HomeMy WebLinkAbout02 SCAG RTP/SCS and PEIRAGENIDA REPORT ITEM # 2
MEETING DATE: FEBRUARY 23, 2012
TO: PLANNING COMMISSION
FROM: COMMUNITY DEVELOPMENT DEPARTMENT
SUBJECT: SCAG RTP/SCS AND PEIR
In accordance with federal law, the Southern California Association of Governments
(SCAG) is required to prepare a long-range regional transportation plan for the region
every four years that prioritizes proposed transportation projects and coordinates a
balanced transportation system. The SCAG region is comprised of Imperial, Los Angeles,
Orange, Riverside, San Bernardino, and Ventura counties.
The Regional Transportation Plan (RTP) is a prerequisite for obtaining and allocating
federal funding for regional transportation projects. These projects are implemented by
agencies other than SCAG.
Within the PTP is the Sustainable Communities Strategy (SCS), which demonstrates the
region's ability to attain and exceed the greenhouse gas emission reduction targets set
forth by the California Air Resources Board. A requirement of Senate BIII 375, the SCS
outlines SCAG's plan for integrating the transportation network and related strategies
with an overall land use ,pattern that responds to projected growth, housing needs and
changing demographics, and transportation demands. The RTP/SCS fully integrates
the two subregional SCSs prepared by the Gateway Cities and Orange County Councils
of Governments.
SCAG released the Draft 2012 RTP/SCS and PEIR for public review. On February 7,
2012, the City Council authorized the Mayor to send the attached comment letter
(Attachment A) to SCAG regarding the Draft 2012 RTP/SCS and its associated Draft
PEIR. Also attached to this report are copies of letters to SCAG from the Orange County
Council of Governments (OCCOG), the Orange County Transportation Authority
(OCTA), and the Center for Demographic Research (Attachments B,C, and D).
Staff identified the following significant issues and concerns which are addressed in the
attached comment letter to SCAG:
That the proposed mitigation measures go above and beyond the strategies of
the OCSCS and requirements of the Regional Transportation Plan and Senate
Bill 375;
Planning Commission Report
SCAG RTP/SCS and PEIR
Page 2
• That many of the proposed mitigation measures are already required by State
and Federal law or are regulated by other agencies such as the South Coast Air
Quality Management District, California Department of Housing and Community
Development, California Department of Fish and Game, and the Regional Water
Quality Control Boards;
• That many of the proposed mitigation measures are contrary to local control;
• That many of the proposed mitigation measures impose taxes or fees that are
financially infeasible for local agencies or project proponents to implement;
• That the use of the wording "can and should" throughout the PEIR and the Draft
RTP/SCS implies that the proposed mitigation measures are feasible, and local
jurisdictions are expected to implement them;
• That the concept of transportation projects inducing growth may be contrary to
the Orange County Sustainable Communities Strategy;
• That adequate funding mechanisms need to be identified in the RTP/SCS. The
City of Tustin cannot support an increase in fees, including the introduction of a
mileage -based user fee, until further economic analysis is completed; and
• That all Regional Transportation Improvement Program (RTIP) projects located
in Tustin be included in the 2012 RTP/SCS, including the Tustin Ranch Road
Extension project.
A copy of the Executive Summary for the Draft RTP/SCS is attached. The complete
document and appendices can be viewed on SCAG's interactive website at
www.scagrtp.net.
Staff will continue to apprise the Planning Commission of the status of the RTP/SCS
and its PEIR as they progress through the approval process.
Scott Reekstin Elizabeth A. Binsack
Senior Planner Community Development Director
Attachments:
A: Letter dated February 8, 2012, from the City of Tustin to SCAG
B: Letter dated February 14, 2012, from OCCOG to SCAG
C: Letter dated February 14, 2012, from OCTA to SCAG
D: Letters dated February 14, 2012, from CDR to SCAG
E: Draft RTP/SCS Executive Summary
ATTACHMENT A
LETTER DATED FEBRUARY 8, 2012, FROM THE CITY OF TUSTIN TO SLAG
Office of the City Council
February 8, 2012
Ms. Margaret Lin
Southern California Association of Governments
818 West Seventh Street, 12th Floor
Los Angeles, CA 90017
SUBJECT: REVIEW DRAFT 2012 SCAG RTP/SCS AND DRAFT PEIR
Dear Ms. Lin:
Thank you for the opportunity to provide comments on the Draft 2012 Southern California
Association of Governments (SCAG) Regional Transportation Plan/Sustainable Communities
Strategy (RTP/SCS) and the Draft Program Environmental Impact Report (DPEIR) for the 2012
SCAG RTP/SCS.
The City of Tustin has prepared the following comments for your consideration at this time:
Most of the proposed mitigation measures go above and beyond the strategies of the
Orange County SCS and requirements of the RTP and. Senate Bill 375. For example,
Mitigation Measure "Greenhouse Gas Emissions 5" states that "SCAG shall assist ARB
and air districts in efforts to implement the AB 32 Scoping Plan." Implementation of the
AB 32 Scoping Plan goes above and beyond the scope of SB 375 and the RTP.
Therefore, this mitigation measure, and others like it that exceed the scope of the RTP
and SB 375, should be removed from the PEIR.
• Proposed mitigation measures are already required by State and Federal law or are
regulated by other agencies such as the South Coast Air Quality Management District,
California Department of Housing and Community Development, California Department
of Fish and Game, and the Regional Water Quality Control Boards should be removed
from the PEIR.
Many of the proposed mitigation measures, including "Land Use 3," "Land Use 10" and
"Land Use 42" are contrary to local control. Mitigation Measure "Land Use 10" is one of
the most compelling examples. It reads "Local jurisdictions can and should provide for
new housing consistent with the Regional Housing Needs Assessment (RHNA) to
accommodate their share of the forecasted regional growth." This mitigation measure is
problematic and should be removed or revised because State Law and the RHNA do not
require local jurisdictions to ensure that housing units are actually built.
• Many of the proposed mitigation measures impose taxes or fees that are financially
infeasible for local agencies to implement or impose an undue burden on the building
industry. For example, Mitigation Measure "Transportation, Traffic and Security 60"
states the following: "Transit and Multimodal Impact Fees: Local jurisdictions can and
Mayor John Nielsen • Mayor Pro Tem Al Murray • Jerry Amante • Deborah Gavello • Rebecca "Beckie" Gomez
l nn /" . i cin -r —
Ms. Margaret Lin
SCAG 2012 RTP/SCS and DPEIR
February 8, 2012
Page 2
should assess transit and multimodal impact fees on new developments to fund public
transportation infrastructure, bicycle infrastructure, pedestrian infrastructure and other
multimodal accommodations." A second example is Mitigation Measure "Transportation,
Traffic and Security 37" which reads "Local jurisdictions and transit agencies can and
should provide public transit incentives such as free or low-cost monthly transit passes
to employees, or free ride areas to residents and customers." Requiring these types of
fees and incentives will increase the cost of development and negatively impact the local
economy. Therefore, all such measures should be removed from the PEIR.
The use of the words "can and should" -throughout the PEIR and the Draft RTP/SCS
implies that the proposed mitigation measures are feasible, and that local jurisdictions
are expected to implement them. The following statement from page 1-7 of the
Introduction makes this intent clear: "Local governments routinely implement the types
of mitigation measures identified in this Draft PEIR during project design, CEQA review,
and/or project construction. This Draft PEIR has made a preliminary determination that
these mitigation measures are feasible and effective. Therefore, it is reasonable to
expect that local governments will actually implement them." There is no analysis in the
Draft RTP/SCS to demonstrate that every local jurisdiction within the SCAG region has
the ability, staffing, and financial resources to implement all of the mitigation measures.
SCAG should replace the words "can and should" with "should" in all of the mitigation
measures in the PEIR and throughout the SCS Chapter of the Draft RTP/SCS. This
change in wording would be consistent with SCAG staffs representation at the Orange
County Council of Governments January 26, 2012, Board meeting that the mitigation
measures are intended to be a "tool box" of options.
The Draft RTP/SCS assumes that the transportation projects outlined in the document
have the potential to induce growth in certain parts of the region. This concept is
evidenced by Mitigation Measure "Biological Resources and Open Space 47" which
reads "Project sponsors can and should ensure that transportation systems proposed in
the 2012-2035 RTP/SCS avoid or mitigate significant impacts to natural lands,
community open space and important farmland, including cumulative impacts and open
space impacts from growth associated with transportation projects and improvements."
This measure is not consistent with the OCSCS and the approved growth projections
and patterns embodied within the Orange County Projections 2010 Modified. Therefore,
all references to induced growth should be removed from the PEIR.
• It is stated on page 80 of the Draft RTP/SCS that "the RTP has the ability to affect the
distribution of that growth." This statement appears to contradict SCAG's agreement
pursuant to the Memorandum of Understanding with the Orange County Council of
Governments (OCCOG) that the strategies and local land use policies of the Orange
County SCS will be respected. The RTP/SCS should acknowledge that the local land
use plans in Orange County will not be changed through the RPT/SCS.
Many of the mitigation measures in the Draft PEIR are draconian and need to removed
and/or revised. One prime example is Mitigation Measure "Land Use 85." It reads in
part "Local jurisdictions can and should reduce heat gain from pavement and other
hardscaping including: Reduce street rights-of-way and pavement widths to pre -World
War II widths (typically 22 to 34 feet for local streets, and 30 to 35 feet for collector
streets, curb to curb)..." Although reduced street widths may be appropriate in some
Ms. Margaret Lin
SCAG 2012 RTP/SCS and DPEIR
February 8, 2012
Page 3
cases and have been implemented in many jurisdictions, it is inappropriate and
counterproductive to require reduced street widths as a mitigation measure in the PEIR.
Reduced street widths, for example, generally do not provide space for on -street parking
which may result in greater, additional paved areas provided in separate parking lots.
The Draft RTP/SCS suggests that $127.2 billion of an approximately $219.5 billion
regional shortfall can be addressed through actions at either the state or federal level
with a $0.15 gas tax increase between 2017 and 2024. After that, the report assumes
that the state or federal government would either replace the gas tax with an indexed
mileage -based user fee of $0.05 per mile, beginning in 2025, or further increase fuel
taxes to generate revenues equivalent to the mileage -based user fee.
The City of Tustin cannot support an increase in fees, including the introduction of a
mileage -based user fee, until further economic analysis is completed and until and
unless there can be an explanation of the return to source principles which will be used
for the distribution of funds collected thereunder. In addition, when considering support
for any kind of a new user -based fee program, an emphasis must be placed on a
process for recognizing and rewarding areas which commit additional revenues.
The Draft RTP/SCS proposes a number of investments that affect Orange County and
go beyond the Long -Range Transportation Plan (LRTP). The City will only consider
additional investments after revenues are identified to account for these commitments.
The regional strategies identified by SCAG do not have clear funding mechanisms, and
it must be made clear that their inclusion in the RTP/SCS does not constitute a
commitment to fund and/or implement the improvements.
• The Sustainable Communities Strategy ("SCS") is recognized as a key portion of the
2012 RTP/SCS, and serves to meet responsibilities associated with SB 375. It is clear
the SCS "Goals and Benefits" involve significant local jurisdiction participation and
efforts. It is critical for the RTP/SCS to recognize the need to sufficiently fund local
agency efforts to assure successful outcomes.
Tables 4.3 - 4.7 of the RTP/SCS identify "Action/Strategy" efforts related to the SCS,
with local jurisdictions being identified as responsible parties for many of the tasks.
Without proper funding for local jurisdiction efforts we believe the effectiveness of the
"Action/Strategy" measures will be compromised.
In general, current policies and goals of the RTP/SCS identify projects and funding
necessary to successfully implement elements of the RTP/SCS. There are also
RTP/SCS goals which essentially require development "from the ground up" at the local
level. We agree the most efficient and effective efforts toward meeting these RTP/SCS
goals will begin with the local jurisdictions.
There needs to be sufficient levels of funding (which do not appear to be addressed in
the current RTP/SCS draft) to allow local jurisdictions to adequately initiate these
specialized efforts. From a practical perspective, this funding would be expected to yield
some of the most immediate and timely results in meeting RTP/SCS goals. They would
consider measures which could include, but not be limited to:
Ms. Margaret Lin
SCAG 2012 RTP/SCS and DPEIR
February 8, 2012
Page 4
o Programs for improved use of public transit
o Responsiveness to demographic changes
o Improved management of existing transportation infrastructure and roadways
o Employer -based Transportation Management Plans
o Trip -reduction efforts including promotion of telecommuting
o Carpool/transit parking near transportation corridors
o Better "place marking" which includes an increase of walkable environments
o Support of bicycle programs including bicycle storage and bike lanes
o Bridging gaps between mass transit options and shipping and service centers
o Programs for new construction and reconstruction of non -motorized
transportation paths
• Measures to reduce vehicle miles traveled will involve local jurisdictions and employers
to implement many strategies which include but are not limited to measures such as:
o Increasing rideshare and work -at-home
o Investing in non -motorized transportation facilities
o Developing appropriate land use strategies
o Encouraging universal employee transit access passes
o Synchronizing traffic signals
o Using LED technology for new traffic signals and street lights
o Allocating convenient parking areas, loading areas and larger parking spaces for
vans and HOV
o Creating ride -sharing programs and provide parking near public transportation
o Enhancing safety and cleanliness at transit stations
o Providing shuttles to transit
o Providing incentives, education and publicity to encourage use of transit
It will be necessary to provide funding to local jurisdictions for implementation and/or
management of these and other associated measures.
Table 3.6 shows that the 2012 RTP/SCS anticipates relatively low levels of funding for
local streets and roads, including $1.1 billion for FY2011-FY2015, $1.1 billion for
FY2016-FY2020, and $1.2 billion for FY2021-2025. Funding is increased to $7.9 billion
for FY2026-FY2030 and $9.6 billion for FY2031-FY2035. However, local street and
road improvements offer the best opportunity for quickly improving mobility and realizing
RTP/SCS goals. They also provide economic benefits which could translate into
additional funding in the future. Funding for these programs should be increased and
accelerated in the near future.
One City of Tustin project which has both local and regional significance does not
appear to be included in the RTP/SCS. It is therefore requested that the following
project be added to the RTP/SCS:
o Tustin Ranch Road extension from Walnut Avenue to Warner Avenue, including
a new grade separation over Edinger Avenue and the OCTA/SCRRA Railway.
• In addition, the RTP/SCS should identify the regional transportation infrastructure
deficiencies broken down by county for purposes of transparency.
Ms. Margaret Lin
SCAG 2012 RTP/SCS and DPEIR
February 8, 2012
Page 5
Again, thank you for the opportunity to review and comment on the Draft 2012 Southern California
Association of Governments (SCAG) Regional Transportation Plan/Sustainable Communities
Strategy (RTP/SCS) and the Draft Program Environmental Impact Report (DPEIR) for the 2012
SCAG RTP/SCS. If you have any questions regarding the City's comments, please call Elizabeth
Binsack, Community Development Director at (714) 573-3031.
Sincerely,
Jodi t' Nielsen
Mayor
cc: Hasan Ikhrata, SCAG
Dave Simpson, OCCOG
Tustin City Council
Jeffrey C. Parker
Doug S. Stack
Elizabeth A. Binsack
Dana Ogdon
Scott Reekstin
SR:environmental etc1SCAG 2012 RTP SCS and PER Letter.doc
ATTACHMENT B
LETTER DATED FEBRUARY 14, 2012, FROM OCCOG TO SCAG
OW90 c6pnty
Cmn& i f Govvrnoment5
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February 14, 2(Y12
,Mr. Hasan lkhrata-
Executive Director
,§,o;uthern Calif bmia Association of �mtnehtt,
We* 4eventh Street, 4210 Floor
Los Angeles, CA 90017-3435'
,7
Dear Hasan,
.On behalf of the Oronge County Council of Governments (0 COG), I
woo Id like to.. commend Q91iforniA A
4M sociatOn o. the SOut11 `'s ,
1, 1 � :- - f
PovotrItnents (SCAG) Ano, its staff who worked hard to prepare th6 draft
Regional Transp.ort.at:io-n IPlIan. (RTP)/Sustainable Communities ties Strate V
(SPIS).,tho Program F,01ronmental Impact Report (PEIR) and
I Report I I . !-7 :
documents. This effort was monurhehtal',Art4 Opte
i
U.. , cedented'nour history
and throughout the process collaboration between $CAG and Orange
County stakeh Id rs h.asb n exceptional;
The
The 34 Orange County loll and d six special districts . . that
_
comprise OCCOG thank you for theopportunityto comment on.the Draft
201g RIP and:,a ja -IF
_$s0c
PIE
.As you know, Oran 9, '0 e. County tock upon itself the task of developing a
subregional SCS. The continued bo(jporeO*Q
A.: of SCAG staff and the,
0*ero4s references throughout the 'document where the RTP,/SCS
.expressly states that it incorporates the, OrangeI County . Sustainable
Communities Strategy (OC SCS into the Cldocument
appreciated.
