TRANSDEF submitted a massive comment set on ARB’s 2017 Scoping Plan, 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.
The 2016 Scoping Plan Update proceeded in a thoroughly dysfunctional fashion, in which TRANSDEF critiqued the Potential VMT Reduction Strategies being considered by ARB as obviously incapable of producing significant results. TRANSDEF’s 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.”
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 are set 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.