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1) The draft Scoping Plan is silent on increased state funding for
local transit projects and operational costs.  Increased
availability of transit is critical to the success of transit
villages and transit oriented development.  Revisions to the
city’s Land Development Code to address reduced parking ratios,
parking maximums, shared parking strategies, etc. are contingent
upon the provision of an enhanced and efficient transit system.
Recent state funding cutbacks to transit has resulted in reduced
transit services in the San Diego region.

2) ETAC review: p.3-12 
Smart Growth and Transit Villages- More emphasis should be placed
upon the state providing additional funding for transit (both for
infrastructure and to increase service).  This will allow
jurisdictions to address regulatory obstacles such as parking
ratios, prohibitions on tandem parking and reluctance to allow
shared parking to fulfill parking requirements.  It also allows
for increases in density and a mix of uses which, as the report
notes, results in a reduction in vehicle miles traveled (VMT).

3) p.33 – Regional Targets 
The expected greenhouse gas emission reductions for land use and
transportation planning are anticipated to be very low, according
to the report.   If land use strategies are believed to achieve
only minimal results, then there will be little incentive for
local governments to make the difficult decisions to support smart
growth.  It may be that the numbers appear low because smart growth
and transit investments occur in limited areas, while the results
of their projected benefits are spread over the entire built
environment.  In order to gain a better understanding of the role
of, and potential emission reductions that can occur through land
use and transportation strategies, focused areas should be studied
and compared to conventional, auto-oriented development. In
addition, current modeling practices do not likely capture the
change in driving habits that is rapidly occurring due to the
increasing cost of gasoline.   Better transit and land use
planning will provide people with opportunities for more
affordable living, and is likely to be an important part of
California’s future. Not mentioned in the report is the crucial
need for more transit funding to make smart growth work.  San
Diego’s recently updated General Plan includes a “City of
Villages” strategy for new growth to be focused in transit-served
areas.  However, the local reality is that the San Diego region
has been forced to cut transit service due to lack of funding. 

4) ETAC ETAAC Final Reportp. 3-8 – Consumer Education
Education about the benefits of reduced driving will not be
effective if people do not have access to alternative forms of
transportation, or the ability to live in areas where they can
walk to school, stores, and services.

5) p. 3-12  Smart Growth and Transit Villages
Not adequately mentioned in the report is the crucial need for
more transit funding to provide Californians with an effective
alternative to driving.  San Diego’s recently updated General Plan
calls for development to be focused in transit corridor and station
areas in order to increase transit use and cut emissions.  
However, the local reality is that the San Diego region has been
forced to cut service due to lack of funding.    

We suggest that the report further explore the potential role of
public transit, and include strategies to increase transit
operations funding.  A potential source of information is a study
prepared by the Transit Cooperative Research Program (TCRP) of the
Transportation Research Board (TRB).  The report, entitled Public
Transportation’s Contribution to U.S. Greenhouse Gas Reduction,
shows that a solo commuter switching his or her commute to public
transportation can reduce a household’s carbon emissions up to 30
percent.   

6) p. 3-13 Concur that state CEQA Guidelines should be revised to
better evaluate multi-modal transportation impacts and benefits. 
It is not productive for a CEQA document to call out a higher
density, smart growth project as having significant impacts that
can be mitigated by lowering density, if the alternative to
providing that housing is to continue urban sprawl practices.  It
would be helpful to explore the potential to evaluate the impacts
of urban infill development based on per capita impacts (VMT,
water use, etc) compared to a regional or state-wide “norm.”

7) p. 3-14 A key obstacle to implementing smart growth is
inadequate funding for transit investments and operations. 

8) p. 3-15 Concur that LOS Guidelines are an auto-centric measure
of mobility, as a transportation corridor may have a poor street
intersection LOS, yet excellent transit service and pedestrian
mobility.  However, any changes to the LOS measures would also
need to address the air quality impacts that result from
congestion hot spots.

9) p. 7-12 Please explore how mitigation requirements and perhaps
in-lieu fees may be used to further support strategic tree
planting.  

10) ETAC P.3-15   We do have concerns regarding the recommendation
that: “The use of Level of Services (LOS) as a measure of
environmental impacts for transportation projects under CEQA
should be replaced with broader measure of access to goods and
services and quality of life.”  The LOS of transportation
facilities is included within DSD’s significance thresholds, and
is a measure of the length of time people are waiting at
intersections and other transportation facilities.  However, the
LOS is not just a measure of automobile convenience as stated on
the third paragraph of that page.  It also is used to determine
air quality impacts since exhaust emissions can potentially cause
direct localized “hotspot” impacts (CO) near or at new
developments and air quality impacts are exacerbated by congestion
(vehicles either idling or moving at a slow or stop and go pace). 
We are concerned about air quality (another CEQA issue) due to the
potential health impacts on sensitive receptors.  Therefore, I
believe that DSD would have concerns about the replacement of
currently defined LOS as a measure of environmental impacts for
transportation impacts under CEQA and would need to know more
about the potential addition of broader measures including access
to goods and services and quality of life.  The terms should be
carefully defined since we would need to know, for example, how
quality of life would be defined in the CEQA context.  How would
the environmental impacts of each of any of the newly included
measures be defined and quantified, and what suggested
significance thresholds would be proposed? 

11) ETAC p. 7-12   One of the tasks that DSD is undertaking as a
component of the City of San Diego General Plan Action Plan is the
incorporation of measures such as tree planting as formal
mitigation.  State assistance would be appreciated in quantifying
such measures and developing such a program.

Original File Name:

Date and Time Comment Was Submitted: 2008-07-30 11:19:10