Early this month, the California Air Resources 
Board released a Draft 2022 SB 150 report. For those that may need a refresher, the SB 150 report tracks progress on how regions are meeting their greenhouse gas emission targets. You can read more about it here in Streetsblog. Unsurprisingly the findings of the draft 2022 SB 150 report are remarkably similar to the previous report, California is still not meeting greenhouse gas emission targets. Instead, GHG emissions and VMT are still increasing across all regions.
The urgency is clear within the draft, and there is a clear focus on implementation. But we still don’t think there is accountability to the actions laid out in the report. ClimatePlan has drafted a comment letter commending CARB and their implementation plan, but we call for more transparency and accountability.
Join ClimatePlan in urging CARB to take leadership in “coordinating” actions from the SB 150 report. To sign on to this letter, complete this google form: https://forms.gle/ksUGxEdYmcRFG8oa6. The deadline for comments is July 14th, 2022. We will be accepting sign-ons until July 14th, 12:00 pm.
Figure 1 from the California Air Resource Board Draft 2022 SB 150 Report.
ClimatePlan's letter:
Dear Manager Kimura Szeto:
On behalf of the undersigned organizations, we respectfully submit the following comments on the 2022 Draft SB 150 report. ClimatePlan is a network of 50+ organizations that work on issues that intersect transportation, housing, land-use planning, air quality, and climate resilience. In 2017 ClimatePlan co-sponsored SB 150 (Allen). We believed the SB 150 report could be a powerful tool to achieve accountability and transparency. But the new draft report reiterates the same finding as the 2020 report: GHG emissions and VMT are still increasing across all regions.
With that said, we understand that the implementation of the Climate Action Plan for Transportation Infrastructure (CAPTI) and some regions' efforts across the state are slowing the rate at which we increase our emissions. But, it still is not enough. And so, we applaud staff for their diligent research and for calling out the urgency to act. In particular, we support that the 2022 draft includes actions that
- Accelerate delivery of VMT reducing projects and improve access to funding for high mode shift projects.
This report is yet another example of how California needs to significantly change what is being invested in for transportation at all levels of government (1, 2, 3). This means spending transportation dollars better by prioritizing multimodal solutions. This type of investment allows for all communities to be able to access important services without depending on a car.
- Prioritize community needs
Policies and investments have historically harmed Black, Indigenous, other communities of color as well as other discriminated against groups. Current planning and funding still do not account for the needs of these communities. For example, as seen in the 2022 draft report, many of them lack accessible, alternative mobility options to driving. To truly achieve the state’s commitment to equity, there needs to be prioritization of community needs in all land-use and transportation policies and investments.
- Require anti-displacement in all investments
All communities should be able to benefit from investments. Without careful planning and policies, historical inequities will be exacerbated, further harming these communities, and forcing more driving and climate pollution from those who have the highest propensity to ride transit.
- Expand tools and resources to increase and protect affordable housing
It is vital that all communities are able to afford to live near jobs and other access to opportunities and they are not forced to drive to be able to get access.
We urge CARB to take leadership and work in partnership with agencies, local governments, community-based organizations, and others, to implement the actions outlined in this progress report. Overall, taking these actions would be vital to ensuring our investments and policy are holistic and move the state toward achieving its climate goals and equity commitments.
We also urge CARB to take the following initial actions to better create accountability:
- Explicitly name state agencies, referred to in the draft 2022 report. Naming the agencies will make it easier to know which agency is undertaking the action and hold them accountable.
- Create an accountability matrix from the list of potential actions.
- Update the dashboard to be able to track how the actions above are being implemented.
ClimatePlan looks forward to working in partnership in this process and to ensure sustainable community strategies are implemented.
Sincerely,
Nicole Cheng, ClimatePlan
Policy Assistant
1. Ethan N. Elkind (2015). “Moving Dollars: Aligning Transportation Spending with CA’s Environmental Goals.” __Berkeley Law. Web. Retrieved from: https://www.law.berkeley.edu/research/clee/research/climate/transportation/.
2. Sciara, Gian-Claudia & Amy Lee (2018). “Aligning California's Transportation Funding with Its ClimatePolicies.” __UC Davis: National Center for Sustainable Transportation. Retrieved from __https://escholarship.org/uc/item/9jp6d597.
3. Strategic Growth Council (2022). California Transportation Assessment Report. Strategic Growth Council. Web. __Retrieved from: https://sgc.ca.gov/resources/.