needs high quality jobs, new manufacturing facilities and small
business growth. Rational state environmental policy, supported by
economic impacts analysis, will help us achieve these goals.

Unfortunately, the state is implementing another expensive
environmental program that drags the economy farther down. SB 375,
passed into law two years ago, seeks bold greenhouse gas emission
reductions by controlling regional planning policies.

As the lead agency, the California
Air Resources Board (CARB) has been charged with working with Regional
Metropolitan Planning Organizations (MPOs) to determine reasonable and
achievable greenhouse gas targets to meet the goals of SB 375. The
substantial undertaking started out as a collaborative process but it
has turned into a disaster for the economy.

In Northern California, the
Metropolitan Transportation Commission (MTC), the planning,
coordinating and financing agency for the nine-county San Francisco Bay
Area, modeled their most aggressive target at 12 percent greenhouse gas
emission reduction by 2035. The MTC highlighted that the most
aggressive targets are "not considered attainable by any stretch of the
imagination." Despite this warning, CARB’s suggested target for the Bay
Area is 15 percent by 2035.

MTC concluded that a target of 12 percent (let alone 15 percent) would
require gas prices of $9 per gallon to encourage less driving.

Similarly, the Sacramento Area Council of Governments (SACOG) evaluated
significant new transportation pricing policies to meet the SB 375
targets. These include congestion pricing for the region’s major
freeways, with tolls ranging from 10 to 25 cents per mile; a general
miles-traveled charge of 1 to 3 cents per mile; increased off-street
parking charges at employment centers; and additional subsidies to
transit fares. Overall, annual travel costs could skyrocket 460 percent
to meet these standards.   This will have severe effects on consumers
and local manufacturers already struggling to compete in California.

The CARB targets also count on a poor economy and lost jobs as a tool
to meet greenhouse gas emission reduction targets. According to MTC’s
analysis, forecasting and planning for 180,000 fewer jobs and less
economic growth could result in 5 percent emission reductions. It’s
hard to tell from the analysis whether that is a goal that CARB wants
to achieve or just a bad situation that they can use to their
advantage. For the more than 630,000 workers whom have lost their
manufacturing jobs over the last decade, they’d be a lot more
comfortable with a policy that actually worked to increase high wage

Smart growth is a goal we all share.  But CARB staff has proposed
target levels that are neither "smart", nor growth-oriented. Deemed
unachievable, the targets will discourage new business investments,
incite a flurry of California Environmental Quality Act lawsuits and
result in the loss of more quality jobs in the manufacturing and small
business sectors.

CARB is scheduled to meet on September 23rd to consider adopting the SB
375 targets.   For the good of the state, these targets need to be
fully vetted for their job and economic impacts. CARB staff needs to
reveal the reasons for the last minute changes that set the target
levels at or above the unachievable levels. And, if the CARB board
approves these targets, they need to detail the policies that will be
pursued to meet the targets.

We have seen the consequences of adopting far-reaching policies without
first evaluating the economic impacts. Let’s not make that same mistake
with the SB 375 implementation.