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My letter and 4 reference files are in the attached zip files. 

In case that doesn't work, here is the letter:

Mike Bullock 
mike_bullock@earthlink.net
1800 Bayberry Drive
Oceanside, CA 92054
October 15,2015, 2010

Air Resources Board
1001 I Street
P.O. Box 2815
Sacramento, California 95814
SUBJECT: Car and Light-Duty Vehicle (LDV) Considerations of Joint
agency workshop to initiate discussion of an update to the AB 32
Scoping Plan to reflect the State's "40% by 2030" GHG emission
reduction target
Dear Air Resources Board Chair Mary Nichols and Members of the
Board:
1.0	Introductory Comments
Since this is a technical topic, I feel I should list some of my
qualifications.  I have a BSEE degree, and an MSE. I am a retired
satellite systems engineer, and a guest lecturer at UCSD on the
topic of climate and transportation. I have authored two papers at
the Air and Waste Management Association (AWMA) on how cars and
light-duty trucks could achieve climate-stabilizing targets, in
California. I have also coauthored an AWMA paper on car-parking
policy.
Regarding climate, it is time to be brutally honest and open. You
have a responsibility to explain the difference between climate
stabilization at a livable level and climate destabilization, where
the positive feedbacks become dominant; we lose the ability to
prevent disaster; and the climate changes to one which will not
support most life forms on the planet, including our own species. A
2008 issue of Scientific American, The Ethics and Economics of
Climate Change, describes our situation as heading towards a
“devastating collapse of the human population.”
A reasonable climate stabilizing target for 2030 is 80% below 1990
levels; not the 40% below 1990 levels of B-30-15. 
My AWMA paper, Reference 1 of this letter, derives the 2030 climate
of 80% below 1990 levels (see also Reference 2), using Reference
3.
However, the B-30-15 target is seen to be too little by your own,
Scoping Plan, words, for which I thank you deeply and sincerely
(emphasis added):
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.
Regarding the emphasized words, as we all know, the atmospheric
level of CO2e already exceeds 400 PPM. The kicker here is that it
may be that the 1.5°C threshold is what we should have been working
to from the start. We need the reductions to be as soon as possible
and as large as possible. The AB 32 words come to mind that all
mitigations are needed that are “technologically feasible and cost
effective.”
CARB can use Reference 1 to show how a systems engineer would solve
this problem.
Part of the Reference 1 solution was the required per-capita
driving reduction
2.0	Comments Regarding Your Appendix C - Focus Group Working
Papers, 1 March 14, 2014
As near as I can tell, Appendix C is all true. It is useful. Thank
you for the work. However it needs to be much more quantitative.
The LDV fleet-efficiency must be quantified and the LDV per-capita
driving level that is associated with the derived fleet efficiency
must also be shown. The strategies and mitigation measures to
reduce driving must have driving-reduction estimates associated
with them and the total must equal what is required. 
Parking Policy and a Viable State Strategy
In order to solve this climate problem (how LDVs can support
B-30-15), CARB must focus on how to get improved methods of how we
pay for parking widely implemented. The damage from bundled-cost
parking (often called “free”) must be fully mitigated, in nearly
all cases. This paper, Reference 4 of this letter shows how this
can be done:
http://www.sandiego.gov/environmental-services/pdf/sustainable/parkingcosts.pdf.
Regarding parking, this is one of the two most-promising entries
(Page 18, emphasis added):
A new coordinated policy and planning approach should utilize all
available means, including, but not limited to, regulations,
regional planning, enforceable agreements, project mitigation, and
a sustained commitment to incentives (e.g., grants, vouchers,
rebates, parking or transit benefits, high occupancy vehicle lane
access, etc.). Each of these can play a strategic role in
implementation of the vision for transportation.
Here is the second (Page 21, emphasis added):
In order to expedite the proliferation of equitable TODs and other
infill, it will be necessary to break through common barriers
created by federal, State, regional, local, and private sector
policies and practices on financing, environmental review, parking,
and other issues.
Here is the third (Page 23, emphasis added):
Continuing to promote employer-based transportation solutions such
as facilitated carpooling and parking cash out would allow
employees more options to reduce commute-related VMT.
Finally, here is the fourth (Page 24, emphasis added):
Given the urgency of the necessary transition, policy measures will
be needed to increase incentives in varying forms and decrease
operating costs. In addition to financial incentives, other equally
effective incentives can take the form HOV lane access,
preferential parking, among other approaches.
None of these 4 statements regarding parking show sufficient
thought, considering what is at stake and the fact that parking is
generally operated in a way that is unfair, economically. Parking
is required by local governments and legislation will eventually be
needed to stop the unfairness, not to mention the harmful climate
implications. 
However, what is needed first is a demonstration project of a
reduced-feature (compared to the Reference 4 system) system. 
Road Usage Charge (RUC, see SB-1077)
The authors of Appendix C have overlooked the fact that the gas tax
is already being subsidized heavily by general taxes and this can’t
continue, given our urgent need for improved fleet efficiency.
Reference 1 shows how fast we must adopt zero-emission vehicles
(ZEVs) over internal combustion engine vehicles (ICEs). Reference 5
shows that the state is developing a Road Usage Charge pilot
project. I am disappointed that CARB is not participating to ensure
that this work will support a system with the features needed to
both protect low-income drivers and contribute significantly to
solving our climate crisis. Reference 6 shows a set of useful
requirements for a RUC. Legislation is needed as soon as possible
to direct and speed up the process to get an environmentally-sound
RUC that will also protect the economic interests of low-income
drivers.  
Need for a Systems Engineering Solution
Appendix C needs to follow the path shown in Reference 1 to
quantify the needed LDV fleet conversion and the needed reduction
in per-capita driving, with respect to the SB375 reference year of
2005. Table 9 in reference 1 shows how the needed LDV fleet
efficiency could be achieved; Equation 9 computes the associated
driving reduction to be 32% (a factor of 0.68).
The advantages of systems to unbundle the cost of parking and
