SB 375’s Emissions Gap: Explained

There is a seven percent gap in the Air Resources Board (ARB) framework to achieve GHG goals by reducing automotive travel. The gap results from reductions called for in the Scoping Plan and the targets set under SB 375.  As a result, state goals require additional actions. To date, most of the scrutiny over emissions in the “SB 375 category” (our phase for reductions related to reduced emissions from cars and light trucks) have focused on regional efforts.  Fair enough. But little attention has been given to what additional state strategies are needed to address the seven percent gap.  We explain.

What are the SB 375 Targets?

The SB 375 targets require Metropolitan Planning Organizations (MPOs) to incorporate a set of GHG reduction strategies (called a Sustainable Communities Strategy or “SCS”) within a Regional Transportation Plan.  The current targets range from 13 to 19 percent per capita and result in an 18 percent reduction in SB 375 Category emissions statewide.  [See Scoping Plan-Identified VMT and State Climate Goals, page 3].

How Do the SB 375 Targets Fit Within the Scoping Plan?

The Scoping Plan describes how to achieve the GHG reduction goals set by SB 32. The statutory goal requires a 40 percent reduction in statewide emissions by 2030 (from the total emissions in 2020). The Plan also lays the groundwork for how the state can achieve an 80 percent reduction by 2050. [See Executive Orders S-03-05 (Schwarzenegger) and B-30-15 (Brown)].

SB 375 emissions would decrease by 25 percent. [See Scoping Plan, page 75.] This figure derives from an assumption that vehicle miles traveled (VMT) would decrease by 15 percent by 2050 (based on the Executive Order goal) in yet another ARB plan called the Mobile Source Strategy. [See Mobile Source Strategy, page 36-37; and model details on page 166].

Confusing, we know. But if you were reading closely you may have caught that these metrics do not align. The SB 375 targets achieve per capita GHG emission reductions by the year 2035 using 2005 as a base year. Alternatively, the Scoping Plan/Mobile Source Strategy assumes VMT would decrease in years 2030 and 2050, but uses 1990 as a base year. Making matters more complicated, only the “40 percent by 2030” goal is in statute; the “80 percent by 2050”  is in an executive order.

After a lot of math, ARB reconciled the differing authorities, metrics, and target years. It estimated that a 7.5 percent reduction in VMT by 2035 would be in line with a 15 percent reduction by 2050.  ARB then determined that a 7.5 % VMT reduction was the equivalent of a statewide SB 375 target average of 25 percent. [See Scoping Plan, page 75; see also: ARB SB 375 Workshop Presentation, slide 19].

Ergo, the Seven Percent Gap

Thus, there is a seven percent gap between the 25 percent reduction in the Scoping Plan and the 18 percent target average set under SB 375. ARB acknowledges that although the SB 375 targets “make significant progress,” they do not “provide all of the reductions that will be needed” to meet the State’s climate goals.  [See Scoping Plan, page 75; see also Scoping Plan-Identified VMT and State Climate Goals, page 4].

Why Weren’t the SB 375 Targets Set at 25 Percent?

The short answer is that MPOs do not have sufficient authority. ARB explored setting higher targets but concluded that MPOs lacked sufficient resources and authority.  [See Scoping Plan-Identified VMT and State Climate Goals, page 3]. For example, “other factors,” like gas prices and employment. affect travel behavior. The constant change in external factors requires policymakers to “think through what tools and practices will allow each region to meet its goal.” [See SB 150 Report, page 24].

More Intergovernmental Partnership

“Structural changes and additional work by all levels of government are still needed to implement regional strategies. Staff and elected officials of local, regional, and state government have critical authorities and roles to contribute. … But as a whole, all actors responding rationally to the incentives, political forces, and policy restrictions in front of them have not been able to enact the magnitude of change needed. … The current structure of policies and lack of incentives will continue to produce and exacerbate the insufficient results unless shared responsibility, changes in authority or mandates and incentives, and strong, deliberate, collaborative action is taken to change them. CARB finds that this disconnect impedes progress on attaining the SB 375 targets and their co-benefits.”

[See SB 150 Report, page 56].

In other words, achieving the full reductions in the “SB 375 category” requires cooperation at all levels of government: local, regional, and state:

  • While no single agency or level of government alone bears the responsibility for this work; there is an important opportunity to partner across many agencies on taking collaborative action toward better results. [See SB 150 Report, page 4].
  • More discussion among a broad suite of stakeholders from transportation, the building community, financial institutions, housing advocates, environmental organizations, and community groups are needed to develop the needed set of strategies to achieve necessary VMT reductions. [See Scoping Plan, page 75].
  • California – at the state, regional, and local levels – has not yet gone far enough in making the systemic and structural changes to how we build and invest in communities that are needed to meet state climate goals. To meet the potential of SB 375 will require state, regional, and local agency staff and elected officials to make more significant changes across multiple systems that address the interconnected relationship of land use, housing, economic and workforce development, transportation investments, and travel choices. [See SB 150 Report, page 6].

Is There a Plan to Address the Seven Percent Gap?

No. Table 17 of the Scoping Plan does provide a list of statewide strategies. But there is no comprehensive plan to achieve reductions beyond the 18 percent assigned to regional agencies. One of the state’s most recent actions is to add the SB 743 VMT analysis into the CEQA Guidelines. This new rule will likely affect land use economics in a way that will yield GHG reductions. [See our SB 743 Resource Center]. But it would be aggressive to think it would cover all, or even most, of the seven percent gap.

Table 17 of the Scoping Plan also lists three additional strategies:

  • Pricing.  Policies to support low-GHG transportation (e.g., road user, parking pricing, transit discounts)
  • Performance Measures.  The state will harmonize performance with emission reductions and increase the competitiveness of transit and active transportation modes vial guideline documents, funding programs, and project selection.
  • Electric Cars (ZEVs).  The operation of 1.5 million zero and hybrid electric vehicles on California roads by 2025; and 4.2 million by 2030.  (Note: this goal would reduce GHG emissions, but not necessarily lead to VMT reductions).
[See Scoping Plan, page 103]. Of these, ZEV policy and pricing measures fall clearly outside the authority of MPOs. Harmonizing performance with emission reductions in state grant programs also falls within state authority, although many MPOs apply similar selection criteria to increase the competitiveness of different project types.

And finally, there is Appendix C. The Scoping Plan recommends that the gap be addressed by additional VMT measures “mentioned in Appendix C.” [See Scoping Plan, page 79]. Appendix C lists about 30 high-level policy concepts that the state should “explore.” Many of these policies (like pricing and land use controls) require a heavy political lift. The nine-page document lacks a fiscal analysis or discussion of priorities.  As a result, it is difficult to conclude that the policies in Appendix C are part of a larger integrated plan.

What’s Our Point?

Better understanding. People give us confused looks every time we raise the issue.  We are sympathetic: it’s difficult to sort through all the ARB documents to draw a distinction between the reductions in the SB 375 targets and the Scoping Plan. There is also a lot of room for misinterpretation. That is why we relied so heavily on ARB’s documents here. Our hope is that in distilling all this information it will help build common ground among stakeholders. Hopefully, it helped.

ARB Document Quick Reference Links