|
Template ARB Letter - AB32
Submit Comments by August 1, 2008 on the
California Air Resources Board
AB32 Scoping Plan to reduce Greenhouse Gas Emissions
By Funding Safe Routes to School Programs
The Safe Routes to School National Partnership urges organizations to submit comments on the Scoping Plan for AB32 to the California Air Resources Board (ARB) website at: http://www.arb.ca.gov/lispub/comm2/bcsubform.php?listname=sp-transport-ws&comm_period=1 Comments are due August 1, 2008. Below please find a draft template letter that you can customize to emphasize the importance of transportation, land use, school siting and Safe Routes to School in reducing greenhouse gas emissions.
Date
California Air Resources Board:
Name of Organization is writing to submit comments on the California Air Resources Board’s (ARB) draft scoping plan for AB32, which is being designed to reduce greenhouse gas emissions in the State of California to1990 levels by the year 2020.
Our comments focus on the transportation sector, which accounts for approximately 38% of greenhouse gas emissions in the State of California. While we are pleased that the ARB asks for the development of regional plans that will document and reduce greenhouse gas emissions (GHG) emissions, we feel that your target for land use, (2 million metric tons) is quite low, as this represents less than 1% of the overall GHG emissions reductions. This land use target is not at all proportionate to its share of GHG emissions within the transportation sector.
We are particularly interested in having the scoping plan be amended to include a specific focus related to schools which play a major role in how communities are designed, and how local traffic is generated, with its corresponding vehicle miles traveled (VMT) and carbon emissions.
1) Land Use and VMT: name of organization asks that you increase requirements in the scoping plan for GHG reductions through the land use sector, and make tracking vehicles miles (VMT) traveled and targets associated with VMT reductions a requirement through new regional land use targets. We also ask for you to require that regional transportation agencies include school siting and Safe Routes to School as components of their GHG reduction plans, and create an enforcement mechanism around these GHG reduction plans.
2) Safe Routes to School: We further ask that ARB include Safe Routes to School infrastructure and non-infrastructure programs in the section of the scoping plan titled “public education and programs to reduce vehicle miles traveled” so that the program can be expanded to all elementary and middle schools in California. Include a sentence about your organization’s work with Safe Routes to School and any data you might have generated related to mode shift. The Safe Routes to School National Partnership has calculated that if every school in the state currently operated a Safe Routes to School program that this could annually reduce 468,156 tons of CO2, and create an annual reduction of 1,099,357,028 VMT through school trips alone. Safe Routes to School programs should be funded from cap and trade allowance allocations or other new revenue sources committed to reducing CO2 emissions at a rate of $90 million/year which will be matched through federal and local funding. The state should also require VMT reduction targets related to SRTS in the regional land use plans.
3) School Siting: In addition, ARB should work with the California Department of Education (CDE) on the revision of their school siting requirements (Title 5) which are being updated now to ensure that CDE is encouraging neighborhood schools, and specifically mention the importance of school siting and neighborhood schools within the final Scoping Plan. The National Household Travel Survey indicates that only 42% of school trips are one mile or less in California. As we are building and rebuilding more schools in this state, it will be important to ensure that these new schools are neighborhood schools, where children can safety walk and bicycle as walking and bicycling to school decreases dramatically as residents are located further from schools.
Safe Routes to School and school siting are important issues to include within the scoping plan both for funding allocations through the cap and trade program, and as requirements for the regional target plans.
The State of California should not focus only on technological solutions to reduce GHG emissions. Without improved land use, increased VMT will prevent us from achieving the 2020 emissions reduction goals. Additionally, funding school-oriented programs that promote walking and bicycling will have co-benefits such as improved land use, healthy lifestyles and reducing obesity-related illnesses that are exacerbated due to a lack of opportunities for safe physical activity.
Thank you for your careful consideration of our comments.
Sincerely,
Name, Title
Name of Organization
Address
Phone
Email
Website
|
