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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 the land use context in
which transportation occurs is absolutely crucial to the success
of the Scoping Plan.  But the Plan has little to offer in this
area.

The Draft Scoping Plan fails to acknowledge how deeply entrenched
in Business As Usual the system of General Plans, Congestion
Management Plans and Regional Transportation Plans is.  These
plans have massive momentum, which results in ever-increasing VMT.
 Changing the direction of land use and transportation planning is
a very major task.  While there are bright spots, such as SACOG’s
Blueprint process, the coordination of transportation and land use
will only occur if the State steps in with mandates.

Having closely observed the Bay Area’s regional transportation
planning process for the past 15 years, it is abundantly clear
that “recommending” the setting of GHG emissions reduction targets
will not work.  Local governments’ satisfaction with what has
worked in the past has resulted in enormous inertia.  Even with
all the scientific evidence of global warming available in 2008,
an agency like MTC has proven itself utterly resistant to
reconsidering its past commitments to transportation projects,
despite the obvious negative impacts of those projects on GHGs. 

Unless CARB mandates regional targets, agencies like MTC will
remain deeply stuck in Business As Usual, incapable of making the
necessary and difficult decisions to reduce emissions, such as
cancelling politically popular highway programs that increase VMT
and GHGs.  As evidence of its stuckness, MTC refused TRANSDEF’s
request to include in its RTP EIR a Maximum Emissions Reduction
Alternative, which proposed a lower-carbon transportation system
that would require reprogramming resources previously committed. 


TRANSDEF strongly supports regional targets, and urges CARB to
mandate a specific reduction target for each region, based on a
per capita reduction for existing residents and a higher per
capita reduction for future residents (who would be expected to
adopt a lower-carbon lifestyle as a result of improved community
design).  We believe a mandate is needed to create the political
space in which fresh thinking can occur.  Our experience is that
local government planning moves in an evolutionary and incremental
manner--an arc that does not work when a profound challenge like
global warming requires drastic change.  With mandated regional
targets, the local jurisdictions within each region will then be
encouraged to negotiate with each other to create a consensus plan
to achieve their regional target in the most mutually acceptable
fashion possible.  This kind of process will encourage the kind of
‘blank sheet of paper’ thinking that is needed when coming up with
comprehensive creative solutions.

TRANSDEF urges CARB to raise with the Legislature the issue of the
future role for Congestion Management Agencies.  These
legislatively created agencies are mandated to reduce congestion. 
They have become the institutional driving force for highway
widening projects within California.  These projects and the
development they facilitate, however, are central to the State’s
trend of ever-increasing VMT.  In a letter last year to MTC, Bay
Area CMAs declared that climate change should not be considered in
regional transportation planning.  The subtext was that they should
be left alone to work on their highway projects.  CMAs as
institutions are inherently hostile to assisting with the
implementation of AB 32.  They do not see themselves as having a
mandate to “partner with regional planning agencies to create a
sustainable vision for the future that accommodates population
growth in a carbon-efficient way.“ (Scoping Plan, page 32).  We
believe that legislatively changing the mission of CMAs will be
crucial in shifting the politics of regional transportation
planning agencies to support reducing mobile source GHGs.

Original File Name:

Date and Time Comment Was Submitted: 2008-08-01 14:24:46