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Comment 9 for 2030 Target Scoping Plan kickoff workshop (2030targetsp-ws) - 1st Workshop.
First Name: Michael
Last Name: Bullock
Email Address: mike_bullock@earthlink.net
Affiliation: Elected to SDCDPCC
Subject: CARB Scoping of B-30-15 & Climate Stabilization
Comment:
My letter and 4 reference files are in the attached zip files. In case that doesn't work, here is the letter: Mike Bullock mike_bullock@earthlink.net 1800 Bayberry Drive Oceanside, CA 92054 October 15,2015, 2010 Air Resources Board 1001 I Street P.O. Box 2815 Sacramento, California 95814 SUBJECT: Car and Light-Duty Vehicle (LDV) Considerations of Joint agency workshop to initiate discussion of an update to the AB 32 Scoping Plan to reflect the State's "40% by 2030" GHG emission reduction target Dear Air Resources Board Chair Mary Nichols and Members of the Board: 1.0 Introductory Comments Since this is a technical topic, I feel I should list some of my qualifications. I have a BSEE degree, and an MSE. I am a retired satellite systems engineer, and a guest lecturer at UCSD on the topic of climate and transportation. I have authored two papers at the Air and Waste Management Association (AWMA) on how cars and light-duty trucks could achieve climate-stabilizing targets, in California. I have also coauthored an AWMA paper on car-parking policy. Regarding climate, it is time to be brutally honest and open. You have a responsibility to explain the difference between climate stabilization at a livable level and climate destabilization, where the positive feedbacks become dominant; we lose the ability to prevent disaster; and the climate changes to one which will not support most life forms on the planet, including our own species. A 2008 issue of Scientific American, The Ethics and Economics of Climate Change, describes our situation as heading towards a “devastating collapse of the human population.” A reasonable climate stabilizing target for 2030 is 80% below 1990 levels; not the 40% below 1990 levels of B-30-15. My AWMA paper, Reference 1 of this letter, derives the 2030 climate of 80% below 1990 levels (see also Reference 2), using Reference 3. However, the B-30-15 target is seen to be too little by your own, Scoping Plan, words, for which I thank you deeply and sincerely (emphasis added): B. Achieving Climate Stabilization Scientific research indicates that an increase in the global average temperature of 2°C (3.6°F) above pre-industrial levels, which is only 1.1°C (2.0°F) above present levels, poses severe risks to natural systems and human health and well-being. Considering knowledge from the paleo-climate record with changes currently observed in the Greenland and Antarctic ice sheets, we can expect substantial sea level rise, 0.4 to 0.8 meters, with upper end uncertainties approaching one meter above present day during the 21st Century and continued substantial increase after 2100 even with stringent mitigation of emissions to achieve 2°C stabilization. Increased climate extremes, already apparent at present day climate warming (~0.9°C), will no doubt be more severe. To have a good chance (not a guarantee) of avoiding temperatures above those levels, studies focused on a goal of stabilizing the concentration of heat-trapping gases in the atmosphere at or below the 450 parts per million (ppm) CO2-equivalent (CO2e, a metric that combines the climate impact of all well-mixed GHGs, such as methane and nitrous oxide, in terms of CO2). The CO2e target is a somewhat approximate threshold, and the exact level of CO2e is not precisely known because the sensitivity of the climate system to GHGs has uncertainty. Different models show slightly different outcomes within this range. An example of a pre-IPCC assessment study (Meinshausen et al. 2009)15 which has synthesized many studies on climate sensitivities, concluded that we would need to stabilize at about 400 ppm CO2e in order to likely avoid exceeding the 2°C threshold (even at that stabilization target, there is still about a 20 percent chance of exceeding the temperature target). Further, a recent paper by an international team of scientists (Hansen et al. 2013)16 asserts that the widely accepted target of limiting human-made global climate warming to 2°C above preindustrial levels is likely too high and may subject future generations and nature to irreparable harm. Recognizing this fact, the international community agreed in meetings in Cancun in 2012 to review, by 2015, progress to the 2°C target and consider whether it should be strengthened to a 1.5°C threshold. Regarding the emphasized words, as we all know, the atmospheric level of CO2e already