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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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