Draft MTP/SCS Comments Received - sacog
Draft MTP/SCS Comments Received - sacog
Draft MTP/SCS Comments Received - sacog
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What are you commenting on?<br />
Metropolitan Transportation Plan/Sustainable Communities Strategy<br />
Name<br />
John Andoh<br />
Email<br />
jandoh@ci.rio-vista.ca.us<br />
Do you want a written response?<br />
Yes<br />
Address<br />
<strong>Comments</strong> on the <strong>MTP</strong>/<strong>SCS</strong><br />
Attached are my comments on chapter 5C regarding transit. The City of Isleton has a contract with the City of Rio<br />
Vista for transit services within their community. I would request that the information on page 5C-2 include this<br />
notion.<br />
Does the tables and figures in Chapter 5C regarding bus ridership also include Delta Breeze ridership within<br />
Isleton? If not, can it be included. We have this data available.<br />
Upload Your Documents<br />
Rio-Vista-comments-to-<strong>MTP</strong>.pdf<br />
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eircomments <strong>sacog</strong> - Davis 5th Street between A and L Streets<br />
From: Jim Skeen <br />
To: <br />
Date: 12/2/2011 3:21 PM<br />
Subject: Davis 5th Street between A and L Streets<br />
I may have missed something, but it appears that there is only one project that proposes to reduce the number of<br />
lanes for vehicles and it is the one described in the subject line.<br />
It should be prioritized last. It seems motivated by politics, not rational planning.<br />
Page 3 of 165
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eircomments <strong>sacog</strong> - Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
From: <strong>MTP</strong> <strong>Comments</strong> <br />
To: <br />
Date: 12/2/2011 5:04 PM<br />
Subject: Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
What are you commenting on?<br />
Metropolitan Transportation Plan/Sustainable Communities Strategy<br />
Name<br />
Lynn Merrick<br />
Email<br />
lynn@rocklin.com<br />
Do you want a written response?<br />
Yes<br />
Address<br />
<strong>Comments</strong> on the <strong>MTP</strong>/<strong>SCS</strong><br />
At the session I attended, we all made clear that we want light rail extended to western Placer County. The plan<br />
does not make appropriate provisions to meet this need.<br />
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eircomments <strong>sacog</strong> - Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
From: <strong>MTP</strong> <strong>Comments</strong> <br />
To: <br />
Date: 12/5/2011 6:42 PM<br />
Subject: Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
What are you commenting on?<br />
• Metropolitan Transportation Plan/Sustainable Communities Strategy<br />
Name<br />
Email<br />
Brigitte Driller<br />
bkdriller@ucdavis.edu<br />
Do you want a written response?<br />
No<br />
<strong>Comments</strong> on the <strong>MTP</strong>/<strong>SCS</strong><br />
To be frank, the <strong>MTP</strong>/<strong>SCS</strong> <strong>Draft</strong> totally bummed me out. Beneath glossy discussions of sustainability, equity, and<br />
multi-modality, this draft appeared to promote a clear and disturbing goal: Business As Usual.<br />
First, I cannot understand why SACOG wants to invest so much money in new and widened roads. I bet you are<br />
thinking to yourself, 7 billion is really not that much to spend on transportation infrastructure. Let me rephrase my<br />
question: Why do you want to invest ANY money in new roadway infrastructure? The roadway network is already<br />
sufficiently built out (seriously, it is!). If congestion is the justification I may just roll over and die. More roads/lanes<br />
will not alleviate congestion in the long term. But you probably already know this, which leads me to my next point.<br />
I find your goal of reducing congestion problematic. The population growth in this region in the next 25-ish years will<br />
be immense. With this increase in population, how could congestion not increase? Regardless of whatever your<br />
model is telling you, you need to accept that congestion is going to increase, and I for one am looking forward to it.<br />
Without this increase in congestion, why would anyone choose to switch to an alternative mode?<br />
Most of all, I am severely disappointed in the targets set for nonmotorized transportation. You predict a mode share<br />
increase of less than 1% for bicycles? Really? I mean, really? If you invested zero dollars in bicycle infrastructure,<br />
bike mode share would still increase by more than 1%. Why? Because people are poor. They are getting poorer by<br />
the minute and they are going to bicycle whether you want them to or not.<br />
In conclusion, I hope SACOG will give some serious rethinking to this document. I beg you to be visionary! Set the<br />
bar high! Thanks for listening, and I look forward to a much improved final product.<br />
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eircomments <strong>sacog</strong> - Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
From: <strong>MTP</strong> <strong>Comments</strong> <br />
To: <br />
Date: 12/6/2011 8:00 AM<br />
Subject: Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
What are you commenting on?<br />
Metropolitan Transportation Plan/Sustainable Communities Strategy<br />
Environmental Impact Report<br />
Name<br />
Kerry Wicker<br />
Email<br />
osugmukaw@gmail.com<br />
Do you want a written response?<br />
Yes<br />
Address<br />
<strong>Comments</strong> on the <strong>MTP</strong>/<strong>SCS</strong><br />
Please include in both documents an immediate plan to add transit in Yolo County that connects Route 215 in<br />
Madison and/or Esparto, with Winters and Vacaville (to hook up to Solano transit). Service to/from Winters/Esparto<br />
could start for just Friday and Saturday nights to take advantage of entertainment in Winters that might include an<br />
adult beverage. Avoids DUI.<br />
Also, please fill the service gaps of YoloBus #215 to allow workers to fully commute from Western Yolo County. As<br />
is, it is not possible to stay at work a full day b/c of the 4+ hour gap in service.<br />
Please please please put in a bicycle lane (better yet, path) right away along Hwy 16 from Esparto to Woodland.<br />
Also, continuing the bike lane up the Canyon from Esparto is hugely beneficial as well. I usually ride on any<br />
roadway, but there are too many drunks/irresponsible drivers to brave the highway. The CalTrans Hwy 16 project is<br />
still in litigation, but whatever comes out should be the bike lane/trail.<br />
All these actions will reduce carbon emissions, improve public health, accessibility, water and other air quality.<br />
Let me know when you plan to add these services/infrastructure.<br />
Page 6 of 165
Roseville Public Hearing <strong>Comments</strong> from December 6, 2011<br />
Anonymous Maintenance and rehabilitation funds should apply to all modes of transportation, including pedestrian infrastructure.<br />
David Allen The plan should have accountability to hold our region to the performance goals and metrics we set in the plan.<br />
Rebecca McIntyre Transit operations should be coordinated so that transitioning among systems is a smoother process.<br />
Page 7 of 165
Woodland Public Hearing <strong>Comments</strong> from December 8, 2011<br />
Anonymous I do not think a Sac. River crossing at Broadway would have a net negative impact to Southside Park in that growth in commute traffic from W.<br />
Sac. To Downtown Sac would begin to come through Southside Park.<br />
• In a spread, longer peak period with No Broadway Bridge<br />
Kendra Bridges<br />
• In a short ≤ 1 hour peak period with a Broadway Bridge<br />
I believe the residents of West Sacramento and Sacramento would benefit from an additional multi‐modal (auto/pedestrian/bicycle) river<br />
crossing South of Highway 50 in the Broadway to Sutterville area of Sacramento. This would help on both sides of the river by often avoiding the<br />
Downtown Sacramento area.<br />
The plan should look at how infill development will affect housing prices and displacement.<br />
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eircomments <strong>sacog</strong> - Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
From: <strong>MTP</strong> <strong>Comments</strong> <br />
To: <br />
Date: 12/9/2011 7:14 PM<br />
Subject: Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
What are you commenting on?<br />
• Metropolitan Transportation Plan/Sustainable Communities Strategy<br />
Name<br />
Email<br />
Kevin Mackey<br />
kevin.mackey87@gmail.com<br />
Do you want a written response?<br />
No<br />
<strong>Comments</strong> on the <strong>MTP</strong>/<strong>SCS</strong><br />
I think the ideas and goals of the <strong>MTP</strong> are excellent. As an econ major, I would like to see more financial<br />
information or data on how the project will be sustained and possible scenarios if budget issues continue/worsen. I<br />
would like to be included on a mail list for future meetings/presentations to better understand the <strong>MTP</strong>, current<br />
progress, and how it is adapting to current successes and setbacks.<br />
Page 9 of 165
Folsom Public Hearing <strong>Comments</strong> from December 14, 2011<br />
Lindell Price<br />
All weather, predawn, and dusk bicycle and pedestrian routes are crucial to achieving the mode shifts forecasted in the <strong>MTP</strong>. Bicycle and<br />
pedestrian routes are typically affected more severely by weather than vehicular routes, making bicycle and pedestrian travel less reliable than<br />
other modes, which disproportionately affects persons who cannot afford vehicular travel (EJ issue). SACOG's future funding rounds should<br />
include criteria that take into account the appropriateness of bicycle and pedestrian facilities for all weather, year round travel.<br />
Stanley Price<br />
The delay caused by roadway incidents should be considered in congestion computations in the <strong>MTP</strong>. Understanding collision patterns related to<br />
road design, intersections, speed, and connectivity is crucial to reducing collisions and the resulting impact on circulation.<br />
The <strong>MTP</strong> should analyze the economic impact of health co‐benefits.<br />
<strong>MTP</strong> modeling should include collision projections based on past data.<br />
The EIR should address public health issues related to bicycle and pedestrian travel, including safety concerns and the economic and health<br />
benefits realized from incorporating active transportation into everyday life.<br />
The definition of "high quality transit" is restrictive. Commuter service, which typically does not run every 15 minutes, is productive and serves<br />
an important role.<br />
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eircomments <strong>sacog</strong> - Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
From: <strong>MTP</strong> <strong>Comments</strong> <br />
To: <br />
Date: 12/19/2011 8:56 PM<br />
Subject: Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
What are you commenting on?<br />
• Metropolitan Transportation Plan/Sustainable Communities Strategy<br />
Name<br />
Email<br />
Julie Nguyen<br />
julnguyen05@yahoo.com<br />
Do you want a written response?<br />
No<br />
<strong>Comments</strong> on the <strong>MTP</strong>/<strong>SCS</strong><br />
I'm glad that you guys are trying to improve our community. It's nice to know the little things can make a big<br />
difference.<br />
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eircomments <strong>sacog</strong> - Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
From: <strong>MTP</strong> <strong>Comments</strong> <br />
To: <br />
Date: 12/23/2011 11:08 AM<br />
Subject: Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
What are you commenting on?<br />
• Metropolitan Transportation Plan/Sustainable Communities Strategy<br />
Name<br />
Email<br />
ray tretheway<br />
ray@sactree.com<br />
Do you want a written response?<br />
Yes<br />
Address<br />
sacaramento tree foundation<br />
191 Lathrop Way suite D<br />
sacramento, California 95815<br />
United States<br />
Map It<br />
<strong>Comments</strong> on the <strong>MTP</strong>/<strong>SCS</strong><br />
I believe SACOG should rethink and retool its <strong>MTP</strong>/<strong>SCS</strong> to respond to the emerging set of research and studies on<br />
how urban forests contribute to the vibrancy of the Sacramento region. There is growing understanding that forests<br />
in urban settings make positive and measureable contributions to air quality, public health and well-being,<br />
stormwater quality and runoff reduction, greenhouse gas reductions, urban heat island mitigation, energy<br />
conservation and enhance the mobility choices of pedestrians and bicyclists.<br />
Without a comprehenisve urban forest element in the <strong>MTP</strong>/<strong>SCS</strong>, these critical benefits will be more difficult to attain<br />
as the Blueprint urban areas grow in size and density.<br />
There are important parallels between the changing conceptualiztion of urban forests with the one taking place in<br />
regard to rural-urban connections. In both instances, priorities are beginning to rest with the economic vitality,<br />
environmental sustainability and human health and well-being of future growth patterns.<br />
The recognition of a more important ecological and social role for urban forests leads directly to the realization that<br />
policies and programs designed to maintain and enhance urban forests in the Sacramento region must expand in<br />
purpose and scope. There is a regional need for SACOG 's Sustainable Communities Strategy to take the lead in<br />
capturing this enhanced vision of urban forests; communicating it effectively to the general public and political<br />
leadership; and encouraging its member cities and counties to develop more functionally sophisticated programs.<br />
Given SACOG's proven work on minimizing negative transportation impacts on our regions' environmental health<br />
and community well-being, increasing the region's tree canopy as part of a larger green infrastructure network<br />
provides a variety of benefits to the region's mobility, environment and people.<br />
Region-wide the lack of tree canopy in urban and suburban settings adversely affects the health and well being of<br />
its residents, contributes to higher summer ambient air temperatures and to incidences of air pollution. From<br />
unshaded parking lots, streets and highways, sidewalks and pathways, enlarging the region's tree canopy should<br />
be a goal of the <strong>MTP</strong>/<strong>SCS</strong>.<br />
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The Sacramento Tree Foundation has enlisted the support of elected officials, and their respective 22 cities and 6<br />
counties, for the regional Greenprint initiative to optimize the benefits of trees throughout the region; create<br />
sustainable urban forests; and build community-wide appreciation for our urban forests.<br />
The multiple benefits of trees can be part of the solution to some of the more intractable issues facing our region<br />
today:<br />
- healthy tree canopy above our streets, sideways and bicycle paths offer an open invitation for exercise and play:<br />
exercise is key to combating childhood obesity.<br />
- expanding the region's tree canopy to 30% and greater will filter and clean the air we breathe by removing millions<br />
of pounds of air pollutants annually; reduce ground-level ozone up to 7%; decrease health risks during extended<br />
heat waves; and mitigate the negative effects of urban heat islands.<br />
- healthy tree canopy extends the lifespan of asphalt streets by up to 30%.<br />
- shaded parking spaces reduce evaporative emissions from parked cars during summer months up to 20%.<br />
As stated in the <strong>MTP</strong>/<strong>SCS</strong> our region is at a crossroads. We will soon begin to grow rapidly following the Blueprint<br />
initiative. By incorporating a comprehensive transportation approach to rebuilding and expanding our region's urban<br />
forests in the <strong>MTP</strong>/<strong>SCS</strong>, SACOG can reap the benefits, that far exceed the costs, in making our region's<br />
communities healthy and sustainable.<br />
We believe special attention in the <strong>MTP</strong>/<strong>SCS</strong> should be directed to the role that healthy tree canopy and civic<br />
engagement can play in regaining the environmental quality and health of neglected neighborhoods. Many<br />
neighborhoods throughout the Blueprint region are underserved and economically challenged. People living in<br />
these neighborhoods often have fewer opportunities or resources to secure safe, affordable housing; transit<br />
options; nearby employment; safe places to be active including parks and greenspaces; a healthy tree canopy; and<br />
most effected by the impacts of air pollution. Dirty air incurs costs from human health to environmental degradation.<br />
Neighborhoods that are deprived of trees are deprived of everything a neighborhood should be: safe, welcoming<br />
and full of vitality. Expanding and caring for a healthy tree canopy are practical ways to engage people of all ages,<br />
and all neighborhoods, to revitalize their communities.<br />
Page 13 of 165
December 23, 2011<br />
Board of Directors<br />
Sacramento Area Council of Governments<br />
1415 L Street Suite 300<br />
Sacramento, CA 95814<br />
Re: Metropolitan Transportation Plan/Sustainable Communities Strategy 2035<br />
Dear SACOG Board of Directors:<br />
We are pleased to offer our comments on the <strong>Draft</strong> Metropolitan Transportation<br />
Plan/Sustainable Communities Strategy 2035, and thank you for the opportunity to continue<br />
our involvement in planning for transportation and land use needs in the Sacramento region.<br />
The <strong>MTP</strong>/<strong>SCS</strong> moves the region in the right direction by focusing on meeting the needs of our<br />
growing population through compact growth, with a variety of transportation mode options,<br />
and with the needs of all communities in mind.<br />
To ensure that all residents in the region have the opportunity to thrive, the transportation<br />
network must be planned for all users. It must include reliable, affordable access to multiple<br />
modes, including transit, walking, and bicycling. It must serve all of our neighborhoods, linking<br />
jobs, housing options at all income levels, services, educational institutions and opportunities<br />
for recreation.<br />
The Coalition on Regional Equity (CORE) advocates for regional development that is equitable,<br />
sustainable and promotes public health for lower income people and communities of color in<br />
the greater Sacramento Region. The Coalition includes affordable housing advocates and<br />
developers, environmentalists, transportation advocates, homeless and anti-poverty advocates,<br />
social service providers, civil rights leaders and health groups. We have a vision for the<br />
Sacramento region that includes opportunities for all residents to live in communities rich with<br />
jobs, connected by transit as well as bicycle and pedestrian networks, accessible to services and<br />
recreation, and without threat that public investment will drive housing costs up and displace<br />
residents from their homes.<br />
The <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> makes strides toward achieving this vision of a sustainable, equitable<br />
region. However, we respectfully recommend that SACOG strengthen and enhance the equity<br />
provisions of the <strong>MTP</strong>/<strong>SCS</strong> that address the transportation and planning needs of low-income<br />
communities, communities of color, other vulnerable populations, as well as preserve our<br />
natural habitat. We believe SACOG should do so for two reasons: first, it will bring the<br />
nd federal legal and regulatory<br />
Page 14 of 165
Coalition on Regional Equity <strong>MTP</strong>/<strong>SCS</strong> Comment Letter, Page 2<br />
obligations; second, more equitable transportation and land use planning will facilitate more<br />
robust and sustainable economic growth in the region. 1 recommendations to achieve<br />
this are as follows:<br />
1. Promote Affordable Housing in All Communities<br />
Promote affordable housing in all parts of the region.<br />
To this end, add a Strategy to Policy 4 to prevent gentrification and displacement of<br />
existing residents from transit-<br />
support and incentivize best practices to prevent gentrification resulting in<br />
displacement of existing resident, including practices that stabilize existing renters and<br />
lower and moderate income homeowners; create new homeownership opportunities<br />
for low to moderate income households; facilitate comprehensive community benefits<br />
packages that include good jobs and land use provisions; facilitate income and asset<br />
creation in affected areas; and support neighborhood-specific measures to fund the<br />
2<br />
2. Create a Jobs-Housing Fit Analysis Tool<br />
The importance of this tool, as specified in Strategy 4.3, cannot be over-emphasized.<br />
Use this new modeling tool to help create opportunities for people at all income levels<br />
to live where they work.<br />
3. Meet the Needs of Transit Dependent Populations<br />
Add a Strategy (or multiple Strategies) to Policy 23 that specifically addresses the needs<br />
of the following transit-dependent populations: low-income people and youth under<br />
age 18. The Strategy should include improving transit services and options for lowincome<br />
people and youth by employing the same mechanisms set forth in Strategy<br />
23.1.<br />
o We suggest adding the following language<br />
discounted monthly passes, and plan bus and other transit routes compatible<br />
<br />
o Specifically to address the needs of youth under 18, we suggest the following<br />
<br />
transit providers to ensure that district and or public bus routes enable all K-12<br />
<br />
<br />
low income and minority communities whose needs and concerns otherwise might be<br />
<br />
1 Notable references on the linkages between equity and economic prosperity include Just Growth: Inclusion and<br />
by Chris Benner and Manuel Pastor, and <br />
is the Superior Growth Model by PolicyLink.<br />
2 We refer SACOG to the tool for measurement and interventio<br />
Community Innovation described in Mapping Susceptibility to Gentrification, available here:<br />
http://communityinnovation.berkeley.edu/publications.html for further development of this strategy.<br />
2<br />
Page 15 of 165
Coalition on Regional Equity <strong>MTP</strong>/<strong>SCS</strong> Comment Letter, Page 3<br />
Add a Strategy to Policy 24 that encourages transit agencies to consider and plan for<br />
the needs of low-income and other vulnerable populations in rural parts of the region,<br />
perhaps through stakeholder meetings, a speaker series or series of webinars.<br />
4. Promote Transportation Equity for All, Including Transit Dependent and Choice Riders<br />
Transit service networks should connect communities in the region to opportunities to<br />
live, work, recreate, access services, and worship without the need for a private<br />
automobile.<br />
Street networks should facilitate travel by all modes, necessitating prioritizing<br />
investment in pedestrian and bicycle infrastructure throughout communities and near<br />
transit stops.<br />
Develop specific strategies to ensure appropriate phasing of transit and active<br />
transportation improvements with residential development. While SB375 only requires<br />
quality transit to be planned within the time horizon of the <strong>MTP</strong>/<strong>SCS</strong> for residential<br />
projects to meet the criteria for CEQA benefits, development built without transit<br />
inevitably becomes car-oriented, and it is difficult to reverse this behavior.<br />
5. Prioritize Equity-Promoting Investments First<br />
<br />
constraints when financially feasible, with attention to restore and strengthen service to<br />
low-income communities and other areas where transit-<br />
Add to Policy 28 a Strategy to fund equity-promoting investments first. We suggest the<br />
<br />
projects that enhance equity in the region, laying the foundation for the remainder of<br />
<br />
6. Create an Equity Scenario in the Next <strong>MTP</strong>/<strong>SCS</strong>, or Integrate Equity in Every Scenario<br />
Strengthen the equity analysis for future plans by including an analysis to measure the<br />
impact of the plan on low-income communities, communities of color, and other<br />
vulnerable populations (Environmental Justice Communities) that live outside of the<br />
<br />
help determine true impact on these populations.<br />
Apply the jobs-housing fit tool to the analysis for the next <strong>MTP</strong>/<strong>SCS</strong>.<br />
Track the equity performance of this plan to provide the analytical foundation for future<br />
plans.<br />
Hold a series of conversations with equity partners to identify key planks of an equity<br />
scenario and how they can best be integrated into the next <strong>MTP</strong>/<strong>SCS</strong> scenario(s).<br />
Create a defined public process for CEQA streamlining determinations. SB 375 gives the<br />
local jurisdiction the discretion for making the determination for what level of CEQA<br />
exemptions a project is qualified for within the <strong>MTP</strong>/<strong>SCS</strong>, but there is no mandate for a<br />
public hearing or review process for this determination. A public process must be<br />
established to ensure that equity, health, and environmental interests are adequately<br />
addressed.<br />
Page 16 of 165
Coalition on Regional Equity <strong>MTP</strong>/<strong>SCS</strong> Comment Letter, Page 4<br />
7. Improve Ecological Impact Analysis and Include Strategic Planning for Habitat and Open<br />
Space Conservation<br />
The interests of equity, public health and compact transit-oriented development are<br />
best served by complementary planning for natural resource and open-space<br />
conservation. While we applaud the work of the Rural Urban Connections Strategy to<br />
analyze regional agricultural viability, considerations of habitat viability and<br />
opportunities for outdoor recreation and education could be improved to better serve<br />
the needs of the region.<br />
Coordinated conservation strategies and tools must be developed to aide adherence to<br />
the <strong>MTP</strong>/<strong>SCS</strong> urban footprint and provide ample opportunity for open space<br />
preservation.<br />
We believe that these recommendations, if included in the <strong>MTP</strong>/<strong>SCS</strong>, will help the Sacramento<br />
region address the needs of all residents in a meaningful way. Strengthening the analysis of<br />
how the <strong>MTP</strong>/<strong>SCS</strong> will impact low-income communities, communities of color, other vulnerable<br />
populations, and natural habitat, as well as creating specific strategies to address the needs of<br />
these populations as the <strong>MTP</strong>/<strong>SCS</strong> is implemented, will create a more equitable, sustainable,<br />
and prosperous region.<br />
<br />
equitable future, and urge the SACOG Board of Directors to support the strengthening of equity<br />
measures and strategies in the <strong>MTP</strong>/<strong>SCS</strong>.<br />
The Coalition on Regional Equity- and its member organizations throughout the region- are<br />
committed to supporting the ongoing planning and implementation of the <strong>MTP</strong>/<strong>SCS</strong> through<br />
th<br />
constituents on ensuring that equity and opportunity for all in the Sacramento region become a<br />
reality.<br />
Thank you for considering our comments and recommendations.<br />
Sincerely,<br />
Kendra Bridges<br />
Land Use Policy Director<br />
Sacramento Housing Alliance<br />
Sarah Mercer<br />
Director of Government Affairs<br />
California Pan-Ethnic Health Network<br />
Efren M. Guttierrez<br />
Executive Director<br />
Chicano Consortium of Sacramento<br />
Jonathan Ellison<br />
Board President<br />
Environmental Council of Sacramento<br />
Mona Tawatao<br />
Regional Counsel<br />
Legal Services of Northern California<br />
Linda Deavens<br />
Chief Executive Officer<br />
Paratransit, Inc.<br />
Page 17 of 165
Coalition on Regional Equity <strong>MTP</strong>/<strong>SCS</strong> Comment Letter, Page 5<br />
Frances Gracechild<br />
Executive Director<br />
Resources for Independent Living<br />
Barbara Stanton<br />
Founder/Director<br />
RiderShip for the Masses<br />
Stanley Keasling<br />
Chief Executive Officer<br />
Rural Community Assistance Corporation<br />
Rachel Iskow<br />
Chief Executive Officer<br />
Sacramento Mutual Housing Association<br />
Rafael Aguilera<br />
Director<br />
Solistic Institute<br />
Alvin D. Vaughn, Jr.<br />
Director, Advocacy & Communications<br />
Ubuntu Green<br />
Teri Duarte<br />
Executive Director<br />
WALKSacramento<br />
Mindy Romero<br />
Board President<br />
Yolo Mutual Housing Association<br />
Eric Vega<br />
Board Chair<br />
Sol Collective<br />
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Administration<br />
COUNTY OF PLACER<br />
Community Development Resource Agency<br />
ENGINEERING &<br />
SURVEYING<br />
MEMORANDUM<br />
DATE: JANUARY 4, 2012<br />
TO:<br />
FROM:<br />
MAYWAN KRACH, ECS<br />
REBECCA TABER<br />
SUBJECT: METROPOLITAN TRANSPORTATION PLAN / SUSTAINABLE COMMUNITY<br />
STRATEGIES FOR 2035 UPDATE, POLICY DOCUMENT AND DRAFT EIR<br />
The Engineering and Surveying Department and the Department of Public Works Transportation<br />
Division have reviewed the <strong>Draft</strong> Metropolitan Transportation Plan (<strong>MTP</strong>) / Sustainable<br />
Community Strategies (<strong>SCS</strong>) for 2035 and associated <strong>Draft</strong> EIR. The project applicant is the<br />
Sacramento Area Council of Governments (SACOG).<br />
Thank you for the opportunity to review and comment on this policy document and <strong>Draft</strong> EIR.<br />
We would like to provide the following comment for your consideration:<br />
1. Since the <strong>MTP</strong> is a long-range planning document for the SACOG region, the<br />
following completed projects should be omitted from Appendix A (list of projects):<br />
a. Douglas Boulevard Pedestrian Facilities and Landscaping.<br />
b. Foresthill Passing Lane Modification Project.<br />
c. Sheridan SRTS Project.<br />
2. <strong>Draft</strong> Metropolitan Transportation Plan Project List: It appears that the City of<br />
Lincoln Department of Public Works item on page 27 of 142 (dated October 27,<br />
2011) in Appendix A to widen Fiddyment Road to 4 lanes from East Catlett to<br />
Nicolaus Road may be in error. Fiddyment Road ends at Moore Road at its northern<br />
limit, and this portion of Fiddyment is within the Placer County Department of Public<br />
Works jurisdiction.<br />
3. <strong>Draft</strong> Metropolitan Transportation Plan Project List: There is an error on page 38 of<br />
142 in Appendix A – instead of Bell Ave., it should be Bell Road.<br />
cc:<br />
Phil Vassion, DPW Transportation<br />
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Sacramento Public Hearing <strong>Comments</strong> from January 4, 2012<br />
Amy Williams, Legal<br />
Services of Northern<br />
California<br />
Earl Withy Combe<br />
The <strong>MTP</strong> is a good plan, but the timeline is too spread out. We need improved transit service now. The California Endowment's initiative<br />
"Building Healthy Communities" will be completed in eight years, and SACOG should attempt to complement that initiative with increased<br />
transit service that will address equity issues and benefit low‐income communities.<br />
The <strong>MTP</strong>/<strong>SCS</strong> performance measures should include more measures related to public health and healthy communities.<br />
Accountability Gap: SACOG does not have the land use authority to guarantee achievement of the <strong>SCS</strong> goals, only the ability to model that<br />
attainment is possible. SACOG should begin a program of incentives and disincentives to encourage and incentivize local jurisdictions to adopt<br />
and embrace the Blueprint vision, including the siting of high‐density developments near transit. SACOG should institute a bonus point system<br />
in the programs, planning, and enhancement funding to give bonus point in communities where the local jurisdictions have clearly<br />
demonstrated that they support the Blueprint goals and they enforce those in the approval of new land use projects. Over time, SACOG should<br />
add a similar bonus system to other pots of funding. SACOG needs more levers to achieve the goals of the <strong>SCS</strong>. The plan is somewhat wishful<br />
thinking without such controls.<br />
Michael Monasky<br />
Mike Barnbaum<br />
SACOG should consider something akin to the 30/10 initiative that was approved in L.A. County. This initiative establishes a sales tax increase<br />
that will be used to bond new transit projects over a 10‐year period that would otherwise take 30 years. The SACOG region needs another<br />
funding option for returning transit service levels and expanding them. The region should consider an initiative like the one in L.A.<br />
Anything we can do to bring down GHG emissions is desirable.<br />
Disappointed with the public comment process. Usually, a public hearing is started and ended officially and the members who comprise the<br />
Board are present, but not a single Board member is present to hear comments.<br />
Concerned about the air quality chapter, including diesel contaminants.<br />
SACOG should include public health officials in public outreach.<br />
The <strong>MTP</strong> puts too much investment in roadway projects. Greater investment in transit projects would yield better returns for reductions in<br />
vehicle miles traveled and better air quality. Vulnerable populations carry more of this burden in terms of adverse health outcomes.<br />
GHG emissions are still growing. Roadway maintenance and rehabilitation projects (which account for $7 billion of total <strong>MTP</strong> expenditures)<br />
should not be included as non‐exempt projects in air quality conformity determinations because the current infrastructure is already causing<br />
too much GHG emissions.<br />
The <strong>MTP</strong> project list needs to include something about the San Joaquin corridor that runs from Oakland/Sacramento to Bakersfield.<br />
During the unmet transit needs process, transit needs that are found to be reasonable to meet should be specially recognized or "fast tracked"<br />
in the <strong>MTP</strong>/<strong>SCS</strong> to speed implementation of these services.<br />
The region should consider something like the 30/10 initiative approved in L.A. County. SACOG should think outside the box to help move the<br />
region forward.
Sacramento Public Hearing <strong>Comments</strong> from January 4, 2012<br />
Mona Tawatao,<br />
Legal Services of<br />
Northern California<br />
Ruby Avila, Youth<br />
Advocate Network<br />
for Sustainable<br />
Communities<br />
Teri Duarte,<br />
WALKSacramento<br />
The draft plan moves the region in the right direction, especially considering a more challenging fiscal environment. The commitment to<br />
developing affordable housing and addressing equity issues is appreciated. However, the plan could and should do more to address equity issues<br />
throughout the region. SACOG has legal and regulatory obligations in this regard, particularly with concern for whether or not the plan promotes<br />
access to opportunity, lessens or exacerbates racial segregation, and avoids or mitigates potential impacts, especially to residents in<br />
environmental justice communities. Promoting equity in the plan also enhances economic growth. Minority populations will continue to grow<br />
rapidly. People and communities of color, as well as those living in low‐income areas, typically bear the burden of failed systems and<br />
infrastructure. We can't thrive as a region if we don't act aggressively to close these gaps and disparities. We need to treat the upcoming<br />
generation as an asset because the region's economic health depends on it.<br />
1) Jobs/housing fit should ensure that people live near where they work.<br />
2) Analysis of displacement of residents and potential effects of such displacement in terms of transit, service, and job access.<br />
3) Analysis of whether or not any part of the plan has disproportionate impacts on communities of color.<br />
4) Frontload transit investments. Improving transit benefits groups that are already far behind in terms of access and opportunity, and delaying<br />
transit investments may be too little too late to benefit these groups.<br />
Public transit improvements, complete streets, and more frequent transit are very important. SACOG should remember to include youth in their<br />
outreach efforts.<br />
The <strong>MTP</strong>/<strong>SCS</strong> needs a timetable to achieve complete streets. The region doesn't have a complete network of bicycle and pedestrian<br />
infrastructure.<br />
Each transportation project should go through a review to see how closely it achieves health, environmental, and equity goals of the region.<br />
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909 12 th Street<br />
Sacramento, CA 95814<br />
Phone: (916) 444-5900<br />
Fax: (916) 444-6661<br />
staff@sacbreathe.org<br />
www.sacbreathe.org<br />
www.SceneSmoking.org<br />
www.sacSTAND.org<br />
Board of Directors<br />
2011 - 2012<br />
Sue Schooley,<br />
President<br />
Ralph Propper,<br />
President-Elect<br />
Jarvio Grevious,<br />
Treasurer<br />
Diana Proctor,<br />
Immediate Past<br />
President<br />
Roni Abacherli<br />
Paul Adams<br />
Peter Adams<br />
Jennifer Copeland<br />
Patricia Dean<br />
Jim Edelen<br />
Gordon Garcia, MD<br />
Doug Grandt<br />
Kristin Gray<br />
Helen Hernandez<br />
Ken Hough<br />
Michelle Kessel-Harbart<br />
Diana Parker<br />
Ashley Rice<br />
Rita Ruecker<br />
Arif Seyal, MD<br />
Jean Shaw<br />
Sue Teranishi<br />
Earl Withycombe<br />
Kori Titus, CEO<br />
Breathe California of<br />
Sacramento-Emigrant Trails is<br />
dedicated to healthy air and<br />
preventing lung and other airpollution<br />
related diseases by<br />
partnering with youth, advocating<br />
public policy, supporting air<br />
pollution research, and educating<br />
the public.<br />
January 9, 2012<br />
Chair Peter Hill<br />
Board of Directors<br />
Sacramento Area Council of Governments<br />
1415 L Street Suite 300<br />
Sacramento, CA 95814<br />
Re: <strong>Draft</strong> Metropolitan Transportation Plan/Sustainable Communities Strategy 2035 (<strong>MTP</strong>/<strong>SCS</strong><br />
2035)<br />
Dear Mr. Hill and SACOG Board Members,<br />
Breathe California of Sacramento‐Emigrant Trails (BCSET) has been active in the region since<br />
1917, advocating for clean air, healthy lungs, and a tobacco free future. We have developed a<br />
Clean Air Agenda which includes various strategies and recommendations for local jurisdictions,<br />
businesses, organizations and individuals that can be achieved through efficient energy and land<br />
use. Our mission is to ensure air quality and public health concerns are being addressed through<br />
minimizing mobile source pollution and promoting alternative forms of transportation such as<br />
walking, biking, and using public transportation.<br />
We commend SACOG’s enormous effort to put forth a Sustainable Communities Strategy; we<br />
encourage efforts to meet air quality standards and continued investment in alternative forms of<br />
transportation. Although we are pleased to see a 7 % increase in funding per capita for bicycle<br />
and pedestrian use in the 2011 <strong>MTP</strong> <strong>Draft</strong> Plan for 2035; we would like to see increased funding<br />
for this effort and a developed timeline to achieve a complete system of active transportation.<br />
BCSET is confident that increasing this investment will help the overall well being of our region by<br />
reducing vehicle miles traveled and encouraging residents to use alternative forms of<br />
transportation.<br />
As stated in the corresponding DEIR, our region will initiate efforts to develop an emissions<br />
budget for PM 2.5. In accordance to this regulation, we encourage an increase in the size of<br />
buffer zones from 500 feet to 1,000 feet in high‐volume roadways and land use for residents. This<br />
will benefit public health by minimizing the impacts to residents living near roadways and high<br />
traffic areas. In addition, these mitigation practices will assist our region with meeting air quality<br />
standards as set forth by SB 375, California’s sustainable communities and Climate Protection Act.<br />
We are grateful for SACOG’s staff effort and leadership to create a thorough and prosperous plan<br />
for 2035, and look forward to the continued development of this blueprint to better benefit air<br />
quality and public health in our region. As always, BCSET looks forward to continued partnership<br />
with SACOG staff and are thankful for your time.<br />
Cordially,<br />
Kori Titus<br />
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1/10/2012<br />
Clint Holtzen - Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
From: <strong>MTP</strong> <strong>Comments</strong> <br />
To: <br />
Date: 1/9/2012 4:20 PM<br />
Subject: Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
What are you commenting on?<br />
Name<br />
Email<br />
• Metropolitan Transportation Plan/Sustainable Communities Strategy<br />
• Environmental Impact Report<br />
Christal Waters<br />
chrystal2waters@yahoo.com<br />
Do you want a written response?<br />
Yes<br />
Address<br />
Davis Bicycles!, c/o Christal Waters<br />
809 Pine Lane<br />
Davis, California 95616<br />
United States<br />
Map It<br />
<strong>Comments</strong> on the <strong>MTP</strong>/<strong>SCS</strong><br />
The following comments are submitted on behalf of Davis Bicycles!<br />
Davis Bicycles! appreciates the opportunity to comment on the Sacramento 2035 Metropolitan Transportation<br />
Plan/Sustainable Communities Strategy. Our comments are both on the 2035 <strong>MTP</strong> and the EIR. The 2035 <strong>MTP</strong> is<br />
complex and encourages bicycling and walking as vital modes of transportation for achieving environmentally<br />
sustainable regional growth. In our community, we see more people bicycling than we used to. Our downtown is<br />
filled with bicyclists competing for bike parking spaces. We see parents out bicycling with their children, teaching<br />
them safe bicycling as they ride. We are starting to see a turnaround in the historic decline of students bicycling and<br />
walking to school and more people are bicycling, walking and taking public transit to get to work. The 2035<br />
<strong>MTP</strong>/<strong>SCS</strong> could take advantage of this uptick with a jumpstart to funding more active transportation projects in the<br />
near future. A near-term substantial dedication to funding bicycle and pedestrian projects would greatly increase<br />
bicycle/pedestrian modeshare far more than a slow steady increase in those active transportation expenditures , or<br />
worse, delaying those expenditures and trying to play catch-up closer to 2035. Furthermore, expenditures on active<br />
transportation are generally lower in cost than expenditures increasing freeway and arterial capacity and can be<br />
undertaken when the economy is slow and budgets are tight.<br />
2035 <strong>MTP</strong>/<strong>SCS</strong> Questions and <strong>Comments</strong>:<br />
Table 4.1 on page 4-2, Summary of <strong>MTP</strong>/<strong>SCS</strong> Invdstments<br />
What capital inflation rate is used for these investment categories and is the inflation rate the same over all<br />
categories from current year to year of expenditure? If the increase in cost is measured as a percentage of current<br />
costs, the costs for the bike and pedestrian category increases at 43% - the largest cost increase. The other<br />
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categories are 40% increase for Transit and for Programs, Planning, Enhancements and 42% increase for Road<br />
and Capital Improvement Projects, and Maintenance and Rehabilitation. While it is true that bicycle and pedestrian<br />
improvements are in Maintenance and Rehabilitation Projects, the dedicated-purpose bike and pedestrian<br />
improvements, those usually associated with higher miles or higher costs, have a higher inflation rate. If the<br />
inflation rate is the same for all categories, is the higher bike/pedestrian project rate due to their implementation at a<br />
later date than the other categories? If so, then we don’t believe that the Plan takes advantage of the current<br />
economy to jumpstart an active transportation modeshare that can significantly contribute to improved air quality,<br />
reduced carbon emissions, and public health.<br />
Relationship of 2035 <strong>MTP</strong> Project List and Regional Bicycle Master Plan:<br />
Where does the plan discuss the relationship between the 2035 <strong>MTP</strong> Project List and the Regional Bicycle Master<br />
Plan? We understand that the Regional Bicycle Master Plan and the <strong>MTP</strong> form the basis for SACOG project<br />
funding. For Yolo County, the Alternative Transportation Corridor (ATC) appears on the project list, but only through<br />
right of way acquisition, not through construction, even though the year-end date of this plan is nearly 25 years out.<br />
(See also comment above about jumpstarting bicycle/pedestrian investment.) However, the Woodland/Davis ATC<br />
is only one project and there are many projects and programs in the Davis Bicycle Plan, which is part of the<br />
Regional Bicycle Master Plan. Other projects are being considered for inclusion into our Bicycle Plan. If to be<br />
eligible for SACOG <strong>MTP</strong> funding a bicycle project or program need not be directly included in the 2035 <strong>MTP</strong> Project<br />
list, that should be so stated, and the Regional Bicycle Plan incorporated by reference into the 2035 <strong>MTP</strong>.<br />
2035 <strong>MTP</strong> Project List for Davis:<br />
The Fifth Street Road Diet and Multimodal Parking Structure are projects that we are aware of, and we understand<br />
the issues related to the California Street Bridge Replacement and I-80/Richards Boulevard interchange. However,<br />
we do not understand why some of the other projects have been listed. For example, we do not know why the<br />
widenings of Covell Boulevard near Hwy 113 and Mace Boulevard with completion in 2035 are included in the plan,<br />
with no new development being considered or serious problems occurring along those roads, to our knowledge.<br />
Environmental Impact Report:<br />
Neither Alternative 3, nor the rejected Alternatives 4 and 5 discuss the bicycle/pedestrian community’s suggestion<br />
last year to accelerate funding of bicycle and pedestrian projects and programs. Alternatives 4 and 5 are rejected<br />
because of restrictions to funding sources. What would need to be changed in those funding sources to allow<br />
bicycle and pedestrian projects to receive a higher earlier priority?<br />
Alternative 3 seems to have been dismissed because the market, local land use plans and financial incentives do<br />
not currently support the land use assumptions of Alternative 3 and because under it, congestion would increase.<br />
Given that markets respond to constraints as well as opportunities, please give some thought to allowing<br />
congestion to further increase over the short term while completing the investment in complete streets, transit and<br />
bike/pedestrian infrastructure that could further reduce congestion over the long term.<br />
Thank you for the opportunity to comment on the 2035 <strong>MTP</strong>/<strong>SCS</strong> and its environmental impact report.<br />
/s/<br />
Mont Hubbard, President<br />
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Sacramento Area Council of Governments January 9, 2012<br />
SACOG Board of Directors<br />
SACOG, <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
1415 L Street, Suite 300,<br />
Sacramento, CA 95814<br />
Re:<br />
2035)<br />
<strong>Draft</strong> Metropolitan Transportation Plan/Sustainable Communities Strategy 2035 (<strong>MTP</strong>/<strong>SCS</strong><br />
To the SACOG Board of Directors and Executive Director Mike McKeever:<br />
We commend SACOG on the vision put forth in this <strong>MTP</strong>/<strong>SCS</strong>. It is clear that SACOG has incorporated<br />
principles that public health representatives would agree with, such as prioritizing transit, bicycling, and<br />
walking over driving, incorporating Safe Routes to Schools and Complete Streets as often as possible,<br />
preserving agricultural lands and natural resources, preserving affordability of housing while<br />
aggressively pursuing compact development, assessing air quality dangers of placing housing near<br />
freeways, ameliorating greenhouse gas emissions, improving accessibility to needed destinations such<br />
as jobs, schools, and parks, and supporting mitigations of motor vehicle collisions. However, after<br />
reviewing the plan carefully and based on many of our organizations’ experience reviewing plans from<br />
other regions and developing health and equity metrics, we believe there are a number of ways that this<br />
plan could better reflect health and equity priorities.<br />
As background to this letter, in the spring and summer of 2011, Human Impact Partners (HIP) worked<br />
with over twenty organizations and agencies statewide to prioritize 13 indicators of health and equity<br />
that could be incorporated into Sustainable Communities’ Strategies across California. We are attaching<br />
our report (Appendix C), which supplies the evidence that connects these indicators to health outcomes<br />
as well as suggested sources for methodology. Due to regional differences, we did not suggest<br />
benchmarks as we felt that would be more appropriate for organizations and agencies in each region to<br />
do so. HIP’s report, “Elevating Health and Equity into the Sustainable Communities Strategy Process”,<br />
provides the basis for suggested measurements contained in this comment letter.<br />
Throughout our comments, in most cases we recommend supplemental analyses, monitoring, and<br />
reporting to more completely incorporate health outcomes and health determinants. However, there<br />
are a few key areas in which we hope to push SACOG to more explicitly and fully incorporate health into<br />
the <strong>MTP</strong>/<strong>SCS</strong>:<br />
Affordability:<br />
o Measure Housing + Transportation costs as a percentage of household income<br />
for all modes of travel;<br />
o Disaggregate the results by income level, race, EJ vs. non‐EJ community, TPA,<br />
and community type.<br />
Respiratory health:<br />
o For development that is proposed near busy roadways, change the analysis<br />
buffer from 500 to 1,000 feet to trigger a health analysis & potentially require<br />
mitigations based on that analysis;<br />
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<strong>SCS</strong> Health & Equity Metrics August 2011<br />
o Measure respiratory disease caused by PM 2.5 and NO (i.e., connect modeled<br />
emissions with projected health outcomes).<br />
