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