Report 2020-114 Recommendation 8 Responses

Report 2020-114: California Air Resources Board: Improved Program Measurement Would Help California Work More Strategically to Meet Its Climate Change Goals (Release Date: February 2021)

Recommendation #8 To: Air Resources Board, State

To ensure that the State is positioned to assess the status of the Sustainable Communities program, by April 2021 CARB should report to the Legislature whether it will have a usable source for measuring regional GHG emissions in time for the 2022 report. If CARB believes it may not, it should identify any administrative or bureaucratic barriers it faces in accessing data it needs for the estimates and request relevant action by the Legislature to make those data available.

60-Day Agency Response

Since completing the 2018 Progress Report on California's Sustainable Communities and Climate Protection Act, CARB initiated efforts to better measure and track SB 375 progress at a regional level. One of these efforts is tracking additional region-specific metrics in each metropolitan planning organization's (MPO) sustainable community strategy (SCS) starting with third-round SCSs. While these metrics are not direct measures of GHG emissions or VMT, they provide additional context on progress toward expected plan outcomes to meet GHG targets set by CARB.

Additionally, CARB is exploring using retail fuel sales data from the California Energy Commission in conjunction with statewide fuel sales data from the California Department of Tax and Fee Administration to estimate regional VMT and GHG emissions. Early analysis indicates that this could be a useful approach for MPOs whose VMT is relatively contained within the region. Results from this approach will not provide a complete picture for all regions, but it will be an improvement to CARB's previous analysis. This is the approach we will use for the 2022 Progress Report.

For future reports, CARB is exploring the viability of using big data. Big data could provide a complete accounting of VMT and where it is occurring, and an insight on travel behavior and trends through the consolidation of location data from millions of mobile devices. CARB anticipates needing new staff and contract resources to acquire and analyze big data for this purpose.

We notified Assemblymember Rudy Salas, Chair of JLAC, of this work on April 20, 2021.

California State Auditor's Assessment of 60-Day Status: Fully Implemented

CARB's response, and its letter to the Legislature informing it about CARB's planned course of action, do not satisfy our recommendation that CARB inform the Legislature whether CARB will have a usable source for measuring regional GHG emissions in time for the 2022 report. Instead, the letter indicates that CARB is exploring the use of fuel sales data, but cautions that this approach may not provide "a complete picture for all regions".

Because of this ambiguity, we reached out to CARB for clarification. When we did so, CARB confirmed that it will use the fuel sales data in the 2022 report and indicated that it has found additional data sources that it believes will address the limitations described in its initial response. Therefore, because CARB has committed to this approach, we consider the recommendation to be fully implemented.

All Recommendations in 2020-114

Agency responses received are posted verbatim.