Physical activity:<br />
o Measure physical activity and chronic disease co‐benefits of transportation<br />
priorities, projects, policies, and changes.<br />
Accessibility & VMT:<br />
o Measure access to a more comprehensive list of goods and services<br />
Injuries:<br />
o Measure injuries per capita in addition to per 100 million VMT<br />
o Do EJ analysis of injuries by mapping injuries and fatalities and providing totals<br />
disaggregated by geography, income level, race, and disability.<br />
Environmental Justice:<br />
o Do an equity analysis for every indicator<br />
o Measure proportion of below market rate housing proposed within 1,000 foot<br />
buffer of busy roadways vs. market rate housing for analysis and mitigation<br />
purposes.<br />
<strong>Comments</strong> below follow the chapters of the <strong>MTP</strong>/<strong>SCS</strong> for easier inclusion. When alternate or<br />
supplemental indicators and measures are suggested, they have been printed in bold for easy<br />
identification. Important appendices that we have attached to this letter are:<br />
Appendix A – a table comparing SACOG’s performance measures to health and equity metrics<br />
for <strong>SCS</strong>s. This comparison table shows how the Health & Equity metrics (developed by HIP and<br />
over 20 other health and equity focused organizations and agencies around the state; see<br />
Appendix C) would fit in with existing performance measures included in the <strong>MTP</strong>/<strong>SCS</strong>. We<br />
recommend that SACOG consider adding some of the Health & Equity metrics to their existing<br />
list of performance measures.<br />
Appendix B – detailed comments on SACOG policies and strategies; and<br />
Appendix C – Human Impact Partners’ report entitled “Elevating health and equity in Sustainable<br />
Communities Strategies”, which includes our suggested metrics, measurement methodologies,<br />
health and equity evidence supporting their inclusion, and standards.<br />
We begin with comments on Appendix G‐6 because the performance measures included in this<br />
appendix are broad and overarching.<br />
Appendix G‐6: Performance Measures<br />
The crux of our comments have to do with outcomes; as a society, we value what we measure. As<br />
such, we note the absence of some important health outcomes in SACOG’s many excellent<br />
performance measures upon which you will be monitoring the progress of the <strong>MTP</strong>/<strong>SCS</strong>.<br />
Entrance into the discussion in the SACOG region by some of the groups signed onto this letter<br />
unfortunately came at a later stage of <strong>MTP</strong>/<strong>SCS</strong> development, which precluded early involvement<br />
into what performance measures should ultimately be used in the <strong>MTP</strong>/<strong>SCS</strong>. Others of us were<br />
involved early on and commented on <strong>MTP</strong>/<strong>SCS</strong> development from our perspective, but did not have<br />
specific public health indicator expertise. The undersigned together support the detailed<br />
suggestions put forth in this letter and we respectfully submit our comments and request that even<br />
‐2‐<br />
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<strong>SCS</strong> Health & Equity Metrics August 2011<br />
if SACOG is unable to include indicators suggested below and in attached Appendices as<br />
performance measures, that you do include them in a monitoring plan for the <strong>MTP</strong>/<strong>SCS</strong>, that in<br />
TPA planning, you consider these (or very similar) indicators, and when planning begins for the<br />
next <strong>MTP</strong> in two years, these health and equity indicators are incorporated.<br />
The health and equity indicators (Appendix C) include four actual health outcomes indicators:<br />
fatalities and injuries from collisions, respiratory disease from vehicle emissions, and physical<br />
activity due to transportation choices. Of these, SACOG is already measuring two: fatalities and<br />
injuries. Eight of the indicators are transportation and land use health “determinants” – or planning<br />
elements that we know from scientific literature predict health behaviors. SACOG is already<br />
measuring some of these indicators (see table in Appendix A). Finally, our last indicator is the<br />
measurement of all other indicators with regard to equity concerns – depending on the indicators<br />
SACOG chooses, many of these are already included in SACOG’s social equity analysis. In sum, we<br />
applaud you on what you are doing for health and equity and request that you do just a little more<br />
to protect the health of all people in the SACOG region, and in particular those most vulnerable to<br />
past planning decisions leading to environmental injustices. To see a comparison of SACOG’s<br />
performance measures and the Health and Equity in <strong>SCS</strong> Metrics, please see Appendix A. We are<br />
not suggesting that SACOG abandon the valuable and hard work you have done to prioritize and<br />
choose your performance measures, merely that you consider the addition of metrics we set forth<br />
below.<br />
Appendix A is for comparison purposes only. Our requests and recommendations are included in<br />
the body of this letter and in Appendix B.<br />
Chapter 2 – Planning Process<br />
‐ We commend SACOG for a robust public participation process that has been very participatory<br />
and thorough.<br />
Chapter 3 ‐ Land Use Forecast<br />
Housing<br />
‐ The increase in housing choices near transit and increased focus on transit is very positive.<br />
‐ Health evidence supports SACOG’s intention to provide a good housing choice mix in all<br />
community types, noting the population changes that are going to take place and housing<br />
choices that will be changing. The goal of providing more attached and small lot single‐family<br />
units for the changing demographics is beneficial.<br />
‐ Compact development in areas with rich mixes of commercial, residential, and retail supports<br />
increased physical activity, more social interaction, and decreased regional VMT and air<br />
emissions. One concern and recommendation about housing, particularly in the Center and<br />
Corridor Communities, is that development of housing within a 1,000 foot buffer to busy<br />
roadways be studied as to the health dangers for local residents and to help suggest<br />
mitigations to potentially allow such development.<br />
‐3‐<br />
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<strong>SCS</strong> Health & Equity Metrics August 2011<br />
‐ Compact development can also heighten risk and perception of crime, so SACOG can guide local<br />
jurisdictions to coordinate crime prevention efforts in these cases.<br />
‐ Introducing transit‐oriented development in communities with rich public transit options opens<br />
a risk for gentrification. The <strong>MTP</strong>/<strong>SCS</strong> realizes this and is measuring it in their EJ analysis.<br />
Another tool for measurement and intervention is the University of California‐ Berkeley’s Center<br />
for Community Innovation report Mapping Susceptibility to Gentrification: The Early Warning<br />
Toolkit. Additionally we would suggest monitoring the cost of housing + transportation for all<br />
incomes and all community types.<br />
‐ The amount of proposed housing in Developing Communities is concerning in terms of reaching<br />
the goal of not increasing the urban footprint. While increasing the housing to match the<br />
current employment centers in Developing Communities is laudable to decrease VMT, please<br />
develop protocols which prioritize transportation infrastructure for existing urbanization<br />
before Greenfield expansion. Additionally we suggest that investment is not directed away<br />
from existing communities to benefit new development.<br />
Mix of Uses<br />
‐ SACOG focuses, rightly, on the jobs‐housing fit in their discussion of Mix of Uses. We look<br />
forward to the work SACOG is doing on better measuring jobs‐housing fit within 4 miles of job<br />
centers.<br />
‐ We also suggest that SACOG conduct a mapping analysis to measure the proportion of<br />
households that can walk or bike (10 minutes) to meet at least 50% of their daily needs. We<br />
propose that public daily needs be defined as: schools, parks, healthcare institutions and<br />
transit. We propose that private daily needs be defined as: restaurants, grocery stores, food<br />
markets and childcare. Public health literature shows that having goods and services within a ½<br />
mile increases the likelihood that people will use active transport to get them.<br />
Chapter 4 – Budget and Investments<br />
‐ We recommend moving up the timeline for investments in public transit and<br />
bicycle/pedestrian infrastructure improvements. As written in the <strong>MTP</strong>/<strong>SCS</strong>, these are delayed<br />
until the later years of this plan, and in order to realize the health benefits as early as possible<br />
from active transport, we believe that these investments should be prioritized. Specifically, we<br />
recommend assessing the cost and timeline for building out Complete Streets network by 2024,<br />
prioritizing Complete Streets and provision of transit on deserving arterials.<br />
‐ Also, with regard to phasing and funding of transit, we suggest that SACOG work with other<br />
agencies and local jurisdictions to support and hasten transit for high‐density arterial corridors,<br />
when sufficient density of homes or jobs has been reached; in order to do this jurisdictions<br />
could defer costly transit capital projects until densities have been reached. Finally,<br />
prioritization of costs should also defer or cancel road construction projects that could trigger<br />
growth outside of urban areas.<br />
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‐ We commend the SACOG for allocating 7.9% of the total budget for bicycle and pedestrian<br />
investments. This is a greater proportion than many other MPOs in the state. In addition, we<br />
acknowledge that per capita funding in bicycle and pedestrian investments actually increases by<br />
7% due to reduction in population growth estimates.<br />
‐ However, there is still a net decrease of 1% in funding for bicycle and pedestrian investments.<br />
Bicycle and pedestrian networks in the region remain deficient and incomplete, while vehicle<br />
roadway networks are extensive and vastly prioritized. Bicycle and pedestrian investments are<br />
anticipated to reduce greenhouse gas emissions, improve air quality, and improve health by<br />
encouraging more physical activity. In light of these tremendous benefits, which address<br />
overall goals of the <strong>SCS</strong>, SB375 and AB32, we recommend an increase in total funding for<br />
bicycle and pedestrian investments. As an example, the Los Angeles County Department of<br />
Public Health analyzed the funding put forth by SCAG for their pedestrian and bicycle<br />
infrastructure and found that in order to reach their goals they would need to increase the<br />
bike/ped funding more than six times. 1<br />
‐ Table 4‐2 displays a list of projects proposed in the <strong>SCS</strong>, in various categories (such as rail,<br />
bike/pedestrian, new roads, bridges, etc). We recommend also adding a list of projects and<br />
services that are being eliminated due to a smaller budget (if any).<br />
‐ There are two separate categories for vehicle/roadway‐related projects: Maintenance &<br />
Rehabilitation and Road Capital & Operations. In contrast, there are single categories for Transit<br />
and Bike/Pedestrian projects. This type of reporting understates the actual proportion of the<br />
budget going to vehicle roadway projects versus projects related to transit and bike/pedestrian<br />
projects. We recommend adding an additional table comparing the budget allocation for<br />
vehicles, transit, and bike/pedestrian projects.<br />
Chapter 5A – Transportation Trends and Performance<br />
‐ The evidence‐based analysis of regional factors that affect VMT, biking, walking, and transit use<br />
is also supported by health literature. SACOG and others use the measure of number of jobs<br />
within a 30‐minute commute time to establish regional accessibility, and this is shown to<br />
increase by almost one‐third in the <strong>MTP</strong>/<strong>SCS</strong>, which is excellent. We suggest also measuring<br />
number of jobs within a 30‐minute public transit and bicycle commute and a 15‐minute walk<br />
commute. In addition, the average commute time to work by Californians is lower than 30<br />
minutes, and thus we recommend reducing the status quo commute time to reflect true<br />
conditions as well as the aspiration for reducing rather than increasing commute time.<br />
‐ Mix of use is also shown to have a large impact on walking and biking. The health‐supporting<br />
increase in mix of use, particularly in the Developing communities, was good to see. In addition<br />
to the relative proportions of residential, jobs, retail and other uses as a measure, we suggest<br />
using the proportion of households that can walk or bike (10 minutes) to meet at least 50% of<br />
their daily needs.<br />
1 Berg N. December 23, 2011. $6 Billion for Southern California's $40 Billion Need. The Atlantic.<br />
http://www.theatlanticcities.com/commute/2011/12/6‐billion‐southern‐californias‐40‐billion‐need/797/<br />
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‐ It is excellent to see that street pattern and urban design is being measured at all, and the<br />
evidence base around using number of intersections to measure this is good. Moving forward,<br />
for local jurisdictions seeking a more refined measure of walkability and bikeability, we<br />
suggest that cities and towns use the PEQI and BEQI. 2 3 These tools can help target complete<br />
streets improvements to the spots most requiring of infrastructure improvements for<br />
pedestrians and bicycles.<br />
‐ The improvement in average distance to transit in Center and Corridor communities, and<br />
overall, is encouraging. This measurement is very helpful to assess likelihood of taking transit<br />
and of getting more physical activity. We know that investing in public transit is a challenging<br />
prospect and encourage SACOG to continue your commitment.<br />
Chapter 5B – Roadway Congestion and Vehicle Miles Traveled<br />
Vehicle Miles Traveled<br />
‐ In order to compare this <strong>MTP</strong>/<strong>SCS</strong> with the 2002 and 2008 <strong>MTP</strong>s, SACOG uses the indicators<br />
VMT and VMT per capita. We recommend also including mileage traveled by other<br />
transportation modes as indicators (i.e., walking, biking, and transit). These additional modes<br />
are also important indicators of physical activity, air quality, traffic accidents and injuries, and<br />
greenhouse gas emissions.<br />
‐ As alluded to above, physical activity is not considered as an indicator or desired outcome in the<br />
VMT analysis. We recommend measuring changes in physical activity as an outcome of<br />
changes in VMT. 4<br />
‐ The discussion of VMT is based primarily on modeling of commute‐hour trips. We recommend<br />
also modeling and targeting reductions in non‐commute trips.<br />
‐ The <strong>SCS</strong> measures vehicle trips to transit but excludes bicycle and pedestrian trips to transit. We<br />
recommend including bicycle and pedestrian trips to transit as a metric.<br />
Roadway Congestion and Delay<br />
‐ The <strong>MTP</strong>/<strong>SCS</strong> philosophy of measuring the amount of under‐utilization or over‐utilization of<br />
roadways is superior to measuring LOS, and we commend SACOG in adopting this outlook.<br />
Measuring proper utilization of roadways supports efforts to decrease VMT, and ultimately<br />
exposure to poor air quality and improvements to increase the attractiveness of active<br />
transport. Focusing on “right‐sizing” projects and prioritizing inclusion of complete streets<br />
infrastructure while doing so will do this.<br />
2 San Francisco Dept. of Public Health Program on Health, Equity, and Sustainability. Bicycle Environmental Quality Index.<br />
Available at http://www.sfphes.org/HIA_Tools_PEQI.htm<br />
3 San Francisco Dept. of Public Health Program on Health, Equity, and Sustainability. Bicycle Environmental Quality Index.<br />
Available at http://www.sfphes.org/HIA_Tools_BEQI.htm<br />
4 California Dept. of Public Health. Health Co‐Benefits and Transportation‐Related Reductions in Greenhouse Gas Emissions in<br />
the Bay Area: A Technical Report. Available at<br />
http://www.cdph.ca.gov/programs/CCDPHP/Documents/ITHIM_Technical_Report11‐21‐11.pdf<br />
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‐ We also commend SACOG for focusing on congested VMT and how to decrease it over focusing<br />
on time delay; focusing on time delay creates solutions to decrease time delay (often roadway<br />
expansion), while focusing on congested VMT creates solutions to decrease congested VMT.<br />
‐ SACOG states that non‐work travel is 17% of all arrivals during peak time and only 8% during the<br />
highest peak time hour, which speaks to the focus on measuring commute travel. Evidence<br />
shows that half of all trips in metropolitan areas are three miles or less and 28% are one mile or<br />
less; in rural areas 30% of all trips are two miles or less. 5 Yet a majority (65 percent) of one‐mile<br />
trips in metropolitan areas are still made by automobile. 6 As such, we suggest also measuring<br />
the proportion of daily trips less than 3 miles and less than 1 mile by mode<br />
(walking/biking/bus and rail transit/driving).<br />
Chapter 5C – Transit, Bicycle and Pedestrian<br />
Transit<br />
‐ SACOG’s focus on increasing transit to its former levels and expanding it in the detailed ways<br />
presented shows the commitment they have to not only reduce GHG emissions but also to<br />
improve efficiency of the entire transportation system (roadways included) and along with that,<br />
improve health behaviors and reduce harmful exposures.<br />
‐ The assumption that transit fares will remain steady is understandable from a modeling<br />
perspective. However, it is unclear if that assumption will hold true. For that reason we<br />
recommend measuring percent of household income consumed by transportation costs.<br />
Ideally, we recommend measuring the percent of household income consumed by both<br />
housing and transportation to get a better sense of the jobs‐housing fit – which it appears that<br />
SACOG is doing.<br />
‐ SACOG’s goals for changes to the transit system are laudable, and the quantity and quality<br />
indicators SACOG is measuring to get there are very instructive. While the map on page 5C‐13<br />
is very useful, it would be better for monitoring if both the tables and data related to the map<br />
were available and the maps were created for a finer‐grained look at the state of transit<br />
currently. We suggest also measuring proportion of households and proportion of jobs within<br />
1/4 mile of local public transit (including both bus and rail) or 1/2 mile of a regional public<br />
transit, that has less than 15 minute frequencies.<br />
‐ SACOG expects that ridership and farebox revenues will increase, which is heartening. However,<br />
if it does not, there should be an adaptive management process in place for decision‐making so<br />
that decisions are not made on an ad‐hoc or reactive basis about cutting services or delaying<br />
transit improvements, but instead making evidence‐based changes that continue to support<br />
Blueprint and <strong>MTP</strong>/<strong>SCS</strong> goals of increased use of public transit.<br />
5 U.S. Department of Transportation, Bureau of Transportation Statistics. (2002). National Household Travel Survey: Daily Travel<br />
Quick Facts.<br />
6 Complete Streets Coalition. Complete streets ease congestion. Available at: http://www.<strong>sacog</strong>.org/completestreets/toolkit/files/docs/NCSC_CS%20Ease%20Congestion.pdf<br />
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‐ When measuring transit trips by community type, SACOG has reported out combined<br />
transit/bike/walk trip‐making. This makes it difficult to distinguish between these modes of<br />
active transport. We suggest disaggregating it in the report and in monitoring.<br />
‐ We further suggest measuring daily amount (in minutes) of work‐trip and non‐work trip<br />
related physical activity, and if possible, chronic disease outcomes due to physical activity.<br />
Methodology for measuring physical activity exists (see Health and Equity Metrics) and other<br />
MPOs in California are embracing this measure. Also, modeling chronic disease outcomes from<br />
physical activity changes due to transportation investments has been done by the California<br />
Department of Public Health. 7<br />
‐ SACOG bases some of their predictions of an increase in public transit use on an increase in use<br />
of transfers, aided in part by streamlining measures such as the policy to implement the Connect<br />
Card. However, should streamlining measures fail to produce an increase in transfers, SACOG<br />
should plan for an adaptive decision‐making process that does not automatically decrease the<br />
importance of public transit support strategies but revise those strategies – informed by data.<br />
‐ While an increase in farebox revenues would be a boon to funding public transit, we express a<br />
concern about which populations would be most heavily burdened. Therefore, we again<br />
recommend as an equity measure that SACOG monitor transportation costs as a percentage of<br />
household income by all forms of transportation, disaggregating and reporting it out by<br />
community type as well as by income levels, and monitoring this on a regular basis.<br />
Assumptions about farebox revenue increases are hopeful but again, adaptive decision‐making<br />
processes should be put in place in case predictions do not hold true.<br />
Bicycle and Pedestrian<br />
‐ We commend SACOG for the discussion of public health benefits associated with walking and<br />
biking, alluding to equity by describing that people with safe places to walk exercise more than<br />
people who live in unsafe places, and highlighting the importance of pedestrian and bike<br />
infrastructure (i.e., sidewalks and safe bikeways) in the choice and ability to walk.<br />
‐ We commend SACOG for the planned changes to the non‐motorized transportation system (i.e.,<br />
more bicycle trails and lanes, bike/pedestrian amenities on roads, complete street connections<br />
within and between cities, and to transit and schools).<br />
‐ The measures of biking and walking used in the <strong>SCS</strong> are:<br />
Commuters reporting walk/bike/transit (however, commute trips that include transit<br />
are counted as transit trips even if they include walking and biking)<br />
Bike route mileage by class<br />
Number of bicycle person trips and walk person trips<br />
Weekday trips per capita by transit/bike/walk in various community types (center city,<br />
developing, rural, etc)<br />
Mode of travel for commute and non‐commute (drive alone, carpool, transit, bike walk)<br />
7 California Dept. of Public Health. Health Co‐Benefits and Transportation‐Related Reductions in Greenhouse Gas Emissions in<br />
the Bay Area: A Technical Report. Available at<br />
http://www.cdph.ca.gov/programs/CCDPHP/Documents/ITHIM_Technical_Report11‐21‐11.pdf<br />
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We agree with these metrics, and we recommend the addition of the following metrics<br />
associated with walking and biking:<br />
Proportion of households that can walk or bike (10 minutes) to meet at least 50% of<br />
their daily needs<br />
Daily amount (in minutes) of physical activity<br />
Per capita miles traveled by mode<br />
Map and count annual number of pedestrian and bicycle collisions (and severity of<br />
injury/fatality)<br />
Stratify all metrics by demographics to illuminate equity issues<br />
Chapter 6 – Policies and Strategies<br />
‐ We have some general suggestions, then comments on each section of the policies and<br />
strategies. Appendix B includes a detailed list of suggestions, resources, and comments that<br />
we look forward to your response on. Generally, we recommend:<br />
o Including public health representatives on the Board or performance measure selection<br />
committees.<br />
o Tying strategies of “support” or “encouragement” or “incentivizing” to methods of<br />
supporting and directing the reader to the larger <strong>MTP</strong>/<strong>SCS</strong> document that identifies<br />
specific dollar amounts of programs, if not stated.<br />
o Including health outcomes indicators and health determinants indicators in any<br />
modeling, monitoring, and reporting.<br />
o In places that SACOG has a strategy of educating, doing outreach, and publicizing,<br />
ensure that the stakeholder list include not only decision‐makers, policy‐makers, local<br />
staff, and other agencies, but the public and engaged CBOs, as well as media.<br />
o When creating efficiencies, seeking public‐private partnerships for funding, and<br />
increasing competition, make sure to not violate union contracts. If creating new<br />
bidding on new or current projects for operations or construction/maintenance, include<br />
first‐source hiring to employ local residents and prioritize minority‐owned businesses.<br />
o Moving up the timeline for investments in public transit and bike/ped infrastructure<br />
improvements.<br />
See HIP Comment Letter Appendix B: Health & Equity comments on SACOG Policies & Strategies<br />
Chapter 7 ‐ Environmental Sustainability<br />
‐ While this chapter includes a section on open space resources for recreational use, it does not<br />
discuss equity in access to this open space. We recommend measuring the proportion of<br />
households that can walk or bike (10 minutes) to parks, and including stratification by income,<br />
race, age, and disability, in future monitoring, in planning for Transit Priority Areas, and other<br />
future plans and evaluations.<br />
‐ While health impacts associated with air pollutants (i.e., ozone, PM 10 , PM 2.5 , and CO) are<br />
described (i.e., pages 7‐22 – 7‐24), we recommend modeling health impacts associated with<br />
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current and future emissions. For example, pre‐mature mortality attributed to traffic related<br />
ambient PM 2.5 , and asthma incidence and asthma exacerbations attributed to traffic related<br />
NO 2 should be modeled.<br />
‐ We commend SACOG for recommending against sensitive development within a 500‐foot buffer<br />
of major roadways, defined as freeways or urban roads with traffic volumes of 100,000 or more<br />
vehicles per day or rural roads with 50,000 or more vehicles per day (in accordance with the ARB<br />
Handbook). However, the percentage of the region’s population living within this buffer is still<br />
predicted to increase between from 2.02% to 2.4% between 2008 and 2035. We recommend<br />
ensuring the assessment of health impacts for developments within 1,000 foot buffer of busy<br />
roadways. We further recommend estimating the proportion of affordable housing units vs.<br />
market rate units within above identified areas.<br />
‐ While we commend the use of Sacramento Metropolitan Air Quality Management District<br />
(SMAQMD) protocol for project developers to use in assessing potential risks to residents from<br />
siting adjacent to major roadways (i.e., page 7‐29), we recommend the use of a 1,000‐foot<br />
buffer as a trigger for assessment of potential health risks and mitigations to decrease those<br />
health risks if development moves forward.<br />
‐ In the section on Travel Behavior Approach (page 7‐40), there is a statement that investments in<br />
public transportation infrastructure are expensive. We encourage a deeper analysis of economic<br />
costs and benefits of public transportation, pedestrian, and bicycle infrastructure. For example,<br />
bicycle infrastructure projects create 11.6 jobs for every $1 million spent and pedestrian<br />
projects create 9.6 jobs per $1 million, while vehicle roadway‐only projects only create 7.8 jobs<br />
per the same expenditure. 8<br />
Chapter 8 – Equity<br />
‐ We commend SACOG for working with the UC Davis Center for Regional Change to come up<br />
with enhanced criteria for designating Environmental Justice (EJ) populations, and for assessing<br />
inequities associated with impacts on these populations. In order to assess inequities, the<br />
following indicators were stratified by both EJ and non‐EJ populations:<br />
Mode share (public transit, walking, bicycling)<br />
Personal vehicle use<br />
Access to transit<br />
Transit access to jobs, medical care, higher education, and parks<br />
Vehicle access to jobs, medical care, higher education, and parks<br />
Unsurprisingly, EJ areas performed well on all of these indicators; this is likely because EJ areas<br />
are typically transit‐rich and near freeways.<br />
In addition to these indicators, we recommend measuring and stratifying the following<br />
additional indicators by EJ and non‐EJ designations: 9<br />
8 Garrett‐Peltier H (University of Massachusetts, Amherst, Political Economy Research Institute). June 2011. Pedestrian and<br />
Bicycle Infrastructure: A National Study of Employment Impacts.<br />
9 For more detail, see Human Impact Partners, August 2011. Elevating Health & Equity into the Sustainable Communities<br />
Strategy (<strong>SCS</strong>) Process: <strong>SCS</strong> Health & Equity Performance Metrics.<br />
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<br />
<br />
<br />
<br />
<br />
<br />
<br />
<br />
Annual number of pedestrian and bicycle collisions (and severity of injury/fatality)<br />
Proportion of households that can walk or bike to meet at least 50% of their daily needs<br />
Proportion of daily trips less than 3 miles and less than 1 mile by mode<br />
Daily amount (in minutes) of work‐trip and non‐work trip related physical activity<br />
Share of housing growth, proportion of projected population growth, and proportion of<br />
projected jobs in transit priority areas<br />
Percent of household income consumed by housing and transportation combined and<br />
separately<br />
For all daily trips, per capita miles traveled by mode (walking, biking, transit, vehicle)<br />
Pre‐mature mortality attributed to traffic related ambient PM2.5, and asthma incidence<br />
and exacerbations attributed to traffic related NO2.<br />
‐ We commend SACOG’s analysis of the proportion of residents within 500 feet of high volume<br />
roadways and stratification by EJ and non‐EJ populations. It is acknowledged that in both 2008<br />
and 2035, the percentage of the total EJ population living within 500 feet of high volume<br />
roadways exceeds that of non‐EJ populations by 2 to 1. Between 2008 and 2035, this proportion<br />
of the regional EJ population changes from 3.3% to 4%, while this proportion of the regional<br />
non‐EJ population changes from 1.6% to 1.8%. In addition to analyzing this within a 1,000 foot<br />
buffer rather than a 500‐foot buffer, as stated above, we recommend ensuring that the EJ<br />
population does not bear such a larger brunt of this proportional increase as compared to the<br />
non‐EJ population. In addition, we recommend also estimating the proportion of affordable<br />
housing units versus market rate units within the 1,000‐foot buffer.<br />
Chapter 9: Economic Vitality<br />
‐ SACOG’s land use strategies of focusing new housing near current jobs and new jobs near<br />
current housing helps to decrease the cause of the largest amount of VMT, which is that driving<br />
to work is usually the longest trip of the day. Other prioritized projects such as HOV lanes,<br />
Transportation Demand Management, improving and increasing transit, and adding Class 1 and<br />
2 bike lanes, also contributes to the decrease of VMT, and ultimately of the regional exposure to<br />
vehicle emissions, as well as encouraging physical activity.<br />
‐ Considering the rural community in the SACOG region separately is another success strategy<br />
that SACOG has employed to refine solutions for rural roads that are targeted to their needs.<br />
‐ The detailed analysis of the goods movement industry was good to see. The alternative routing<br />
decisions of truck drivers to avoid congestion is a concern, and trucks backing up local traffic as<br />
well as destroying pavement because of their use of rural roads. SACOG has considered some<br />
creative solutions, but looking toward some of the regions that have been dealing with goods<br />
movement for ideas about fees, fines, incentives, and other policies to enable counties and<br />
towns to capture costs that they are bearing would warrant investigation.<br />
‐ We commend the inclusion of the financial and economic development benefits of bicycle and<br />
pedestrian infrastructure projects, and would also include health benefits as well, especially if<br />
SACOG can adopt the measure of physical activity gleaned from all modes of transportation.<br />
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‐ We look forward to further work on the TPAs – their environmental analyses and their<br />
community‐driven action plans, and how they incorporate all of the measures SACOG is<br />
collecting for the <strong>MTP</strong>/<strong>SCS</strong> as well as the suggestions made by our health‐focused organizations.<br />
Chapter 9: Financial Stewardship<br />
‐ We appreciate the difficulty SACOG and counties, cities, and towns face with regard to financing<br />
maintenance and operations as well as capital projects. The detail provided about the<br />
replacement costs of transit and the labor costs of operations of transit are instructive, as well<br />
as the ways that transit operators can stretch the time of replacement due to decreased use of<br />
buses and other vehicles during the recession.<br />
‐ Understandably, many investments are slated to be implemented more fully in the 2020 – 2035<br />
time frame, rather than the 2012 – 2020 timeframe. In order for the region to begin realizing<br />
health benefits from the <strong>MTP</strong>/<strong>SCS</strong> as soon as possible, we urge SACOG to accelerate bike/ped<br />
improvements and phase public transit improvements with existing housing and job centers.<br />
‐ We are gratified to see the sensitivity to fare increases for transit‐dependent people highlighted.<br />
‐ SACOG has translated transportation system efficiencies (less road expansion, right‐sizing other<br />
capital efforts) into creative budgeting to allow for more public transit and complete streets<br />
infrastructure support. We agree that this will pay out in decreased VMT and increased active<br />
transport uptake.<br />
‐ Seeing road safety infrastructure continue to be prioritized is important for the most direct<br />
health outcome of transportation systems: fatalities and injuries from collisions.<br />
‐ We appreciate SACOG reporting out number of fatalities and injuries from collisions with<br />
vehicles, and reporting them out disaggregated by pedestrian, bicycle, truck, and auto. While<br />
we understand reporting of number of fatalities per 100 million VMT, it would be easier for the<br />
general public to digest if it were reported as a map of annual number of pedestrian and<br />
bicycle collisions (and severity of injury/fatality) per capita, per geographic area, by daytime<br />
population, and also to see the total number of vehicle, bike and pedestrian collisions per<br />
capita, broken down by severity: fatalities and injuries.<br />
‐ Finally, we also suggest that SACOG create an expenditure category for safety. In doing this,<br />
SACOG would be able to track safety projects as well as their effectiveness, based on a<br />
geographic breakdown of injuries from collisions.<br />
We thank you for the opportunity to submit comments on the draft SACOG <strong>MTP</strong>/<strong>SCS</strong>. Again, we applaud<br />
SACOG for incorporating the consideration of public health into many of the decisions, analyses, and<br />
goals included in this <strong>MTP</strong>/<strong>SCS</strong>. The recommendations that we’ve included in this letter reflect the<br />
expertise of individuals and organizations around the state that specialize in health and equity, and we<br />
hope you will thoughtfully consider adopting many of them in the <strong>MTP</strong>/<strong>SCS</strong> itself, in monitoring its<br />
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impacts in coming years, and in transit‐priority area and other decision‐making processes.<br />
Sincerely,<br />
Healthy Places Coalition<br />
Human Impact Partners<br />
WalkSacramento<br />
Coalition on Regional Equity<br />
Environmental Council of Sacramento<br />
Physicians for Social Responsibility<br />
Sacramento Chapter<br />
Physicians for Social Responsibility – Los Angeles<br />
Safe Routes to School National Partnership<br />
California State Network<br />
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Sacramento Area Bicycle Advocates<br />
California WALKS<br />
Appendix A: SACOG performance measures compared to health and equity metrics<br />
Appendix B: Health & Equity comments on SACOG Policies & Strategies<br />
Appendix C: Elevating Health in the Sustainable Communities Strategy: full report and 1 page<br />
summary of metrics of measurement methods<br />
Cc:<br />
Kacey Lizon, SACOG Senior Planner<br />
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Appendix A:<br />
Comparison Table: SACOG performance measures and Health & Equity in <strong>SCS</strong> Metrics<br />
In this comparison table, each Health & Equity indicator (from Human Impact Partners’ report entitled<br />
“Elevating Health and Equity in Sustainable Communities Strategies”; see Appendix C) is listed in the<br />
right hand column, in the <strong>MTP</strong>/<strong>SCS</strong> Section where HIP identified that it would most likely fit. In some<br />
cases, the Health & Equity indicator was very similar to an existing performance measure included in the<br />
<strong>MTP</strong>/<strong>SCS</strong>, and in this case it was placed beside the existing measure. The number in parentheses<br />
corresponds to the number of the indicator in HIP’s report (see Appendix C). The report contains<br />
suggested methodologies and resources.<br />
The purpose of this table is simply to compare SACOG’s performance measures with the Health and<br />
Equity in <strong>SCS</strong> Metrics. For requests and recommendations, please refer to the comment letter and to<br />
Appendix B.<br />
Section <strong>MTP</strong>/<strong>SCS</strong> performance measure Health & Equity measure<br />
Land Use Measures<br />
Housing Growth in housing units by Community Type<br />
Change in housing product mix by<br />
Community Type<br />
Housing growth through reinvestment<br />
a. Percent of household income consumed<br />
by housing and transportation combined;<br />
b. Percent of income going towards housing<br />
costs. (9)<br />
Employm Employment growth in different Community<br />
ent Types by sector<br />
Employment growth by Community Type<br />
Employment growth through reinvestment<br />
Land Use Compact development: growth in<br />
population compared with acres developed<br />
Farmland acres developed – total and per<br />
capita<br />
Vernal acres developed<br />
Developed acres by Community Type<br />
Mix of<br />
uses<br />
Jobs‐Housing balance within four‐mile radius<br />
of employment centers<br />
Mix of use by Community Type<br />
Proportion of households that can walk or<br />
bike (10 minutes) to meet at least 50% of<br />
their daily needs. Public daily needs defined<br />
as: schools, parks, healthcare institutions<br />
and transit. Private daily needs defined as:<br />
restaurants, grocery stores, food markets<br />
and childcare. (3)<br />
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TOD<br />
Urban<br />
Design<br />
Growth in dwelling units within half‐mile of<br />
quality transit (in TPA) by county<br />
Growth in employees within half‐mile of<br />
quality transit (in TPA) by county<br />
New housing product mix in TPA by county<br />
Proximity to transit by Community Type<br />
Change in street pattern in different<br />
Community Types<br />
Change in residential density by Community<br />
Type<br />
Transportation Measures<br />
Driving<br />
Access<br />
VMT<br />
Total jobs within 30‐minute drive by<br />
Community Type<br />
Total weekday VMT & average annual<br />
growth rates – regionally, by county, and per<br />
capita<br />
Weekday VMT by source and total<br />
Commute share of HH generated VMT<br />
Weekday VMT by source per capita or per<br />
job<br />
Total VMT per capita<br />
% change in VMT per capita or per job<br />
compared to 2008<br />
Weekday HH‐generated VMT per capita by<br />
Community Type<br />
Weekday HH‐generated VMT per capita by<br />
TPA<br />
HH‐generated commute VMT by Community<br />
Type and regional total<br />
Commute VMT per worker by Community<br />
Type and regional total<br />
a. Share of housing growth in transit<br />
priority areas, targeting measure of how<br />
many large (3‐4) bedroom units, senior<br />
housing, low‐income units will be built;<br />
b. Proportion of projected population<br />
growth located in transit priority areas;<br />
c. Proportion of projected jobs in transit<br />
priority areas (8)<br />
Proportion of households and proportion of<br />
jobs within 1/4 mile of local public transit<br />
(including both bus and rail) or 1/2 mile of a<br />
regional public transit, that has less than 15<br />
minute frequencies (4)<br />
Daily amount (in minutes) of work‐trip and<br />
non‐work trip related physical activity (6)<br />
a. Percent of household income consumed<br />
by housing and transportation combined;<br />
c. Percent of income going towards<br />
transportation costs (9)<br />
For all daily trips, per capita miles traveled<br />
by mode (walking, biking, transit, vehicle)<br />
(10)<br />
Proportion of daily trips less than 3 miles<br />
and less than 1 mile by mode<br />
(walking/biking/bus and rail transit/driving)<br />
(5)<br />
Congeste<br />
Congested VMT total and per capita<br />
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d VMT<br />
Transit<br />
service<br />
Transit<br />
productiv<br />
ity<br />
Bike<br />
infrastruc<br />
ture<br />
Transit,<br />
walk and<br />
bike<br />
travel<br />
Roadway<br />
utilizatio<br />
n<br />
Commut<br />
e travel<br />
Noncommute<br />
travel<br />
Congested VMT by source – total, per capita,<br />
per job<br />
Congested VMT for HH‐generated travel by<br />
Community Type<br />
Increase in transit vehicle service hour per<br />
day by transit type<br />
Weekday transit vehicle service hours,<br />
passenger boardings, boardings per service<br />
hour, farebox revenues as % of operating<br />
cost<br />
Mile of bike route mileage by county<br />
Bike route miles per 100,000 population<br />
Weekday person trips by transit, walk and<br />
bike modes<br />
TWB trips per capita<br />
TWB trips per capita by CT<br />
Transit trips per capita by TPA<br />
TBW trips per capita by CT<br />
Transit trips per capita by TPA<br />
Underutilized, optimally utilized, overutilized<br />
roadways by roadway type<br />
Proportion of households and proportion of<br />
jobs within 1/4 mile of local public transit<br />
(including both bus and rail) or 1/2 mile of a<br />
regional public transit, that has less than 15<br />
minute frequencies (4)<br />
Work and non‐work trip mode share<br />
(including biking, walking, transit (bus and<br />
train), carpooling and SOV) Both at peak<br />
times and all day (7)<br />
Weekday commute tours by mode<br />
Commute mode share<br />
Weekday non‐commute person trips by<br />
mode<br />
Work and non‐work trip mode share<br />
(including biking, walking, transit (bus and<br />
train), carpooling and SOV)‐ Both at peak<br />
times and all day (7)<br />
Non‐commute mode share<br />
Safety % reduction in accident rates Map annual number of pedestrian and<br />
bicycle collisions (and severity of<br />
injury/fatality): per capita, per geographic<br />
area, by daytime population (1)<br />
Environmental Measures<br />
Farmland Farmland conversion<br />
impacts Acres of impact from growth &<br />
transportation project by type of farmland<br />
% of Williamson Act contract acres impacted<br />
Habitat<br />
impacts<br />
% of habitat & land cover impacted<br />
Acres of impact from growth & trans project<br />
Total number of vehicle, bike and<br />
pedestrian collisions per capita, broken<br />
down by severity: fatalities and injuries (2)<br />
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Floodplai<br />
n<br />
develop<br />
ment<br />
Toxic air<br />
contamin<br />
ants<br />
by type of wildland habitat/land cover<br />
% of housing units expected to be<br />
constructed in 200‐yr floodplain<br />
% of population within 500 feet of highvolume<br />
roadway by county, region<br />
Proposed housing near busy roadways will<br />
require (12)<br />
a. Assessment by local air district or public<br />
health department of the need for<br />
environmental/health impact analysis<br />
when housing is proposed near (within<br />
1,000 feet) busy roadways (over<br />
100,000 Average Annual Daily Traffic<br />
(AADT)) or other significant pollution<br />
sources (e.g., rail yards, port terminals,<br />
refineries, power plants, etc); and<br />
b. Best practice mitigation requirements<br />
by local governments when the above<br />
assessment determines that<br />
environmental quality is below standard<br />
for such proposed housing, and if such<br />
housing is determined to be safe by<br />
local air districts and public health<br />
departments with identified mitigation.<br />
In highly urban regions, we suggest an<br />
alternate metric (12):<br />
a. Estimate the number of sensitive sites<br />
(homes, schools, daycares, parks, etc.)<br />
within 1,000 feet of freeways and other<br />
major pollution sources, where that<br />
source contributes to more than 0.3<br />
μg/m 3 of PM2.5 or or cancer risk of<br />
greater than 10 additional cases of<br />
cancer/ million. (Note these are based<br />
on BAAQMD’s CEQA thresholds.)<br />
b. Estimate proportion of affordable<br />
housing units vs. market rate units<br />
within above identified areas.<br />
Working with a local public health<br />
department, university or air quality<br />
management district: Estimate pre‐mature<br />
mortality attributed to traffic‐related<br />
ambient PM 2.5, and estimate asthma<br />
incidence and asthma exacerbations<br />
attributed to traffic related NO2. (11)<br />
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GHG<br />
emissions<br />
GHG emission by sector<br />
GHG emission reductions per capita by<br />
pounds per day, %<br />
Environmental Justice Measures<br />
Land Use % of EJ area and non‐EJ area population in CT<br />
% of EJ area and non‐EJ area population in<br />
TPAs by county<br />
Housing Housing product mix in EJ and non‐EJ areas<br />
by CT<br />
Transit<br />
Service<br />
Transit<br />
Accessbili<br />
ty<br />
Mode<br />
share<br />
Auto<br />
accessibil<br />
ity<br />
Comparis<br />
on of<br />
transit<br />
and auto<br />
accessibil<br />
ity<br />
Toxic air<br />
contamin<br />
ants<br />
Increases in daily transit vehicle service<br />
hours in EJ areas<br />
Accessibility from EJ and non‐EJ areas within<br />
30 min by transit to jobs, retail jobs, medical<br />
jobs, higher education, park acres<br />
EJ & non‐EJ area transit mode share<br />
Bike & Walk mode share in EJ & non EJ areas<br />
Accessibility from EJ and non‐EJ areas within<br />
30 min by car to jobs, retail jobs, medical<br />
jobs, higher ed, park acres<br />
% of jobs, retail jobs, medical jobs, higher ed,<br />
park acres accessibility within 30 min by<br />
transit vs. car from EJ and non‐EJ areas<br />
% of population within 500 feet of highvolume<br />
roadway by county, region<br />
Share of housing growth in transit priority<br />
areas, targeting measure of how many large<br />
(3‐4) bedroom units, senior housing, lowincome<br />
units will be built; (8)<br />
a. Percent of household income consumed<br />
by housing and transportation combined;b.<br />
Percent of income going towards housing<br />
costs (9)<br />
Proportion of households that can walk or<br />
bike (10 minutes) to meet at least 50% of<br />
their daily needs. Public daily needs defined<br />
as: schools, parks, healthcare institutions<br />
and transit. Private daily needs defined as:<br />
restaurants, grocery stores, food markets<br />
and childcare. (3)<br />
Work and non‐work trip mode share<br />
(including biking, walking, transit (bus and<br />
train), carpooling and SOV)‐ Both at peak<br />
times and all day (7)<br />
Proportion of households that can walk or<br />
bike (10 minutes) to meet at least 50% of<br />
their daily needs. Public daily needs defined<br />
as: schools, parks, healthcare institutions<br />
and transit. Private daily needs defined as:<br />
restaurants, grocery stores, food markets<br />
and childcare. (3)<br />
Housing near busy roadways (12)<br />
a. Estimate the number of sensitive sites<br />
(homes, schools, daycares, parks, etc.)<br />
within 1,000 feet of freeways and other<br />
major pollution sources, where that<br />
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source contributes to more than 0.3<br />
μg/m 3 of PM2.5 or or cancer risk of<br />
greater than 10 additional cases of<br />
cancer/ million. (Note these are based<br />
on BAAQMD’s CEQA thresholds.)<br />
b. Estimate proportion of affordable<br />
housing units vs. market rate units<br />
within above identified areas.<br />
Measure and stratify all indicators by<br />
race/ethnicity; income; geography<br />
(neighborhood, census block or tract, or<br />
Community of Concern); age; disability. (13)<br />
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Appendix B: Health and Equity comments on SACOG Policies and Strategies<br />
Strengths<br />
Environmental Sustainability<br />
Complementary strategies<br />
# Comment<br />
2.5 Continuance of the social equity analysis.<br />
3 All of Policy 3 further health goals<br />
4.3 Tool development measuring jobs/housing fit and Housing & Transportation cost analysis.<br />
4.5 Support for jurisdictions in overcoming impediments to fair housing.<br />
6 Incentives for infill and alternative modes of transit, minimizing the urban footprint,<br />
conserving open space and natural resources all support positive health outcomes.<br />
7.7 Incentives for rural land use and transportation practices that benefit the region and as<br />
well as local rural areas.<br />
8.1‐ TDM, SECAT, and Spare the Air support.<br />
8.3<br />
10 Policies and programs to reduce the environmental, health, and equity effects of goods<br />
movement. Any change in practice requires multiple approaches and it is good to see<br />
SACOG focusing at the systemic and corporate levels as well as at behavior change among<br />
individual drivers. We encourage prioritization among individual drivers.<br />
# Comment<br />
1.5 Have a local public health representative on the advisory team when helping local<br />
governments create and maintain a development activity tracking tools assessing growth<br />
patterns.<br />
2.2‐ When monitoring transportation and air quality impacts of development patterns,<br />