exceeds 400 PPM. The kicker here is that it may be that the 1.5°C threshold is what we should have been working to from the start. We need the reductions to be as soon as possible and as large as possible. The AB 32 words come to mind that all mitigations are needed that are “technologically feasible and cost effective.” CARB can use Reference 1 to show how a systems engineer would solve this problem. Part of the Reference 1 solution was the required per-capita driving reduction 2.0 Comments Regarding Your Appendix C - Focus Group Working Papers, 1 March 14, 2014 As near as I can tell, Appendix C is all true. It is useful. Thank you for the work. However it needs to be much more quantitative. The LDV fleet-efficiency must be quantified and the LDV per-capita driving level that is associated with the derived fleet efficiency must also be shown. The strategies and mitigation measures to reduce driving must have driving-reduction estimates associated with them and the total must equal what is required. Parking Policy and a Viable State Strategy In order to solve this climate problem (how LDVs can support B-30-15), CARB must focus on how to get improved methods of how we pay for parking widely implemented. The damage from bundled-cost parking (often called “free”) must be fully mitigated, in nearly all cases. This paper, Reference 4 of this letter shows how this can be done: http://www.sandiego.gov/environmental-services/pdf/sustainable/parkingcosts.pdf. Regarding parking, this is one of the two most-promising entries (Page 18, emphasis added): A new coordinated policy and planning approach should utilize all available means, including, but not limited to, regulations, regional planning, enforceable agreements, project mitigation, and a sustained commitment to incentives (e.g., grants, vouchers, rebates, parking or transit benefits, high occupancy vehicle lane access, etc.). Each of these can play a strategic role in implementation of the vision for transportation. Here is the second (Page 21, emphasis added): In order to expedite the proliferation of equitable TODs and other infill, it will be necessary to break through common barriers created by federal, State, regional, local, and private sector policies and practices on financing, environmental review, parking, and other issues. Here is the third (Page 23, emphasis added): Continuing to promote employer-based transportation solutions such as facilitated carpooling and parking cash out would allow employees more options to reduce commute-related VMT. Finally, here is the fourth (Page 24, emphasis added): Given the urgency of the necessary transition, policy measures will be needed to increase incentives in varying forms and decrease operating costs. In addition to financial incentives, other equally effective incentives can take the form HOV lane access, preferential parking, among other approaches. None of these 4 statements regarding parking show sufficient thought, considering what is at stake and the fact that parking is generally operated in a way that is unfair, economically. Parking is required by local governments and legislation will eventually be needed to stop the unfairness, not to mention the harmful climate implications. However, what is needed first is a demonstration project of a reduced-feature (compared to the Reference 4 system) system. Road Usage Charge (RUC, see SB-1077) The authors of Appendix C have overlooked the fact that the gas tax is already being subsidized heavily by general taxes and this can’t continue, given our urgent need for improved fleet efficiency. Reference 1 shows how fast we must adopt zero-emission vehicles (ZEVs) over internal combustion engine vehicles (ICEs). Reference 5 shows that the state is developing a Road Usage Charge pilot project. I am disappointed that CARB is not participating to ensure that this work will support a system with the features needed to both protect low-income drivers and contribute significantly to solving our climate crisis. Reference 6 shows a set of useful requirements for a RUC. Legislation is needed as soon as possible to direct and speed up the process to get an environmentally-sound RUC that will also protect the economic interests of low-income drivers. Need for a Systems Engineering Solution Appendix C needs to follow the path shown in Reference 1 to quantify the needed LDV fleet conversion and the needed reduction in per-capita driving, with respect to the SB375 reference year of 2005. Table 9 in reference 1 shows how the needed LDV fleet efficiency could be achieved; Equation 9 computes the associated driving reduction to be 32% (a factor of 0.68). The advantages of systems to unbundle the cost of parking and driving is that, if need be, they could be adjusted to get the driving reductions we need in a responsible way. 3.0 Comments Regarding Your Slides, “2030 Scoping Plan, October 1, 2015, Slides 61 to 80 As for Appendix C, these slides show no quantification of the problem. CARB can’t possibly solve a problem it does not first “size” the problem. Again, see Reference 1 to see how the requirement to achieve a target (in the case of Reference 1, it is a climate-stabilizing target) can be flowed down into fleet efficiency and level of driving. Page 17 of Reference 1 starts the information on how to achieve the needed driving reduction. 