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Move San Diego is a California 501(c)3 non-profit corporation with
a mission to improve the sustainability of San Diego County's
transportation network. MoveSD represents a collaboration of
community planners, developers, businesses and environmentalists
creating common ground to improve the economic and environmental
performance of our regional transportation investments and smart
growth policies.

We understand that the San Diego region will be the first region
statewide to go through the SB375 Sustainable Communities planning
process, including the update of our Regional Transportation Plan
(RTP) and Regional Housing Needs Assessment. 

INTEGRATION = Making the Land Use & Transportation Connections
Since fossil fuel consumption by transportation is known to be the
single largest source of California's GHG emissions, accounting for
some 41% of emissions, improvement to planning and running our
regional transportation networks is critical. While regions are
pursuing "smart growth" by adding additional development and
redevelopment, the connections between land use planning and
transportation performance are lagging behind.

Specifically, our coalition agrees that transit planning
performance is the key strategic, economic and environmental
investment that is being the most ignored and would like the RTAC
to become much more aware and involved in further quantification
and integration of transit as critical - and required - to achieve
the wealth of benefits sought by Californians in smart growth and
climate change policies.

Transit contributions to VMT and emissions reductions
In a recent regional study of GHG emissions sources and policies
conducted by the Energy Policy Initiatives Center at the University
of San Diego , the policy strategies
needed to drive  transportation-based GHG emissions downward to
achieve State goals were ranked. The top two strategies were
changes out of the direct control of the region's governments.
However, the third top strategy that the region does have some
control over is to reduce VMT (Vehicle Miles Traveled). In turn,
having studied the issue over time, we believe the biggest change
that allows for the largest number of people to reduce their VMT,
other than moving where they live or work which is often
unachievable by the vast majority of people, is for drivers to be
able to change to transit at least for their work commutes. This
would also provide the greatest peak period congestion relief
benefits. Furthermore, we believe that having more drivers change
to transit will actually be required for us to meet State goals
pursuant to Assembly Bill 32 (AB 32). Therefore, the issue of what
allows and attracts people to change from driving to transit is
strategically critical.

What will allow a region to reduce VMT?
While our region has adopted a myriad of smart growth policies,
and has invested billions in transit projects, ridership has not
risen enough to significantly impact either VMT or congestion -
distinct from recent peaks in gas prices. Why not? Why don't
significant numbers of drivers change to transit?

Market research in the San Diego region has shown that drivers can
be divided into six basic market groups, 1/6 will never take
transit; 1/6 prefer transit. There are four groups "in the middle"
representing 2/3 of drivers who would change to transit, but only
if it meets their needs. Those needs can be summed up as:
sufficient network connectivity; trip times competitive with
driving times; reliable/safe/attractive to use. See more info at:
http://www.sdearthtimes.com/et0408/et0408s5.html

What is a key barrier to reducing VMT?
We have identified that a key barrier to reducing VMT is lack of a
transit network that meets existing drivers' service needs. Transit
projects are not currently being designed based on what market
research shows drivers need in order to use transit. They are being
shaped by a myriad of planning regimes and funding requirements,
and not based on the key factors that would attract significant
numbers of riders.

We believe that  a market-based approach to transit infrastructure
and service planning is required to both comply with AB 32's
requirement of reducing GHG emissions and achieve smart growth
goals - including improving the region's economic competitiveness.
Hi-tech and knowledge workers especially hate traffic and are
willing to change to transit, but not if it requires significant
amounts of additional time. Improving transit performance also has
a huge benefit to improving conditions for the poor and disabled.

Objections to policies to reduce VMTs
We have heard some say that improvements in the emissions profiles
of cars and trucks will mean we don't have to reduce VMTs. Indeed,
the biggest changes out of a region's control are expected to come
from manufacturers or through other governmental actions. However,
even as emissions profiles of vehicles continue to improve, traffic
congestion would still remain as a smart growth challenge and drag
on economic performance and quality of life. Better connecting jobs
and housing is critical to economic performance. Therefore, a
smart, market-based transit system is a requirement to achieve
smart growth.

What would such a system look like?
MoveSD searched worldwide for the global best transit planning
practices most applicable to our region's land use and
transportation growth pattern. We then hired experts to design a
transit network based on the market-service principles determined
by the market research.

We believe this market-based approach to transportation network
planning has important implications for many urban regions,
especially those dealing with sprawl, traffic and dispersed
regional job centers.

Our findings determined applying this "FAST Planning" approach
(Financially Achievable, Saves Time) could provide significant
regional benefits including:

- better target and serve major regional job zones and housing
areas
- better support transit-oriented development.
- improves the cost-efficiency of transit investments and transit
operations.
- is affordable to build and operate
- increases transit use by attracting significantly more riders
- flexible enough to adapt to future conditions
- measurably improves congestion
- a more consistent approach to developing infrastructure designed
to be more attractive

Investing in mass transit is also a job engine AND real estate
investment, unlike other potential policies to reduce energy use
such as telecommuting.

Impediment to Smart Growth and Climate Change reductions
We feel the biggest impediment to achieving reductions in VMT and
related smart growth goals is the lack of any state requirement to
provide a minimum standard for transit services in order to qualify
as "smart growth" or a "sustainable community" approach. We see
planners promoting smart growth, but it is not smart when it is not
supported by a sufficient transit network to support the increased
densities. 

Investments in transit that do not meet user market-based service
needs or that do not sufficiently improve the network connectivity
of regional job centers and housing density, merely result in more
congestion and do not offer significant emissions reductions
benefits.

Yes, smart growth can offer a wealth of benefits. But it is only
as smart as its weakest link. We find, right now, that weakest
link, is indeed the design and performance of regional transit
networks. Without requiring transit performance improvements, there
is a wealth of evidence that we will not achieve the benefits of
smart growth; indeed, adding density without having sufficient
transit connectivity is exactly what has happened in our region.
Additionally, state cuts to transit have reduced transit services
to many "Transit Oriented Development" locations. So right now, it
becomes a formula for more congestion and more emissions and more
parking - the exact opposite of what we need from smart growth.

Note some statistics from our existing RTP:
- 2006 vehicle miles traveled (VMT) is 74.7 million.  Under this
RTP, VMT would be 113.5.  (DEIR at 7-3, table 7.0-1).  This is a
38.8 million (34%) increase in VMT.

- The total number of freeway lane miles would increase by over
800 from existing conditions.  RTP DEIR at 7-12.

- The transportation improvements under the proposed RTP would
increase gasoline consumption by approximately 505 million gallons
per year or 31.26 percent relative to existing (2006) conditions.

- Total diesel consumption would increase by 48.7 million gallons
or 25.00 percent relative to existing conditions.  DEIR at 4.7-23.
- Annual greenhouse gas ("GHG") emissions under the 2007 RTP would
exceed existing levels by the substantial margin of about 31
percent or 5.3 million tons of CO2 per year in 2030.  DEIR at
4.7-34. The document finds that this increase in GHG emissions
would contribute to the exacerbation of climate change and
concludes this impact to be significant. Id. at 4.7-34 and 4.7-38. 
          

Therefore, we urge you to make the connection in this most
strategic location - the performance of our transit networks as
necessary to achieve both climate change reduction and indeed all
goals related to smart growth and sustainability.

To view our presentation: Improving transit performance by
applying global best practices
http://movesd.org/Downloads/FASTonline%20version%202.4.htm

You may also download a 2-page summary of FAST Planning from our
Programs page:
http://movesd.org/programs.html

Thank you for the opportunity to comment.