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Comment 33 for Public Workshop on the Transportation Sector to Inform the 2030 Target Scoping Plan Update (scoplan2030trnspt-ws) - 1st Workshop.


First Name: Wesley
Last Name: May
Email Address: wfmay3@gmail.com
Affiliation: Engineering Contractors' Association

Subject: Vibrant ommunities and Landscapes
Comment:
Re: Public Comment on Vibrant Communities and Landscapes 

The Engineering Contractors’ Association respectfully submits the
following comments on the draft state agency vision statement
entitled Vibrant Communities and Landscapes.
We recognize that as a “vision statement” that this document has no
legally binding authority, but is more in the nature of a trial
balloon to express the state’s approach to climate change under the
vision of Governor Brown and his allies in the environmental
movement in our state. 
We want to assure you, the governor, the various state employees
and the invited environmentalists who drafted this policy plan that
we are in favor of a balanced approach to safeguarding the future
growth, prosperity and health of all Californians, current and
future. 
Unfortunately, balance is the key ingredient missing from the
prescriptions outlined in the list of “Actions” proposed.  While
vigorously espousing concern for socio-economic equity for
communities it would destroy the dream of the residents of those
places to own a home of their own, with a command and control
approach to in-fill housing that would condemn them to Soviet-style
apartment blocks.
For those Californians already occupying the 6, 883, 493(1)
single-family homes in our state, this vision would condemn them to
an eternity trapped on our freeways under the “road diet” plan
expressed in the referenced companion “discussion document” on
vehicle miles traveled(2) which is the backbone of your comments
regarding transportation.
For the three million Californians over the age of 65(3), among the
fastest growing segments of our population, you offer a
prescription of “active transportation,”—walking or bicycling—to
meet their needs for food and medical care, not to mention trips to
friends, family or other venues, not a very golden age prospect.
The “vision statement” lacks any supporting documentation to
demonstrate the efficacy of the policy prescriptions that it
outlines, not to mention the alleged “benefits” that make up a
fourth of the ideas expressed in the paper.  We have to assume that
you have at least some of this material, but since there was no
public input to the plan, other than that from the “invited”
environmentalists, which is a critical failing in the state’s
approach in this document.
Oddly enough, California state government action is still a
democratically controlled effort and the rule of law still applies.
 Based on that, visionary assertions such as the goal of an 80
percent reduction in greenhouse gas emissions by 2050 are not
official state policy, other than from executive orders issued by
the current governor, which can be repealed by a future governor.
The current state legislature has specifically recoiled from such
an extreme measure, making sure it was not contained in the
recently passed SB 32. 
We are confident that the eight-agency approach to regulatory
control expressed in your vision statement will be recalled and
retooled, opened to public scrutiny and participation and brought
before the Legislature before it is enacted. Then, the full process
of the state’s Administrative Procedures Act can be brought to
bear, complete with full Brown Act compliance so that no more
backroom bureaucratic deals will be struck with favored
constituencies. 
Balance between the goals expressed in the rough draft Vibrant
Communities and Landscapes and the real needs of California and its
citizens will be a paramount consideration.  We recommend the
following.

1.	 Immediate withdrawal of the proposed policies, including a
companion policy issued earlier this year to expand the California
Environmental Quality Act (CEQA) to impose a statewide “road diet”
and make the act of driving one mile in a car or pickup truck an
adverse new environmental impact.
2.	A commitment to obtain Legislative authorization prior to taking
any agency action in furtherance of the non-statutory 80% GHG
reduction target in any sector. 
3.	A commitment to engage in formal rulemaking prior to proposing
or adopting any plan, policy, or regulation that modifies existing
regional GHG reduction targets established under SB 375 in the land
use and transportation sectors. 
4.	A commitment to use all available state resources and authority
to timely complete transportation and infrastructure improvement
projects approved by California voters, and transportation and land
use plans and policies approved by local and regional agencies,
that are consistent with the state’s approved SB 375 GHG reduction
targets and Sustainable Communities Strategies, and to refrain from
applying any new state policy, plan or regulation that would
increase costs or otherwise increase regulatory obligations,
burdens or risks on these voter-approved and SB 375 compliant
projects. 
5.	A commitment to fully disclose and analyze the social, equity,
economic, employment, and global (not just California) GHG
consequences, to complete a comprehensive environmental impact
report under CEQA, and to seek express Legislative authorization,
prior to taking any action to modify any regional SB 375 targets or
otherwise adopting any policy, plan or regulation that would
increase the compliance costs, litigation risk, or cause any
further delay, in the implementation of SB 375-plan compliant
projects, policies and plans. 


Sincerely,

Wesley F. May
Executive Director
Engineering Contractors'Association
2190 S. Towne Centre Place Ste. 310
Anaheim, CA 92806



Attachment: www.arb.ca.gov/lists/com-attach/67-scoplan2030trnspt-ws-UyVcM1U2ByYHYAJs.pdf

Original File Name: Vibrant Communities Landscapes - Public Comments.pdf

Date and Time Comment Was Submitted: 2016-09-28 16:09:37



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