California YIMBY Comment on CARB 2022 Scoping Plan

June 28, 2022
An illustration of a woman sitting in traffic

California YIMBY submitted the following comments regarding the California Air Resource Board’s Draft 2022 Scoping Plan Update. We commend CARB’s analysis and encourage the Air Board to use existing SB 32 authority to preempt local restrictions at inextricable odds with California’s climate mandate.

The number one source of greenhouse gas pollution in California is the transportation sector. The State Legislature and the Air Board have adopted several strategies to reduce this pollution, namely: The low-carbon fuel standard; the zero-emissions vehicles program; and land use reforms, along with transit and complete streets investments, to reduce vehicle miles traveled (VMT).  

In subsequent updates to its efforts in these areas, CARB staff have found that this three-pronged approach is necessary to achieve the state’s climate goals; it is not possible to reduce ambition on any of the three and hit the state’s targets. At the same time, the State has acknowledged that progress on the zero-emissions vehicle strategy is behind schedule, making the VMT reduction strategy more urgent and important.

For that reason, we would like to commend CARB for acknowledging the need to reduce vehicle miles traveled (VMT) in its Draft 2022 Scoping Plan Update. CARB also deserves recognition for drawing a clear connection between land use patterns and VMT, particularly in Appendices D and E of the draft scoping plan update. As CARB notes, greater urban density puts more Californians within walking or biking distance of daily necessities, reducing the need for regular car trips. Additionally, building robust public transit infrastructure is more viable in dense areas, where it can serve a greater number of riders. The public transit and active transportation projects that greater density makes possible are critical to reducing VMT.

But although CARB has correctly diagnosed the key challenges to meeting California’s climate goals, its proposed solutions are strangely disconnected from the problems it identifies. In its current form, the Draft 2022 Scoping Plan Update does not provide the state with many tools to reduce VMT—other than asking for city and county governments to make it a priority. Instead, the draft scoping plan update relies heavily on carbon sequestration to reach state climate goals.

California YIMBY supports experimentation with innovative ways of reducing carbon emissions, and we view carbon sequestration as a promising mitigation tool. However, heavy dependence on carbon sequestration would be a mistake. No country or state has attempted to deploy this technology at a large scale. Carbon sequestration’s feasibility at scale remains unproven; the state would be taking a major risk if it made the success or failure of its climate mitigation plan hinge on making it work — particularly given that failure is an existential threat.

The draft scoping plan update’s heavy dependence on carbon sequestration is particularly striking because CARB leaves so many other sustainability tools—particularly tools that would reduce VMT—untouched. Given CARB’s acknowledgment that VMT is the largest contributor to emissions statewide, one would expect CARB to emphasize VMT reduction more than speculative, unproven policy interventions.

California YIMBY urges CARB to shift their emphasis from carbon sequestration to proven solutions that directly address the issue of VMT. CARB mentions several of those solutions in Appendix D; they include waiving parking requirements for some projects, building on infill sites, and relaxing zoning restrictions that prevent the development of dense neighborhoods. Recent history tells us that many localities will not take these actions unless the state compels them to do so. This leads to a collective action problem that threatens to prevent California from achieving its climate goals.

Instead of leaving the power to maintain unsustainable VMT levels to the discretion of local governments, CARB should use its existing authority to promulgate land use regulations. AB 32 and SB 32 grant CARB broad authority to adopt regulations aimed at “[achieving] the maximum technologically feasible and cost-effective greenhouse gas emission reductions.” To date, the Air Board has not used this authority to preempt local land use regulations, much less to encourage the development of denser cities and transportation networks that don’t place the private automobile at their center. We believe it should.

Reducing VMT and increasing urban density would lead to significant benefits for California over and above helping the state meet its climate goals. These additional benefits include:

  • Reducing building sector emissions. Single-unit housing is the default housing typology in jurisdictions that prohibit denser, multi-family “infill.” Single-unit homes are more energy-intensive. Legalizing multi-family housing can reduce energy demand by 27 – 47%.
  • Affordability. Removing limits on urban density in the central areas of California cities would allow for the construction of more housing. The addition of more housing supply would help to drive down costs and end California’s housing affordability crisis.
  • Traffic safety. Thousands of Californians die in traffic collisions every year. Reducing VMT would necessarily reduce the incidence of fatal car collisions. Additionally, research shows that urban density is closely associated with fewer traffic deaths.
  • Productivity gains. Greater urban density has been found to increase economic productivity. As California becomes denser, it is therefore likely to become more economically prosperous.

Additionally, it should be noted that CARB could impose land use regulations at no cost to the state’s general fund through its current authority as conferred by SB 32. Conversely, although the cost of carbon sequestration is likely to decline in the near future, deploying the technology at scale would still require significant state investment. Given that California faces a structural deficit in future budget years, it make sense for the state to prioritize cost-neutral approaches to curbing emissions.

Just as reducing VMT and increasing urban density carries major benefits, failing to do so would result in significant costs. The greatest of those costs is that the state would likely fall short of its climate goals. Additionally, traffic deaths and housing costs would remain unconscionably high, and the state would continue to lose out on unrealized economic gains. If the state relies on carbon sequestration to meet its climate goals, there is also the risk that the state will eventually discover it has spent precious time and resources on an approach that is infeasible at scale. Given the existential nature of the climate crisis, the state cannot afford that risk.

With the balance of these potential costs and benefits in mind, we urge CARB to use its existing authority under AB 32 and SB 32 to preempt local restrictions on development where those restrictions conflict with the state’s climate goals—for example, where local governments make it illegal to build multifamily housing near public transit. If CARB disagrees with California YIMBY’s interpretation of existing statute, it should clarify what powers it believes AB 32 and SB 32 grant the Air Board, and consider asking the legislature for additional statutory authority to regulate land use.

CARB and the state have a remarkable opportunity to meet our shared climate goals while enriching California in innumerable other ways. We believe that ignoring this opportunity in favor of speculative, unproven approaches to climate mitigation would be a mistake.

We appreciate having the opportunity to submit this comment and look forward to working with CARB to achieve our housing, climate, and clean transportation goals.