RT.PjS tnentle. greatly,
The OCCOG Technics! 1 A4visory.Committee lOCCOG TAC), made up, of
member agency planning staff, created an ' ad hoc committee i . dedicated to
the review sof Draft'RtTOISCS and .PE.IR. This committeeet four
ur
times since January 3. 2012, and has collectively spent hundreds cif ,h
our$
since revlewring1he draft plan and documents. The OCCOO TAC reviews
and analysis; was conoid Wed. in lat
e January by the. OCCob:Board and
serves as the basis for OCCOG's comments.
The following general 'comments and recommendations are offered by
OCCOG on the draft 2012-2035 RTP and SCS (draft RTP/SCS) and
associated Appendice.s.arld draft PEIR (draft PEIR), OCCOG requests
that this letter and its attachments be included in the public record as our
collective Comments on the draft RTP/SCS, PEIR and associated
documents.
Prange County Councilof,00vernmejjts.
550 150uih Macri Street.' RQ,Bax 14184 / Orange / CafibM18 92863-1584 / (714) 560-6282
1� GROWTH FORECASTS
Issue: Growth Pro'ectoons: The 2012 growth projections identify population, housing
and employment data for the six -county SCAG region, from 2008 (existing) to 2020 and
2035. These growth projections represent the best available information from local
jurisdictions, the business community, and landowners. However, as time passes, what
is 'feasible for any given project can change. The triggers for change to adopted growth
projections can range from factors such as market conditions, new information or data,
infrastructure availability, changes in funding availability (such as the dissolution of
redevelopment agencies statewide), and changes to jurisdictional boundaries resulting
from future annexations and incorporations of previously designated unincorporated
territory. SCAG should continue to adopt the 2012 growth projections at a countywide
level, consistent with past approvals of the RTP growth forecasts.
A county 'level of geography accommodates internal adjustments to changing conditions
as described above, without compromising the integrity of the overall growth
projections. However, approving the growth projections at any lower level of geography,
such as at the city level, would be challenged with continual revisions and shifts to the
total number of housing, population and employment within a city, among cities, and
between cities and counties as a result of the factors described above. Adoption of the
data at a level lower than the county would limit jurisdictional control and create
inflexibility in a regional planning document. In addition, the level of geography in which
RTP/SCS growth forecast is adopted should not be determined by other processes. For
example, the Regional Housing Needs Allocation (RHNA) allocations must be
consistent with the RTP/SCS; state law does not require that they be identical. The
RTP/SCS can be adopted at the county level and the RHNA process may proceed
independently until it is completed after the appeals, trades, and transfers are
completed. The RHNA allocations that were derived from the growth forecast can still
be determined to be consistent with the RTP/SCS, even if changes are made to the city
totals during the appeals, trades, and transfers process,
Growth Proiections Recommendation: SCAG®s adoption of the growth forecast
numbers should be at the county level, consistent with past RTPs, and not at a
smaller level of geography such as city, census tract, or traffic analysis level.
Issue: Orange County. Projections (0CP)-2010 Mod f ed., On January 26, 2012, the
update to the CCP -2010 dataset known as "OCP -2010 Modified" was officially approved
by the OCCOG Board of Directors and is a data amendment to the OC SCS. The
dataset includes the 2010 Census population and housing data, along with the 2010
Employment Development Department Benchmark data, consistent with SCAG's
updated growth forecast dataset. The dataset was provided to SCAG staff in December
2011 and this letter also serves as the formal notice of the update that should be
incorporated into the 2012 RTP/SCS, PEIR, and related documents.
OCP -2010 Modified Recommendation: All documents, tables, maps, narrative,
modeling runs, PEIR Alternatives (including Alternate C/3/Envision 2) referencing
Page 2 of 32
the Orange County growth forecasts should be updated with the Orange Counn y
Projections -2010 Modified Growth Projections, as adopted by the OCCOG Board
of Directors and consistent with the subregional delegation Me crandum rzf
Understanding (MOU) between OCCOG, OCTA and SLAG.
2. DRAFT RTP/SCS
Issue: 2012 Draft RTP/SCS: The RTP/SCS identifies strategies to reduce greenhouse
gas (GHG) emissions from cars and light duty trucks. Because counties, jurisdictions
and agencies have different needs and feasibility of implementation, we believe these
strategies should be clearly identified as a menu of options that can be used to achieve
the goal of reduced GHG emissions. However, the document can be construed to
suggest that each of the strategies listed in the table on pages 150-153 are necessary
to successfully implement the SCS, many of which are beyond SCAG's purview or
control. It is requested that the language be clear that it is permissive.
2012 Draft RTP/SCS Requests:
1. Revise language on page 149: "The following tables list specific
implementation strategies that local governments, SCAG, and other
stakeholders may use or consider while preparing specific projects
which that help Gan and should undeFtake in GrdeF to successfully
implement the SCS."
2. Please provide SCAG analysis supporting the strategies in the Draft
RTP/SCS Chapter 4.
3. Please describe what municipal obligations are anticipated as a result of
adopting these strategies as a list to be accomplished rather than a
menu of options.
Issue: OC SCS Strategies: There are strategies in the OC SCS that are not included
in the regional SCS. Similarly, there are some strategies in the regional SCS that are
not consistent with the strategies in the OC SCS. This creates confusion and
clarification is needed.
Under S8 375 and only within the SCAG region, subregional councils of government
were allowed to prepare subregional plans that SCAG is then required to incorporate
into the regional SCS. In Orange County, the OCCOG and the Orange County
Transportation Authority (OCTA) developed a countywide or subregional OC SCS that
was to be incorporated in whole into the SCAG SCS. Local agencies in Orange County
developed the OC SCS and approved it in June 2011. SCAG has incorporated the
OC SCS in its entirety into the regional SCS as an appendix to the regional SCS, but it
is unclear what the standing is of the OC SCS. The OC SCS contains a set of strategies
that were agreed upon by local governments, agencies and other stakeholders within
Page 3 of 32
Orange County and was accepted by SCAG and should represent the CCC that is
applicable to the Orange County region.
OC SCS Strategies Recommendation: Please revise the text in the last paragraph
on page 106 to state: "These subregional SCS documents are incorporated into
the regional SCS and represent the SCS for each of these subregions."
3. DRAFT PER
Issue: Mitigation Monitorina Program Intent: It is unclear how SCAG intends to
implement the Mitigation Monitoring Program with regard to the proposed mitigation
measures, as may be implemented by local agencies. Section 1-5 of the PEIR
specifically provides that "Lead agencies shall provide SCAG with documentation of
compliance with mitigation measures through SCAG's monitoring efforts, including
SCAG's Intergovernmental Review (IGR) process," It is infeasible for SCAG to require
local jurisdictions to report when such mitigation measures are considered for any
project. doting that the SCAG region includes 5 counties, 14 subregional entities and
191 cities, this reporting requirement would surely fall short of expectations. Given this
identified infeasibility, please clarify what obligations local agencies may have regardMg
SCAG's mitigation monitoring efforts.
Mitigation Monitorina Program Intent Requests/Recommendations:
1. Does SCAG intend to require all jurisdictions that avail themselves of
the mitigation measures to report to SCAG when such measures are
considered for any project?
2. SCAG's approval of the PER needs to clearly state the intent and
applicability of the mitigation measures and the PER reflective of our
comments below and that mitigation measures do not supersede
regulations under the jurisdiction of other regulatory agencies.
3. Add language to Executive Summary and Introduction: "Mitigation
measures do not supersede regulations under the jurisdiction of other
regulatory agencies."
4. Feasibility and Applicability
On pages 1-5 and 1-7, the language should reflect that Lead agencies will determine
the feasibility and applicability of measures and that the measures are intended to offer
a menu of options available should a lead agency opt to utilize them. The PER makes
the assertion on page 1-7 of the Project Description under Transportation Project
Mitigation and Lund Use Planning and Development Project Mitigation sections that the
draft PER has made a preliminary determination that all of the mitigation measures in it
are considered feasible. SCAG has not identified any analysis that supports the
feasibility of the mitigation measures that are to be undertaken by entities other than
Page 4 of 32
SCAG and SCAG staff has stated on numerous occasions that the mitigation measures
were intended to be a menu of options for consideration by lead agencies.
issue: Mitigation ieasures Impose Obligations Beyond Scope of 83 375. Given
the combination of the RTP and the SCS processes, as mandated by SS 375, we
recognize that SCAG must undertake the difficult task of balancing the goal of having a
coordinated regional transportation system with land use strategies that encourage a
more compact use of land. However, a key principle of SS 375 is that it is not intended
to supersede local agencies' authority to regulate land uses. Specifically, Government
Code section 65030(b)(2)(K) provides, in relevant part that ". . . .Nothing in a
sustainable communities strategy shall be interpreted as superseding the exercise of
the land use authority of cities and counties within the region..."
In light of the limitation expressed at Government Code Section 65080(b)(2)(K), we find
language in the PEIR, and specifically the mitigation measures therein, imposing
affirmative obligations on local agencies within the SCAG region to be inappropriate and
contrary to law. The proposed language as recommended below would remedy the
legal conflict with Section 65080(b)(2)(K), yet achieve SCAG°s recognition that
project -specific environmental review is the appropriate level of review for projects that
have their own unique, site-specific circumstances.
The revisions are further consistent with CCCGG°s understanding that SCAG intended
to provide the mitigation measures as a "toolbox" to local agencies for use within their
discretion if and when appropriate for projects within their respective jurisdictions,
Indeed, from materials presented by SCAG, including the January 26, 2012 workshop
held at the City of Anaheim Council Chambers, SCAG explained that "This PEIR offerz
a "toolbox" of m11gaVon measures for future project -level environmental analyses...
It also includes suggested mitigation measures for local agencies to consider for
implementation, if appropriate and feasible (phrased as "can and should"). This
language is permissive and not mandatory upon local agencies."
Mitigation Measures Impose Obligations Beyond Scope of SB 375
Recommendations:
1. Please provide SCAG analysis supporting the feasibility of mitigation
measures in the PEIR.
2. Change language on page 1-7 found in 2 places under MITIGATION
MEASURES, subheadings Transportation Project Mitigation and Land
Use Planning and Development Project Mitigation: "This Draft PEIR has
made a preliminary determination that the proposed mitigation
measures are feasible and effective. Therefore, of is reasonable to
expect that these agencies will actually implement them where, in the
agencies' independent discretion, the measures are deemed applicable
in light specific circumstances at the project level."
Page 5 of 32
3, Change language on page 1-5, first paragraph: "Mitigation Measures
proposed in this PEIR are available as tools for implementing agencies
and local lead agencies to use as they deem applicable. The
implementing agencies and local lead agencies are responsible fe-r
ensuring adherence to the mitigation measures as 29122935 RTP/SCS
projects are considered for approval over time."
4. please make similar text amendments to other sections, including the
E,,mcutive Summary, of the PEIR that reference how the mitigation
measu3,es are to be used by lead agencies.
5. 66Can and hould"
As indicated in the PEIR on page 1-5, state law provides that it is appropriate to indicate
in mitigation measures that they "can and should" be implemented where the authority
to implement the measures rests with agencies other than SCAG. The language
conveys to local agencies an affirmative obligation to address each mitigation measure,
irrespective of whether such agencies deem the measures applicable to a particular
project or duplicative of their own or other governmental agencies' regulatory measures
(as discussed in Section 14). OCCOG recognizes that SCAG's use of the words "can
and should" are derived from California Environmental Quality Act (CEQA), at Public
Resources Code sections 21031 and 2155.2(b)(5)(B)(ii) and CEQA Guidelines,
including section 15091(a)(2). Nevertheless, given the express limitation of SB 375
upon respective local agencies' land use authority, OCCOG deems any language
seemingly imposing afifirmative obligations contrary to SB 375 inappropriate. As such,
the use of the language "can and should" for mitigation measures addressed to local
agencies is inappropriate.
"Can and Should" Recommendations: Change language in all mitigation
measures identifying entities other than SCAG to read "saw -and should consider
where applicable and feasible." To clarify the intent that the mitigation measures
are a menu of options for which feasibility has not been established for any given
project, the "can and should" language should be changed in all mitigation
measures identifying entities other than SCAG to read "should consider where
applicable and feasible."
6. CEQA Streamlining:
One of the key components of SB 375 was the inclusion of incentives that provided
CEQA streamlining for projects consistent with the objectives of the bill as well as
consistent with the SCS. As identified on pages 1-10 through 1-12, for projects to
qualify for these incentives, mitigation measures from the applicable environmental
document must be incorporated into the project. It is not clear, however, which
measures would need to be incorporated into a project for it to qualify, particularly in
light of the intent of SCAG for the measures to be a toolbox.
Page 6 off 32
CEQA Streamlining Recommendations: Please clarify how the "menu od
mitigation measures" from this PER is expected to be used by a lead agency as
well as which ones lead agencies should address in order for a project to qualify
the use of the CEQA streamlining provisions of S13375.
7. GGTP/SCS Policies
Please ensure that the discussion of the pok° es represented by the RTP/SCS in the
draft PER is consistent with the policies actually in the RTP/SCS. In particular, the
bullet lost on the page 2-3 is stated to represent the land use strategies of the plana;
however, the strategies listed are not specifically identified in the regional SCS.
lncluding different language in the PEIR implies additional policy.
RTP/SCS Policies Recommendation: Amend the land use strategies identified on
page 2-3 of the Project Description, under the section Purpose and Need for
Action to reflect the strategies included in the SCS chapter of the RTP.
8. PER Mitigation Measures
By far the most concerning portion of the Draft 2012 RTP/SCS to CCC®G members is
the PER. Specifically, the proposed mitigation measures included in the PER extend to
and impact a broad spectrum of technical and policy areas. Many examples of these
concerns are included on Attachments 1 and 2 of this letter. In sum, the concerns are
that the mitigation measures:
• Appear to go above and beyond the requirements of the Regional (Transportation
Plan and Senate RI 375;
• Are measures already required by State and Federal law or are regulated by
other agencies such as the South Coast Air Quallty Management District,
California Department of Housing and Community Development, dish and Game,
and the Regional Water Control Boards;
• Appear to run counter to local control; and
• Are financially infeasible for the agencies responsible for implementation.
PER Mitigation Measures Recommendations.
1. In order for the mitigation measures to truly be considered a toolbox of
options for consideration by various entities in the SLAG region as
intended, all mitigation measures in the PER intended for entities other
than SLAG should be moved into an appendix to the PER and renamed
"Sustainability Strategies". These strategies could then be identified for
consideration by lead agencies as mitigation for future projects should
Page 7 of 32
a lead agency choose to do so and deem them applicable and feasible.
The PEIR would only retain mitigation measures applicable to SCAG.
This action would also require that the Executive Summary,
Introduction, and Project Description be updated to reflect the nature of
the new appendix of Sustainability Strategies.
2. Remove language within mitigation measures that establishes policies
not included in the RTP/SCS or modifies the measure to specify a policy
or endorses specific technology which would limit agency authority.
3. In the draft PEIR, please replace text in all mitigation measures that
identify policy for either SCAG or other entities with language that
reflects either adopted SCAG policies or are policies that are included in
the RTP and SCS. Mitigation measures should not be used to establish
new policy for the region.
For example:
• MM -TR 17: "SCAG shall (for its employees) and local jurisdictions Gan—a-nd
should institute where applicable and feasible teleconferencing, telecommute,
and/or flexible work hour programs
• MM -TR 23: "focal jurisdictions should consider when applicable and feasible
coordinated and controlled intersections so that traffic passes more efficiently
through congested areas. Where traffic signals or streetlights are installed,
require the use of a feasible, energy efficient Lig—€mittORO gj
technology."
• MM -TR 35: "Local jurisdictions should consider where applicable and feasible
the adoption of a comprehensive parking policy that
encourages the use of alternative transportation."
9. SCAG Authority
Several mitigation measures identify actions that SCAG shall undertake to mitigate
impacts of the plan. Many appropriately direct SCAG to provide a discussion forum or
serve as a central data repository for a broad range of topics that affect the region as a
whole. However, many measures inappropriately direct SCAG to establish practices,
standards, or policy in areas unrelated to what SCAG has purview over. (Further, the
measures often appear to be directed at policy implementation that is unrelated to the
plan itself, such as implementing AB 32. Such measures will essentially require SCAG
to establish policy in areas for which it has no authority. Additionally, it is not clear how
SCAG would fund the work efforts because they are not directly related to its mission
and, therefore, do not have funding. For example, MM -PS 118 states: "SCAG shall
continue to develop energy efficiency and green building guidance to provide direction
on specific approaches and models and to specify levels of performance for regionally
Page 8 of 32
significant projects to be consistent with regional plans." Green building practices and
energy efficiency measures are already addressed by various state and federal
agencies, as well as by other local organizatlons. Further, SCAG does not have the
authority to specify levels of perf'ormance for land use or buildings.
