Recently the League of California Cities Task Force on AB 32 and SB 375 recommended the state suspend or delay SB 375 implementation until proper funding is available. I argue that SB 375 implementation can and should proceed, even amidst funding uncertainty.
It is true that ideal SB 375 implementation will require additional investments in models and data, and variety of funds are available from multiple sources, including Prop 84 (though held up by state’s inability to sell bonds at a decent price). Part of the League’s concern appears to be the belief that SB 375 requires a new planning process for greenhouse gas emissions. This is simply not the case.
CalCOG says that the $57 million in federal funds the MPOs receive each year are already allocated and cannot be used for implementing SB 375. I take issue with this statement. Properly implemented, SB 375 will require that MPOs make additional investment in infrastructure for modeling travel and emissions. This is especially true in areas where models are not sensitive to the land use changes SB 375 will bring about. However, the bulk of SB 375’s policy weight is a change in goals and objectives for the Regional Transportation Plan. The chief environmental concern of the Regional Transportation Plan has previously been air quality conformity – making sure that the increase in VMT observed under the plan doesn’t outpace adoption of cleaner vehicles and result in higher net criteria pollutant emissions. Regions can demonstrate air quality conformity by taking the outputs of their travel demand model (how far vehicles are going and what speeds they’re traveling at) and inputting these into the EMFAC or MOVES model, which are free and developed by the state and federal government, respectively. SB 375 adds a new objective – reducing per capita GHG, which can also be measured using MOVES or EMFAC. It does this by merging two existing, funded, planning processes (the Regional Housing Needs Plan and the Regional Transportation Plan) and tasks MPOs with coordinating these processes to achieve per capita GHG/VMT reduction. This new goal – per capita GHG reduction – can be implemented at minimal additional expense through existing planning processes.
Even with existing so called four-step travel demand models, which must be improved to capture the full effects of potential SB 375 implementation strategies, a region will be able to measure the per capita VMT effects of allowing increased density and infill development near existing jobs centers. Additional funding is not required to implement a regional transportation plan in the spirit of SB 375.
This doesn’t mean that MPOs don’t need additional funds for ideal SB 375 implementation. Only a small percentage of the money spent on transportation infrastructure is spent on planning and coordinating the interactions of that infrastructure. Regions would be well-served by having access to models that are sensitive to a variety of transportation and land use strategies and programs that have become relevant in the move to a lower GHG economy. These models will be capable of predicting regional GHGs with much greater precision, something required for good public policy under any cap and trade system that includes the transportation sector. This will require substantial investment in new, advanced travel and emissions models, which are capable of learning as new data is fed to them, and the data to feed these models.
A properly calibrated regional model with a range of sensitivities will provide a more accurate prediction of regional travel and greenhouse gases. However, academics and practitioners do know the directional effects of a variety of policies, but not necessarily the magnitude of these effects (especially when policies are implemented in combinations). Members of the SB 375 Regional Targets Advisory Committee have debated the relative merits of using travel demand models or best management practices, which use the best available information on the directions and magnitudes of policy effectiveness. In cases where travel demand models are not sensitive to the various SB 375 implementation strategies, regions may be well served by having best management practices approach available for the first round of SB 375 implementation. The best management practices approach is likely to be far less costly to regions than full travel model development and implementation. I realize that this comes at the expense of some regional autonomy: the Air Resources Board would hand regions a sophisticated list of strategies they could implement, rather than allowing regions to develop and model their own strategies.
Implementing best management practices will help prepare a region for subsequent rounds of SB 375 implementation when precision becomes more important under a cap and trade system. By this point, better modeling capabilities can be funded and should be available. Additionally, even if regions can’t accurately predict emissions reductions expected in the first round of SB 375 implementation, this practice will expose future research and funding needed to create better models and implement better public policy.