cost. These
financial burdens are generally invisible, inescapable, and even
apply to those citizens who never drive or park a car.
 
Regarding car parking at work, we cite a CEQA lawsuit against the
County of San Diego’s Climate Action Plan (CAP). The lawsuit
resulted in a published Appellate Court ruling, thereby
establishing the legal precedent that CAPs must have meaningful
targets, enforceable measures, and must not ignore feasible
mitigations that have been proposed. However, to this day, San
Diego County, at their downtown office building, which is located
near to good transit, and some of the most expensive real estate in
the world, provides “free” parking to its employees. The lawsuit
proposed a mitigation measure to operate the employee parking as a
business for the financial gain of the County employees. The
following description is of a system that was found to be feasible
mitigation in the CEQA lawsuit against the County of San Diego’s
CAP:

The municipality would develop a Demonstration Project to Unbundle
the Cost of Parking (“Demonstration Project”) at a city employee
location (“Proposed Location”).
 
The municipality would (assuming the demonstration project was
successful) unbundle the cost of the parking at all municipal
buildings.

BACKGROUND: Currently, municipal employees do not have the ability
to choose between earnings and driving – employees effectively pay
for parking out of their salary, whether or not they use the
parking.  The Demonstration Project will provide the opportunity
for the employees to choose between earnings and driving. This
implements the California Air Pollution Control Officers
Association (CAPCOA) measure of unbundling the cost of parking.

PROJECT: Parking would be charged at a given rate (for example
$0.02/min – roughly $9.60/day).  Funds generated from these parking
charges would be distributed as earnings to all employees working
at the proposed location in proportion to each employee’s time
spent at work, at the proposed location. Those who decide not to
drive will not be charged for parking but will still make earnings
based on time spent at work at the location.  Implemented
correctly, this free market approach will substantially reduce
vehicle miles traveled (VMT) and greenhouse gas (GHG) emissions, by
reducing the drive-alone mode.

For employees whose parking charges are greater than parking lot
earnings, an “add-in” may be included so that no employee loses
money, compared to “free parking”. With such “add-in” payments,
there could be an “Opt in or Opt out” choice, meaning that those
that “Opt out” will see no changes on their pay check, relative to
“free parking”.

This project may be helped by receiving a grant to pay the
development and installation cost, as well as the “add in”
payments, for some specified number of years. The municipality
would need to apply for such a grant.

The County was ordered to rescind their Climate Action Plan and pay
all legal fees. They are currently without a Climate Action Plan.
However, we still do not know if they will implement the
car-parking measure that was found to be feasible. All of the
municipal governments in California would benefit if CARB took the
initiative on this mitigation measure.

Please start a process to design and implement such a plan, for
your own employees, at a site where the parking is currently
operated as a bundled benefit (AKA, “free”.) We could provide the
contact information of a vendor who would be happy to do this
work.

There is political support and awareness of the need for such a
system and for transportation reform in general. For example, the
following is from the 2016 CDP Platform:

o	Work for equitable and environmentally-sound road and parking
operations; Support strategies to reduce driving, such as smart
growth, “complete streets”; teaching bicycling traffic skills; and
improving transit, from local systems to high speed rail

o	Work for shared, convenient and value-priced parking, operated
with a system that provides earnings to those paying higher costs
or getting a reduced wage, due to the cost of providing the
parking;

4.)	Good Bicycle Projects and Bicycle Traffic Skills Education
(3%)

The best criterion for spending money for bicycle transportation is
the estimated reduction in driving per the amount spent. The
following strategies may come close to maximizing this parameter.

a.)	Projects to Improve Bicycle Access

All of the smart-growth neighborhoods, central business districts,
and other high-trip destinations or origins, both existing and
planned, should be checked to see if bicycle access could be
substantially improved with either a traffic calming project, a
“complete streets” project, more shoulder width, or a project to
overcome some natural or made-made obstacle.

b.)	League of American Bicyclist Certified Instruction of “Traffic
Skills 101”

Most serious injuries to bike riders occur in accidents that do not
involve a motor vehicle. Most car-bike accidents are caused by
wrong-way riding and errors in intersections; the
clear-cut-hit-from-behind accident is rare.

After attending Traffic Skills 101, students that pass a rigorous
written test and demonstrate proficiency in riding in traffic and
other challenging conditions could be paid for their time and
effort.

