Comment Log Display

Thank you for the opportunity to comment on the Draft Scoping Plan
and its appendices.  A great deal of effort and expertise have
been expended to develop this plan in such a short period of time.
 I have been a land use, transportation, and environmental planner
for over 20 years and have watched the debate over climate change
during that time with great interest.  It has now become
imperative that influential governments, such as California, take
decisive action.

Business as usual for the last 60 years has created today’s
problems in California.  Business as usual has resulted in poor
and declining air quality in an increasing number of air basins. 
Although strides have been made toward better air quality in
California, the price has been paid almost exclusively by
stationary sources:  industries such as architectural coatings,
furniture manufacturing, and agriculture.  Significantly, it has
been California's inability to establish controls on vehicle
emission standards and development practices that has prevented
the achievement of federal and state air quality standards,
resulting in significant public health costs and premature deaths
for thousands of Californians.  Government regulations have proven
over the years the only meaningful way to make significant progress
toward achieving important public goals.  Literally nothing is more
important than reducing greenhouse gas emissions and I urge you to
require compact, automobile-independent development to speed the
state toward achieving the worthy goals of AB 32.

As California's population rises from 35 million in 2000 to 55
million in 2000, approximately 33 percent of the new growth in
California is expected to occur in the San Joaquin Valley.  The
Department of Finance projects the population of the San Joaquin
Valley to grow from 3.3 million in 2000 to 5.3 million in 2020 to
9.4 million in 2050.  The San Joaquin Valley has an ample supply
of valuable farmland that serves as a reservoir of cheap land for
automobile-dependent suburban sprawl.

The target of a two percent reduction in greenhouse gas emissions
due to “business-as-usual” development patterns is far too low. 
My own calculations indicate that a target reduction in greenhouse
gas emissions from land use-transportation of more than 11 percent
for the San Joaquin Valley and more than 5 percent for the rest of
the state are achievable by 2020 by simply requiring (1) infill
development (2) in locations planned for more intensive
“alternative” transportation:  bus, rail, bicycling, and walking. 
Using this strategy, the improvements would be significantly higher
in 2050.

Reducing emissions from residential development does not involve
new or special technologies, but simply requires changing the
product type offered and its location.  This is not an unknown
technology:  there are thousands of examples, both new and old, of
urban development and housing product types that support
non-automobile transportation.

The cap-and-trade strategy is commonly used in situations where
pollution reduction occurs via new  technologies and only a small
number of regulated parties are initially able to take advantage
of the new technologies, allowing trading.  This is inherently
unfair, since California has consistently required industry and
agriculture to reduce air pollution emissions over the years,
while requiring no changes in transportation and development
patterns, an enormous potential source of emission reductions.

Which brings me to another point:  the draft scoping plan failed
to account for the transportation of foodstuffs into California to
replace food that would have been grown on agricultural land that
was converted to agricultural uses.  California has recently
become a net importer of food, the transport of which results in
greenhouse gas emissions and increased food costs to Californians,
while also undermining California's economy.  The more agricultural
land that is allowed to convert to urban or suburban development,
the greater greenhouse gas emissions result from food
transportation and the greater the drain on personal income and
the state economy--and the greater the loss of carbon
sequestration potential from agricultural soils and products. 
Eliminating greenfield development and maintaining the current
supply of agricultural land will reduce the distance food must
travel to market, reducing greenhouse gas emissions and food
costs, while preserving an important sector of the economy.  It is
not insignificant that California's demand for agricultural
products increases concomitantly with the population, so the state
can ill afford to allow the continued conversion of agricultural
land to houses.

I believe that the carbon fee strategy (page 41) imposes an unfair
burden on the citizenry after encouraging--or at least not
discouraging--private interests to build in a manner that
inherently results in high greenhouse gas emissions.  The proposal
allows land developers to continue business as usual, consuming
large quantities of agricultural land to create
automobile-dependent developments, then to penalize the people who
buy into these automobile-dependent developments by charging them
carbon fees for behaving the only way they can in their
automobile-dependent developments.  It is fairer and more sensible
to require development to occur in a manner that fully supports
alternative transportation and then penalizes with carbon fees
individuals who opt not to use alternative modes of transportation
that are now convenient due to the low-energy
(non-automobile-dependent) development pattern in which they
live.

To support the necessary sea-change in transportation and land
development and to make the most effective use of dwindling public
infrastructure dollars, California should cease funding
transportation projects that increase roadway capacity for
automobile travel and aggressively move toward funding rail
transportation (freight and passenger), bus travel, and bicycle
facilities, while maintaining the state's current roadway
facilities for personal automobiles.

I believe that any voluntary measures to reduce greenhouse gas
emissions should receive zero emissions credit.  Reducing
greenhouse gas emissions will require substantial changes in the
way we live and only a small number of Californians are likely to
change voluntarily.  In order to create incentives for change, the
state will need to fund transportation and energy alternatives that
are simply more attractive than continuing to live the way we do
today.  Once Californians see that their alternative future is not
so scary, but creates many new, attractive alternatives to
contemporary living, people will be more willing to change their
current lifestyles to a less energy-intensive lifestyle.

The Draft Scoping Plan assumes an expansion of the state's
renewable energy portfolio to 33 percent and also depends upon the
use of "low-carbon fuels" to achieve greenhouse gas emission
reductions in the transportation sector.  This strategy fails to
account for the likely shift away from petroleum-based fuels for
transportation as supplies dwindle and prices increase and toward
electricity or other alternative fuel sources, thus overestimating
the transportation sector GHG reductions from "low-carbon fuels"
and underestimating the need for renewable energy sources.  I
recommend aggressively pursuing research and development of
alternative, renewable energy sources, while creating a
significantly more compact development pattern, which will
position California as a world leader in energy technology, while
reducing California's consumption of energy.

Cindy van Empel, M.A., AICP