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CARB Cap & Trade Comments

Thank you for the opportunity to make these comments. I am the
Manager of Planning for the Capitol Corridor Joint Powers Authority
(CCJPA). My comments come with a background in air quality and as a
twice successful TIRCP grantee. The comments that follow regard
review of grant materials related to disadvantaged and low income
communities but more so, how project benefits will be assessed
during repeated project evaluations. CARB literature on this topic
acknowledges the challenges of accounting for hard-to-quantify
project benefits. This is precisely where I wanted to comment.

Capitol Corridor Intercity Passenger Rail (IPR) TIRCP awarded
projects are a challenge. In nearly all cases that we can envision,
the benefits of a project accrue to some or all parts of the larger
corridor. For instance, we were awarded funds to expand service
between Sacramento and Roseville by two additional round trips. The
physical location of the project is, in this case, mostly in the
Roseville city area but the benefits of the project are purely
operational in nature and the benefits we accrue are two additional
round trips – we get to extend two more trains starting or ending
in Roseville. Once this project goes into service we expect more
ridership due to those two additional round trips. Two more round
trips means our project includes two more locomotives operating
between Sacramento and Roseville and all the locomotive emissions
that can be expected in operations. Whether it is the Roseville
project or other projects that generally aid ridership, the obvious
benefit is to reduce (primarily) light-duty vehicle use by offering
those two additional round trips. The result is less emissions and
hopefully benefits to disadvantaged communities, but how do we
measure all that?

Those light-duty vehicles that no longer make their trips due to
the new train service, we do not know where they are from, which
neighborhood, but we can guess many are from the general Roseville
area. Where would those vehicles no longer be headed? The answer is
quite mixed but many were, if we use the Roseville project example,
probably headed to Sacramento, or Davis, or perhaps further west –
we don’t know precisely but we have some general ideas. The way
ridership is measured is by collected tickets that have origins and
destinations. How ridership goes up or down and is spread across
the provided service is caused by a variety of factors, economy,
gas prices, added frequency, free WiFi on the train, a job
relocation, or no longer having to drop off the kids at school,
thus making a train trip possible, or the reverse, starting to
drive kids to school – the factors are many and complicated.
Drawing out the benefits as TIRCP related, next to impossible, not
to mention assigning that benefit to a specific DAC or two, or
three or all in Northern California.

The metrics by which we have been asked to assess benefits of the
funded TIRCP project falls completely outside any reasonable means
of assigning cause but also location; meaning location in the way
specific communities might benefit. We can suggest answers but the
criteria asked to assess project benefits will generally never be
specific enough to allow CARB to definitively claim clear project
benefit. The only means of getting at this would be to conduct
extensive surveys that draw out such information. The CCJPA did do
this for introduction of free WiFi, but determining that there was
a 2.7% increase in trips on the Capitol Corridor involved a
partnership with UC Davis researchers and a $40,000 budget. We
don’t have the resources to respond to every nuance in ridership
changing and sort it out. Over the FY 15 ridership year compared to
FY 16, our ridership increased 6.8% with only some schedule changes
near the end of the comparative year. That increase exceeds any of
the estimated ridership benefits from each of the two TIRCP awarded
projects and if this happens at any time during the “benefit”
period of our TIRCP projects, how do we claim TIRCP benefits with
this sort of noise in the measurement criteria?

When we get to assessing benefits to specific disadvantaged
communities, the complications in making benefit claims multiply.
Our benefits are always in ridership (light-duty vehicles not
driven) but sometimes those must be offset by locomotive emissions
associated with additional service. If a particular TIRCP project
has locomotive emissions (e.g., the Roseville project does), we can
determine in which corridor those emissions are being emitted and
then each criteria pollutant can be assessed for its impact based
on accepted CARB measurement criteria. This is what is done for
CEQA environmental impact documentation. But for reduced light-duty
vehicle activity, we have no such measure because we do not know
what trip O-Ds were not made due to the project. Using our station
ridership O-D information, we have a general sense of what the
alternative freeway/road routes might have been for any O-D pair
but don’t have that assessment available at a disadvantaged or low
income community level. On a daily, monthly, or annual basis we
can’t say that 27 less light-duty vehicles would have passed
through DAC X, Y, or Z nor can we say that the benefits were for
DAC X were 4.2 times more than DAC Z. We just have boarding a
station and an alighting station and tremendous noise as to if that
was a new non-taken trip because of a particular TIRCP project.