2.3 include health outcomes monitoring and equity monitoring (see attached Health and<br />
Equity indicators: # 1,2,6, 11, 13). Specifically, monitor respiratory disease impacts of air<br />
quality changes due to development; injuries/fatalities due to changed traffic patterns,<br />
and change in physical activity levels – and how development patterns impact race,<br />
ethnicity, low‐income communities. 10<br />
2.4 Educational materials should include health impacts of neighborhood travel behavior,<br />
and enlist public health departments to help create these.<br />
2.7 One methodology to include health impacts in review transportation projects in the<br />
design phase is including health impact assessment in the planning requirements, or a<br />
health/social checklist. 11<br />
12 13<br />
2.9 Include in the economic land use modeling ways of modeling cost of health impacts.<br />
10 For more detail, see Human Impact Partners, August 2011. Elevating Health & Equity into the Sustainable<br />
Communities Strategy (<strong>SCS</strong>) Process: <strong>SCS</strong> Health & Equity Performance Metrics. Available at<br />
http://www.humanimpact.org/projects<br />
11 For more information about Health Impact Assessment, see http://www.humanimpact.org/hia<br />
12 Pedestrian and Bicycle Infrastructure: A National Study of Employment Impacts. University of Massachussetts,<br />
Amherst, Political Economy Research Institute, June 2011.<br />
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2.10 When providing education and analysis to inform decision‐makers, local staff, and other<br />
stakeholders about open space, economic, and environmental benefits, also inform them<br />
of health and equity benefits. Can be done by reporting out monitoring results for health<br />
and equity indicators, by including public health representatives when designing<br />
materials. Make sure other “stakeholders” are the public as well.<br />
3.7 When researching and modeling to provide evidence to support parking regulation<br />
modification and incentivizing, take outcomes of air emissions and transportation<br />
circulation patterns out to respiratory health outcomes from air quality changes,<br />
pedestrian/bike injuries/fatalities from collisions, and changes in physical activity levels. 14<br />
4.1 Publicize and educate policy‐makers and the public about the RHNA results.<br />
4.3 One methodology to supplement SACOG’s tool measuring the jobs/housing fit is the<br />
Center for Community Innovation at University of California – Berkeley’s Early Warning<br />
Toolkit for Gentrification. 15<br />
4.5 Could you give more detail on how you would support overcoming common issues local<br />
analyses of impediments to fair housing (and regional analyses)?<br />
5.1 Do an equity analysis to see if the lands identified to meet goods movement needs<br />
disproportionately negatively impact economic justice communities.<br />
5.2 Studies of the land needs for goods movement and distribution should include indicators<br />
of health outcomes impacted by increased truck traffic such as motor vehicle collisions<br />
with other vehicles, pedestrians, and bicyclists; respiratory disease outcomes from<br />
increased exposure to diesel emissions from trucking, and noise impacts of localized and<br />
regional goods movement.<br />
5.3 Agriculture industry needs for goods movement should include in studies the size of<br />
farms and prioritize needs for small and mid‐size farmers, who have been hit<br />
disproportionately by development and by the recession.<br />
6.5,<br />
7.1,<br />
&<br />
7.4<br />
Local jurisdictions could use health impacts analyses to build on RUCS data and tools to<br />
analyze possible impacts to agriculture and natural resource from any urban footprint<br />
growth. HIA is a useful stakeholder‐driven methodology that can supplement other<br />
methods, processes, and tools. 16 Also, SACOG should foster or participate in a process to<br />
develop additional tools and a more comprehensive dataset of the region’s natural<br />
resources and examine how they contribute to purify water, mitigate urban heat island<br />
effect, and other public health interests.<br />
7.6 Local partners at University of California at Davis may be able to support the work SACOG<br />
is doing to support Farm to Market access.<br />
8.4 There are tools available to support SACOG’s support in studying localized air pollution<br />
impacts on health: MTC, tools from the Health and Equity metrics in <strong>SCS</strong>, and SFDPH’s<br />
13 Growing Healthy in Southern California. American Lung Association of California.<br />
http://www.lungusa.org/associations/states/california/advocacy/fight‐for‐air‐quality/smart‐growth‐forcalifornia.html<br />
14 HIP, ibid. Elevating Health & Equity into the Sustainable Communities Strategy (<strong>SCS</strong>) Process: <strong>SCS</strong> Health &<br />
Equity Performance Metrics.<br />
15 Chapple K. 2009. Mapping Susceptibility to Gentrification: The Early Warning Toolkit. Available at<br />
communityinnovation.berkeley.edu/reports/Gentrification‐report.pdf<br />
16 HIP, ibid. Elevating Health & Equity into the Sustainable Communities Strategy (<strong>SCS</strong>) Process: <strong>SCS</strong> Health &<br />
Equity Performance Metrics.<br />
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modeling to guide placement of residential development and development for sensitive<br />
receptors). 17<br />
9 Policies and strategies to decrease GHG are generally good for health. Please ensure that<br />
any projects or programs implemented do not have unforeseen health and equity<br />
impacts in other areas besides the impact of GHG and air emissions on health.<br />
9.1 For these pilot programs, how will SACOG decide where to target them? Suggest have<br />
public health and equity partners on any selection committee.<br />
9.4 For regional climate action plan, prioritize projects and policies known to have the largest<br />
impact on health outcomes for vulnerable communities<br />
10.2 When encouraging alternative modes to move freight, study the health and equity<br />
impacts of how that might be done. You can do this through use of HIA or potentially use<br />
of prioritized health indicators in planning.<br />
Concerns<br />
# Comment<br />
6.4 SACOG support for reducing protections to environmentally sensitive developments, even<br />
at the edges of existing urbanization. These are the places where environmental injustice<br />
takes place.<br />
Strengths<br />
Finance<br />
# Comment<br />
Prioritizing transit investments, encouraging Complete and Green Streets and Safe<br />
Routes to Schools.<br />
13.6 Conditioning funding for regional transportation plans on implementation of mitigation<br />
measures.<br />
14.4 Helping local agencies get funding for safety programs and improvements.<br />
Complementary strategies<br />
# Comment<br />
11.2 Make sure, when simplifying and adding flexibility to funding structures or tools, that<br />
simplification does not bypass protections for public health and equity such as<br />
environmental impact assessments. When pursuing projects that qualify for CEQA<br />
streamlining, continue to incorporate health and equity studies; while the effects of<br />
TOD and smart growth are fairly well‐accepted in terms of positive environmental<br />
impacts, some TOD and smart growth projects uncover tradeoffs in health outcomes.<br />
11.3 If promotion of competition in the interest of efficiency incurs new RFPs or bidding, put<br />
in place a local hire policy and minority‐owned business policy.<br />
14.6 Include public health agencies as one of the multiple disciplines that you coordinate<br />
17 HIP, ibid. Elevating Health & Equity into the Sustainable Communities Strategy (<strong>SCS</strong>) Process: <strong>SCS</strong> Health &<br />
Equity Performance Metrics.<br />
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with in planning and actions.<br />
15.1 When pooling funds and programming to increase flexibility in use of funds, do not pool<br />
funds targeted for Environmental Justice concerns and projects. Keep these earmarked<br />
so as not to deprioritize them.<br />
16.2 Keep in mind equity concerns when looking at Value Pricing and HOV toll lanes, pay‐atthe‐pump<br />
auto insurance, or auto loans.<br />
Strengths<br />
System Maintenance and Operations<br />
# Comment<br />
17.3 Considering operational improvements to decrease congestion before considering road<br />
expansion.<br />
18.2 Encouraging stakeholder engagement in the development of the Corridor System<br />
Management Plan.<br />
18.4 Seeking more funding from programs such as the Sustainable Communities and<br />
California Strategic Growth Council.<br />
20.1 Improving pedestrian and bike access to public transit.<br />
21.2 Looking at specialty transit access to agriculture areas seasonally and for agritourism.<br />
This is a great equity move for agriculture workers, and could improve economic<br />
outcomes for farmers.<br />
22.1 Educational outreach on improving perception of forms of public transit. These could<br />
include health impacts of public transportation as well in those outreach materials.<br />
24 Outreach to low income and minority communities to ensure improvements are<br />
equitable.<br />
25.6 Considering how to encourage transporting freight by rail or ships instead of primarily<br />
trucks.<br />
26.2 Diverting freight traffic around the region, and not through the region ‐ must be sure to<br />
not incur negative impacts on other regions.<br />
Complementary strategies<br />
# Comment<br />
17.2 When considering public‐private partnerships and competitive service contracts for<br />
maintenance and operations, make sure not to violate union contracts, and target new<br />
contracts for local hire with first source hiring rules and points for minority‐owned<br />
businesses.<br />
18.3 Include health indicators and outcomes in the modeling for travel forecasting and<br />
analysis associated with each CSMP. 18<br />
20.3 Include monitoring of actual health outcomes of pedestrian safety concerns: pedestrian<br />
injuries and fatalities from collisions with vehicles.<br />
20.5 For Connect Card universal fare card implementation, support or seek support for<br />
18 HIP, ibid. Elevating Health & Equity into the Sustainable Communities Strategy (<strong>SCS</strong>) Process: <strong>SCS</strong> Health &<br />
Equity Performance Metrics.<br />
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subsidies for low‐income residents and youth.<br />
24.5 When mitigating transportation impacts, include Health & Equity Metric #12 19 :<br />
assessing need for EIA/HIA when housing is near 1,000 feet of a busy roadway and<br />
requiring best practice mitigation requirements when the assessment determines that<br />
air quality is a risk to health. Ideally, an equity analysis would be done, including<br />
estimating the proportion of affordable housing units vs. market rate units within 1,000<br />
foot buffer of busy roadways (over 100,000 AADT).<br />
25.1 When improving regional freight forecasting tools, including health impacts from diesel<br />
and other air emissions, injuries/fatalities from collisions, and health outcomes due to<br />
noise.<br />
25.2 Include members of the public and also public health advocacy and agencies on the<br />
goods movement advisory group.<br />
25.3 Include health outcomes impacts of logistics industry (not just measures of noise<br />
changes, air emissions changes, and safety).<br />
25.4<br />
&<br />
26.1<br />
When identifying new preferred truck access routes, conduct a health and equity<br />
analysis.<br />
Strengths<br />
System Expansion<br />
# Comment<br />
Health evidence supports expansion of transit over road expansion, and supporting<br />
expansion that supports infill development, limits to increase of the urban footprint,<br />
and circulation patterns that will encourage active transport.<br />
28.12 Encouraging supportive features that will help encourage people to take public transit.<br />
29.2 ‐<br />
29.4<br />
Investing in bike/ped networks in the order identified, sharing information in order to<br />
increase connectivity, and funding complete streets.<br />
Complementary strategies<br />
# Comment<br />
27.3 Ensure that new intercity rail services do not encourage sprawl.<br />
28.3 We commend SACOG for considering the full life‐cycle costs of transit options; does<br />
SACOG also do this for roadway projects? When considering the costs, is this a place to<br />
also consider the Housing + Transportation costs for the consumer?<br />
28.4<br />
&<br />
When deciding on where to develop transit corridors between communities and local<br />
transit and how/where to design commute transit, include a mapping and quantitative<br />
19 HIP, ibid. Elevating Health & Equity into the Sustainable Communities Strategy (<strong>SCS</strong>) Process: <strong>SCS</strong> Health &<br />
Equity Performance Metrics.<br />
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28.6 measure of ¼ mile access to local transit for different communities. See methodologies<br />
in the Health & Equity metrics for assistance. 20<br />
28.10 Strengthen this strategy to better ensure that development will match rail density<br />
requirements. The strategy should rely on existing “local smart growth plans”, not<br />
simply “local smart growth planning” and developers must be held to a high standard of<br />
evidence that growth will happen and will support rail.<br />
29.1 Investing in safe bicycle and pedestrian routes is an excellent strategy. We would<br />
encourage mapping/measuring, monitoring changes in, and reporting out ½ mile access<br />
from residences to schools, worksites, shopping, and transit stops.<br />
30.1 ‐<br />
30.3<br />
Have good public processes around projects that expand roads, even if they support<br />
effective transit services and intend to reduce congestion near infill. Processes should<br />
look at health and equity impacts of road expansion, include analyses of induced traffic<br />
(by forecasting changes in VMT and other “miles traveled” such as pedestrian and bike<br />
miles traveled) as a result of improvements made in conjunction with road expansion.<br />
Analyses should consider a wide time horizon to account for induced travel.<br />
30.3 When proposing to expand roads near infill, make sure to measure and model<br />
respiratory health impacts, equity impacts, and mode used for proportion of daily trips<br />
less than 3 miles and less than 1 mile by mode (auto, bike, walk). 21<br />
30.5 When proposing expansion of trunk arterials around job centers and freeway<br />
interchanges, be sure to measure and model health impacts for those in housing within<br />
1,000 feet of these access routes, and propose mitigations for projects which show<br />
negative respiratory and cardiovascular health impacts. 22<br />
Concerns<br />
# Comment<br />
28.9 This strategy is exemplary from a health lens. Bus service is a cost‐effective way to<br />
increase and improve use of public transit.<br />
20 HIP, ibid. Elevating Health & Equity into the Sustainable Communities Strategy (<strong>SCS</strong>) Process: <strong>SCS</strong> Health &<br />
Equity Performance Metrics.<br />
21 HIP, ibid. Elevating Health & Equity into the Sustainable Communities Strategy (<strong>SCS</strong>) Process: <strong>SCS</strong> Health &<br />
Equity Performance Metrics.<br />
22 HIP, ibid. Elevating Health & Equity into the Sustainable Communities Strategy (<strong>SCS</strong>) Process: <strong>SCS</strong> Health &<br />
Equity Performance Metrics.<br />
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<strong>SCS</strong> Health & Equity Metrics August 2011<br />
Appendix C<br />
Elevating Health & Equity into the Sustainable Communities<br />
Strategy (<strong>SCS</strong>) Process<br />
<strong>SCS</strong> Health & Equity Performance Metrics<br />
Human Impact Partners<br />
August 2011<br />
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<strong>SCS</strong> Health & Equity Metrics August 2011<br />
Table of Contents<br />
Introduction 3<br />
The Metrics<br />
Safety 5<br />
Access to Goods, Jobs, and Services 7<br />
General Transportation 16<br />
Future Growth 21<br />
Economic 23<br />
Environmental Pollution 25<br />
Equity 36<br />
How to use the Health and Equity Metrics 38<br />
Appendix: Metrics recommended for future study 40<br />
References 41<br />
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<strong>SCS</strong> Health & Equity Metrics August 2011<br />
<strong>SCS</strong> Health & Equity Performance Metrics<br />
INTRODUCTION<br />
In 2008, the California legislature passed SB375, the intent of which is to decrease emissions of<br />
greenhouse gases to target levels in each region of the state. Given the connection between how<br />
our environment is built and health behaviors, outcomes, and inequities, this is a unique<br />
opportunity to elevate health and equity into transportation and land use planning.<br />
The bodies responsible for implementation are the Metropolitan Planning Organizations<br />
(MPOs) in each of the 18 regions of the state, and they are planning for this change through<br />
their Regional Transportation Plans (RTPs), an update of transportation policies and guidelines,<br />
as well as guidance on the types of projects (and in some cases the actual projects) that will be<br />
constructed over the next 25 years. Within the RTPs, all MPOs will be developing a Sustainable<br />
Communities Strategy (<strong>SCS</strong>), which is the document and vision for decreasing greenhouse gas<br />
emissions through transportation and land use planning.<br />
Given the high levels of chronic disease, including obesity, diabetes, and asthma, that we are<br />
facing as a country, it is imperative that we address the root causes. We spend a higher percent<br />
of our GDP on healthcare than any other country and while access to healthcare and genetics are<br />
important factors that determine our health status, there is growing recognition that the land use<br />
and transportation systems that influence our personal behaviors affect our health status even<br />
more. As described below, transportation systems impact health in many ways, through injuries<br />
and fatalities, environmental quality (e.g., air quality and noise), physical activity, and income.<br />
These impacts are typically not distributed evenly across all populations, with lower income<br />
populations and communities of color often facing worse outcomes for a variety of reasons.<br />
Understanding the causes of these differences is an important piece of addressing them. For this<br />
reason, we believe that equity (defined here to mean the absence of systematic disparities in<br />
health or in the major social determinants of health, between groups with different levels of<br />
underlying social advantage/disadvantage 1 ) must be assessed in addition to health.<br />
A statewide group of public health advocates convened by Human Impact Partners has<br />
developed the following set of 13 performance metrics for use in the RTP/<strong>SCS</strong> processes across<br />
the state. In the past, public health and equity have not been fully considered in land use and<br />
transportation planning and many health and equity outcomes related to those plans have been<br />
poor. We hope to inform the discussion of performance metrics with a health perspective and<br />
thereby improve future health outcomes related to these planning efforts. MPOs across the state<br />
are including different voices in the Sustainable Communities Strategy discussions as part of their<br />
RTPs. Our hope is that MPOs will consider including the following metrics in their <strong>SCS</strong>s and<br />
including public health and equity professionals and advocates in the process of developing their<br />
RTP/<strong>SCS</strong>.<br />
This document lists the 13 health and equity performance metrics prioritized by statewide health<br />
experts, agencies, advocates, and transportation planners. This list of 13 was chosen from an<br />
original 129 indicators.<br />
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<strong>SCS</strong> Health & Equity Metrics August 2011<br />
There were many agencies, advocates, planners, and individuals involved in choosing the Health<br />
& Equity metrics. Inclusion on this list does not imply a “sign-on” to the metrics, only that the<br />
agencies and organizations contributed to the prioritization, suggested methodologies and<br />
standards.<br />
• Climate Plan<br />
• American Lung Association<br />
• California Department of Public<br />
Health<br />
• Los Angeles County Department of<br />
Public Health<br />
• Shasta County Department of<br />
Public Health<br />
• BARHII<br />
• San Mateo County Health System<br />
• Move LA<br />
• Prevention Institute<br />
• Public Health Law & Policy<br />
• Reconnecting America<br />
• Safe Routes to Schools<br />
• Public Health Institute<br />
• PPIC<br />
• TransForm<br />
• Marin County Department of<br />
Public Health<br />
• Public Advocates<br />
• PolicyLink<br />
• Public Law Center<br />
• Raimi & Associates<br />
• Nelson & Nygaard<br />
• Fehr & Peers<br />
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The effort was funded by the Resource Legacy Fund.<br />
Metrics chosen needed to be: measurable over time; evidence-based; geographically<br />
scale-able (measured at various scales, like local and regional, and at scales useful to<br />
those using them); understandable and accessible to policy-makers; stratifiable by race,<br />
ethnicity, place, income; relevant to health and equity; and, of course, relevant to the<br />
Sustainable Communities Strategy.<br />
The metrics are the result of an intensive 2-month collaboration with the above groups.<br />
The metrics will not apply equally to every region, particularly the more rural regions. It<br />
is our hope that in each region, local public health agencies and advocates will work with<br />
transportation agencies and advocates to adapt the metrics to fit their region. Human<br />
Impact Partners and other organizations involved are available to assist those efforts<br />
(see “How to Use Health and Equity Metrics” at the end of this document).<br />
This document does not provide recommendations of benchmarks for each metric.<br />
While we do provide standards, it is again our hope that agencies and advocates<br />
concerned about health and equity will take this document and use it to craft<br />
recommendations specific to their region and the politics that exist locally.<br />
Finally, any prioritization process cannot necessarily include all of the metrics. There<br />
were metrics that participants felt were important but did not make the final list. Some<br />
of the metrics, listed in the appendix below, were recommended for further study by the<br />
MPOs.<br />
The structure of the document includes the thirteen metrics and with each metric we<br />
provide the evidence that connects that metric to health and equity, a suggested<br />
methodology for measuring the metric, resources to help if the methodology is<br />
unfamiliar, limitations of the methodology if there are any, and some standards that exist<br />
around the metric.<br />
SAFETY<br />
METRICS: SAFETY<br />
1. Map annual number of pedestrian and bicycle collisions (and severity of injury/fatality):<br />
per capita, per geographic area, by daytime population<br />
2. Total number of vehicle, bike and pedestrian collisions per capita, broken down by<br />
severity: fatalities and injuries<br />
EVIDENCE BASE<br />
Health Impacts<br />
Number of collisions is directly tied to injuries and fatalities. Motor vehicle crashes are the leading<br />
cause of death among those ages 5-34 in the U.S. ii Areas with high levels of vehicle miles traveled per<br />
capita tend to have higher collision and injury rates. More time in a car means higher exposure to the<br />
perils of driving, including collisions. iii There is a statistically significant relationship between traffic<br />
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volume and the number of vehicle collisions involving a pedestrian. iv v vi vii California’s pedestrian<br />
fatality rates are much higher than the nation’s, with pedestrians accounting for more than 17 percent<br />
of motor vehicle collision related deaths in California. viii The lifetime odds of dying as a car driver or<br />
passenger are 1 in 261, compared to 1 in 64,596 as a bus occupant or 1 in 115,489 on a train. ix<br />
The risk of pedestrian injuries may discourage walking as a mode of transport, and negatively impact<br />
physical activity levels. The perception of collision risk may also prevent people from cycling. In a<br />
survey of adults in the Vancouver metropolitan area, the top deterrents to cycling were the risk of<br />
injury from car-bike collisions; the risk from motorists who don't know how to drive safely near<br />
bicycles; motorized vehicles driving faster than 50 km/hr; and streets with a lot of car, bus, and truck<br />
traffic. x Additionally, beyond the immediate physical consequences of a collision, an individual’s wellbeing<br />
can also be impacted from resulting levels of disability, high medical costs and lost<br />
productivity. xi<br />
Equity Impacts<br />
Pedestrian collisions are more common in low-income areas, potentially reflecting greater residential<br />
density, greater traffic volume, and lower automobile ownership among residents of these<br />
neighborhoods. xii In Alameda County, for example, the combined rate of pedestrian injury or death<br />
in high poverty areas is six times that in low poverty areas (12 cases per 1,000 people in high poverty<br />
areas vs. 2 cases per 1,000 people in low poverty areas). xiii<br />
There are also racial disparities in risks associated with pedestrian crashes. xiv A greater incidence of<br />
crashes involving pedestrians exists among minorities; African American and Hispanic race/ethnicity<br />
as well as uninsured status are linked to increased risk of mortality from collisions. xv<br />
METHODOLOGY<br />
In California, the Statewide Integrated Traffic Records System (SWITRS) records data for all vehicle,<br />
bicycle and pedestrian collusions that are reported. This data is available at the intersection level and<br />
therefore able to be geocoded and aggregated by census tract, neighborhood, city or region-wide.<br />
When calculating collisions per capita, the daytime population (when available) may be a more<br />
reliable denominator, however collisions before 5 AM and after 7 pm should be excluded when using<br />
the daytime population. Alternatively, residential population overall can be used as the denominator.<br />
Race/ethnicity data is largely missing from SWITRS, so stratification by race is not possible using<br />
this data.<br />
TIMS (Transportation Injury Mapping System) will map SWITRS data by census track, traffic zones,<br />
schools, etc. http://www.tims.berkeley.edu/ MPOs need to be careful with TIMS data as it doesn't<br />
include all collisions (only those that are severe or fatal). For complete data use the SWITRS site.<br />
RESOURCES<br />
Serious and fatal injuries are geocoded and available at no cost from UC Berkeley SafeTREC<br />
(http://www.tims.berkeley.edu/)<br />
Monitoring: San Francisco Department of Public Health- Healthy Development Measurement Tool:<br />
Indicator ST.3.c Number of bicycle collisions- http://www.thehdmt.org/indicators/view/59<br />
Forecasting: An example of the development and use of a multivariate, area-level regression model of<br />
vehicle-pedestrian injury collisions that has been applied to predict area-level change in vehiclepedestrian<br />
injury collisions associated with land use development and transportation planning<br />
decisions:<br />
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Wier M, Weintraub J, Humphreys EH, Seto E, Bhatia R. (2009). An area-level model of vehiclepedestrian<br />
injury collisions with implications for land use and transportation planning. Accident<br />
Analysis & Prevention, 41(1):137- 45.<br />
http://www.sfphes.org/transportation/Pedestrian_Injuries_and_Fatalities_SF.pdf<br />
LIMITATIONS<br />
As mentioned above, SWITRS data relies on collisions that have been reported. However, collisions<br />
that do not result in a serious injury and collisions resulting from poor road maintenance tend to go<br />
unreported. A joint study by the San Francisco Department of Public Health and the San Francisco<br />
Bicycle Coalition found that only 5 percent of dooring incidents (i.e., when a bicyclist is hit by a car<br />
door) were reported to the police. xvi In addition, neighborhoods in San Francisco with higher<br />
immigrant population densities may have lower reporting rates because of fear of law enforcement,<br />
whereas neighborhoods with a strong community police presence may be more likely to report<br />
collisions. xvii<br />
STANDARDS<br />
Statewide, in California in 2009:<br />
The motor vehicle collision fatality rate was 7.3 per 100,000 people;<br />
The motor vehicle collision injury rate was 425 per 100,000 people. xviii<br />
The pedestrian fatality rate from collisions with motor vehicles was 1.5 per 100,000 people<br />
The pedestrian injury rate from collisions with motor vehicles was 34 per 100,000 people. xix<br />
The bicyclist fatality rate from collisions with motor vehicles was 0.3 per 100,000 people;<br />
The bicyclist injury rate from collisions with motor vehicles was 31 per 100,000 people. xx<br />
Healthy People 2020 xxi<br />
The U.S. Department of Health and Human Services (USDHHS) Healthy People 2020 provides<br />
science-based, 10-year national objectives for improving the health of all Americans. By 2020, the<br />
following should be achieved:<br />
Unintentional injury prevention<br />
Reduce nonfatal motor vehicle crash-related injuries to 1.2 deaths per 100 million vehicle<br />
miles traveled;<br />
Reduce pedestrian deaths on public roads to 1.3 deaths per 100,000 population;<br />
Reduce nonfatal pedestrian injuries on public roads to 20.3 injuries per 100,000 population;<br />
Reduce cyclist deaths on public roads to 0.22 deaths per 100,000 population.<br />
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ACCESS TO GOODS, JOBS & SERVICES<br />
METRIC: ACCESS TO GOODS, JOBS & SERVICES<br />
3. Proportion of households that can walk or bike (10 minutes) to meet at least 50 percent of<br />
their daily needs. Public daily needs defined as: schools, parks, healthcare institutions<br />
and transit. Private daily needs defined as: restaurants, grocery stores, food markets and<br />
childcare.<br />
EVIDENCE BASE<br />
Health Impacts<br />
Neighborhood conditions can have a powerful effect on health. xxii A neighborhood’s physical<br />
characteristics may promote health by providing safe places for children to play and for adults to<br />
exercise that are free from crime, violence and pollution. xxiii Being within walking or biking distance<br />
of neighborhood goods and services promotes physical activity, reduces vehicle trips and miles<br />
traveled, and increases neighborhood cohesion and safety. xxiv Reducing vehicle trips and miles<br />
traveled can also reduce air and noise pollution, which subsequently impacts respiratory disease,<br />
cardiovascular disease, and other health conditions. Living in dense, mixed-use communities can also<br />
improve cardiovascular and respiratory health as well as reduce the risk of obesity. xxv<br />
PUBLIC GOODS & SERVICES (health care, schools, parks & transit):<br />
Access to Health Care Services and Health<br />
The timely use of primary care has a role in preventing morbidity and hospitalizations for a<br />
number of chronic diseases, including asthma and diabetes. Research has found that Federally<br />
Qualified Health Centers in medically underserved areas can lower preventable hospitalization<br />
rates. xxvi Travel distance to a health care provider and lack of transportation are well established<br />
barriers to receiving adequate health care. xxvi xxvii xxviii Additionally, people with a usual source<br />
of health care are more likely than those without a usual source of care to receive a variety of<br />
preventive health care services. xxix xxx Fifteen percent of adults in the U.S. lack a usual source of<br />
health care. This equates to more than 40 million people that have no particular doctor’s<br />
office, clinic, health center, or other place where they regularly go for health care advice. xxxi<br />
School Location, Education and Health<br />
Research findings indicate that the physical location of schools, in particular the distance that<br />
students travel to school, significantly impact health outcomes. Long travel distances to school<br />
are a primary barrier and have the strongest influence on the students’ decision to walk or bike<br />
there. xxxii xxxiii Living within a half-mile of a school greatly increases the likelihood of walking or<br />
biking to that school across all racial groups. xxxiv Active commuting to school can provide a<br />
substantial portion of children’s physical activity and has been associated with increasing levels<br />
of independence, social interaction and communication. xxxv xxxvi xxxvii xxxviii xxxix However, the level<br />
of violence in the surrounding area where a school is located can make it difficult for students<br />
to travel to and from school safely, discouraging them from walking or bicycling to school<br />
regardless of the distance or the walkability of the neighborhood. xl<br />
Access to and duration in school are incredibly important, as there are well-documented<br />
associations between education and health. xli In 1999, the age-adjusted mortality rate of high<br />
school dropouts between the ages of 18-64 was more than twice as large as the mortality rate<br />
of those with some college education. xlii Better educated individuals have healthier behaviors;<br />
are less like to be hypertensive and suffer from diabetes; and are more likely to exercise and<br />
obtain preventative care. In addition, maternal education is strongly associated with infant and<br />
child health; four more years of schooling lowers the probability of reporting in fair or poor<br />
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health by 6 percentage points; and estimates suggest that a year of education increases earnings<br />
by about 10 percent. xliii<br />
Access to Parks and Health<br />
People who live closer to parks are more likely to use them for physical activity. xliv Having park<br />
space available increases the amount of exercise that residents get. xlv For example, a 1 percent<br />
increase in park space can increase physical activity in youth by 1.4 percent. xlvi Nationally,<br />
about 30 percent of physically active people report exercising in public parks. xlvii Access to<br />
parks and open space is also associated with higher levels of social interaction, which has<br />
positive impacts on mental health through higher social support and better social networks.<br />
Access to Public Transportation and Health<br />
Public transportation that is both convenient and fast, and transit oriented development<br />
(meaning walkable, mixed-use communities located around transit stations) can affect travel<br />
activity and provide large health benefits, including reduced traffic crashes and pollution<br />
emissions, xlviii increased physical fitness, xlix improved mental health, l improved basic access to<br />
medical care and healthy food and increased affordability which reduces financial stress to<br />
lower-income households. li In fact, Americans who use public transit spend a median of 19<br />
minutes daily walking to and from transit; twenty-nine percent achieve at least 30 minutes of<br />
physical activity a day solely by walking to and from transit. xlix<br />
PRIVATE GOODS & SERVICES (food retail & childcare centers)<br />
Access to healthy food retail and health<br />
Lack of access to healthy food is one of the barriers, particularly for low-income communities,<br />
to healthy eating. Diet-related disease is one of the top sources of preventable deaths among<br />
Americans, with the burden of overweight and obesity falling disproportionately on<br />
populations with the highest poverty rates. lii liii It is well known that nutritious eating and<br />
regular physical activity aid in the prevention of chronic medical conditions, especially diabetes,<br />
cardiovascular diseases and cancers, and can alleviate the effects of conditions such as<br />
obesity. liv<br />
The choices that people make about what they consume on a day-to-day basis are influenced<br />
by the food options available at different retail locations. lv For many low-income populations<br />
in urban areas, accessible and affordable nutritious food remains a significant unmet need.<br />
Such households often buy less expensive but more accessible food at fast food restaurants or<br />
highly processed food at corner stores. These types of foods are usually higher in calories but<br />
lower in nutritional value. lvi Eating at fast-food restaurants is associated with higher caloric<br />
intake, lower vegetable consumption, greater consumption of sweetened beverages and higher<br />
rates of obesity. lvii Research has shown that where there are high numbers of fast-food<br />
restaurants compared to grocery stores, there are also higher rates of diabetes, cardiovascular<br />
disease, and cancer. lvii<br />
Childcare centers and health<br />
Today, the majority of U.S. children live in families in which all parents work. lviii Access to<br />
childcare is essential for working parents to maintain employment and/or education.<br />
Accessible high-quality childcare provides children with valuable opportunities for cognitive,<br />
behavioral and educational development, and results in positive physical health outcomes.<br />
lxii<br />
lix lx lxi<br />
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From an extensive study done about land use in Seattle, they saw that the land uses that were most<br />
strongly linked to the percentage of household walking trips in the Seattle area were educational<br />
facilities, commercial office buildings, restaurants and taverns, parks, neighborhood scale retail<br />
establishments, civic uses, grocery stores. They also found that the number of retail establishments<br />
(rather than total retail square footage) was found to be important in the decision to walk for nonwork<br />
purposes. For each quartile increase in the number of retail locations, walking for non-work<br />
trips increased 19 percent. lxiii<br />
Equity Impacts<br />
Inequities exist not only in access to goods and services within certain neighborhoods, but also in the<br />
ability to live in neighborhoods with health-promoting conditions – an ability which varies with<br />
household economic and social resources. xxiii Nearly one fifth of all Americans (approximately 52<br />
million people) live in poor neighborhoods (i.e., neighborhoods in which at least 20 percent of<br />
residents are poor). xxiii Between 1970 and 2000, poor families became more likely to live in<br />
neighborhoods with concentrated poverty and rich families became more likely to live in<br />
neighborhoods with concentrated wealth. lxiv This concentrated poverty impacts inequity – according<br />
to a recent study, the median wealth of white households is 20 times that of black households and 18<br />
times that of Hispanic households, a finding most recently impacted by plummeting home values. lxv<br />
Individuals in minority racial or ethnic groups are more likely to live in poor neighborhoods – nearly<br />
half of all blacks live in poor neighborhoods, compared with only one in ten whites. lxvi<br />
Historic trends of reduced public spending affect poor neighborhoods more than wealthy<br />
communities. lxvii The influence of socioeconomic segregation as well as racial or ethnic segregation<br />
influences neighborhood conditions in a variety of ways, from funding and quality of public schools<br />
to employment opportunities, housing quality, municipal services, and hazards such as pollution,<br />
noise and crime. xxiii A recent study in New York revealed that low-income non-white populations are<br />
at a disadvantage when trying to access daily goods and services. There was a stronger relationship<br />
for black populations than Latino populations but both populations have less access. lxviii For lowincome<br />
families, the costs of childcare can consume a major portion of income, leaving less money<br />
for food, housing and other necessities. Finally, children with low neighborhood amenities or those<br />
lacking neighborhood access to sidewalks or walking paths, parks or playgrounds, or recreation or<br />
community centers had 20 to 45 percent higher odds of obesity and overweight, compared with<br />
children who had access to these amenities. lxix<br />
METHODOLOGY<br />
Use GIS to map the distribution of daily goods and services in a particular region and households<br />
that can access them by biking or walking. Display the proportion of parcels that can access a<br />
minimum of four out of the eight public and private goods/services (50 percent) by noting the<br />
geographic areas with access below 50 percent access and those areas above 50 percent access. This<br />
analysis should produce two different maps, one showing bike access and one pedestrian access, as<br />
well as a display of the geographic equity of distribution.<br />
RESOURCES<br />
The San Diego Association of Governments (SANDAG) has begun to develop methodology for<br />
mapping and quantifying neighborhood access to healthful resources. For more information, contact<br />
Vikrant Sood at vso@sandag.org.<br />
Richmond General Plan: Neighborhood Completeness Index xxiv – Moore Iacofano Gostsman, Inc.<br />
(2007). Richmond general plan update- Issues & opportunities paper #8: Community health and<br />
wellness(<strong>Draft</strong>). p23<br />
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http://www.cityofrichmondgeneralplan.org/docManager/1000000640/Existing%20Condictions%2<br />
0Report%20August%202007.pdf<br />
LIMITATIONS<br />
While geographic distance is just one dimension of accessibility, proximity to services does not<br />
necessarily promote increased walking and biking, reduced daily vehicle trips and miles traveled,<br />
increased, and increased interactions among neighbors and others on the street. While this metric<br />
demonstrates the geographic distribution of key public services within a neighborhood, two residents<br />
within the same neighborhood may have very different abilities to access goods and services, due to<br />
the size and topography of the neighborhood, available transportation options, affordability of goods<br />
and services, hours of operation, and language and cultural accessibility. lxx It is also important to note<br />
that accessibility is not a measure of the quality of goods/services available.<br />
STANDARDS<br />
Richmond General Plan xxiv : If a given parcel in the city is within 1⁄4 mile of at least 9 of the 18<br />
services listed, that parcel is considered to have good physical proximity to daily goods and services<br />
(service index of 0.5). A service index of 0.5 or higher relates to completeness of neighborhoods.<br />
Available at:<br />
http://www.cityofrichmondgeneralplan.org/docManager/1000000640/Existing%20Condictions%2<br />
0Report%20August%202007.pdf<br />
SFDPH: Proportion with access to 8 out of 11 public goods and services and 9 out of 12 key retail<br />
services.<br />
Available at: http://www.thehdmt.org/objectives/view/62<br />
Ahwahnee Principles for Resource Efficient Communities lxxi<br />
Community Principle 1. All planning should be in the form of complete and integrated<br />
communities containing housing, shops, workplaces, schools, parks and civic facilities essential<br />
to the daily life of the residents.<br />
Community Principle 2. Community size should be designed so that housing, jobs, daily needs,<br />
and other activities are within easy walking distance of each other.<br />
Community Principle 7. The community should have a center focus that combines commercial,<br />
civic, cultural and recreational uses.<br />
Community Principle 8. The community should contain an ample supply of specialized open<br />
space in the form of squares, greens and parks who frequent use is encouraged through<br />
placement and design.<br />
Available at: http://www.lgc.org/ahwahnee/principles.html<br />
California TOD Housing Program Guidelines lxxii . Transit-supportive land use<br />
This law establishes the priorities for distributing funding for TOD communities, and it gives points<br />
for housing that will be built near a transit stop and has access to 10 of the following uses:<br />
Bank, child care facility, community center, convenience store, hair care, hardware store,<br />
pocket park or playground, health club or outdoor recreation facility, laundry or dry cleaner,<br />
library, medical/dental office, pharmacy, place of worship, policy/fire station, restaurant,<br />
coffee shop, deli/bakery, school, senior care facility, shoe repair, grocery store, social service<br />
facility, theater.<br />
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METRIC: ACCESS TO GOODS, JOBS & SERVICES<br />
4. Proportion of households and proportion of jobs within 1/4 mile of local public transit<br />
(including both bus and rail) or 1/2 mile of a regional public transit, that has less than 15<br />
minute frequencies<br />
EVIDENCE BASE<br />
Health Impacts<br />
The greatest pedestrian “capture rate” is when transit stops are within a 10 minute walk from home<br />
or office, have frequent headways, and are close to a dedicated transit right-of-way. lxxiii<br />
Accessibility of transit to both homes and workplaces provides the opportunity for a number of<br />
different health benefits. High per capita traffic fatality rates as well as the increase of diseases related<br />
to sedentary lifestyles both contribute to the poor health outcomes and high costs of care in the<br />
U.S.. li Recent analysis by Todd Litman of the Victoria Transportation Policy Center li of the health<br />
benefits of public transportation in the U.S. found that:<br />
Current demographic and economic trends (aging population, rising fuel prices, increasing health<br />
and environmental concerns, and rising medical care costs) are increasing the value of public<br />
transportation health benefits;<br />
Inadequate physical activity contributes to numerous health problems, causing an estimated<br />
200,000 annual deaths in the U.S., and significantly increasing medical costs. Among physically<br />
able adults, average annual medical expenditures are 32 percent lower for those who achieve<br />
physical activity targets ($1,019 per year) than for those who are sedentary ($1,349 per year);<br />
Public transit reduces pollution emissions per passenger-mile, and transit-oriented development<br />
provides additional emission reductions by reducing per capita vehicle travel;<br />
Traffic casualty rates tend to decline as public transit travel increases in an area. Residents of<br />
transit-oriented communities have only about a quarter the per capita traffic fatality rate as<br />
residents of sprawled, automobile-dependent communities;<br />
Neighborhood design features that support transit, such as walkability and mixed land use, also<br />
support public health. Of people with safe places to walk within ten minutes of home, 43 percent<br />
achieve physical activity targets, compared with just 27 percent of less walkable area residents.<br />
Alternatively, the more time a person spends in a car, the less time that person has to engage in<br />
leisure time physical activity. lxxiv Each additional hour spent in a car per day is associated with a 6<br />
percent increase in the likelihood of obesity. Each additional hour walked per day is associated with a<br />
4.8 percent reduction in the likelihood of obesity. lxxv<br />
Frequency of public transit service is an important predictor of whether people use and rely on<br />
transit as an alternative to driving alone for daily trips. Shifts from driving to transit use can decrease<br />
vehicle miles traveled at a regional level - with potential health benefits including reductions in air<br />
pollution and greenhouse gas emissions as well as injuries and deaths in motor vehicle collisions. At<br />
the local level, increases in transit use and decreases in personal vehicle trips can reduce local traffic<br />
volumes and benefit local air quality, reduce traffic related noise levels, and decrease traffic hazards to<br />
pedestrians and bicyclists. Shifts to transit from driving also support increases in physical activity<br />
through walking and biking trips to get to transit, and its related benefits to physical and mental<br />
health. Safe, quality public transportation systems also support social interaction and community<br />
cohesion. lxxvi<br />
Access to public transportation is currently low. Nearly 60 percent of the U.S. population lives in<br />
major metropolitan areas of over 1 million, but only 8.3 percent of households have access to major<br />
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subway service, and over 50 percent of Americans do not live within one-quarter mile of a transit<br />
stop. lxxvii A study in Seattle showed that for every quarter mile increase in distance from a transit stop<br />
to home, the odds of taking a transit trip decreased by 16 percent. A quarter mile increase in distance<br />
from transit to work reduced the likelihood of taking transit to work by 32 percent. lxxviii<br />
* For research regarding the health impacts of access to work and thus income see Metric #9-<br />
Percent of household income consumed by housing and transportation combined.<br />
Equity Impacts<br />
While public transit use has benefits such as increased physical activity, public transit infrastructure in<br />
most US cities is not as convenient as vehicle transport, and those who do not have the option to<br />
buy a car may have a disadvantage, particularly elderly people and families with young children.<br />
Residents in low-income communities are less likely to own a car and more likely to rely on public<br />
transportation, lxxix lxxx and therefore often have longer commutes. People of color are also more likely<br />
to use transit and carpooling to get work, increasing the likelihood of longer commute times. lxxxi<br />
Costs and inaccessibility to public transit are barriers to accessing one’s workplace and other<br />
resources. Other barriers include poor sidewalk quality, no sidewalks, lack of proper signage, and<br />
absence of bus shelters or benches. As transportation expenditures continue to rise, the amount<br />
households have to spend on housing, food, health care, insurance, education, and other needs<br />
decreases. Prohibitive transportation costs can interfere with employment prospects, economic selfsufficiency,<br />
and access to needed goods and services including health care and food. Providing<br />
affordable public transportation, particularly to transit dependent and low-income communities, is<br />
one way to address these inequities in access that negatively impact health. lxxxii<br />
Of special concern also are rural communities. Two-thirds of rural Americans – 60 million people –<br />
are almost wholly not served by public transportation. lxxxiii<br />
