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Here is the conclusion of the attached letter to the ARB:

Targets will have to be more stringent than the AB 32 and S-3-05
target trajectories if we are going to fulfill our world leadership
responsibility and give the world a chance at avoiding climate
destabilization. The 2020 Target of -7% (per-capita from VMT) can
only result in an AB 32 level reduction if both “Pavley” and the
LCFS factors are used. The 2035 reduction target of -13% would have
to instead be 35.15%, to just meet the straight-line trajectory of
S-3-05 for 2035, and this is assuming the Pavley reductions
continue on the “Pavley 1” trajectory all the way to 2035. This
assumption about “Pavley” may be overly optimistic. The
science-supported 2035 reduction is 45%.

The best, largely overlooked strategies to reduce VMT are a
comprehensive and variable road use fee pricing system, as is being
installed by Skymeter; unbundling the cost of car parking; good
bicycle projects and bicycle education; putting a stop to all
freeway expansions; and reconfiguring sales taxes for freeways or
freeway/transit combinations to instead be 100% for transit. These
strategies could easily be implemented by 2020 and would easily
decrease driving by a sum of at least 45%. The strategies to do
this are primarily those that increase fairness for families that
drive less than average.
 
Given this set of conclusions, it is clear that the reductions
proposed for SANDAG are neither just nor reasonable. By extension,
this is true for the reductions proposed for the other MPOs.

Sincerely,
Mike Bullock