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The East Bay Bicycle Coalition strongly encourages the Air
Resources Board to adopt the highest targets for reducing
greenhouse gas, and does so in a way the reasonably brings the
State of California into attainment of the year 2020 goals of
reducing GHG's to the levels of 1990. We also strongly encourage
you to adopt absolute GHG target reductions and not "per capita"
reductions. Per capita reductions are not actually reductions, as
MTC Executive Director Steve Heminger explained at the July 28,
2010 MTC Commission Meeting that per capita is not a reduction at
all. AB 32 and SB 375 call for absolute reductions. Please revise
your methodology to reflect real reductions in GHG's from the
transportation sector.

Thank you very much for your consideration of these comments.

Dave Campbell
Program Director
East Bay Bicycle Coalition
www.ebbc.org
Office: 510.845.7433
Email: dave.campbell@ebbc.org