Comment Log Display

Comments on the Discussion Draft 2030 ARB Scoping Plan Update  
Steve Smith, Director of Planning, San Bernardino Associated
Governments
ssmith@sanbag.ca.gov
December 16, 2016

San Bernardino Associated Governments (SANBAG) appreciates the
opportunity to provide comments on the December 2, 2016 discussion
draft of the California Air Resources Board (ARB) 2030 Target
Scoping Plan Update.   SANBAG is the County Transportation
Commission and the Council of Governments for San Bernardino
County, serving 24 cities and the County of San Bernardino.  We
were the lead agency on the Regional Greenhouse Gas Inventory and
Reduction Plan and accompanying Environmental Impact Report for San
Bernardino County, prepared in 2014. A number of cities in the
County prepared local Climate Action Plans (CAPs) based on this
work, focusing on 2020 goals and tiering from the regional EIR for
their environmental clearance.  We understand the structure,
benefits, and challenges of GHG reduction planning at the local
level.  Our comments focus on three primary topics:

•	Climate Action with Local Permitting (pages 102 through 105)
•	Transportation Sustainability (pages 48-56), and 
•	Funding (general)

Climate Action with Local Permitting

On page 104, the Discussion Draft makes the following statement:

“The recommended local government goals of six metric tons CO2e per
capita
by 2030 and no more than two metric tons CO2e per capita by 2050
are intended to provide consistency with the 2030 Target Scoping
Plan and the State’s long term goals. Knowing that the per capita
emissions goals may not be appropriate in some jurisdictions, mass
emissions and service population emissions are also important to
discuss. Per the community protocol, a local government should
focus on those emissions that the jurisdiction controls, while
disclosing emissions within its geographical boundary but for which
the local government does not have regulatory authority.”

To date, our Regional GHG Reduction Plan and the targets in our
jurisdictions’ CAPs have been based on percentage reduction of GHGs
from a baseline.  Even SB 32 is based on a percentage reduction of
GHGs from 1990 levels.  A fixed goal of six metric tons of CO2e per
capita is unworkable, as it fails to take into consideration the
baseline characteristics of the climate and other characteristics
of individual jurisdictions.  Home energy consumption, for example,
tends to be lower in coastal communities and higher in the inland
areas and deserts.  

Residents of California have many reasons for living where they do,
and one of the major factors is affordability.  Median home prices
in San Bernardino County are half of the median price in Los
Angeles County and one third of the median price in Orange County. 
Many inland residents may prefer to live closer to the coast, with
a more temperate climate, but cannot afford to do so.  Further, San
Bernardino County has one of the largest concentrations of
disadvantaged communities in the State.  Imposing the same fixed
goal on an inland city as for a coastal city would unfairly burden
the inland communities, and it is likely that the 6 metric ton goal
would be unattainable by 2030 for most inland locations.  In the
spirit of the “ambitious but achievable” language of AB 32, we urge
the language of the Scoping Plan to be modified to express other
specific options, such as percent reductions, not an implied
absolute target.  

Further, we believe that the choice of CAP targets should be made
at the local level and not at the state level.   A
one-size-fits-all target would be inappropriate and
counterproductive. We recognize that the CAP targets should be
related to the 2030 reduction target in SB 32, but the approach
should ultimately be left up to the responsible local agency.  This
has worked well for the original 2020 target, and the concept
should be carried forward to 2030.  

We also appreciate the mention of tiering as a CEQA tool, as this
is a means to see achievement of GHG reduction goals more
holistically, with greater flexibility at a project level.  Having
a project-by-project view, for either development projects or
transportation projects, is an inefficient and restrictive means to
accomplish either GHG reduction or VMT reduction goals.  A tiered
approach can also promote regional goals and policies more
effectively.

Transportation Sustainability

The last paragraph on page 50 begins with the statement:

“While the majority of the GHG reductions from the transportation
sector in this Discussion Draft will come from technologies and low
carbon fuels, a reduction in the growth of VMT is also needed.” 

