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Comment 1 for : Comment docket for updating the Senate Bill 375 regional passenger vehicle greenhouse gas emission reduction targets for the State's MPOs (sb375targetupdate-ws) - 1st Workshop.


First Name: Michael
Last Name: Bullock
Email Address: mike_bullock@earthlink.net
Affiliation:

Subject: SB 375 Driving Reduction Targets for MPOs & Strategies to Reduce Drivingf
Comment:
Honorable CARB Chair and Members:

I have attached a Power Point file which is the visual part of my
message. My words to further explain the Power Point slides are as
follows:

 [Power Point Slide #1] I am Mike Bullock, a twice-elected member
of the San Diego County Democratic Party Central Committee, a
retired satellite systems engineer, and a volunteer for an
environmental organization, where I work on local transportation
issues. I also submit and present papers for the
Energy-Utility-Environment Conferences (EUECs) and the Air and
Waste Management Association (AWMA) conferences. I have presented 5
AWMA papers, all on the topic of climate and transportation.

My first 13 slides are on the setting of the updated SB 375
Vehicle-Miles Traveled (VMT) Reduction Targets. I will then present
6 slides on how the needed VMT reduction can be achieved.

[Slide 2] 

CEQA requires an EIR for Regional Transportation Plans (RTPs). The
EIRs must show whether or not the RTP will result in cars and
light-duty trucks achieving climate-stabilizing targets. CEQA is
about the physical world; not just laws. SB 32 may or may not be
climate stabilizing. Also, the EIR must not ignore feasible
mitigations. CARB should help MTPs obey CEQA. In 2011, SANDAG
violated CEQA law, in part because they were led to believe that
all they had to do was achieve your 2035 target, even though that
target did not even come close to supporting Executive Order
S-3-05, let alone climate stabilization.
 
[Slide 3] Cars and Light-duty trucks are the biggest emitters of
GHG

[Slide 4] Climate Literacy, defined

[Slide 5] How Bad Could It Get?

[Slide 6] Our climate crisis (and showing that Scott Pruitt is
obviously incorrect)

[Slide 7] Fixing the Problem

[Slide 8] What the climate scientist say

[Slide 9] The climate-stabilizing target

[Slide 10] From the 2016 California Democratic Party Platform:

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

To do that, we would need to know the fleet efficiency, for the
target year. The California Democratic Party understood this.
Therefore:

[Slide 11] 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

Unfortunately, neither you (CARB) nor any MPO is doing such a plan,
to my knowledge. Fortunately, however, there is a plan that has
been peer-reviewed by both the Energy-Utility and Environment
Conference officials and the Air and Waste Management Association.
I would be happy to forward that report to you. Please let me know
if you are interested.
 
[Slide 12] Here are two cases that were considered, using the
methods developed in the AWMA report. The columns of numbers are
the percent of the fleet sold in California that is
Battery-Electric. The case on the left is from the comments made by
you, Madam CARB Chair. The case on the right is a more realistic
case, because it requires a smaller reduction in driving. The “CARB
Case” would require a 58 percent reduction in per-capita driving,
with respect to 2005; the more-realistic case requires a 32%
reduction, which is achievable.

[Slide 13] Finally, from the CDP Platform:

•	Work for equitable and environmentally-sound road and parking
operations
•	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

The next 6 slides are about how the needed VMT reductions could be
achieved. For more detail, please request the above-mentioned AWMA
report.
 
[Slide 14] How to Reduce Vehicle-Miles Traveled

This could be especially helpful if there is less money to spend
and/or estimated costs are rising.

[Slide 15] Stop adding new freeway lanes and by that I mean all
types of lanes, even managed lanes. More lanes will not reduce
congestion. Academics sometimes call the effect Induced Traffic
Demand.
 
[Slide 16] More lanes won’t relieve congestion but they will result
in more

•	Vehicle-miles-travelled (VMT)
•	GHG emissions
•	Criteria pollutants that harm health, especially in low-income
neighborhoods and
•	More frustrated drivers

More lanes use money, some of which could be used for
 
•	Road maintenance
•	Improvements in mass transit
•	Improvements in conditions for active-transportation and
•	Projects to improve how we pay for the use of roads, and/or car
parking

The last three items would reduce VMT. Expanding freeways is a
lose, lose, lose proposition.
  
[Slide 17] Projects to reduce driving include

•	More mass transit 
•	Improvements in conditions for active-transportation
•	Systems to improve how we pay for the use of roads, and/or car
parking
•	Transit Oriented Development

[Slide 18] Improve How We Pay for the Use of Roads 

There is an on-going pilot project of a Road Use Charge, or “RUC”.
This is being conducted by the RUC Technical Advisory Committee or
“RUC TAC”, of the California Transportation Committee, under SB
1077. When complete, it will be time for the coming revolution: 
the System Design and Implementation of a RUC which should, for
example, fund all road maintenance. Whether the RUC is good or bad
is up to us. A sales tax or bond measure for maintenance is the
wrong approach. CARB needs to provide leadership in its scoping
plans and its SB 375 target-setting process.

[Slide 19] Improve how we pay for the use of parking  

This is sometimes described in San Diego County environmental
organization response letters. There’s the link showing details,
for this pricing-and-payout system. First, demonstration projects
are needed.
 
•	Such a proposal was called feasible mitigation in Appellate
Court, here in San Diego. San Diego County, like most municipal
governments, strives mightily to avoid meaningful change. CARB
needs to provide leadership. 
•	From the 2016 California Democratic Party Platform: 
“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”

I have reports that spell out exactly how a demonstration project
could be set up to develop and improve the needed hardware and
software. A demonstration project could include a feature that
would allow employees to opt out of the program, if they wish. This
feature was included in the mitigation measure identified in the
SDC Climate Action Plan lawsuit. The Appellate Court Justice that
asked about this measure in Oral Arguments was impressed and called
the measure an example of a feasible mitigation that was ignored.
 
Please do not ignore this feasible mitigation measure. Leadership
is needed.
 
Thank you for your environmental leadership.

Sincerely,

Mike Bullock

Attachment: www.arb.ca.gov/lists/com-attach/2-sb375targetupdate-ws-BmVdOlUmVWQEXQN3.ppt

Original File Name: CARB_TargetsThenVMT_Reduction.ppt

Date and Time Comment Was Submitted: 2017-03-19 17:20:57



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