As an example of what could be done in San Diego County, if the
average class size was 3 riders per instructor and each rider
passes both tests and earns $100 and if the instructor, with
overhead, costs $500 dollars, for a total of $800 for each 3
students, that would mean that $160M could teach $160M/$800 =
200,000 classes of 3 students, for a total of 600,000 students. The
population of San Diego County is around 3 million.

5.)	Eliminate or Greatly Increase the Maximum Height and Density
Limits Close to Transit Stops that Meet Appropriate Service
Standards (2%)

As sprawl is reduced, more compact, transit-oriented development
(TOD) will need to be built. This strategy will incentivize a
consideration of what level of transit service will be needed, how
it can be achieved, and what levels of maximum height and density
are appropriate. Having no limits at all is reasonable if
mathematical models show that the development can function without
harming the existing adjacent neighborhoods, given the level of
transit service and other supporting transportation policies (such
as car parking that effectively unbundles the cost or benefit of
parking and furthermore supports the full sharing of parking) that
can be assumed.

6.)	Improve the Way We Pay for the Use of Transit

Eventually, using transit, car parking, and roads should be no
different than using water or electricity. This will require a new
design. To show an example of how this could be described and as an
example showing that people that have become educated on the topic
of climate and transportation are ready for change, the following
is provided as a resolution that will be submitted to the
California Democratic Party. The Democratic Club of Carlsbad and
Oceanside has already passed a nearly-identical resolution.

Support for the Development and Installation of a Single System to
Operate Roads, Car-Parking, and Transit

WHEREAS, (1) greenhouse gas (GHG) emissions must be reduced; (2)
about 35% of California’s GHG is caused by driving; (3) given
reasonable estimates for future fleet efficiency, to achieve
climate-stabilization targets, driving must be reduced; and (4) the
second bullet of the Transportation Sub-plank of the 2016 CDP
Platform calls for “equitable and environmentally-sound road and
parking operations”; and

WHEREAS, in California, (1) user fees (gas tax and/or tolls) do not
cover the cost of road maintenance; (2) our fleet must combust less
fuel each year, thereby reducing gas-tax revenue yearly; (3) hiding
the true cost of road use increases driving, air pollution,
congestion, propensity to approve sprawl development, and GHG
emissions; (4) a 2011 California Transportation Commission
assessment found 58 percent of our roads needing rehabilitation or
maintenance; (5) prevailing-wage construction jobs are needed; and
(6) there is a current state pilot project for a Road Usage Charge
(RUC) but no legislation to implement a RUC and no RUC system
design;

WHEREAS, (1) bundled-cost parking (“bundled-cost” denotes that the
parking is offered at no charge because its cost is “bundled” into
the cost of other items) increases the cost of everything, from
rent to food; (2) bundled-benefit parking (“bundled-benefit”
denotes that it is an employee benefit, like a salary, or a medical
benefit) reduces wages; (3) the fourth bullet of the Transportation
Sub-plank of the 2016 CDP Platform calls for “shared, convenient
and value-priced parking, operated with a system that provides
earnings to those paying higher costs or getting a reduced wage,
due to the cost of providing the parking”; and (4) technology could
increase the convenience of paying for driving, parking, and using
transit and distributing earnings, taken from these revenue
streams, to individuals, as appropriate;

THEREFORE, BE IT RESOLVED, that the California Democratic Party
supports a transit-use, road-use, and car-parking-use pricing,
collection, and payout system, operated with modern technology and
specified by a system-requirements document (such a document
unambiguously defines what the system does, as the first step of
system design), covering such topics as privacy, protection for
low-income users, base-and-congestion price, detection, and
statement-mail-out methods, always assuming prevailing-wage jobs.

BE IT FURTHER RESOLVED, that this support be communicated to
Governor Edmund G. Brown, Senate Pro-Tem Kevin de Leon, Speaker
Anthony Rendon, the Air Resources Board, and the California
Transportation Commission.

In conclusion, we need enforceable measures that will reduce
driving by reforming our transportation systems. The estimates of
the driving reductions that will result from these measures will
need to add up to the total needed, given the target-year fleet
efficiency and the climate-stabilizing target.

Thank you for your leadership,

Mike Bullock
760-754-8025