SCAG Authority Recommendation: Remove the following mitigation measures for
SLAG which it does not have purview for under the law or directed to do by the
Regional Council through policy direction. List may not be exhaustive.
MM-BIO/OS 44
MM -LU 42
IMM -LU 77
MM -PS 68
MM-BIO/OS 45
MM -LU 47
MM -LU 80
MM -PS 71
MM-BIO/OS 46
MM -LU 48
MM -LU 81
MM -PS 95
MM-BIO/OS 48
MM -LU 51
MM -LU 82
MM -PS 121
MM -G IG 3
MSM -LU 53
MM -LU 83
MM -`SIR 17
MM-GHG 8
MM -LU 56
MM -NO 12
MM -TR 23
MM -G IG 11
MM -LU 57
MM -NO 16
MM -TR 28
MM -LU 9
MM -ALU 60
MM -POP 1
MM -TR 35
MM -LU 21
MM -LU 61
MM -PS 3
MM -TR 83
MM -LU 22
MM -LU 64
MM -PS 14
MM -TR 85
MM -LU 24
MM -LU 65
MM -PS 25
MM -TR 96
MM -LU 26
MM -LU 69
MM -PS 37
MM -W 34
IMM -LU 32
MM -LU 71
MM -PS 39
MM -W 59
MM -LU 34
MM -LU 74
MM -PS 41
MM -W 60
MM -LU 41
MM -LU 75
MM -PS 67
MM -W 65
10. SCAG MitiUaVon M-sazuras
It would be helpful to understand how SCAG will implement the mitigation measures
that it is assigned to do. Many of the mitigation measures will expand SCAG's role into
areas that are not currently under Its purview and are under the jurisdiction of other
entities. Many also constitute significant work efforts.
SCAG Mitigation Measures Request: Please explain how the actions and
programs required by the measures SLAG is assigned to do would be funded to
ensure that they are truly feasible for SCAG to undertake.
11. Ensuring Outcomes
SCAG has limited authority in many of the areas included in the measures and will not
be able to ensure impacts are mitigated and that the outcomes identified do actually
occur. SCAG can assist, offer information, educate, and provide discussion forums for
topics outside its area of jurisdiction; however, it is not possible to "ensure" that
outcomes are achieved for things that are outside of its purview.
Page 9 of 32
Ensuring Outcomes Recommendation: Remove all references within mitigation
measures that SCAG will "ensure" rorr "-shall minimize impacts" that result from e
mitigation measures.
Example:
MM-CUL17: "
WGFmatffioR shaFing, and SCAGIs. shall, through cooperation,
information sharing and ongoing regional planning efforts such as web -
based planning tools for local government including CA lots, and direct
technical assistance efforts such as Compass Blueprint's Toolbox Tuesday
series, provide information and assistance to local agencies to help them
avoid impacts to cultural resources. Resource agencies, such as the Office
of Historic Preservation, shall be consulted during this process."
12. Fees and Taxes
Several mitigation measures indicate that local jurisdictions or other entities should
implement new fees or propose taxes to pay for a variety of programs or for acquisition
of land for preservation. lncreases to fees or taxes are issues that could require voter
approval and, thus not he approved. They also represent prescriptive means to
accomplish the mitigation,
aas 5 e nd Taxes Recommendations:
1. Reword measures to indicate that a new or increased fee, new tax, or
other increase is only an option as a way to implement the mitigation.
The following list may not be exhaustive.
MM-BIO/OS55
MM-PS15
MM- T R30
MM-TR88
MM-LU29
MM-PS63
MM-TR3p
MM-TR94
MM-LU53
MM-PS75
MM- R47
MM-TR96
MM-LU54
MM-PS76
MM-TR52
MM -W6
MM-LU80
MM-PS78
MM-TR60
MM -W32
MM-LU81
MM-PS92
MM-TR69
MM -W52
MM-LU82
MM-PS106
MM-TR74
MM -W58
MM-LU83
MM-PS107
MM-TR75
MM-POP4
MM-PS113
MM-TR80
MM-PS12
MM-TR28
MM-TR84
2. Please clarify whether it was assumed that these additional fees were
considered feasible and if the new fees that are suggested were
considered in the financial plan or economic analysis of the RTP.
Page 10 of 32
13. Guidance Documan°ts
Guidance documents aro there as information sources for consideration; however, they
do not represent regulation or estabiiish standards that are required to be achieved. For
example, MM-AQ19 inappropriately indicates that project sponsors should comply with
the CARB Air Quality and Land Use Handbook (June 2005) which is only a guidance
document.
Guidance Documents Recommendation: Remove references that indicate a
compliance with guidance documents from mitigation measures.
14. Duplicative/Existing Regulations
It is noted that many of the mitigation measures are duplicative of existing regulation or
processes (e.g. CEQA review requirements). Under the CEQA, it is intended that
measures be identified that will mitigate impacts of the project. Existing regulations are
already assumed to be abided by in the evaluation of the impact and the significance of
the impact is after all existing regulation is applied. Therefore, mitigation measures
should address those actions that need to be undertaken in addition to existing
regulation in order to mitigate the impact. Therefore, mitigation measures that simply
restate existing regulation are not valid mitigation for ;purposes of CEQA. Further, it is
possible for regulations to change over time. Because of this, restatement of the
regulation in the mitigation measures could result in future conflict between the stated
mitigation and the regulation. It has become common practice to state that existing
regulation will be implemented. When this is done, it is common practice when
compliance is used as a mitigation measure to simply state that the responsible entity
will simply comply with the regulation. If mitigation measures that restate existing
regulation are not removed, then it is requested that the wording of the measures be
restated to simply read that compliance with all applicable laws and regulations will be
undertaken. Language that could be used is: "Local jurisdictions, agencies, and project
sponsors shall comply, as applicable, with existing federal, state, and local laws and
regulations." Similar language is included in some mitigation measures. It is offered that
MM -PS 13 is a good example of the type of appropriate language and reads "Project
sponsors can and should ensure that projects are consistent with federal, state, and
local plans that preserve open space."
The water section provides another example. The PEIR includes 68 mitigation
measures in the Water Resources section regarding water quality. At least 35 of these
are related to storm water runoff best management practices (BMPs) that are currently
regulated through Municipal National Pollutant Discharge Elimination System (NPDES)
Storm Water Permits issued by Regional Water Quality Control Boards. In the SCAG
region, there are five water quality control boards each with its own Municipal NPDES
Storm eater Permit. The regulations and requirements contained in these permits vary
from each other. By listing specific measures in the PEIR that are not included in a
project's applicable Municipal NPDES Storm Water Permit, the PEIR creates conflicting
compliance requirements. To eliminate potential conflict with existing regulations, the
Paye 11 of 32
mitigation measures regarding specific EMPs should be removed and replaced with a
single requirement that each project must comply with its applicable Municipal NPDES
Storm Water PermR.
[OupDiz;Eitive/Existin(c Rec_ulallons Recommendations:
1. Please remove all mitigation measures listed in Attachment I ",mhos h a�
duplicative of existing regulations administered by or under the
jurisdiction of other agencies. The list may not be exhaustive.
2. For each impact, please add the following language: "Local
Nurisdictions, agencies, and project sponsors should comply, as
applicable, with existina federal, state, and local laws and reaulations."
15. Draconian Mitigation Measures
Many of the mitigation measures in the Draft PEIR are draconian and need to be
removed. One prime example is MM -LU 35. It reads in part "Local jurisdictions can and
should reduce heat gain from pavement and other hardscaping including: Reduce street
rights-of-way and pavement widths to World War II widths (typically 22 to 34 feet for
local streets and 30 to 35 feet for collector streets curb to curb)..." Although reduced
street widths may be appropriate in some cases and have been implemented in many
jurisdictions, it is inappropriate and counterproductive to require reduced street widths
as a mitigation measure in the PEIR. Reduced street widths, for example, generally do
not provide space for on -street parking which may result in greater, additional paved
areas provided in separate parking lots. A second example is MM-LU15: "Project
sponsors can and should ensure that at least one acre of unprotected open space is
permanently conserved for each acre of open space developed as a result of
transportation ,projects/improvements." Measures should support the SCAO Energy and
Environment Committee which recommended that the programs build upon existing
open space land acquisition and open space programs in the region, tailoring programs
to each individual county in the region. These include, but are not limited to, OCTA's
Measure M Mitigation Program, and Transportation Corridor Agency's open space
mitigation program, which has protected 2,200 acres in perpetuity to date. Open space
conservation should be pursued in a voluntary manner, working with willing private
sector landowners and not be overly prescriptive and specific.
Draconian Mitigation Measures Recommendations: Remove mitigation measures
that are very prescriptive, such as reducing street widths to WW II widths or
specifying preferred technology.
In addition to the above comments, detailed technical comments, language changes,
and questions on the RTP/SCS, Appendices, and PEIR documents are included in
Attachment 2.
Paye 12 of 32
recognre the Immense rte. it tQQk to prepare these documents. They represent
incriibly coinple t�echrtical �nreck aril have irnportr-`rpt and far-raachirtc piolidy, impacts
for aur regiQn . However, bemuse of this importance and complexity, we would like to
expfconcAm About the timing of the release of AhO documents and hope that
preparation of future RTNtC& 'documents will take into 'account the need to
accommodate adequate rev%wx discussion and revision time for all of the
documents.,
The current timeline: of document release publlp comm -60t period, anti tirrie alie�red far
the response to oo rnents results in an inability to havecredible discussion regarding
passible changes because the timeline does not allow fol• recirculation or full discussion
of;regtae - change$. The documents were released over the .holiday season and
Included thO release of the clr�aaft PEl1 document on 0 bot tber 30, 2011. The rnloi tturtr
-day public comment period closes cin `February Only a few Meeks are
provided tO prspar"e responaes-to co ' rii nts.and amend the oocuments.to ensure that
the Regional Council may consi.dr'the certification of the PAIR and the approval of the
draft Fel-MCS on April 4, 2012:
We appreciate your consideration of all of`the com nts providad in this letter and its
attachr6en4 end look forward #o your responses; .It is; a shared goal to have: an
.RTP/SCS adopted that is credible and defensible ,on all, levels, If you have any
quiestiQns, please do:. not hesitate to contsct.me or. Dave Simpson, OCCOO's Executive
Director.
o
"')Peter Heriog.
Chairmen
cc. OCCO M ember Agencies
OCCG .Board of Director$
OCTA 869rd of Directors
Grange County City Managers, Association
Fogs 13 of 32
Attachment 1: Mitigation Measures Duplicative of E,,dsting Regulation
(Listed by type of regulation measures duplicates)
M -T
QuaNy/AQ D
CDFG
Fszlsral & stata
]z-']
Fa-far@�
F, a30UTZ;r
agendas
MM-AQ1
MM-BIO/OS1
MM-HM3
MM-LU14
MM-TR33
MM-AQ2
MM-BIO/OS3
MM-HM4
MM-LU30
MM-BIO/OS29
MM-AQ3
MM-BIO/OS4
MM-HM5
MM-BIO/OS30
MM-AQ4
MM-BIO/OS8
MM-HM6
MM-BIO/OS31
MM-AQ5
MM -S3 O/OS10
MM-HM7
NPDES
MM-BIO/OS32
MM-AQ6
MM-BIO/OS11
MM-LU28
MM-AQ16
MM-BIO/OS33
MM-AQ7
MM-BIO/OS17
MM-NO18
MM-
BIO/OS19
MM-BIO/OS34
MM-AQ8
MM-BIO/OS18
MM-PS13
MM-GEO5
MM-BIO/OS35
MM-AQ9
MM-BIO/OS21
MM -W36
MM -W1
MM-BIO/OS50
MVi-AQ10
MM-BIO/OS22
MM -W37
MM -W13
MM-BIO/OS51
MM-AQ11
MM-BIO/OS23
MM -W38
MM -W58
MM-AQ12
MM-BIO/OS24
MM-AQ13
MM-BIO/OS25
Flood control
MM-AQ14
MM-BIO/OS26
MM-HM8
MM-AQ17
MM-BIO/OS27
MM, --AQ18
MM-BIO/OS28
Local
A encles
MM-BIO/OS14
MM-AV11
MM-BIO/OS7
3•121S lays
MWAV3
MM-HM10
MM-PS4
MM-PS107
MM -W25
MM-AV6
MM-HM11
MM-PS8
MM-PS113
MM -W26
MM-AV12
MM-HM12
MM-PS10
MM-PS119
MM -W27
MM-BIO/OS20
MM-HM13
MM-PS12
MM-PS122
MM -W28
MM-CUL1
MM-HM14
MM-PS14
MM-TR29
MM -W29
MM-CUL2
MM-HM15
MM-PS16
MM-TR49
MM -W30
MM-CUL3
MM-HM16
MM-PS35
MM-TR55
MM -W31
MM-CUL4
MM-LU10
MM-PS36
MM-TR75
MM -W32
MM-CUL5
MM-LU11
MM-PS37
MM -T89
MM -W39
MM-CUL6
MM-LU17
MM-PS42
MM -W6
MM -W43
MM-CUL7
MM-LU19
MM-PS43
MM -W8
MM -W46
MM-CUL8
MM-LU20
MM-PS48
MM -W9
MM -W47
MM-CUL9
MM-LU38
MM-PS55
MM -W10
MM -W48
MM-CUL10
M-LU43
MM-PS56
MM -W11
MM -W49
MM-CUL11
MM-LU44
MM-PS57
MM -W12
MM -W50
Page 14 of 32
MM-CUL12
MM-LU48
MM-PS59
MM -W15
MM -W51
MM-CUL13
MM-LU58
MM-PS61
MM -W16
MM -W52
MM-CUL15
MM-NOI
MM-PS67
MB�fli-W17
MM -W54
MM-CUL16
MM -N04
MM -V S69
MM-VVl8
MM -W55
MM-GE01
MM -N08
MM-PS71
mm -w19
MM -W56
MM-CE02
MM -909
MM-PS73
MM -W20
MM -W61
MM-GE03
MMM-POP2
MM-PS77
MM -W21
MM -W62
MM-GE04
MM-POP4
MM-PS89
MM -W22
MM -W64
MM-GE06
MM-PS1
MM-PS92
MM -W23
MM -W66
MM-HM9
MM-PS2
MM-PS97
MM -W24
MM -W68
Page 15 of 32
Attachment 2: Additional Technical Clarifications on documents are also offered as
follows:
2012 I � u P/SC S
Page 16 of 32
TOPIC/
PAGE
RTP NARRATIVE, COMMENT &
REQUEST
REFERENCE
RECOMMENDATION
1
General
all
All chapter headings should include the Chapter
Comment
number on each page for ease of reference.
2
Clarification
1, left column
"The 2012 RTP/SCS includes a strong commitment
to reduce emissions from transportation sources to
comply with SB 375, both improve public health,
and meet the National Ambient Air Quality
Standards as set forth by the federal Clean Air Act,
As
3
Clarification
4, right
"This region needs a long-term, sustainable funding
column
plan that ensures the region receives its fair share
of funding, supports an efficient and effective
transportation system that grows the economy,
provides mobility choices, and improves our quality
of life,"
4
Clarification
page 7-
Is additional $0.15 gas tax the sum total of both
Table 2 and
state and federal taxes or $0.15 each?
page 95 -
Table 3.3
5
Clarification
40, left
"Strategic investments, put forth by the private
column
sector, that would remove barriers associated with
telecommuting are expected..."
5
Correction
page 42-
241 toll road completion year is 2030
Table 2.2
7
Please
50, left
"scrip„
define in the
column
text and add
to a glossary
8
Clarification
54, right
"Express/1-10 T Lane Network
column
Despite our concerted effort to reduce traffic
congestion through years of infrastructure
investment, the region's system demands continue
to exceed available capacity during eak eriods."
9
Clarification
70,78
Greenhouse Gases and Air Quality
SCAG seems to rely on CEQA to achieve the
"maximum feasible" reductions in emissions from
transportation. However, this is not consistent with
the intent of SB 375's goal of achieving specific
thresholds of 8% by 2020 and 13% by 2035 through
a sustainable communities strategy plan.
Page 16 of 32
Page 17 of 32
TOPIC/
PAGE
RTP NARRATIVE, COMMENT
REQUEST
REFERENCE
RECOMMENDATION
Please provide clarification to this section indicating
if the air quality and greenhouse gas CEQA
mitigation measures obligate regional agencies and
project developers to undertake more strategies,
programs and mandates beyond those included in
the OC SCS.
