Who should be accountable when it appears a Sustainable Community Strategy (SCS) will not achieve the target set by the California Air Resources Board (CARB)? Most believe the answer is obvious: It should be the Metropolitan Planning Organization (MPO) that adopted the SCS.
But we think differently. Our answer is: “it depends.”
Here’s why. Although MPOs are indeed responsible for developing the SCS, their authority to enact all of it’s strategies is limited. In addition, the types of decisions in which MPOs have the most influence (like investment decisions) have less effect on GHG emissions from cars and light trucks than other state-level policies that affect personal driving decisions. Similarly, local land use decisions also affect the long-term efficacy of MPO investments.
As a result, many of the most significant policy levers needed for successful SCS implementation are in the hands of other governmental agencies. We’ll explain.
Broadening SCS Accountability
As we described in Mostly Infill with a Chance of Sprawl, the Regional Transportation Plan (RTP) does not guide land use in the same way as a city or county general plan. (Remember: the SCS is part of the RTP). Thus the RTP/SCS relies on sophisticated forecasts for travel demand, economic growth, and other factors to estimate the region’s anticipated transportation needs. The MPO then selects a set of projects and strategies that will achieve an emissions reduction goal and serve the region’s mobility needs.
Note that the authority to enact these projects and strategies lies with a combination of state, regional, and local agencies. For example, a typical RTP/SCS might include strategies to increase housing densities in transit corridors (requiring local zoning), funds to increase transit capital in key corridors (requiring regional project programming), and statewide programs that support transit operating costs (requiring state legislation or budget appropriations).
Now fast forward ten years. What happens the emissions-reduction target will not be achieved? Who is accountable?
The answer is: “it depends.”
Although it may seem logical to blame the MPO (it was their plan after all), a more accurate analysis would group the strategies by responsible agency and then review where progress has been made (and where it has not). Has the zoning materialized? have the right kind of projects been programmed? Has the state actually developed a program to make transit more affordable?
This kind of analysis will provide a more accurate picture of what has actually happened and should lead to more effective discussions of how to improve SCS implementation going forward.
To give a real-world example: consider the recent RTP/SCS, Plan Bay Area 2050, adopted by the Metropolitan Transportation Commission. CARB certified that the plan would indeed achieve its target if implemented. The RTP/SCS is very ambitious. It requires a great deal from MTC and the Bay Area’s local governments. But it also assumes significant state actions. Here, three planning assumptions are particularly noteworthy: (1) that a well funded state rail plan will allow several key Bay Area projects to proceed; (2) that all lane tolling will be permitted on most of the state highway corridors in the Bay Area; and (3) that the state will act to authorize a 55 mile per hour speed limit on state highways in the Bay Area.
So let’s go back to that exercise. Fast forward to 2035 and assume that cars are still driving 65 mph on general purpose (untolled) lanes and the funding gap for state rail projects was not filled. How should we analyze accountability for the implementation of MTC’s SCS then? To what extent should MTC be held accountable? What is the state’s level of accountability?
The Biggest Implementation Gaps Require State Action
Our point is that the SCS blends accountability among state, regional, and local agencies. As a result, any review of SCS implementation should account for this structure. Too narrow of a review overlooks key ways that the state must be supporting these efforts.
But to date there has been little review regarding how the state is doing in its SCS implementation role. We first raised this issue in SB 375’s Emission Gap Explained. More recently, CARB concurred that additional state action is necessary.
But don’t take our word for it. Read theirs.
Tracking Progress, the second SB 150 report (posted as a draft in June 2022) is a good read. The report tracks whether the SCSs are working. Not surprisingly, it finds that California is still not reducing GHG emissions from personal vehicle travel as needed under SB 375. Californians are still choosing to drive.
So the report must blame the MPOs, right?
No. Instead, CARB determines that SCS implementation requires better alignment across state, regional, and local actions. The report says that the current toolbox is insufficient for the job; and that more state resources are needed to implement its recommended strategies.
The crux (at least for us) of the report is the 20 pages of CARB recommended actions. (See pages 38 to 57). There are a total of 56, of which 52 require the state to enact new legislation or take administrative action (either solely or in partnership with regional and local agencies) that would improve MPOs ability to reduce emissions. To compare, regional agency action is identified in 26 of the strategies (often working in collaboration with a state action). Only 11 are local in nature. (Check our Work).
That begs the question: How can MPOs be solely accountable for SCS implementation when so much more State policy is required? Or even better: If CARB has determined that success hinges on new state policy and funding, how are we tracking the state’s implementation progress?
To be clear, we are not excusing MPOs from accountability. (It is their plan after all). We only suggest that it’s time to broaden the scope of accountability enough to hold the state more accountable. Successful SCS implementation depends on it.
Ergo, A New Accountability Matrix
We would like to continue the conversation that CARB started. We tried to summarize the recommendations in the Tracking Progress report (with a few of our own) in a one page table. It’s a small start. We hope that it can help us move past the conversation of whether SCSs are merely “on track” toward a more helpful understanding as to why SCSs–or are not–being implemented.
Please take a look. And let’s continue the conversation.
- View the PDF version of our Accountability Matrix (with small print); or
- Use the Accordion View below
And a Format for Web Viewing
The neat structure of the PDF document cannot be duplicated on this webpage in a way that will be easy to view on the multiple devices accessing this page. Thus, the tiles below represent the major strategy areas for SB 375 implementation (the rows of the table). Click on the plus sign to see a list of actions that could be applied by local governments, regional agencies, and the state (which are the columns of the table).
Caveats: (1) Not all of these strategies are right for every region; particularly rural areas. Local conditions will dictate the choice and implementation of polices for the best result. (2) “Externalities” like overall economic activity, gas prices, penetration of autonomous vehicles and other external influences may affect the ability of any or all of these strategies to achieve the overall goal. (3) This table was developed with a specific focus on GHG emissions. All climate policies, however, should be reconciled for potential conflicts or barriers related to other state goals related to equity, housing, economic prosperity, and other environmental goals.