Climate Change Policy

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TRANSDEF’s organizational focus is the reduction of GHG emissions from transportation. Much of our work has involved the state’s policy-setting agency for climate change, the California Air Resources Board, or ARB. ARB has produced generally excellent climate change plans, called Scoping Plans. However, it has consistently been weak in the area of reducing GHG emissions from transportation, despite determining that nearly half of the state’s GHG emissions are generated by the transportation sector.

TRANSDEF suspects that high-level officials in state government are unwilling to take on the inevitable controversy that would accompany a serious effort to shift how Californians travel. Not only would this represent an unprecedented level of cultural change, it would require shifting transportation funding to exclusively low-carbon modes, which entrenched interest groups would resist.

ARB’s lack of courage in this sector is generally unrecognized, even within the climate advocacy community. TRANSDEF’s concern is that without significant reductions in transportation emissions, the state will not reach its goal of 2050 GHG emissions 80% below 1990 levels, the percentage reduction identified as needed to prevent global temperatures from rising more than 2
° C. TRANSDEF has a long history of advocacy in climate policy, in an effort to help the state meet its goal:

TRANSDEF
requested the Air Resources Board provide guidance in the use of its mobile sources air emissions model, EMFAC, so that regions properly determine their regional GHG emissions without including State-level emissions reductions measures. This is important because SB 375 calls for emissions reductions from the regions, above and beyond what the State does.

ARB 2017 Scoping Plan
TRANSDEF submitted a massive comment set, made up of 1).
General Comments; 2). VMT Reduction Comments, Attachment: Comments on State-level Strategies; 3). Environmental Assessment Comments, Attachment: Comments on CHSRA 2016 Business Plan; and 4). Comments on Regional Emissions Reduction Targets.

TRANSDEF identified the challenges in reducing emissions in its comments on
ARB's Draft 2008 Scoping Plan and Final 2008 Scoping Plan.

SB 375 directed ARB to adopt regional emissions reduction targets for the state’s Metropolitan Planning Organizations (MPOs, the large regional agencies that allocate funding for transportation projects, including SCAG, SANDAG, SACOG and MTC). Rather than call on these agencies to proportionately reduce emissions along with the other emissions sectors, ARB allowed the MPOs to recommend their own targets and then essentially adopted them. Even though ARB characterized the targets as “aggressive” TRANSDEF criticized these targets as far too comfortable for these agencies. Rather than achieve the overall reduction in regional GHGs that was called for by SB 375, the adopted targets allow regional emissions to grow with population. See these comment letters:

ARB’s Draft Regional GHG Emissions Reduction Targets, regarding MTC’s submissions--2010
ARB’s Draft Regional GHG Emissions Reduction Targets--2010
ARB’s Final Regional GHG Emissions Reduction Targets--2010
Testimony to ARB on Regional GHG Emissions Reduction Targets--2010

TRANSDEF called for a fundamental transformation of transportation in its comments on
ARB’s 2013 Scoping Plan Update and ARB’s Draft 2015 Investment Plan Update.

Bending to strong pressure from the MPOs, ARB declined to update its regional targets. See
Comments on 2014 Regional Targets Update.

TRANSDEF asserted that the draft Funding Guidelines and associated Quantification Methodologies were an open invitation to widespread application fraud in its
Comments on ARB’s Greenhouse Gas Reduction Fund Guidelines.

In Comments on ARB’s 2015 Scoping Plan Update, designed to meet the requirements of the Governor’s Executive Order establishing a midpoint GHG target, TRANSDEF observed that “The ARB policy team is fully equipped to lead the parade, as California transforms itself to meet the requirements of climate change. The problem is, no one at the local level is following them.” The letter traces out the disconnect between state-level policy and local-level policy in transportation:

A very large percentage of transportation funds statewide are still devoted to building infrastructure that locks-in California's dependence on solo driving, resulting in permanently increased VMT and resultant GHGs. This disconnect, where local agencies expect the State to do all the heavy lifting, where most large transportation projects result in increased GHGs, where MPOs successfully pressure ARB to adopt regional emissions reduction targets low enough to allow them to evade fundamental change, and where approved densities in infill development areset so low that they don't support transit effective enough to promote mode shift, will be fatal to achieving the Executive Order targets. Practitioners of the status quo need to be dragged into alignment with the State's climate change policy framework.

The 2016 Scoping Plan Update is continuing in an even more dysfunctional fashion, in which TRANSDEF critiqued the Potential VMT Reduction Strategies being considered by ARB as obviously incapable of producing significant results. Its comment letter on the Plan stated that “The current Draft Plan telegraphs to the world that the Administration is leery of backlash: programs that reduce VMT in the near-term could inconvenience people. While caution is understandable, further growth of VMT will only make the eventual reductions more painful and perhaps damaging to the economy.”

Regional Transportation Plan Guidelines
TRANSDEF has been active in a Working Group of the California Transportation Commission that updates the state’s official
Regional Transportation Plan Guidelines. Starting in 2007 with an update in response to AB 32, the Group drafted Climate Change-Responsive RTP Guidelines to accommodate the requirements of SB 375. The 2017 Guidelines Update saw a serious backlash against this document, to which TRANSDEF responded with comments on the 2016 Draft and a stinging critique of where the update process was heading.

The California Transportation Plan
Caltrans issued its draft update of the California Transportation,
CTP 2040, in 2015. TRANSDEF was very laudatory in its comments. As the plan went through the review process, however, the draft plan was taken down from the official CTP 2040 site, never to be seen again. By the time the Final CTP 2040 was approved in 2016, much of the focus on reducing GHG emissions had been stripped out. TRANSDEF’s comments acknowledged that the Plan represented a significant cultural shift for Caltrans, but criticized it for failing to provide an action plan for an 80% reduction in GHGs. In its later comments on the Guidelines being written for the CTP Update process, TRANSDEF accused Caltrans of intentionally violating SB 391, the law that direct the CTP to plan for the needed 80% reduction in GHGs.

Older Comment Letters
Sonoma County Comprehensive Transportation Plan EIR--2009
Attachment Part 1, Attachment Part 2
Supplementary comments on the Draft LUSCAT Report --2008
Draft LUSCAT Report--2008

Past Writings
TRANSDEF's President David Schonbrunn wrote several articles for Thinking Highways magazine and spoke at their climate change conference:
View from Another Planet
Thought Piece
MegaProjects
Climate Change Conference