10
Clarification
73, right
"Greenhouse Gases
column
On road emissions (from passenger vehicles and
heavy duty trucks) constitute 93 percent of the
transportation sector total. Emissions from
passenger vehicles, which are the subject of
SB 375 and this RTP/SCS, constitute % of the
transportation sector's greenhouse gas emissions
total."
11
Clarification
30, left
Statements are made, such as the following, "the
column
RTP has the ability to affect the distribution of that
growth" (in population in the region). These
statements could be interpreted to be contrary to
SCAG`s obligation under the Memorandum of
Understanding with OCCOG to respect the
strategies and local land use policies in the OC
SCS.
Please clarify how it is in SCAG°s ability to affect
local change when the OC SCS is consistent with
acceptance of local land use plans and planned
population and employment distribution?
Recommended text change: "Transportation
projects including new and expanded infrastructure
are necessary to improve travel time and can
enhance quality of life for those traveling throughout
the region. However, these projects also have the
potential to +age attract more of the regional
population growth in certain areas of the region.
This means that although Ail, SCAG does not
anticipate that the RTP would affect the total growth
in population in the region, the RTP has the ability
to affect the distribution of that growth."
transportation projects in the RTP also have the
potential to divide established communities,
rimarily through acquisition of rights-of-way."
Page 17 of 32
#
TOPIC/
PAGE
RTP NARRATIVE, COMMENT &
REQUEST
REFERENCE
RECOMMENDATION
82, right
Text indicates that the RTP and projects in the
column
RTP/SCS as "inducing" growth. It is noted that use
of the term "induced growth" has a negative
connotation and implies growth above and beyond
what would occur naturally. However, it is stated in
the RTP that the population, housing, and
employment growth totals are fixed and only the
distributions may change based on the plan. This
means there will not be "new" growth and that the
RTP and SCS may simply influence and shift the
growth anticipated for the region. This moving of
growth is the result of changes in distribution that
are due to changes in land use or densities.
Because of this, it is requested that references to
"induced growth" be reworded to reflect the shifting
of growth in the region.
Recommended text change: "Cumulative impacts
from the projected growth 6ndUGed by thq RTD
include increased impervious surfaces;..."
12
Clarification
Chapter 3
SCAG's Financial Plan includes a significant portion
of "New Revenue Sources and Innovative
Financing Strategies" that are not currently in place
or available. While some of the proposed revenues
are within the control of SCAG or MPOs and
County Transportation Commissions, the majority of
the revenues (in terms of dollars) require either
state or federal action to implement.
Please explain what the implications are if these
new revenue sources and innovative financing
strategies do not become available?
13
Clarification
page 95-
"Mileage based useF fees w9 �'�'� be
Table 3.3
feplese--gas tax and augment estimated at .,hn„+
inn n
PUFGha staFting 292-
Suggested language is from page 31 of Growth
Forecast Appendix:
"Current gasoline tax, estimated at about $0.05
(2011$) per mile will increase through 2025, then in
2026 it would be replaced with a mileage -based
user fee indexed to maintain purchasing power."
Page 18 of 32
#
TOPIC/
PAGE
RTP NARRATIVE, COMMENT &
REQUEST
REFERENCE
RECOMMENDATION
14
Clarification
105, right
"While the region was once known worldwide as the
column
"capital of sprawl," the region today is projecting
growth on only a small fraction of the ha6 14e raw
land available in the region 'A-ft- t.9 ;aGG9mmedate
15
Clarification
105, right
"While the region was once known worldwide as the
column
"capital of sprawl," the region today is projecting
growth on only a small fraction of the has little raw
land available in the region
16
Clarification
106
SCAG indicates that the OC SCS has been
incorporated into the regional SCS. OCCOG was
one of two subregions that undertook the arduous
task and obligation of preparing an SCS.
Please add clarifying text that these subregional
SCSs, including the OC SCS, represent the
Sustainable Communities Strategies applicable to
those subregions.
17
Clarification
110, right
"Municipal water and sewer systems, for example,
column
ensure clean water. At the same time, sepsrete
apA
as areas become more
urbanized and the percentage of impervious
surface is increased, the hydrologic regime is
dramatically altered. Drainage conveyances that
once were natural and riparian are required to be
engineered as hardened flood control channels to
provide adequate protection of private property and
public infrastructure from the increased frequency,
duration, peak flow, and overall volume of
stormwater runoff. With this armoring of once
natural channels, water quality benefits from
biofiltration are lost along with opportunities for
infiltration and evapotranspiration, which can lead to
hydromodifcation downstream in sections which are
not vet engineered and hardened. Many
strategies..."
18
Clarification
112,117
The SCS documents the development of four
scenarios to explore basic aspects of future growth.
These scenarios were used in public outreach and
the SCS and the associated Appendix states that
"Using the public dialogue and feedback from the
analysis of the SCS Scenarios, SCAG developed
Page 19 of 32
Page 20 of 32
TOPIC/
PAGE
RTP NARRATIVE, COMMENT &
REQUEST
REFERENCE
RECOMMENDATION
the 2012 RTP/SCS Plan alternatives." (&mHar
references are also include at RTP/SCS p. 117, and
SCS Background Documentation p. 71). The
RTP/SCS and Appendix then describes a process
that led to the Plan alternatives. Neither the
RTP/SCS, Appendix or PEIR expressly state or
illustrate the fundamental land use and
socioeconomic foundation for the SCS.
In order to confirm consistency with the OC SCS, it
is requested that SCAG include appropriate tables,
graphics and maps that provide the detail that
confirm this consistency.
19
Clarification
113,122
The regional SCS states that the
scenarios/alternatives were developed using the
Local Sustainability Planning Tool (LSPT). The
LSPT is a sketch planning tool that flattens
geographical areas to a 5 -acre grid coll. The OC
SCS land use data was provided at much greater
level of detail in that specific parcel data and detail
were provided by each jurisdiction. A cursory review
of some LSPT data reveals inconsistencies
regarding interpretation of Orange County land
uses.
It is acknowledged that the regional SCS states,
"Land use inputs for OCCOG SCS were
unchanged". Yet use of the LSPT and SCAG
Development and Community Types presented in
the SCS leave open the question as to whether the
OC SCS was altered, as noted above.
Please provide confirmation that the underlying OC
SCS land use data was used without significant
alteration and LSPT flattening and interpretation in
the development of the regional SCS Plan and
alternatives.
20
Add to
127, right
"Gentrification"
17
glossary
column
21
Clarification
128, left
"Thus, this adjustment allowed the land use pattern
column
to conform more closely to local e)(peG--,'--ti---
general plans, while reducing the amount of vehicle
miles traveled."
Whose/What are "local expectations?"
Page 20 of 32
#
TOPIC/
PAGE
RTP NARRATIVE, COMMENT
REQUEST
REFERENCE
RECOMMENDATION
22
Clarification
149, right
Revise language to clarify that SCAG intends
column
policies, strategies, and measures are a menu of
options.
"The following tables list specific implementation
strategies that local governments, SCAG, and other
stakeholders may use or consider while oreparinq
specific projects which would help
to successfully implement the
SCS."
23
Clarification
150-152
The OC SCS was accepted by SCAG and
represents the set of strategies and the growth
distribution that outlines the best approach for how
the requirements of SB 375 would be met 'within the
subregion. Specifically, the OC SCS included 15
specific Sustainability Strategies, reflecting a menu
of 222 practices and actions that OC agencies have
agreed to pursue (or continue to ,pursue) to achieve
GHG reductions that support SB 375.
Why doesn't the regional SCS specifically
acknowledge these 15 strategies yet include other
strategies and performance measures not included
in the OC SCS (e.g., Locational Efficiency)?
24
Add to
166, right
"Greenfield"
glossary
column
25
Clarification
194, right
"In addition to these targeted outreach efforts, all
column
regular and special meetings of the RTP task
forces, the Transportation Committee (TC), the
CEHD, the EEC, and the SCAG Regional Council
are publicly noticed and ..."
26
Clarification
201
Please clarify whether the text stating "Long-term
emission reduction for rail, with a goal of zero -
emissions rail system" is intended to reflect a zero -
emissions freight rail system, or whether this goal
also applies to passenger rail.
27
Clarification
202,
Unfunded operational improvements, of which
203-
several are listed on page 203, Table 7.1, include
Table 7.1
transit station improvements in Irvine, Fullerton, and
Santa Ana, bus rapid transit (BRT) in Orange
County, and high speed rail (HSR) Phase 11.
Please confirm that these are consistent with the
OC SCS.
Page 21 of 32
#
TOPIC/
REOUEST
PAGE
REFERENCE
RTP NARRATIVE, COMMENT &
RECOMMENDATION
23
Clarification
207
Strategic Finance
growth
Please explain what will happen if reasonably
forecast
foreseeable revenue sources of approximately $200
numbers
million do not become available?
29
Add to
205
"Active transportation"
glossary
numbers (i.e. OCP -2010 Modified) into all reports,
GROWTH FORECAST APPENDIX
#
TOPIC
PAGE
REFERENCE
NARRATIVE, COMMENT & RECOMMENDATION
1
Updated
23, Table 13
In December 2011, Orange County provided SCAG
growth
with the revised growth forecast dataset, OCP -2010
forecast
Modified, per the OC SCS MOLD (official OCCOG
numbers
Board action 1/26/2012).
Please incorporate revised Orange County
numbers (i.e. OCP -2010 Modified) into all reports,
tables, exhibits, alternatives, maps, and modeling
runs for final RTP.
PERFORMANCE MEASURES APPENDIX
#
TOPIC
PAGE
REFERENCE
NARRATIVE, COMMENT &RECOMMENDATION
1
Clarification
1
The document states, "The performance measures
are used to evaluate how well the RTP/SCS
addresses the adopted goals and performance
outcomes."
Is there any formal role for the performance
measures?
ARB will evaluate for SB 375 compliance not based
on these measures but based on ARB process.
Please include language clarifying that this is a
requirement to demonstrate compliance with federal
requirements and not for the obligations under SB
375.
Page 22 of 32
Page 23 0132
TOPIC
PAGE
REFERENCE
NAFR_F�ATI` E, COMMENT & RECOMMENDATION
2
Clarification
1, end of first
Add statement; "Performance measures and
paragraph
expected outcomes will be used to monitor the
RTP/SCS at the regional level; these measures and
outcomes are not proposed for use at the
subregional or project -specific level."
3
Clarification
1, column 2
The document states, "The Regional Council will
formally adopt the goals and outcomes as part of
the final 2612 RTP/SCS.,,
Does this bring any formal obligation to meet goals?
Goals are general, flexible, and aspirational rather
than specific, as on p.1.
4
Clarification
13, Table 3
The RTP/SCS claims an extra 2% CO2e emissions
reduction in 2035 from the NITS post -processing
analysis. While the RTP/SCS meets the ARB
SB375 goal without the extra 2%, we would like to
note that the extra 2% could be important if the
attorney general raises concerns about backsliding.
Consequently, the reliability of the extra 2%
reduction should be checked. Questions on the
NHTS model are below.
It would be useful to know the answers to better
judge the quality, although we do note that the
report does look like it meets the standards or best
practice.
5
Clarification
g
NFITS Model Documentation Report
Are the auto and bus accessibility variables
included in the regression models for 30 -mile rings?
In "Number of trips" model e is number of cars,
included as an independent variable, the actual or
predicted value?
The same question applies to other models.
6
Clarification
23, Table 10
NHTS Model Documentation Report
Were the elasticities for the SCAG NHTS study
calculated at sample means, or for each
observation and then averaged for the sample?
Page 23 0132
#
TOPIC
PAGE
REFERENCE
NARRATIVE, COMMENT & RECOMMENDATION
7
Clarification
24, Test 3
NHTS Model Documentation Report
define
column
(Compare Trip -Based and NHTS Model): The final
test was to compare the results of the Trip -Based
2
Clarification
71-74, 80-83
Model and the NHTS Model for the same scenarios.
Please describe the scenarios tested.
TRANSPORTATION FINANCE APPENDIX
#
TOPIC
PAGE
REFERENCE
NARRATIVE, COMMENT & RECOMMENDATION
1
Clarification
General
What are the implications if revenues other than
define
column
core revenues do not become available?
Please describe any implications to the ability of the
2
Clarification
71-74, 80-83
region to meet SB 375 GHG emission reduction
targets or the federally required air quality
conformity?
SCS BACKGROUND DOCUMENTATION APPENDIX
#
TOPIC
PAGE
REFERENCE
NARRATIVE, COMMENT & RECOMMENDATION
1
Please
53, right
Housing Options and Mix:
define
column
Define Larger -lot single family in text
2
Clarification
71-74, 80-83
Alternatives naming: A, B, C
Names of Alternatives differ than those listed in the
PEIR on pages ES -3 and 1-4.
Please be consistent with naming protocol for
alternatives between two/all documents.
Page 24 of 32
Page 25 of 32
TOPIC
PAGE
NARRATIVE, COMMENT & RFCON lei ENDATlON
REFERENCE
3
Revise
71, right
"Plan Alternative (B)
language to
column
... The alternative maintains city-level forecast
clarify
control totals for both households and jobs,
however, within city boundaries shifts are made to
focus a much larger share of future growth in a
more compact way around HQTAs, except in
Gateway and Orange County COG subregions per
their SCS delegation agreements. Future housing
market demand is expected to shift significantly to
small lot single -family, townhomes and multi-family
hggsin ."
4Please
71, right
Plan Alternative (B)
define
column
Define small lot single family in text
5
Revise
71, right
Plan Alternative (C)
language to
column
"As a result very suburban communities may
clarify
experience no new housing or employment growth,
while some urban areas with very good access to
regional transit may experience significant
increases in housing or employmentgrowth."
6
Revise
72, left
"While each alternative is distinctive, a number of
language to
column
parameters remained constant across each
clarify
alternative: the regional RTP/SCS forecast total for
population, households and jobs;..."
"Detailed forecast: the detailed distribution of
population, households, and jobs across the
region... "
7
Revise
72, Table D1
Alternatives A & B:
language to
"Controlled to TAZ-based RTP/SCS Forecast for
clarify
2020; Controlled to city-level RTP/SCS Forecast for
2020-2035, except in Gateway and Orange County
COG subregions per their SCS delegation
agreements."
Add statement to table notes: Gateway and Orange
County COG subregions' local input data will not be
chan ed per their SCS delegation agreements.
8
Revise
74, Table D2
Alternatives A & B:
language to
Add statement: Gateway and Orange County COG
clarify
subregions' local input data will not be changed per
their SCS delegation agreements.
Page 25 of 32
Page 26 of 32
TONIC
PAGE
NARRATIVE, COMMENT & RECOMMENDATION
REFERENCE
9
Clarification
75, right
°`Development Types
column
The alternatives are built on, and provides data at,
the level of the TAZ, which includes housing units
and employment."
Please clarify if TAZ is Tier 1, Tier 2, or both.
19
Revise
79, right
"Subregional SCSs submi2ed by the Gateway
language to
column
Cities Council of Governments (GCCOG) and the
clarify
Orange County Council of Governments (OCCOG)
will be Fespeeted unchan d and integrated into the
alternatives (with possible revisions for Alternative
C only)."
11
Clarificatlon
79
The section includes the following language:
"Subregional SCSs submitted by the Gateway
Cities Council of Governments (GCCOG) and the
Orange County Council of Governments (OCCOG)
will be respected and integrated into the
alternatives (with possible revisions for Alternative
C only)."
Please clearly indicate what the "possible revisions"
are and what process would be used to coordinate
with Orange County should changes to the
socioeconomic data contained in the OC SCS be
proposed?
12
Revise
89
Alternative A
language to
Add statement: Gateway and Orange County COG
clarify
subregions' local input data will not be changed_�er
their SCS delegation agreements.
Page 26 of 32
Page 27 of 32
TOPIC
PAGE
NARRATIVE, COMMENT & RECOMMENDATION
REFERENCE
13
Revise
31
Alternative B
language to
It is not clear whether Alternative B is the SCS land
clarify
use plan. if it is, statements in the appendix lead
one to believe the CC SCS foundation has been
altered. For example, adjustments made to Band
uses to locate proximate to High Quality
Transportation Areas (HQTA) and intensification of
residential and employment development in HQTA
that diverge from local General Plans as well as
implementation of a vehicle user fee are not part of
the OC SC&
Is Alternative B the SCS Ian,d use plan?
Add statement: Gateway and Orange County COG
subregions' local input data will not be changed per
their SCS delegation agreements.
14
Clarification
115, left
Transit Zoning Code Santa Ana 2011
column
Is this a duplicate of the 2010 Santa Ana project?
Page 27 of 32
PEIR
#
TOPIC
PAGE
REFERENCE
PEIR NARRATIVE, COMMENT &
RECOMMENDATION
1
Revise
language to
clarify
ES -2
ES contains matrix of mitigation measures which
reference project sponsors, local agency, and
project implementation agency without definitions.