It is therefore critical to ensure that communities not only have access to transit in order to reach<br />
jobs and needed services, but also that this transit is affordable. When modeling accessibility,<br />
different modes of public transportation, such as local buses, commuter buses, light rail and<br />
commuter rail, need to be disaggregated. When aggregated, the resulting analysis may suggest<br />
communities have access to transit that is, in actuality, high-fare and unaffordable, and rail service<br />
expansion may come at the cost of affordable local bus service.<br />
METHODOLOGY<br />
Enumerate both bus and rail public transit stops with less than 15 minute frequencies from local<br />
transit authorities; Estimate distance between stops and each household/job or intersection location.<br />
Using GIS network analysis so that true distance to transit is captured rather than “as the crow flies”<br />
will avoid underestimates of travel distance.<br />
MPOs should use their region-specific Travel Demand Models that include data on residents, jobs<br />
and transit for this performance metric and use the local transit authorities to gather information on<br />
transit frequency.<br />
RESOURCES<br />
Transit access and transit frequency methodologies:<br />
Example of transit access methodology: SFDPH-HDMT Indicator ST.2.b Proportion of households<br />
with 1/4 mile access to local bus or rail link http://www.thehdmt.org/indicators/view/52<br />
Examples of transit frequency methodologies:<br />
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MTC Appendix C: Regional Snapshot Analysis Detailed Methodology.<br />
http://www.mtc.ca.gov/planning/snapshot/Appx%20C-Detailed%20Methodology.pdf<br />
SFDPH-HDMT: Indicator ST.2.c Local transit service frequency, morning peak commute<br />
http://www.thehdmt.org/indicators/view/223<br />
OnTheMap is a tool by the U.S. Census's LEHD project that maps a number of different layers,<br />
including education, transportation and workforce categories: http://lehdmap.did.census.gov/<br />
The National TOD Database is a GIS platform that includes every fixed-guideway transit system in<br />
the U.S. and demographic and land-use data for the half-mile radius around all stations:<br />
http://toddata.cnt.org/<br />
LIMITATIONS<br />
Proximity does not necessarily equal accessibility. Lower income communities tend to rely more<br />
heavily on public transportation and modes of transportation used to access work are dependent<br />
upon numerous variables. Among many others, these may include cost, perceived and actual safety,<br />
lack of pedestrian facilities and signage, weather, pedestrian access and safety, traffic patterns,<br />
availability of bicycle lanes and racks, hours of operation, availability of parking, and availability of<br />
travel stipends/incentives provided by work or to low-income families. lxxxiv<br />
An additional concern is the aggregation of transit modes in some Travel Demand Models.<br />
Aggregating bus and train transit together assumes that low-income residents can afford to commute<br />
to jobs on high-cost transit like BART in San Francisco. As a result, when rail service increases, it is<br />
likely to show increased transit accessibility for low-income communities, and affordable bus services<br />
may be cut.<br />
STANDARDS<br />
We can look to transit-oriented design guidelines for some standards. While they do not directly<br />
address the metric of proportion of housing and jobs near transit, they can supply guidance.<br />
The Metropolitan Transportation Commission (MTC) in the Bay Area established corridor<br />
thresholds for amount of housing that would support different types of public transit in the MTC<br />
Resolution 3434 TOD policy for regional transit expansion projects. lxxxv<br />
BART 3,850 units<br />
Light Rail 3,300 units<br />
BRT 2,750 units<br />
Commuter Rail 2,200 units<br />
TOD Design Guidelines Matrix lxxxvi<br />
Average Jobs/Housing Mix<br />
Urban Core – 10 jobs per 1 dwelling unit<br />
Urban general - 5 jobs per 1 dwelling unit<br />
Mix of Uses (% residential, % non-residential)<br />
Urban Core - 20% residential and 80% non-residential<br />
Urban General – 50% residential and 50% non-residential<br />
Jobs/Acre<br />
Urban Core – 500 jobs/acre<br />
Urban General – 75-150 jobs/acre<br />
California TOD Housing Program Guidelines. lxxxvii Net density for housing:<br />
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Large city downtown:<br />
Urban center<br />
All other areas<br />
60 units per acre<br />
40 units per acre<br />
25 units per acre<br />
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METRIC: ACCESS TO GOODS, JOBS & SERVICES<br />
5. Proportion of daily trips less than 3 miles and less than 1 mile by mode<br />
(walking/biking/bus and rail transit/driving)<br />
EVIDENCE BASE<br />
Analysis of national data regarding daily travel found that half of all trips in metropolitan areas are<br />
three miles or less and 28 percent are one mile or less; in rural areas 30 percent of all trips are two<br />
miles or less. lxxxviii Yet a majority (65 percent) of one-mile trips in metropolitan areas are still made by<br />
automobile. lxxxix Research also demonstrates that proximity to public transit helps to determine travel<br />
choice. xlviii<br />
While neighborhoods characteristics shape travel mode choice, xc the “5-D factors” xci also promote<br />
transit ridership when they occur near rail transit stations. The "5 Ds" include:<br />
1) Net-Residential Density – "denser developments generate fewer vehicle-trips per dwelling<br />
unit than less dense developments";<br />
2) Job-Housing Diversity – "having residences and jobs in close proximity will reduce the<br />
vehicle-trips generated by each by allowing some trips to be made on foot or by bicycle";<br />
3) Walkable Design – "improving the walking/biking environment will result in more nonauto<br />
trips and a reduction in auto travel" (with synergistic effects with density and<br />
diversity);<br />
4) Destinations – "households situated near the regional center of activity generate fewer<br />
auto trips and vehicle-miles of travel";<br />
5) Distance to Rail Mass Transit Station – "transit ridership rates among station-area<br />
residents increase exponentially as the distance to a rail station declines. Land use and<br />
transportation planning that does not incorporate the above factors contributes to<br />
increases in miles driven in motor vehicles, along with the associated hazards from air and<br />
water pollutants, noise, and vehicle collisions. Heavy volumes of local vehicle traffic also<br />
create traffic “hotspots” and contribute to unfair burdens of air pollution, noise, and stress<br />
for those living adjacent to busy streets and highways, and degrade the environment for<br />
walking, biking, and public transit.”<br />
* Further discussion of the health and equity aspects of access to public transit and different mode<br />
share can be found in Metrics #4, 6 & 7.<br />
Equity Impacts<br />
African Americans widely report low levels of leisure time physical activity. xcii xciii While the benefits<br />
of physical activity have been discussed elsewhere in this document (see Metric #6) one outcome of<br />
low levels of physical activity is an increased rate of obesity. Racial differences in risk factors are<br />
established early; evidence from one study found that by age 4, 13 percent of Asians and 16 percent<br />
of whites were obese, compared to 21 percent of blacks, 22 percent of Hispanics and 31 percent of<br />
American Indians. xciv In women in the U.S., body weight is inversely related to socioeconomic<br />
status. xcv Multiple studies have found that the lack of recreational facilities and concerns about<br />
personal safety can discourage exercise. xcvi xcvii<br />
Although the prevalence of obesity is higher for black than for white women, obesity is more<br />
strongly related to mortality for white than for black women. xcviii xcix One study focused on assessing<br />
the challenges to maintaining a healthy weight found that transportation difficulties, physical settings<br />
offering little opportunity for physical activity, food insecurity and rural isolation were all factors<br />
contributing to obesity among rural, economically disadvantaged women. c<br />
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Another population suffering from high rates of obesity is adolescents. Approximately 50% of U.S.<br />
youth do not currently meet the public health recommendations for frequency and vigorousness of<br />
physical activity. ci cii ciii<br />
METHODOLOGY<br />
MPOs should use their region-specific Travel Demand Models to measure this metric.<br />
RESOURCES<br />
Metropolitan Transportation Commission. Planning Section. Transportation 2035 Plan For the San<br />
Francisco Bay Area Travel Forecasts. Data Summary, Table E22. Oakland, CA: MTC, December<br />
2008. p. 121-125.<br />
STANDARDS<br />
Every decade, Caltrans conducts a statewide travel survey. civ The update is in process now, but from<br />
the last survey, we can provide some benchmarks. In California, the proportion of total trips made to<br />
and from different sources is included in the following table. While not included here, the tables also<br />
report out the proportion of trips that drivers make to and from different sources, and the<br />
proportion of “person trips” taken to and from difference sources. This source also includes the<br />
breakdown by MPO region for all regions in the state.<br />
From To Percent<br />
Home Other 41%<br />
Other Other 15%<br />
Home Work 23%<br />
Home Shop 11%<br />
Work Other 10%<br />
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GENERAL TRANSPORTATION<br />
METRIC: GENERAL TRANSPORTATION<br />
6. Daily amount (in minutes) of work-trip and non-work trip related physical activity<br />
EVIDENCE BASE<br />
Health impacts<br />
Walking to work helps people meet minimum requirements for physical activity. Americans using<br />
public transit spend a median of 19 minutes daily walking to and from transit; twenty-nine percent<br />
achieve at least 30 minutes of physical activity a day by walking to and from transit. xlix However,<br />
commuting to work makes up only 15 percent of the daily travel trips people take; forty-five percent<br />
of daily trips are for shopping/errands and 27 percent are social and recreational. cv Numerous health<br />
benefits could result if individuals walk or bike during all or a portion of these trips. The benefits of<br />
physical activity include a reduced risk of premature mortality and reduced risks of coronary heart<br />
disease, hypertension, selected cancers, obesity and diabetes. cvi cvii cviii cix cx cxi Regular participation in<br />
physical activity also reduces stress, depression and anxiety, improves mood, and enhances ability to<br />
perform daily tasks throughout the life span. cxii cxiii Additionally, walking and biking as forms of<br />
transportation do not contribute to noise or air pollution emissions.<br />
Even with all the known benefits of regular physical activity, in 2003 only 53 percent of Americans<br />
achieved 30 minutes of moderately vigorous activity at least 5 days a week and approximately 23<br />
percent of Americans had no leisure-time physical activity within the past month. cxiv Physically<br />
inactive people are twice as likely to develop coronary heart disease as regularly active people and<br />
heart disease is the leading cause of death among men and women in the United States. cxv Sedentary<br />
lifestyles and inactivity can also lead to overweight/obesity. cxvi Persons who are overweight or obese<br />
are at increased risk for high blood pressure, type 2 diabetes, coronary heart disease, stroke,<br />
gallbladder disease, osteoarthritis, sleep apnea, respiratory problems and some types of cancer.<br />
Equity impacts<br />
Residents in low-income communities are less likely to own a car and rely on public transportation to<br />
a greater extent. cxvii cxviii Nationally, people of color tend to have longer commutes than the white<br />
population, with a lower share of African-Americans, Asians and Hispanics enjoying commutes<br />
under 20 minutes and a higher share of people of color having “extreme commutes” over 60<br />
minutes. cxix People of color are also more likely to use transit and carpooling to get work, increasing<br />
the likelihood of longer commute times. cxx VMT and commute times correlate with obesity and have<br />
an inverse relationship to amount of physical activity. cxxi cxxii A study of adults in Chicago found that<br />
“people of lower socioeconomic status tend to walk more frequently, but also tend to live in<br />
neighborhoods that discourage walking.” cxxiii Costs and inaccessibility to public transit are barriers to<br />
accessing one’s workplace and other resources.<br />
METHODOLOGY<br />
Because traveling between the home and work and running errands are daily events for most people,<br />
and because many adults in this country do not meet the minimum requirement for daily exercise, we<br />
support a performance metric related to the amount of physical activity people obtain during their<br />
daily travel trips.<br />
MPOs could consider using an activity-based model to calculate the amount of physical activity from<br />
daily work and non-work trips. The Metropolitan Transportation Commission in the Bay Area is<br />
developing such a process, although it is not complete yet. More information about the MTC’s<br />
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Activity-based model development is available at:<br />
http://www.mtc.ca.gov/maps_and_data/datamart/abm/.<br />
We suggest MPOs using either the American Community Survey (ACS) or the National Household<br />
Transit Survey (NHTS) (in conjunction with regional transportation surveys, if available) to calculate<br />
this metric.<br />
Using the time distribution by mode, the ACS gives the number of persons spending a threshold<br />
number of minutes it takes to get to work. Using a standard threshold (e.g., 15 minute or more),<br />
calculate the amount of physical activity for walking and bicycling, when available. The ACS is<br />
collected every 3 years on the city level.<br />
If using the NHTS, disaggregate work and non-work trips. Calculate daily duration of walking<br />
and cycling trips per capita by dividing the daily minute totals by mode by the number of<br />
persons, yielding average trip times. Both the 2001 and 2009 NHTS data contain information<br />
regarding bike and pedestrian travel modes by work and non-work trips. The NHTS is available<br />
at the state- and Metropolitan Statistical Area (MSA)-level and conducted every 5-7 years.<br />
Additional add-on samples, along with random national samples collected in the add-on area, are<br />
available for purchase and compiled into a cleaned geocoded database for ready application to<br />
local planning and forecasting.<br />
LIMITATIONS<br />
Few MPOs currently have created the capability to capture this indicator using an activity-based<br />
model.<br />
ACS Limitations: The ACS only captures trips taken to work (and not all daily travel trips). If<br />
commute trips involve more than one mode, respondents are asked to report the mode used for<br />
most of the trip distance. Also, bicycling is included with motorcycling as a mode, so the ACS cannot<br />
give an accurate estimate of physical activity from biking.<br />
NHTS Limitations: Because the NHTS is a national probability sample, the data is not very reliable at<br />
the city level. It is possible to purchase add-on data for specific metropolitan regions, which would<br />
add statistical reliability to the sample.<br />
RESOURCES<br />
Journal articles using the NHTS for transportation decision-making:<br />
http://nhts.ornl.gov/2009/pub/Compendium.pdf<br />
Example calculation of bike/pedestrian physical activity using NHTS: Pucher J, Buehler R,<br />
Merom D & Bauman A (2011). Walking and Cycling in the United States, 2001-2009: Evidence<br />
From the National Household Travel Surveys. American Journal of Public Health, 101, in press<br />
[Epub ahead of print].<br />
Example calculation of transit-associated walking times using the NHTS: Besser LM &<br />
Dannenberg AL. (2005). Walking to public transit: Steps to help meet physical activity<br />
recommendations. American Journal of Preventative Medicine, 29(4): 273–280.<br />
<br />
For more information regarding CDPH methodology (replicating the London Woodcock Active<br />
Transportation modeling), contact Neil Maizlish, PhD, MPH. California Department of Public<br />
Health at Neil.Maizlish@cdph.ca.gov<br />
STANDARDS<br />
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The Surgeon General recommends that adults engage in moderate-intensity physical activity five<br />
times per week for at least 30 minutes each time, or in vigorous-intensity physical activity three times<br />
per week for at least 20 minutes each time, in order to achieve adequate levels of physical activity. cxxiv<br />
Healthy People 2020 cxxv<br />
The U.S. Department of Health and Human Services (USDHHS) Healthy People 2020 provides<br />
science-based, 10-year national objectives for improving the health of all Americans. By 2020, the<br />
following should be achieved:<br />
Physical Activity<br />
Objective PA-2: Increase the proportion of adults who meet current Federal physical activity<br />
guidelines<br />
for aerobic physical activity of moderate intensity;<br />
Objective PA-13: Increase the proportion of trips made by walking;<br />
Objective PA-14: Increase the proportion of trips made by bicycling.<br />
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METRIC: GENERAL TRANSPORTATION<br />
7. Work and non-work trip mode share (including biking, walking, transit (bus and train),<br />
carpooling and SOV) – Both at peak times and all day<br />
EVIDENCE BASE<br />
Health Impacts<br />
Commute travel between the home and the workplace, as well as non-work related trips, is a good<br />
indicator of environmental impacts, physical activity, obesity, social cohesion, and mental health. The<br />
extent of these impacts depends on transit mode. Vehicle miles traveled are directly proportional to<br />
air pollution and greenhouse gas emissions. xlviii Air pollutants, including ozone and particulate<br />
matter, are causal factors for cardiovascular mortality and respiratory disease and other illness. cxxvi<br />
Greenhouse gases contribute to climate change, which may increase the following: heat-related illness<br />
and death, health effects related to extreme weather events, health effects related to air pollution,<br />
water-borne and food-borne diseases, and vector-borne and rodent-borne disease. cxxvii The more time<br />
a person spends in a car, the less time a person has to engage in leisure time physical activity. cxxviii<br />
Transportation choices impact obesity. Each additional hour spent in a car per day is associated with<br />
a 6 percent increase in the likelihood of obesity. Each additional hour walked per day is associated<br />
with a 4.8 percent reduction in the likelihood of obesity. cxxix<br />
Driving to work is a significant cause of stress for many people, so reduced commuting time could<br />
lead to decreased stress levels. cxxx Highway congestion has been associated with elevated blood<br />
pressure among car or bus drivers. cxxxi Some studies have looked specifically at “commute<br />
impedance,” such as traffic jams, and road construction. Researchers have concluded that traffic<br />
impedance is associated with higher blood pressure, more self-reported “tense” and “nervous”<br />
feelings, more self-reported colds and flu, and more days at the hospital. cxxxii<br />
Long commutes can distance an individual from his/her community and decrease social connectivity.<br />
Amount of time spent commuting impacts time for family and social activity. cxxxiii Social connectivity<br />
helps manage stress, and is connected with longer lifespan and access to emotional and physical<br />
resources. cxxxiv cxxxv Drivers in the Southern California region have especially long work trip travel<br />
times. For example, Los Angeles and Riverside were ranked by the U.S. Census as having the fourth<br />
and fifth highest percentages of people with “extreme” commutes of longer than 90 minutes per day<br />
(5 percent and 3 percent, respectively), cxxxvi and 20 percent of those living in the larger Los Angeles<br />
region commute more than 45 minutes each way to work. cxxxvii<br />
It is important to note that building or expanding freeways, thereby adding lane miles, has not<br />
proven to be a long-term solution to congestion. It can, in fact, exacerbate the problem by inducing<br />
travel. cxxxviii cxxxix cxl cxli cxlii<br />
The health impacts of biking and walking as modes of transportation are discussed above in Metric<br />
#6.<br />
Equity impacts<br />
The different modes of transportation used to access work, as well as other goods and services, are<br />
influenced by a number of factors including cost, distance, accessibility, perceived and actual safety,<br />
weather, pedestrian safety, traffic patterns, availability of bicycle lanes, hours of operation, availability<br />
of parking, and availability of travel reimbursement or incentives provided by work or to low-income<br />
families. cxliii Lower income, transit-dependent households who work in industries that do not have<br />
regular 9 to 5 working hours are much more vulnerable to reductions in off-peak transit service. Jobs<br />
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in the health care, retail, food and personal service, and hospitality industries, for example, have<br />
fewer educational requirements but also require odd hour commutes. These industries also tend to<br />
have less flexible working hours, making transit-dependent lower income households are more<br />
vulnerable to travel delays.<br />
Residents in low-income communities are less likely to own a car and rely on public transportation to<br />
a greater extent. lxxix People of color are more likely to use transit and carpooling to get work,<br />
increasing the likelihood of longer commute times. cxliv Costs and inaccessibility to public transit are<br />
barriers to accessing one’s workplace and other resources. Commute distance can be an indicator of<br />
travel costs: longer commutes are generally associated with higher costs of gas, vehicle wear and tear,<br />
and/or public transit fares. Low-income populations spend a higher proportion of their income on<br />
travel costs associated with commuting, and thus bear this cost burden to a greater degree.<br />
METHODOLOGY<br />
MPOs should use regional transportation surveys or region-specific travel demand models to analyze<br />
mode share. If MPOs do not have modeling capabilities, the National Household Travel Survey<br />
(NHTS) collects data on daily trips by mode.<br />
RESOURCES<br />
Monitoring & Forecasting: Forecasting pedestrian and bicycle travel demands using travel demand<br />
model and mode share/trip length data: http://www.bicyclinginfo.org/library/details.cfm?id=4461<br />
Forecasting: An M & Chen M. (2007). Estimating Nonmotorized Travel Demand. Transportation<br />
Research Record, 2002: 18-25.<br />
LIMITATIONS<br />
As mentioned above, because the NHTS is a national probability sample and the data is not very<br />
reliable at the city level. It is possible to purchase add-on data for specific metropolitan regions,<br />
which would add statistical reliability to the sample.<br />
STANDARDS<br />
Caltrans conducts a statewide travel survey once a decade. They are in the process of conducting the<br />
survey now, but using data from the 2000-2001 CA Statewide Travel Survey, we can see the weekday<br />
mode share split for the entire state. cxlv<br />
All weekday trips Commuter trips 24 hour Commuter trips<br />
7-9 am<br />
SOV trips 69% 83% 85%<br />
Driving with passengers 19% 10% 8%<br />
Public transportation 2% 3.4% 3.8%<br />
School bus 2% N/A N/A<br />
Bike 0.7% 0.7% 0.6%<br />
Walk 7% 2.6% 2.4%<br />
In 1992 when the city of San Diego was rolling out its TOD Design Guidelines, they targeted an<br />
“ambitious” 40 percent non-auto mode split goal. cxlvi<br />
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FUTURE GROWTH<br />
METRIC: FUTURE GROWTH<br />
8. Growth of population, housing, and jobs in transit priority areas<br />
a. Share of housing growth in transit priority areas, targeting measures of how many<br />
large (3-4) bedroom, senior housing, and low-income units will be built<br />
b. Proportion of projected population growth located in transit priority areas<br />
c. Proportion of projected jobs in transit priority transit areas<br />
EVIDENCE BASE<br />
Health impacts<br />
Transit-oriented development (TOD) is effective for regional reducing vehicle use and associated air<br />
pollutant emissions (including greenhouse gas) and noise, and for improving traffic safety, access to<br />
goods and services, and access to schools and jobs. Provided that local air quality and traffic collision<br />
impacts near TOD sites are mitigated, this metric is positively associated with health.<br />
Transit-oriented development can increase physical activity. cxlvii In San Francisco, transit<br />
neighborhoods had 120 percent more trips by walking or biking to work than did auto-orientated<br />
neighborhoods. Mode share for work trips by pedestrians was between 1.2 and 10.6 percent<br />
higher for the transit neighborhoods. In Los Angeles mode share for walking to work was 1.7 to<br />
24.6 percent higher in the transit neighborhoods. cxlviii<br />
A dense mix of uses, well served by mass transportation systems, can ensure access to essential<br />
goods and services while reducing vehicle miles traveled (VMT), thereby reducing environmental<br />
and health costs associated with personal vehicle trips. cxlix<br />
Transit-oriented development is generally positive for health at the regional level but local health<br />
impacts may not always be positive. Due to decreasing amounts of urban land available for infill,<br />
many of these developments are now placed close to freeways and their associated air pollution and<br />
noise. Additionally, access to public transit stops can increase local traffic, leading to an increase in<br />
risk for pedestrian and bicycle injury.<br />
Transit-oriented development areas can be associated with increased vehicles on a local level,<br />
even as it reduces vehicle miles traveled overall. Consequently, high VMT per capita leads to<br />
higher accident and injury rates associated with vehicle-vehicle, vehicle-pedestrian, and vehiclebicycle<br />
collisions. cl In addition, there are typically more pedestrians in dense TOD areas, which<br />
leads to greater risk of pedestrian collisions. cli<br />
While transit-oriented development is often associated with reduced vehicle trips and VMT<br />
regionally, it can be associated with greater air pollution locally. clii<br />
Equity impacts<br />
Increasing the share of growth in transit accessible areas can have positive or negative outcomes for<br />
low-income people and people of color, depending on the other policies in place.<br />
Positive equity impacts include:<br />
Decreased transportation costs. Building more affordable housing near transit allows more<br />
people to take advantage of the transportation cost savings provided by these locations. cliii<br />
Increased economic opportunity. As more jobs are accessible by transit, low-income workers<br />
(who may already be living in transit-rich neighborhoods) may be able to take transit to those<br />
jobs. Nationally, the number of households earning $35,000 and under is 10 percentage points<br />
higher in neighborhoods around transit than it is in the transit zones’ host regions. cliv<br />
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Negative impacts are also possible if proactive policies and planning measures are not in place:<br />
Because many transit areas have a higher share of low-income households, negative public health<br />
impacts (e.g., pedestrian injuries) could have a disproportionate affect on those families.<br />
In addition, there are significant current and historical environmental injustices related to lowincome<br />
communities and communities of color having disproportionate exposures to hazardous<br />
air quality associated with freeways, which may be perpetuated by increasing growth in places<br />
with these characteristics. clv<br />
The demand for housing near transit is equally strong amongst all income groups. clvi New<br />
development, including transit-oriented development, can lead to a risk of displacement for<br />
existing low-income populations. This can be mitigated by providing affordable housing in TOD<br />
areas clvii and by stabilizing rent prices for local small businesses.<br />
METHODOLOGY<br />
Through the SB375 Sustainable Communities Strategy process, MPOs should use their regionspecific<br />
analysis of housing, population and workforce growth in proposed transit priority areas.<br />
RESOURCES<br />
Brookings Institute Report: State of Metropolitan America – On the front lines of demographic<br />
transition<br />
http://www.brookings.edu/~/media/Files/Programs/Metro/state_of_metro_america/metro_a<br />
merica_report.pdf<br />
This report uses the Census Bureau’s Population Estimates Program. Using data from the last<br />
decennial census, more recent national surveys, and administrative records at all levels of<br />
government, the Population Estimates Program produces annual estimates of population, and its<br />
“components of change” (natural increase, domestic migration, and immigration), for all<br />
incorporated municipalities, counties, and states nationwide. The program also estimates state and<br />
county populations by age and race/ethnicity annually.<br />
http://www.census.gov/popest/topics/schedule.html<br />
ABAG (The Association of Bay Area Governments) is responsible for making long-term<br />
forecasts or population, housing, and employment for the nine-county Bay Area. These forecasts<br />
assist local governments in planning for our changing environment. ABAG produces updated<br />
forecasts every 2 years and publishes them as Projections. In recent updates, the Projections<br />
forecasts have presented a realistic assessment of growth in the region, while recognizing trends in<br />
markets and demographics, while also recognizing local policies that promote more compact<br />
infill- and transit-oriented development. http://www.abag.ca.gov/planning/currentfcst/<br />
STANDARDS<br />
See standards suggested for Metric #4.<br />
Frank & Pivo’s 1995 study on the impact of smart growth on modal shift clviii may offer useful<br />
benchmarks:<br />
Nearly all travel is done by car until residential density reached 13 persons per acre;<br />
Employment density levels greater than 75 employees per acre is necessary before there is a<br />
substantial increase in transit and pedestrian travel for work trips.<br />
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ECONOMIC<br />
METRIC: ECONOMIC<br />
9. a) Percent of household income consumed by housing and transportation combined; b)<br />
Percent of income going towards housing costs; c) Percent of income going towards<br />
transportation costs<br />
EVIDENCE BASE<br />
Health Impacts<br />
Income is one of the strongest and most consistent predictors of health in the public health research<br />
literature. clix clx As transportation and housing costs rise, the less money households have to spend on<br />
medical resources (health care and health insurance), healthy food, schooling costs, leisure activities<br />
and exercise. clxi<br />
Prevalence of obesity and Type 2 diabetes is higher among groups with the lowest levels of income<br />
and education, living in deprived areas. clxii Additionally, individuals with less income are more likely<br />
to report experiencing traumatic life events as well as the harmful psychosocial effects of<br />
neighborhood violence or disorder, residential crowding, and struggles to meet daily challenges with<br />
inadequate resources.<br />
clxiii clxiv clxv clxvi<br />
Equity Impacts<br />
The distribution of income has become increasingly concentrated among a smaller segment of people<br />
in the United States over the past decades, and the gap between the highest and lowest-earning 20<br />
percent continues to grow. clxvii Racial/ethnic inequities in income are particularly striking. In 2004, for<br />
example, the median household income was approximately $30,000 among blacks and nearly $50,000<br />
among whites. clxviii<br />
While public officials, renters, homeowners and bankers often use 30 percent of a household’s<br />
income as the benchmark of affordability, this measure omits transportation costs, which can vary<br />
significantly by neighborhood, city and region. In order to obtain affordable housing, people often<br />
live far away from work, believing they’ll save money on housing costs. However, the time and<br />
money spent on long commutes can place further stress on tight budgets. clxix In the Los Angeles<br />
metro area, 46 percent of communities would be considered affordable using the standard measure<br />
of 30 percent of income. However, this statistic drops to only 29 percent when both housing and<br />
transportation costs are considered. clxx Low-income households living in the city cores of the Bay Area<br />
and/or near transit tend to have a much lower housing and transportation costs than households<br />
living in outer areas. clxxi In neighborhoods highly susceptible to gentrification, housing and<br />
transportation costs that are disproportionately high indicate that residents are unlikely to be able to<br />
stay in the absence of supportive housing policies and may be more likely to be displaced. clxxi<br />
The lack of affordable housing constrains choices about where families and individuals live, often<br />
relegating lower-income families to the periphery and/or to substandard housing in unsafe,<br />
overcrowded neighborhoods with higher rates of poverty and fewer resources like parks, bike paths,<br />
recreation centers and other health promoting activities. clxxii This type of housing instability also has<br />
health impacts. One study found that children living in areas with higher rates of unaffordable<br />
housing tend to have worse health, more behavioral problems and lower school performance. clxxiii<br />
METHODOLOGY<br />
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The Center for Neighborhood Technology (CNT), in collaboration with the Center for Transit-<br />
Oriented Development, has devised a methodology to estimate how much households of different<br />
income levels pay for both housing and transportation (H+T). clxxiv The CNT’s Housing +<br />
Transportation Affordability Index covers most regions in California. We recommend that MPOs<br />
use the CNT’s methodology in order to measure these affordability metrics.<br />
RESOURCES<br />
CNT H+T Affordability Index: http://www.htaindex.org/index.php.<br />
LIMITATIONS<br />
While a majority of California has been analyzed by CNT's H+T Affordability Index, there are some<br />
rural areas that have not been captured. Also, data instability at the block group level make estimates<br />
at that level of specificity unreliable. Therefore we recommend that MPOs use the H+T<br />
methodology and their region-specific data, when available.<br />
STANDARDS<br />
Housing: Federal standards for housing affordability suggests no one should spend more than 30<br />
percent of household income on housing (rent and utilities). Households that spend more than 50<br />
percent of their income on their homes are classified by the National Low Income Housing Coalition<br />
as severely cost-burdened. clxix<br />
Transportation: CNT has found 18 percent of Area Median Income (AMI) to be an attainable<br />
standard for transportation affordability and have set 15 percent as a goal. clxxv<br />
Housing & Transportation: Combining the 15 percent level with the 30 percent housing affordability<br />
standard, CNT recommends that 45 percent of AMI be established as the affordability target for<br />
combined housing and transportation costs in the U.S. clxxv Page 88 of 165<br />
52
ENVIRONMENTAL POLLUTION<br />
METRIC: ENVIRONMENTAL POLLUTION<br />
c. For all daily trips, per capita miles traveled by mode (walking, biking, transit, vehicle)<br />
EVIDENCE BASE<br />
Transit mode share is an indicator of how many people are driving, driving alone, taking public<br />
transit, or using active transportation such as biking or walking.<br />
Health impacts<br />
There are a variety of negative health outcomes associated with increased amounts of driving. These<br />
include increased stress and musculoskeletal injuries as well as health outcomes associated with noise<br />
and air emissions, and a decrease in physical activity and social cohesion.<br />
For example, less driving means more time for physical activity and therefore reduced obesity<br />
rates. In a landmark study, each additional hour spent in a car was shown to be associated with a<br />
6 percent increase in the likelihood of obesity, and each additional hour walked was associated<br />
with a 4.8 percent reduction in obesity. clxxvi clxxvii VMT and commute times correlate with obesity<br />
and have an inverse relationship to amount of physical activity. clxxviii clxxix<br />
Also, time spent driving puts drivers at risk for musculoskeletal pain. People who drive more<br />
have higher odds of shoulder pain compared to those who spend less time driving. People who<br />
drive 9,000 – 18,000 annual miles are 75 percent more likely to have neck and back pain than<br />
those who travel 3,000 miles annually. clxxx<br />
Vehicle trips are a significant cause of stress for many people. clxxxi<br />
Higher VMT impacts time for family and social activity. clxxxii Social connectivity helps manage<br />
stress, and is connected with longer lifespan and access to emotional and physical resources. clxxxiii<br />
clxxxiv<br />
Building or expanding freeways in an effort to reduce time spent driving, and thereby adding lane<br />
miles, has not proven to be a long-term solution to congestion and can, in fact, exacerbate the<br />
problem by inducing travel. clxxxv clxxxvi clxxxvii clxxxviii clxxxix Transportation Demand Management<br />
strategies lead to better health outcomes than road expansions.<br />
Higher traffic volume increases the risk of pedestrian, cyclist and motorist injury and death, with<br />
pedestrians, cyclists, and motorized two-wheeled vehicle users bearing a disproportionate share<br />
of road injury burden. xlviii cxc<br />
The Environmental Protection Agency’s Greenhouse Gas (GHG) Emissions Inventory for the<br />
U.S. showed that in the 1990s GHGs from mobile sources increased 18 percent, primarily from<br />
VMT. cxci California has less coal in it’s electricity mix, so the transportation sector is the largest<br />
source of emissions; thus transportation was responsible for 38 percent of California’s GHG<br />
emissions in 2004. cxcii<br />
There are positive as well as negative health outcomes associated with use of alternative modes of<br />
transportation:<br />
Americans who use public transit get more exercise.<br />
o Public transit users spend a median of 19 minutes daily walking to and from transit; of these<br />
individuals, 29 percent achieve at least 30 minutes of physical activity a day by walking to and<br />
from transit. xlix cxciii<br />
o In fact, 16 percent of all recorded walking trips are part of transit trips, and these tend to be<br />
longer than average walking trips, according to an analysis of U.S. travel survey data. cxciv<br />
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o When comparing train commuters to car commuters, train commuters averaged 30 percent<br />
more walking, more frequently reported walking for 10 minutes or more, and were 4 times<br />
more likely to achieve 10,000 daily steps recommended for fitness and health. cxcv<br />
o Transit users average 1.05 daily miles of walking a day – ten times more than the 175 yards<br />
of walking averaged by non-transit users. cxcvi<br />
o This level of physical activity enables people to reach the Centers for Disease Control’s<br />
recommended amount of daily physical activity simply by taking public transit. cxcvii Meeting<br />
recommended levels of physical activity lowers risks for obesity, cardiovascular disease,<br />
diabetes, cancers, depression, and can increase strength for bone health. cxcviii Higher use of<br />
public transit has been shown to be beneficial for air quality and decreases greenhouse<br />
gases. cxcix<br />
More active transport increases the amount of physical activity people get. Walking and biking<br />
have direct health benefits, for example lower rates of premature mortality, heart disease,<br />
diabetes, high blood pressure, colon cancer, depression and anxiety, obesity, osteoporosis, and<br />
psychological well-being. cc<br />
Using public transportation also offers more opportunities for decreasing isolation by<br />
encouraging casual contact from unplanned social interactions. Mortality rates of socially isolated<br />
people are two or more times the rates of people with more social support. cci<br />
Increased use of car sharing has been shown to reduce vehicle travel by 47 percent and increased<br />
use of public transit, walking and cycling. ccii<br />
There are increased rates of crime near subway stations, however this increased risk as well as<br />
perception of safety can potentially be mitigated. cciii<br />
Active transport is associated with increased exposure to pedestrian or bicycle injury, but with<br />
well-designed communities, this risk can be mitigated.<br />
Equity impacts<br />
Lower income residents are less likely to own automobiles – about 26 percent of low-income<br />
households do not own a car compared to 4 percent of other households. Thus, lower-income<br />
residents are more likely to use public transportation; 5 percent of lower-income households use<br />
public transit vs. 2 percent of other households. Also, lower-income residents are more likely to walk;<br />
5 percent of lower-income households report walking to work and work-related trips vs. 3 percent<br />
for other households. cciv Those walking and biking and taking transit can gain all of the health<br />
benefits associated with those modes.<br />
Low-income households also spend a higher percentage of their income on transportation costs than<br />
high income households. ccv Car ownership can be estimated to cost a household about $5,000<br />
annually, including the costs of gas and insurance. Households that take more transit, or walk and<br />
bike, spend less than this on transportation.<br />
METHODOLOGY<br />
MPO-specific Travel Demand Models include information on per capita miles traveled by mode.<br />
RESOURCES<br />
For an example of an MPO data set and forecast of number of trips by mode by trip length, see the<br />
Bay Area’s Metropolitan Transportation Commission (MTC)’s Change in Motion analysis, available<br />
at http://www.mtc.ca.gov/planning/2035_plan/tech_data_summary_report.pdf (pg 110). This<br />
analysis gives some level of background methodology in the text portion and tables defining their<br />
performance measures for the 2009 Regional Transportation Plan: Vision 2035. Table D4 beginning<br />
on page 81 is also of interest for this metric.<br />
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STANDARDS<br />
Walking & biking<br />
The Surgeon General recommends that adults engage in moderate-intensity physical activity five<br />
times per week for at least 30 minutes each time, or in vigorous-intensity physical activity three times<br />
per week for at least 20 minutes each time, in order to achieve adequate levels of physical activity. ccvi<br />
Averages across California and in different regions are supplied here as a level at which to compare<br />
each region’s performance.<br />
CA: 0.8% of people biked to work (in SF county 1.7%, in LA county 0.6%, in Placer County<br />
0.4%)<br />
CA: 2.7% of people walked to work (in SF county 7%, in SF county 2.8%, in Placer County<br />
<br />
1.5%) ccvii<br />
Metropolitan Transportation Commission. Low-income households in the Bay Area have an<br />
average of 11 minutes per day of physical activity due to active transport currently. Non lowincome<br />
households in Bay area haveare 9 minutes per day currently.<br />
Public transit<br />
In the 2005 – 2007 American Community Survey of the U.S. Census: 5% of Californians took<br />
public transit. ccviii<br />
In 2008 in the U.S., transit participation grew between 3% – 16%. In California overall, there was<br />
a 6% increase in transit ridership in 2008, and a corresponding 5% decrease in VMT. A report<br />
about the impact of high gas prices on transit ridership suggests a “high but realistic” goal of<br />
increasing public transit ridership by 10%. ccix<br />
Vehicle Miles Traveled (VMT)<br />
According to Caltrans Data Branch, in 2005, the average VMT per capita in California counties<br />
was 5,053. ccx<br />
Rural counties had much higher VMT; in the 10 counties with highest VMT per capita had an<br />
average population of just under 23,000 people. In the 10 counties with lowest VMT per capita<br />
included Los Angeles, Orange, Santa Clara, Sacramento, and San Francisco.<br />
o Bay Area: 5,407 per capita per month<br />
o Solano: over 8,000<br />
o San Francisco: 1,752<br />
o Average for Los Angeles, Riverside, Orange: 4,858<br />
o Los Angeles: 4,034<br />
o Riverside: 5,861<br />
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METRIC: ENVIRONMENTAL POLLUTION<br />
d. Working with a local public health department, university and/or air quality<br />
management district: Estimate pre-mature mortality attributed to traffic-related ambient<br />
PM 2.5, and estimate asthma incidence and asthma exacerbations attributed to traffic<br />
related NO2.<br />
EVIDENCE BASE<br />
Health Impacts<br />
Epidemiologic studies have consistently found that proximity to high traffic density or flow results in<br />
reduced lung function and increased asthma hospitalizations, asthma symptoms, bronchitis<br />
symptoms, and medical visits. ccxi Children appear to be the most sensitive to adverse effects.<br />
California freeway studies show exposure levels approach background levels after a distance of 500<br />
feet from a freeway. ccxii Specific epidemiologic research findings include:<br />
Reduced lung function in children associated with traffic density, especially trucks, within 1,000<br />
feet and the association was strongest within 300 feet. ccxiii<br />
Increased asthma hospitalizations associated with living within 650 feet of heavy traffic and<br />
heavy truck volume. ccxiv<br />
Increased asthma symptoms with proximity to roadways, with the greatest risk within 300<br />
feet. ccxv<br />
Asthma and bronchitis symptoms in children associated with high traffic in a San Francisco Bay<br />
Area community with good overall regional air quality. ccxvi<br />
<br />
<br />
Increased medical visits in children living within 550 feet of heavy traffic in San Diego. ccxvii<br />
In a prospective study of 3399 participants in Germany, living within 150m of major roads is<br />
associated with an increased risk of coronary heart disease over time even after adjusting for<br />
individual risk factors and background air pollution. ccxviii<br />
Living in close proximity to busy roadways<br />
Children living in close proximity to busy roadways have been found to suffer from increased<br />
respiratory disease symptoms and asthma, and reduced lung function. ccxix ccxx ccxxi ccxxii ccxxiii ccxxiv ccxxv<br />
ccxxvi ccxxvii ccxxviii Studies also show higher rates of cardiovascular and respiratory disease among adults<br />
living near freeways, particularly for those living within 75 - 650 feet of heavy traffic and heavy truck<br />
volume. ccxxix ccxxx ccxxxi ccxxxii ccxxxiii Long-term exposure to traffic-related air pollution is associated with<br />
an increased risk of lung cancer, ccxxxiv and diabetics exposed to air pollution have an increased risk for<br />
heart disease. ccxxxv ccxxxvi Additionally, living in areas with high levels of air pollution is a disincentive<br />
to exercise, ccxxxvii and exercise reduces risks for heart disease, diabetes, osteoporosis, and stress-related<br />
anxiety and depression. ccxxxviii CARB recommends not locating sensitive land uses within 500 feet of a<br />
highway that has traffic in excess of 100,000 vehicles per day. ccxxxix<br />
PM 2.5 and health outcomes<br />
Motor vehicle emissions, power plants, and refineries are the predominant sources of fine particulate<br />
air pollution (PM2.5). Several large-scale studies demonstrate that increased exposure to PM2.5 is<br />
associated with detrimental cardiovascular outcomes, including increased risk of death from ischemic<br />
heart disease, higher blood pressure, and coronary artery calcification. ccxl ccxli ccxlii<br />
Research in some locations based on measurements of fine particulate matter (PM 2.5) has found<br />
that a significant share of spatial intra-urban air pollution variation in ambient levels of PM 2.5 is due<br />
to local traffic sources, ccxliii and that traffic density explains variation in local and regional PM 2.5<br />
concentrations. ccxliv ccxlv Individual epidemiological studies have linked roadway proximity or vehicle<br />
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emissions to impairments of lung function; ccxlvi asthma symptoms; ccxlvii ccxlviii ccxlix medical visits for<br />
asthma; ccl asthma prevalence and incidence; ccli cclii ccliii ccliv cclv and ischemic heart disease. cclvi cclvii<br />
Nitrogen Dioxide and health outcomes<br />
While traffic pollution comprises a diverse mix of chemicals, NO 2 is a good proxy measure for<br />
cumulative exposure. The Health Effects Institute states that a good surrogate for traffic should have<br />
the following attributes: (1) traffic should be its major source; (2) emissions vary with motor vehicle<br />
type; (3) it can be measured reasonably accurately at low concentrations, and is inexpensive; and (4) it<br />
does not have independent health effects. cclviii NO 2 can feasibly be measured at a large number of<br />
locations, and it has been widely used as a proxy for the mixture of traffic-related pollutants that vary<br />
markedly depending on distance from roadways, season, wind speed, and wind direction. cclix cclx cclxi<br />
Research from the Los Angeles region shows that ambient NO 2 within 150 meters was associated<br />
with 2.18 times the risk of new-onset asthma in children. cclxii Further research shows that there is an 8<br />
percent increased risk of asthma diagnosis with early life exposure to NO 2 (150 meters from highway<br />
and 50 meters from major road) and a 12 percent increased risk of asthma diagnosis with early life<br />
exposure to NO 2 . cclxiii<br />
Equity impacts<br />
Poorer residents and people of color are more likely to live near roadway sources of air pollution. In<br />
California, the proportion of children of color living in high traffic density blocks is inversely related<br />
to median family income, and children of color are three times more likely to live in high-traffic areas<br />
than white children. cclxiv Thus, poorer children of color are more likely to be disproportionately<br />