driving is that, if need be, they could be adjusted to get the
driving reductions we need in a responsible way. 
3.0	Comments Regarding Your Slides, “2030 Scoping Plan, October 1,
2015, Slides 61 to 80
As for Appendix C, these slides show no quantification of the
problem. CARB can’t possibly solve a problem it does not first
“size” the problem. Again, see Reference 1 to see how the
requirement to achieve a target (in the case of Reference 1, it is
a climate-stabilizing target) can be flowed down into fleet
efficiency and level of driving. Page 17 of Reference 1 starts the
information on how to achieve the needed driving reduction.  
4.0	Unbundling the Cost of Car Parking 
For the vast majority of destinations in California, the cost of
car parking is hidden within other costs. This has serious
consequences. For example, at most places of employment, parking
costs reduce the wages that can be paid to all the employees, even
those that never use the parking. Similarly, at many apartment
complexes, bundled parking costs increase the rent and this is
true, even for families that do not own a car. Bundled parking
costs routinely increase the costs of goods, such as groceries, for
all customers. Again, this is even true for those that do not
drive. Since governments require businesses to provide minimum
levels of parking, they are involved in this economic
discrimination towards those that drive less. 
Driving less is, to some degree, a lifestyle choice. Since
government has no valid reason to encourage driving, the lifestyle
choice of less driving deserves constitutional, or at least legal,
protection from any practices that discriminate against it,
economically.
 On June 22nd (2010), I presented a paper (Reference 4) on how
parking could be operated to unbundle parking costs in a way that
supports the sharing of parking. This was at the 101st Conference
and Exhibit of the Air and Waste Management Association, in
Calgary, Canada. The session, Sustainable Land Use and
Transportation, included my paper, A Plan to Efficiently and
Conveniently Unbundle Car Parking Costs, which was well received.
My paper is therefore both peer reviewed and published. I would be
pleased to present this paper to the staff of CARB, in the hopes
that CARB could bring about equitable and environmentally-sound
parking policies to California.
The following points, taken from the paper, apply.
•	Vehicle miles traveled (VMT) are a major cause of global warming
and pollution.
•	California’s Metropolitan Planning Organizations (MPOs) will need
to adopt strategies that reduce vehicle miles traveled (VMT), in
order to meet SB375 GHG reduction targets, to be issued by the
California Air Resources Board in late 2010, for years 2020 and
2035.
•	The appropriate pricing of parking is one of the least costly
tools documented to reduce VMT.
•	New technologies, such as sensors feeding computer-generated
billing, offer the potential to efficiently bill drivers for
parking and alert law enforcement of trespassers.
•	Reformed parking policies can increase fairness, so that, for
example, people who use transit or walk do not have to pay higher
prices or suffer reduced wages, due to parking.
•	Methods to unbundle parking cost are inefficient unless they
support the spontaneous sharing of parking spaces. Shared parking
with unbundled cost would ultimately allow cities to require
significantly less parking.
•	Typical systems of timed parking and metered parking are far from
ideal. Parking has no automated record keeping, so it is difficult
to know where there is too much or too little. 
•	Good policies will eventually let cities turn parking minimums
into parking maximums.
Less land and resources devoted to parking will support mixed use
and make “smart growth” more economically viable. It should
therefore be a key ingredient supporting the MPO’s stated desire to
foster “smart” growth, where “smart” should be defined as “less
VMT”.
 Here is a copy of the abstract of the paper.
The Introduction shows documented driving reductions due to the
pricing of parking. It notes that although the benefits of priced
and shared parking are known, such parking has not been widely
implemented, due to various concerns. It states that a solution,
called “Intelligent Parking,” will overcome some of these concerns,
because it is easy to use and naturally transparent. It asserts
that this description will support a “Request for Proposal” (RFP)
process. Eight background information items are provided, including
how priced parking would help California achieve greenhouse gas
reduction targets. A story demonstrates some of the key features of
Intelligent Parking. Arguments for less parking, shared parking,
and priced parking are made. Barriers to progress are identified.
The fair pricing of parking is described.  New ways to characterize
transportation demand management are presented. Seven goals of
Intelligent Parking are listed. Eleven definitions and concepts,
that together define Intelligent Parking, are described. This
includes a method to compute a baseline price of parking and how to
adjust that price instantaneously to keep the vacancy above 15%
(“Congestion Pricing”). An implementation strategy is described.
This abstract aroused enough interest among those responsible for
A&WMA’s Sustainable Land Use and Parking session that they
requested that I submit a manuscript, which was ultimately selected
to become part of the written Conference Proceedings and for
presentation. I hope that it will similarly arouse the interest in
the CARB Board and staff. CARB needs to consider working to execute
the implementation strategy described in A Plan to Efficiently and
Conveniently Unbundle Car Parking Costs. I would be honored to help
in any way possible.
References 4, 7, and 8 have the details. 
6.0	Conclusions
Climate is a math problem. More specifically, it is a systems
engineering problem.
The best, largely overlooked strategies to reduce VMT are a
comprehensive and variable road use fee pricing system; unbundling
the cost of car parking; and putting a stop to all freeway
expansions. I would like to discuss further a state-wide strategy
to unbundle the cost of car parking.
CARB’s performance so far is going to put too much emphasis on the
fact that fuel for vehicles is a capped sector. This is unsound
policy. If the increased cost of gasoline becomes the dominant way
that driving is reduced, there is a significant risk that there
will be a powerful political backlash. Ideally, the state will be
led by a CARB that realizes that policy to both improve fleet
efficiency and reduce driving in a controlled way will mean the
emission trajectory from LDVs will be achieved without much need to
apply the Cap and Trade to limit allocations. Frankly, we do not
want to give our friends in the oil industry ammunition to shoot
down these vital efforts. 
Sincerely yours,
 