Another complicating factor are the categories of pollutants
themselves. If we divert a light-duty trip, how is benefit measured
for ozone precursors vs particulates? How many miles wide and which
dispersion direction is the source of benefit for each pollutant
type? Do those get assessed at a local to regional scale (depending
on the accepted assessment criteria for pollutant types) along the
trip-shed based on O-D pairs and then we see what DACs might
benefit using general transport patterns? For GHG calculation –
because it is a global scale and just related to non-geographic
calculations, there are no issues. It is not the same with the
criteria pollutants that present the dispersion issues and benefit
assessment challenges.

Given the context I have discussed above, let’s view the present
day criteria used to assess how beneficial a particular project
really is. My answers for just about any passenger rail project are
as follows:

Benefits to Disadvantaged Communities (DAC) (Y/N) – ANSWER – sure,
conceptually there must be benefits somewhere at some level
DAC Census Tracks Benefiting from the Project – ANSWER – every DAC
Census track conceptually in and downwind from the benefit area of
the projects impact but how far do you want to carry that and by
what pollutant?
DAC Criteria Satisfied – ANSWER – Yes in general. The transit
service is better and the pollutants are less because less people
drive so generally all measurement criteria improve qualitatively.
Identify What DAC Needs the Project Addresses – ANSWER – all of
them for criteria pollutants and transit access. Some criteria as
better off than others but generally every thing improves.
Identify How the Project Address the DAC Need – ANSWER – every way
that reduced criteria pollutant emissions help any community and
every way in how more transit or more attractive transit options
benefit people.
Qualitative Description of How the Project Benefits the DAC –
ANSWER – in the same way the project addressed DAC need.
Estimated Total TIRCP Dollars Benefiting DAC ($) – ANSWER – I do
not know how to spread out the investment across DACs and non-DACs

Our concerns discussed above regard over estimating or under
estimating project benefits and the specificity of measuring
project benefits to specific geographic locations. If we respond in
this way, we are doing the Cap & Trade program benefits, but it
would be difficult for CARB to report that these DACs got better
and those other ones did not. There is no accepted means of first,
drawing out the TIRCP benefits, secondly, compartmentalizing
benefits across a corridor, and finally, assigning those benefits
to geographical locations based on criteria pollutant behavior.
Project proponents do not have anything close to the tools or
knowledge that might be applied in such an attempt.

We suggest that CARB consider a different scale of gathering
project benefits and then, based on the nature of the project’s
benefits distributed by the project proponent (aka with varying
intensity along the route) that CARB provide the criteria, by
pollutant, for assessing dispersal to DAC and low-income
communities. If CARB could accept initial project benefit estimates
(which models are used to predict success), then we could “believe
the model” and use that share of benefit (as opposed to sifting out
all the many factors that affect ridership) and disperse that
modeled benefit accordingly. For instance, we can suggest that
project benefits might be applied across a distribution of
locations, more in some and perhaps tapering off the further west
you get in the example of the Roseville service expansion. If the
benefits are distributed across a geography perhaps using GIS then
CARB pollutant criteria and air quality emission and dispersion
models can be used to distribute benefits to DACs and low income
areas. This is just a suggestion but hopefully this sparks some
ideas because the present situation is, at best, intellectually
uncomfortable, inaccurate, and probably not a suitable reporting
tool for legislative purposes.

If you have any questions regarding the points raised, please feel
free to contact me at jima@capitolcorridor.org. Thank you for your
time reviewing and considering this correspondence.

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Original File Name:

Date and Time Comment Was Submitted: 2017-02-01 08:25:04