exposed to respiratory-disease causing emissions.<br />
METHODOLOGY<br />
Regarding premature mortality related to PM2.5: Find the population weighted average<br />
transportation-attributable PM2.5 concentration and NO 2 (either by measurement or estimate by<br />
modeling e.g., CAL3QHCR or AERMOD Dispersion model using local traffic volumes, vehicle<br />
emissions models, topography, meteorology). Estimate parcel level population as share of total area<br />
residential building volume. To find premature mortality, asthma incidence and asthma<br />
exacerbations, apply the Exposure-Response Function (ERF) to population exposure. Use California<br />
ARB consensus on PM2.5-Mortailty ERF.<br />
Regarding asthma incidence and exacerbations related to NO 2 : contact Human Impact Partners for<br />
further assistance and information. Kim Gilhuly, kim@humanimpact.org.<br />
MEASUREMENT RESOURCES/EXAMPLES<br />
<br />
<br />
<br />
SFDPH: Air Quality Measurement and Modeling:<br />
http://www.sfphes.org/HIA_Tools_Air_Quality.htm<br />
Bhatia, R & Rivard, T. (2008). Assessment and Mitigation of Air Pollutant Health Effects from<br />
Intra-urban Roadways: Guidance for Land Use Planning and Environmental Review.<br />
http://www.sfphes.org/publications/Mitigating_Roadway_AQLU_Conflicts.pdf<br />
BAAQMD 2010: Estimation of health effects as related to PM2.5.<br />
http://www.baaqmd.gov/~/media/Files/Planning and Research/Plans/2010 Clean Air<br />
Plan/Resource and Tec/Multi-Pollutant Evaluation Method Technical Document-April<br />
2010.ashx<br />
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CARB 2009: Methodology for Estimating Premature Deaths Associated with Long-term<br />
Exposure to Fine Airborne Particulate Matter in California.<br />
http://www.arb.ca.gov/research/health/pm-mort/pm-mort_final.pdf<br />
Human Impact Partners Health Impact Assessments using air modeling and health prediction<br />
methodology (both available at http://www.humanimpact.org/past-projects):<br />
- Pittsburg Railroad Ave. Specific Plan Health Impact Assessment<br />
- San Pablo Avenue Corridor<br />
SFDPH Road Pricing HIA. http://www.sfphes.org/HIA_Road_Pricing.htm<br />
Resource for NO2 and asthma incidence/exacerbations: Chen, Lisa C. (2011). A Method to<br />
estimate the cumulative impact of traffic-related pollution on childhood asthma: A meta-analysis.<br />
(Master's thesis) Berkeley: University of California, School of Public Health.<br />
For a copy of this paper, please contact Kim Gilhuly, kim@humanimpact.org<br />
STANDARDS<br />
Healthy People 2020 cclxv<br />
Respiratory Disease Objectives<br />
Reduce asthma deaths<br />
RD 1.1 Reduce asthma deaths in children under age 5 years<br />
o Baseline: There were 3.4 asthma deaths per million children under age 5 years in<br />
2007<br />
o Target: None listed; assuming target of 0 deaths for children<br />
RD 1.2 Reduce asthma deaths in people age 5 - 64 years<br />
o Baseline: There were 11 asthma deaths per million in people age 5 - 64 years in<br />
2007<br />
o Target: 6 deaths per million in children and adults age 5 - 64 years<br />
RD 1.3 Reduce asthma deaths in adults age 65 and over<br />
o Baseline: There were 43 asthma deaths per million in adults over age 65 years in<br />
2007<br />
o Target: 23 deaths per million in adults over age 65 years<br />
Reduce hospitalizations for asthma<br />
RD 2.1 Reduce asthma hospitalizations in children under age 5 years<br />
o Baseline: There were 41 asthma hospitalizations per 10,000 children under age 5<br />
years in 2007<br />
o Target: 18 asthma hospitalizations per 10,000 children under age 5 years<br />
RD 2.2 Reduce asthma hospitalizations in children and adults age 5 - 64 years<br />
o Baseline: There were 11 asthma hospitalizations per 10,000 in children and adults<br />
age 5 - 64 years in 2007<br />
o Target: 9 deaths per 10,000 in children and adults age 5 - 64 years<br />
RD 2.3 Reduce asthma hospitalizations in adults age 65 and over<br />
o Baseline: There were 25 asthma hospitalizations per 10,000 adults over age 65<br />
years in 2007<br />
o Target: 20 hospitalizations per 10,000 adults over age 65 years<br />
Reduce hospital emergency department visits for asthma<br />
RD 3.1 Reduce asthma hospitalizations in children under age 5 years<br />
o Baseline: There were 133 asthma hospitalizations per 10,000 children under age 5<br />
years in 2007<br />
o Target: 96 emergency department visits per 10,000 in children under age 5 years<br />
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RD 3.2 Reduce asthma hospitalizations in children and adults age 5 - 64 years<br />
o Baseline: There were 56 asthma hospitalizations per 10,000 children and adults<br />
age 5 – 64 years in 2007<br />
o Target: 49 emergency department visits per 10,000 in children and adults age 5 –<br />
64 years<br />
RD 3.3 Reduce asthma emergency department visits per in adults age 65 and over<br />
o Baseline: There were 21 asthma emergency department visits per 10,000 adults<br />
over age 65 years in 2007<br />
o Target: 13 emergency department visits per 10,000 in adults over age 65 years<br />
California and Federal Air Quality Standards are provided in the following table:<br />
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Source: CARB. 2007. California Ambient Air Quality Standards. California Air Resources Board. Available at<br />
http://www.arb.ca.gov/research/aaqs/aaqs2.pdf.<br />
The California Air Resource Board, Air Quality and Land Use Handbook: A Community Health<br />
Perspective ccxii provides the following recommends for locating sensitive receivers near sources of air<br />
pollution:<br />
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CARB 2005 Guidance on Preventing Air Quality—Land Use Conflicts<br />
Source of Air Pollution<br />
Air Resource’s Board Recommendations<br />
Freeways and High-<br />
Traffic Roads<br />
Distribution Centers<br />
Rail Yards<br />
Ports<br />
Refineries<br />
Chrome Platers<br />
Dry Cleaners Using<br />
Perchloro-ethylene<br />
Gasoline Dispensing<br />
Facilities<br />
Avoid siting sensitive land uses within 500 feet of a freeway, urban roads with<br />
100,000 vehicles/day, or rural roads with 50,000 vehicles/day.<br />
Avoid siting sensitive land uses within 1,000 feet of a distribution center (that<br />
accommodates more than 100 trucks per day, more than 40 trucks with operating TRUs<br />
per day, or where TRU unit operations exceed 300 hours per week).<br />
Take into account the configuration of existing distribution centers and avoid locating<br />
residences and other sensitive land uses near entry and exit points.<br />
Avoid siting sensitive land uses within 1,000 feet of a major service and maintenance rail<br />
yard.<br />
Within one mile of a rail yard, consider possible siting limitations and mitigation<br />
approaches.<br />
Consider limitations on the siting of sensitive land uses immediately downwind of ports<br />
in the most heavily impacted zones.<br />
Consult with local air districts for the latest available data on health risks associated with<br />
port emissions.<br />
Avoid siting sensitive land uses immediately downwind of petroleum refineries.<br />
Work with local air districts to determine an appropriate separation.<br />
Avoid siting sensitive land uses within 1,000 feet of a chrome plater.<br />
Avoid siting sensitive land uses within 300 feet of any dry cleaning operation. For large<br />
operations with two or more machines, provide 500 feet.<br />
Do not site sensitive land uses in the same building with perc dry cleaning operations.<br />
Avoid siting sensitive land uses within 300 feet of a large gas station (defined as a facility<br />
with a throughput of 3.6 million gallons per year or greater). A 50 foot separation is<br />
recommended for typical gas stations.<br />
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METRIC: ENVIRONMENTAL POLLUTION<br />
e. Proposed housing near busy roadways will require:<br />
a. Assessment by local air district or public health department of the need for<br />
environmental/health impact analysis when housing is proposed near (within 1,000<br />
feet) busy roadways (over 100,000 Average Annual Daily Traffic (AADT)) or other<br />
significant pollution sources (e.g., rail yards, port terminals, refineries, power plants,<br />
etc); and<br />
b. Best practice mitigation requirements by local governments when the above<br />
assessment determines that environmental quality is below standard for such<br />
proposed housing, and if such housing is determined to be safe by local air districts<br />
and public health departments with identified mitigation.<br />
For MPOs representing highly urban regions, we suggest an alternate metric due to the ongoing<br />
concern about the lack of developable land, the need for housing, and equity concerns about placing<br />
low-income residents near polluting emissions of cars and trucks.<br />
Alternate Metric 12: Working with a local public health department, university and/or air<br />
quality management district:<br />
c. Estimate the number of sensitive sites (homes, schools, daycares, parks, etc.) within<br />
1,000 feet of freeways and other major pollution sources, based on standards such as<br />
BAAQMD’s listed below (“Standards”).<br />
d. Estimate proportion of affordable housing units vs. market rate units within above<br />
identified areas.<br />
EVIDENCE BASE<br />
Health and Equity Impacts<br />
See Metric # 11 for health and equity evidence.<br />
METHODOLOGY<br />
1) The MPO should engage the local air district or public health department to assess need for<br />
environmental/health impact analysis according to protocol similar to the Bay Area’s CEQA<br />
guidelines for all development located within 1,000 feet of busy roadways (see Resources below for<br />
link to detailed methodology)<br />
2) The MPO should document whether local general plans and other policies require mitigations for<br />
housing proposed in areas with poor air quality.<br />
This metric has raised some concerns about the potential conflict between the health dangers of<br />
placing homes and other sensitive uses near busy roadways and the need and desire in urban areas of<br />
California to create infill development that is often near freeways, in particular affordable housing<br />
options. Because there has been an ongoing statewide conversation regarding this issue, an effort was<br />
made to solicit input about which indicator would be best. Many organizations and agencies that<br />
have been most involved in the statewide discussion participated in the decision on this health and<br />
equity metric. Those organizations and agencies were: the American Lung Association of California,<br />
the California Department of Public Health, the Natural Resources Defense Agency, ClimatePlan,<br />
the Bay Area Air Quality Management District, the Sacramento Air Quality Management District,<br />
Housing California, the Sacramento Council of Governments, the San Diego Association of<br />
Governments, the Los Angeles County Public Health Department, Human Impact Partners, the<br />
Environmental Health Coalition, the Coalition for Clean Air, Reconnecting America, Prevention<br />
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Institute, Public Health Law and Policy, the San Mateo County Health Systems, the Central Valley<br />
Air Quality Coalition, and East Yard Coalition for Environmental Justice.<br />
Methodology for Alternate Metric 12 also exists. The San Francisco Department of Public Health<br />
has worked closely with the Bay Area Air Quality Management District to conduct hot spot analysis<br />
in the City and County of San Francisco to guide healthy development.<br />
RESOURCES<br />
<br />
<br />
<br />
<br />
<br />
Bay Area Air Quality Management District. CEQA Guidelines. Tools and Methodology.<br />
http://www.baaqmd.gov/Divisions/Planning-and-Research/CEQA-GUIDELINES/Toolsand-Methodology.aspx<br />
Example mitigation recommendations: SFDPH HDMT (see "Policies/Design Strategies")<br />
http://www.thehdmt.org/objectives/view/55<br />
San Francisco’s Air Quality Ordinance and Frequently Asked Questions:<br />
http://www.sfphes.org/Policy_Air_Quality.htm<br />
Lepe, C. 2008. Addressing air quality related health impacts associated with siting residential<br />
development near high traffic roadways in California and the city of San Jose. Master’s Thesis,<br />
Dept. of Urban Planning. San Jose State University. For a copy of this resource email Kim<br />
Gilhuly at kim@humanimpact.org.<br />
San Francisco Department of Public Health Environmental Health: Air Quality: Assessment.<br />
Planning, Policy Development, and Regulation. Article 38 addition to San Francisco Health<br />
Code. Available at http://www.sfdph.org/dph/EH/Air/default.asp<br />
STANDARDS<br />
The Natural Resources Defense Council has compiled the following list of policies and thresholds<br />
for action regarding siting of housing near busy roadways.<br />
Geographic Scope,<br />
Agency, and Start<br />
Date<br />
Recommended<br />
Distance<br />
Threshold or Trigger Process<br />
Bay Area Air Quality<br />
Management District,<br />
2011<br />
San Francisco, Dept. of<br />
Public Health, 2008<br />
Sacramento Air Quality<br />
Management District,<br />
2011<br />
South Coast Air Quality<br />
Management District,<br />
2005<br />
1,000 ft of permitted<br />
source, a highway, or<br />
roadway w/ >10,000<br />
AADT<br />
150m of a road >100,000<br />
AADT; 100m of road<br />
>50,000 AADT; 50 m of<br />
road >10,000 AADT<br />
500 ft of roads with<br />
100,000 AADT, urban or<br />
50,000 AADT, rural<br />
“close proximity”<br />
0.3 ug/m 3 PM2.5; 10<br />
additional cases of<br />
cancer/million; >1.0<br />
non-cancer Hazard<br />
Index, chronic or acute.<br />
0.2 ug/ m 3 average<br />
annual exposure from<br />
roadway vehicles within<br />
150m buffer of sensitive<br />
receptor<br />
Increased individual<br />
cancer risk of<br />
276/million<br />
CEQA thresholds<br />
published in 2011: P10 -<br />
110 lbs/day; PM2.5 – 55<br />
CEQA requirements for<br />
screening relative to<br />
thresholds; Health<br />
Impact Assessment<br />
required if over<br />
thresholds + mitigation<br />
Health Effects Analysis<br />
and Hierarchy of<br />
Mitigations<br />
Site-specific Health Risk<br />
Assessment. Estimate<br />
cancer risk at 6 model<br />
receptors 50, 100, 200,<br />
300, 400, and 500 ft<br />
from source roadway.<br />
Report cancer risk<br />
publicly.<br />
Consider mitigations<br />
such as separating source<br />
and receptor, decreasing<br />
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Los Angeles County<br />
DRAFT General Plan<br />
2035<br />
Los Angeles City “Green<br />
Zones” under<br />
consideration by the<br />
Council for some EJ<br />
neighborhoods, 2011<br />
San Diego Air Pollution<br />
Control District (county)<br />
“Discourage”<br />
development within 500<br />
ft of freeway<br />
Select environmental<br />
justice neighborhoods in<br />
LA City<br />
None<br />
lbs/day; max increase in<br />
cancer risk 10/million;<br />
hazard index > 1.0<br />
N/A<br />
Does the proposed<br />
project affect a sensitive<br />
receptor (not defined as a<br />
residence) as determined<br />
by the environmental<br />
analyst? If so, use AAQS<br />
as guideline. 24 hr<br />
standard 35 ug/m 3. ,<br />
annual arithmetic<br />
mean12 ug/m 3<br />
CARB Statewide, 2005 500 ft of roadway California and National<br />
Ambient Air Quality<br />
Standards for PM2.5; 24<br />
hr standard 35 ug/m 3. ,<br />
annual arithmetic<br />
mean12 ug/m 3<br />
source emissions, siting,<br />
permitting and zoning<br />
policies, and capping<br />
cumulative impacts of<br />
various pollution<br />
sources.<br />
“Encourage mitigation”<br />
for sites within 1500 ft<br />
of freeway<br />
Prepare an EIR<br />
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EQUITY<br />
METRIC: EQUITY<br />
f. Measure and stratify all indicators by race/ethnicity; income; geography (neighborhood,<br />
census block or tract, or Community of Concern); age; disability.<br />
EVIDENCE BASE<br />
Health Impacts<br />
Neighborhoods are shaped by specific policies that guide development and, consequently, individual<br />
well-being. cclxvi A growing body of research demonstrates a strong relationship between health and<br />
the environments in which people live. The disproportionately high rates of heart disease, asthma,<br />
diabetes, and other chronic diseases among residents living in high-poverty neighborhoods – often<br />
disproportionately residents of color cclxvii – can be linked to many aspects of the built environment,<br />
including access to healthy foods and physical activity, quality affordable housing, and transportation<br />
options. Such cumulative inequities can have dire health outcomes. For example, African American<br />
children growing up in high-poverty urban neighborhoods (such as Harlem or Chicago’s South Side)<br />
are more likely to die or become disabled far before reaching old age; in these neighborhoods, onethird<br />
of African American girls and two-thirds of boys who reach their fifteenth birthdays do not live<br />
to celebrate their sixty-fifth. cclxviii cclxix In comparison, only 10 percent of girls and about 25 percent of<br />
boys nationwide fail to live to age sixty-five. cclxx<br />
Alameda County is an example of an area of California with large differences in placed-based health<br />
outcomes. A recent report by the Alameda Department of Public Health highlighted the ways<br />
inequities clustered in certain neighborhoods over time. cclxxi Through their research they found:<br />
Compared with a White child in the Oakland Hills, an African American born in West Oakland<br />
is 1.5 times more likely to be born premature or low birth weight and seven times more likely to<br />
be born into poverty.<br />
As a toddler, this child is 2.5 times more likely to be behind in vaccinations. By fourth grade, this<br />
child is four times less likely to read at grade level and is likely to live in a neighborhood with<br />
twice the concentration of liquor stores and more fast food outlets.<br />
As an adult, he or she will be five times more likely to be hospitalized for diabetes, twice as likely<br />
to be hospitalized for and to die of heart disease, and twice as likely to die of cancer. This person<br />
can also expect to die almost 15 years earlier than a White person born in the Oakland Hills.<br />
West Oakland residents also breathe air that contains three times more diesel particles than in<br />
the rest of the Bay area.<br />
Alameda County households earning less than $20,000 per year spend over half of their income<br />
on transportation.<br />
The United States spends more than any other nation in the world on health care. cclxxii Yet despite<br />
consistent increases in spending, health disparities among different demographic groups persist.<br />
David Satcher, former Surgeon General of the United States, stated that “Although critical to<br />
eliminating disparities, access [to health care] only accounts for 15 to 20 percent of the variation in<br />
morbidity and mortality that we see in different populations in this country.” cclxxiii In order to address<br />
the root causes that account for the other 80 to 85 percent of poor health, we must look beyond<br />
health care and health insurance and towards the policies that affect where we live, how we get to<br />
work, what we eat and the air we breath.<br />
Because each of the proposed Health & Equity metrics has the potential to affect various<br />
populations differently, and often disproportionate burdens accumulate in low-income populations<br />
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and populations of color, we recommend that disparities be specifically measured. We advocate that<br />
social equity be integrated into each performance metric, and we have built equity considerations into<br />
each of the recommended metrics within this analysis. We recommend stratification by<br />
demographics (e.g., race/ethnicity, income, age, and/or other indicators of vulnerability to health<br />
risks) as well as place-based (i.e., neighborhood) stratification within all performance metrics.<br />
METHODOLOGY<br />
Not only is it important to understand the equity dimensions of each metric, but also the cumulative<br />
impact across all the metrics. Through the Strategic Growth Council, California Department of<br />
Public Health has developed indicators of Healthy Communities. As part of that process CDPH has<br />
proposed three different composite scores that are used to demonstrate levels of equity with regard<br />
to race/ethnicity, income and place. Depending on data availability, each equity score can be applied<br />
city-, county-, or region-wide by drawing on information from census tracts and individuals. We<br />
suggest that MPOs use a similar analysis in order to stratify the proposed metrics by these equity<br />
dimensions and identify communities with high or low levels of equity.<br />
LIMITATIONS<br />
Not all data is available at the stratified level. We recommend that future data be collected so that it<br />
can be stratified to assess equity issues.<br />
RESOURCES<br />
For more information regarding CDPH methodology, contact Neil Maizlish, PhD, MPH. California<br />
Department of Public Health at Neil.Maizlish@cdph.ca.gov.<br />
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HOW TO USE THE HEALTH AND EQUITY METRICS<br />
These metrics can be used in a variety of ways to elevate the consideration of the health<br />
and equity impacts in the RTP/<strong>SCS</strong> processes going on around the state.<br />
When can I use Health and Equity Metrics?<br />
There are a variety of places in the <strong>SCS</strong> decision making process where you can request<br />
that health and equity be considered through the use of these metrics. Throughout their<br />
planning processes, MPOs invite stakeholder input:<br />
Visioning for the RTP/<strong>SCS</strong>. MPOs typically have a period of time in which<br />
they reach out to the public in a structured way to get input on what the<br />
RTP/<strong>SCS</strong> should look like. Use the health and equity metrics as a comment<br />
about how the RTP/<strong>SCS</strong> should consider these important outcomes.<br />
Performance Measures. MPOs develop a set of performance measures and<br />
then score alternative scenarios for their RTP/<strong>SCS</strong>, including transportation<br />
projects that they might fund over the next 25 years, against these measures.<br />
Suggest that MPOs incorporate the health and equity metrics as performance<br />
measures.<br />
Baseline analysis. The RTP/<strong>SCS</strong>s include an analysis of Existing Conditions.<br />
Including health and equity metrics in the Existing Conditions analysis is<br />
important because the RTP/<strong>SCS</strong>s gets updated every three years, and thus so<br />
does the Existing Conditions analysis. Evaluating the metrics regularly would<br />
serve as a way to show how each metric had changed based on the<br />
transportation projects that had been implemented.<br />
Release of the RTP/<strong>SCS</strong>. When the RTP/<strong>SCS</strong> is released publicly, the MPO<br />
will seek stakeholder and community feedback. At this time, you can evaluate<br />
what has been included and what still needs to be included, with regard to<br />
health and equity.<br />
Environmental Impact Review. When the RTP/<strong>SCS</strong> is ready, the MPO will<br />
conduct an environmental impact review of it. This is another public process<br />
with several different points for suggesting different ways to analyze prospective<br />
changes due to the proposals included in the RTP/<strong>SCS</strong>. The health and equity<br />
metrics can be evaluated as part of the environmental review process.<br />
Local planning processes. There may be ways through County<br />
Transportation Commissions or city planning agencies to also suggest the use of<br />
the health and equity metrics in evaluating individual projects. Sometimes these<br />
bodies make the decisions around dispersion of funds, and also require<br />
environmental impact analyses and community participation in planning.<br />
How can I interact with MPOs?<br />
There are many ways to interact with MPOs or other planning bodies. Every region is<br />
different, and thus the openness to public input varys. MPOs are required to accept<br />
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stakeholder input and tend to be open to doing so. They may do so through a variety of<br />
means, including:<br />
Community engagement workshops. The creation and vetting of the<br />
RTP/<strong>SCS</strong> is a long process that has many points along the way where MPOs<br />
are required to solicit stakeholder engagement. For example, in the Southern<br />
California Association of Governments’ RTP/<strong>SCS</strong> planning process, they are<br />
holding 18 community meetings in the different counties of the region to vet<br />
alternative scenarios. Go to a community engagement workshop and speak up<br />
about health and equity using these metrics.<br />
Subcommittee meetings. Many MPOs divide the work into separate<br />
committees, so researching the different subcommittees and attending their<br />
meetings is another way to suggest use of these metrics.<br />
One on one meetings with MPO staff. Finding the staff person responsible<br />
for the RTP/<strong>SCS</strong> and meeting with them about the incorporating the health<br />
and equity metrics is a powerful way to suggest use of the metrics as well as hear<br />
back about what is possible for the MPO.<br />
Meetings with MPO Board members and other decision-makers. MPO<br />
staff is very important and can shape suggestions to the Board members and<br />
subcommittees. However, ultimately the Board of the MPO will be making the<br />
final decisions, so reaching out to them is important as well. Boards have<br />
representatives from different districts and different agencies, so strategically<br />
planning with coalition members about how to reach them all is important.<br />
Comment letters. Sending in comment letters before key decisions is an<br />
effective way to advocate for inclusion of the metrics. MPOs are required, at<br />
different times, to respond to public comment.<br />
Media. A strategic way to reach decision-makers and staff is by placing stories<br />
in local or statewide media. It is not always the right strategy, as sometimes your<br />
message may not be conveyed clearly by a reporter.<br />
Who can help if I have questions?<br />
There are organizations that are engaged statewide in these discussions with MPOs, and<br />
are also connected to local public health agencies and groups in each region. These<br />
include:<br />
Climate Plan: http://www.climateplan.org/<br />
American Lung Association of California:<br />
http://www.lungusa.org/associations/states/california/<br />
Prevention Institute: http://www.preventioninstitute.org/<br />
Public Health Law and Policy: http://www.phlpnet.org/<br />
Natural Resources Defense Council: http://www.nrdc.org/<br />
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Appendix: Metrics recommended for future study<br />
Metric<br />
Population exposed to ambient<br />
noise >55dB (WHO community<br />
standard)<br />
Basic pedestrian and bicycle<br />
infrastructure<br />
Participation in RTP planning<br />
process throughout all stages.<br />
Pollutants generated by travel<br />
(CO, NOx, PM2.5, PM10, Sox,<br />
VOC, ozone, diesel emissions)<br />
Reason for exclusion and research<br />
recommendation<br />
Methodology exists to model noise exposure on a local level,<br />
however, it is resource intensiveness led to its exclusion, .<br />
MPOs should work with health experts and others to<br />
develop an efficient way to do this, as well as consider<br />
regional level noise<br />
If MPOs don’t measure this, they cannot plan for it. For this<br />
reason, we suggest that MPOs research best and most<br />
efficient practices for assessing pedestrian and bicycle<br />
infrastructure quality. It was excluded in the final version<br />
due to current resource constraints and lack of an agreedupon<br />
methodology, however models exist, such as the<br />
Pedestrian Environmental Quality Index and the Bicycle<br />
Environmental Quality Index from SFDPH.<br />
Have full participation in RTP planning processes. Potential<br />
ways of measuring this could include public documentation<br />
of notes from meetings including attendance (number and<br />
what groups/individuals attend); advocates’ scoresheets on<br />
participation in planning. This was excluded as partners<br />
recognized that this was not a “metric” but rather something<br />
that would be requested and monitored, but not written into<br />
RTP/<strong>SCS</strong>.<br />
Collecting pollutants is important. We recognize that 1. This<br />
information can be extrapolated from VMT per household<br />
and 2. MPOs do not collect this data sub-regionally. Thus it<br />
was excluded recognizing the methodological limitations<br />
currently. However, we recommend that MPOs partner<br />
with academics and other groups to investigate measuring<br />
methodologies that exist but might be time-consuming at<br />
this point, such as air quality modeling based on traffic<br />
counts for sub-regional prediction of pollutants.<br />
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cxviii Vallianatos M, Shaffer A, Gottlieb R. Transportation and food: the importance of access. Center for<br />
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cxx Pisarski, Alan. Commuting in America III: The Third National Report on Commuting Patterns and<br />
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cxxiv U.S. Department of Health and Human Services. (1996). Physical activity and health: report of the<br />
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cxxv U.S. Department of Health and Human Services. (2010). Healthy People 2020- Physical Activity<br />
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cxxix Frank L, Andresen MA, Schmid TL. Obesity relationships with community design, physical activity,<br />
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cxxx BBC. 2000. Commuting is ‘biggest stress’. Available at<br />
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cxxxiii Putnam R. 2001. Bowing alone. Simon & Schuster. New York, NY.<br />
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cxlv California Dept. of Transportation. 2003. 2000 – 2001 California Statewide Travel Survey. Weekday<br />
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cxlvi Calthorpe Associates. 1992. City of San Diego Land Guidance System. Transit-Oriented Development<br />
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ccx CalTrans Traffic Data Branch. VMT on State Highways by County. http://trafficcounts.dot.ca.gov/monthly/histdatacounty.xls.<br />
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ccxii California Air Resources Board. Air Quality and Land Use Handbook: A Community Health<br />
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ccxiv Lin S, Munsie JP, Hwang SA, Fitzgerald E, Cayo MR. Childhood asthma hospitalization and<br />
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ccxv Venn A, Lewis SA, Cooper M, Hubbard R, Britton J. Living near a main road and the risk of<br />
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2001;164:2177-2180.<br />
ccxvi Kim JJ, Smorodinsky S, Lipsett M, Singer BC, Hodgson AT, Ostro B. Traffic-related air pollution and<br />
respiratory health: East Bay Children's Respiratory Health Study. American Journal of Respiratory and<br />
Critical Care Medicine. 2004;170: 520-526.<br />
ccxvii English P, Neutra R, Scalf R, Sullivan M, Waller L, Zhu L. Examining Associations Between<br />
Childhood Asthma and Traffic Flow Using a Geographic Information System. Environmental Health<br />
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ccxviii Hoffmann B, Moebus S, Stang A, et al. Residence close to high traffic and prevalence of coronary<br />
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ccxix Brugge D, Durant J. Rioux C. 2007. Near-highway pollutants in motor vehicle exhaust: A review of<br />
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ccxx Guaderman WJ, Vora H, McConnell R, Berhane K, Gilliland F, Thomas D, Lurmann F, Avol E,<br />
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ccxxi Brunekreef B, Janssen NA, Hartog J. 1997. Air pollution from truck traffic and lung function in<br />
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ccxxii Lin S, Munsie JP, Hwang SA, Fitzgerald E, Cyo MR. 2002. Childhood asthma hospitalization and<br />
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ccxxiii Kim JJ, Smorodinsy S, Lipset M, Singer BC, Hodgson AT, Ostro B. 2004. Traffic-related air<br />
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ccxxiv McConnell RB, Yao K, Jerrett M, Lurmann F, Gilliland F, Kunzli N, Gauderman J, Avol E, Thomas<br />
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ccxxv Venn AJ, Lewis SA, Cooper M, Hubbard R, Britton J. 2001. Living near a main road and the risk of<br />
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ccxxvi English P, Neutra R, Scalf R, Sullivan M, Waller L, Zhu L. 1999. Examining associations between<br />
childhood asthma and traffic flow using a Geographic Information System. Env Health Pers<br />
107(9):761-7.<br />
ccxxvii Brauer M, Hoek G, Van Vliet P, et al. Air pollution from traffic and the development of respiratory<br />
infections and asthmatic and allergic symptoms in children. American Journal of Respiratory and<br />
Critical Care Medicine. 2002;166:1092-1098.<br />
ccxxviii B, Janssen NA, de Hartog J, Harssema H, Knape M, van Vliet P. Air pollution from truck traffic<br />
and lung function in children living near motorways. Epidemiology. 1997;8:298-303.<br />
ccxxix Lin S, Munsie JP, Hwang SA, Fitzgerald E, Cayo MR. Childhood asthma hospitalization and<br />
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ccxxx Jerrett M, Burnett RT, Ma R, Pope CA III, Krewski D, Newbold KB, (ET AL). 2005. Spatial analysis<br />
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ccxxxi Brugge, et. al. 2007, ibid.<br />
ccxxxii Kunzli N, Bridevaux PO, Liu S, Garcia-Esteban R, Schindler C, Gerbase M, Sunyer J, Keidel D,<br />
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ccxxxiii Environment and Human Health, Inc. The Harmful Effects of Vehicle Exhaust. Available at:<br />
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ccxxxiv Beelen R, Hoek G, van den Brandt PA, Goldbohm RA, Fischer P, Schouten LJ, Armstrong B,<br />
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Epidemiology 19(5):702-10.<br />
ccxxxv Zanobetti A, Schwartz J. 2002. Cardiovascular damage by airborne particles: Are diabetics more<br />
susceptible? Epidemiology 13(5):588-92.<br />
ccxxxvi O’Neill MS, Veyes A, Sarnat JA, Zanobetti A, Gold DR, Economides PA, Horton ES, Schwartz J.<br />
2007. Air pollution and inflammation in Type 2 diabetes: A mechanism for susceptibility. Environ<br />
Med 64:373-9.<br />
ccxxxvii Wen XJ, Balluz LS, Shire JD, Mokdad AH, Kohl HW. 2009. Association of self-reported leisuretime<br />
physical inactivity with particulate matter 2.5 air pollution. J Environ Health. 72(1):40-4.<br />
ccxxxviii CDC. 1999. Physical Activity At A Glance. Centers for Disease Control and Prevention. Available<br />
at http://www.cdc.gov/nccdphp/sgr/ataglan.htm.<br />
ccxxxix CARB 2005. California Environmental Protection Agency Air Resources Board Air Quality and<br />
Land Use Handbook: A Community Health Perspective. Available at<br />
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ccxl Simkhovich BZ, Kleinman MT, Kloner RA. Air Pollution and Cardiovascular Injury: Epidemiology,<br />
Toxicology, and Mechanisms. J Am Coll Cardiol. 2008;52(9):719-26.<br />
ccxli Delfino RJ, 2002. Epidemiologic evidence for asthma and exposure to air toxics: linkages between<br />
occupational, indoor, and community air pollution research. Environmental Health Perspectives,<br />
110(S4):573-589.<br />
ccxlii HEI (Health Effects Institute), 2009. "Traffic-Related Air Pollution: A Critical Review of the<br />
Literature on Emissions, Exposure, and Health Effects." Special Report #17. Available:<br />
http://pubs.healtheffects.org/view.php?id=306.<br />
ccxliii Weijers EP, Khlystov AY, Kos GPA, Erisman JW. 2004. Variability of particulate matter<br />
concentrations along roads and motorways determined by a moving measurement unit. Atmospheric<br />
Environment. 38: 2993-3002.<br />
ccxliv Ross Z, Jerrett M, Ito K, Tempalski B, Thurston GD. 2007. A land use regression for predicting fine<br />
particulate matter concentrations in the New York City region. Atmospheric Environment. 41: 2255-<br />
2269.<br />
ccxlv Moore DK, Jerrett M, Mack WJ, Kunzli N. 2007. A land use regression model for predicting ambient<br />
fine particulate matter across Los Angeles, CA. Journal of Environmental Monitoring. 9: 246-52.<br />
ccxlvi Brunekreef, B. et al. “Air pollution from truck traffic and lung function in children living near<br />
motorways.” Epidemiology. 1997; 8:298-303.<br />
ccxlvii Venn AJ, Lewis SA, Cooper M, Hubbard R, and Britton J, 2001. Living near a main road and the risk<br />
of wheezing illness in children. American Journal of Respiratory and Critical Care Medicine, 164:2177-<br />
2180.<br />
ccxlviii Lin, S. et al. “Childhood asthma hospitalization and residential exposure to state route traffic.”<br />
Environ Res. 2002;88:73-81.<br />
ccxlix Kim, J. et al. “Traffic-related air pollution and respiratory health: East Bay Children’s Respiratory<br />
Health Study.” American Journal of Respiratory and Critical Care Medicine 2004; Vol. 170. pp. 520-<br />
526<br />
ccl English P., et al. “Examining Associations Between Childhood Asthma and Traffic Flow Using a<br />
Geographic Information System.” (1999) Environmental Health Perspectives 107(9): 761-767.<br />
ccli McConnell R, Berhane K, Yao L, Jerrett M, Lurmann F, Gilliland F, Kunzli N, Gauderman J, Avol E,<br />
Thomas D, and Peter J, 2006. Traffic, susceptibility, and childhood asthma. Environmental Health<br />
Perspectives, 114:766-772.<br />
cclii Gauderman WJ, Avol E, Lurmann F, Kuenzli N, Gilliland F, Peters J, McConnell R. Childhood<br />
asthma and exposure to traffic and nitrogen dioxide. Epidemiology. 2005 Nov;16(6):737-43.<br />
ccliii Jerrett M, Shankardass K, Berhane K, Gauderman WJ, Künzli N, Avol E, Gilliland F, Lurmann F,<br />
Molitor JN, Molitor JT, Thomas DC, Peters J, McConnell R. Traffic-related air pollution and asthma<br />
onset in children: a prospective cohort study with individual exposure measurement. Environ Health<br />
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ccliv Kim JJ, Huen K, Adams S, Smorodinsky S, Hoats A, Malig B, Lipsett M, Ostro B. Residential traffic<br />
and children's respiratory health. Environ Health Perspect. 2008 Sep;116(9):1274-9.<br />
cclv McConnell R, Islam T, Shankardass K, Jerrett M, Lurmann F, Gilliland F, Gauderman J, Avol E,<br />
Kuenzli N, Yao L, Peters J, Berhane K. Childhood Incident Asthma and Traffic-Related Air Pollution<br />
at Home and School. Environ Health Perspect. 2010 Mar 22. [Epub ahead of print]<br />
cclvi Hoffmann B, Moebus S, Mohlenkamp S, Stang A, Lehmann N, Dragano N, Schmermund A,<br />
Memmesheimer M, Mann K, Erbel R, and Jockel KH, 2007. Residential exposure to traffic is<br />
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116:489-496.<br />
cclvii Hoffmann B, Moebus S, Stang A, Beck EM, Dragano N, Mohlenkamp S, Schmermund A,<br />
Memmesheimer M, Mann K, Erbel R, and Jockel KH, 2006. Residence close to high traffic and<br />
prevalence of coronary heart disease. Heinz Nixdorf RECALL Study Investigative Group. European<br />
Heart Journal, 27:2696-2702.<br />
cclviii Health Effects Institute. 2009 October. Traffic-Related Air Pollution: A Critical Review of the Literature on<br />
Emissions, Exposure, and Health Effects. Presentation to the Clean Air Act Advisory Committee in Crystal<br />
City, VA<br />
cclix Gauderman JW, Avol E, Lurmann F, Kuenzli N, Gilliland F, Peters J, McConnell R. 2005 November.<br />
"Childhood Asthma and Exposure to Traffic and Nitrogen Dioxide." Epidemiology. 16(6):737-743.<br />
cclx Jerrett M, Shankardass K, Berhane K, Gauderman WJ, Künzli N, Avol E, Gilliland F, Lurmann F,<br />
Molitor JN, Molitor JT, Thomas DC, Peters J, McConnell R. 2008 October. "Traffic-Related Air<br />
Pollution and Asthma Onset in Children: A Prospective Cohort Study with Individual Exposure<br />
Measurement." Environmental Health Perspectives. 116:10: 1433-1438.<br />
cclxi Kim JJ, Smorodinsky S, Lipsett M, Singer B, Hodgson AT, Ostro B. 2004. "Traffic-related air<br />
pollution near busy roads: the East Bay Children's Respiratory Health Study." American Journal of<br />
Respiratory and Critical Care Medicine. 170: 520-526.<br />
cclxii McConnell R, Islam T, Shankardass K, Jerrett M, Lurmann F. 2010. “Childhood Incident Asthma and<br />
Traffic-Related Air Pollution at Home and School.” Environmental Health Perspectives. 118(7): 1021 –<br />
1026.<br />
cclxiii Clark NA, Demers PA, Karr CJ, Koehoorn M, Lencar C. 2009. Effect of Early Life Exposure to Air<br />
Pollution on Development of Childhood Asthma.” Environmental Health Perspectives. 118(2): 284-290.<br />
cclxiv Gunier RB, Hertz A, Von Behren J, Reynolds P. 2003. Traffic density in California: Socioeconomic<br />
and ethnic differences among potentially exposed children. J Expo Anal Environ Epidemiol 13(3):240-<br />
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cclxv CDC. Healthy People 2020. Respiratory Diseases. Centers for Disease Control and Prevention.<br />
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cclxvi Bay Area Regional Healthy Inequities Initiative (BarHii) (2009). Healthy Planning Guide. Available at:<br />
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cclxvii U.S. Department of Health And Human Services- Office of Health Reform. (2009). Health<br />
Disparities: A case for closing the gap. Available at:<br />
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cclxviii Geronimus AT. (2001). Understanding and eliminating racial inequalities in women’s health in the<br />
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Complete Streets Coalition of Sacramento<br />
Statement of Goals<br />
Sacramento Area Council of Governments (SACOG) on the<br />
<strong>Draft</strong> Metropolitan Transportation Plan (<strong>MTP</strong>)<br />
January 9, 2012<br />
1. 20% Target for walk and bike trips: The <strong>Draft</strong> Metropolitan Transportation Plan (<strong>MTP</strong>)<br />
estimates that with the current project list, 12.1% of all non‐commute trips will be by<br />
walking or bicycling. We can do better. The plan should set a target of 20% of all trips<br />
by walking and bicycling.<br />
2. Set a timetable Complete Streets by 2024: The <strong>Draft</strong> <strong>MTP</strong> has no target for achieving<br />
Complete Streets in the Region. We think the Plan should achieve Complete Streets<br />
throughout the Region including a continuous bicycle/pedestrian network by 2024 – in<br />
the next 12 years!<br />
3. Make safety for walking and bicycling highest priority: The plan has no performance<br />
measures or targets for pedestrian or bicycle safety. We think safety for walkers and<br />
bicyclists is critical and should be integrated into all aspects of the <strong>MTP</strong> including<br />
performance measures for funding.<br />
We can do this by:<br />
• Investing sooner rather than later: By spending money now for pedestrian and bicycle<br />
infrastructure (frontloading) we can achieve the 20% or more sooner, we will all be<br />
healthier, and the air will be cleaner.<br />
• Integrating Complete Streets into all road maintenance and rehabilitation projects: By<br />
investing our road maintenance money prudently we can make many pedestrian and<br />
bicycle infrastructure improvements with minimal money. SACOG can develop a<br />
template for road rehabilitation programs that build in consideration of changes to the<br />
roadway markings – bike‐lane, pedestrian crossing markings, and even lane narrowing<br />
to achieve Complete Streets.<br />
• Learning lessons from other cities and countries: By finding out how other communities<br />
have achieved greater mode share, we can apply the lessons learned in our<br />
communities.<br />
• Tracking our progress: By keeping a score card of our improvements we can assess our<br />
progress both in infrastructure improvements and in mode change.<br />
• Planning for pedestrian and bicycle improvements: By developing, adopting and<br />
updating pedestrian and bicycle master plans in each of our Region’s jurisdictions, we<br />
can prioritize our investments to achieve Complete Streets jurisdiction by jurisdiction<br />
throughout the region.<br />
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Signed by:<br />
Argelia Leon, Policy Manager, Breathe California – Emigrant Trails<br />
Keith Roberts, Chair, Transportation, Air Quality and Climate Change Committee,<br />
Environmental Council of Sacramento<br />
Lindell Price, Resident of El Dorado County<br />
Marie Schelling, bicycle and pedestrian advocate<br />
Terry Preston, Complete Streets Coordinator, WALKSacramento<br />
Tricia Hedahl, Executive Director, Sacramento Area Bicycle Advocates<br />
Page 121 of 165
January 9, 2012<br />
Chair Peter Hill<br />
Board of Directors<br />
Sacramento Area Council of Governments (SACOG)<br />
1415 L Street Suite 300<br />
Sacramento, CA 95814<br />
Re: <strong>Draft</strong> Metropolitan Transportation Plan/Sustainable Communities Strategy 2035 (<strong>MTP</strong>/<strong>SCS</strong> 2035)<br />
Dear Chair Peter Hill and Honorable Members of the SACOG Board of Directors:<br />
Thank you for your impressive work to advance regional planning and SB 375, California’s<br />
Sustainable Communities and Climate Protection Act. Beginning with its blueprint efforts and<br />
continuing through the current implementation of SB 375, SACOG has led the state and nation with<br />
cutting-edge regional planning and transportation planning. This leadership continues with this draft<br />
<strong>MTP</strong>/<strong>SCS</strong> 2035. Its strengths include:<br />
• By growing in strategic locations, and by boosting transit service along key arterial roads and in<br />
town centers, the plan dramatically increases the portion of jobs and housing near high quality<br />
transit, by around 150% and 200% respectively. Just as importantly, the jobs-housing balance will<br />
improve in 14 out of 15 job centers, allowing more people to walk or bike to work or to meet their<br />
daily needs.<br />
• The plan achieves SACOG’s goal of “doing more with less.” This <strong>MTP</strong> has 12.5% less funding<br />
than its predecessor, but through careful spending still makes great accomplishments: bike lanes<br />
increase by 77%; transit service nearly doubles; and transit frequencies improve to 10-15 minute<br />
frequencies on many key corridors, leading to weekday ridership more than doubling and<br />
significant increases in farebox revenues.<br />
• Congestion declines for the first time in any of its <strong>MTP</strong>s, by 7%, a dramatic turnaround from<br />
the worsening congestion planned for in 2002 (58%) and 2008 (22%). The region overshoots its<br />
2020 per capita greenhouse gas reduction target and achieves its 2035 target – the highest in the<br />
state.<br />
In the spirit of further strengthening a good plan and continuing one step further down the trajectory<br />
that this <strong>MTP</strong>/<strong>SCS</strong> creates for the region, we offer the following suggestions.<br />
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I. Ensure Transportation Projects Speed Toward a Complete Network of Transportation<br />
Choices for All Users<br />
In finalizing this <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> 2035, SACOG should ensure it is doing all it can to create a<br />
complete system of active transportation and transit options. To achieve this goal, it should<br />
prioritize projects that help achieve regional goals in the early years of the plan, and align<br />
transportation project phasing with the timing of future development. Specifically, we<br />
encourage SACOG to:<br />
• Commit to adopting a Complete Streets Action Plan within two years, including a<br />
timetable and budget for completing a continuous bike/pedestrian network around the<br />
region. Just as SACOG does comprehensive regional planning for transit and for highoccupancy<br />
vehicle (HOV) lanes, we recommend that SACOG create a regional plan for a<br />
continuous and comprehensive network of bike/ped infrastructure. This plan should estimate a<br />
target completion date and a budget of funds necessary, and it should seek to have this network<br />
meet a stretch target for what percentage of all trips in 2035 would occur via active<br />
transportation. To create the Action Plan, SACOG should work with a full range of<br />
stakeholders to:<br />
o Encourage local jurisdictions to upgrade their pedestrian and bicycle master<br />
plans;<br />
o Identify high-priority active transportation improvements for local and regional<br />
circulation;<br />
o Work with local jurisdictions and other agencies to establish the desired timing<br />
for those improvements based on their location, value for regional connectivity, current<br />
and projected densities, and the location of key destinations such as schools and transit;<br />
o Identify the likely cost and funding gaps for those improvements;<br />
o Schedule regional funds to help fill funding gaps and ensure timely construction;<br />
o Identify policy shifts that could accelerate the timeline for those top priorities,<br />
such as continuing to prioritize those local bike/pedestrian circulation that will serve the<br />
most travelers (Strategy 29.1), and conducting systematic advance planning with local<br />
public works directors to ensure roadway maintenance achieves the maximum<br />
bike/pedestrian safety enhancement; and<br />
o Integrate these policies and investments into future TIPs and the next <strong>MTP</strong>/<strong>SCS</strong>,<br />
and fully analyze the health and air quality benefits of this comprehensive network.<br />
• Work with other agencies and local jurisdictions to identify and accelerate transit<br />
for high-density arterial corridors. In arterial corridors where transit service doesn’t currently<br />
exist, service would ideally begin as soon as a sufficient density of homes or jobs is built. In<br />
places where that density already exists, service should begin as soon as possible. SACOG<br />
should flag arterial corridors that currently lack this transit service or that may lack it at the<br />
time of housing or workplace construction, and then work with local jurisdictions and transit<br />
operators to find strategies and funding sources to accelerate service there. In addition, SACOG<br />
should carefully program its existing transportation funds to support transit expansion in these<br />
key corridors. SACOG assumes that new sales tax revenue will fund transit operations – an<br />
essential effort that we stand ready to support. In addition to working to secure additional funds<br />
for transit operations, in this <strong>MTP</strong> SACOG should (a) insert a strong policy commitment to<br />
support transit service at the time of development, (b) consider creating a placeholder for funds<br />
