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Comment 35 for Comments in general on ARB Implementation of SB 375 (sb375-general-ws) - 1st Workshop.
First Name: Jerry
Last Name: Walters
Email Address: j.walters@fehrandpeers.com
Affiliation: Fehr & Peers
Subject: MPO Forecasts of Ambitious, Achievable GHG Reductions
Comment:
I commend the MPOs for their considerable efforts in assessing their GHG reduction potential. In many cases, the MPOs drew upon many months of public outreach and stakeholder discussions, scenario testing and modeling and “bottom up process” within the regions to assess their GHG reduction potential. The material they presented at the May 25 RTAC meeting represents an impressive set of individual and collaborative efforts to identify “ambitious and achievable” land use and transportation strategies in response to SB375. I also understand that many of the MPOs are planning to further refine and evaluate the planning scenarios over the coming months. My comments below are offered in the spirit of helping the MPOs to fine tune and amplify strategy proposals, and to improve their confidence in and accountability for the resulting GHG estimates. They are also intended to help ARB bring consistency and equity to its interpretation of the findings and to assess whether the MPO scenarios and estimates have gone far enough in reducing travel and GHG. 1. Ambitiousness of Land Use Scenarios The four major MPOs envision a shift in the real estate market with the recovering economy toward significantly reduced emphasis on large-lot single family development. All project that 60% to 80% of their regions’ growth between 2020 and 2035 will be in the form of attached units or small lot single-family. Under their most ambitious smart growth planning strategies, SCAG and SANDAG and MTC all project that at least 85% of their growth could be focused on attached and small-lot housing. MTC, SANDAG and SACOG anticipate locating most of their regions’ growth in transit priority areas, while SCAG projects only about half of its growth will occur in designated transit areas. My question is whether these ambitious assumptions are not, in fact, closer to what we can realistically anticipate than are the “achievable” scenarios. Testimony last year to the RTAC by representatives of the development community, and recent reports on real estate development trends and forecasts by Price Waterhouse and others, suggest that the most ambitious land use forecasts presented by the MPOs may actually be more in line with the real estate market than the achievable forecasts. Information provided by SCAG demonstrates the important difference between what experience tells and what is, in fact, foreseeable. SCAG’s table summarizing the planning intentions of its sub-regions indicates that they are intending or exploring potential mixed-use, transit oriented, infill and compact development at levels that are double or triple the levels they identify as “fully adopted”. In contrast, information presented by Kern COG seems to suggest that the land use vision of local planners is limited to the development proposals they’ve been presented in the past rather than a projection of the locations and forms of development that the real estate market has the potential to deliver in the future. 2. Ambitiousness of Roadway Pricing Assumptions Based on forecasts from ARB, the regions assume an increase in vehicle maintenance and fuel prices, with real automobile operating costs per mile in 2035 about 45% greater than 2005, expressed in constant dollars. While this may seem like a significant increase and a deterrent to automobile travel, it is important to note that 2005 California gasoline prices were about $2.50 per gallon. Price increases that have already occurred since 2005 represent about half of the 2005-to-2035 growth projected by ARB. Relative to today’s fuel prices, the 2035 projections translates to an increase of less than 1% per year. Even when combined with the MPOs roadway pricing assumptions, the low growth in auto operating costs results in a continued erosion in roadway user costs per mile traveled, a phenomenon that has produced profound loss in real transportation funding over the past 40 years. 3. Mutual-Supportiveness in Strategy Sets SCAG, SANDAG and SACOG also anticipate significant increases in transit service per capita by 2035. However, among the three largest MPOs, it is MTC that projects the greatest increase in per capita transit ridership. This appears to support the notion that, for regions with well-established transit networks, a combination high levels of roadway pricing and strong orientation of land use growth toward transit opportunity areas produces the greatest gains in transit use. It’s not apparent that the other regions have yet found the “sweet spot” of combined land use, roadway pricing and transit investment. 4. Worsening Jobs/Housing Balances In several regions, including MTC and SACOG, the regional balance of jobs and housing is projected to become worse in the future in spite of the SB 375 requirement that regions achieve a feasible balance. SCAG might also consider whether its “achievable” blueprint scenario fully reflects the region’s best efforts to balance jobs and housing within its individual sub-regions. 5. Differences in the Baseline GHG and Strategy Effectiveness The results presented to the RTAC contained an apparent inconsistency in San Diego’s ability to achieve significantly greater benefits from travel demand management (TDM) strategies than the other major regions, even though its list of strategies appears less ambitious. This finding accompanies information submitted by SANDAG indicating that its baseline 2005 GHG per capita was about 20% higher than the levels reported by the other major MPOs. ARB should have a method of assessing and resolving apparent inconsistencies in the MPOs’ reported assumptions and findings. 