Add definitions into ES at end of ES.1:
In -general, the terms "local agency," "project
sponsor" and "project implementing agency" are
used throughout this PEIR to identify agencies,
organizations, companies and individuals that will
act as lead agencies or project applicants for
different types of individual projects. Individual
projects that are
anticipated to occur pursuant to the 2012-2035
RTP/SCS consist of planning projects (general
plans, specific plans, climate action plans, etc.),
development projects (including Transit Priority
Projects (TPPs) and other similar projects), and
transportation projects.
In general, "local agency" is used to refer to a public
aaencv that would propose a planning project or a
public infrastructure project and/or an agency that
would be lead agency for individual projects.
"Project sponsor" is typically used to refer to an
applicant (that could be public or private, an
organization or an individual) that proposes a
project. "Project implementing agency" is used to
refer to an agency responsible for implementing a
project. In this document, project -implementing
agencies are those that are responsible for carrying
out (reviewing, approving, constructing)
transportation projects.
2
Clarification
ES -3, 1-4,
Chapter 4
Alternatives' Naming: No Project Alternative,
Modified 2008 RTP Alternative, Envision 2
Alternative; Alternatives 1, 2, 3
Names of Alternatives differ than those listed in the
SCS Background Documentation appendix on
pages 71-74 and 80-83.
Please be consistent with naming protocol for
alternatives between all documents.
Page 28 of 32
#
TOPIC
PAGE
PEIV � NARRATIVE, COMMENT &
REFERENCE
RECOM MENDATION
3
Fix
ES -31
Duplicate naming of GHG11 and GHG12
numbering
4
Please
ES -42
LL163- What are the smart growth principles?
define
5
Please
ES -42
LU64- What are the benchmarks for smart growth?
define
6
Fix
ES -51
PSI 7 & PSI 8 are missing
numbering
7
Fix
ES -53
Duplicate naming of PS36 & PS37
numbering
8
Please
ES -67
TR 34- what are the identified transportation
define
benchmarks?
9
Please
ES -83, 3.13-
Define climate change hydrology
define
42
MM -W43
10
Please
ES -40, 3.821
Define urban groNjvth boundary
define
MM-LU42
11
Please
ES -57, 3.11-
Define parking cash out program/ cashouts
define
49
MM-PS68 &
ES -74, 3.12-
43 MM-TR96
12
Clarification
1-5
Besides IGR, what other monitoring efforts is SCAG
in charge of? (that would require lead agencies to
provide SCAG with documentation of compliance
with mitigation measures)
13
Language
1-6,
Language correction: "The 4-rUaF fiormZ)F find ing...
correctionara
rah 3
14
Language
2-5
Sustainability section should be separated.
correction
Language correction:
Sustainability. The 2012-2035 RTP/SCS is subject
to specific requirements for environmental
;performance.
New paragraph:
"Beyond simply meeting these requirements, a ..."
15
Language
2-5, Table
"Align the plan investments and policies with while
correction
2-2
improving..."
16
Please
2-14
Define "scrip"
define
Page 29 of 32
L�
TOPlC
PAGE
PEIR NARRATIVE, COMMENT
REFERENCE
REC®MM ENDA Tl®N
17
Narrative
2-21
AB 32 is global warming solutions act. SB 375 was
determined to be stand-alone legislation. RTP
document is not forum to address global cl°mate
change and references distract from GGTP goal and
purpose. "Global warming" and "global climate
change" are not interchangeable phrases.
References should be removed or, where
appropriate, language should be changed to "global
warming".
1regf
Bali c
18
Clarification
2-27
Not in SCAG's authority, nor funding available.
paragraph 4
Delete sentence:
SGAG will we* with !eG-'
mi in stakeholders t- See1�cI___UfGea—a4;d1
GGFnd
g e RtFi io
es and VUIma__rn_hIq_Q bins
19
Clarification
2-27
"The 2012-2035 RTP/SCS land use development
paragraph 5
pattern accommodates over 50 percent of new
housing and employment growth in HQTAs, while
keeping jurisdictional totals consistent with local
input."
Please confirm that there are no changes to the
local land use inputs provided by ®range County.
Page 30 of 32
Page 31 of 32
TOPIC
PAGE
REFERENCE
PEIR NARRATIVE, COMMENT &
RECOMMENDATION
20
Clarification
2-29
"For purposes of SCAG's SCS, a Development
Type reflects an estimated average density of 22
residential units per acre, (However, it is important to
note that the designation is a potential ultimate
average for the "JAZ—and is not an absolute
project -specific requirement that must be met In
order to determine consistency with the SCS. In
other words, the SCS was not developed with the
intent that each project to be located within any
given TAZ must exactly equal the density and
relative use designations that are indicated by the
SCS Development Type in order for the project to
be found consistent with the SCS's use
designation, density, building intensity and
applicable policies, Instead, any given project,
having satisfied all of the statutory requirements of
either a residential/mixed-use project or TPP, may
be deemed by the lead agency to be consistent
with the SCS so long as the project does not
prevent achieving the estimated average use
designations, densities and building intensities
indicated by the Development Type within the TAZ,
assuming that the TAZ will be built -out under
reasonable local planning and zoning
assumptions."
Does the above PEIR language create a
requirement for average TAZ density levels in 2035
and a requirement that each local project not
preclude those density levels?
Additionally, please clarify whether in HQTAs, these
densities could be exceeded as well as implications
of an area that is already fully developed not
redeveloping such that it ever achieves the
identified densities.
21
Please
3.3-5
Define "open space"
define
paragraph 3,
Page 31 of 32
Page 32 of 32
TOPIC
PAGE
REFERENCE
PEIR NARRATIVE, COMMENT
RECOMMENDATION
22
Revise
4-39
Envision 2 alternative contains growth projections
language to
that would place housing in flight paths, locate
clarify,
housing on sites for which housing is not allowed
due to environmental contamination, would
significantly impact existing industrial operations
necessary to maintain puaRy jobs in the region,
and does not include deveiopment projects that are
legally allowed due to having existing entitlement
for development. Because this alternative does not
consider the existing health and safety of future
residents nor the existing legal approvals of
development in the region, it is not possible to
determine if the alternative is actually superior to
other alternatives. It is simply another alternative
for consideration.
Please remove references to the Envision 2 (or any
other name of this alternative) as being
environmentally superior.
ENVIRONMENTALLY SIJP ENVISION 2
ALTERNATIVE
23
Revise
4-40
"Of the three alternatives, the Envision 2 Alternative
language to
would be considered by State CEOA Quidelines as
Clarify
the environmentally superior alternative because it
does not allow further use of land for single-family
develo ment..."
Page 32 of 32
ATTACHMENT C
LETTER DATED FEBRUARY 14, 2012, FROM OCTA TO SCAG
80ARD or DIRECTORS
February 14, 2012
Paul G. Glaab
Chairman
Mr. Hasan Ikhrata
Executive Director
__ mg wintarhoJ6m
Vice Chainnan
Southern California Association of Governments
JorryArnrtntc
818 West Seventh Street, 12th Floor
Dimdor
Los Angeles, CA 90017-3435
Dor; GonkhoOd
DirA0t°r
Re: Comments on the Draft 2012 Regional Transportation Plan and Program
Pat,iaia Vale,
Environmental Impact Report
Directnr
�1lrrcarr��rx:n
Director
Dear Mr. Ikhrata:
Carolyn Cavecche
r)irel.tor
Thank you for the opportunity to comment on the Southern California
L-7ayrra,rdall
Association of Governments' (SCAG) draft 2012 Regional Transportation
Director
Plan (RTP) and associated Program Environmental Impact Report (PEIR). The
W;lr'an?.,.Wilton
2012 RTP and PEIR are comprehensive documents that reflect the
Dir°Vor
transportation and funding challenges the region will face in the coming years,
1_oni avomv
in addition to the program level impacts and mitigation options. These
nirectar
documents are critical to the region's ability to operate, maintain, and improve
Din Hari.r.•h
the transportation system.
Director
Michael Hennessey
Director
The Orange County Transportation Authority (OCTA) appreciates that SCAG
has included the commitments identified in OCTA's 2010 Long -Range
r'eter"n2°g
Director
Transportation Plan, Destination 2035, as well as the demographic forecasts
and land -use data submitted through the 2010 Orange County Sustainable
JohnWooriach
Dire(tor
Communities Strategy.. In addition, OCTA appreciates the hard work and
shay �wpr,Gr,
cooperation of SCAG staff throughout the RTP and PEIR development process.
DPrertor
Jr)rretrtr9uYen
OCTA has coordinated with Orange County's local jurisdictions to identify policy
Diructor
and technical issues related to the draft 2012 RTP and PEIR that are of concern
Ili-11`-Ilido
to Orange County. The issues that were identified through this effort, and that
Oirocror
are of particular concern to OCTA, are discussed below. Some of these issues
CirciY C7wn
rzovnrnnr's
were previously transmitted' to SCAG in a letter dated October 7, 2011. Since a
x-of„r;lolvlo�r�lx�r
response to the October letter was never received from SCAG, OCTA strongly
urges SCAG to carefully review the issues below and provide specific and
detailed responses.
::Farr t:,�c=ct� frFir: or1'�<_•ts
1414i�'Vnrlplorl
Innovative Financing and New Revenue Sources
C:nirf 1:� recuthca Gr;Scf�r
The draft RTP suggests that $127.2 billion of the approximately $219.5 billion
regional shortfall can be addressed through actions at either the state or federal
level with a $0.15 gas tax increase between 2017 and 2024. After.that, the
draft RTP assumes that the state or federal government would either replace
the gas tax with an indexed mileage -based user fee of $0.05 per mile,
Orange County Transportation Authority
550 South Mahn Street / P0, Box 14184 / Orange / California 92863.1584 / (714) 560 -OCTA (6282)
Mr. Hasan lkhrata
February 14, 2012
Page 2
beginning in 2025, or further increase fuel taxes to generate revenues
equivalent to the mileage -based user fee.
OCTA cannot support an increase in fees, including the introduction of a
mileage -based user fee, until a comprehensive economic impact study is
completed and presented to the OCTA Board of Directors (Board) for
discussion. In addition, when considering support for any kind of a new
user -based fee program, an emphasis must be placed on the need for a
return -to -source criteria that guarantees funds generated within Orange County
are reinvested in Orange County. Finally, there should also be a process for
recognizing and rewarding areas that keep the transportation system in a state
of good repair.
Caffornia High -Speed Rail
The draft RTP identifies Phase I of the California High -Speed Rail
Authority (CHSRA) Project as a potential solution for improving interregional
and intercity ground transportation. As described in the RTP, the project is
planned to connect San Francisco with Los Angeles and Anaheim. This also
assumes improvements to increase speeds along the Los Angeles -San Diego -
San Louis Obispo (LOSSAN) corridor and the Metrolink Antelope Valley Line.
This project description is consistent with the draft CHSRA Business Plan,
which OCTA has reviewed and provided comments on (Attachment A). OCTA
would like SCAG to take these comments into consideration as the RTP is
refined for adoption in April. In summary, these comments focused on the
following:
OCTA supports the phased delivery approach, which includes early
investment in the existing LOSSAN and Metrolink infrastructure
Rather than initially investing in the central segment, OCTA believes it is
more prudent to begin implementation at the "bookends" of the system
Extending the implementation of Phase I by 13 years may jeopardize
existing funding due to timely use criteria
The updated schedule should account for potential contingencies, and
the associated potential cost increases should be addressed through
contingency planning
The project's dependency on public funds could place CHSRA in direct
competition for funding with existing transit service providers and local
transportation agencies
Mr. Hasan Ikhrata
February 14, 2012
Page 3
• It is questionable whether the funding plan truly complies with the
requirements set out in Proposition 1A, specifically Section 2704.08(c)(2),
items A through K
• The operating assumption of "up to nine trains per hour' will likely result
in an unnecessary level of service, and the projected operating surplus of
$1 billion per year is too optimistic
• The $171 billion alternative investment in airports and roadways does not
account for the airport and roadway investments that will be required
both with and without the high-speed rail project
In addition, OCTA recommends that SCAG provide regular updates to the
Transportation Committee and Regional Council regarding the CHSRA
business plan, financial status, implementation progress, and any changes in
assumptions by the CHSRA; particularly with respect to the status of the
memorandum of understanding that better defines CHSRA's commitments to
near-term speed improvements for the LOSSAN and Metrolink services.
Regional High -Occupancy Toll Lane Network
The draft RTP includes the implementation of a regional high -occupancy toll (HOT)
lane network. This network appears to utilize existing and planned
high -occupancy vehicle lanes to generate new revenues by selling excess
capacity to single -occupancy drivers. The proposed regional HOT lane network
assumes that Orange County would include HOT lanes on Interstate 5 (1-5)
between the San Diego County border and the southern end of
State Route 73 (SR -73); along 1-405 between the northern end of SR -73 and
the Los Angeles County border; and along State Route 91 (SR -91) extending
the Express Lanes west to the Los Angeles County border.
On December 12, 2011, the OCTA Board approved the Express Lane Planning
and Implementation Principles (Attachment B). OCTA requests that these
principles be incorporated into the assumptions for segments of the regional
HOT lane network that are within Orange County. Furthemore, the proposed
HOT lane improvements to 1-5, and SR -91 should be subject to further study to
evaluate right-of-way impacts, community issues, and overall feasibility,rip •or to
inclusion in the constrained plan.
East-West Freight Corridor
Due to continuing growth at the ports of Long Beach and Los Angeles, and
increasing congestion on freeways throughout the SCAG region, the draft RTP
Mr. Hasan Ikhrata
February 14, 2012
Page 4
highlights the need for a zero emission East-West Freight Corridor. The corridor
would aid the movement of goods between the ports and warehousing facilities
located inland. This reflects the findings from the Comprehensive Regional Goods
Movement Plan and Implementation Strategy.
Several other corridors were examined, including the SR -91, through
Orange County and Interstate 10. After considerable study, the State Route 60
corridor was selected for further study based on its proximity to current and
future markets, feasibility and right-of-way constraints, future truck volumes,
and potential for reducing truck -involved accidents. The SR -91 was not
selected primarily due to right-of-way constraints throughout the corridor, and
lack of good access to warehousing locations.
OCTA supports the East-West Corridor as it appears in the Draft 2012 RTP.
OCTA believes that the findings from the Comprehensive Regional Goods
Movement Plan and Implementation Strategy are accurate, and OCTA
encourages SCAG to build on the progress of the East-West Corridor based on
these findings.
Other Regional Strategies
SCAG proposes a number of other investments within the draft RTP that affect
Orange County, and go beyond the Long -Range Transportation Plan (LRTP).
OCTA recognizes that it is within SCAG's purview to plan for regional strategies
that enhance transportation, such as the ones discussed below. It should be
noted that OCTA is committed to delivering the projects within the LRTP.
OCTA will only consider additional investments after revenues are identified to
account for these commitments. The regional strategies identified by SCAG do
not have clear funding mechanisms, and it must be made clear that their
inclusion in the RTP does not constitute a commitment to fund and/or
implement the improvements.
Examples of regional strategies include the congestion management projects
identified by the California Department of Transportation. In Orange County,
these corridors include State Route 57, State Route 22, interstate 605, SR -91,
and 1-405. The improvements consist of relatively low-cost operational
improvements such as ramp metering, auxilary lanes, and other ramp and
interchange enhancements. These are in addition to what was already submitted to
SCAG by the county transportation commissions (CTCs) such as OCTA, and rely on
funding sources beyond those identified in the LRTP.
Mr. Hasan lkhrata
February 14, 2012
Page 5
The draft RTP also proposes additional transit enhancements throughout
the region. The key transit investments that go beyond what the CTCs have
committed include expanding local bus service, additional bus rapid transit,
and new express bus service. These improvements are not specified in the
draft RTP, but the additional cost to the region for these services is estimated at
about $2.6 billion. These additional costs are are covered by SCAG's assumed
transportation funding levels, which are beyond the available and committed
resources identified in the LRTP.
An additional emphasis is also placed on walking and bicycling, which is
referred to as "active transportation," The draft RTP proposes to increase the
regional investment in active transportation by about $4.5 billion. When the
committed investments submitted by the CTCs are accounted for, the total
active transportation investment is approximately $6 billion for the SCAG
region. Again, this additional investment is over and above resources identified in
the LRTP, and the improvements are addressed only at the regional level.
Throughout the draft RTP and PER, there are references to transportation
projects inducing growth and influencing land -use development and demand.
One such instance is on page 80 of the draft RTP, which states the following:
"Transportation projects including new and expanded infrastructure are
necessary to improve travel time and can enhance quality of life for
those traveling throughout the region. However, these projects also
have the potential to induce population growth in certain areas of the
region. Although SCAG does not anticipate that the RTP would affect
the total growth in population in the region, the RTP has the ability to
affect the distribution of that growth."
