Comment Log Display

By statute, ARB is required to review each adopted SCS, and make a
determination whether “the strategy submitted would, if
implemented, achieve the greenhouse gas emission reduction targets
established by” ARB.  (Gov. Code sec. 14522.2(b)(2)(I)(ii).) ARB’s
determination must be based on proper modeling methods, as
described in the Calif. Transp. Commission's RTP Guidelines.

The attached report prepared by UC Davis Prof. Deb Neimeier and her
colleague, Dr. Alex Karner, demonstrates that MTC/ABAG did not
consistently model land-use outcomes (pp. 2-6), and did not comply
with the CTC Guidelines (pp. 6-8). The Urban Sim land-use model was
used to forecast the housing distribution for several EIR
alternatives. That was not the case, however, for the preferred
alternative. There, instead of allowing Urban Sim to forecast how
much of the housing distribution would fall within "Priority
Development Areas" (PDAs), MTC/ABAG manually assigned 80% of the
housing growth to PDAs; Urban Sim was only used to model the
distribution of those units within each PDA.

Had the preferred alternative been modeled properly (and
consistently with the alternatives), the resulting housing
distribution would have been far less compact, raising serious
questions about whether the region's GHG targets would be met.  

As a result, it has not been demonstrated that, if implemented,
Plan Bay Area will achieve the region’s GHG reduction targets.

Before ARB determines whether it can approve Plan Bay Area as
meeting the requirements of SB 375, it should review MTC/ABAG's
modeling methods carefully, and provide guidance on necessary
corrective actions.

Attachment:
http://www.publicadvocates.org/sites/default/files/library/ssr_technical_memorandum_5_16_13.pdf