Comment Log Display

August 6, 2008

Ms. Mary D. Nichols
Chair
California Air Resources Board 
Sacramento, CA 95814-2719

Dear Chair Nichols:

Recommendations for Improving Draft AB 32 Scoping Plan
 
The Metropolitan Planning Commission (MTC) is the federally
designated Metropolitan Planning Organization (MPO) for the San
Francisco Bay Area. Our core responsibility is to plan and finance
transportation investments for the nine-county Bay Area. In pursuit
of that responsibility, we coordinate our work with that of our
sister regional agencies: the Association of Bay Area Governments
(ABAG), the Bay Area Air Quality Management District (Air
District), and the Bay Conservation and Development Commission
(BCDC).

The four agencies are jointly implementing a Climate Protection
Program to address is-sues related to global warming. Our joint
program recognizes the critical role that urban development and
transportation will have to play in addressing our climate
challenges. It is from this perspective that we submit the
following four recommendations for improv-ing the Draft Scoping
Plan that was released by your agency in June.

1.	Separate Measure #13 “Local Government Actions and Regional GHG
Targets” into two distinct measures with separate emissions
reduction targets. 

Measure #13 as presently structured mixes soup and nuts in a
manner which makes re-sponsibility unclear, complicates the
tracking of progress, frustrates assertive and coordi-nated
action, and diffuses accountability for results. We recommend,
instead, that two distinct measures be created in the scoping
plan.

A “Transportation and Land Use” measure should focus on
coordinated regional/local planning of land use and transportation
development so as to reduce the region’s carbon footprint. This is
a multi-faceted effort involving (a) the regional “blueprint”
processes, (b) local cities and counties as the entities with
specific land-use authority, and (c) re-gional, county-level and
local transportation projects. In administrating this measure, it
is essential that an emissions target be set at the regional
level. Most vehicular travel occurs within the metropolitan
region, frequently crossing local-government boundaries, and
“vehicle miles traveled” reduction goals are not appropriate to
set, measure, or monitor at less than the regional “commuter
shed.”

A “Local Government Actions” measure should focus on community
energy, waste, re-cycling, water and other non-transportation/land
use actions that are appropriate at a city/county scale for
planning and implementation. As the draft plan states, these types
of actions can be expected to provide significant GHG reductions in
addition to those achieved through transportation and land-use
planning. A separate emissions target should be set for these
important local government actions.

2.	Enhance the 2 MMT emissions reduction target currently set for
Measure #13.

A more ambitious target is definitely needed for the strategy
overall—we should not sell its potential short. In addition, some
areas, like the San Francisco Bay Area, have a head start in
thinking about the connection between better integrated land
use/transportation strategies. These regions should be encouraged
to do more/faster. 

Most importantly, we need to start making significant changes now
if we are to achieve the very large emissions reductions required
by 2050. While AB 32 mandates a reduction from the current 14
tons/person to 10 tons/person by 2020, the 2050 target established
by the Governor’s Executive Order pushes us down to 1.5
tons/person! The significant land use changes and VMT reduction
that will be needed for that “California makeover,” must begin
today. Land use changes take time. Therefore it is critical that
we lay the founda-tion between now and 2020. This time period is
also important for producing great devel-opment projects that can
show the way and become our “learning laboratories.”

Therefore, we recommend a “tiered” approach to GHG reduction
targets for these strate-gies:

·	A “basic” target that represents a regulatory floor.  We assume
some “penalty” would be assigned or some supplemental action
triggered for areas that did not reach their share of that mark.

·	An “aspirational” target would be set based on those areas who
are committed and have the capacity to deliver land
use/transportation changes more quickly. 

To reward and motivate such actions, fiscal incentives would be
awarded to those entities pursuing actions at a level commensurate
with the higher aspirational target. These incen-tive could be
drawn from existing sources of state infrastructure assistance
(e.g. transpor-tation funding through the CTC/Caltrans; housing
funds via HCD) OR could be pursued as new funding sources
dedicated for this purpose. 

3.	Move pricing strategies from the “under consideration” list to
the Scoping Plan. 

While land use will take years to provide large reductions in
GHGs, pricing strategies can be implemented in much shorter time
frames and can produce significant results by 2020. One only has
to look at the last year in California to see how higher gas
prices have re-duced driving, increased transit use and spawned a
vibrant public dialogue about a series of related topics,
including housing development. We believe that HOT lanes, cordon
pricing, bridge tolls, parking policies, pay-as-you-drive
insurance and other pricing strategies will have an equally
powerful impact on VMT and GHGs.

Recognizing that the Air Resources Board is under a tight deadline
to complete the final Scoping Plan and not wishing to burden you
with excessive correspondence, we have not elaborated our
recommendations in great detail. Nevertheless, we would be happy
to work with your staff over the next few months if required to
refine how these suggestions could be reflected in the final
plan.

4.	Include an initiative to improve our ability to accurately
measure vehicle miles traveled (VMT) and resultant carbon
emissions.

Finally, to make this process work, the State and the regional
agencies must develop a new, accurate and consistent method of
measuring VMT.  We currently only estimate VMT very indirectly. 
We do not actually measure it.  A process like AB 32 demands
measurement and reporting that is reliable and believable, two
qualities seriously lacking in our current VMT estimates. We must
be able to talk about transportation VMT with the same confidence
that other sectors discuss kilowatt hours, renewable portfolio
stan-dards, etc. ARB and the regional agencies should convene a
working group as soon as possible to recommend the way forward on
this critical technical piece.  To the extent that achieving VMT
reduction targets are contemplated as part of any AB32 regulation,
the application of accurate, consistently applied measuring and
monitoring mechanisms for VMT become especially critical.


Sincerely,


Therese McMillan
Deputy Executive Director