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Comment 51 for Land Use Comments for the GHG Scoping Plan (sp-landuse-ws) - 1st Workshop.


First Name: Stuart
Last Name: Cohen
Email Address: stuart@transcoalition.org
Affiliation: Transportation and Land Use Coalition

Subject: Land Use/Regional Targets Recommendations
Comment:
COMMENTS ON AB 32 DRAFT SCOPING PLAN

July 31, 2008 

California Air Resources Board Members and Staff:

The Transportation and Land Use Coalition, a partnership working
for World Class Transit and walkable communities in the Bay Area
and beyond, applauds the Air Resources Board’s comprehensive and
ambitious draft AB 32 scoping plan.  For many sectors it will
propel California into a leadership position on both the national
and international stage.

Unfortunately the one place that it truly falls short is on the
reduction targets for “Local Government Actions and Regional
Targets”. The draft scoping plan calls for only 2 million metric
tons (MMT) of GHG reductions from regional targets.  In 2006,
California’s Climate Action Team (CAT) predicted the State to
eliminate 9 MMT from this sector from “blueprint” programs alone.

The 2 MMT is equivalent of a 2% decrease in per capita VMT by
2020.  If the number was calculated simply on the new increment of
growth that will take place between 2010 and 2020 – in other words
existing residents will continue to drive as much as they do today
– then this decrease may be a reasonable estimate.  

However, there are tremendous potential efficiencies to be gained
from transportation pricing, new transportation infrastructure,
and education and incentive programs.  Some of these programs are
acknowledged in the scoping plan and are listed as "under
evaluation”.  These include the Indirect Source Rule,
Pay-As-You-Drive Insurance, Congestion Pricing, and
Education/Incentive Programs.   The scoping plan acknowledges that
these could bring up to another 4 MMT.  

In the scoping plan appendices there are a host of additional
programs that are discussed and essentially we believe these
should all be undertaken.  

We encourage CARB to make the following revisions to the Scoping
Plan:
	CARB should set a higher reduction target for “regional
targets” based on VMT (Vehicle Miles Traveled) reductions. We are
working with ClimatePlan members and national experts to determine
the potential reductions and will have that analysis to you
shortly. 

	Transportation efficiency measures should not be
separated out from these “regional targets”.  Since multiple
programs are likely to be introduced at the same time, it will be
very difficult to know how much benefit to assess each strategy. 
This is congruent with a “regional blueprint” approach that
simultaneously considers land use scenarios along with
transportation systems, pricing and operational scenarios.  

	Regional targets should be distinct from local government
targets.  Local government actions and regional targets are
currently combined.  Any local government actions that can reduce
VMT, such as programs to increase transit are carpooling use, or
improved community design, should be captured under the regional
targets section.   There is an obvious danger of double counting,
or simply creating burdensome and inefficient measurement
protocols by combining these strategies together.  It is possible
that some of the other local government strategies can be counted
separately, such as recycling or community energy, but it seems
that in all of these areas the issue of double counting remains.

	CARB should allocate transportation GHG targets at the
regional scale and set interim milestones to gauge whether each
region is on track to achieve the targets

	The plan should make it a top priority to invest in and
sustain public transportation and programs to improve
transportation efficiency and reduce congestion. While CARB cannot
do that through the state budget process there may be ways to
enable the state or regions to raise additional funds for climate
friendly transportation programs from carbon-based revenue.

	Cities, counties and regions should be given incentives
to conserve forests and working landscapes that sequester carbon,
provide local food, and reduce wildfire hazard. 

	Municipalities should be given additional financial and
technical resources to develop climate-friendly specific plans,
general plans, etc.  

There is agreement amongst a broad range of stakeholders that we
need to move to a smart land use paradigm as California adds
another 20 million new residents or more by 2050.  There is also a
growing movement towards regional cooperation, with all major
regions in the state undertaking blueprint planning over the last
seven years 

While all stakeholders might not agree on the strategies, that
should not make CARB timid about addressing this in the scoping
plan.  We believe it is possible to have flexible implementation
strategies that can be adapted by each region, and still meet much
higher reduction targets than were sent out by the draft scoping
plan.

There is, understandably, concern about how reductions targets in
this sector can be enforced.  In other words, what would CARB do
if a region had a blueprint and was implementing a variety of VMT
reduction strategies but was not meeting its GHG/VMT milestones by
2015, 2017, or some other date? 

One possible direction is to rely on a few scalable implementation
mechanisms.  These mechanisms would provide valuable resources to
regions as they work to reduce VMT, promote walkable communities,
and protect valuable farmland and open space.  They could include

•	An Indirect Source Rule that promotes lower-carbon community
design and provides financing for planning and projects that are
climate-friendly.
•	public goods charges on gasoline to fund alternative
transportation, 
•	container fees to fund low-emission goods movement, or 
•	congestion pricing as a way to raise revenue for transportation
alternatives while helping manage demand.  
These tools would essentially represent additions to the very
limited toolbox currently available to cities, counties and
regions.  

Some of these measures could initially be voluntary or set at
modest levels. With others, such as road-pricing mechanisms, the
state could simply provide statutory authority that would allow
regions to choose whether and how to implement these programs. 

Then, CARB would measure VMT at certain milestone years, and if a
region is not meeting these milestones then some of these tools
could be strengthened or “scaled up” in order to achieve greater
GHG reductions.   For example, the GHG per capita threshold for
the Indirect Source Rule in that region could be reduced or the
container fee increased to fund additional goods movement. 

Since all of these programs utilize efficient market mechanisms
and pricing signals -- they put a price on high-carbon activities
and use that funding to incentivize low-carbon alternatives --
there should be strong economic, social and public health benefits
from their implementation.  These benefits would include
significant traffic congestion reduction, lower overall
transportation costs as more people gain access to affordable
alternatives, cleaner and faster goods movement, reduced
particulate matter in local communities, and more.  

Each of these programs should contain measures to ensure
significant benefits accrue to low-income communities, and that an
equity analysis is conducted to ensure the benefits to these
communities are at least as great as any cost.

We must do everything possible to prevent global warming’s most
disastrous consequences and costs, and a stronger land use section
would not only help us achieve the 2020 reduction targets, but set
us on a more clear trajectory towards reducing emissions 80% by
2050.  We look forward to working with you as you finalize the
scoping plan and develop an implementation plan that can improve
the quality-of-life for all Californians while setting an
extraordinary model for the world.  


BY: Transportation and Land Use Coalition
Contact: Stuart Cohen, Executive Director
510-740-3150 Stuart@transcoalition.org

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Date and Time Comment Was Submitted: 2008-08-01 16:00:51



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