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Page 123 of 165
that would specifically deploy transit equipment in new areas of growth, and (c) program<br />
existing transportation funds strategically to support and incentivize TOD.<br />
• Work with other agencies and local jurisdictions to flag and defer or cancel any<br />
costly transit capital projects that would begin construction before the densities would<br />
justify the cost. Defer these projects until sufficient densities are present and until bus service<br />
has proven that strong ridership demand exists, as suggested by Strategy 28.9.<br />
• Work with other agencies and local jurisdictions to ensure road construction does<br />
not trigger growth outside existing urban areas. Carpool lane extensions or other road<br />
widening at the urban edge should occur later in the plan, to ensure that they are not built<br />
prematurely but only after housing or workplace construction in the corridor has created<br />
transportation demand. Premature roadway construction could induce expansionary, inefficient<br />
growth patterns at the outer fringe and have substantial negative impacts. This can and should<br />
be avoided by carefully scheduling any road construction.<br />
• Continue to improve service for transit-dependent populations. SACOG should<br />
continue its efforts to help provide mobility for transit-dependent populations, including youth,<br />
seniors, lower-income, and disabled people. New policies should commit SACOG to work with<br />
transit providers toward better service for youth, to direct early <strong>MTP</strong> funding to projects or<br />
programs that advance regional equity, and to restore transit service to low-income<br />
communities and other areas where transit-dependent populations live and work.<br />
• Commit to a full transportation project review in the next <strong>MTP</strong>/<strong>SCS</strong> similar to<br />
MTC’s Project Performance Review, which examines how each project helps achieve the<br />
region’s health, equity and environmental goals.<br />
II.<br />
Measure What Matters<br />
A strong regional plan will not only reduce greenhouse gases but improve air quality and help regions<br />
become more equitable, healthier, and more sustainable. We are grateful that this <strong>MTP</strong>/<strong>SCS</strong> forecasts<br />
the outcomes of this plan on a number of these important indicators. Yet, other important measures<br />
were not included. SACOG should improve its ability to understand the wide-ranging impacts of land<br />
use and transportation decisions as follows:<br />
• Measure the draft plan’s impact on a wider range of performance measures. We believe that<br />
this <strong>MTP</strong>/<strong>SCS</strong> will likely result in significant public benefits that have not been identified; such<br />
analyses could help SACOG communicate the benefits of the plan – and help spur its successful<br />
implementation. Letters from the Coalition on Regional Equity and a collaborative of health<br />
organizations offer details on potential performance measures to examine. These might particularly<br />
include additional analyses around active transportation and the shorter trips and nearby services<br />
that make it possible; households within 1000’ of highways; housing plus transportation costs;<br />
daily amount (in minutes) of transportation-related physical activity; and an expanded equity<br />
analysis. To the extent possible, these analyses should be conducted prior to the plan’s adoption.<br />
• Commit to monitoring a broad set of indicators during the plan’s implementation in an<br />
annual or mid-cycle State of the Region report. Before ratifying this plan, SACOG should<br />
commit to monitoring a full suite of health, equity, and environmental indicators, such as injuries to<br />
cyclists and pedestrians, jobs-housing fit, the combined cost of housing and transportation,<br />
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gentrification/displacement, air quality and respiratory illness, transportation-related physical<br />
activity; and others. This should particularly include emerging performance measures that are<br />
difficult to forecast accurately. Monitoring these indicators could bolster implementation of the<br />
many positive steps in this <strong>MTP</strong>/<strong>SCS</strong> by showing the benefits it is creating for the region.<br />
• Commit to developing additional health and equity analysis tools to use in developing the<br />
next <strong>MTP</strong>/<strong>SCS</strong>. SACOG deserves praise for committing to develop several important tools, such<br />
as one for jobs-housing fit, and should strengthen this by committing to their availability by the<br />
next <strong>MTP</strong>/<strong>SCS</strong> cycle. SACOG should work to better understand and convey its decisions’ impacts<br />
on public health such as the impact of emissions on respiratory disease and on disadvantaged<br />
people throughout the region.<br />
• Commit to developing improved natural resource data and conservation strategies for<br />
integration into the next <strong>MTP</strong>/<strong>SCS</strong>. While RUCS is an innovative and impressive program, it is<br />
focused almost exclusively on agriculture alone, and habitat and other ecosystem services do not<br />
receive the same level of analysis in the <strong>MTP</strong>/<strong>SCS</strong> or corresponding DEIR. Considering historical<br />
development trends in the Sacramento region, the Blueprint will best be adhered to with the aide of<br />
corresponding strategies and incentives for preserving the lands outside of the anticipated urban<br />
footprint. Improved data and tools are needed to inform planning decisions and efficient investment<br />
for mitigation, conservation and development.<br />
III.<br />
Use Transit Priority Area Planning As A Springboard For Advancing Regional Goals<br />
Implementing this plan should be a high priority for the region, and SACOG deserves applause for its<br />
approach to implementation. The plan identifies and studies transit priority areas (TPAs) where transitoriented<br />
development will have the greatest impact. This effort will provide SACOG staff with greater<br />
knowledge about what best promotes health, equity, and sustainability around regional transit hubs. To<br />
leverage this work, we recommend SACOG commit to:<br />
• Include experts in promoting health, equity, and sustainability on each TPA’s action<br />
planning team to help community leaders find successful strategies for key goals. These teams<br />
should include expertise in these subjects, among others: safe active transportation; affordable<br />
housing, transportation justice; gentrification / displacement avoidance; community benefits of<br />
development; ensuring nearby access to daily needs; and public health.<br />
• Ensure each TPA Action Plan addresses a full range of important issues. SACOG plans to help<br />
each neighborhood set its own goals and create an action plan to achieve it. SACOG should<br />
complement this with a checklist of issues that it asks each team to consider, created through an<br />
inclusive public process, to ensure TPAs discuss key health, equity, and sustainability issues. This<br />
checklist should be created via public input and should include:<br />
o building new affordable housing;<br />
o creating safe routes to transit for children and adults, via an active transportation inventory;<br />
o stabilizing existing renters, homeowners, and local businesses;<br />
o facilitating community benefits such as income and asset creation;<br />
o helping higher-density infill projects receive community support, thereby removing<br />
pressure to develop natural areas and farmlands; and<br />
o exploring parking pricing options to remove the costs from those who choose to not drive.<br />
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• Identify a short set of performance measures and indicators to be used during Transit<br />
Priority Area planning. These should be a subset of the overall regional performance measures<br />
mentioned in the previous section, and should particularly focus on measures that are especially<br />
relevant to neighborhood-scale planning, such as gentrification/displacement, and households<br />
within walking distance of daily needs.<br />
• Identify and share lessons learned with local officials and stakeholders around the region.<br />
• Explore resources to speed the adoption of particularly important policies. SACOG should<br />
stand ready to provide funding or staff assistance to those jurisdictions who wish to adopt essential<br />
policies and meet certain performance thresholds.<br />
We again express our appreciation and gratitude to the Board and staff. Your efforts to implement SB<br />
375 can help reduce climate change and ensure that future generations of Californians have cleaner air<br />
and water, healthier places to live, a stronger and more resilient economy; and greater opportunity for<br />
people across the economic spectrum.<br />
Sincerely,<br />
Carl Anthony and Paloma Pavel, PhD<br />
Co Directors<br />
Breakthrough Communities<br />
Marice Ashe, JD<br />
Executive Director<br />
Public Health Law & Policy<br />
Matthew Baker<br />
Habitat Director<br />
Environmental Council of Sacramento<br />
Autumn Bernstein<br />
Director<br />
ClimatePlan<br />
Kendra Bridges<br />
Land Use Policy Director<br />
Sacramento Housing Alliance<br />
Craig K. Breon<br />
Regional Climate Change Project Director<br />
Sierra Nevada Alliance<br />
Jeremy Cantor, MPH<br />
Program Manager<br />
Prevention Institute<br />
Stuart Cohen<br />
Executive Director<br />
TransForm<br />
Terry Davis<br />
Director<br />
Mother Lode Chapter Sierra Club<br />
Teri Duarte, MPH<br />
Executive Director<br />
WALKSacramento<br />
Jonathan Heller<br />
Executive Director and Co-Founder<br />
Human Impact Partners<br />
Bonnie Holmes-Gen<br />
Executive Director, Air Quality & Public Health<br />
American Lung Association in California<br />
Matthew Marsom<br />
Vice President, Public Health Policy & Advocacy<br />
Public Health Institute<br />
Jessica Meaney<br />
California Policy Manager<br />
Safe Routes to School National Partnership<br />
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Page 126 of 165
Liz O’Donoghue<br />
Director of Infrastructure and Land Use<br />
The Nature Conservancy<br />
James J. Provenzano<br />
President<br />
Clean Air Now<br />
Shamus Roller<br />
Executive Director<br />
Housing California<br />
Dan Silver<br />
Executive Director<br />
Endangered Habitats League<br />
Dave Snyder<br />
Executive Director<br />
California Bicycle Coalition<br />
Jim Stone<br />
Executive Director<br />
WalkSanDiego<br />
Ron Sundergill<br />
Sr. Director Pacific Region<br />
National Parks Conservation Association<br />
Cristina Tirado<br />
Director<br />
Center for Public Health & Climate Change<br />
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S A C R A M E N T O A R E A B I C Y C L E A D V O C A T E S<br />
January 9, 2012<br />
Sacramento Area Council of Governments<br />
SACOG Board of Directors<br />
SACOG, <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
1415 L Street, Suite 300<br />
Sacramento, CA 95814<br />
Subject: <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> 2035 and <strong>Draft</strong> EIR on <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
Dear SACOG Board of Directors and Executive Director Mike McKeever:<br />
Thank you for the opportunity to comment on both the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
and its <strong>Draft</strong> EIR. We applaud SACOG for the extraordinary effort that has<br />
gone into conducting the analyses underlying the <strong>MTP</strong>/<strong>SCS</strong> and in<br />
presenting extensive amounts of information to the public. Particularly<br />
impressive was the advance in integrating land-use and transportation<br />
planning.<br />
We appreciate that per capita funding for bike/pedestrian projects has<br />
increased by 7% since the last <strong>MTP</strong> and that many of the roadway<br />
maintenance and rehabilitation projects are to include bike and pedestrian<br />
facilities. However, we are concerned by the very small increase in<br />
bike/pedestrian mode share that is projected over the 27-yr life of the plan<br />
(e.g. non-commute bike/pedestrian mode-share increases only from 10.6%<br />
to 12.1%; see Table 5C.7). Figure 5C.6 shows that the <strong>MTP</strong>/<strong>SCS</strong> 2035 does<br />
not accelerate the growth trend of historical “bike+walk” person trips between<br />
2008 and 2035.<br />
We understand that the <strong>MTP</strong>/<strong>SCS</strong> is a forecast, not a regulatory program.<br />
The <strong>MTP</strong>/<strong>SCS</strong> stands, however, as a valuable planning and implementation<br />
tool that can have great impact on actual conditions for bicyclists and<br />
pedestrians. Additionally, it guides the nature of projects that will be funded<br />
by SACOG. We have 3 key recommendations for improving the <strong>MTP</strong>/<strong>SCS</strong><br />
2035 for bicycling in the region:<br />
1. We suggest that the <strong>MTP</strong>/<strong>SCS</strong> 2035 state an ambitious goal for<br />
bike/pedestrian mode-share of 20% for non-commute trips by 2035<br />
to reflect the broad and direct importance of non-vehicular travel options<br />
for improving community health, travel safety, air quality, energy<br />
efficiency, and overall mobility of all transportation-system users. In<br />
stating an ambitious goal for mode-share increase, the <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
should focus on planning and investing in bicycle and pedestrian<br />
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infrastructure in those communities and with the types of facilities that will result in<br />
the biggest increases in mode-share.<br />
The following strategies will help achieve a 20% non-commute bike/pedestrian<br />
mode-share by 2035:<br />
Invest in bicycle and pedestrian infrastructure as soon as possible and<br />
during the planning period to begin reaping benefits in mode-share increase<br />
as soon as possible.<br />
<br />
<br />
<br />
Set an equally aggressive goal for increasing the densities of urban land use<br />
to make bike and pedestrian travel more viable,<br />
909 12 T H STREET, SUITE 116 SACRAMENTO, CA 95814 (916) 4 44-6 600 WWW.SACBIKE.ORG<br />
Focus funded projects on communities with high mode-shift potential<br />
such as mixed-use, high-density, and transit-priority areas. For example,<br />
Environmental Justice Areas have the highest existing mode share for<br />
bicycling and walking. EJA mode share is forecast to increase at 4 times the<br />
rate of the increase in bike/pedestrian mode-share in non EJAs (Table 8.9).<br />
Therefore, roadway and bike and pedestrian projects in EJA areas should<br />
receive much higher priority for early funding.<br />
Prioritize bicycle infrastructure improvements on low-volume/low-speed<br />
roadways and streets that will be much more attractive for bicycling by a<br />
broader swath of our population than on high-speed/high-volume arterials.<br />
2. The <strong>MTP</strong>/<strong>SCS</strong> 2035 should strengthen the Policies and Supportive Strategies<br />
presented in Chapter 6 to better focus on assuring “Complete Streets” are<br />
implemented wherever possible throughout the region. We believe that most<br />
<strong>MTP</strong>/<strong>SCS</strong> funded projects should have complete street elements and follow<br />
complete street principles. Nearly all transportation projects can have positive or<br />
negative impacts on travel by foot, bike, or transit and therefore should be planned<br />
with complete-street considerations, including all surface-street projects and all<br />
maintenance and rehabilitation of surface streets. Even freeway projects that create<br />
wide interchanges with high vehicle volumes and speeds should be required to<br />
install extraordinary protections for bicyclists and pedestrians in otherwise hostile<br />
environments (for example, the Hwy 50/Watt Avenue interchange project has<br />
required special bike and pedestrian infrastructure so that bicyclists and pedestrians<br />
can get safely travel through the interchange area).<br />
Expanding Complete Streets in the region is a critical way to address the Guiding<br />
Principles of the <strong>MTP</strong>/<strong>SCS</strong>. However, Complete Streets are not the subject of any of<br />
the 31 policies (and only a few of the strategies) presented in Chapter 6 of the<br />
<strong>MTP</strong>/<strong>SCS</strong>.<br />
We recommend that SACOG better define the extent and purpose of adopting a<br />
Complete Streets policy as mentioned in Strategy 9.1 (page 6-7). Strategy 9.1<br />
supports a policy to help reduce greenhouse gas emissions. The <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
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should also recognize the many other benefits of Complete Streets such as<br />
improving community health and safety, energy efficiency, travel mobility, and air<br />
quality.<br />
We believe this is best accomplished through a stand-alone policy under the policy<br />
category of Land Use and Environmental Sustainability to address ways to greatly<br />
expand Complete Streets in the SACOG region. An expanded policy should<br />
recognize the many co-benefits of making streets safe and desirable for all<br />
travel modes. We recommend the Complete Streets policy include these<br />
specific strategies:<br />
<br />
<br />
<br />
<br />
<br />
<br />
Establish a definition for what would qualify any street to be a complete<br />
street (using multi-modal level of service estimates),<br />
Develop a goal for what proportion of a jurisdiction’s surface streets<br />
should ultimately qualify as Complete Streets (we believe this proportion<br />
should be near 100%),<br />
Establish a timetable by when local jurisdictions and the region will<br />
achieve specified proportions of making all streets complete (perhaps 50% of<br />
potential streets complete by 2025 and 100% by 2035),<br />
Develop and promote a template for local jurisdictions to use in<br />
considering how to make any surface street into a Complete Street, either<br />
during construction or as part of maintenance and rehabilitation,<br />
Offer incentives, both technical and financial, to encourage local<br />
jurisdictions to upgrade their surface streets into Complete Streets, and<br />
Review and comment on transportation project designs to enhance their<br />
complete-street qualifications.<br />
1. The <strong>MTP</strong>/<strong>SCS</strong> 2035 should invest in planning and implementing continuous<br />
and direct bike networks between key destinations to promote local circulation<br />
within Community Types that have greater land-use densities. Because of higher<br />
densities, the Center, Corridor, and Established Community Types have the greatest<br />
potentials for substantial increases in bike mode share.<br />
Much of Policy 29 (in Chapter 6) encompasses strategies to invest in connectivity for<br />
local and regional circulation. We recommend that an additional strategy be<br />
adopted to support Policy 29 that aims to define how a bike network for local<br />
circulation can qualify as safe, comfortable, continuous, and direct for<br />
potential bike riders of all ages and abilities.<br />
Bike networks are safe and desirable for riders of all ages and capabilities (from<br />
school children to grandparents) when they consist of bikeways that have low traffic<br />
volumes and speeds and are continuous and direct between key destinations. Such<br />
networks can be comprised of combinations of Class I paths, Class II lanes, and<br />
Class III routes but they also have special protection for bicyclists when crossing<br />
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high speed/high volume arterials or other barriers and have signage to direct riders<br />
to their intended destinations. Facilities such as protected/painted bike lanes, cycle<br />
tracks, bike boxes (for left turns and congested intersections), and special<br />
signalization may also be needed.<br />
Key destinations include residential neighborhoods, schools, shopping and dining<br />
areas, community centers and parks, as well as job concentrations. Comfortably<br />
bike-able key destinations will typically be within distances easily traveled on a 30-<br />
minute bike ride (about 3-5 miles) for most people.<br />
For example, continuous and direct bikeways do not currently exist between the<br />
inner “Park” neighborhoods of Sacramento and the downtown core of commercial<br />
and government offices, a distance of about 3 miles. Although current bike facilities<br />
are a gradually expanding, they are typically a patchwork of bike lanes and Class 3<br />
routes and often these bikeways are interrupted by high volume/speed arterials<br />
without adequate protection for bicyclists and pedestrians to cross them. Even<br />
arterials with bike lanes may not feel safe for bicyclists if a high speed differential<br />
exists between vehicles and bicyclists.<br />
In addition to our three key requests discussed above, we have these specific questions<br />
and comments:<br />
1) <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> page 4-6, 1 st paragraph:<br />
Please discuss why only 5 percent of “maintenance and rehabilitation” projects is spent<br />
on bicycle and pedestrian facilities. We believe every roadway maintenance and<br />
rehabilitation project should consider what measures and features can make the<br />
roadway safer for bicyclists and pedestrians.<br />
2) <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> page 4-7, 1 st paragraph:<br />
Please state the criteria for defining Complete Streets and discuss why only 33% of<br />
<strong>MTP</strong>/<strong>SCS</strong> projects qualify as Complete Streets.<br />
3) <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> page 5C-29, Table 5C.6:<br />
Please explain the lack of increase in commute mode share for carpools between 2008<br />
and 2035, even with the huge investments in carpool lanes shown in Table 4.2.<br />
4) <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> page 10-17, 3 rd paragraph:<br />
We request that the <strong>MTP</strong>/<strong>SCS</strong> 2035 provide more safety performance measures and<br />
information for bicyclists and pedestrians because vehicle collisions with such travelers<br />
have much higher risk of fatality. Specifically, these collision, fatality, and injury data<br />
should be reported per capita and disaggregated by mode and type of street or roadway<br />
of occurrence (e.g. high speed arterial, local street).<br />
5) DEIR page 16-60 in Chapter 16 – Transportation, 1 st paragraph:<br />
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The first paragraph lists ways that roadway projects may interfere with the bicycle or<br />
pedestrian system. The first bullet should be modified to state (added text underlined):<br />
“Roadway improvement projects or land use changes which result in higher vehicle<br />
volumes or speeds adjacent to Class 1 paths or Class 2 lanes, or on Class 3 routes.”<br />
The second bullet should similarly be modified to mention Class 3 routes (which do not<br />
have painted lanes but sometimes signage, sharrows, or other markings on roadway).<br />
Thank you for the opportunity to comment on the draft <strong>MTP</strong>/<strong>SCS</strong> 2035. We look forward<br />
to further progress with this process and again commend SACOG, its officers, and staff<br />
for their attention and hard work in making the Sacramento region a safe and desirable<br />
place to live, work, and play.<br />
SABA works to ensure that bicycling is safe, convenient, and desirable for everyday<br />
transportation. Bicycling is the healthiest, cleanest, cheapest, quietest, most energy<br />
efficient, and least congesting form of transportation<br />
Sincerely,<br />
Tricia Hedahl<br />
Executive Director<br />
CC:<br />
Kacey Lizon, SACOG Senior Planner<br />
Lacey Symons-Holtzen, SACOG Assistant Planner<br />
Page 132 of 165
Attachment: Specific <strong>Comments</strong> about <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
Chapter 6 “Policies and Supportive Strategies”<br />
Strategy 2.1: Providing computer software and technical assistance should include<br />
tools for estimating and projecting Multi-Modal Level of Service for complete-street<br />
improvements.<br />
Strategy 2.3: Monitoring and reporting commute patterns should cover all modes of<br />
transportation.<br />
Strategy 2.7: Assessment of transportation projects should ensure full provision of<br />
Complete Streets features.<br />
Strategy 3.5: Providing connections for bicyclists and pedestrians should address<br />
connections across freeways and high speed/high volume arterials in addition to gated<br />
communities, walls, and cul-de-sacs.<br />
Strategy 3.7: Travel modeling studies should be shared with active transportation<br />
groups in addition to local governments and air districts.<br />
Policy 17: “Preservation of the existing road and highway system as top priority for local<br />
public works agencies and Caltrans” must acknowledge that it is also high priority that<br />
that system be modified and enhanced to provide complete-street features to serve all<br />
transportation modes throughout the system.<br />
Strategy 19.2: Supporting seamless trips should also address the “last mile problem” by<br />
providing bicycle improvements such as bike-share programs, directional signage, and<br />
bike storage facilities.<br />
Strategy 20.1: Improving transit access should include providing designated bike routes<br />
and signage around transit stops.<br />
Policy 22: Supporting “proactive and innovative education and transportation demand<br />
management” should include 1) a strategy to consider congestion pricing and parking<br />
management, and 2) a strategy to support active transportation groups in producing<br />
bicycle-route maps, delivering pedestrian and bicycling education, and in completing the<br />
bikeway network.<br />
Policy 24: Outreach to low income and minority communities must include a strategy<br />
that sets a high priority on establishing continuous and direct bicycle networks to key<br />
destinations in Environmental Justice Areas because these communities currently use<br />
active transportation modes at a much higher rate than other communities and will<br />
respond with the greatest increases in bike mode share if adequate facilities exist.<br />
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Policy 26: “Providing additional capacity for local and regional traffic on major arterials”<br />
must ensure that mobility for bicyclists and pedestrians on such arterials is enhanced<br />
and that barriers to biking and walking are not created.<br />
Strategy 29.2: The word “eventual” modifying “creation of a regional bicycle and<br />
pedestrian network” must be replaced by the word “rapid” to demonstrate the high<br />
priority, front-loaded necessity of investing in this network, especially in Environmental<br />
Justice Areas, not just where good local circulation networks already exist.<br />
Policy 30: Giving primary priority to “road expansion” violates the <strong>MTP</strong>/<strong>SCS</strong> Guiding<br />
Principle of Equity and Choice (i.e. provide real, viable travel choices for all people . . .).<br />
Instead this policy should state that selective road expansions will be considered if they<br />
enhance Complete Streets infrastructure and enhance mobility options for all<br />
transportation modes. As stated, this policy encourages single-occupancy vehicle<br />
travel.<br />
Page 134 of 165
January 9, 2011<br />
Sacramento Area Council of Governments<br />
Board of Directors and staff<br />
1415 L Street, Suite 300<br />
Sacramento, CA 95814<br />
Re:<br />
<strong>Draft</strong> Metropolitan Transportation Plan/Sustain<br />
nable Communities Strategy 2035<br />
Update<br />
Dear SACOG Board<br />
of Directors and staff:<br />
WALKSacramento is<br />
pleased to<br />
comment<br />
on the October 27, 2011 draft Metropolitan<br />
Transportation Plan/ /Sustainable Communities Strategy 2035 Update. The<br />
more we read<br />
and delvee into the draft <strong>MTP</strong> and its appendices, the more we appreciate the breadth<br />
and<br />
depth of the work of SACOG’s dedicated staff.<br />
We commend SACOG for its intention to increase thee level of pedestrian and bicycle<br />
infrastructure in the region with its commitment to fund $2.8 billion in new bicycle and<br />
pedestrian projects or 7.9% of <strong>MTP</strong> investments. Ass well, the draft <strong>MTP</strong> anticipates<br />
Completee Street features will be<br />
as much as 16% of its investments in Road Capital &<br />
Operations Projects.<br />
This would bring the<br />
region’s overall percentage of regional<br />
investment in pedestrian and bicycle improvements over the next 23 years<br />
to as high as<br />
11.3% of total funds. Truly SACOG is leading the nation.<br />
We offer several recommendations for strengtheningg the <strong>MTP</strong>’s<br />
provision for Complete<br />
Streets to<br />
support increased walking and bicycling in this letter and in our attached<br />
comments and recommendations on the specific provisions of the <strong>MTP</strong> and its key<br />
appendices.<br />
We have participated<br />
in the collaborative work of Climate Plan and Human<br />
Impact<br />
Partnership helping to craft their recommendations related to walking, bicycling and health.<br />
We support the thorough review<br />
and recommendations of both of these efforts.<br />
WALKSacramento began its existence as part of the Lung Association of Sacramento<br />
Immigrant Trails’ involvement in<br />
the 1997 <strong>MTP</strong> planning process. At that time walking<br />
was<br />
largely ignored by transportation planners both at thee local and regional level. We believed<br />
then that the provision of safety<br />
for pedestrians wouldd go a long<br />
way toward addressing<br />
some of the region’s<br />
transportation needs.<br />
We are pleased thatt what was true in 1997 is no longer true. SACOG and<br />
the region’s<br />
cities and<br />
counties recognize the needs of<br />
pedestrians and bicyclists – and<br />
the needs<br />
of a<br />
diverse population of young and<br />
old, able bodied andd disabled. However, while the<br />
policies are there, particularly in<br />
our most urban areas, there are<br />
still many, many<br />
Page 135 of 165
oadways that are unsafe for both pedestrians and bicyclists. This hinders our freedom to<br />
get to nearby destinations on foot and bicycle; it limits our ability to take transit; it limits our<br />
ability to reduce VMT by substituting walking and bicycling trips for vehicle trips; and it<br />
handicaps our ability to support our health by incorporating physical activity into our daily<br />
lives.<br />
Now more than ever it is critical to plan and implement transportation projects that support<br />
walking and bicycling – for all ages. To strengthen the <strong>MTP</strong>’s provision for walking and<br />
bicycling we recommend the following:<br />
1. Set Timetable for Achieving Complete Streets<br />
SACOG’s draft <strong>MTP</strong> lacks an overall goal of completing the system for walking and<br />
bicycling. We urge that the <strong>MTP</strong> include such a goal of Complete Streets by 2024.<br />
The <strong>MTP</strong> does not compare funding for bicycles and pedestrians with what is needed to<br />
achieve a complete system including a continuous bicycle / pedestrian network. The plan<br />
does not achieve Complete Streets throughout the region even within the life of the plan<br />
(25 years).<br />
A complete system for bicycles and pedestrians would allow a significantly greater<br />
proportion of the population to utilize “active transportation” to obtain physical activity on a<br />
daily basis for both utilitarian and recreational trips. From a public health perspective, this<br />
is critical, because the most common causes of chronic illness and death today are related<br />
to widespread physical inactivity. The high cost of health care today is due in part to the<br />
increasing numbers of people requiring medical treatment for conditions that could be<br />
alleviated with regular exercise.<br />
Replacement of shorter trips (less than three miles) with walking and bicycling would also<br />
reduce emissions of air pollutants, especially given that the shorter vehicle trips are the<br />
most polluting, mile per mile. The Sacramento Valley air basin is one of the most top ten<br />
polluted in the nation, causing elevated rates of asthma and other conditions related to<br />
high concentrations of ozone and particulate matter. Vehicles are the primary source<br />
(about 70%) of these air pollutants.<br />
Why 12 years? Twelve years is three more <strong>MTP</strong> cycles. During the first plan cycle,<br />
SACOG’s cities and counties could develop or update their bicycle and pedestrian master<br />
plans. The next two cycles would provide for plan implementation. By spending money<br />
now for pedestrian and bicycle infrastructure (frontloading) we can achieve higher levels of<br />
walking and bicycling, we will all be healthier, and the air will be cleaner.<br />
We realize that SACOG and the region’s cities and counties are at the end of a<br />
deliberative process and that a major shift in focus may not be possible with this <strong>MTP</strong>.<br />
That said, we do believe it is possible to make changes that will assure that we move at a<br />
reasonable and accelerated pace to achieve Complete Streets – Safe Routes For All on<br />
our major roadways. We think this can be accomplished by adopting the concept of a<br />
“Plan for a Plan” – a plan to create a plan to achieve Complete Streets. We urge that<br />
SACOG’s include its intention to do this work as part of this <strong>MTP</strong> and its work-plan for the<br />
909 12 th Street, Suite 122, Sacramento, CA 95814<br />
(916) 446-9255 / www.walksacramento.org<br />
Page 136 of 165
next four years so that the next <strong>MTP</strong> will include the implementation strategies to achieve<br />
the Complete Streets in the Region.<br />
2. Establish a 20% target for all non-commute walk and bike trips.<br />
Of all trips in the region, most (80%) are for reasons other than the commute to work and<br />
most of those are relatively short distances. The plan estimates that with the current<br />
project list, by 2035, 12.1% of all non-commute trips will be by walking or bicycling. This is<br />
a very modest 14% increase from the current (2008) 10.6% share by walking and<br />
bicycling. This compares with the draft <strong>MTP</strong>’s estimate of a transit mode share increase<br />
from .8% to 1.8% or a more than 125% increase. (The transit commute mode share<br />
increase is estimated at 193%.) A stretch goal for walking and bicycling should be<br />
included with this plan as well.<br />
We recommend a “stretch” target of 20% of all non-commute trips by walking and<br />
bicycling, including walking and bicycle to transit. We believe this target could be<br />
achievable through incorporating provision for walking and bicycling into SACOG’s funding<br />
policies and funding programs.<br />
We offer additional suggestions for accomplishing this in our comments on the <strong>MTP</strong>’s<br />
specific provisions (Attachment 1).<br />
3. Integrate Complete Streets into road maintenance and rehabilitation projects<br />
We appreciate the extensive work SACOG staff has accomplished “doing more with less”<br />
in these difficult economic times. Integrating consideration for Complete Streets into road<br />
maintenance and rehabilitation projects is another way to achieve “more with less”. Many<br />
pedestrian and bicycle infrastructure improvements such as improved street markings can<br />
be incorporated with minimal funds into ongoing maintenance and rehabilitation.<br />
Adding bike-lane markings on streets as a part of rehabilitation is one example. Many<br />
streets have overly wide lanes which if narrowed can provide room for bike-lanes.<br />
Another important example is providing marked crosswalks at both signalized and nonsignalized<br />
intersections. Many marked crosswalks were removed in the 1970’s and 1980’s<br />
particularly at un-signalized intersections as a result of limited research that led to the<br />
conclusion that marked crosswalks give pedestrians a false sense of security. New<br />
research has provided much sounder basis for how to mark uncontrolled intersections to<br />
provide the pedestrian greater safety and the driver greater knowledge of the presence of<br />
pedestrians. Using this new research, traffic engineers can assess their intersections to<br />
determine the most effective treatments for providing pedestrian accessibility and safety. If<br />
done in advance of road rehabilitation, these striping treatments can be incorporated into<br />
the rehabilitation work with minimal additional cost.<br />
SACOG working with its member jurisdictions can develop a template for “best practices”<br />
road rehabilitation programs that build in time for evaluating, planning and engineering for<br />
changes to the roadway markings – bike-lane, pedestrian crossing markings, and even<br />
lane narrowing to achieve Complete Streets. This is a very cost-effective way to increase<br />
the miles of Complete Streets.<br />
909 12 th Street, Suite 122, Sacramento, CA 95814<br />
(916) 446-9255 / www.walksacramento.org<br />
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4. Incorporate specific pedestrian and bicycle projects in the <strong>MTP</strong>’s transportation<br />
project list.<br />
The <strong>MTP</strong>’s Project List is largely vehicle and transit related. That gives the impression to<br />
many that projects that serve pedestrian and bicycle modes are not included. While it is<br />
noted in the plan that a significant portion of SACOG’s funds will be spent on pedestrian<br />
and bicycle projects, it is a separate funding process.<br />
We recommend that each jurisdiction identify its high priority bicycle-pedestrian projects<br />
just as it does for its other projects as part of the project identification stage. This will allow<br />
the community to know what the jurisdiction’s priorities for pedestrian and bicycle<br />
improvements are in the context of its other transportation priorities.<br />
In hindsight we realize that one of the most critical steps in the <strong>MTP</strong>’s development is the<br />
determination of what projects will be included in the final plan. We urge that this step be<br />
made more explicit in the outreach process so that citizens can make their project<br />
recommendations along with their scenario recommendations.<br />
Additionally, the <strong>MTP</strong> project list is large and difficult to review. It would be helpful if it<br />
were divided into county subsets with information included to identify which projects will<br />
add to Complete Streets.<br />
5. Set performance measures for pedestrian and bicycle safety and health<br />
outcomes associated with transportation-related physical activity.<br />
The plan has no performance measures or targets for pedestrian or bicycle safety. Safety<br />
for walkers and bicyclists is critical and should be integrated into all aspects of the <strong>MTP</strong><br />
including performance measures for funding. Consider utilizing the safety metrics in the<br />
SB375 Health and Equity Metrics developed by Human Impact Partners<br />
(www.humanimpact.org)<br />
Potential health outcome performance measures could include:<br />
• Increase the average daily time walking or biking per person for transportation by 60%<br />
(for an average of 15 minutes per person per day). Note that this includes time walking<br />
to transit (not noted in other transportation statistics).<br />
• Improvements in population health status that could be made with the adoption of a<br />
complete system for walking and bicycling.<br />
6. Incorporate the promotion of walking and bicycling into the greenhouse gas<br />
reduction strategies<br />
The transportation sector is the biggest contributor overall to GHG emissions, yet the plan<br />
does not incorporate strategies to increase to replace car trips with walking and bicycling<br />
for the short trips. A significant increase in walking and bicycling trips may enable the<br />
achievement of a further reduction in total GHG emissions.<br />
909 12 th Street, Suite 122, Sacramento, CA 95814<br />
(916) 446-9255 / www.walksacramento.org<br />
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We appreciate working with SACOG, its staff and elected leaders, on this latest <strong>MTP</strong> and<br />
new Sustainable Communities Strategy. Thank you for your consideration of our<br />
comments.<br />
Sincerely,<br />
Teri Duarte, MPH<br />
Executive Director<br />
Anne Geraghty<br />
Policy Consultant<br />
909 12 th Street, Suite 122, Sacramento, CA 95814<br />
(916) 446-9255 / www.walksacramento.org<br />
Page 139 of 165
Attachment 1 – January 9, 2011<br />
WALKSacramento’<br />
’s comments on the specific provisions of the<br />
2011 <strong>Draft</strong> SACOG Metropolitan Transportation Plan/Sustainable<br />
Communities<br />
Strategy<br />
2035 Update<br />
Chapter 1 – Introduction<br />
n: Building a Sustainable<br />
System<br />
The 20111 <strong>Draft</strong> <strong>MTP</strong>‐SCuse, performance‐based planning that began a decade ago. WALKSacramento has<br />
participated in the process of this evolution since SACOG’s Transportation Roundtable of 2002.<br />
SACOG is<br />
to be commended for the steady progress toward this integration including the<br />
is a milestone in SACOG’s progress toward integrated transportation<br />
and land<br />
improved<br />
outcomes of this plan.<br />
The summary providedd in this chapter illustrates how SACOG,<br />
step by step, has developed incremental and<br />
significant improvements to the plan, most<br />
notably the Blueprint approach and most recently the Rural‐Urban Connections<br />
Strategy and SB<br />
375.<br />
• We urge thatt SACOG’s next area of focus should be on Complete Streets. We ask that<br />
SACOG to develop a Complete Streets focus for the next plan<br />
iteration by developing<br />
and implementing a work‐plan that focuses on how Complete Streets can be achieved in<br />
our region and how this will improve<br />
the region’ s economic and environmental<br />
sustainability.<br />
Chapter 2 – Planning Process<br />
This chapter outlines<br />
the reasons for preparing a <strong>MTP</strong> ncluding to assure the region’s eligibility<br />
to receive federal transportationn funds. Any<br />
project that would receive federal funding must be<br />
included in the project list of the<br />
<strong>MTP</strong>. The deadline of April 2012 iss mandated by SB 375.<br />
WALKSacramento has a seat on the SACOG Bike/Ped Advisory Committee and has worked<br />
informally with SACOG staff as part of the Complete Streets Coalition. WALKSacramento<br />
participated with the<br />
Safe Routes for All Coalition in thee nine region‐wide workshops in October<br />
2010 on the draft scenarios. We<br />
advocated for a “4 th Scenario” thatt would support completing<br />
the bicycle – pedestrian network. At several of the workshops, participants supported even<br />
greater emphasis on walking and<br />
bicycling beyond the most intensive 3 rd scenario. Anecdotally,<br />
it appeared that there was a region‐wide desire by mostt participants no matter<br />
which scenario<br />
they favored that walkable and bikable communities be incorporated into all scenarios.<br />
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We note that the work to develop the project list was primarily a SACOG‐local government staff<br />
to staff process with little public input. In the future, greater involvement of the public in the<br />
development of the project list would lead to a greater likelihood that the project list reflects<br />
the true desires of the community.<br />
Chapter 6 – Policies and Supportive Strategies<br />
This chapter provides the policy framework that supports the <strong>MTP</strong> beginning with the <strong>MTP</strong>’s Six<br />
Guiding Principles adopted by the SACOG Board of Directors in 2005:<br />
1. Smart Land use<br />
2. Environmental Quality and Sustainability<br />
3. Financial Stewardship<br />
4. Economic Vitality<br />
5. Access and Mobility<br />
6. Equity and Choice<br />
Thirty‐one policies are grouped under 4 policy/strategy areas:<br />
1. Land Use and Environmental Sustainability Policies and Strategies (1‐10)<br />
2. Finance Policies and Strategies (11‐16)<br />
3. System Maintenance & Operations Policies and Strategies (17‐26)<br />
4. System Expansion Policies and Strategies (27 – 31)<br />
The chapter outlines the existing adopted policies and strategies of the prior plan and targeted<br />
modifications “to reflect new projects, research, and conditions since the last <strong>MTP</strong>, such as the,<br />
Rural‐Urban Connections Strategy (RUCS) and Lifeline Transit Study.” Additionally changes<br />
necessitated by SB 375 including requirements to “open a path for qualifying residential/mixeduse<br />
projects to use the CEQA streamlining benefits” of SB 375 are included.<br />
Complete Streets policies are incorporated throughout the policies and strategies though there<br />
is no specific policy devoted to Complete Streets. It would be helpful to have a section fully<br />
devoted to Complete Streets with some additional strategies not now included under the <strong>MTP</strong>’s<br />
31 draft policies such as:<br />
• Developing a regional Complete Streets Plan with a goal and a timeframe for achieving a<br />
system of Complete Streets throughout the region.<br />
• Developing an inventory of Complete Streets and an annual or biannual progress report<br />
on progress toward a complete system.<br />
• Encouraging all cities and counties in the region to develop and adopt pedestrian and<br />
bicycle master plans and project lists.<br />
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• Training for local and regional staff on the latest pedestrian and bicycle quantification,<br />
engineering and planning methodologies.<br />
• Consideration of the development of a regional levee maintenance and rehabilitation<br />
plan that includes multiuse trail development.<br />
There is no specific policy related to safety but a few of the strategies do address the issue of<br />
safety. We think this is an area that deserves greater focus, especially the safety of pedestrians<br />
and bicyclists.<br />
We offer the following suggested additions and/or changes to underscore the importance of<br />
Complete Streets and the provision of pedestrian and bicycle infrastructure:<br />
1. Land Use and Environmental Sustainability Policies and Strategies<br />
Policy 1: Information, tools & incentives –<br />
• We recommend a new Strategy 1.6: “Create and invest in a Complete Streets strategy<br />
and program to achieve Complete Streets/Safe Routes for All throughout the region<br />
consistent with the Blueprint Principles.”<br />
Policy 2: Education<br />
• 2.3: Add the underlined to this strategy: Monitor and report on commute patterns,<br />
traffic levels, transit use, and bicycle & pedestrian mode share compared with the<br />
projections in this <strong>MTP</strong>/<strong>SCS</strong>.<br />
• 2.4: Add to this strategy: “Additionally, provide training on the latest analytic methods<br />
related to pedestrian and bicycle planning, modeling, data collection, and infrastructure<br />
design.”<br />
Policy 3: Community activity centers & transit.<br />
While not mentioned in the policy, we appreciate the emphasis on complete streets in some of<br />
the strategies. It might be useful to rename this policy so that complete streets are given<br />
greater emphasis.<br />
Policy 7: Rural‐Urban Connection Strategy<br />
• Strategy 7.4: Add to this strategy the following: “Additionally, consider how rural land<br />
use strategies affect access by active transportation (walking and bicycling).”<br />
Policy 8: Reducing vehicle emissions to achieve clean air and better public health<br />
• Add a new Strategy 8.5: “Study and document the emission reduction benefits of<br />
Complete Streets infrastructure and the potential for increased emission reductions<br />
from increased walking and bicycling.”<br />
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Policy 9: Greenhouse Gas emission reductions<br />
• Modify Strategy 9.1 (as noted by underlines): Adopt a transportation pricing policy,<br />
adopted a Safe Routes to School policy and implement a pilot program, expand public<br />
access to travel information through 511 program, and adopt a Complete Streets policy<br />
and implementation program.<br />
2. Finance Policies and Strategies<br />
Policy 11: Pursue sustainable funding sources …<br />
• Add Strategy 11.5: “Advocate for funds to complete the streets for the region so that<br />
residents can walk and/or bicycle to locations within 10‐30 minute distance from<br />
housing and workplaces.”<br />
Policy 13: SACOG’s investments of federal and state funds …<br />
• Add new Strategy 13.6: “Study, coordinate discussions, and explore options for<br />
establishing a region‐wide program dedicated to funding the full implementation of<br />
Complete Streets including pedestrian and bicycle infrastructure necessary for a fully<br />
interconnected Complete Streets system.”<br />
Policy 14: SACOG seeking special funding<br />
• Add new Strategy 14.8: “Work with local, state and federal agencies to develop new<br />
sources of transportation funding based on improving public health including new<br />
sources of funding for expanding pedestrian and bicycle infrastructure.”<br />
Policy 15: Manage state and federal funding<br />
• Add new Strategy 15.5: “Work with local agencies to improve and accelerate project<br />
delivery, especially of bicycle and pedestrian infrastructure project.”<br />
3. System Maintenance & Operations Policies and Strategies<br />
This grouping of policies and strategies is particularly relevant to cost‐effectively maximizing the<br />
current system for walking and bicycling. We recommend adding the following paragraph after<br />
the first paragraph:<br />
• “Road and highway maintenance and rehabilitation can be an economical way to<br />
increase Complete Streets and mobility for walking and bicycling. The addition of bike<br />
lanes, the consideration of lane restriping to make room for bike lanes and sidewalks,<br />
and the addition of crosswalk markings and other crossing enhancements can greatly<br />
expand the pedestrian and bicycle network with minimal investment. By reviewing in<br />
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advance the roadways programmed for maintenance and rehabilitation, the specific<br />
plans can incorporate provision for walking and bicycling at a low cost compared with<br />
retrofits completed at a later date.”<br />
Policy 17: Acknowledge preservation as top priority and help secure funding<br />
• Add new Strategy 17.5: “Assist local agencies in developing multi‐year maintenance and<br />
rehabilitation programs than enable early identification of cost‐effective enhancements<br />
