Comment Log Display

On behalf of a wide variety of business, labor and community
interests – including the California Building Industry Association,
National Federation of Independent Business- CA, and many others  –
we would like to ask for your help on an urgent matter. The
California Air Resources Board has proposed greenhouse gas emission
reduction targets under SB 375 that are extremely restrictive, and
ultimately impossible to meet. The targets would result in massive
cost increases for the average family and small businesses, would
place huge financial and infrastructure burdens on local
governments, and would open the business community to unbearable
lawsuits and restrictions on development. Experts at regional
planning organizations have forecasted that these high regulations
will result in negative impacts that will harm our state’s
residents and our economic recovery – for example:

 

·         $9.07 per gallon gas prices

·         Congestion fees in metropolitan areas

·         Taxes on vehicle miles traveled (VMT)

·         Parking fee increases in local municpalities

·         Relocation of 200,000 people into the city centers.

 

We need your help! The California Air Resources Board is set to
vote on these targets next Thursday, September 23rd. You can help
in the following ways:

·         Email the members of the California Air Resources Board
telling them to adopt more achievable targets in 2020 and to delay
adopting 2035 targets until more comprehensive analysis of economic
impacts is conducted. You can email the board members at 
arbboard@arb.ca.gov  and the chair Mary Nichols at
mnichols@arb.ca.gov. You can also call the California Air Resources
Board at (800) 242-4450.

·         Over 70 organizations from across the state have joined
this effort. To add your name to the effort and this letter please
reply to this email.

 

What Happened?

After a series of public workshops focusing on setting realistic
targets for greenhouse gas emission reduction, the California Air
Resources Board (CARB) staff unexpectedly proposed unreasonable and
unachievable targets that will impede economic recovery and impose
major financial burdens on local communities.  During the
stakeholder process, the Metropolitan Transportation Commission
(MTC), the planning, coordinating and financing agency for the
nine-county San Francisco Bay Area, stated that they could achieve
a 5% reduction in 2020 and 5% reduction in 2035. However, CARB’s
recommendation set more extreme target levels of 7% for 2020 and
15% for 2035. Similarly, the Southern California Association of
Governments (SCAG), which is the metropolitan planning organization
representing six counties, 190 cities and more than 19 million
residents, recommended a realistic target range of 6-8% for 2020
and 3-6% for 2035. But CARB set the Southern California levels at
8% for 2020 and 13% for 2035. 

 

Major Economic and Lifestyle Impacts

·         Consumer costs.   According to the MTC‘s professional
staff evaluation of Bay Area impacts, the extreme targets proposed
by CARB would result in massive price increases for families and
businesses.

·          Increased gas prices: The MTC concluded that even a
target of 12% (let alone 15%) would require gas prices of $9.07 per
gallon to encourage less driving.

·         Congestion tax: The MTC would have to institute
congestion fee pricing of $0.25 per mile for using freeways during
peak periods – resulting in a 460% annual increase to travel costs.
 

·         Parking fee increases:  Parking costs across the state
would be increased by $1.00 per hour. 

·         Overall, CARB’s targets would increase auto operation
costs by five-fold. 

·         Population relocation.  CARB’s targets would force people
to abandon suburban life-styles and move into city centers with
higher population density. The MTC projected moving 200,000 people
out of the suburbs and into the city center to meet the targets. 

·         Lack of funding.  Local governments simply do not have
the funding to support the infrastructure needs nor the planning
activities that would be required under the targets. Already local
governments have to cut budgets and reduce public transit service –
there is no guaranteed additional funding to support the new
transit needs that would be necessary to meet the targets. 

·         Potential loss of federal funds.  The unrealistic
regional planning processes required under the SB 375 could likely
result in the additional loss of federal transportation funding for
local governments. 

·         Faulty assumptions.  CARB’s emission reduction targets
rely on the fruition of future high-cost transportation projects
that are still in early development phases. Without these projects,
the targets are even further out of reach. These projects include
high speed rail, high occupancy lanes, toll roads, etc. 

 

Preventing Economic Growth, Creating Uncertainty

·         Counting on a poor economy.  The GHG reduction targets
rely on a poor economy and lower jobs as a tool for meeting their
strict emission reductions.  According to MTC’s analysis,
forecasting and planning for fewer jobs and less economic growth
could result in 5% emission reductions 

·         Uncertain regulatory process.  CARB has released targets
that are unreasonable, but has established an alternative process
to re-evaluate these targets.  This uncertainty over the targets is
detrimental because businesses need certainty and clarity in the
regulatory requirements in order to support investment decisions
regarding location, expansion and operation. 

·         More lawsuits.  The infeasible targets could be used to
justify even more lawsuits designed to stop any new development.
With extreme emission reduction requirements, businesses will be
forced to pay huge fines, implement expensive and unreasonable
mitigations, and possibly face lawsuits that could stop their
development altogether if it is determined to be too far outside
the city center. 

·         Preserving the recession. Unreasonable restrictions on
development, construction and home building will prevent our
economy from rebounding and harm efforts to reduce the state’s high
unemployment numbers. 

 

Flawed Process 

SB 375 was passed in 2008 to address regional planning for
transportation, housing and greenhouse gasses. CARB set forth on a
collaborative process that engaged officials at the local level to
identify emission reduction targets associated with land use and
transportation that are both ambitious and achievable. Regional
Metropolitan Planning Organizations (MPOs) were in charge of
recommending emission reduction targets that they forecasted to
meet the goals of SB 375. However, CARB staff disregarded the input
and analysis provided during the stakeholder process, and instead
have proposed completely unrealistic reduction targets that were
not even discussed or modeled.

·         Targets not evaluated.  The SB 375 process included
numerous public workshops to examine emission reduction targets
that would be both ambitious and reasonable for local governments.
The MPOs evaluated target ranges, and determined that the
aggressive targets being explored were overly ambitious and simply
not achievable. However, CARB’s targets were even higher than the
most aggressive options mentioned in the workshops. 

o   In Northern California, the Metropolitan Transportation
Commission (MTC) modeled their most aggressive target at 12% GHG
reduction by 2035. The MTC highlighted that the most aggressive
targets are “not considered attainable by any stretch of the
imagination.” Despite this warning, CARB’s suggested target for the
Bay Area is 15% by 2035

o  The Southern California Association of Governments suggested
that a GHG reduction of 5 or 6% by 2035 is attainable. They
forecasted that GHG reductions above 10% by 2035 are considered too
ambitious and unattainable. However, CARB’s suggested target for
the region is set at 13% by 2035. 

·         No basis for last minute change.  There is no explanation
as to why CARB moved way beyond the targets discussed in the
workshops. They ignored public input and expert testimony, and
adopted extreme targets that were never vetted in the public
process. 

·         Ignores realistic human costs.  Each incremental
percentage reduction for emissions is exponential. Therefore each
percentage increase in the targets requires huge behavior changes
and skyrocketing costs.  

 

 

We need your help! Please contact us at dsubers@ka-pow.com  to find
out more, or to add your name to this effort!