1. Differing baselines: Many local jurisdictions are using data from different baseline inventories, impeding apples-to-apples comparison of climate action goals across cities, counties, and metropolitan planning organization (MPO) boundaries.
2. Inconsistent projections of policy and program impacts: Many local jurisdictions have developed their own formulas for projecting the impact of common GHG reducing strategies – ranging from energy efficiency measures to the impact of transit-oriented development on vehicle miles traveled (VMT).
3. Uncertainty with respect to “crediting” state policies and programs: No regional or statewide consensus currently exists on the key issue of how much to “credit” state policies and programs for potential success in reducing GHG levels in coming years. For example, many local climate planners are unsure how to account for the likely impact of the Pavley Standards, the Low Carbon Fuel Standard (LCFS), the Renewable Portfolio Standard (RPS), Title 24/25 energy efficiency standards, and other key initiatives.
In the absence of a common approach, some local jurisdictions project that state policies and programs will be sufficient to achieve nearly all of the required reductions under AB 32, while others expect that the preponderance of reductions must be achieved primarily through local and regional action. The ambiguity surrounding this key issue has deterred many local decision-makers from moving forward with robust climate action initiatives.
4. Local climate action plan development cost, complexity, and resourcing: Only a handful of the more progressive and financially capable of California’s more than 500 cities and counties have completed local Climate Action Plans (CAPs). For many municipalities, this reflects the reality that CAPs can be very time-consuming and costly to produce, often assuming the character of General Plans in terms of their demand on staff and consultant time, public process, and CEQA review.
Moreover, even those cities which do complete their CAPs may find that they are subject to “file and forget” treatment. In some cases, many of the recommended actions are so modest in terms of impact (e.g., “switching from 30% to 100% recycled paper”) that they do not add up to a meaningful impact on local emissions. In other cases, proposed measures may be so ambitious and resource-intensive (e.g., “install 20 MW of new solar PV”) that they do not pass the feasibility test.
Finally, many municipalities are discovering that there are few effective policy levers to drive GHG reduction within their individual jurisdiction purview – and that the bulk of high-impact strategies will require the coordinated action of multiple jurisdictions, including counties, regional agencies, and the state. To date, some counties have begun to develop effective intra-county climate consortia.