4.0 Unbundling the Cost of Car Parking For the vast majority of destinations in California, the cost of car parking is hidden within other costs. This has serious consequences. For example, at most places of employment, parking costs reduce the wages that can be paid to all the employees, even those that never use the parking. Similarly, at many apartment complexes, bundled parking costs increase the rent and this is true, even for families that do not own a car. Bundled parking costs routinely increase the costs of goods, such as groceries, for all customers. Again, this is even true for those that do not drive. Since governments require businesses to provide minimum levels of parking, they are involved in this economic discrimination towards those that drive less. Driving less is, to some degree, a lifestyle choice. Since government has no valid reason to encourage driving, the lifestyle choice of less driving deserves constitutional, or at least legal, protection from any practices that discriminate against it, economically. On June 22nd (2010), I presented a paper (Reference 4) on how parking could be operated to unbundle parking costs in a way that supports the sharing of parking. This was at the 101st Conference and Exhibit of the Air and Waste Management Association, in Calgary, Canada. The session, Sustainable Land Use and Transportation, included my paper, A Plan to Efficiently and Conveniently Unbundle Car Parking Costs, which was well received. My paper is therefore both peer reviewed and published. I would be pleased to present this paper to the staff of CARB, in the hopes that CARB could bring about equitable and environmentally-sound parking policies to California. The following points, taken from the paper, apply. • Vehicle miles traveled (VMT) are a major cause of global warming and pollution. • California’s Metropolitan Planning Organizations (MPOs) will need to adopt strategies that reduce vehicle miles traveled (VMT), in order to meet SB375 GHG reduction targets, to be issued by the California Air Resources Board in late 2010, for years 2020 and 2035. • The appropriate pricing of parking is one of the least costly tools documented to reduce VMT. • New technologies, such as sensors feeding computer-generated billing, offer the potential to efficiently bill drivers for parking and alert law enforcement of trespassers. • Reformed parking policies can increase fairness, so that, for example, people who use transit or walk do not have to pay higher prices or suffer reduced wages, due to parking. • Methods to unbundle parking cost are inefficient unless they support the spontaneous sharing of parking spaces. Shared parking with unbundled cost would ultimately allow cities to require significantly less parking. • Typical systems of timed parking and metered parking are far from ideal. Parking has no automated record keeping, so it is difficult to know where there is too much or too little. • Good policies will eventually let cities turn parking minimums into parking maximums. Less land and resources devoted to parking will support mixed use and make “smart growth” more economically viable. It should therefore be a key ingredient supporting the MPO’s stated desire to foster “smart” growth, where “smart” should be defined as “less VMT”. Here is a copy of the abstract of the paper. The Introduction shows documented driving reductions due to the pricing of parking. It notes that although the benefits of priced and shared parking are known, such parking has not been widely implemented, due to various concerns. It states that a solution, called “Intelligent Parking,” will overcome some of these concerns, because it is easy to use and naturally transparent. It asserts that this description will support a “Request for Proposal” (RFP) process. Eight background information items are provided, including how priced parking would help California achieve greenhouse gas reduction targets. A story demonstrates some of the key features of Intelligent Parking. Arguments