SANDAG sent written responses to seven KPBS questions about its 2015 regional transportation plan. Portions of the answers are quoted in the KPBS story on the plan, but they are also presented in full here.
1. Does the 2015 SANDAG RTP comply with the state's 2035 and 2050 Executive Orders (reducing greenhouse gas emissions to 80 percent below 1990 levels by 2050)?
First, and foremost, SANDAG is not required to “comply” with the Executive Orders – they are broad goals. We are required to comply with targets set by the California Air Resources Board – the Regional Plan does that. In fact, it exceeds those greenhouse gas reduction targets.
To further explain:
Just like every other regional transportation plan in the state of California, our region’s long range transportation plan does not result in greenhouse gas reductions that would meet the goals set in the Executive Orders (EO-B-30-15 and EO-S-3-05). Even the state doesn’t know how it will “comply” with the goals it has set for itself in the Executive Orders. The governor is setting goals for the state, and then later will try to figure out IF and HOW the goals will be met.
It’s important to keep in mind that the Executive Orders set OVERALL goals for the entire state from ALL SOURCES. There are many different sources of greenhouse gas emissions in the state. In order to achieve these overall goals set by the governor’s office, ARB will set specific targets for each sector. (This is what SB 375 did – set specific targets for planning organizations like SANDAG.)
The key point, in terms of your question above, is that ARB has set specific targets for metropolitan planning organizations for the year’s 2020 (7 percent per capita reduction over 2005 baseline) and the year 2035 (13 percent per capita reduction over the same baseline). The Draft Regional Plan exceeds those targets – achieving 18 percent reduction in 2020 and 24 percent in 2035.
However, ARB has not set targets for 2050. It might be tempting to assume that that target would be 80 percent reduction from 1990 levels for every GHG producing sector (because that would mirror the OVERALL goal set in Exec Order S-3-05), but that is not how the state has approached GHG reductions to date. Some sectors, such as vehicle fuel efficiency and fleet mix (more alternative fuel vehicles) may be able to achieve far greater reductions than other sectors (such as sectors that depend on land use changes, which occur very slowly over long periods of time – and as cars become more efficient or rely on alternative sources of fuel, GHG reduction from vehicle miles traveled becomes increasingly difficult to achieve). So exactly what those targets will be for SANDAG is unknown to us and all the other metropolitan planning organizations in the state – and at this point none of them are able to produce reductions that would equal 80 percent reduction over 1990 levels in their sectors. (That sector, by the way, is defined as “reducing vehicle miles traveled through coordinated transportation and land use planning.”).
Here’s an enlightening example regarding SANDAG’s role in achieving statewide reductions: in the state’s planning to meet its 2020 GHG reduction target, it expects statewide implementation of SB 375 – so not just SANDAG but all regions – will provide JUST 6 PERCENT of needed reductions. In other words, 94 PERCENT OF REDUCTIONS WILL COME FROM OTHER SECTORS, with the biggest contributions from things like cleaner vehicles, fuels and technologies, renewable electricity, and cap-and-trade.
Here are some examples of the types of major statewide changes that would be needed to meet the 2030 executive order target:
• Double energy efficiency in buildings and industry
• 50 to 60% renewable electricity
• 6-7 million zero emission and plug-in hybrid vehicles on the road
• 50% of natural gas demand is met with biogas
Here are some examples of the types of major statewide changes that would be needed to meet the 2050 executive order target (note: even if implemented, these MAJOR changes would still fall short of getting to the 2050 goal):
• Double high-speed rail deployment
• Replace ALL natural gas in buildings with electric heat pumps by 2030
• 50 percent residential zero net energy retrofits by 2030
• 2.2 Gigawatts of nuclear power capacity by 2050
• 8 carbon capture and sequestration facilities at power plants
So, to be clear -- no law exists that requires SANDAG to meet the goals in the Executive Orders – the arguments in litigation have been about how much SANDAG has to analyze and disclose with regard to its plans and the Executive Orders in order to comply with the California Environmental Quality Act. The only portion of the statewide goals SANDAG has mandated GHG reduction targets for is passenger cars and light duty trucks, for 2020 and 2035, and the Regional Plan is projected to exceed these goals.
An analogous example may be the statewide goal to reduce water use. Locally there is a goal to reduce water use by 25 percent and a mandate in the City of San Diego to only water yards on certain days of the week. Each household is not required to meet the statewide goal, nor is it required for each type of water use to show a cut of 25 percent. It is up to each of us to decide whether to cut back on showers and running dishwashers and washing machines – the only specific requirement for each household is that it must only water yards on certain days.
