Comment Log Display

June 22, 2010 

Mary Nichols, Chairman 
California Air Resources Board 
1001 “I” Street 
Sacramento, CA 95814 

Re: MPO Scenarios and SB 375 targets 

Dear Chairman Nichols, 

Environment Now (EN) greatly appreciates the extensive work that
CARB, the Regional Targets Advisory Committee (RTAC), and the
Metropolitan Planning Organizations (MPOs) have done to implement
SB 375. The planning scenarios created by the MPOs offer a wide
range of approaches to improve land use and transportation planning
to reduce greenhouse gas emissions (GHG) and improve air quality,
public health, housing options, and transportation choices in
California. 

Moving forward, we urge you to ensure that regions adopt truly
ambitious targets and move away from business as usual. While there
are many good examples of planning tools in the MPO scenarios that
could be applied statewide, we also believe that each region can do
more. None of the scenarios include highway or road networks that
are different than already adopted Regional Transportation Plans.
Truly ambitious targets would encourage more: (1) housing growth in
urbanized infill areas; (2) transit, highway, biking, and walking
infrastructure investments; and (3) aggressive pricing measures
before and beyond 2020. CARB should consider developing and
modeling an ‘all-star’ scenario that draws from all of the MPOs’
submissions, highlighting the best of each and applying those
policies/practices across regions.

CARB should carefully evaluate the MPO travel models use in the
scenarios to ensure that GHG benefits fully account for
non-motorized travel (walking and biking). Many of the models used
by MPOs underestimate these benefits. 

We request CARB identify (and include in the draft targets) a set
of performance indicators that address social equity, jobs-housing
fit, public health, land consumption, and other important outcomes.
We believe that the scenarios and draft targets currently fall
short of meeting the RTAC’s recommendations on this subject.
Especially in this economy, strategies that could reduce GHG
emissions while achieving economic benefits for working families,
such as increasing jobs-housing fit and expanding low-cost
transportation choices, should be prioritized. 

CARB should ensure that 2035 targets are a step forward, not
backward. Most of MPO scenarios predict lower levels of GHG savings
in 2035 when compared to 2020 despite the fact that most empirical
evidence says just the opposite. CARB should look carefully at the
models and scenarios to correct this problem. 

We recognize that California's regions and municipalities face
many challenges. The draft targets must be responsive to the
current economic situation, however establishing targets that are
truly ambitious and achievable (especially for the 2035 timeframe)
is needed to motivate local and regional governments to actively
develop a shared blueprint to improve planning and create a better
future. 

Again, thank you for the extensive work you have done. 

Sincerely,
 
Terry O’Day			
Executive Director