TRANSDEF’s latest comment letter on SB 375 implementation is the sharpest to-date, accusing the agency of pretending to be reducing transportation GHGs.
An early 2019 report by ARB has acknowledged that, because VMT is continuing to grow, GHG emissions from transportation continue to grow, threatening the ability of the State to achieve its climate targets. TRANSDEF submitted its comments on the 2018 Progress Report.
SB 375 directed ARB to adopt regional GHG 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). ARB has consistently refused to push MPOs to move away from their status quo planning, allowing them to continue to increase rather than reduce VMT (Vehicle Miles Travelled). Despite an excellent turnout of climate activists (see ARB Board Transcript) demanding stronger targets, the targets ARB approved in 2018 fail to accomplish the 25% reduction called for in the Scoping Plan update adopted December 2017. TRANSDEF sent a memo to ARB staff following a meeting to discuss SB 375 implementation.
Here is the sequence of TRANSDEF letters, starting at the beginning of the update process, running towards a proposed final draft, and then comments on a workshop late in the process, when staff recommended changing the direction of analysis away from modeling, and towards metrics to be determined later:
March 2017 Regional Target Updates
2017 Regional Target Update EA Comments
December 14 Regional Targets Hearing
SB 375 Discussion Notes is a memo to staff, summarizing a hard-hitting discussion with TRANSDEF about the failings of the proposed targets.
Bending to strong pressure from the MPOs, ARB declined to update its regional targets in 2014. See Comments on 2014 Regional Targets Update.
Rather than call on the MPOs to proportionately reduce emissions along with the other emissions sectors, ARB allowed the MPOs to recommend their own targets and then essentially adopted them in 2010. 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.
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