for less parking, shared parking, and priced parking are made. Barriers to progress are identified. The fair pricing of parking is described. New ways to characterize transportation demand management are presented. Seven goals of Intelligent Parking are listed. Eleven definitions and concepts, that together define Intelligent Parking, are described. This includes a method to compute a baseline price of parking and how to adjust that price instantaneously to keep the vacancy above 15% (“Congestion Pricing”). An implementation strategy is described. This abstract aroused enough interest among those responsible for A&WMA’s Sustainable Land Use and Parking session that they requested that I submit a manuscript, which was ultimately selected to become part of the written Conference Proceedings and for presentation. I hope that it will similarly arouse the interest in the CARB Board and staff. CARB needs to consider working to execute the implementation strategy described in A Plan to Efficiently and Conveniently Unbundle Car Parking Costs. I would be honored to help in any way possible. References 4, 7, and 8 have the details. 6.0 Conclusions Climate is a math problem. More specifically, it is a systems engineering problem. The best, largely overlooked strategies to reduce VMT are a comprehensive and variable road use fee pricing system; unbundling the cost of car parking; and putting a stop to all freeway expansions. I would like to discuss further a state-wide strategy to unbundle the cost of car parking. CARB’s performance so far is going to put too much emphasis on the fact that fuel for vehicles is a capped sector. This is unsound policy. If the increased cost of gasoline becomes the dominant way that driving is reduced, there is a significant risk that there will be a powerful political backlash. Ideally, the state will be led by a CARB that realizes that policy to both improve fleet efficiency and reduce driving in a controlled way will mean the emission trajectory from LDVs will be achieved without much need to apply the Cap and Trade to limit allocations. Frankly, we do not want to give our friends in the oil industry ammunition to shoot down these vital efforts. Sincerely yours, Mike Bullock mike_bullock@earthlink.net 760-754-8025 1800 Bayberry Drive Oceanside, CA 92054 1 Bullock, Mike R; The Development of California Light-Duty Vehicle (LDV) Requirements to Support Climate Stabilization: Fleet-Emission Rates & Per-Capita Driving, Paper 30973-AWMA, from the Air and Waste Management Association’s 107th Annual Conference and Exhibition; Long Beach, CA, June 24-27, 2014; Attached with submission of comment letter and available on request from mike_bullock@earthlink.net 2 Power Point Slides used to present Reference 1, attached with submission of comment letter (if possible) and available on request from mike_bullock@earthlink.net 3 Hansen, James, Brief of Amicus Curiae, Exhibit A; United States District Court for the Northern District of California San Francisco Division, Case4:11-cv-02203-EMC Document108 Filed 11/14/11 http://ourchildrenstrust.org/sites/default/files/Hansen%20Amicus%20.pdf 4 Bullock, M.; Stewart, J.; A Plan to Efficiently and Conveniently Unbundle Car Parking Costs; Paper 2010-A-554-AWMA, from the Air and Waste Management Association’s 103rd Annual Conference and Exhibition; Calgary, Canada, June 21-24, 2010. Available on request from mike_bullock@earthlink.net or http://www.sandiego.gov/environmental-services/pdf/sustainable/parkingcosts.pd 5 Madaffer, Jim; Letter from the Chair of the Road Users Charge Technical Advisory Committee to Stakeholders, May 5, 2015. http://www.catc.ca.gov/meetings/Committees/Road_Charge/Road_Charge_March_27_2015/Stakeholder_Agenda_Letter_March_2015.pdf 6 Bullock, Mike; Environmentally-Sound and Economically-Fair Road Usage Charge; a resolution of the California Democratic Party Environmental Caucus; approved on May 16, 2015; available on request from mike_bullock@earthlink.net 7 Bullock, Mike; Equitable and Environmentally-Sound Car Parking Policy at Schools; July 20, 2011; unpublished report; attached with submission of comment letter and available on request from mike_bullock@earthlink.net 8 Bullock, Mike; Equitable and Environmentally-Sound Car Parking Policy at a Work Site; Oct. 4, 2014; unpublished report; attached with submission of comment letter (if possible) and available on request from mike_bullock@earthlink.net
Attachment: www.arb.ca.gov/lists/com-attach/9-2030targetsp-ws-Uj5VNgRxUnUCYVUn.zip
Original File Name: Letter2CARB_And4References.zip
Date and Time Comment Was Submitted: 2015-10-15 19:31:49
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