We agree with this general assessment.  However, ARB should not
under-estimate the challenges nor over-estimate the potential GHG
reduction benefits of VMT-related strategies.  SANBAG has been at
the front lines of VMT-reduction initiatives for a number of years,
through the promotion and funding of ridesharing programs, transit
service improvements, collaborative land use planning with local
jurisdictions and regional agencies, and active transportation
planning and implementation.  

We are now investing in high-capacity transit systems at a level
unprecedented for San Bernardino County, with over $600 million
being committed to capital improvements (i.e. excluding operations)
for passenger rail and bus rapid transit systems over the 10-year
period beginning in 2014.  We have been actively pursuing with the
South Coast Air Quality Management District the opportunity to
implement zero emission light rail service for our nine-mile
Redlands Passenger Rail Project, currently in design, and planned
for operation in 2020.  Even with these major investments and
aggressive policies supporting transit oriented development (TOD),
it is a stark reality that significant reductions in VMT (or at
least slowing the growth in VMT) will come very slowly.  

To illustrate this point, the California population grew by almost
two thirds between 1980 and today.  Over the same period, VMT has
essentially doubled, with a slight dip during the Great Recession.
At the same time, Corporate Average Fuel Economy for light duty
vehicles has increased significantly, by about 45% since 1980. 
This illustrates the power of technology to temper the impact of
population growth.  

Much like the dramatic advancements that have been made in
reduction of criteria pollutants, we believe technology is also the
primary path to GHG reduction.  Freedom of travel, a world-class
goods movement network, and associated economic growth is what has
enabled these technological investments to occur in cleaning up the
air.  The state should be cautious not to apply policies that
restrict travel in a way that would set back the economy.  This
would limit the generation of capital needed to fund the building
energy upgrades, efficiency measures, and penetration of zero and
near-zero emission vehicles that will ultimately drive the
reduction in GHGs.  The more successful we are at reducing the
vehicle-based GHG output, the less important VMT reduction becomes
from a GHG perspective.  

We also appreciate the acknowledgement on page 49 of the importance
of freight.  This relates to our comments immediately above.  For
example, a number of improvements need to be made to our freeway
system to address current freight bottlenecks.  Future state
policy, related to SB 743 or otherwise, should not make it more
difficult to deliver these projects, which are vitally needed to
support our logistics-based economy.

Funding

We also appreciate the acknowledgement on page 24 that:

“California’s strategic vision for achieving at least a 40 percent
reduction in GHG emissions by 2030 is based on the principle that
economic prosperity and environmental sustainability can be
achieved together.” 

We believe this is possible, but the state needs to be wary of
possible unintended consequences of its actions.  We have alluded
above to the care that will be needed in how VMT reduction
strategies are applied, particularly with respect to maintaining
efficient freight flows within and through our region.  About a
third of San Bernardino County jobs are tied to the logistics
economy.  This is particularly important given the substantial
presence of disadvantaged communities, for whom logistics industry
employment is an important gateway to the middle class. 

That said, the costs of achieving the SB 32 GHG reduction goals
will be extraordinary.  Just the ARB Mobile Source Strategy and
State Implementation Plan (SIP) Strategy show costs in the tens of
billions of dollars by 2031.  In pursuing these goals, we need to
be aware that the businesses needed to fund the technological
improvements should not be put in a position of having to choose
between growing their business in California versus moving to or
growing in places where costs will be lower, just so that they are
able to stay competitive in the global economy.  Leakage of
business activity to other states would be an unfortunate result
and would ultimately undermine our ability to generate the capital
needed for the technologies to reach these goals, as stated
earlier.  In other words, we should be careful not to get too far
ahead of the GHG reduction progress in the U.S. overall.  Although
California is the largest state in the Union, we cannot do this
alone.  The federal government should also be player in providing
incentive funding, rather than the full burden falling on
California alone.   

Again, we appreciate the opportunity to comment and look forward to
the receipt of the full draft in January 2017.