These types of statements are misleading for a number of reasons. For
example, the excerpt quoted above states that the "RTP has the ability to affect
the distribution of growth." This can be understood to imply that SCAG has the
ability to influence growth through the development of the RTP. OCTA trusts
that this is not SCAG's intent. OCTA recommends that such references be
clarified, as land use decisions are within the purview of local agencies.
Moreover, and more importantly, statements such as the above excerpt imply a
lack of coordination between land -use and transportation agencies, especially
Mr. Hasan Ikhrata
February 14, 2012
Page 6
in the light of the recent efforts to develop the Sustainable Communities
Strategies at the subregional and regional levels. There should be an emphasis
in the -RTP on the fact that land -use and transportation agencies are
coordinating better now than ever before. OCTA recommends that SCAG
clarify the negative implication of the statements regarding induced growth, and
highlight the elevated level of coordination occurring today.
Draft Program Environmental Impact Report
The Draft PEIR is a program level document that is intended to serve as an
informational document, disclosing all potential environmental impacts and
possible mitigation measures. OCTA has coordinated with a number of
agencies throughout Orange County who have expressed interest in reviewing
and commenting on the draft 2012 RTP and PEIR (Attachment C). These
agencies have identified a variety of concerns during their review of the
documents, in particular with the list of 549 mitigation measures within the
PEIR. The key concerns that have been identified include:
The Draft PEIR states that it "has made a preliminary determination that
the proposed mitigation measures are feasible and effective." It is
unclear how this determination was made, and this assumption could
prove to be inaccurate if and when these mitigation measures are
considered at a project level. Therefore, any feasibility determinations in
the PEIR must clearly state that they only apply at the program level.
• Several of the mitigation measures that identify SCAG as the acting
agency propose measures that appear to exceed the purview of SCAG.
SCAG must be mindful of local and county land -use and transportation
authorities, and use great discretion when making commitments and/or
suggesting policies and strategies that may impact and encroach upon
local and county agencies' responsibilities.
• The PEIR includes mitigation measures that restate existing
requirements enforced by other agencies and, therefore, do not need to
be repeated in this list of mitigation measures.
Additionally, OCTA understands that only those mitigation measures that state
that "SCAG shall" are required to be carried forward. Any mitigation measure
that identifies an agency other than SCAG can be considered at the discretion
of the appropriate agency; however, such consideration is not required unless
the agency chooses to use the PEIR in order to tier when performing project
level environmental analysis.
Mr. Hasan Ikhrata
February 14, 2012
Page 7
OCTA understands the term "can and should" to mean that the agency
identified by SCAG in a mitigation measure has the authority to implement the
mitigation measure, and that SCAG encourages the agency to do so. The term
is not intended to imply that the measures are feasible nor required.
Finally, SCAG's current Intergovernmental Review ("IGR") policy "encourages"
the use of the mitigation measures identified in the 2008 RTP PEIR to "aid with
demonstrating consistency with regional plans and polices." SCAG will most
likely update the IGR policy to refer to the 2012 RTP PEIR mitigation
measures. As explained above, and as already recognized by SCAG,
compliance with the RTP PEIR mitigation measures is mandatory for SCAG only.
These mitigation measures, therefore, should not be considered in any way during
the IGR process to determine consistency with regional plans and policies.
While OCTA shares many of the concerns raised by partner agencies and
stakeholders in Orange County, such as those described above, the attached
list of comments on the PEIR (Attachment C) focuses on the issues within
OCTA's purview that were identified through the coordination efforts. Please
provide responses and clarifications with regard to these comments.
OCTA appreciates SCAG's work on the RTP and PEIR to date and looks
forward to the adoption of a complete and accurate 2012 RTP and PEIR in
April. If you have further questions, please contact Gregory Nord,
Senior Transportation Analyst, at (714) 5605885.
Sincerely,
Paul G. Glaab
Chairman
WK:gn
Attachments
c: OCTA Board of Directors
Executive Staff
ATTACHMENT D
LETTERS DATED FEBRUARY 14, 2012, FROM CDR TO SCAG
Center, for Demographic c Research
Sponsors: February 14, 2012
California State Mr, Jacob Lieb
University, Fullerton
Southern California Association of Governments
County of Orange 818 West Seventh Street, 12th Floor
Los Angeles, CA 90017
Municipal Water 2012PEIR@scag.ea.gov/ lieb@seag.ca.gov
District of
Orange County SUBJECT: COMMENTS ON THE DRAFT 2012 RTP PROGRAM
ENVIItONMENTAL 1MPACT REPORT
Orange County
Council of Dear Mr. Lieb:
Governments
Orange County The Center for Demographic Research has reviewed the Draft 2012 Regional Transportation Plan
Sanitation District PEIR. We recognize and appreciate the work SCAG staff has done to produce these reports and
work with local agencies during the development process. We thank you for the opportunity and
Orange County ask for your consideration and response to the following comments.
Transportation
Authority The CDR would like to express support of comments and recommendations on the Draft 2012
Orange County RTP PEIR by the Orange County Council of Governments, the Orange County Transportation
Water District Authority, the Transportation Corridor Agencies, and other Orange County agencies. These
comments include:
Southern California 1) Incorporate the Orange County Projections -2010 Modified Growth Projections, as
Association of adopted by the OCCOG Board of Directors, into all RTP/SCS/PEIR documents,
Governments appendices, tables, maps, narrative, modeling runs, PEIR Alternatives (including
Alternate C/3/Envision 2 referencing the Orange County growth forecasts)
Transportation consistent with the subregional delegation MOU between OCCOG, OCTA and
Corridor agencies SCAG.
2) SCAG's adoption of the growth forecast numbers should be at the county
Contributing Partner: level, consistent with past RTPs, and not at a smaller level of geography such as
city, census tract, or traffic analysis level.
Orange County
LocalAgency 3) Change language in all mitigation measures identifying entities other than SCAG to Form«ation read ean-an should consider where applicable and feasible." To clarify the intent
Commission that the mitigation measures are a menu of options for which feasibility has not been
established for any given project, the "can and should" language should be changed
in all mitigation measures identifying entities other than SCAG to read "should
consider where applicable and feasible."
4) Remove language within mitigation measures that establishes policies not included
in the RTP/SCS or modifies the measure to specify a policy or endorses speck
technology which would limit agency authority.
5) In the draft PEIR, please replace text in all mitigation measures that identify policy
for either SCAG or other entities with language that reflects either adopted SCAG
policies or are policies that are included in the RTP and SCS. Mitigation measures
should not be used to establish new policy for the region.
6) Remove mitigation measures for SCAG which it does not have purview for under
the law or directed to do by the Regional Council through policy direction.
7) Remove all references within mitigation measures that SCAG will "ensure" or "shall
minimize impacts" that result from a mitigation measures.
2600 Nutwood .Avenue, Suite 750, Fullerton, CA 92831-5404 (657) 278-3009 Fax (657) 278-5091 www.fullerton.edu/cdr/
Mr. Lieb
2012 Draft PEIR Comment Letter
2/14/2012
Page 2 of 6
8) Reword measures to indicate that a new or increased fee, new tax, or other increase is only an option as a
way to implement the mitigation.
9) Remove references that indicate a compliance with guidance documents from mitigation measures.
10) Please remove all mitigation measures listed in the OCCOG letter's Attachment 1 which are duplicative
of existing regulations administered by or under the jurisdiction of other agencies.
11) For each impact, please add the following language: "Local jurisdictions, agencies, and project sponsors
should comply, as applicable, with existing federal, state, and local laws and regulations."
12) Remove mitigation measures that are very prescriptive, such reducing street widths to WWII widths or
specifying preferred technology.
13) Other comments on the PEIR document in Table 1.
Table l
#
TOPIC
PAGE
PEIR NARRATIVE, COMMENT & RECOMMENDATION
REFERENCE
1
Clarification
Executive
Add language to Executive Summary and Introduction:
Summary,
Introduction
"Mitigation measures do not supersede regulations under the
jurisdiction of other regglato1y agencies.
Chapters
2
Clarification
ES -2
ES contains matrix of mitigation measures which reference
project sponsors, local agency, and project implementation
agency without definitions. Add definitions into ES at end of
ESA:
In general, the terms "local agency," "project sponsor" and
"project implementing agency" are used throughout this PEIR
to identify agencies, organizations, companies and individuals
that will act as lead agencies or project applicants for different
Wes of individual projects. Individual projects that are
anticipated to occur pursuant to the 2012-2035 RTP/SCS
consist of planning projects(general plans, specific plans,
climate action plans, etc.), development projects (including
Transit Priority Projects (TPPs) and other similar projects), and
transportation projects.
In general, "local agency" is used to refer to a public agency
that would propose a planning_ project or a public infrastructure
project and/or an agency that would be lead agency for
individual proiects. "Project sponsor" is typically used to refer
to an applicant (that could be public or private, an organization
or an individual) thatproposes a project. "Project implementing
agency" is used to refer to an agency responsible for
implementing a project. In this document, project -
implementing agencies are those that are responsible for
carrying out (reviewing, approving, constructing)
transportation ro ects.
Mr. Lieb
2012 Draft PEIR Comment Letter
2/14/2012
Page 3 of 6
#
TOPIC
PAGE
PEIR NARRATIVE, COMMENT & RECOMMENDATION
REFERENCE
3
Clarification
ES -3,14,
Alternatives' Naming: No Project Alternative, Modified 2008
Chapter 4
RTP Alternative, Envision 2 Alternative; Alternatives 1, 2, 3
Names of Alternatives differ than those listed in the SCS
Background Documentation appendix on pages 71-74 and 80-
83.
Please be consistent with naming protocol for alternatives
between all documents.
4
Fix numbering
ES -31
Duplicate naming of GHG11 and GHG12
5
Please define
ES -42
LU63- What are the smart growth principles?
6
Please define
ES -42
LU64- What are the benchmarks for smartgrowth?
7
Fix numbering
ES -51
PS 17 & PS 18 are missing
8
Fix numbering
ES -53
Duplicate naming of PS36 & PS37
9
Please define
ES -67
TR 34- what are the identified transportation benchmarks?
10
Please define
ES -83, 3.13-42
Define climate change hydrology
MM -W43
11
Please define
ES -40, 3.8-21
Define urban growth boundary
MM-LU42
12
Please define
ES -57, 3.11-49
Define parking cash out program/ cashouts
MM-PS68 &
ES -74, 3.12-43
MM-TR96
13
Clarification
1-5,
"Mitigation Measures proposed in this PEIR are available as
paragraph 1
tools for implementing agencies and local lead agencies to use
as they deem applicable. The implementing agencies and local
lead agencies are responsible for ensuring adherence to the
mitigation measures as 2012-2035 RTP/SCS projects are
considered for approval over time."
Other chapters
Please make similar text amendments to other sections,
as applies
including the Executive Summary, of the PEIR that reference
how the mitigation measures are to be used by lead agencies.
14
Clarification
1-5
Besides IGR, what other monitoring efforts is SLAG in charge
of? (that would require lead agencies to provide SLAG with
documentation of compliance with mitigation measures
15
Clarification
1-6,
Language correction: "The lattff former finding..."
paragraph 3
16
Clarification
1-7
Change language on page 1-7 found in 2 places under
MITIGATION MEASURES, subheadings Transportation
Project Mitigation and Land Use Planning and Development
Project Mitigation:
"This Draft PEIR has made a preliminary determination that
the proposed mitigation measures are feasible and effective.
Therefore, it is reasonable to expect that these agencies will
actually implement them where, in the agencies' independent
discretion, the measures are deemed applicable in light specific
circumstances at the ro ect level."
Mr. Lieb
2012 Draft PEIR Comment Letter
2/14/2012
Page 4 of 6
#
TOPIC
PAGE
PEIR NARRATIVE, COMMENT & RECOMMENDATION
REFERENCE
17
Clarification
2-3
Amend the land use strategies under the section Purpose and
Need for Action to reflect the strategies included in the SCS
chapter o the RTP.
18
Update growth
2-3, Table 2-1
In December 2011, Orange County provided SCAG with the
forecast
revised growth forecast dataset, OCP -2010 Modified, per the
numbers
OC SCS MOU (official OCCOG Board action 1/26/2012).
Other chapters
Please incorporate OCP -2010 Modified into all reports, tables,
as applies
exhibits, alternatives, maps, and modeling runs for final RTP
PEIR.
19
Clarification
2-5
Sustainability section should be separated.
Language correction:
Sustainability. The 2012-2035 RTP/SCS is subject to specific
requirements for environmental performance.
New paratEraph•
"Beyond simply meeting these requirements, a..."
20
Clarification
2-5, Table 2-2
"Align the plan investments and policies wM while
im rovin .. "
21
Please define
2-14
Define "scrip"
22
Clarification
2-21
AB 32 is global warming solutions act. SB 375 was determined
to be stand-alone legislation. RTP document is not forum to
address global climate change and references distract from RTP
goal and purpose. "Global warming" and "global climate
change" are not interchangeable phrases. References should be
removed or, where appropriate, language should be changed to
"global warming". Delete sentence in "Goods Movement
Environmental Strategy":
23
Clarification
2-25,
"The SCS demonstrates the region's ability to again meet and
paragraph 3
exceed the GHG emission reduction targets..."
24
Clarification
2-26,
"The RTP/SCS was built primarily from local General Plans
paragraph 1
and input from local governments, the subregional
COGs, 49m the County Transportation Commission, and from
g§jgg the Local Sustainability Planning Tool."
25
Clarification
2-27,
"Additionally, SGAG the region moves towards improving the
paragraph 3
current distribution of households by income category in the
re ion throu "
26
Clarification
2-27,
Not in SCAG's authority, nor funding available. Delete
paragraph 4
sentence:
Mr. Lieb
2012 Draft PEIR Comment Letter
2/14/2012
Page 5 of 6
#
TOPIC
PAGE
PEIR NARRATIVE, COMMENT & RECOMMENDATION
REFERENCE
27
Clarification
2-27,
"The 2012-2035 RTP/SCS land use development pattern
paragraph 5
accommodates over 50 percent of new housing and
employment growth in HQTAs, while keeping jurisdictional
totals consistent with local input."
Please confirm that there are no changes to the local land use
inputs provided by Orange County.
28
Clarification
2-28,
"Cities suah as The City of Pasadena ®provides a
paragraph 1
relevant reference for the City Center community e."
29
Clarification
2-29
"For purposes of SCAG's SCS, a Development Type reflects
an estimated average density of 22 residential units per acre.
However, it is important to note that the designation is a
potential ultimate average for the TAZ—and is not an absolute
project -specific requirement that must be met in order to
determine consistency with the SCS. In other words, the SCS
was not developed with the intent that each project to be
located within any given TAZ must exactly equal the density
and relative use designations that are indicated by the SCS
Development Type in order for the project to be found
consistent with the SCS's use designation, density, building
intensity and applicable policies. Instead, any given project,
having satisfied all of the statutory requirements of either a
residential/mixed-use project or TPP, may be deemed by the
lead agency to be consistent with the SCS so long as the project
does not prevent achieving the estimated average use
designations, densities and building intensities indicated by the
Development Type within the TAZ, assuming that the TAZ
will be built -out under reasonable local planning and zoning
assumptions."
Does the above PEIR language create a requirement for
average TAZ density levels in 2035 and a requirement that
each local project not preclude those density levels?
Additionally, please clam whether in HQTAs, these densities
could be exceeded as well as implications of an area that is
already fully developed not redeveloping such that it ever
achieves the identified densities.
30
Clarification
2-32,
Change title to "Demographic and Economic Categories"
Table 2-20
31
Please define
2-35,
Define "progressive jobs/housing distribution optimized for
Paragraph 1
TOD and infill"
32
Please define
3.8-5
Define "open space"
aragraph 3
33
Clarification
3.8-5
"As shown in Map 3.8-6, urban centers in the SCAG region -is
paragraph 4
are in the form of clusters,..."
34
Clarification
3.11-6
"In addition, some climate change studies suggest ..."
paragraph 4
Mr. Lieb
2012 Draft PEIR Comment Letter
2/14/2012
Page 6 of 6
#
TOPIC
PAGE
REFERENCE
PEIR NARRATIVE, COMMENT & RECOMMENDATION
35
Revise
4-39
Envision 2 alternative contains growth projections that would
language to
place housing in flight paths, locate housing on sites for which
clarify
housing is not allowed due to environmental contamination,
would significantly impact existing industrial operations
necessary to maintain quality jobs in the region, and does not
include development projects that are legally allowed due to
having existing entitlement for development. Because this
alternative does not consider the existing health and safety of
future residents nor the existing legal approvals of development
in the region, it is not possible to determine if the alternative is
actually superior to other alternatives. It is simply another
alternative for consideration.
