First Name: | Cynthia |
---|---|
Last Name: | van Empel |
Email Address: | cvanempel@gmail.com |
Affiliation | |
Subject | Land use and transportation, agriculture, cap and trade |
Comment |
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 |
Attachment |
Original File Name:
Date and Time Comment Was Submitted: 2008-08-11 10:39:31 |
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