San Joaquin Valley COGs: Unpacking the Black Box

The San Joaquin Valley’s first Sustainable Communities Strategies (SCSes) under SB 375 are heading into the home stretch, and while some Valley counties have made great strides, there is plenty of room for improvement. Last month, 24 organizations asked the Air Resources Board (ARB) to ensure that Valley counties meet the targets via ambitious land use and transportation policy improvements.

Board members strongly agreed, noting that too many questions remained about the San Joaquin Valley plans for them to be approved at that time. ARB will hear an update on the Valley plans in July, with review continuing into this fall. However, the stakes go far beyond the San Joaquin Valley. The underlying questions are fundamentally about the strength and integrity of SB 375.

The Dreaded Black Box

SB 375 states that “without improved land use and transportation policy, California will not be able to achieve the goals of AB 32.” Unfortunately, in the San Joaquin Valley, several agencies have been able to meet their greenhouse gas (GHG) targets under SB 375 via “business as usual” scenarios after making changes to their transportation models. Could transportation models become a “black box” where SB 375 targets get “met” without the ambitious but achievable policy progress that will benefit California residents?

Take, for example, Kern. In creating its SCS, Kern Council of Governments (COG) first examined whether its current (2011) Regional Transportation Plan (RTP) would meet the GHG targets of -10% per capita. In a June 2013 meeting, Kern’s Regional Policy Advisory Committee (RPAC) was told that their old plan fell short, achieving only -5.3%. It seemed that Kern would need to significantly improve their plan to meet the target. But the following month, Kern COG staff presented a new analysis, which concluded that the same “old plan” would achieve a 14.3% reduction, far exceeding the target! Soon after, several other counties declared that their business as usual scenarios would meet the targets as well.


Copyright 2006 by Sidney Harris

How did this happen? When Kern released its draft Regional Transportation Plan, the now-famous Kern Table 4-7 showed how Kern was meeting its greenhouse gas targets — by assuming that the recession would continue and that gas prices would rise. In other words, according to Kern’s draft Regional Transportation Plan, in 2040, Kern residents would drive less because too many could not afford gas and too many would have no job to drive to.

This is a problem on two levels. If the economy rebounds, air pollution and climate emissions could rise quickly rather than decline. In the meantime, we will have missed the opportunity to plan and build a region where climate emissions decline even while economic opportunity increases by investing in long-neglected communities, conserving valuable natural and working lands, and creating walkable neighborhoods that improve public health.

Get Out Of Jail Free Card?

Speaking of missed opportunities, what happens to regions that do not meet their greenhouse gas targets? Merced County Association of Governments’ Board chose the worst of three scenarios, and Madera will not only miss the reduction targets, but actually allow per capita GHG to dramatically increase – the worst performance in the entire state. It would appear that officials in these communities have forgotten that statewide climate goals require everyone to pull their weight.

We believe that every region should meet these achievable targets. Higher emissions in Madera and Merced will mean that the state will have a harder time meeting its climate goals.  Most importantly, people in every county deserve the benefits of better land use and transportation planning: reduced air pollution, access to high-quality transit, ways to get to work, school, and businesses on foot and by bike, and an overall improved quality of life.

When a region will not reach its targets, we hope that ARB will increase its engagement. These situations should ring an alarm bell, summoning the attention of statewide stakeholders. Under SB 375 if regions miss their targets, they have to create an Alternative Planning Strategy that answers several important questions – what were the barriers to meeting the targets via an SCS? what is the most practical and realistic approach to meeting the targets? We believe that ARB should provide technical analysis and convene a broader dialogue on these questions.


If regions can meet their targets via economic assumptions rather than improved policy, and if there is no incentive to meet the targets at all, a larger opportunity may be missed — to adopt policies that reduce climate pollution and also improve health, economic opportunity, and land conservation for the benefit of all residents in the San Joaquin Valley.

Ultimately, this is about much more than a math equation. At the June Air Resources Board meeting, Kings County resident Candida Vanegas explained she attended because she “wanted to put a face on the communities” that these decisions affect. “We are the future. We have kids… We are a lot of Latinos out there that need help in the forgotten cities and towns of Kings County.”

We need to make sure that not only do the numbers add up but that the math equation itself measures improvements in people’s lives.  As Chair Mary Nichols explained, “There’s a lot at stake here obviously. It’s not just a technical discussion. It’s not just about, you know, pounds of pollution. It really is about communities.” ARB will next review the Valley’s plans again at their July 24 meeting – stay tuned!

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