Please remove references to the Envision 2 (or any other name
of this alternative) as being environmentally superior.
ENVISION 2
ALTERNATIVE
36
Revise
4-40
"Of the three alternatives, the Envision 2 Alternative would be
language to
considered by State CEOA guidelines as the environmentally
clarify
superior alternative because it does not allow further use of
land for single-family development..."
Thank you again for your consideration.
Sincerely,
Deborah S. Diep
CDR Director
CC: CDR Management Oversight Committee
CDR Technical Advisory Committee
Hasan Ikhrata, SCAG
Scott Martin, CDR
Center.for Demographic Research
Sponsors:
February 14, 2012
California State
Ms. Margaret Lin
University, Fullerton
Southern California Association of Governments
County of Orange
818 West Seventh Street, 12th Floor
Los Angeles, CA 90017
:Municipal Water
RTP@seag.ea.gov/ lin@seag.ea.gov
District of
Orange County
SUBJECT: COMN.ENTS ON THE DRAFT 2012 REGIONAL TRANSPORTATION
PLAN, APPENDICES, AND GROWTH FORECAST DATASETS
Orange County
Council of
Dear Ms. Lin:
Governments
Orange County
The Center for Demographic Research at Cal State Fullerton has reviewed the Draft 2012
Sanitation District
Regional Transportation Plan/Sustainable Communities Strategies, its associated appendices, and
the growth forecast datasets. We greatly appreciate the opportunity to do so and for all of the work
Orange County
SCAG staff has done to produce these reports and work with local agencies during the
Transportation
development process.
:authority
Orange County
First, we would like to express support of recommendations by the Orange County Council of
Water District
Governments, the Orange County Transportation Authority, the Transportation Corridor
Agencies, and other Orange County agencies whose comments also request the inclusion of the
Southern California
updated Orange County growth forecast, the 2010 Orange County Projections Modified, in the
Association of
RTP/SCS plan and alternatives.
Governments
Our comments are grouped as follows:
Transportation
1. Incorporate the Orange County Projections -2010 Modified Growth Projections, as adopted by
Corridor Agencies
the OCCOG Board of Directors, into all RTP/SCS/PEIR documents, appendices, tables, maps,
narrative, modeling runs, PEIR Alternatives (including Alternate C/3/Envision 2 referencing
Contributing Partner:
the Orange County growth forecasts) consistent with the subregional delegation MOU
between OCCOG, OCTA and SCAG.
Orange County
Local .agency
2. SCAG's adoption of the growth forecast numbers should be at the county level, consistent
Formation
with past RTPs, and not at a smaller level of geography such as city, census tract, or traffic
Commission
analysis level.
3. Other Comments on the Draft 2012 RTP documents in Tables 1, 2, and 3.
1. Incorporate the Orange Co1m1y Projections -2010 Modified Growth Proiections, as adopted by
the OCCOG Board of Directors, into all documents, tables, maps, narrative, modeling runs,
and PEIR Alternatives (including Alternate C/3/Envision 2) referencing the Orange County
growth forecasts consistent with the subregional delegation MOU between OCCOG, OCTA
and SCAG.
On January 26, 2012, the update to the OCP -2010 dataset, known as OCP -2010 Modified, was
officially approved by the OCCOG Board of Directors and is a data amendment to the Orange
County Sustainable Communities Strategy. The dataset includes the 2010 Census population and
housing data, along with the 2010 EDD Benchmark data, consistent with SCAG's updated growth
forecast dataset. The dataset was provided to SCAG staff in December 2011 and this is the formal
notice of the update which should be incorporated into the 2012 RTP/SCS, PEIR, and related
documents.
2600 Nutwood Avenue, Suite 750, Fullerton, CA 92831-5404 (657) 278-3009 Fax (657) 278-5091 www.fullertort.edu/cdr/
Ms. Lin
2012 RTP/SCS Comment Letter
2/14/2012
Page 2 of 8
2. SCAG's adoption of the growth forecast numbers should be at the county level, consistent with past
RTPs, and not at a smaller level of geography such as city, census tract, or traffic analysis level.
The 2012 growth projections identify population, housing and employment data for the six -county SCAG
region, from 2008 (Existing) to 2020 and 2035. These growth projections represent the best available
information from local jurisdictions, the business community and landowners. However, as time passes, what
is feasible for any given project can change. The triggers for change to adopted growth projections can range
from factors such as market conditions, new information or data, infrastructure availability, changes in
funding availability (such as the dissolution of redevelopment agencies statewide), and changes to
jurisdictional boundaries resulting from future annexations and incorporations of previously -designated
unincorporated territory. SCAG should continue to adopt the 2012 growth projections at a countywide level,
consistent with past approvals of Regional Transportation plan growth forecasts. A county level of
geography accommodates internal adjustments to changing conditions as described above, without
compromising the integrity of the overall growth projections. However, approving the growth projections at
any lower level of geography, such as at the city level, would be challenged with continual revisions and
shifts to the total number of housing, population and employment within a city, among cities, and between
cities and counties as a result of the factors described above. Adoption of the data at a level lower than the
county would limit jurisdictional control and create inflexibility in a regional planning document. In addition,
the level of geography in which RTP/SCS growth forecast is adopted should not be determined by other
processes. For example, the RHNA allocations must be consistent with the RTP/SCS; state law does not
require that they be identical. The RTP/SCS can be adopted at the county level and the RHNA process may
proceed independently until it is completed after the appeals, trades, and transfers are completed. The RHNA
allocations that were derived from the growth forecast can still be determined to be consistent with the
RTP/SCS, even if changes are made to the city totals during the appeals, trades, and transfers process.
3. Other Comments on the Draft 2012 RTP documents in Tables 1 2 and 3:
Table 1.2012 RTP/SCS COAlMIENTS
#
TOPIC
PAGE
RTP NARRATIVE, COMMENT & RECOMMENDATION
REFERENCE
1
General
all
All chapter headings should include the Chapter number on
Comment
each a e or ease of reference.
2
Clarification
1, left column
"The 2012 RTP/SCS includes a strong commitment to reduce
emissions from transportation sources to comply with SB 375,
be4h improve public health, and meet the National Ambient Air
Quality Standards as set forth by the federal Clean Air Act. As
3
Clarification
4, right
"This region needs a long-term, sustainable funding plan that
column
ensures the region receives its fair share of funding, supports an
efficient and effective transportation system that grows the
economy, provides mobility choices, and improves our quality
of life."
4
Clarification
page 7-
is additional $0.15 gas tax the sum total of both state and
Table 2 and
federal taxes or $0.15 each?
page 95 -
Table 3.3
5
Clarification
12, right
"It also demonstrates how we can transition from things we
column
know to be unsustainable over the long term and beyond the
term of this RTP—such as reliance on fossil fuels—to new
technologies for the future."
Ms. Lin
2012 RTP/SCS Comment Letter
2/14/2012
Page 3 of 8
#
TOPIC
PAGE
RTP NARRATIVE, COMMENT & RECOMMENDATION
REFERENCE
6
Clarification
30, 31, 73
AB 32 is global warming solutions act. SB 375 was determined
to be stand-alone legislation. RTP document is not forum to
address global climate change and references are unnecessary,
off topic, and distract from RTP goal and purpose. "Global
warming" and "global climate change" / "climate change" are
not interchangeable phrases. References should be removed or,
where appropriate, language should be changed to "global
warming"
30, right
"The RTP/SCS includes the following actions to address energy
column
uncertaintyFegion's eea#ibu4ioa to global
31, right
"Adaptation
column
Climate eheage global warming mitigation means reducing or
sequestering greenhouse gases, whereas adaptation is preparing
for known impacts of date -edge global warming. Over the
coming century, some elimate ehange studies project that
Southern California will be expected to manage extremes of
precipitation and temperature, increased storm frequency and
intensity, and sea -level rise. These climate changes will would
impact streamflow, flooding, water supply, sea level, and soil
water content. These impacts wig would affect agriculture,
stormwater, wastewater treatment, wildfire risk, roads, forest
health, and biodiversity. These impacts wi44 would also have
consequences for public health, economic livelihoods, the
financial sector, the insurance industry, individual comfort, and
recreation. In practice, these impacts will would mean coping
with...
73, right
"Goods movement is also a major source of greenhouse gas
column
(GHG) emissions that contribute to global slimate-sl}ae
warmin "
7
Clarification
40, left
"Strategic investments, gut forth by the private sector, that
column
would remove barriers associated with telecommuting are
expected ... 9'
8
Correction
page 42- Table
241 toll road completion year is 2030
2.2
9
Define in text
50, left
"scrip"
and add to
column
glossary
10
Clarification
54, right
"Express/HO T Lane Network
column
Despite our concerted effort to reduce traffic congestion
through years of infrastructure investment, the region's system
demands continue to exceed available capacity during peak
eriods."
Ms. Lin
2012 RTP/SCS Comment Letter
2/14/2012
Page 4 of 8
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RTP NARRATIVE, COMMENT & RECOMMENDATION
REFERENCE
11
Clarification
78, right
"Greenhouse Gases
column
On road emissions (from passenger vehicles and heavy duty
trucks) constitute 93 percent of the transportation sector total.
Emissions from passenger vehicles, which are the subject of SB
375 and this RTP/SCS, constitute % of the transportation
sector's geenhouse gas emissions total."
12
Clarification
80, left
Statements are made, such as the following, "the RTP has the
column
ability to affect the distribution of that growth" (in population in
the region). These statements could be interpreted to be
contrary to SCAG's obligation under the Memorandum of
Understanding with OCCOG to respect the strategies and local
land use policies in the OC SCS.
Please clarify how it is in SCAG's ability to affect local change
when the OC SCS is consistent with acceptance of local land
use plans and planned population and employment
distribution?
Recommended text change: "Transportation projects including
new and expanded infrastructure are necessary to improve
travel time and can enhance quality of life for those traveling
throughout the region. However, these projects also have the
potential to indtwe attract more of the regional population
growth in certain areas of the region. This means that although
SCAG does not anticipate that the RTP would affect
the total growth in population in the region, the RTP has the
ability to affect the distribution of that growth."
" , transportation
projects in the RTP also have the potential to divide established
communities, primarily through acquisition of rights-of-way."
82, right
Text indicates that the RTP and projects in the RTP/SCS as
column
"inducing" growth. It is noted that use of the term "induced
growth" has a negative connotation and implies growth above
and beyond what would occur naturally. However, it is stated
in the RTP that the population, housing, and employment
growth totals are fixed and only the distributions may change
based on the plan. This means there will not be "new" growth
and that the RTP and SCS may simply influence and shift the
growth anticipated for the region. This moving of growth is the
result of changes in distribution that are due to changes in land
use or densities. Because of this, it is requested that references
to "induced growth" be reworded to reflect the shifting of
growth in the region.
Recommended text change: "Cumulative impacts from the
projected growth indueea by twe DTD include increased
im ervious surfaces;..."
Ms. Lin
2012 RTP/SCS Comment Letter
2/14/2012
Page 5 of 8
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PAGE
RTP NARRATIVE, COMMENT & RECOMMENDATION
REFERENCE
13
Clarification
page 95- Table
'4�lileage based user- fees weiald be iinplemen�ed to r-eplaee gas
3.3
taii and augment estimated a abeu4 $0.05 (2011$) pee
Suggested language is from page 31 of Growth Forecast
Appendix:
Current gasoline tax, estimated at about $0.05 (2011$) per
mile will increase through 2025, then in 2026 it would be
replaced with a mileage -based user fee indexed to maintain
purchasing ower
14
Clarification
105, right
"While the region was once known worldwide as the "capital of
column
sprawl," the region today is projecting growth on only a small
fraction of the has4ittle raw land available in the region ate
15
Clarification
106, last
Please revise the text in the last paragraph on page 106 to state:
paragraph
"These subregional SCS documents are incorporated into the
regional SCS and represent the SCS for each of these
subre ions."
16
Clarification
110, right
"Municipal water and sewer systems, for example, ensure clean
column
water. At the same time,
hatin wateF quali as areas
become more urbanized and the percentage of impervious
surface is increased, the hydrologic reizime is dramaticall
altered. Drainage conveyances that once were natural and
riparian are required to be engineered as hardened flood control
channels to provide adequate protection of private property
public infrastructure from the increased frequency, duration,
peak flow, and overall volume of stormwater runoff. With this
armoring of once natural channels, water quality benefits from
biofiltration are lost along with opportunities for infiltration and
evapotranspiration, which can lead to hydromodifcation
downstream in sections which are notengineered and
hardened. Many strategies..."
17
Add to
127, right
"Gentrification"
glossary
column
18
Please clarify
128, left
"Thus, this adjustment allowed the land use pattern to conform
column
more closely to local e*peetatiens-eg neral plans, while reducing
the amount of vehicle miles traveled."
Whose/What are "local expectations.? "
19
Revise
149, right
Revise language to clarify that SCAG intends policies,
language to
column
strategies, and measures are a menu of options.
clarify
"The following tables list specific implementation strategies
that local governments, SCAG, and other stakeholders may
or consider while preparing specific projects which would help
to successfully implement
the SCS."
Ms. Lin
2012 RTP/SCS Comment Letter
2/14/2012
Page 6 of 8
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PAGE
RTP NARRATIVE, COMMENT & RECOMMENDATION
1
Update growth
REFERENCE
In December 2011, Orange County provided SCAG with the
20
Revise
153, right
`Evaluation and Revision
language to
column
SCAG will also track its own progress in implementing its
2
clarify
71-74, 80-83
RTP/SCS strategies in conjunction with the preparation and
adoption of its Overall Work Program and Annual Budget."
Clark if "its progress " is SCAG's progress or the region's
progress.
21
Add to
166, right
"Greenfield"
glossary
column
22
Correct
193, right
RC adopted revised PPP in January 2012
language
column
23
Revise
194, right
"In addition to these targeted outreach efforts, all regular and
language to
column
special meetings of the RTP task forces, the Transportation
clarify
Committee (TC), the CEHD, the EEC, and the SCAG Regional
Council are publicly noticed and ..."
24
Please clarify
203, right
"...including Los Angeles Ontario Airport, the March Inland
column
Port..."
Should LAX and Ontario airports be named separately?
25
Add to
205
"Active transportation"
glossary
I
Table 1. GROWTH FORECAST APPENDIX COMMENTS
#
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PAGE
REFERENCE
NARRATIVE, COMMENT & RECOMMENDATION
1
Update growth
23, Table 13
In December 2011, Orange County provided SCAG with the
forecast
column
revised growth forecast dataset, OCP -2010 Modified, per the
numbers
OC SCS MOU (official OCCOG Board action 1/26/2012).
2
Clarification
71-74, 80-83
Please incorporate OCP -2010 Modified into all reports, tables,
exhibits, alternatives, maps, and modeling runs or anal RTP.
Table 3. SCS BACKGROUND DOCUMENTATION APPENDIX COMMENTS
#
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PAGE
REFERENCE
NARRATIVE, COMMENT & RECOMMENDATION
1
Please define
53, right
Housing Options and Mix:
column
Define Larger -lot singlefamily in text
2
Clarification
71-74, 80-83
Alternatives A, B, C
Names of Alternatives differ than those listed in the PEIR on
pages ES -3 and 1-4.
Please be consistent with naming protocol, for alternatives
between two/all documents.
Ms. Lin
2012 RTP/SCS Comment Letter
2/14/2012
Page 7 of 8
#
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PAGE
NARRATIVE, COMMENT & RECOMMENDATION
REFERENCE
3
Clarification
71, right
"Plan Alternative (B)
column
... The alternative maintains city -level forecast control totals
for both households and jobs, however, within city boundaries
shifts are made to focus a much larger share of future growth in
a more compact way around HQTAs, except in Gateway and
Orange County COG subregions per their SCS delegation
agreements. Future housing market demand is expected to shift
significantly to small lot single-family, townhomes and multi-
family housing."
4
Please define
71, right
Plan Alternative (B)
column
—Define
small lot singlefamily in text
5
Clarification
71, right
Plan Alternative (C)
column
"As a result very suburban communities may experience no
new housingor r employment growth, while some urban areas
with very good access to regional transit may experience
significant increases in housingor r em_ployin growth."
6
Clarification
72, left column
"While each alternative is distinctive, a number of parameters
remained constant across each alternative: the regional
RTP/SCS forecast total for population, households and jobs;..."
"Detailed forecast: the detailed distribution of population,
households, and jobs across the region..."
7
Clarification
72, left column
What does it mean that TAZ boundaries include city
boundaries?
8
Clarification
72, Table D1
Alternatives A & B:
"Controlled to TAZ-based RTP/SCS Forecast for 2020;
Controlled to city -level RTP/SCS Forecast for 2020-2035,
except in Gateway and Orange County COG subregions per
their SCS delegation agreements."