2. On page 94 of the draft plan, Table 2.1 shows reductions under the plan that exceed the ARB's targets under SB 375, but this table only includes greenhouse gas emissions from cars and light trucks. Why does it not show greenhouse gas emissions for transportation, land use and population calculated as part of the Executive Orders and included in your environmental impact report?
SANDAG is required to demonstrate how the Plan – through coordinated land use and transportation planning – can achieve GHG emissions reduction targets established by the ARB for passenger vehicles (cars and light duty trucks). This is the requirement outlined in SB 375 and is why the figure on page 94 of the Plan outlines these GHG reductions.
Overall GHG emissions and how the Plan affects those emissions are described in Section 4.8 of the Regional Plan EIR (which analyzes the transportation improvements called for in the plan over time, as well as the impacts of other changes that are expected to occur over the same time period – such as population growth.) In other words, the Plan describes the projects and programs SANDAG and other agencies will implement over time. The EIR analyzes the potential impacts of those projects and programs within the context of other changes that are reasonably expected to occur over the same time period.
3. In the plan's environmental impact report, projections that include transportation, land use and population show greenhouse gas emissions will be above the local reference points for the 2035 and 2050 state GHG Executive Order targets. (On page 4.8-33 of the EIR, it says the 2050 local reference point is 80 percent of the San Diego region’s 1990 emissions level.) Why are these projections not included in the draft plan?
The analysis of the Executive Orders is appropriately included in the EIR and shows how existing regulations will affect GHG reductions over time. It should be noted that the EIR only makes assumptions about future emissions based on regulations that are in place today. While it is likely the Legislature will pass regulations that further reduce emissions related to fuel efficiency, fuel type, electricity generation, freight vehicles, and other sources of GHG emissions, SANDAG did not make assumptions about what those further reductions would be in the context of the EIR (the California Environmental Quality Act does not permit SANDAG to speculate about future regulations in an EIR because it is required to have substantial evidence for the assumptions we make). Existing state plans and regulations don’t go very far into the future. The AB 32 Scoping Plan goes to 2020. Renewable electricity requirements go to 2020. Clean Cars regulations go to 2025.
4. When SANDAG makes presentations to the public, is it showing the projections that include transportation, land use and population? If not, why not?
SANDAG does show all GHG emissions for the region and what is happening over time in its EIR. SANDAG prepared a GHG inventory for the Plan and some analysis of future emissions through 2050 (see EIR appendix G).
In terms of presentations to the public, SANDAG displays the GHG reductions associated with SB 375 because those are the only the targets that have been set for SANDAG by the relevant state agency – the California Air Resources Board. Per the answer to question one above, GHG reduction targets set by ARB for SANDAG focus only on coordinated land use and transportation planning that can reduce emissions from passenger vehicles and light duty trucks because a regional agency has some ability to control, or at least influence, GHG emissions for this sector, unlike others such as the energy and industrial sectors.
5. If SANDAG's plan won't comply with the state's 2035 and 2050 Executive Orders, why isn't it being adjusted so that it will?
SANDAG is committed to complying with all state regulations concerning the reduction of greenhouse gas emissions. The Regional Plan complies with the law as set by the Legislature (see question one above, in terms of exceeding ARB targets).
In terms of achieving the larger reductions called for in the Executive Orders, SANDAG (and all the other planning agencies in California) need further direction from state regulators. SANDAG believes it will take a concerted effort by all sectors throughout the state to meet any statewide goal. SANDAG is ready and willing to do its share if and when the state sets new or different reduction targets intended to achieve the Executive Order goals. That is why the EIR for the Plan discusses how SANDAG is working to achieve its fair share of the statewide goal, but explains that despite its efforts, a lot of other changes would need to be made on matters it does not control in order for the state to achieve its GHG reduction goals.
6. If SB 32 is passed, will SANDAG need to adjust its 2015 regional transportation plan? If so, how?
Regional transportation plans are required to be updated every four years. SANDAG is required to adopt its Plan by fall of 2015 because SANDAG’s prior RTP is set to lapse in October. If SB 32 passes, it will go into effect on January 1, 2016 and will not have retroactive effect.
However, should SB 32 be signed into law, we expect that it will take ARB time to set targets as directed by the bill as it currently stands (just as ARB did in SB 375) for municipal planning organizations such as SANDAG. Assuming the bill passes and new targets are eventually set, they will be incorporated into the next RTP update.
7. Some environmental groups accuse SANDAG of trying to get its regional transportation plan passed before SB 32 is enacted—how do you respond to that?
SANDAG prepares an updated RTP every four years. We are on our existing cycle and are required to adopt a new RTP in the fall. The next RTP update will have to evaluate all laws (existing and new) that are relevant to the Regional Plan and RTP process.
