Revised GHG Targets--BIA Successfully Pushes for Housing Reform Language

Pursuant to SB 375, each region is required to adopt a Sustainable Communities Strategy (SCS) that contains per capita GHG reduction targets for the land use and transportation sectors. The targets are assigned to each region by the California Air Resources Board (CARB). The Bay Area's current target is a 15% reduction by 2035 from 2005 levels. CARB is now considering new 2035 targets for the region that will apply to the next SCS update in 2021. At its April 2017 meeting, MTC approved a recommendation to CARB that the Bay Area's GHG reduction target increase to 18% for the next SCS. MTC conditioned its support for a revised GHG target, however, on the state undertaking significant legislative and regulatory reforms, with one of the key areas on which MTC conditioned its support being state-level housing reform. Specifically, conditioned its recommendation on the state legislature "strengthening state mandates and incentives to better align housing production and employment center proximity."

The addition of the housing reform condition was recommended by BIA because conditioning any increase in GHG reduction targets on significant state level reform--especially housing production--is important to prevent the state from indirectly forcing regions and local governments to continue to project ever more extremely dense future housing development patterns. BIA testified that the region's SCS has already gone as far as possible in assuming GHG reductions from more dense and intense housing development patterns, and that the region is already falling short of achieving its existing SB 375 housing and GHG reduction goals in large part because local governments retain significant discretion to refuse to approve the housing that is being called for in the SCS, and that some of the projected housing may never be economically feasible. BIA also argued that it is important for MTC to communicate to CARB that it and other state agencies cannot simply expect regions to project ever denser housing patterns in order to justify ever higher GHG reduction targets. MTC recognized BIA's key points, with the staff report expressly acknowledging that the Bay Area's existing SCS is already "push[ing] the envelope in terms of focused growth in land use" and that "feasible land use strategies are not sufficient to achieve the needed reductions in GHG emissions."