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Comment 39 for Scoping Plan Update: The Proposed Strategy for Achieving California's 2030 Greenhouse Gas Target and Draft Environmental Analysis (scopingplan2030) - Non-Reg.

First NameSherman
Last NameLewis
Email Addresssherman@csuhayward.us
AffiliationHayward Area Planning Association
SubjectComment on Scoping Plan 2030
Comment
The plan is commendable in its concern for land use--some 40
references. "Vibrant" got only 13 uses despite its popularity among
those who don't define it. Footnote 160 took me to ARB, "Potential
State - Level Strategies to Advance Sustainable, Equitable
Communities and Reduce Vehicle Miles of Travel VMT) -- for
Discussion." All the references to land use were as undefined as
vibrant, except that sprawl is not good and needs boundaries, and
compact is good. I agree, and this a scoping plan and thus allowed
to be vague.

The discussion document does get much more detailed and invites
discussion, but does not say how the discussion works, so my two
bits comes here.

It's basically good, but, if you are serious, you really need to
find a way to include it in modeling. It is unlikely to make any
difference in the modeling unless it uses block group or block
person densities from American Fact Finder and differentiates for
densities above 50 persons per acre, as well as density brackets
below that. At densities above 50 non-auto modes shift to 60% or
more of the auto/non-auto total (unimportant modes need to be
ignored). The only modal data for small areas is for Means of
Transportation to Work, available at the block group level. 

The relevant high density block groups are a very small percent of
the total and don't amount to a hill of beans in state wide
aggregates. It is too easy to say it doesn't matter, but it is,
compared to average densities, a way of knowing how much VMT can be
reduced by policies moving up the density scale. You don't need to
speculate, you can quantify. The CA Household Transportation Survey
also has geocoded data which can not be used at the record level,
but the guardians of the data can export to you records aggregated
by density level as proxy neighborhoods. 

I've done a lot of the above; contact me if interested.

The SB375 MPO strategies are worthwhile but weak, single measure
nudges short of a systemic approach of enough density and enough
green mobility to get to 60 percent non-auto modes. 

The OPR effort to analyze projects and the SGC guidelines for the
AHSC program are not bad but would be much better if they would
support explicitly the ideas attached. It's not a question of
requiring them, but letting applicants know these policies will be
favored and get more points. Similarly, the ARB modeling of
projects is way too simplistic with three, limited percent awards
of reduced VMT, when projects need a multi-variate analysis based
on a range of best-practice projects that show much more VMT can be
reduced than ARB is recognizing. 

I can't find fault with the discussion document for commission, but
I feel there is a problem with omission, i.e., omission of a
recognition that a complex of policies needs to work together to be
effective. For neighborhoods, for example, doing ten things right
might get to a 20% VMT reduction while doing those ten plus three
more get to a 60% reduction: because the system reaches a tipping
point where non-auto modes (walk, rapid shuttles, urban rail
transit, public cars [taxis, ride apps, car share/rental]) compete
with owning a car, unbundling, and smart meters. 

This is so not a state wide strategy; it only applies in corridors
and centers where densification can reduce vehicle traffic while
increasing trips. 

For an essay on the big picture, look for my article on Walkable
Neighborhood Systems.




Attachment www.arb.ca.gov/lists/com-attach/57-scopingplan2030-AHcFYgFsAjoHaARq.docx
Original File NameWalking Oriented Development for SGC.docx
Date and Time Comment Was Submitted 2017-03-08 11:37:23

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