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Comment 57 for Land Use Comments for the GHG Scoping Plan (sp-landuse-ws) - 1st Workshop.
First Name: David
Last Name: Schonbrunn
Email Address: David@Schonbrunn.org
Affiliation: TRANSDEF
Subject: LUSCAT-stimulated Ideas
Comment:
Here are some ideas that were stimulated by the LUSCAT process, that didn't make it into the Draft Scoping Plan. They deserve full consideration in the Final Scoping Plan: High Speed Rail High-Speed Rail could serve as the future armature tying together the State’s far-flung regions. Its routing serves as a de facto land use plan of where the State will grow in the future. As such, the High-Speed Rail project needs State-enacted land use controls, to make sure that development in future High-Speed Rail station areas helps the state achieve its goals for compact growth. Otherwise, the tremendous expense of the project will provide less than optimal benefits in shaping future growth. The needed controls would impose minimum density zoning guidelines as a requirement for station siting, to catalyze a densification of future growth around station areas, and a development focus on urban cores. These controls are needed because the High-Speed Rail FEIRs did not impose meaningful mitigations for growth inducement, or for the sprawl contained in current land use plans. CEQA The CEQA Guidelines need to identify what constitutes a significant impact. We suggest that emissions of additional GHGs be considered a significant impact. Add the following to the Air Quality section of the Checklist: “Result in greenhouse gas emissions that delay the attainment of AB 32 targets?” We believe the ARB will need to create an extensive CEQA Mitigation Bank, which will enable small projects to pay a mitigation fee to be able to receive a Mitigated Negative Declaration. Such an approach would avoid CAPCOA’s CEQA meltdown scenario, in which no projects would be able to get through CEQA without an EIR. We see fees received from small land use projects being invested in renewable energy projects, solar generation plants, energy efficiency projects, and public transit capital projects. Both the fee itself, as well as the modelling process to determine the level of mitigation needed, as well as the investments of the mitigation bank itself will need to be carefully written into regulation, so as to achieve reliable GHG reductions. We see a Mitigation Bank possibly functioning as part of a future Cap and Trade program. Funding for Urban and Infill Schools A major impediment to Smart Growth is the perception of poor quality urban schools. Attracting families into cities will require good schools. Part of the solution will be additional funding from the State. Please note: The Education Code requirements for playing fields tend to prevent new schools from being sited in infill locations, and push them instead to greenfield locations far from students’ neighborhoods. This needs to be fixed. Market-Priced Parking We need to stop using public funds to subsidize parking. Requiring parking to pay its own way will have a VMT reduction effect, and will result in more economic use of scarce land resources. LAFCOs and Infill Determination of Need LAFCOs need to be instruments of State policy, restricting the annexation of vacant lands so as to push development into infill locations.
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Date and Time Comment Was Submitted: 2008-08-01 20:34:08
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