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Comment 3 for State Government Comments for the GHG Scoping Plan (sp-stategov-ws) - 1st Workshop.
First Name: Steven
Last Name: Goetz
Email Address: sgoet@cd.cccounty.us
Affiliation: Contra Costa County
Subject: State Government
Comment:
A key element of the Scoping Plan is implementation of existing State laws and policies. This element needs to go beyond clean car standards, goods movement measures, and the Low Carbon Fuel Standard. Appendix C refers to a strategy for locating State facilities based on the State’s planning priorities as embodied in Chapter 1016 - Statues of 2002. Construction of prisons, court facilities, colleges, universities, water storage and conveyance facilities, state office buildings, elementary and secondary schools as approved by the State Architect, all have significant influence on the land use policies, development pressures and travel behavior at the local level. This law requires each Governor’s Budget to include a 5-year infrastructure plan. The Governor is also required to prepare and maintain the State Environmental Goals and Policy Report (EGPR). State agencies are to show how their project in the infrastructure plan are consistent with the EGPR. The public outreach and educational component of the Scoping Plan needs to make these documents more visible so the public can understand the sound environmental planning behind the capital facilities supported by each State budget. Has a greenhouse emission reduction goal been included in the EGPR? Is the State measuring and tracking compliance with this statute? Has preparation and maintenance of these documents been acknowledged in applicable State administrative manuals? Should development of the EGPR and the infrastructure plan be coordinated with the activities of the Governor’s Strategic Growth Council? Can a copy of the most recent infrastructure plan and EGPR be made available for review by the public and local jurisdictions and other interested stakeholders? Future GHG reduction efforts for State facilities should be expanded to include a review of the management of parking spaces owned or leased by the State. The Contra Costa County Climate Action Team is evaluating the feasibility of establishing a user fee for parking spaces owned or leased by the County and allocating any surplus revenue to incentives for use of commute alternatives. User fees would eliminate any subsidy that may exist for motorists who do not pay for the cost of the parking they use. Any revenue in excess of the cost to provide the parking could be used to provide improvements to transit service or made available to employees to help pay for their commuting costs. There is a substantial body of studies that shows parking charges can significantly influence commuter behavior. This strategy should be coordinated with potential future efforts listed under “employee practices” on page C-178, and other relevant state regulations such as Executive Order D-73-8 which requires State agencies to implement a transportation management program designed to result in an annual reduction in the number of commute trips by State employees. The description of proposed measures to address “the State’s Carbon Shadow”, which begins on page C-179 needs more detail in the following areas: • The State’s standards for the design of school and medical facilities currently emphasize requirements for buildings and support facilities. Equal emphasis is needed on requirements for site selection and the siting of these facilities in the community to ensure convenient access by transit, walking or bicycling. The criteria used by the State for awarding funding for facility construction should place greater weighting of facility siting in the community and transportation criteria. Some of these recommendations were in the report submitted by the Land Use Subgroup of the Climate Action Team (LUSCAT) but do not appear in the Scoping Plan. • The standards adopted by the State Fire Marshall need to be evaluated for their impact on GHG emissions and community design. The current requirements for fire access roads are based on operation of a standard multi-purpose fire/paramedic vehicle. These standards should encourage flexibility to allow the use of smaller vehicles that are compatible with more pedestrian-oriented street construction. • The Air Resources Board (ARB) needs to improve its administration of the parking cashout program, Chapter 554 - Statutes of 1992. This law requires certain employers who provide subsidized parking for their employees to offer a cash allowance in lieu of a parking space. Parking cashout offers the opportunity to reduce GHG emissions by reducing commute trips. The ARB is the agency authorized by the Legislature to interpret and administer the parking cash-out law. Their administrative efforts have been limited to preparation of an informational guide to help employers determine whether they are subject to the requirements of the law. This “self-implementing” approach by the ARB has resulted in few employers offering a parking cash-out program to their employees. As the appropriate regulatory authority the ARB should, in consultation with affected stakeholders, revise its administrative efforts to increase participation among employers and advise cities and counties on conditions they can impose on new development to expand the application of this statute on employers (e.g. require project sponsors to prepare CC&Rs for the project to ensure parking and building leases are unbundled and that financial compensation to affected occupants is provided as required by applicable state law)
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Date and Time Comment Was Submitted: 2008-08-01 16:34:35
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