Comment Log Display

The initial 5-19% Greenhouse Gas (GHG) target placeholder for the
years 2020 and 2035 was established by SANDAG and provided to the
CARB.  This placeholder was established by SANDAG modeling
scenarios that included very aggressive, unapproved, and unfunded
policies and infrastructure improvements through the year 2035. 
The approved Regional Transportation Plan has a horizon year of
2030, however, SB 375 requires a horizon year of 2035.  Therefore,
the SANDAG region has a period of five years wherein future
transportation planning and investments are not approved, yet for
the purposes of SB 375 must be analyzed for VMT reduction.  
The initial 5-19% GHG reduction scenarios included both current
and future sources of transportation revenue that may not be
available; and also included land use intensification assumptions
that have not been approved by the Board of Directors or by the
local jurisdictions.  SANDAG provided a letter to CARB (dated June
4, 2010) which indicated that the SANDAG Board of Directors
expressed concern that the scenario modeling assumed an
intensification of land use as well as policies, programs, and
investments that were not constrained by actual revenue that will
be available when the Board prioritizes investments as part of the
next Regional Transportation Plan.
It should be noted that SANDAG has an adopted 2030 Regional
Transportation Plan that includes two funding scenarios, the
“Revenue Constrained” scenario (identifying traditional funding
sources) and the “Reasonably Expected Revenue” scenario (which
includes both current funding sources and potential future revenue
sources from state and federal sources).  At the direction of the
SANDAG Board of Directors, a hybrid scenario was developed and the
SANDAG Board of Directors has recommended to CARB a target of 7%
reduction by 2020 and 13% by 2035.
Assumptions contained within the hybrid scenario include highway
improvements that are within the 2030 Revenue Unconstrained highway
network as well as revenue unconstrained number of park and ride
parking spaces.  Without an actual funding source these
improvements and realization of GHG reduction targets may not be
realized.  There are also a number of very aggressive increases to
carpool and vanpool participants within the Systems Efficiency
scenario that may not be realized.  Given the CARB has indicated
the GHG targets should be “ambitious but achievable”, these targets
may not be realized or achieved given that some of the assumptions
in the model include unfunded improvements and investments into the
transportation network.