Comment Log Display

The Transportation Solutions Defense and Education Fund, TRANSDEF,
has actively advocated for the regional planning of land use,
transportation and air quality for the past 15 years.  With mobile
sources being the biggest emissions category in the State’s GHG
inventory, we recognize that modifying transportation policy is
absolutely crucial to the success of the Scoping Plan.  But the
Plan has little to offer in this area.

Transportation Policy
We participated in the LUSCAT process as well as the California
Transportation Commission’s Working Group on climate change
additions to the Regional Transportation Plan Guidelines.  These
processes determined that a central part of the implementation of
AB 32 must be a reduction in Vehicle Miles Travelled (VMT).  The
Bay Area's Joint Policy Committee adopted a Climate Change Plan in
which "Reducing Driving" was a central strategy.  We are
disappointed that the otherwise excellent Draft Scoping Plan is
largely silent on this focus. 

The concern, of course, is that the Business As Usual trend for
statewide VMT will overwhelm any successful efforts at GHG
reductions.  Changing that trend will require a profound shift in
how Californians get around.  TRANSDEF recognizes that change of
this magnitude is politically challenging.  What is not clear from
the text of the Plan is whether its authors have made the delicate
political decision to not broach these issues at this time.  If
that is the case, we think the political calculus deserves a
public airing.  Implying that Californians can get through the
challenges of climate change by retrofitting a few CFLs does them
a disservice.  Very difficult choices face our State, and the
sooner we start changing how our billions of dollars of
infrastructure funds are spent, the sooner we will have viable
lower-carbon alternatives to driving.
 
California needs to dramatically change its priorities in
transportation funding.  We need to stop building highway capacity
to accommodate growth in demand for single-occupant driving. 
Instead, we need to start pricing highways to provide appropriate
economic incentives to discourage single-occupant driving, and to
encourage carpooling, walking, biking and using transit.  We need
to invest the savings from ending highway construction, as well as
the proceeds of congestion pricing, in cost-effective transit
networks, including a system of subsidies to enable low-income
people to maintain mobility.
  
The problem is that the State’s transportation policy is focused
on reducing traffic congestion.  As a result, many billions of
dollars are programmed to widen highways.  These projects will
result in easier driving conditions (although the construction
impacts will make driving harder temporarily), which will result
in increased VMT.  Before the State can achieve any significant
long-term reductions in GHGs, it will need to revisit the mission
of the Department of Transportation, and completely revamp its
focus.  The day-in day-out efforts of Caltrans consistently result
in more VMT and more GHGs.  Until Caltrans is formally assigned a
new mission, its ongoing operations will keep making the State’s
emissions worse.

Instead of widening highways, an entirely different policy
direction is possible--one which makes transit readily available
and creates economic incentives to use it.  Our website,
www.transdef.org contains an extensive discussion of the Smart
Growth Alternative we created, which was modelled in the EIR for
the Bay Area’s 2005 Regional Transportation Plan.  Having
struggled with the issue of highway vs. transit orientation for
the past 15 years, we are extremely well aware of the resistance
of local government, not to mention regional government, to
dropping already-programmed “improvement” projects.  However,
given the State’s financial constraints, it should be obvious to
anyone that the State cannot afford to keep widening highways if
it wants to build up the capacity of transit to become a
significant part of the State’s transport system.

If the State wanted to make a maximum effort to reduce GHGs, it
would re-program the STIP and Proposition 1B Bond proceeds
currently assigned to highway projects over to the capital needs
of improved transit.  It would create new climate change fees and
offsets, which will create major new sources for transit
operations funding, the shortage of which is consistently the
biggest obstacle to expanding transit service.  Obviously, change
of this magnitude would require the creation of a strong political
consensus around the need for such comprehensive solutions.  We
raise these comments to stress the point that the problem in
achieving substantial long-term GHG reductions in the
transportation sector is primarily a political one, rather than a
technical one.

High Speed Rail
TRANSDEF is a strong supporter of High Speed Rail for California,
but is troubled by the inability of the High Speed Rail Authority
to produce a credible environmental document and business plan. 
We are part of an environmental coalition that will soon file suit
to challenge the FEIR for access to the Bay Area.  We are concerned
that HSR planning to date has served development interests and not
the goal of achieving optimal GHG emissions reductions.