to improve pedestrian and bicycle access and safety.”<br />
Policy 19: Ensure coordination among all forms of transit services<br />
• Add new Strategy 19.3: “Support development of plans and investment strategies for<br />
prioritizing pedestrian and bicycle access‐to‐transit infrastructure projects.”<br />
Policy 21: Rural transit services<br />
• Add new Strategy 21.3: “Enhance access to rural transit through planning for safe<br />
bicycle and pedestrian access.”<br />
Policy 23: Service to transit‐dependent populations and attracting new riders who now drive<br />
• Add Strategy 23.3: “Increase the attractiveness of transit by involving the community in<br />
improving the environment of transit stops and stations and the pedestrian and bicycle<br />
access to those transit stops and stations.”<br />
4. System Expansion Policies and Strategies<br />
Policy 28: Transit investments for transit‐dependent and choice riders<br />
• Add Strategy 28.13: “Support strong collaboration between city and county<br />
transportation and land use planners and transit planners to achieve optimum<br />
pedestrian access within ½ mile of transit routes and stations and bicycle access within 3<br />
miles of transit routes and stations.”<br />
Policy 30: Road expansion to support infill development and reduce midday congestion<br />
• Modify Strategy 30.1 as follows (recommended additional wording underlined). Pursue<br />
strategic road expansion that improves reduces congestion, and supports effective<br />
transit services and maximizes provision for Complete Streets – access for walkers and<br />
bicyclists.<br />
• Modify Strategy 30.2 as follows: Expect that feasibility and corridor studies, project<br />
study reports, and environmental studies will consider high‐quality transit and<br />
pedestrian and bicycle investments when examining how to provide additional capacity<br />
on main highway or bridge corridors.<br />
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• Modify Strategy 30.4 as follows: Give priority for roadway and intersection expansion to<br />
routes where midday demand approaches existing capacity or excessive peak period<br />
demand threatens to spill over into midday, so no part of the system fails to function<br />
continuously for much of the day fully considering the safety and level of service of all<br />
modes utilizing the new multi‐modal level of service analysis methods.<br />
Chapter 7 – Environmental Sustainability<br />
• This chapter would benefit from more information on specific communities – how much<br />
VMT and emissions they contribute. This would help to increase awareness on the<br />
importance of land use and complete streets.<br />
Chapter 8 – Equity and Choice<br />
One of the key aspects addressed in this chapter is access to transit which is critical for<br />
individuals without access to a personal motor vehicle. Yet while mentioned briefly, pedestrian<br />
and bicycle access is also critical to people without cars. Walking and bicycling are low cost and<br />
health promoting.<br />
In WALKSacramento’s “Los Rios Transportation Connections” study and plan completed in 2008<br />
we learned that there are significant opportunities to reduce students’ economic burden with<br />
transportation improvements. For example, over ½ of students of American River College live<br />
within 5 miles of the college. Yet access by bicycling in this area of Sacramento’s<br />
unincorporated area is unsafe and walking in the vicinity of the college is difficult because of<br />
the lack of sidewalks on many streets. Parking is low cost and most students drive to the<br />
campus. If students were able to forgo the costs of a car, they would in effect have as much as<br />
a $8,000 bonus which could assist them with their other college expenses.<br />
• We urge that access to walking and bicycling be addressed more comprehensively in this<br />
chapter.<br />
Chapter 9 – Economic Vitality<br />
We appreciate the note on Page 9‐24 that “Increased interest in bicycling and walking has had<br />
additional economic benefits.”<br />
• We suggest this aspect of economic vitality be expanded.<br />
• Additionally we suggest that this chapter address the economic importance of health<br />
and the costs of our health care as it related to transportation. What would be the<br />
909 12 th Street, Sacramento CA 95814 916‐446‐9255<br />
6<br />
Page 145 of 165
economic benefits of the development of a truly walkable and bikable region contribute<br />
to our health and the reduction of health care costs?<br />
Chapter 10 – Financial Stewardship<br />
As we have mentioned in our letter and in our policy recommendations, we believe there is a<br />
significant financial stewardship opportunity to increasing the cost‐effectiveness of our road<br />
rehabilitation funds by incorporating early consideration and planning for Complete Streets<br />
improvements to those roads that are integrated into the rehabilitation when it occurs.<br />
• We urge SACOG to include this concept in its Financial Stewardship approach.<br />
It is suggested on page 10‐7 that the <strong>MTP</strong>/<strong>SCS</strong> assumes a reliance on sales taxes anticipating a<br />
new ½ cent “Measure B” sales tax in Sacramento County beginning in 2014 – and assumes that<br />
this new revenue would be split between transit and capital needs. What portion of this<br />
potential new funding will be used for road rehabilitation?<br />
• We urge Sacramento’s elected leaders to include provision for Complete Streets as part<br />
of any new sales tax measure.<br />
Pedestrian safety is a critical issue in this region. Though pedestrian trips are a relatively small<br />
portion of all trips, they are a significantly greater proportion of all traffic fatalities. As noted on<br />
page 10‐17, pedestrian fatalities from motor vehicle collisions exceed 18% of all fatalities in the<br />
State – much higher than in the national as a whole. In 2009, 18% of traffic fatalities in this<br />
region were pedestrian fatalities. In Sacramento County in 2009 pedestrian fatalities were 25%<br />
of total fatalities (source, California Office of Traffic Safety website).<br />
While roadway fatalities have gone down overall in the state, we believe that pedestrian<br />
fatalities have not declined.<br />
• We urge that the section on Roadway fatalities in the SACOG region include statistics on<br />
pedestrian fatalities.<br />
The greater proportion of pedestrian fatalities in the region and particularly in the region’s<br />
urban areas underscores the need for improved transportation infrastructure for safe<br />
pedestrian mobility.<br />
909 12 th Street, Sacramento CA 95814 916‐446‐9255<br />
7<br />
Page 146 of 165
PO Box 1526 • Sacramento, CA • 95812 (916) 444-0022 <br />
<br />
January 9, 2012<br />
Board of Directors<br />
Sacramento Area Council of Governments (SACOG)<br />
1415 L Street Suite 300<br />
Sacramento, CA 95814<br />
Re:<br />
<strong>Draft</strong> Metropolitan Transportation Plan/Sustainable Communities Strategy, and<br />
corresponding DEIR<br />
Honorable Board Members and Executive Director Mike McKeever:<br />
The Environmental Council of Sacramento (ECOS), Habitat 2020, and the California Heartland<br />
Project are unified in our support of SACOG's first joint <strong>Draft</strong> Metropolitan Transportation Plan /<br />
Sustainable Communities Strategy (<strong>MTP</strong>/<strong>SCS</strong>). The plan is a visionary approach to the SB 375<br />
objective to link regional land use and transportation planning to reduce greenhouse gas<br />
emissions. We applaud the direction of the SACOG Board and the efforts of SACOG staff to<br />
produce a scenario that, if adhered to, will certainly make significant steps towards regional<br />
sustainability.<br />
Considering the financial constraints of this planning cycle, we are impressed with SACOG's<br />
ability to do "more with less" by directing investment to areas that maximize impact by the cost<br />
effectiveness of smart growth and active transportation. Some of the impressive anticipated<br />
outcomes we support include:<br />
o Meeting the CARB GHG reduction targets (10% by 2020, 16% by 2035)<br />
o Declines in congested VMT (6.9%)<br />
o Increases in transit service hours, system productivity, and access overall, and<br />
more so for Environmental Justice Areas<br />
o More homes, jobs, and amenities near high-frequency transit<br />
o 8% proportion of funding to active transportation, with additional bike/ped<br />
improvements integrated into road maintenance funds<br />
While we strongly commend the modeling outcomes the <strong>MTP</strong>/<strong>SCS</strong> presents, there is also room<br />
for strengthening the plan to help ensure these outcomes are achieved. We fully support the many<br />
suggestions offered in the letters of ClimatePlan, Human Impact Partners, and the Coalition On<br />
Regional Equity. But, for the purposes of this letter, we are obliged to highlight some key areas of<br />
weakness that we feel could, in the long-term, be a detriment to the successful implementation of<br />
this valuable plan. We recognize that the following, in some cases, deals with processes that<br />
require further coordination with local jurisdictions, and are not necessarily in the sole control of<br />
SACOG. Given that, we offer these observations for your ongoing consideration in future work.<br />
Page 147 of 165
Transportation:<br />
It has long been a concern of ECOS and others that, too often, housing and commercial<br />
development takes place without adequate transit, and that when and if transit is put in place, it is<br />
then difficult to change car-oriented behavior. It is understood that SB375 only requires quality<br />
transit to be planned within the time horizon of the <strong>MTP</strong> for residential projects to meet the<br />
criteria for CEQA benefits, and we are pleased with SACOG's approach to targeting<br />
transportation projects that will maximize effects of investment. Yet we feel that more specific<br />
strategies are needed to ensure appropriate phasing of transit and active transportation<br />
improvements with residential development.<br />
We hope to see SACOG review transportation project phasing in relationship to current densities<br />
and the timing of future development, working with other agencies and local jurisdictions to<br />
establish protocols which: identify and accelerate transit for high-density arterial corridors and<br />
existing urban areas that currently lack adequate service: flag and defer or cancel any costly<br />
transit capital projects that would begin construction before the densities would justify the cost<br />
(as suggested by Strategy 28.9): Flag, defer or cancel road and transit construction that would<br />
trigger premature peripheral growth.<br />
Land Use:<br />
The land use forecast in the <strong>MTP</strong>/<strong>SCS</strong> represents an improvement over previous regional<br />
planning efforts. The <strong>MTP</strong>/<strong>SCS</strong> anticipates accommodating expected growth with a vision<br />
toward more efficient land use and a smaller expansion of the regional development footprint.<br />
There are a variety of factors that help to make this <strong>MTP</strong> update a promising step toward a<br />
sustainable future for the Sacramento region, including the first-time incorporation of SB 375<br />
requirements, SACOG’s advanced modeling tools, and extensive public outreach to help define<br />
the <strong>MTP</strong>/<strong>SCS</strong> preferred scenario for land use and transportation.<br />
Despite these improvements, the <strong>MTP</strong>/<strong>SCS</strong> includes key assumptions that, if adopted, could<br />
hinder the region’s ability to achieve important land use and transportation objectives.<br />
The single most important assumption in the <strong>MTP</strong>/<strong>SCS</strong> land use forecast that should be reviewed<br />
is the overestimation of demand for single-family large-lot housing. Although this type of<br />
housing has dominated residential development throughout the region for the past several<br />
decades, independent studies consistently show that demographic changes are reducing the<br />
demand for this type of housing. The <strong>MTP</strong>/<strong>SCS</strong> acknowledges that “…there will be significant<br />
demand, especially by the large, retirement age baby boomer generation and the even larger<br />
Generation Y echo-boomer cohort (those born between 1978 and 1994), for new housing,<br />
including rentals and small lot homes…” 1 . Despite this, Table 3.9 of the <strong>MTP</strong>/<strong>SCS</strong> shows that 28<br />
percent of new housing in 2035 is single-family large-lot.<br />
This contrasts sharply with at least one recent study concluding that the Sacramento region<br />
already has enough single-family large-lot residential supply to meet demand through 2035. 2<br />
1 SACOG, <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> 2035, November 10, 2011, p. 3-13.<br />
2 Nelson, Arthur C. The New California Dream: How Demographic and Economic Trends May<br />
Shape the Housing Market. Washington, D.C.: Urban Land Institute, 2011, Table 4.4, p. 43.<br />
Page 148 of 165
This study by the Urban Land Institute estimated that over half of the residential demand between<br />
2010 and 2020 will be for attached units; and by 2035, about 60% of demand will be for attached<br />
units. The <strong>MTP</strong>/<strong>SCS</strong> predicts a lower share of attached units.<br />
This result of this overemphasis on single-family large-lot development is significantly more<br />
developed acreage than necessary to meet demand, and the less-compact land use form results in<br />
greater vehicle trip lengths and greenhouse gas emissions. Table 3.11 of the <strong>MTP</strong>/<strong>SCS</strong> shows<br />
that 45 percent of additional developed acres between 2008 and 2035 are in Developing<br />
Communities – where much of the single-family large-lot development would occur.<br />
The fundamental cause of this problem is the <strong>MTP</strong>/<strong>SCS</strong> assumption that 42 percent of forecasted<br />
housing demand and 18 percent of employment demand will be in Developing Communities. 3<br />
Not surprisingly, the largest increase in housing units by community type between 2008 and 2035<br />
is in Developing Communities, where the share of housing units increases from three percent in<br />
2008 to 13 percent in 2035.<br />
To remedy this problem, we recommend that SACOG work with individual jurisdictions to refine<br />
the demand analysis and land use distribution to reduce the 2035 forecasted housing unit<br />
allocation for Developing Communities by at least 50% (to a total of not more than 75,000 units)<br />
and reallocate the remainder to Center and Corridor Communities.<br />
In addition, we encourage SACOG to develop a guidebook that provides clear examples of the<br />
key characteristics of the various development types in the <strong>MTP</strong>/<strong>SCS</strong>. The Guidebook could be<br />
developed similar to the Title 24 guidebook that was published shortly after the Title 24 standards<br />
were adopted in 1978.<br />
Finally, SACOG’s 2020 and 2035 GHG reduction targets are difficult to consider at the Plan or<br />
Project level because there is currently no method/model that could evaluate plan or project<br />
performance at meeting the targets. We encourage SACOG to work with ARB, local air districts,<br />
educational institutions, and others to develop technical tools (similar to CalEEMod) that would<br />
provide the ability to evaluate individual projects and their contribution to regional targets.<br />
CEQA Streamlining Determination Process:<br />
SB 375 gives the local jurisdiction the discretion for making the determination for what level of<br />
CEQA exemptions a project is qualified for within the <strong>SCS</strong>, but, while it is suggested, there is no<br />
mandate for a public notice, hearing or review process for this determination (PRC 21155.1). In<br />
most cases, the usual required CEQA process would ensue after the determination, but of course;<br />
the determination affects what will be reviewable in that process. Further, after that<br />
determination, the ability to challenge findings is made more difficult, being raised to the<br />
"substantial evidence" standard. And with no precedence, it remains unclear if it is possible to<br />
challenge the determination itself. And, in the event that a project is dubbed to be a "sustainable<br />
communities" project, qualifying for a full CEQA exemption, then there will be no ensuing<br />
process.<br />
Page 3-36 of the plan states, “To determine a project’s consistency with the <strong>SCS</strong>, a jurisdiction<br />
must find it consistent with the general land use, density, intensity, and any applicable land use<br />
3 SACOG, p. 3-15.<br />
Page 149 of 165
policies of the <strong>SCS</strong>. Additional information by jurisdiction and community type is provided in<br />
Appendix E-3.”<br />
The jurisdictional narratives of anticipated growth in Appendix E-3, in conjunction with the<br />
primary map of the plan by community type (Figure 3-2, <strong>MTP</strong>/<strong>SCS</strong>, p. 3-11) and the breakdown<br />
of qualifications for the levels of CEQA benefits in Table 2-16 (DEIR, p. 2-60) offer a very broad<br />
net for jurisdictions to make the interpretation of "consistency" with the <strong>SCS</strong>, or judge the<br />
impacts that have been addressed by the programmatic <strong>SCS</strong> EIR. We understand that SACOG<br />
does not have the capacity to provide oversight for all regional project-level determinations, but<br />
lacking this oversight or a more specific guide for land-use designations, it is extremely important<br />
that there be a public process before these determinations are made. At the very least, an<br />
opportunity for public input should be established in coordination with the local jurisdictions to<br />
ensure that equity, health, and environmental interests are adequately addressed.<br />
Natural Resources:<br />
We are greatly concerned about the continued trend of greenfield development in the region. We<br />
support the reduced growth footprint of this <strong>MTP</strong>/<strong>SCS</strong>, yet there remains a substantial amount of<br />
greenfield development within the footprint (that will now receive CEQA exemptions). And<br />
further, there are currently many thousands of acres of proposed development outside of the plan<br />
that will endanger the plan's future success. Growth outside of the plan in one area will need to be<br />
absorbed by the rest of the region and inhibit the growth of other jurisdictions, in subsequent<br />
<strong>MTP</strong>s. And it is feared that much more than the CEQA benefits provided by the <strong>SCS</strong> will be<br />
needed to incentivize smart growth and adherence to the plan.<br />
The centerpiece of the plan's natural resource element is the Rural Urban Connection Strategy.<br />
We cannot understate our praise for the work of the RUCS program since the last <strong>MTP</strong> in<br />
analyzing the broad range of factors that affect viability of the region's rural communities. And<br />
we commend RUCS's demonstration of the economic imperatives to preserve the regions<br />
agricultural base.<br />
SACOG highlights performance in this area with the projection that, by 2035, 37,000 acres of<br />
agricultural land will be converted to urban development--compared to 200,000 acres converted<br />
since 1988, (despite a greater projected population increase by 2035). This is certainly a great<br />
departure from the past that we support. Clearly, RUCS is an innovative and impressive program,<br />
yet it is essentially an economic viability study for agriculture alone, and the sophisticated<br />
analysis does not extend equally to habitat impacts, or other ecosystem services (i.e. carbon<br />
sequestration, groundwater recharge).<br />
For plant and wildlife habitat viability, the <strong>SCS</strong> relies mostly on the presumed completion of the<br />
region's Habitat Conservation Plans. But these plans, alone, do not address critical regional<br />
connectivity, and, in some cases, do not at this point show certainty of successful completion.<br />
The total acreage of newly developed land in the <strong>SCS</strong> is generally represented to be 53,266-<br />
53,914 (EIR 2-25; 19-20). Within the newly developed areas, 36,392 acres of agriculture<br />
(<strong>MTP</strong>/<strong>SCS</strong>, 7-6), 5,602 acres of designated forest (EIR,4-44), and 37,681 acres of habitat are<br />
impacted (Table 7-5, <strong>MTP</strong>/<strong>SCS</strong> 7-17). Obviously, there are overlaps of these 79,675 acres of<br />
agriculture, forest, and habitat to add up to the ~53,500 figures. Table 6-6 (EIR, 6-35) adds up the<br />
impacts to 53,914 - showing only 16,233 acres of agriculture beyond the 37,000 of habitat. But<br />
how or where the other 24,000 acres overlap is not clearly indicated or shown spatially to be able<br />
to adequately analyze impacts.<br />
Page 150 of 165
Further, while SACOG has used the best data currently available, it is roundly recognized that<br />
comprehensive, accurate, up-to-date natural resource data does not exist for the region to do<br />
sufficient analysis of these impacts.<br />
The lack of data is demonstrated by the plan's simple justification that the 37,500 acres of habitat<br />
impacted represents only "one percent of the 2,543,519 acres of habitat and land cover in the<br />
region today," (<strong>MTP</strong>/<strong>SCS</strong>, 7-16). However, the vast majority of this regional habitat resides in the<br />
National Forest in the mountains, while the vast majority of the impacts are in the valley and<br />
foothills where viable habitat differs greatly and is much more sparse. In the future, a<br />
proportionate analysis of habitat impacts on the valley must be undergone, at a regional level, to<br />
adequately assess environmental sustainability of the <strong>MTP</strong>/<strong>SCS</strong>.<br />
We believe that the interests of equity, public heath, and economic prosperity in compact transitoriented<br />
urban planning are best served by complimentary planning for natural resource and<br />
open-space conservation. Improved natural resource data, analysis and conservation strategies<br />
need to be developed to compliment the <strong>SCS</strong>, to further incentivize adherence to the valuable<br />
urban plan that SACOG has developed.<br />
In the future, this data could be used:<br />
As a public decision-support tool for targeting responsible and efficient investment for<br />
development and conservation.<br />
To enable participation in/development of a Regional Advanced Mitigation Program<br />
To demonstrate co-benefits for ecology, public health, recreation and education, as well<br />
as the economic imperatives for habitat/open-space conservation<br />
To demonstrate co-benefits and economic imperatives to preserve ecosystem services,<br />
(ie. carbon sequestration, flood management and groundwater recharge)<br />
Conclusion:<br />
To reiterate, we applaud SACOG's first joint <strong>SCS</strong>/<strong>MTP</strong>, and we hope the above comments are<br />
constructive to implementation of the plan. We also commend the extensive efforts of SACOG<br />
staff to engage the public throughout the <strong>MTP</strong> process. We greatly appreciate the time and<br />
attention that has been provided us in addressing our concerns and suggestions in development of<br />
this plan, and we look forward to our continued work with SACOG moving forward.<br />
Sincerely,<br />
Jonathan Ellison, President<br />
ECOS Board of Directors<br />
Page 151 of 165
LEGAL SERVICES OF •.-• N ORTH E R N CALf FOR N IA<br />
of Directors<br />
Board<br />
Area Council of Governments<br />
Sacramento<br />
promotes quality affordable and<br />
SHA<br />
housing and enhanced opportunities for lower income households and homeless individuals.<br />
accessible<br />
and works in collaboration with its many community partners to create opportunities<br />
advocates<br />
fair and equitable access to quality transportation, jobs, and food, particularly for the<br />
for<br />
lower income residents, homeless people, communities of color, people with<br />
region's<br />
and other vulnerable or disenfranchised populations. Accordingly, SHA focuses<br />
disabilities<br />
these communities. SHA views application of SB 375 and other laws and regulations<br />
for<br />
the <strong>MTP</strong>/<strong>SCS</strong> process as an opportunity to ensure that the region's disenfranchised<br />
governing<br />
and communities reap the benefits of the Plan and are not disproportionately<br />
residents<br />
or disadvantaged by its implementation, as is too often the case with intended<br />
burdened<br />
demonstrates that SACOG continues to play a<br />
house gas reduction targets; that strives, to a<br />
1SHA also oins in the comments the Coalition on Regional Equity submitted to SACOG on December 23, 2011.<br />
SACRAMENTO COUNTY OFFICE 515 12TH STREET SACRAMENTO CA 95814<br />
VOICE: (916) 551-2150 FAX: (916) 551-2196 WEB:<br />
January 9, 2012<br />
L Street, Suite 300<br />
1415<br />
CA 95814<br />
Sacramento,<br />
Re: <strong>Draft</strong> Metropolitan Transportation Plan/Sustainable Communities Strategy 2035<br />
Dear SACOG Board of Directors:<br />
Services of Northern California submits these comments on SACOG's current <strong>Draft</strong><br />
Legal<br />
Transportation Plan/Sustainable Communities Strategy 2035 ("<strong>MTP</strong>/<strong>SCS</strong>" or "Plan") on<br />
Metropolitan<br />
behalf of the Sacramento Housing Alliance ("SHA"). 1<br />
Consistent with this mission, SHA, and its<br />
project, the Coalition on Regional Equity (CORE), also<br />
these comments on ensuring that the <strong>MTP</strong>/<strong>SCS</strong> promotes equity in<br />
housing and transportation<br />
transportation and land use reform.<br />
SHA believes the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> moves the region in<br />
the right direction and<br />
leadership role nationally in transportation and<br />
use planning. Faced with the challenge of a 5 percent- decrease in per capita funding,<br />
land<br />
has drafted a plan that endeavors to meet the 2035 and exceed the 2020 regional green<br />
SACOG<br />
significant extent, to make much-needed<br />
improvement in<br />
access to transit service and active modes of transportation; and that utilizes<br />
Page 152 of 165
from SHA to SACOG re <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
Letter<br />
9, 2012<br />
January<br />
among Hispanics and<br />
be<br />
Sacramento County is already a so-called "majority-minority" with Yolo County close<br />
Asians.<br />
with a population at 50-50 white-minority. And, it is an unfortunate fact that as with<br />
behind<br />
regions across the state and country, people and communities of color disproportionately<br />
other<br />
the burden of the region's failed systems and infrastructure, and that racial wealth and<br />
bear<br />
gaps have worsened many fold due to the housing and financial crises. Thus, it makes<br />
income<br />
2£19 and Appendix G-5 of the Plan detail many of the state and federal requirements<br />
Page<br />
SACOG must meet in developing and implementing its <strong>MTP</strong>/<strong>SCS</strong>. However, important<br />
that<br />
entered into with HUD as a condition of receiving a<br />
Partnership for Sustainable<br />
SACOG<br />
Grant, SACOG "represent[ed], warrant[ed], and certifie[d] that it Shall comply<br />
Communities<br />
Title VI of the Civil Rights Act of 1964 (Nondiscrimination in Federally Assisted HUD<br />
1. 3 [why isn't there reference to FTA or.DOT?]);<br />
Programs<br />
Title of the Education Amendments of 1972, .as amended (Nondiscrimination on the<br />
2. IX<br />
Sex in Education Programs Activities);<br />
or of Basis<br />
3. Section 504 of the Rehabilitation Act of 1973 (Nondiscrimination Based on Handicap)<br />
http•//www.p•io/•ink.•rg/site/c.•k•xLbMNJrE/b.7843•37/k.B35B/Equity-Summit-2•11:htm.•<br />
statutes and laws listed here refer to and govern programs or activities receiving federal financial assistance.<br />
All<br />
and expansive approaches to promoting equity outcomes, particularly in<br />
innovative<br />
Justice ("E J") areas.<br />
Environmental<br />
SHA believes that SACOG can and must strengthen and enhance the equity<br />
However,<br />
of the <strong>MTP</strong>/<strong>SCS</strong>. Doing so will bring the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> into better compliance with<br />
provisions<br />
state and federal legal and regulatory obligations and, equally important, facilitate<br />
SACOG's<br />
robust and sustainable economic growth in the region. To the latter point, the Plan<br />
more<br />
predicts that greatest population growth over the plan period will<br />
sense from an economic standpoint to make significant investments benefiting disenfranchised<br />
and communities, which, based on SACOG's predicted growth trends, will comprise a<br />
groups<br />
in the region at or near the end of the plan period. The region simply cannot thrive as<br />
majority<br />
a whole if a significant portion of its population is not thriving. 2 SHA urges SACOG to make<br />
changes to the Plan that will better promote equity, and in<br />
turn, will promote economic<br />
opportunity and growth for all.<br />
Necessity for a Complete Legal and Regulatory Requirements List/Description<br />
requirements designed to promote equity are missing from the list.<br />
Under the agreement<br />
with all<br />
applicable Federal statutes, regulations and requirements relating to non,discrimination<br />
and equal opportunity identified in<br />
HUD's regulations at 24C.F:R. Sec. 5.105(a).. including the<br />
following [and their implementing regulations] :" .......<br />
America's Tomorrow: Equity is the Superior Growth Model, Polio/Link 201i at<br />
See<br />
Page 153 of 165
from SHA to SACOG re <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
Letter<br />
9, 2012<br />
January<br />
Title II of the Americans with Disabilities Act of 1990;<br />
4.<br />
The Fair Housing Act;<br />
5.<br />
Executive Order 11063, as amended by Executive Order 12259 (Nondiscrimination and<br />
6.<br />
Opportunity in Housing); and<br />
Equal<br />
7. The Age Discrimination Act of 1974 (Nondiscrimination on the Basis of Age).<br />
Additionally and importantly, SACOG warranted and certified as a<br />
manner that affirmatively further fair housing", 2) to "ensure that employment, contracting<br />
a<br />
other economic opportunities generated by the [Grant] shall, to the greatest extent<br />
and<br />
HUD in its nondiscrimination and equal opportunity compliance activities that are<br />
assist<br />
to maintain and submit racial, ethnic, disability, and other demographic data pursuant<br />
required<br />
to HUD's nondiscrimination and equal opportunity regulations[.]"<br />
(E J) communities. The framework section references Title Vl of the Civil Rights Act,<br />
Justice<br />
prohibits exclusion from participation, denial of benefits and discrimination under any<br />
which<br />
or activity receiving Federal financial assistance on the basis of race, color, national<br />
program<br />
gender, religion and disability, and related federal guidances, as well as Title Vl's broader<br />
origin,<br />
state law counterpart, Government Code Section 11135. <strong>MTP</strong>/<strong>SCS</strong>, pp. 8 1, 2.<br />
California<br />
this framework is very helpful in guiding SACOG and the public regarding SACOG's<br />
While<br />
with respect to EJ areas designated in the Plan, it might be misinterpreted to imply<br />
obligations<br />
Title VI and related laws apply only to the EJ areas, when this is not the case. Indeed,<br />
that<br />
need to... enhance their analytical capabilities to ensure that the long-range<br />
"MPOs<br />
plan and the transportation improvement program (TP) comply with Title VI."<br />
transportation<br />
1 and 2 of the Plan should also be listed on page 2-19 and Appendix G-5.<br />
as SACOG is aware, as a recipient of the HUD Partnership for Sustainable<br />
Finally,<br />
Grant, it must complete a Regional Fair Housi•ng Equity Assessment ("RFHEA").<br />
Communities<br />
See HUD OSHC Terms and Conditions for FY 2010 NOFA, pp. 17 18.<br />
condition of receiving<br />
the HUD Sustainable Communities Regional Planning Grant funds to administer its grant; 1)<br />
"in<br />
be directed to low- and very low-income persons pursuant to Section 3 of Housing<br />
feasible,<br />
Urban Development Act of 1968" and implementing regulations, and 3) "to cooperate and<br />
and<br />
at the beginning of Chapter 8 on Equity and Choice, the <strong>MTP</strong>/<strong>SCS</strong> sets forth a<br />
Laudably,<br />
framework for planning for and addressing the needs of•the, region's Environmenta<br />
legal<br />
[emphasis added] 4.<br />
Accordingly, Title Vl and the related laws, regulations set forth on pages g<br />
The required components of this assessment are detailed below.<br />
The obligation to prepare this<br />
4Federal Highway Administration,<br />
An Overview of Transportation and Environmental Justice at<br />
http://www.polic¥1ink.orR/site/c.lklXLbMNJrE/b.7843037/k.B35B/Equit¥ Summit<br />
2011.htm.<br />
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Letter<br />
9, 2012<br />
January<br />
should be listed as well on page 2-19 and Appendix G-5, as well as set forth<br />
assessment<br />
Chapter 8 of the <strong>MTP</strong>/<strong>SCS</strong> in the Legal Framework section.<br />
explicitlyin<br />
Providing a<br />
is not a technical exercise. Rather, it is as essential to ensure that SACOG will have<br />
<strong>MTP</strong>/<strong>SCS</strong><br />
comprehensive guidance to carry out its <strong>MTP</strong>/<strong>SCS</strong> activities in a manner consistent with<br />
the<br />
obligations, and to provide the transparency required to keep the public fully informed<br />
these<br />
able to monitor and participate in <strong>MTP</strong>/<strong>SCS</strong> development, implementation and activities.<br />
and<br />
Conform pages 2-19 and Appendix G-5 of the <strong>MTP</strong>/<strong>SCS</strong> to pages 17 and 18<br />
Recommendation:<br />
the HUD OSHC Terms and Conditions for FY 2010 NOFA and pages 8- I and 2 of the Plan<br />
of<br />
Improvements and Enhancements to Methodologies and Measures to Ensure<br />
Suggested<br />
and Properly Measure the Impact of the <strong>MTP</strong>/<strong>SCS</strong> on Protected Communities<br />
Equity<br />
appreciates the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> provisions intended to improve transit service,<br />
SHA<br />
the provisions to increase service by 44% per capita, reduce distance to the nearest<br />
including<br />
to 70 by 2035. Commendably, SACOG also endeavors to bring more transit to EJ Areas by<br />
hour<br />
bus service hours by 82 percent and rail and bus by combined 88 percent on routes<br />
increasing<br />
serve EJ. And, SHA supports the sections of the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> in which SACOG goes<br />
that<br />
the Federal Highway Administration EJ order 5 requirements by including sections on<br />
beyond<br />
transportation needs and opportunities to improve transportation services for the senior,<br />
the<br />
and youth populations. With respect to the Environmental Justice areas analysis, SHA<br />
disabled<br />
well-being of residents in EJ areas.<br />
of Title VI of the Civil Rights Act and the federal Fair Housing Act, and related<br />
requirements<br />
mandates within the context of the <strong>MTP</strong>/<strong>SCS</strong> may help put SHA's comments and<br />
equity<br />
Federal Highway Administration Environmental Justice Order 6640•23 (1998) at<br />
SSee<br />
23.htm•<br />
http://www.fhwa.dot.gov/legsregs/directives/orders/6640<br />
complete list of SACOG's legal and regulatory obligations related to the<br />
make explicit reference to the RFHEA so that SACOG and the public have complete and<br />
and<br />
guidance on SACOG's legal and regulatory obligations, including those that will<br />
accurate<br />
promote equity, regarding <strong>MTP</strong>/<strong>SCS</strong> implementation and activities.<br />
station f•om about ¾ to ½ a<br />
mile; and to increase passenger boardings from 33.3 per service<br />
is<br />
pleased that SACOG has added the current <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> performance measures developed<br />
in<br />
with the Center for Regional Change ("CRC"), which are designed to provide a<br />
conjunction<br />
comprehensive picture of impact that the <strong>MTP</strong>/<strong>SCS</strong> will have on the health and overall<br />
more<br />
SHA believes SACOG can and should do much more to advance equity<br />
However,<br />
th"e Plan and hence, offers the recommendations below. An explanation of the<br />
through<br />
recommendations into context.<br />
4<br />
Page 155 of 165
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Letter<br />
9, 2012<br />
January<br />
federal Fair Housing Act prohibits discrimination in a broad range of activities that<br />
The<br />
housing opportunities based on race and national origin, as well as religion, sex, familial<br />
impact<br />
and disability. 6 The Act prohibits not only intentionally discriminatory actions, but those<br />
status<br />
have a "disparate impact" on a protected group as well. 7 The Act prohibits discrimination<br />
that<br />
the form of exclusionary land use practices and policies 8, as well as practices or policies that<br />
in<br />
minorities from one community or concentrate minorities in another community. 9<br />
exclude<br />
Fair Housing Act further requires that federal programs and funds related to<br />
•he<br />
and urban development promote "truly integrated and balanced living patterns. "1° This<br />
housing<br />
in their jurisdiction; (2) take actions to overcome the effects of these impediments;<br />
opportunity<br />
(3) keep records of the analysis and actions. 11 This affirmative obligation requires recipients<br />
and<br />
federal funds to take actions necessary to both identify and break down existing patterns of<br />
of<br />
and other barriers to fair housing.<br />
segregation<br />
fair housing obligations are enhanced by the requirements of both Title VI of the<br />
These<br />
Rights Act, which prohibits discrimination by recipients of federal funds, lz and its state<br />
Civil<br />
federal and state requirements.<br />
HUD's recently released guidance on how this kind of analysis<br />
42 U.S.C• § 3604.<br />
6<br />
See,<br />
7 Pfaj•v. U.S. Dept. of Housing and Urban Development, 88 F.3d 739 (9th Cir. 1996); Keith v. Volpe, 858<br />
e.g,,<br />
467 (gth Cir. 1988).<br />
F.2d<br />
E.g., San Pedro Hotel Co.<br />
8<br />
City of Los Angeles, 159 F.3d 470, 475 (9th Cir. 1998); see generally Metropolitan<br />
v.<br />
Dev. Corp. v. Village of Arlington Heights, 558 F.2d 1283, 1291 (7th Cir. 1977).<br />
Hous.<br />
See,<br />
9<br />
Inclusive Comm. Project, Inc. v. Tex. Dep'tofl-lous. & Comm. Dev., 749 F. Supp. 2d 486, 500 (N.D. Tex.<br />
e.g.,<br />
2010).<br />
Tra•icante lo<br />
Metro. Life Ins. Co., 409 U.S. 205, 211 (1972) (quoting 114 Cong. Rec. 3422 (1968) (statement of<br />
v.<br />
Mondale); The Fair Housing Act, § 808(d), (e), 42 U.S.C. § 3608(d), (e). The Housing Element Law also requires<br />
Sen.<br />
jurisdiction to adopt a series of actions "promote housing opportunities for all persons regardless of race,<br />
each<br />
11<br />
13 See 24 C.F.R. § 91.225.<br />
12<br />
42 U.S.C § 2000d.<br />
13 Cal. Go•. Code § 11135(a); Cal. Code Regs. tit. 22, § 98101.<br />
5<br />
to "affirmatively further fair housing", which SACOG has certified to HUD it will meet,<br />
obligation<br />
SACOG must (1) analyze impediments to integrated housing patterns and access to<br />
means<br />
counterpart, California Government Code §<br />
11135, which prohibits discrimination by recipients<br />
of state funds. •3<br />
A thorough fair housing analysis of the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> is<br />
essential to comply with these<br />
sex, marital status, ancestry, national origin, color, familial status, or disability." Cai Gay. Code §<br />
religion,<br />
65583(c)(S).<br />
Page 156 of 165
from SHA to SACOG re <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
Letter<br />
9, 2012<br />
January<br />
fair housing opportunity should be conducted would help SACOG ensure that its <strong>MTP</strong>/<strong>SCS</strong><br />
of<br />
not perpetuate existing racial and ethnic segregation patterns. 14<br />
does<br />
Indeed, SACOG set a<br />
deadline of December 31, 2011 by which to complete such assessment, is<br />
access to opportunity and d•mographic changes, and the strength of fair housing<br />
impact<br />
and activities. Specifically, HUD recommends utilizing three measures of segregation:<br />
services<br />
a dissimilarity index that measures the evenness with which white residents and residents of<br />
(1)<br />
are distributed across a jurisdiction or region (2) predicted racial and ethnic composition,<br />
color<br />
employed a<br />
fact that only 57 percent of households in Marin would be non-Hispanic white in an equal<br />
the<br />
housing market in contrast to Marin's actual 72 percent white population and that<br />
opportunity<br />
percent white. •6 SACOG, in conducting its required fair housing assessment and regional<br />
58.5<br />
housing analysis, should consider utilizing this methodology to see where in the region<br />
fair<br />
However, a<br />
14. and<br />
Source of data: 2005-2009 American Community Survey 5-Year Estimates, Tables B19001 and<br />
16<br />
B19001H.<br />
See also, Kirwan Institute Opportunity Mapping at http://www.kirwaninstitute.org/research/opportunit¥-<br />
17<br />
as SACOG is aware, all recipients of HUD's Partnership for Sustainable<br />
Relatedly,<br />
grants are required to conduct a Regional Fair Housing and Equity Assessment.<br />
Communities<br />
assessment must include analyses of segregation patterns, racially/ethnically concentrated<br />
The<br />
of poverty, access to existing areas of high opportunity, major public investments that<br />
areas<br />
(3) ethnically concentrated areas of poverty. HUD also recommends an analysis of access to<br />
and<br />
areas of high opportunity. Regarding the second metric, Bay Area equity advocates<br />
existing<br />
methodology that calculates what one would expect the race and ethnic diversity<br />
a city to be if all households regardless of race or ethnicity were free to live where others at<br />
of<br />
income level live. Application of this methodology produced interesting results, including<br />
their<br />
City of Pleasanton, which is<br />
70.8 percent non-Hispanic white, would be expected to be only<br />
exclusive housing patterns lie and take steps to address these patterns in its <strong>MTP</strong>/<strong>SCS</strong>. 17<br />
8 of the <strong>MTP</strong>/<strong>SCS</strong> appropriately focuses the "equity and choice" analysis on EJ<br />
Chapter<br />
in Sacramento. However, the <strong>MTP</strong>/<strong>SCS</strong> should also state clearly that most of the equity<br />
areas<br />
related to ensuring fair housing and transportation access governing the Plan<br />
mandates<br />
and implementation apply to the Plan in its entirety, not just EJ areas.<br />
development<br />
concern regarding the EJ analysis is that that it is•purely place-based, as<br />
Another<br />
people-based. A geographic unit may provide a proxy for some of the protected<br />
opposed•to<br />
categories of persons under Title Vl<br />
and the Fair Housing Act, such as race and ethnicity.<br />
purely place-based analysis does not directly analyze the Plan based on race nor<br />
http://www.hud.gov/offices/fheo/ima•es/fho•.pdf.<br />
14See<br />
Sacramento Region Consortium Sustainable Communities Planning Grant Project description/timeline, pp. 9, 10<br />
is<br />
communities/maooinz/.<br />
Page 157 of 165
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Letter<br />
9, 2012<br />
January<br />
SACOG predicts will represent the greatest population growth between now and 2035<br />
which<br />
Hispanics and Asians). <strong>MTP</strong>/<strong>SCS</strong>, p. 8 7. As it stands, "minorities" are currently in the<br />
(among<br />
which is problematic in terms of SACOG's compliance with its Title VI, fair housing and<br />
analysis,<br />
obligations. Similarly, with respect to developing the criteria for the EJ areas, SHA<br />
related<br />
the <strong>MTP</strong>/<strong>SCS</strong>' inclusion of additional variables developed by the Center for Regional<br />
applauds<br />
however questions setting the "minority" population threshold at 70 percent. This<br />
Change,<br />
appears to have been set too high simply to keep the EJ areas within a manageable<br />
threshold<br />
percent. SHA urges SACOG to consider setting the threshold at 60 percent, which would<br />
26.5<br />
not only avoid and remediate disparate impacts, but affirmatively further fair housing.<br />
must<br />
cannot take necessary remedial and affirmative steps to ensure Title VI and fair housing<br />
SACOG<br />
compliance without a<br />
are several places in the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> that call forfurther equity analysis. For<br />
There<br />
the <strong>MTP</strong>/<strong>SCS</strong> plans to increase the proportion of small-lot and attached homes to 57<br />
example,<br />
EJ aiea, especially in terms of potential displacement and increases in housing costs. See<br />
the<br />
p. 8 -16. SHA urges SACOG to amend the plan to assure that in its entirety, the Plan will<br />
Plan,<br />
includes a<br />
is not made on the basis of race or other protected classes, it is incomplete visa vis<br />
analysis<br />
VI and fair housing obligations.<br />
Title<br />
the disproportionately "minority" residents in EJ a•eas, by SACOG's definition,<br />
Finally,<br />
a higher housing cost burden, lower education attainment, and are more<br />
experienc•<br />
isolated, among other barriers to economic stability and opportunity, as compared<br />
linguistically<br />
residents in whiter, non-EJ areas. And, the income and wealth gap between whites and non-<br />
to<br />
account for or consider the overall growth in<br />
the minority population throughout the region,<br />
in Sacramento County and comprise 50 percent of the population in Yolo County.<br />
majority<br />
Table 8 1, p. 8 6. Thus, under SACOG's current analytical model, the <strong>MTP</strong>/<strong>SCS</strong>'s<br />
<strong>MTP</strong>/<strong>SCS</strong>,<br />
impact on •i<br />
significant part of the region's "minority" population will not be part of the equity<br />
capture more of the populations the <strong>MTP</strong>/<strong>SCS</strong> is<br />
obligated to analyze and for which SACOG<br />
sufficient and proper underlying analysis.<br />
percent.o• housing stock in EJ areas and 39 percent of the new housing options in non-EJ<br />
new<br />
has value, but SACOG must also consider what this shift means for people already living in<br />
areas<br />
benefit and not disproportionately burden<br />
protected classes.<br />
In the section of Chapter 8 of the <strong>MTP</strong>/<strong>SCS</strong> on Transportation and Accessibility, SACOG<br />
number of important categories of analysis, including transit access to jobs, medical<br />
care, higher education and parks.<br />
However, the analysis itself does not adequately measure for<br />
For example, if the increase in transit access to jobs is the same from EJ areas as it is<br />
equity.<br />
non-EJ areas, does this not create or perpetuate a disparate adverse impact on<br />
from<br />
"minorities" depending upon the relative place where each type of area started?<br />
And, since the<br />
whites has grown exponentially due to the financial and housing crises which have hit the<br />
7<br />
Page 158 of 165
from SHA to SACOG re <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
Letter<br />
9, 2012<br />
January<br />
region particularly hard. 18 SACOG has both a legal obligation to utilize its <strong>MTP</strong>/<strong>SCS</strong><br />
Sacramento<br />
its fullest capacity to close this gap, as well as an economic interest in ensuring that all<br />
to<br />
jurisdictions and neighborhoods are thriving and that the region does not devolve<br />
SACOG<br />
into an unequal, more racially and economically segregated and divided region due to<br />
further<br />
the adopted policies.<br />
•<br />
Include language in Chapter 8 that clarifies that the <strong>MTP</strong>/<strong>SCS</strong> must comply with Title<br />
•<br />
Consistent with the HUD-required Regional Fair Housing Assessment and SACOG's<br />
other fair-housing obligations, conduct a<br />
and future <strong>MTP</strong>/<strong>SCS</strong> and make policy, methodology and implementation<br />
current<br />
adjustments to ensure the Plan decreases segregation and affirmatively<br />
measure<br />
fair housing throughout the region. SHA recommends a deadline of June 30,<br />
furthers<br />
2012.<br />
• Continue to collaborate closely with equity organizations such as the Center for<br />
Direct significant investment into projects and policies that have the greatest<br />
•<br />
to promote and achieve equity in the first 5 to 10 years of the planning<br />
potential<br />
period.<br />
Add a Strategy to Policy 4 to address potential segregation and gentrification in<br />
•<br />
transit-rich areas throughout the SACOG region.<br />
comments submitted to SACOG on December 23, 2011.)<br />
Equity's<br />
Absent clear evidence of absence of bias in sources or studies, remove language in<br />
•<br />
Additional recommendations regarding specific changes and additions to <strong>MTP</strong>l<strong>SCS</strong><br />
•<br />
and strategies, consistent with SHA's comments above, are attached.<br />
policies<br />
See Wealth Gaps Rise to Record High Between Whites, Black, Hispanics: Twenty to One (Pew Charitable Trust,<br />
18<br />
26, 2011) at http://www.pews•cia•trends.•rg/2•11/•7/26/wea•th-gaps-rise-t•-rec•rd-hi•hs-between-whites-<br />
July<br />
jump in third quarter, October 29, 2011 at http://www.sacbee.com/2011/09/15/3911662/after-<br />
foreclosures<br />
years-lull-sacramento-area.html#ixzz:lfdQRTWsD.<br />
19 SHA's concern is that such language in the <strong>MTP</strong>/<strong>SCS</strong> will form the basis for land use and housing policy decisions<br />
Recommendations:<br />
VI and the federal Fair Housing Act in its entirety, in addition with regard to EJ areas.<br />
comprehensive fair housing analysis of the<br />
Regional Change and the Coalition on Regional Equity to assess the current<br />
<strong>MTP</strong>I<strong>SCS</strong>,<br />
and SACOG's performance under it,<br />
against federal and state equity mandates and<br />
Plan methodologies, metrics and implementation actions accordingly to<br />
improve<br />
compliance with these mandates.<br />
ensure<br />
(See the Coalition on Regional<br />
that suggests that families of certain races and ethnicities primarily double-<br />
<strong>MTP</strong>l<strong>SCS</strong><br />
or crowd into fewer housing units overall for cultural reasons or for other reasons<br />
