Comment Log Display

Dear ARB Staff:

We’d like to thank you for the opportunity to comment on ARB’s
target updating process under SB 375. As organizations working
directly with disadvantaged communities throughout the San Joaquin
and East Coachella Valleys, we feel it is critical that the state
create sustainable solutions for communities burdened the most by
inequitable land use policies and poor transportation planning. We
believe the target setting process presents an opportunity for
disadvantaged communities to experience co-benefits from greenhouse
gas reductions and equitable land use and transportation planning.

Transportation contributes to 37% of our state’s greenhouse gas
inventory, and the San Joaquin Valley already experiences some of
the poorest air quality in the state and in the country. We believe
that ambitious targets encourage Metropolitan Planning
Organizations (MPOs) to reevaluate land use and transportation
planning to reduce emissions from transportation. The current
targets allow for the continuation of the status quo, which is in
stark contrast with our state’s climate goals. We believe that as
the responsible agency for the implementation of SB 32, the
California Air Resources Board must urge MPOs to create stronger,
more innovative Sustainable Communities Strategies (SCSs), and can
do this by setting more aggressive regional targets.

The Scoping Plan and the target setting process presents an
opportunity for investing in and planning for rural, disadvantaged
communities and maximizing co-benefits to these communities. These
co-benefits include improved air quality and public health,
increased access to reliable, affordable public transit, and
increased connectivity within and to other communities. Many of the
communities throughout the San Joaquin Valley that we work with
lack active transportation infrastructure and public transit
options to help residents access the services they need on a daily
basis. Regions must prioritize projects that reduce Vehicle Miles
Traveled (VMTs) and provide real options for residents in order for
state climate goals to be reached. Additionally, MPOs must consider
models that differ from the traditional modes of public transit to
think more creatively about programs that would fit the distinct
needs of rural communities, such as carshares and vanpools.

ARB must play an active role in ensuring that projects promoting
infill development and investment in existing communities are
prioritized over sprawl development so that regional land-use
planning is aligned with reduction targets. Madera County, for
example, is moving forward with a large residential project in the
northwest area of the county with little to no affordable housing
for low-income residents. This development will arguably increase
VMTs and is therefore in direct contradiction of the intention of
SB 375 and the state’s climate goals as a whole. Higher, more
meaningful targets would provide an incentive for MPOs to make
decisions that are coordinated with the state’s 2030 greenhouse gas
reduction goals and would also encourage MPOs to seek funding for
more equitable projects.

We urge ARB to be more critical of the MPOs reduction target
recommendations and set higher targets to incentivize MPOs to
include stronger programs and policies in their Sustainable
Community Strategies. Ambitious programs will ensure that
disadvantaged communities can experience the benefits that SB 375
intends to provide, and that communities on the frontline of
climate change receive investments to build resiliency.

Sincerely,

Nikita Daryanani 
Leadership Counsel for Justice and Accountability

Dolores Weller 
Central Valley Air Quality Coalition