Undermining efforts to make California a carbon efficient economy, the draft Climate Action Plan, or CAP, would allow “off–shoring” of emissions reductions for new development. This would frustrate the goal of using land use planning and transit to reduce greenhouse gas emissions (GHGs).

As background, state policy sets ambitious targets for reducing GHGs by 2030. According to the California Air Resources Board, vehicle miles traveled (VMT) reductions are “necessary” to achieve this target. See document here. Under SB 375, all regions in the state prepare Sustainable Community Strategies in which planned new development reduces automobile use and increases transit use in order to cut carbon emissions.  

Even though land use and transportation is the single thing that local governments absolutely control, the Department of Planning and Development Services proposes to do nothing to change patterns of future growth and development, contending that there are no “feasible” ways to do so. Specifically, the CAP contains no requirement to reduce vehicle miles traveled in newly planned residential development.

Instead of requiring newly planned development – specifically amendments to the current General Plan – to reduce automobile use through proper location near jobs and services, projects can claim carbon emissions reductions by purchasing offsetting “credits” when on–site measures, like energy efficiency, aren’t enough. Offsets may be out–of–county, out–of–state, and out–of–nation, in quantities only limited by determinations of “financial feasibility,” as judged by the Director of the Department, with no guidelines offered. In contrast, a GHG–emitting power plant in California is only allowed to go out–of–state for a tiny fraction of its emission reductions. 

We can expect the developers themselves to prepare the feasibility determinations. The draft CAP is nothing less than a “green light” for automobile dependent sprawl in remote locations, and completely undermines the Sustainable Community Strategy prepared by the San Diego Association of Governments. 

While the CAP says that GHG emissions from cars will go way down, the actual distances traveled by cars go way up. There is no evidence that this gap will be closed by a huge shift to electric vehicles, nor evidence that sufficient offsets for new development will actually be available, enforceable, or effective. In effect, by allowing unhindered sprawl and increased vehicle miles traveled, the plan “shoots itself" – and the region – "in the foot.” Presumably, the County expects the cities to make up for its own bad behavior.

The goal should be for the County to reduce its own emissions, and do its fair share in reducing regional vehicle miles traveled. By reducing far flung development, GHG emissions are avoided in the first place. Reducing sprawl also saves natural and agricultural open space, and the County’s essential character.

And what is “feasible” for developers? We have our answer in the automobile–dependent Newland Sierra project near Twin Oaks which intends to reduce only 18% its emissions through on–site measures, and the rest through remote offsets.