up<br />
other than out of economic choice. (See Plan, pp. 8 12 and 8 16.) 19<br />
blacks-hispanics/; Rick Daysog, Sacramento Bee, Foreclosures surge in<br />
region, September 15, 2011; New<br />
that perpetuate biases to the detriment of people and communities of color.<br />
8<br />
Page 159 of 165
from SHA to SACOG re <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
Letter<br />
9, 2012<br />
January<br />
the Provisions in the <strong>MTP</strong>/<strong>SCS</strong> Related to Promoting and Increasing the Sm)•)lv of<br />
StrenRthen<br />
Housing Across the SACOG Region and Within Each Local Jurisdiction<br />
Affordable<br />
strongly recommends that SACOG add language to Policy 4 that gives more explicit<br />
SHA<br />
of affordable housing need across the region and in every jurisdiction within<br />
consideration<br />
model that would measure the degree to which a geographic area's housing actually "fits"<br />
fit<br />
affordable to) the types of jobs workers in that area have, since SACOG had committed to<br />
(is<br />
Consortium Sustainable Communities Planning Grant Project description/timeline, pp.<br />
Region<br />
14. SHA urges SACOG to move more aggressively toward developing this model so as to<br />
10,<br />
whether the <strong>MTP</strong>/<strong>SCS</strong> truly facilitates development of affordable housing across the<br />
assess<br />
as a whole as well as within specified jurisdictions or other geographic units.<br />
region<br />
• Amend Policy 4 as follows: SACOG supports every local jurisdiction's efforts to<br />
•<br />
Adopt a Policy or Strategy in the <strong>MTP</strong>/<strong>SCS</strong> that set a target date for completion of the<br />
as CRC and CORE throughout the process of developing the jobs-housing fit<br />
such<br />
and the process of making necessary changes to the current or next <strong>MTP</strong>/<strong>SCS</strong><br />
model<br />
Ensure that the <strong>MTP</strong>/<strong>SCS</strong> Promotes Transportation Equity<br />
with Title Vl, by insuring that its federally funded activities, including development and<br />
comply<br />
of the <strong>MTP</strong>/<strong>SCS</strong>, do not discriminate implementation the basis of race, color or other<br />
on<br />
appreciates the <strong>MTP</strong>/<strong>SCS</strong>' relative level of investment in transit and increase in<br />
SHA<br />
the 2008 level of service--by 2035. However, SHA is concerned about the<br />
service--doubling<br />
SACOG.<br />
SHA is<br />
pleased to see strategies in the <strong>MTP</strong>/<strong>SCS</strong> that reference creating a jobs-housing<br />
create such a model by April :1, 201:1. See Plan, Chapter 6, Strategies 2.9 and 4.3; Sacramento<br />
Recommendations:<br />
facilitate development of housing in all<br />
price ranges, to meet the housing needs of the<br />
workforce and population, especially lower-income populations, and forestall<br />
local<br />
for long external commuting to work and essential services.<br />
pressure<br />
fit model. SHA proposes June 30, 2012.<br />
jobs-housing<br />
Collaborate closely with equity and affordable housing partners and stakeholders,<br />
•<br />
based on application of the model.<br />
Cognizant of the funding challenges SACOG faces in<br />
its efforts to promote<br />
efficiency and equity, SHA believes that the <strong>MTP</strong>/<strong>SCS</strong> must and transportation do much<br />
can<br />
to promote equity. Again, as a recipient of federal transportation funds, SACOG must<br />
more<br />
protected categories.<br />
9<br />
Page 160 of 165
from SHA to SACOG re <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
Letter<br />
9, 2012<br />
January<br />
of the <strong>MTP</strong>/<strong>SCS</strong>, but not until 2020. P. 10-6. This, unfortunately, is opposite of the<br />
years<br />
of equity investment approach that SHA supports and recommends. SHA is<br />
"front-loading"<br />
that deferring investment into transit to late in the plan period will have a disparate<br />
concerned<br />
adverse impact on low-income communities, communities of color, people with disabilities<br />
and<br />
mechanisms through the <strong>MTP</strong>/<strong>SCS</strong> to address any adverse impact, including<br />
Develop<br />
Ensuring that decision regarding routes and times of services are<br />
•<br />
is a business approach to what is a social service. In times of<br />
levels<br />
resources, SACOG should prioritize the transit funding it has on<br />
limited<br />
Ensuring that the proceeds from Measure B in Sacramento County<br />
•<br />
in 2014 support transit operational and capital needs that<br />
beginning<br />
promote equity;<br />
also<br />
Ensuring that the anticipated shift of more than $2 billion of flexible<br />
•<br />
from road to transit over the planning period occurs in the<br />
revenue<br />
part of the remainder of the plan period;<br />
earlier<br />
to support systems expansion and restoration of routes and<br />
revenues<br />
times earlier in the plan period.<br />
running<br />
In collaboration with regional transit operators, transit users and equity<br />
•<br />
consider and analyze potential revenue generating measures,<br />
partners,<br />
road maintenance and<br />
timing of transit such investment as compared to investments in<br />
rehabilitation.<br />
<strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> states that "the limited growth in transit services for the first ten<br />
The<br />
dueto revenue constraints" means that there will be more robust growth in the later<br />
years<br />
and other populations that are disproportionately transit-dependent.<br />
Recommendations:<br />
the impact that the timing of the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong>' transportation<br />
Analyze/measure<br />
priorities will have on populations in the SACOG region protected under Title VI<br />
investment<br />
and related equity mandates, and if the impact is<br />
disparate and negative, take affirmative<br />
steps to avoid and/or mitigate such impacts.<br />
determined by level of need--not level of ridership.<br />
Using ridership<br />
the communities who are in most need of reliable transit services.<br />
.<br />
Analyzing the potential for increased ridership, through lowering of<br />
•<br />
of limited income transit-dependent riders, to increase transit<br />
fares<br />
such as the City of Los Angeles' 30/10 Initiative, which would create a<br />
revenue source to develop 12 key mass transit projects in<br />
10 years,<br />
rather than 30. This is consistent with the concept of front-loading<br />
10<br />
Page 161 of 165
from SHA to SACOG re <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
Letter<br />
9, 2012<br />
January<br />
to achieve transit equity in the earlier part of the remainder<br />
investment<br />
the SACOG Plan period.<br />
of<br />
you for considering our comments and recommendations. SHA looks forward to<br />
Thank<br />
engagement and collaboration with SACOG to ensure that the <strong>MTP</strong>/<strong>SCS</strong> meets its<br />
continued<br />
Tawatao<br />
Mona<br />
Counsel<br />
Regional<br />
fullest potential to advance sustainability, equity and economic growth for all<br />
in the SACOG<br />
region.<br />
Sincerely,<br />
11<br />
Page 162 of 165
from SHA to SACOG re <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
Letter<br />
9, 2012<br />
January<br />
help <strong>MTP</strong>/<strong>SCS</strong> updates and local discussions on development patterns, including transportation<br />
to<br />
measures and opportunities related to accessibility, equity, public health, a• youth,<br />
performance<br />
Strategy: During the design phase, review transportation projects to assess whether they foster<br />
2.7<br />
choices, improve local community circulation and provide access to areas of hiqh<br />
transportation<br />
or divide and further seqreqate communities, and either avoid or mitigate negative impacts<br />
opportunity<br />
those to public health;safety; air quality; housinq quality, affordability and stability; and the<br />
(including<br />
Strategy: Encourage adequate supply of housing at a variety of price ranges in the region, to meet<br />
4.3<br />
demand and prevent the export of housing to adjacent regions and the exacerbation of<br />
local<br />
Strategy: Provide support for jurisdictions to overcome common issues identified in local analyses of<br />
4.5<br />
to fair housing, such as racial and ethnic seqreqation, and a regional analysis funded by<br />
impediments<br />
Strategy: Help air districts and local agencies study localized air pollution impacts on health and the<br />
8.4<br />
particularly in EJ areas and areas of hiqh poverty and/or racial/ethnic concentration,<br />
environment,<br />
air toxins, by providing analysis and information from SACOG's planning work. Support public<br />
including<br />
efforts to raise awareness of these connections.<br />
information<br />
Strategy: Examine, analyze and steer funds and resources toward addressinq commute pattern<br />
24.3<br />
needs of those in job placement programs such as CaI-WORKS, those working nontraditional<br />
travel<br />
shifts, and those with reverse commutes as-a-guide-• for transit and supplemental travel<br />
employment<br />
imp'rovements.<br />
service<br />
Strategy: Ensure through examination, context sensitive design, and avoidance or mitigation of<br />
24.5<br />
system impacts wherever feasible, particularly displacement of residents, localized air<br />
transportation<br />
ATTACHMENT TO SACRAMENTO HOUSING ALLIANCE'S COMMENT LEI-rER ON DRAFT <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
2.5 Strategy: Continue to develop and apply social equity analysis methods and performance measures<br />
racial/ethnic inteqration and de-concentration of poverty.<br />
environment).<br />
racial/ethnic seqreqation and poverty concentration.<br />
federal grant funding from HUD.<br />
quality and noise impacts, when building improvements in<br />
low-income and minority communities<br />
adjacent to freeways, major roadways, and railroad corridors.<br />
12<br />
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eircomments <strong>sacog</strong> - Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
From: <strong>MTP</strong> <strong>Comments</strong> <br />
To: <br />
Date: 1/9/2012 7:16 PM<br />
Subject: Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
What are you commenting on?<br />
• Metropolitan Transportation Plan/Sustainable Communities Strategy<br />
Name<br />
Email<br />
Rick Bettis<br />
rckbettis40@gmail.com<br />
Do you want a written response?<br />
No<br />
<strong>Comments</strong> on the <strong>MTP</strong>/<strong>SCS</strong><br />
I believe the <strong>MTP</strong>/<strong>SCS</strong> is cvery comphrensive and apparently technically sound. SACOG staff should be<br />
commended on ther inclusive process and thoroughness of their work.<br />
I do have a few comments on some elements of the Plan that are primarily my view on priorities and emphasis.<br />
1. The growth projections should be monitored during implementation of the Plan to insure that the additions to the<br />
planned develoment are not made prematurely.<br />
2. SACOG is commendedfor ahieving increased per capita transit ridership even though the transit funding per<br />
capita has been reduced. This is due to emphasis on the Transit Priority Areas. It is important that these areas<br />
continue to recive priority treatment.<br />
3. Transit improvements such as the extention of LRT should begiven priority over road expansions such as HOV<br />
lanes or new roads such as the Placer Parkway.<br />
4.I agree that regulatory reforrm should be a priority so that good transit oriented compact mixed use development<br />
can be expedited.<br />
4. To facilitate compact mixed use infill significant public education efforts will continue to be necessary.This<br />
education should include the imprtance of environmental justice and equity.<br />
5.conjestion reduction as comtemplated in the Plan is a demonstration of what can result from good planning. We<br />
should deemphasize 'level of service" criteria and focus on motivating the public to use transit.<br />
6. There should a continued emphasis on funding transit operation and maintence of transit.<br />
7.Parking pricing and management should be used as a tool to motivate transit and bike-ped use and should not be<br />
considered as a means of funding other projects such as be considred by the city of Sacramento for a sports<br />
entetainment facility.<br />
8.Housing to meet the needs of all social economic levels should be facilitated. There should be a integrated and<br />
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inclusinary mix of housing types.<br />
9. A jobs housing fit methology needs to be developed and emphasized.<br />
9. Bike-ped connectivity and complete streets should be given a high priority.<br />
10. Goods movement needs to improved including the possible reestablishment of local short line freight rail.<br />
11. SACOG and local governments should be active in advocating for low emmisions vehicles and clean fuels that<br />
are under the regulatory jurusdiction of the State and Federl governments.<br />
12. In the Equity Chapter the access to facilities should include more emphasis on access by means of walking and<br />
transit. This is especially true for parks which should e accessible in all communities by walking.<br />
13. For new and replacement pavements considration should be given light colored "cool' pavements to reduce<br />
heat bulidup.<br />
14.Implementation of the forward thinking RUCS progam need continued emphasis. food trnsport is a major source<br />
of GHG and pollutant emmisons.<br />
15. SACOG should work with education providers to aquint the young with the importance of emmisions reduction<br />
to our health, economy and environment.<br />
Thank You Very Much for Your considration.<br />
rRck bettis<br />
Natural Resources Director League of Women Voters of Sacramento County<br />
Policy co-Chair Beathe Ca.- Sacramento<br />
Conservation-Co chair and Climate Change Chair Sierra club Sacramento and Mother Lode Chapter<br />
.<br />
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eircomments <strong>sacog</strong> - Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
From: <strong>MTP</strong> <strong>Comments</strong> <br />
To: <br />
Date: 1/11/2012 5:10 PM<br />
Subject: Comment on the <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> and EIR from<br />
What are you commenting on?<br />
• Metropolitan Transportation Plan/Sustainable Communities Strategy<br />
Name<br />
Email<br />
Becky Wood<br />
bwood@teichert.com<br />
Do you want a written response?<br />
No<br />
<strong>Comments</strong> on the <strong>MTP</strong>/<strong>SCS</strong><br />
There is a concept in the State guidance documents referred to as "distance maters". The idea being that the<br />
distance you need to transport material is important - to air quality, greenhouse gas production, congestion, vmt,<br />
etc. To help with minimizing the distance trucks move material you should plan for and protect your natural<br />
resources that are needed for build out of your plan. Therefore the plan should address aggregate resources<br />
needed for the life of the plan and the closest locations to supply the material. It should ensure that truck routes to<br />
those resources are protected and zoning includes the MRZ overlay. Otherwise enacting the plan will have a larger<br />
impact than necessary Please contact me if you need additional information to include in your plan..
NATURAL RESOURCES DEFENSE COUNCIL<br />
January 25, 2012<br />
Chair Susan Peters<br />
Board of Directors<br />
Sacramento Area Council of Governments<br />
1415 L Street, Suite 300<br />
Sacramento, CA 95814<br />
Re: <strong>Comments</strong> on <strong>Draft</strong> <strong>MTP</strong>/<strong>SCS</strong> 2035<br />
Dear Chair Peters:<br />
We appreciate the opportunity to comment on SACOG’s 2035 <strong>MTP</strong>/<strong>SCS</strong>. This plan truly<br />
implements the intent of SB 375 by designing a transportation network and land use pattern to be<br />
mutually reinforcing to reduce emissions, and your staff should be commended. In particular, the<br />
following achievements are of note:<br />
• By employing land use as a transportation demand management strategy, this plan<br />
achieves a remarkable 7% reduction in congested vehicle miles traveled per capita, a<br />
noteworthy first for the region. While regions across the country have widened their<br />
roads in vain attempts to alleviate congestion, SACOG demonstrates that the more lasting<br />
and effective approach is to reduce the distances between homes and daily needs and<br />
provide real transportation choices for local travel. This is such an important<br />
accomplishment it can hardly be overstated.<br />
• This plan responds to the strong and growing demand for real transportation choices by<br />
increasing transit service hours by 98% and bike lanes by 77%.<br />
• Job accessibility improves by 31% on average, with jobs-housing balance improving in<br />
14 out of 15 major employment centers. SACOG’s innovative approach of focusing new<br />
housing around existing employment centers stands as a model for other regions to<br />
consider.<br />
In the spirit of collaboration and continual refinement, we offer our thoughts below on the areas<br />
in which this plan could be improved.<br />
Ensure that SACOG’s Housing Product Mix Meets Market Demand and Strengthens the<br />
Regional Economy<br />
As noted in the <strong>MTP</strong>/<strong>SCS</strong>, the 28 cities and counties of the SACOG region have been working<br />
voluntarily to incorporate the Blueprint plans and policies into their local general plans, and thus<br />
the housing mix SACOG assumes with this <strong>MTP</strong>/<strong>SCS</strong> is far different than the original Blueprint<br />
base/case scenario. Both the local general plans and SACOG’s analysis of housing market trends<br />
www.nrdc.org<br />
111 Sutter Street NEW YORK ⋅ WASHINGTON, DC ⋅ LOS ANGELES ⋅ CHICAGO ⋅ BEIJING<br />
20 th Floor<br />
San Francisco, CA 94104<br />
TEL 415 875-6100 FAX 415 875-6161
seem to suggest a preference for a greater variety of housing choice—in particular, increased<br />
demand for attached and smaller lot single family product nearer amenities and with greater<br />
transportation choices. Compared to the current available housing choices, the <strong>MTP</strong>/<strong>SCS</strong> moves<br />
the region in the right direction.<br />
But when considering the latest available housing market studies, it appears that the SACOG<br />
<strong>MTP</strong>/<strong>SCS</strong> may not go far enough in the right direction. A November, 2011 report from the<br />
Urban Land Institute (ULI) entitled The New California Dream compares the current (2010)<br />
supply of various housing product types to future (2035) market demand in California’s four<br />
largest regions i . The ULI report makes two particularly relevant findings for the Sacramento<br />
region:<br />
1. The 2010 supply of large lot single family housing (>1/8 th acre) in the SACOG region<br />
exceeds the projected demand for this housing type in 2035. Stated more clearly: the<br />
SACOG region already has more of this product type than will be needed in 2035, even<br />
assuming population growth. By contrast, the demand for small lot single family and<br />
attached products is strong and exceeds current supply by approximately 453,000 units,<br />
illustrated below in Figure 4.1.<br />
2. The projected 2035 demand for homes near transit is so strong that even if all new units<br />
constructed in the SACOG region between 2010 and 2035 were located near transit, the<br />
2035 demand would still outstrip supply, as depicted in Figure 4.2, below.<br />
2
Consideration of this information—which arguably represents the most detailed supply and<br />
demand analysis of SACOG’s housing market conducted to date—casts a new light on<br />
SACOG’s land use pattern. The ULI study admits that, while the best available market<br />
information finds little to no new demand for large lot single family homes, there will be some<br />
exceptions to this trend in niche markets. However, the general conclusion, which seems to be<br />
consistent across all four regions, is that there is a surplus of large lot single family homes in<br />
2010 as compared to 2035 demand: in SACOG’s case, that surplus is projected to be the<br />
equivalent of 193,000 homes. By contrast, the <strong>MTP</strong>/<strong>SCS</strong> projects that 29% of all new growth<br />
between 2008 and 2035 will be in the form of large lot single family homes. When compared<br />
with a robust market study that claims very little to negative demand for this housing type,<br />
SACOG’s housing mix appears a cause for concern.<br />
In addition to the threat posed to valuable natural resources by proposing to house nearly a third<br />
of the next increment of growth in large lot single family homes, there is an economic risk.<br />
Overbuilding a product type which appears to already be oversupplied, even assuming 23 years<br />
of robust population growth, can threaten the value of existing homes of this product type. We<br />
strongly urge the SACOG board to take note of this and other similar market studies and to<br />
consider the broader regional economic impacts.<br />
Second, the study finds a robust demand for homes near transit. In 2008, only 14 percent of<br />
housing units and 27 percent of employees were within SACOG’s definition of transit priority<br />
areas. Over the life of the plan, SACOG locates 38 percent of new dwelling units and 39 percent<br />
of new employees in these areas. SACOG’s investment in new transit service brings high quality<br />
service to an additional 152,216 existing dwelling units and 240,013 existing employees. While<br />
the provision of new transit to both new and existing units is the equivalent of serving all new<br />
growth with transit, the fact remains that with this next increment of growth, SACOG locates<br />
fewer than half of new homes and jobs near transit. As SACOG continues to monitor<br />
implementation of this <strong>SCS</strong> and prepare for either a mid-cycle update or the next <strong>SCS</strong>, we would<br />
strongly encourage you to focus development in areas that provide people with real<br />
transportation choices.<br />
3
We acknowledge that the ULI report is just one market study out of many and that all such<br />
projections are by nature uncertain. Still, a report that projects a future surplus of nearly 200,000<br />
housing units of a product type that SACOG continues to build should be given some serious<br />
consideration. Prior to its next RTP, we would encourage SACOG to conduct or continue to<br />
refine its own market study to ensure SACOG’s next 20 years of growth are appropriate to the<br />
market demand and help to strengthen the regional economy.<br />
Invest Transportation Dollars Strategically to Deliver Real Results<br />
SACOG puts its money in the right places, and critically, operates within its means. The new<br />
plan spends 12.5% less than the existing one, but the decrease is spread intelligently: a 20%<br />
decrease in capital projects versus only a 9% decrease in O&M, consistent with a “fix-it-first”<br />
investment strategy. It proposes to spend 8% of total revenues for bike and walk projects, plus<br />
include bike lane and sidewalk features on most arterial projects, dwarfing other region’s efforts<br />
to promote active transportation. The plan spends only 3% of revenues on state highway<br />
improvements, which no other region has done in 50 years of RTPs. SACOG’s fiscal constraint<br />
should be a model for other California regions, some of which simply assume new revenues to<br />
meet an ever growing appetite for new projects. And yet, in spite of this sound investment<br />
strategy, unfortunately 85% of all trips in the SACOG region by 2035 are still made by car.<br />
Below we make recommendations for strategies SACOG might consider to improve the return<br />
on its transit investments.<br />
• Prioritize transit investments in high-density arterial corridors. High density arterial<br />
corridors with no or limited transit service present strategic investment opportunities and<br />
should be prioritized to receive funding. SACOG should flag any sufficiently dense<br />
arterial corridors that currently lack this transit service and work with local jurisdictions<br />
and transit operators to accelerate service there. In arterial corridors where transit service<br />
doesn’t currently exist, service introduction should be timed with a sufficient density of<br />
homes or jobs along these arterial corridors.<br />
• Ensure sufficient densities and strong ridership potential prior to initiation of costly<br />
capital transit projects. As suggested by strategy 28.9, bus transit may be a less<br />
expensive and more practical investment in key new transit corridors prior to capital<br />
intensive rail projects. It may make sense to defer some of these rail projects until bus<br />
service has proven that strong ridership demand exists in these corridors.<br />
• Schedule road construction to occur later in the plan to avoid triggering growth<br />
outside existing urban areas. Any capacity increases at the urban edge should be phased<br />
to occur during the plan’s later years to ensure they are not growth-inducing, but rather<br />
demand management strategies. Construction of these costly capital facilities should be<br />
initiated only once demand is strong enough to warrant their development.<br />
• Improve parking policies to support walkable communities and transit use. Chapter<br />
3 specifically notes that parking policies may be a barrier to realization of SACOG’s<br />
desired land use pattern. Strategies 3.7 and 16.1 can help to address what is surely one of<br />
the most powerful drivers of the decision to drive in the SACOG region--the abundance<br />
of free and available parking--and we strongly support prioritizing these research efforts,<br />
and moving towards implementation of their findings. Modifying current parking<br />
4
egulations can help to ensure that developers are able to deliver the walkable, transitoriented<br />
housing the market is demanding. Well designed, parking pricing policies can<br />
help pay for business improvement districts and shuttles, boost returns for local merchant,<br />
and support increased transit use.<br />
Additional Policies and Recommendations<br />
In addition to detailing its proposed investments and land use pattern, this plan includes an<br />
excellent chapter on additional policies and strategies to ensure effective implementation. This<br />
chapter could be strengthened by providing more detail on the state policies which will be<br />
necessary to realize the promise of this plan. The recent Supreme Court decision on the<br />
elimination of redevelopment agencies, for example, provides a significant complication for<br />
implementation of this plan.<br />
This plan can take a step towards achieving its goals by articulating clearly for state policy<br />
makers which additional tools will be necessary for implementation.<br />
In particular, Strategy 1.2 calls for regulatory reform at the state, national and local levels to<br />
encourage Blueprint-style growth. More detail on the nature of such reforms would help guide<br />
policymakers. Strategy 18.4 mentions working with the state Strategic Growth Council. We<br />
would strongly recommend that SACOG work closely with the Council, the Governor, and the<br />
Legislature to advocate the necessary reforms to ensure this plan delivers on its promise. This<br />
collaboration should begin with a presentation to the Council with recommendations for<br />
administrative and legislative solutions to remove barriers.<br />
We thank you for your continued excellence in leadership and look forward to working with you<br />
in the weeks and months to come.<br />
Sincerely,<br />
Amanda Eaken, Deputy Director for Sustainable Communities<br />
Natural Resources Defense Council<br />
Meea Kang, President<br />
California Infill Builders Association<br />
i http://www.uli.org/ResearchAndPublications/~/media/ResearchAndPublications/Report/ULI%20Voices%20Nelson%20The%20New%20Califor<br />
nia%20Dream.ashx<br />
5
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
Jim Seif<br />
Process is a sham. Decisions are already made by developers; we didn’t get to<br />
sit at the table when plans were being made.<br />
He and others are not being properly represented at SACOG by their local<br />
elected who sit on SACOG board; local SACOG representatives don’t record or<br />
report back their SACOG actions.<br />
SACOG says we have local control, but SB 375 says communities will be sued if<br />
not incompliance with regional plan.<br />
SACOG is deciding how, where, and when people should live and that’s wrong.<br />
Yuba and Sutter are different from Sacramento and our elected officials aren’t<br />
hearing us say we don’t want this.<br />
Process should include real public input for all citizens. If citizens could vote on<br />
SACOG Board, they would vote to get out of SACOG.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
Debbie Gaylord<br />
Disappointed the staff presentation didn’t get into meat of plan because did go<br />
through it to come up with real questions and concerns after reviewing plan.<br />
Reference page 2-9 related to Public Participation Plan for stakeholders<br />
representing social equity, bicyclists, pedestrians, etc., but is wondering about<br />
people like me who want to drive my car and live on ¼ acre. This plan doesn’t<br />
allow for that. .<br />
Beale doesn’t pay sales tax to county so the county has no authority over their<br />
air emissions; seems detrimental to Yuba County to have to consider them an<br />
established community in the county (in the same way as other established<br />
communities).<br />
Referenced page 3-13, real estate forecasts for small lot, mixed use, and<br />
commercial use and is concerned that mixed-use housing cannot be financed.<br />
Would like the source for information on that page.<br />
Referenced pages 3-18 and 3-19 regarding number of houses on a large lot,<br />
attached and detached. This says you can put 5-8 homes on a large lot and 8-25<br />
homes on a large lot. This can’t be done, I have asked developers and they say<br />
you can’t build 25 detached houses on one acre. Yuba and Sutter county<br />
residents don’t want to live that way. Many of the residents came to Yuba and<br />
Sutter counties for affordable housing.<br />
Referenced page 3-20 regarding jobs-housing fit measure to assess the fit at<br />
smaller geographic scale for local workers and affordable housing. This sounds<br />
like Yuba and Sutter counties would only get help attracting low-wage jobs and<br />
that’s not what they want.<br />
Have questions and would like answers.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
John Larimer<br />
United Nations has propagated global warming hoax. United Nations has<br />
abandoned global warming. Agenda has percolated to local level. Agenda 21.<br />
Commenter read resolution approved by Republican National Committee on<br />
January 13- Resolution Exposing United Nations Agenda 21.<br />
We have AB 32, SB 375 all to control greenhouse gas emissions. Why? Because<br />
CARB is trying to control carbon emissions and climate change. CARB figured out<br />
most emissions are from freeways so they want to change fuels and restrict<br />
driving. Carbon emissions are not causing any trouble at all, temperatures are<br />
not rising even a half a percent.<br />
In the process of trying to fix global warming, which is non-existent, they want to<br />
stack us and pack us, take away automobiles, telling us where to live, sticking us<br />
in the projects. If you want to see where this is going look at Siskiyou County.<br />
Water rates have gone up 800%, farmers are literally being driven off their land.<br />
Concerned that the <strong>MTP</strong> is an extension of United Nations Agenda 21 and fears<br />
loss of personal freedoms and property rights if this plan is supported/adopted.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
Carla Verga<br />
Upset this is supposed to be a meeting for Elected Official and that there are not<br />
very many officials from Yuba County. Concerned plan is being rubberstampedupset<br />
to see people supposed to be representing us selling us up the river.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
Bob Sweringen<br />
This plan is part of agenda 21. Agenda 21 is about forcing people to live in high<br />
density housing. One way doing that is by coming to counties like this and<br />
offering incentives or money to implement this so counties are agreeing because<br />
they need money. If you go to northern California the people there will tell you<br />
they are destroying their land. Can’t access forest lands anymore, no longer<br />
allowed as recreation areas.<br />
Ultimately what they want is for everyone to live on corridors. Want to take<br />
agriculture and move it to other countries so if you’re a farmer in America, they<br />
will change what can happen on your land. Bottom line, start learning about<br />
Agenda 21. Understand what you are buying into and committing us to.<br />
This plan is telling you that you will live in apartments. They are telling us that<br />
the number of single family homes will be less. What if we don’t want to live in a<br />
high rise apartment?<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
Larry Berga<br />
Agenda 21 defines sustainable development, this presentation just skimmed over<br />
it. Can you tell me what sustainable development means as referenced in this<br />
plan.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
Chuck Miller<br />
Believes plan has direct relationship with United Nations Agenda 21. Believes<br />
Agenda 21 is implementing communism and that the first thing communist<br />
regimes do is get rid of old people. These folks are doing what the law is telling<br />
them (AB 32 and SB 375) to do and there is something wrong with that.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
Vera Correa<br />
As part of the plan she has seen infrastructure, sidewalks, signs that tell kids<br />
where they can walk safely. Need to make it so much safer for children and<br />
pedestrians and we need this money, the county doesn’t have it. This is<br />
something that we as citizens need to do, it’s not about Republicans or<br />
Democrats.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
Jerry Antonetti<br />
Worked at Caltrans before there was a SACOG. Cities and counties used to<br />
decide where money was spent. George Bush started these MPOs. Caltrans had<br />
never administered money like this. Now we see SACOG is involved is in Agenda<br />
21.<br />
Does not see how this plan works with city councils and other local governments<br />
that are able to provide the necessary infrastructure in the transportation plans<br />
with air quality maintenance districts regarding air pollution and contamination.<br />
Believes it is now a matter of land use planning via air quality controls. AQMD is<br />
really the true power behind this. Land Use and transportation planning by air<br />
quality controls.<br />
AQMD has very divisive factor here, people will die from cholesterol at<br />
McDonalds before they die of GHGs. Spoke to new auto technology.<br />
Believes this is all based on false science and premises. I’m involved in Agenda 21<br />
lawsuit against US Forest Service and Bureau of Land Management regarding<br />
shutting down trails and access to forest land.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
Pat Miller<br />
Referenced reading from Agenda 21 where private property rights go against<br />
what is good for society over all with the goal for society not the individual.<br />
Believes government will start taking away freedoms and then next put people in<br />
stack and pack houses, dictate what people drive, and take people's property<br />
and guns.<br />
To get the federal funds for sidewalks and signs you have to cooperate with<br />
executive order and environmental section which is form of bribery.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
Dot Sweringen<br />
If it is not broken, why are we doing it?<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
Bob McClard<br />
To get to the point this is forcing or encouraging people to live more densely<br />
packed. By getting people to live closer together and closer to work. Were<br />
people asked if they wanted to live in denser housing?<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
Anonymous<br />
Where will funding for high density housing come from? Is it all government<br />
subsidized?<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Yuba County Elected Official Information Session Public <strong>Comments</strong> from January 25, 2012<br />
Anonymous<br />
Wanted to say thank you. Lot of these other commenters are older; they<br />
won’t be here in 20 years. My son will. Appreciate planning for better air<br />
quality.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Lincoln Community Meeting <strong>Comments</strong> from January 9, 2012<br />
Anonymous<br />
Comment about which jurisdictions may have abstained from supporting the MOU<br />
for the <strong>MTP</strong>/<strong>SCS</strong>.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Lincoln Community Meeting <strong>Comments</strong> from January 9, 2012<br />
Anonymous<br />
This is a republic not a democracy.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Lincoln Community Meeting <strong>Comments</strong> from January 9, 2012<br />
Anonymous<br />
Principle disagreement about federal/state/regional influence on local land use.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Lincoln Community Meeting <strong>Comments</strong> from January 9, 2012<br />
Bob Rafighi<br />
All of the beauty we have, you are telling me we have to change. It is not clear<br />
what part of the city or region are included in the drawings, mixed circles and<br />
color scheme. How do you draw a circle on private property without infringing on<br />
my property rights?<br />
The commenter voted for city council members and thinks he is being told he has<br />
to accept funds and other aspects of plan. He doesn't want to go forward. He<br />
hasn't seen any buses go around area with more than 2 people in them. Believes<br />
there is also an assumption about transportation needs for older people. He is 75<br />
years old and doesn't want to be told how to travel and live.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Lincoln Community Meeting <strong>Comments</strong> from January 9, 2012<br />
John T. Larimer<br />
The "right to notice" is a fundamental right and that the plan was not adequately<br />
noticed. The plan that he was only able to download on Sunday was dated<br />
December 10, 2011. The earliest comment was December 19. The plan was put<br />
on the internet in a form that he was not able to download on his computer.<br />
Concerned about command economy and control of his property and rights.<br />
This is reminiscent of communist countries of which he listed countries by<br />
example. The high language in the plan talking about utopia is more like<br />
enslavement; even if we have our property will not be able to enjoy it.<br />
Expressed concern about the comment period during the holidays.<br />
Don’t know how you can have an environmental impact report without clarity of<br />
what the report is studying.<br />
Water price increases for farmers and ranchers have gone up 800% in<br />
anticipation of four damns being blown up. Cost is astronomical. If we want to<br />
be able to eat, can’t be having waters stolen for salmon and trout.<br />
Concerned government is creating a bureaucratic monster with decisions that<br />
won’t be made by local council members and Board of Supervisor. Concerned<br />
about the authority that planners and the rest of this bureaucracy will have.<br />
1033 pages. Has the mayor read this?<br />
Elected officials are relying on the planners to tell them what to do. You are<br />
picking winners and losers in this action.<br />
At a time when state, federal, counties and cities are broke, government<br />
planners and NGO employees are spending tons and tons of money and hours to<br />
steal freedom and destroy prosperity.<br />
They are planning on increased population while we see thousands of people<br />
leaving California.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Lincoln Community Meeting <strong>Comments</strong> from January 9, 2012<br />
Jim Ricketts<br />
What is the source of the power in addition to the local laws and legislation and<br />
the power to disburse funds from the public purse? Concerned that this<br />
authority allows for funding expenditures to projects that serve narrow interests<br />
and that funds are taken from citizens and passed onto the interests of those<br />
authorities. Funds always come with strings attached.<br />
Concerned that government will take away single family homes and ability for<br />
people to use private autos as well as freedoms to live, work, and shop where<br />
people want. We will decide where and how we are going to live not SACOG.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Lincoln Community Meeting <strong>Comments</strong> from January 9, 2012<br />
Kathy Dorsey<br />
Question regarding Financial Stewardship and list of various funds on overhead<br />
and portion attributed to Placer County. How was the portion apportioned to<br />
Placer County calculated?<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Lincoln Community Meeting <strong>Comments</strong> from January 9, 2012<br />
Pat Patterson<br />
Helpful to listen and ask what is applicable to me. Ask the dear Lord to give me<br />
guidance to do the important thing even if it will cost me my life in order to do<br />
what is right and moral.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Lincoln Community Meeting <strong>Comments</strong> from January 9, 2012<br />
Judy Roberts<br />
What are our abilities to assess the efficiencies of public transit services that we<br />
have right now?<br />
Fair to say it (transit service) operates at a deficit?<br />
Highways are a need with demand, but rail and transit runs at a deficit. In the<br />
future there will be a transit cost that is greater and will require more funds be<br />
taken from people or their cars will be taken away.<br />
Road congestion question about carpool lanes and inquired about the<br />
efficiencies of carpool lanes to reduce congestion. Would seem that after seeing<br />
so many of years of this inefficiency, it would seem that this isn’t where funds<br />
should be spent.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Lincoln Community Meeting <strong>Comments</strong> from January 9, 2012<br />
Lois Engle<br />
New resident of Placer County with property on Sierra College Boulevard. Was<br />
not told when she purchased it that there were planned changes that would<br />
impact her grazing lands. Real estate and the Town of Loomis should have<br />
provided her information for what was the potential for the land she purchase.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Lincoln Community Meeting <strong>Comments</strong> from January 9, 2012<br />
Cynthia Atkinson<br />
It is dishonest to plan meeting to take place during the holidays because you get<br />
the smallest outcome of input from the smallest number of people and therefore<br />
go forward. Meeting should have been scheduled during a time when the<br />
majority of people would be able to attend.<br />
Believes that the suggestions and guidelines for the disabled in the <strong>MTP</strong> were<br />
developed before being given to the disabled. Difficult for an elderly person to<br />
take the bus to a meeting or service. When you are disabled, how will you feel<br />
about going out yourself in that fashion and looking for your public<br />
transportation and then waiting and trying to get on as an older man? Lots and<br />
lots of people use the scooters for mobility. Most of the elderly are projected to<br />
need more help than to be dropped off at a bus.<br />
As a social worker, believes that there is a misappropriation of funds to whatever<br />
small group at the top decides is the priority for funds. Generally concerned that<br />
government is deciding what to spend money on and believes it is the people<br />
who should decide how money is spent.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Lincoln Community Meeting <strong>Comments</strong> from January 9, 2012<br />
Judi Caler<br />
Wanted to encourage the residents of Lincoln to drop out of this activity and<br />
appreciate that you have not accepted the funding.<br />
Where are these funds coming from if our country, state, county and cities are<br />
broke?<br />
Seem to think that funds from the federal government is free. Funds from<br />
stimulus projects and grants will deplete any savings or inflation that we have<br />
worked for. Need ability to opt out of this free money.<br />
Concerned that the plan is a recipe to take over society. Doesn't believe the plan<br />
is about protect the environment but about taking control of people.<br />
Believes global warming is a joke and a lie. Research since 1990 has failed to<br />
substantiate any direct man made cause for global warming. A consensus is<br />
nothing more than an absence of recorded disagreement.<br />
Believes that local representative government is almost obsolete. When<br />
government wants the public involved, it is to give the appearance of public<br />
participation and to marginalize any opposition to its plans. These are called<br />
visioning meetings with unreasonable alternatives as choices.<br />
It is audacious of planners to determine that they are better than the rest of us<br />
to make decisions better than the rest of us. In Lincoln, stand up for your rights<br />
and the constitution which makes laws for the common good.<br />
Concerned that traveling by transit will be the only travel option.<br />
Concerned local governments are using federal monies which come with strings<br />
attached for stack and pack housing which may not be of all of our choosing.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Lincoln Community Meeting <strong>Comments</strong> from January 9, 2012<br />
Ruth Crone<br />
Is this a map of what you want it to look like in the future or what you want it to<br />
look like now? Question specific of rural residential communities in Yolo County.<br />
What is the difference between current map and the map you want us to be on?<br />
Map is still assuming that our region will be growing. Heard several references to<br />
state and federal statutes, and legal foundation at SACOG, asked if SACOG staff<br />
could elaborate so public could understand.<br />
SACOG and its plan create another level of separation because local jurisdictions<br />
joined into this regional function with support of state and federal government in<br />
some cases.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Colfax City Council Meeting <strong>Comments</strong> from February 8, 2012<br />
Neil Wilson<br />
Concerned about loss of private property rights, freedom and judgment with<br />
everything being planned by government.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Colfax City Council Meeting <strong>Comments</strong> from February 8, 2012<br />
Ed Duffek<br />
Does not understand how priority development areas, sustainable living is going<br />
to take place. Are we going to be forced to do this? Is he going to move into a<br />
stack building? The map showing that there will be very little rural development.<br />
Does not understand how moving a lot of people into a little city will conclude<br />
the global warming.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Colfax City Council Meeting <strong>Comments</strong> from February 8, 2012<br />
John Larimer<br />
This plan is stacking and packing housing and development.<br />
This planned ties in with United Nations Agenda 21 and that ICLEI is the United<br />
Nations' private organization immediately beneath and apart of Agenda 21.<br />
There is no such thing as greenhouse gases.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Colfax City Council Meeting <strong>Comments</strong> from February 8, 2012<br />
Judy Caler<br />
Encouraged the city council to continue avoiding this scheme.<br />
Government has its eyes set on money that it believes is theirs when it really<br />
belongs to the people. Bureaucrats are unknowingly threatening our freedoms.<br />
How do planners know better than us? To projection that the population will<br />
increase is an insult to us.<br />
Where in this document is any authority given to private property rights?<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Colfax City Council Meeting <strong>Comments</strong> from February 8, 2012<br />
RayAnn Vowell<br />
Sustainable development sounds very good. What it really is a leading to an<br />
abolition of private property rights. They are trying to get people off their farms<br />
and off their lands. Most Americans do not know or understand the integrated<br />
policy of sustainability.<br />
Concerned that this plans has ties with United Nations Agenda 21 and will lead to<br />
control over land, water use, energy use, food production, and number of<br />
children families can have.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Colfax City Council Meeting <strong>Comments</strong> from February 8, 2012<br />
Bob Refugi<br />
Problem with the word sustainability is that everything is supposed to be<br />
sustainable. We have always had everything we need in this country. Suddenly<br />
we have this agenda that is appearing before everyone in the US that says we<br />
have problems with water, endangered species, utility meters...everything has to<br />
be sustainable.<br />
I don’t think my utility meter needs to be smart. It is a fabricated crisis that we<br />
are jumping against. Do you think we are going to be here in 2035 to cut<br />
ribbons?<br />
Where is the transportation to forests and farmland? Concerned about not<br />
having access to forests and farmland. Local land use and property rights will be<br />
taken away.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Colfax City Council Meeting <strong>Comments</strong> from February 8, 2012<br />
Dwayne Armstrong<br />
Disagreed with the outcome that SACOG was proposing. If you put people into<br />
confined areas, major pollutions are going to go up. There will be impacts to<br />
sewer system, crime will increase and government is going to control the water.<br />
A lot of cities are going to reclaim water.<br />
By 2035, SACOG’s agenda is going to change. How can you come up with a<br />
conclusion when you do not have all the facts?<br />
Technology is going to replace the fossil fuel burning.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.
Colfax City Council Meeting <strong>Comments</strong> from February 8, 2012<br />
Pat Patterson<br />
Concerned about being able to grow own food and that government may take<br />
that away. We need to be extremely careful and watch the details.<br />
The comments here are summaries of the oral testimonies provided at this public meeting.