The State needs to support High-Speed Rail as the future armature
tying together its regions.  This system needs to become the
default mode of choice for interregional travel.  It will also
provide the infrastructure for extensive networks for
intraregional travel.  The development of High-Speed Rail needs to
impose minimum density zoning guidelines as the requirement for
station siting, to catalyze a densification of future growth
around station areas, and a development focus on urban cores.

Other Measures Under Evaluation
We strongly believe the Transportation Measures Under Evaluation
to be essential to the creation of a more sustainable
transportation system--one that provides strong economic signals
to both encourage lower-carbon approaches and discourage Business
As Usual.  We find the emissions reduction entries on Table 22 for
these measures to be extremely conservative.  This is where much of
the 35 MMT of Additional Emissions Reductions from Capped Sectors
could come from.  We urge CARB to bring these measures forward in
the Final Scoping Plan as appropriate for implementation.

Consistent with the National Surface Transportation Policy and
Revenue Study Commission’s recommendations, we support the tolling
of interstate highways in congested metropolitan areas.  This would
both open a new revenue source, to replace shrinking gas tax
revenues, and provide incentives to peak period drivers to shift
to transit, carpooling and off-peak auto travel, thus reducing
peak period traffic congestion and GHG emissions.  (See pages 5-24
through 5-28 of:
http://www.transportationfortomorrow.org/final_report/pdf/volume_2_chapter_5.pdf
)

We are enthusiastic about the potential for Pay as You Drive auto
insurance to reduce VMT.  Feebates will be excellent incentives to
steer purchasers towards lower-carbon emitting vehicles.

We believe ‘Public Education and Programs to Reduce Vehicle
Travel’ to be worthwhile, but very weak in comparison to the
billions of dollars the State spends annually to make driving
easier.  Such a program would need much higher visibility than it
received in the Draft Plan to have any effect at all.  If such a
program were made the centerpiece of the transportation sector
program, it would help call attention to its inherent conflict
with where the State spends its transportation money.

For years, we have been advocating that Indirect Source Rules,
including Mitigation Fees, are needed to correct a tremendous
failure of market economics:  greenfield development is much more
profitable than infill development, yet creates vastly more
environmental impacts.  If the economic playing field were
levelled through ISR mitigation fees, sprawling subdivisions would
not be attractive to developers, and new investment would pour into
downtown areas with transit, where the impacts will be much less. 


TRANSDEF’s Own Strategies
TRANSDEF has come before the Air Resources Board several times to
ask the agency to adopt a list of Transportation Control Measures
that it finds to be Reasonably Available.  Unfortunately, VMT
reduction was not seen back then as an area CARB felt comfortable
in.   The recognition of human-caused global warming, and the
accompanying need to reduce VMT, should change that.  

Because the California Clean Air Act requires non-attainment areas
to adopt all feasible control measures, TRANSDEF believes this to
be the most direct regulatory route to an effective VMT reduction
program.  Once CARB adopts a list of reasonably available TCMs,
air districts will then be required to implement them in their air
quality plans.  We would be pleased to discuss innovative TCM
concepts in detail with CARB.  

Here is one:  Adoption of mitigations for increases in trip
generation and GHG emissions as part of the conditions of local
project approval.  These should include best management practices
in parking, including parking pricing, parking cash-out,
ecopasses, car sharing, unbundling of parking from leases and real
estate purchases, and committed funding for shuttles. 

Here is another:  The single most effective VMT reduction measure
in California has been the Employee Trip Reduction Ordinance. 
Unfortunately, the Legislature rescinded the authority of air
pollution control districts to impose such ordinances when it
adopted Health & Safety Code Section 40717.9, enacted as SB 437. 
To implement effective strategies to reduce employee commute
trips, the Scoping Plan needs to ask the Legislature to revisit
this issue.

TRANSDEF recommends shifting as much goods movement as possible to
rail, as a means of reducing GHG emissions.  This could be
encouraged by offering State funding for capital improvements
through GHG offset programs and regional transportation plans.