Bullseye: How ARB can get targets right for the climate and for California communities

How time flies! Four years have passed since the California Air Resources Board (ARB) set greenhouse-gas reduction targets for every region’s first transportation plan under SB 375. Nearly every region has completed its first smart growth plan or Sustainable Communities Strategy (SCS),and we’re tracking their implementation.

We’ve hit an important milestone: ARB’s first review of the groundbreaking SB 375 program and its greenhouse-gas reduction targets. ARB can now set new targets if it determines that the current ones won’t reduce greenhouse gases enough to fight climate change effectively. We first started following this in January, with particular focus by our partners, the American Lung Association in California, and things have come a long way.

We’ve just submitted a letter to ARB signed by twenty state and local environmental, health, and community groups. The letter built upon comments offered in the recent round of public workshops.

Here’s what our letter urges:

Hurry the spread of best practices: We saw great innovation in the first round of smart growth plans. (We’ve highlighted a few in our Greatest Hits of 2011 and 2012, and updates from Fresno.) ARB can help spread this innovation to other regions. New ideas can help everyone do better, whether it’s incentives like grant programs, new modeling methods, or fresh reviews of planned transportation projects. Some regions are asking ARB to delay updating their targets until “Round 3” so they can focus on implementing their first plans; that might make sense if it includes a strong commitment from ARB and the regions to use that time to share and adopt best practices.

Calculate and increase benefits beyond greenhouse-gas reductions: Strong regional plans can do much more than reduce greenhouse gases. They can increase physical activity and health, expand economic opportunity, save water and energy, reduce smog and soot pollution, help protect essential landscapes and farmland, address infrastructure gaps in underserved communities, and even reduce costs for families and local governments. New modeling tools can increasingly forecast all of these benefits. ARB and the regions should account for them in a consistent way. This will help communities get the best results. Most importantly, clear data on benefits, when added up across California, will show the state why it should invest in bringing these plans to life.

“Okay,” you might be thinking. “But what about the targets?”

I’ll get to that in a second. First, though, I want to point out that the advances under SB 375 have often come from changing the dialogue, shifting priorities, and building new relationships. Even if ARB only focused on spreading best practices and calculating health, community, and conservation benefits, that would improve California’s land use and transportation.

OK. Now the targets. ClimatePlan and our partners want ARB to look closely at the current greenhouse-gas reduction targets, and to update them to cut as much carbon pollution as we need to. Transportation is the largest source of greenhouse-gas emissions in the state. We can’t rely on technology alone (like hybrid cars); we have to help people drive less. Changing land-use patterns and expanding transportation options are essential to achieve the 2020 and 2050 goals set under AB 32 and Executive Order S-3-05. In fact, ARB should add a new target for 2050, specifically for land use and transportation under SB 375, to make sure the state is on track.

How can CARB ensure targets are ambitious and effective?

Here’s what we and our partners suggest:

Start updating targets now for Round 3: Setting targets soon for Round 3 will give every region – even San Diego, whose Round 2 plan is set to be adopted in less than a year – enough time to plan to meet them.

In regions with “placeholder” targets—including the San Joaquin Valley—consider updating targets faster, so they can be used in the Round 2 Regional Transportation Plans (RTPs): Some regions received targets based upon very little information, and some plans overshot the targets so easily that the original targets must have been underestimates. In those regions, the targets should be reviewed using CARB’s analysis of the plans.

Fix the modeling and make assumptions consistent between regions: The law states that “without improved land use and transportation policy, California will not be able to achieve the goals of AB 32” (SB 375, Section 1(c)). Yet some regions are reportedly reaching targets via business as usual strategies, or via assumptions about gas prices or the economy. Relying upon these trends is not enough; the targets should be an ambitious stretch beyond what business as usual can achieve.

Account for inter-regional trips in a consistent way: When San Joaquin County believes a certain number of commuters will drive west into the Bay Area every morning, while the Bay Area believes a different number of commuters will arrive from the east, you know something is wrong! Of course, it’s hard to accurately forecast commuter numbers for 2035, but as Steve Heminger, head of the Bay Area’s Metropolitan Transportation Commission joked at the last Roundtable, “we at least want to be wrong consistently!” (Of course, both regions’ modelers are working hard to be as right as possible.) While this might sound like a small thing, in the Bay Area it generated a lawsuit. And in some Valley counties, close to half of travel is interregional, so incorrect assumptions could really skew the results.

Finally, as CARB moves forward in the target review process, the role of public input and involvement is essential. Just as CARB set up a Regional Targets Advisory Committee and held public workshops in the last round of target-setting, it should have a stakeholder review process now.

Back when it was setting the targets, CARB estimated that the program would collectively save over 15 million metric tons per year by 2035 compared to a business-as-usual trajectory. As regions have overshot their targets, this number has surely grown. But as Chairperson Mary Nichols commented at the Board meeting in May, “It’s not just about…pounds of pollution. It really is about communities.”

The Air Resources Board will be discussing the SB 375 program and the target setting process soon: Join us at the hearing in Diamond Bar, CA on October 23-24 to ask CARB Board members to establish a strong process for updating targets, to both meet the state’s climate goals and make California’s communities more healthy, equitable, and sustainable.

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