Mike Bullock
mike_bullock@earthlink.net
760-754-8025
1800 Bayberry Drive
Oceanside, CA 92054

1	Bullock, Mike R; The Development of California Light-Duty Vehicle
(LDV) Requirements to Support Climate Stabilization: Fleet-Emission
Rates & Per-Capita Driving, Paper 30973-AWMA, from the Air and
Waste Management Association’s 107th Annual Conference and
Exhibition; Long Beach, CA, June 24-27, 2014; Attached with
submission of comment letter and available on request from
mike_bullock@earthlink.net 
2	Power Point Slides used to present Reference 1, attached with
submission of comment letter (if possible) and available on request
from mike_bullock@earthlink.net
3	Hansen, James, Brief of Amicus Curiae, Exhibit A; United States
District Court for the Northern District of California San
Francisco Division, Case4:11-cv-02203-EMC Document108 Filed
11/14/11
http://ourchildrenstrust.org/sites/default/files/Hansen%20Amicus%20.pdf
4	Bullock, M.; Stewart, J.; A Plan to Efficiently and Conveniently
Unbundle Car Parking Costs; Paper 2010-A-554-AWMA, from the Air and
Waste Management Association’s 103rd Annual Conference and
Exhibition; Calgary, Canada, June 21-24, 2010. Available on request
from mike_bullock@earthlink.net or
http://www.sandiego.gov/environmental-services/pdf/sustainable/parkingcosts.pd
5	Madaffer, Jim; Letter from the Chair of the Road Users Charge
Technical Advisory Committee to Stakeholders, May 5, 2015.
http://www.catc.ca.gov/meetings/Committees/Road_Charge/Road_Charge_March_27_2015/Stakeholder_Agenda_Letter_March_2015.pdf
6	Bullock, Mike; Environmentally-Sound and Economically-Fair Road
Usage Charge; a resolution of the California Democratic Party
Environmental Caucus; approved on May 16, 2015; available on
request from mike_bullock@earthlink.net
7	Bullock, Mike; Equitable and Environmentally-Sound Car Parking
Policy at Schools; July 20, 2011; unpublished report; attached with
submission of comment letter and available on request from
mike_bullock@earthlink.net
8	Bullock, Mike; Equitable and Environmentally-Sound Car Parking
Policy at a Work Site; Oct. 4, 2014; unpublished report; attached
with submission of comment letter (if possible) and available on
request from mike_bullock@earthlink.net