6. Counter-Intuitive Findings and Need for VMT Information Counter-intuitive findings exhibited in the findings presented to the RTAC also include the fact that the achievable 2020 reduction percentages for the three largest MPOs were actually higher than projected reductions in 2035. Several possible explanations were mentioned, such as pre-2020 implementation of roadway pricing and vehicle fuel economy and low-carbon fuel standards, but several RTAC members believed that more information was needed in order to judge the credibility of these assumptions and results. They recommended that ARB obtain more complete information, including forecasts of vehicle miles traveled (VMT), from the MPOs before concluding that the performance dip should be adopted into targets. The reported GHG reductions blend the effects of reduced VMT with the assumed effects of improved vehicle fleet efficiency and the carbon content of fuels. SB375 places specific emphasis on the degree to which coordinated regional land use and transportation strategies reduce VMT as a distinct component of GHG reduction. Even though GHG may be deemed the primary measure of performance under SB375, it seems essential that ARB also be provided each MPO’s VMT statistics in order to address apparent anomalies in the other data submitted by some of the MPOs. 7. Consistency and Equity in Rules and Assumptions Information submitted by the MPOs also raises questions on the consistency of key assumptions from region to region. For example, Fresno, Kern and SJCOG appear to be using different population growth rate assumptions than one another and than provided by the Department of Finance. The Central Valley MPO’s have also raised important questions concerning the assumptions and forecasting methods that should be used to project interregional travel. Kern and Santa Barbara have also raised concerns about the reasonableness of holding MPOs accountable for the GHG generated by travel from state and federal institutions over which they have no control, such as prisons, military bases and universities. 8. Reasonableness Checks Before beginning to compare the MPO forecasts to one another and draw conclusions related to targets, ARB should perform several technical reasonableness checks on the modeling data submitted. This need not be a complex modeling process, but can be accomplished using information on typical effectiveness of land use and TDM strategies that the University of California has been preparing for ARB. MPOs such as Fresno, Kern and San Luis Obispo submitted evidence that they had improved their models with 4D sensitivities and based their target-setting submissions on results from the more sensitive models. Other MPOs such as SCAG, SANDAG and MTC have not been as clear on the degrees to which their models are sensitive to key land use, demand management and transportation system strategies. All three have mentioned longer range efforts to improve their models to “activity based” frameworks, and SCAG and SANDAG have also mentioned more immediate improvements to include 4D and other enhancements to their trip-based models and to independent visioning and sustainability tools. However, none have reported whether the models used in scenario analyses submitted to ARB were based on improved models. This raises important questions about the consistency of reporting among MPOs and about whether the target proposals submitted by some MPOs realistically portray the VMT and GHG reductions that are achievable under their tested scenarios. ARB should request information from all of the MPOs who have submitted target proposals on the quality of modeling used in their respective estimations. Key criteria upon which the consistency and performance of the models should be judged include their quantitative sensitivities to: • The effects of land use compactness, centrality, mix and transit orientation on auto ownership, mode choice, vehicle trips generation and VMT and travel speed profiles. • The effects of different travel demand management (TDM) strategies individually and in combination and as they vary with urban form and context • The effects of roadway and parking pricing, including VMT pricing, both at low levels and at levels above or beyond magnitudes previously experienced • The effects of transit service improvements such as service coverage, frequency, on-time performance, and fares on automobile mode shares and VMT The University of California information provides empirical evidence on expected ranges of these effects that can be used to judge the performance of the models in providing reliable reports on the effectiveness of strategies contained within the submitted MPO planning strategies. 9. Other Benefits of Reliable Forecasting Insuring the accuracy and consistency within these forecasts is important not only to assuring fairness among the MPOs and accuracy in overall target setting, but it is also in promoting effective policy planning within the regions. Elected officials in all regions will be able to make more effective decisions on transportation policy and planning guidelines if provided accurate information on the potential consequences of their options. Forecasting should be able to inform decision makers, for example, of the costs, impacts, benefits and co-benefits of their policy and planning strategies. Jerry Walters, Principal Fehr & Peers One Walnut Creek Plaza Walnut Creek, CA 94596 925-930-7100 j.walters@fehrandpeers.com
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Date and Time Comment Was Submitted: 2010-06-23 23:34:51
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