On Wednesday and just in time for the Independence Day long weekend, the City of Cleveland Office of Sustainability released its long-awaited (by me, anyways) draft Climate Action Plan. As one would expect with a draft report, the city is welcoming public comments, so I went through the document with a fine-toothed comb yesterday. Here are my major takeaways/comments:
- Methodology: The report really calls out for a detailed methodology section. Part of sustainability is transparency, and failing to provide a clear picture of how you have reached your conclusions undercuts this goal. This methodology could take many forms, such as a complete section at the start of the report or a shorter section at the beginning with a detailed technical appendix at the end. However it is done, this piece is an essential component. It’s important for people reading and tracking the Climate Action Plan to know what emissions scenario was used, where the temperature and precipitation projections are coming from, and whether a sensitivity analysis was completed. I understand the desire to make this easily approachable to the general public, and I laud that. Perhaps the technical annex would be the better alternative.
- Methodology Part 2: On page 12 of the draft, the report discusses the costs and benefits of the proposed action plan. However, once again, it demands a methodology for how this cost-benefit analysis was completed (provided one actually was). What were the assumptions and parameters that went into this calculation? What was the discount rate (for a good primer on discount rates, read David Roberts’ piece) used? Did it include a sensitivity analysis?
- Business As Usual Projections: On page 20, the report describes future projections and how its authors put together the Business As Usual (BAU) baseline that was used. Clearly, as with all medium- to long-term climate plans, these projections carry a high level of uncertainty. The report discusses this issue by saying:
Due to the high level of uncertainty associated with this type of forecasting exercise, a flat line BAU forecast was assumed for now. However, this assumption of no growth or decline in emissions can be adjusted in the future to account for changing conditions.
I have to question the decision to approach uncertainty in this manner, however. It seems to me that the best practice for approaching uncertainty is to internalize that uncertainty and attempt to manage the associated risk. Accordingly, I would prefer to see the flat line forecast used as just one of a few different BAU models. It could constitute a mid-range analysis to be supplemented by low-range (conditions improve significantly in the region) and high-range (conditions significantly deteriorate in the region) analyses.
- Parking Minimums: In Focus Area 3, Sustainable Mobility, the report notes the City’s desire to “reduce single occupancy vehicle mode share from 69% to 62% by 2020, 55% by 2030.” Logically, one action step noted to address this goal is to “review parking space requirements and prioritize advanced parking strategies.” Unfortunately, the report never directly mentions the issue of minimum parking standards. As Matt Yglesias from Slate has discussed on many occasions, minimum parking standards are a major urban planning boondoggle that waste valuable public space, lower economic production, and reduce tax revenues. Cleveland is considerably overbuilt currently, and our abundance of parking is not something we should be proud of. The city was recently included as one of 16 cities in Streetsblog’s “Parking Madness” competition. We should be lamenting the fact that the Warehouse District has undergone this transformation since the 1970s:
- Plastic Bags: Page 55 of the Climate Action Plan (part of Focus Area 4: Waste Reduction & Resource Conservation) alludes to the challenge of properly managing plastic bag waste:
An organized and coordinated approach to waste reduction and diversion across the Cleveland community, starting with policies that restrict certain materials, such as plastic bags, or divert others, such as organic waste, are important tools in encouraging waste reduction both at the residential and commercial level.
Interestingly, despite noting the issue, the plan never goes so far as to propose implementing a plastic bag tax. It stops short of this approach, calling instead for implementing an “approach that significantly reduces the use of disposable plastic bags, including a public education campaign.”
While I understand that you don’t want to promote a specific approach without studying alternatives, the Climate Action Plan could have at least suggested conducting a study of the extent of plastic bag waste in our watercourses and landfills. This was the first step Washington, DC took prior to implementing its bag tax. The District’s study found that plastic bags accounted for 21% and more than 40% of total waste in the Anacostia River and its tributaries, respectively. Within just the first five months of its program, which applies a $0.05 tax on bags, DC saw plastic bag waste fall by 60% and raised $2.5 million in revenues. Surely a similar program could help reduce Cleveland’s waste stream and improve its paltry 9.25% recycling rate.
Overall, I’m pleased with the draft Climate Action Plan, and I think it represents a good first step in the right direction. The City assembled an impressive working group of diverse stakeholders and fielded input throughout the process. That said, I definitely think it can be better, and I hope they will consider my comments. I have also submitted a copy of marked-up version of the plan directly to the Office of Sustainability for their review.