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Comment 2 for Comments on staff's approoach on residential and commercial projects under the CEQA (ceqa-rescom-ws) - 1st Workshop.


First Name: Bob
Last Name: Johnston
Email Address: rajohnston@ucdavis.edu
Affiliation: UC Davis

Subject: Residential and Commercial Projects: Transportation GHGs Performance Standard
Comment:
Doug,

Re. The need for a performance standard for residential and
commercial projects with respect to transportation GHG emissions 

1.  On p. 15, par. 3, under Residential and Commercial Projects,
the ARB staff requests "input... on appropriate performance
standards for these sub-sources..."  Transportation is one of the
sub-sources.  "Performance standards that already exist....are
preferable."  On pp. 14-15 the rept. says that the performance
standards are for carbon efficiency and will have to "reach beyond
current State mandates by a substantial amount..."  By viewing
Attachment B, one can see that, until local climate plans or
sustainable communities plans are adopted and approved by the ARB
as attaining the SB 375 targets, or if not an MPO county,
attaining the SB 32 budgets, Performance Standards, will be the
relevant ones.  So, for the next several years, performance
standards will be paramount to getting early GHG reductions, which
is the purpose of this whole document and proposed rule. 

2.  I can suggest an existing performance standard for part a. in
Box 3, for transportation.  The U.S. FTA New Rail Starts
evaluation procedure for funding passenger rail proposals has a
category for Transit Supportive Land Use.  This category is
important in that it gets half the weight in the evaluation
procedure.  This system has been used successfully for several
years.  It is clear from empirical evidence and from modeling
exercises that we must get mode shifts from  cars to  walk, bike,
and transit, in order to substantially reduce GHG emissions from
personal travel.  What works for transit also works for walk and
bike.  The recent Rodier paper done for your staff reviews the
modeling literature and the recent Ewing book and review for NRDC
sent to your staff review the empirical literature.  In addition,
the Frank review of URBEMIS for EDF?, also critiques and
summarizes the empirical studies.  Density is critical, along with
good transit service (rail or BRT), sidewalks, land use mix, and
centrality within the urban region.  

The most important FTA papers are:  FY 2009 New Starts and Small
Starts Evaluation and Rating Process, for an overview, and
Reporting Instructions for the Section 5309 New Starts Criteria,
for some details.  You should be able to google these.  If you
have problems, let me know.  I am aware of these Federal rules and
agency procedures, because I published a critique of the previous
FTA evaluation method about 20 years ago.  Also, I did a
historical paper on the downzonings around many BART stations,
after it opened, and lobbied BART about 20 years ago to require
density before opening a station.  This was a widespread argument
across the U.S. and filtered up to FTA. 

You could, alternatively, require set levels of population
density, land use mix, walkability/bikeability, and other urban
design values, relying on the "4 Ds" and "5 Ds" studies.  Caltrans
did a report on them, Assessment of Local Models and Tools for
Analyzing Smart-Growth Strategies, July 27, 2007.  It can be
googled from the Caltrans website.  These methods have been used
by California local govts successfully.  Jerry Walters, from Fehr
and Peers, who spoke at the Haagen-Smit Symposium, is the expert
on this method.

2.  For part b. in Box 3, I suggest your URBEMIS model, or any
other similar site-level analysis tool.  Evaluating the VMT
dependent on a single project is inherently uncertain, though. 
That's why the "AND" is so important between a. and b., requiring
the project to meet both sets of criteria.  

3.  In my many modeling studies of the Sacramento region, with
several travel models and urban models, I found that charging for
worktrip parking was usually the most-effective policy.  Density
and transit is good, but charging for parking at workplaces is
also needed to get substantial mode shifts to walk, bike, and
transit.  So, parking with hourly and daily charges should be a
criterion in both part a. and part b.  It is not mentioned in the
FTA ratings system and is underappreciated in URBEMIS and the 4 Ds
systems. 

I hope these ideas are helpful.  I do appreciate the great efforts
of you and your staff to meet the AB 32 scoping deadlines and the
CEQA guidelines calendar, also. 

Bob
 

Robert A. Johnston, Emeritus Professor                            
                    
Dept. of Environmental Science & Policy
University of California, Davis
Home/Office Phone: 530 582-0700
15299 Wolfgang Rd., Truckee, CA 96161
Mobile Phone: 530 559-0032
http://www.des.ucdavis.edu/faculty/johnston/index.htm

 

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Date and Time Comment Was Submitted: 2008-10-30 21:27:50



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