Broadening Accountability for SCS Implementation

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.”

If ARB has determined that success hinges on new state policy and funding, how are we tracking the state’s implementation progress?

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.

The State must authorize and fund more strategies that support SCS implementation.

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.

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).


Local Government Actions

  • Specific Plans for infill and corridor areas, including TOD plans and policies
  • Use higher densities in urbanized areas
  • Plan for Jobs/Housing balance
  • Leverage CEQA streamlining
  • Limit auto use near transit corridors
  • Use EIFDs, NIFTIs, AHAs to finance infill
  • Reduce cost and/or time of infill projects (permit streamlining, by-right zoning)
  • Reduce minimum parking standards
  • Conserve open spaces and agriculture

Regional MPO Actions

  • Identify strategic growth areas in RTP/SCS
  • Provide incentives, information, tools, technical assistance, and encouragement to support local planning and implementation
  • TOD plans and policies
  • Allocate REAP funds to local agencies to transform infill communities
  • Encourage TOD policies
  • Consider SB 743 mitigation banks or exchanges

State & Legislative Actions

  • Find a “real” replacement for redevelopment
  • Enlarge Infill Infrastructure Grant (IIG) program
  • Expand tax increment financing options and other financing tools for infill supportive infrastructure (e.g., water, sewer, electrical, telecommunications, active transportation, urban greening, and parks).
  • Build mixed use at under-used public sites
  • Create certainty administrating SB 743 mitigation banking or exchanges
  • Reduce CEQA barriers to density and affordable housing in transportation-efficient areas

Local Agency Actions

  • Housing Element updates, including zoning for more multi-family housing
  • Specific Plans for infill and corridor areas, including TOD plans and policies
  • Plan for higher density uses in areas with existing infrastructure
  • Plan for Jobs/Housing balance
  • Reduce minimum parking standards
  • Reduce cost and/or time of development (permit streamlining, by right zoning, reduced parking requirements, etc)

MPO Regional Agency Actions

  • Work with local agencies to allocate RHNA in location efficient areas
  • Encourage mitigation of displacement in areas identified for revitalization
  • Fund Regional Housing Trusts and regional housing finance authorities
  • Provide incentives, information, tools, technical assistance, and encouragement to support Housing Element updates
  • Allocate REAP funds to local agencies to accelerate housing

State and Legislative Actions

  • Fund catalyst infrastructure (water, sewer)
  • Fund housing and infill projects that accelerate VMT-reduction such as REAP 2.0, AHSC, TCC
  • Scale up factory-built housing production, investing in workforce development, reduce time and cost of delivering multifamily infill housing
  • Incentivize conversion of a broader array of opportunity sites for affordable housing construction including redevelopment of aging malls, office parks, and other major reuse sites

Local Agency Actions

  • Improve Circulation, ATP & Trail Plans
  • Adopt Vision Zero Plans and policies
  • Include Vision Zero Revitalization for LSR & RMRA funded projects
  • Seek ownership of urban state highways
  • Traffic calming to improve safety
  • Use authority to reduce auto speed limits
  • Enforce safety laws

MPO/Regional Actions

  • Prioritize regional funding
  • Regional Vision Zero plans and policies
  • Provide incentives, information, tools, assistance to support implementation
  • Fund bike highway & trail systems
  • Promote civic engagement and awareness like GoHuman; May is Bike Month

State and Legislative Action

  • Improve design guidelines
  • Adopt statewide safety standards
  • Expand funding for state programs (such as ATP, REAP, TIRCP, LCTOP)
  • Further approve lower auto speed limits
  • Add facilities in Caltrans ROW (where appropriate)
  • Support & fund non-infrastructure safety programs like Safe Routes to School

Local Agency (including Transit Agencies) Actions

  • Improve Circulation Elements
  • Improve Transit Route Design
  • Improve transit stops/stations/facilities
  • Increase access to transit by increasing development density near transit
  • Increase transit frequency
  • Micro-mobility or on-demand service
  • Reduce fares or offer free fares
  • Invest in transit quality (e.g., safety)
  • Plan for first/last mile connection options

MPO/Regional Agency Actions

  • Provide technical & grant assistance to improve the frequency, hours of service, and coverage
  • Fund more bus rapid transit, express bus, and frequent fixed-route service
  • Transit/Mobility Hub planning
  • Fund TOD Plans and policies
  • Prioritize funding in low VMT areas
  • Facilitate fare sharing between providers

State and Legislative Actions

  • Find long term funding support for operations
  • Update the State’s Transit Strategic Plan
  • Fund local transit improvements
  • Implement and fund the State Rail Plan
  • Fund TIRCP as provided in FY 22-23 budget
  • Directly fund transit transition to electric buses
  • Ensure affordability for everyone
  • Reduce threshold for locally funded sales taxes that fund transit and multi-modal investments Complete the High-Speed Rail (HSR) System

Local Agency Actions

  • Regulate Curb access
  • Adopt local TDM policies
  • Reduce minimum parking standards
  • Reduce auto speed limits
  • Price parking
  • Safe Routes to School Programs
  • Broadband to support shifts in telework
  • Innovative education focused on promoting a variety of alternatives to driving alone

MPO/Regional Agency Strategies

  • Support transit and local agencies to develop, test, and pilot new mobility services such as microtransit, bike share.
  • Regional and local TDM programs
  • Implement HOV & HOT lane programs
  • Coordinate regional broadband/digital equity (Telework and remote services)
  • Innovative education to promote alternatives to driving alone
  • Partner state & locals to reduce speed

State and Legislative Actions

  • Develop a statewide transportation demand management (TDM) framework
  • Reduce speeds on state highways (e.g., 55 mph)
  • Authorize bus on shoulder programs
  • Innovative education focused on promoting a variety of alternatives to driving alone
  • Establish an statewide system for trip planning, booking, payment, and user accounts that enables efficient and equitable multimodal systems
  • End the State’s subsidies for employee parking

Local Agency Actions

  • Adopt paid parking ordinances
  • Regulate curb access in high use areas
  • Use paid parking mechanisms (meters)
  • Use cordon pricing in high use areas
  • Offer complimentary transit programs

MPO/Regional Agency Actions

  • Planning, location identification
  • Design regional programs
  • pilots to develop new policy innovations
  • Cordon pricing (upon state approval)
  • Corridor Plans
  • Implement Tolling (upon state approval)
  • Program viable transit & TDM programs.

State and Legislative Actions

  • Authorize and implement pricing strategies
  • Convert general lanes to transit or toll lanes
  • Permit full facility tolling of state-owned facilities
  • Replace declining gas tax to maintain investments in maintenance & sustainable transportation
  • Fund complimentary transit & TDM programs.
  • Allow efficient enforcement of toll evasions

Local Agency Actions

  • Develop Local ZEV Readiness Plans
  • Incentivize or increase home, apartment, workplace, and public space charging
  • Adopt EV sharing programs l
  • Convert local government fleets to ZEVs
  • Support deployment of ZEVs by exceeding state building codes, permit streamlining, infrastructure siting, consumer education, preferential parking policies)

MPO/Regional Actions

  • ZEV Readiness Action Plans for infrastructure gaps and to facilitate regional solutions
  • Provide incentives, information, tools, technical assistance to support local governments EV plans and infrastructure
  • Invest in EV car sharing programs (like Mio Car)

State and Legislative Actions

  • Electric vehicle incentives
  • Address grid needs
  • Charging at state parks/state lands
  • Update building codes
  • Fund local, regional, and state transition efforts
  • Fund purchases of Electric buses by local transit agencies

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.


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