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Comment 1 for Comments on Local Government Toolkit. (localgov-toolkit-ws) - 1st Workshop.


First Name: David
Last Name: Somers
Email Address: david.somers@lacity.org
Affiliation: City of LA, Department of City Planning

Subject: ARB Tools to give local governments - Quantify TDM Mitigation Measures
Comment:
I would like to submit a suggestion/answer to question of are there
other tools ARB can develop to assist local governments to reduce
GHG emissions?  

Local governments in their role as Lead Agencies can provide
mitigation measures on projects subject to CEQA. Though a current
barrier to incorporating meaningful GHG reducing mitigation
measures is lack of quantified threshold, and secondly lack of
quantified reductions of mitigation measures (MM) that could
directly reduce GHG reductions on a project level. CARB could help
local governments in researching and developing the methodology to
develop a centralized GHG mitigation toolbox with each MM
quantified as their GHG reductions. Similar work is being conducted
by SCAQMD in their drafting of rule 2301.

Special potential could be developed for MMs that have co-benefits
in trip reductions. Most transportation agencies are way behind the
curve in quantifying trip reduction benefits of transportation
demand management (TDM) measures, as well as transit and pedestrian
strategies. So Cities still are over reliant on supply side
physical improvements (ie lane widening) as the primary means to
mitigate traffic, which increase GHG over the long term by creating
car dominated land uses. This is because they at least are
quantified and a industry approved methodology. TDM does both,
reduces trips and GHGs. Once a standard approach is available for
TDM reductions then local governments can draft policies that
explicitly prioritize TDM as a MM for traffic, and local
governments all over the state will have little excuse for
mitigating LOS by lane widening, rather then TDMs. I have attached
generalized mitigation language than can be seen as a starting
point. Other reference documents as follows:

Los Aangeles Metropolitan Transportation Authority, 2002
Congestion Management Plan, Appendix F - toolbox of Strategies; 

CALTRANS, July 2007 "Local Models and Tools for Analyzing
Smart-Growth Strategies"; 

NelsonNygaard Consulting Associates, August 2005 "Crediting
Low-Traffic Developments Adjusting Site-Level Vehicle Trip
Generation Using URBEMIS";

SCAQMD, PR Rule 2301: List of Transportation Emission Reduction
Measures To be included in the PR2301 Guidance Document WORKING
DRAFT

Attachment: www.arb.ca.gov/lists/localgov-toolkit-ws/1-tdm_package.pdf

Original File Name: TDM Package.pdf

Date and Time Comment Was Submitted: 2009-03-09 10:54:47



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