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The Draft Plan says that the policies in the Local Govt. Actions
category are uncertain and so only get 2M tons. However, many of
the recommended technical fixes are also very uncertain, such as
Light-Duty Vehicle GHG Standards (delayed by USEPA), Sustainable
Forests (scientifically unclear), and Energy Efficiency (which has
not worked in the past, due to more appliances and also the 
occupants change behaviors).

There is a considerable body of empirical literature and of
modeling studies, sent by me previously to the Local Govt. Actions
category, that largely agree that land use policies can have a
large effect on reducing VMT.  The empirical research and the
modeling studies often show similar effects for each of the 
different policies, such as density, mix, and walkability, that
are in basic agreement re. magnitude of effects. This gives one
some confidence in the results.  Also, many of the modeling
studies in the U.S. and Europe have used advanced urban models
where one can examine policies one by one, or in groups.  These
modeling studies are in general agreement about the effects of
various policy packages, too. 

I urge the ARB staff to treat uncertainty in a more evenhanded
fashion, across these policy areas.  

A more reasonable target for Local Govt. Actions would be 6M tons,
for 2020.  This represents about 1M ton per year of policy
implementation, 2014-2020, which is consistent with the middle of
the pack of the empirical research and the modeling studies. 

Thanks.