Add statement to table notes: Gateway and Orange Countv
COG subregions' local input data will not be changed per their
SCS dele ation a eements.
9
Clarification
74, Table D2
Alternatives A & B:
Add statement: Gateway and Orange County COG subregions'
local input data will not be charged per their SCS delegation
alleements.
10
Clarification
75, right
"Development Types
column
The alternatives are built on, and provides data at, the level of
the TAZ, which includes housing units and employment."
Please clarify if TAZ is Tier 1, Tier 2, or both.
11
Clarification
79, right
"Subregional SCSs submitted by the Gateway Cities Council of
column
Governments (GCCOG) and the Orange County Council of
Governments (OCCOG) will be Fespeete unchanged and
integrated into the alternatives (with possible revisions for
Alternative C only)."
Ms. Lin
2012 RTP/SCS Comment Letter
2/14/2012
Page 8 of 8
#
TOPIC
PAGE
NARRATIVE, COMMENT & RECOMMENDATION
REFERENCE
12
Clarification
80
Alternative A
Add statement: Gateway and Orange County COG subregions'
local input data will not be changed per their SCS delegation
a eements.
13
Clarification
81
Alternative B
Add statement: Gateway and Orange County COG subregions'
local input data will not be changed per their SCS delegation
a eements.
14
Clarification
115, left
Transit Zoning Code Santa Ana 2011
column
Is this a duplicate of the 2010 Santa Anaproject?
Again, we thank you for your time and consideration of the comments above.
Sincerely,
Deborah S. Diep
CDR Director
CC: CDR Management Oversight Committee
CDR Technical Advisory Committee
Hasan Ikhrata, SCAG
Scott Martin, CDR
ATTACHMENT E
DRAFT RTP/SCS EXECUTIVE SUMMARY
EXECUTIVE SUMMARY
-% 'W
I A,
REGIONAL TRANSPORTATION PLAN
2012-2035
Towards a Sustainable Future
q,
a
Viafl 2£112 RTP documents,
r talo of1he Execatilie Summary.
4
Our Vision
Towards a Sustainable Future
For the past three decades, the Southern California Association of Governments (SCAG)
has prepared Regional Transportation Plans (RTPs) with the primary goal of increasing
mobility for the region's residents and visitors. While mobility Is a vital component of
the quality of life that this region deserves, it is by no means the only component. SCAG
has placed a greater emphasis than ever before on sustainability and integrated plan-
ning in the 2012 Regional Transportation Plan/Sustainable Communities Strategy (RTP/
SCS), whose vision encompasses three principles that collectively work as the key to our
region's future: mobility, economy, and sustainability.
The 2012 RTP/SCS includes a strong commitment to reduce emissions from transporta-
tion sources to both improve public health and meet the National Ambient Air Quality
Standards as set forth by the federal Clean Air Act. As such, the 2012 RTP contains a
regional commitment for the broad deployment of zero and near -zero emission transpor-
tation technologies in the 2023-2035 timeframe and clear steps to move towards this
objective. This is especially critical for our goods movement system. The development
of a world class zero emission freight transportation system is necessary to maintain
economic growth in the region, to sustain quality of life and to meet federal air quality
requirements. The 2012 RTP puts forth an aggressive strategy for technology develop-
ment and deployment to achieve this objective. This strategy will have may co -benefits,
including energy security, cost certainty, increased public support for infrastructure, GHG
reduction and economic development.
Never before have the crucial linkages and interrelationships between the economy, the
regional transportation system, and land use been as important as now. For the first
time, the 2012 RTP includes a significant consideration of the economic impacts and
opportunities provided by the transportation infrastructure plan set forth in the 2012 RTP,
considering not only the economic and job creation impacts of the direct investment in
transportation infrastructure, but also the efficiency gains in terms of worker and busi-
ness economic productivity and goods movement. The 2012 RTP outlines a transporta-
tion infrastructure investment strategy that will beneficially impact Southern California,
the state, and the nation in terms of economic development, competitive advantage,
and overall competitiveness in the global economy in terms of attracting and retaining
employers in the Southern California region.
The 2012 RTP/SCS will transform the region, serving as a blueprint for improving quality
of life for our residents by providing more choices for where they will live, work, and play,
and how they will move around. Its safe, secure, and efficient transportation systems will
provide improved access to opportunities, such as jobs, education, and healthcare. Its
emphasis on transit and active transportation will allow our residents to lead a healthier,
active lifestyle. It will create jobs, ensure our region's economic competitiveness through
strategic investments in our goods movement system, and improve environmental and
health outcomes for 22 million residents by 2035. More importantly, the RTP/SCS will
also preserve what makes the region special, including our stable and successful neigh-
borhoods and our array of open spaces for future generations to enjoy.
The Setting
In order to successfully overcome the challenges that lie before us, this RTP/SCS first
recognizes the impacts that recent events and long-term trends will have on how people
choose to live and move around.
ECONOMIC RECESSION
800,000 jobs have been lost in the region
due to the Great Rao-pssion
The economic turmoil faced by many of the region's residents is likely to impact
their housing choices and travel behavior, including their transportation mode
choice and day-to-day travel patterns. This will potentially require different types
of transportation solutions.
2 2012 Regional Transportation Plan I Executive Summary
POPULATION GROWTH
The region will add 4 million people by 2035
This growth in population will only exacerbate our region's existing mobility challenges.
The SCAG region is already home to 18 million people, or 49 percent of California's popu-
lation. If it were its own state, the SCAG region would be the fifth most populous in the
nation. Furthermore, this expected growth will occur mainly in the suburban inland coun-
ties of Riverside and San Bernardino, adding to the existing imbalance of jobs and hous-
ing in the region, and requiring people to travel which contributes to transportation and
air quality challenge. In addition, with the aging of the Baby Boomer generation (the share
of the population 65 years or older will increase from 11 percent in 2010 to 18 percent in
2035), the region will soon have a greater need for efficient modes of transportation for
those who can no longer drive as their main form of transportation.
MULTIMODAL TRANSPORTATION SYSTEM
Over the past few decades, the region has invested heavily in a multimodal transportation
system that serves as the backbone of the region's economic well-being.
THE SYSTEM AT A GLANCE
121,630 miles of highways and arterials
470 miles of passenger rail
6 air carrier airports
Nine out of ten trips in the region utilize our extensive highway and arterial network,
which supports a host of modes, including the automobile, transit, and active transporta-
tion. The region is also home to a growing number of passenger rail lines, none of which
existed 20 years ago. Our regional aviation system is the nation's largest and most com-
plex in terms of number of airports and aircraft, and our goods movement industry plays a
critical role in sustaining the economy of our region. The importance of this system to our
region cannot be understated.
THE REGION IN MOTION
446 million miles driven each day
81 million air passengers each year
45% more urban rail riders between 2000 and 2006
34% of our jobs depend on the goods movement industry
Challenges
The challenges facing the region are daunting. When combined, our mobility, air quality,
and funding challenges present an imposing threat to the quality of life for both current
and future residents.
MOBILITY CHALLENGES
�� million N����
The region VVaS1eSover �� mmwm��m��mm hOU[S
each year sitting in traffic
The region's roadways are the most congested inthe nation, and traffic relief iscritical,
even more so in our current economic situation. By failing to address our congestion, we
have foregone jobs—every 10 percent decrease in congestion can bring an employment
increase ufabout 132.00Djobs.
SAFETY CHALLENGES
On the brighter side, our roadways are among the nation's safest, with rate of fatal and
injury collisions declining dramatically since the 1030'o. But eowecontinue tosuccess-
fully impmvooufet for our motorists, mmcannot neglect the alarming fatality rates of
those traveling onother modes oftransportation.
21% of all traffic -related fatalities involve pedestrians
This fatality rate isunacceptable, and if we plan to successfully move towards umore
sustainable future that includes plenty of active transportation, we must address the
safety deficiencies inall modes oftransportation.
2U12Regional Transportation Plan )Executive Summoiy 3
AIR QUALITY CHALLENGES
Inaddition, while Southern California isoleader inreducing emissions and ambient levels
ofair pollutants are improving, the SCAGregion continues iohave the worst air quality in
the nation and air pollution still causes thousands of premature deaths every year, as well
aoother serious adverse health effects. The South Coast Air Quality Management District
(AQMD) estimates the monetary cost of air pollution in Southern California to be at Ieast
$14.6 biflion annually.
Even with on-going aggressive control strategies, ever more stringent national ozone
standards require further oxide ofnitrogen (N&x)emission reductions inthe SCAGregion.
In the South Coast Air Basin, for example, it is estimated that NOx emissions will need
to be reduced by approximately two-thirds in 2023 and three-quarters in 2030. This is a
daunting challenge. The level of emission reduction required is so significant that 2030
emissions forecasted from just three sources—ships, trains, and aircraft—would lead
to ozone levels near the federal standard. Because most sources, including cars and
factories, are already controlled by over 90 percent, attainment of ozone standards will
require broad deployment of zero and near -zero emission technologies in the 2023-2035
timeframe.
Senate B�fl 375
New tothis RTP, California's Sustainable Communities and Climate Protection Act,
orSenate Bill (S0375'calls for this RTP toinclude enSCS that reduces greenhouse
gas (GHG) emissions from passenger vehicles by 8 percent per capita by 2020 and 13
percent per capita by 2035 compared to 2005, as set by the California Air Resources
Board (ARB). SB 375 enhances the State's goals of Assembly Ki 32, the Global Warming
Solutions Act uf20O8.Meeting the required targets will not boeasy, but itmust bodone
for the health and quality of life of current and future generations. Meeting these targets
will point the region towards overall sustainability and will provide benefits beyond reduc-
ing carbon emissions.
4 2012 Regional Transportation Plan I Executive Summary
FINANCIAL CHALLENGES
Of all the challenges facing us today, there is perhaps none more critical than funding.
With the projected growth in population, employment, and demand for travel, the costs
of our multimodal transportation needs surpass projected revenues available from our
historic transportation funding source—the gas tax.
State and federal gas taxes have not changed
in nearly 20 years
Yet, highway construction costs
have grown by 82%
As a result of years of underinvestment, a significant amount of our roadways and bridges
have fallen into a state of disrepair. It is imperative that this situation be addressed. The
rate of deterioration will only accelerate with continued deferral, significantly increasing
the cost of bringing our assets back into a state of good repair. Furthermore, with recent
declines in transit funding, the region's transit operators continue to face major obstacles
to providing frequent, attractive transit service.
Rail operating costs have increased by
over 40% in the past decade
Intercity transit operators have been forced
to cut service by up to 20%
The region must consider ways to stabilize existing revenue sources and supplement
them with reasonably available new sources. This region needs a long-term, sustainable
funding plan that supports an efficient and effective transportation system that grows the
economy, provides mobility choices, and improves our quality of life.
Our Approach
7o address these challenges, SCAG performed a careful analysis of our transporta-
tion system, the future growth of our region, and potential new sources of revenue, and
embarked on a massive outreach undertaking to hear what the region had to say. While
SCAG continued to work closely through hundreds of meetings with stakeholder agen-
cies that it has always collaborated with, it also conducted a series of planning sessions
throughout the region to find out what Southern Californians want to see in their future.
The result of this multi-year effort is the 2012 RTP/SCS, a shared vision for the region's
sustainable future.
Transportation Investments
The RTP/SCS contains a host of improvements to our multimodal transportation system.
These improvements include closures to critical gaps in the network that hinder access to
certain parts of the region, as well as the strategic expansion of our transportation sys-
tem where there is room to grow in order to provide the region with the mobility it needs.
These improvements are outlined in TABLE 1.
New photo coming soon
2012 Regional Transportation Plan I Executive Summary 5
TABLE 1 Transportation Investments
Transit
$ 49.7 billion
Bus Rapid Transit (BRT)
New BRT routes, extensions, and/or service enhancements in Los Angeles, Orange, Riverside, San Bernardi-
no, and Ventura Counties
$ 4.6 billion
Light Rail Transit (LRT)
New Light Rail routes/extensions in Los Angeles and San Bernardino Counties
$13.1 billion
Heavy Rail Transit (HRT)
Heavy Rail extension in Los Angeles County
$ 11.1 billion
Bus
New and expanded bus service in Los Angeles, Orange, Riverside, San Bernardino, and Ventura Counties
$ 20.9 billion
Passenger and High -Speed Rail
$ 51.6 billion
Commuter Rail
Metrolink extensions in Riverside County and Metrolink systemwide improvements to provide higher speeds
$ 3.9 billion
High -Speed Rail
Improvements to the Los Angeles to San Diego (LOSSAN) Rail Corridor with an ultimate goal of providing
San Diego -Los Angeles express service in under two hours
Phase I of the California High -Speed Train (HST) project that would provide high-speed service from Los
$ 47.7 billion
Angeles to the Antelope Valley
Active Transportation
$ 6.0 billion
Various Active Transportation Strategies
Increase our bikeways from 4,315 miles to 10,122 miles, bring 12,000 miles of deficient sidewalks into com-
pliance with the Americans with Disabilities Act (ADA), safety improvements, and various other strategies
$ 6.0 billion
Transportation Demand Management (TDM)
4X dillior.
Various TDM Strategies
Strategies to incentivize drivers to reduce solo driving:
J Increase carpooling and vanpooling
Increase the use of transit, bicycling, and walking
Redistribute vehicle trips from peak periods to non -peak periods by shifting work times/days/Iocations
Encourage greater use of telecommuting
$ 4.0 billion
Other "First Mlle/Last Mlle" strategies to allow travelers to easily connect to and from transit service
at their origin and destination. These strategies include the development of mobility hubs around major
transit stations, the integration of bicycling and transit through folding -bikes -on -buses programs, triple
bike racks on buses, and dedicated racks on light and heavy rail vehicles
6 2012 Regional Transportation Plan I Executive Summary
Transportation Systems Management (TSM) (includes Intelligent Transportation Systems (ITS)) $ 6.8 billion
Various TSM Strategies Enhanced incident management, advanced ramp metering, traffic signal synchronization, advanced traveler
information, improved data collection, universal transit fare cards (Smart Cards), and Transit Automatic $ 6.8 billion
Vehicle Location (AVL) to increase traffic flow and reduce congestion
Highways
$ 72.3 billion
Mixed Flow Interchange improvements and closures to critical gaps in the highway network to provide access to all $18.4 billion
parts of the region
High -Occupancy Vehicle (HOV)/
Closures to gaps in the high -occupancy vehicle (HOV) lane network and the addition of freeway -to -freeway
$18.7 billion
High -Occupancy Toll (HOT)
direct HOV connectors to complete Southern California's HOV network
A connected network of Express/HOT lanes
Toll Facilities
Closures to critical gaps in the highway network to provide access to all parts of the region
$ 35.2 billion
Arterials
$ 22.1 billion
Various Arterial Improvements
Spot widenings, signal prioritization, driveway consolidations and relocations, grade separations at high -vol-
$ 22.1 billion
ume intersections, new bicycle lanes, and other design features such as lighting, landscaping, and modified
roadway, parking, and sidewalk widths
Goods Movement (includes Grade Separations)
$ 47.9 billion
Various Goods Movement Strategies
Port access improvements, freight rail enhancements, grade separations, truck mobility improvements,
$ 47.9 billion
intermodal facilities, and emission reduction strategies
Aviation and Airport Ground Access
Included in modal
investments
Various Airport Ground Access Improvements
Rail extensions and improvements to provide easier access to airports, and new express bus service from
Included in modal
remote terminals to airports
investments
Operations and Maintenance
$ 216.9 billion
Transit
$139.3 billion
Highways
Operations and maintenance to preserve our multimodal system in a good state of repair
$ 56.7 billion
Arterials
$ 20.9 billion
Financial Plan
The 2012 RTP financial plan identifies how much money is available to support the
region's transportation investments. The plan includes a core revenue forecast of existing
local, state, and federal sources, along with reasonably available new revenues sources
that are likely to materialize within the RTP time frame. These new sources include
adjustments to state and federal gas tax rates based on historical trends and recom-
mendations from two national commissions (National Surface Transportation Policy and
Revenue Study Commission and National Surface Transportation Infrastructure Financing
Commission) created by Congress, further leveraging of existing local sales tax measures,
value capture strategies, potential national freight progam/freight fees, as well as pas-
senger and commercial vehicle tolls for specific facilities. Reasonably available revenues
also include innovative financing strategies, such as private equity participation.
TABLE 2 presents ten categories of new revenue sources and innovative financing tech-
niques that are considered to be reasonably available and are included in the financially
constrained plan. For each funding source, SCAG has examined the policy and legal
context of implementation, prepared an estimate of the revenue potential, and identified
action steps to ensure the funds are available to implement the region's transportation
vision.
Revenue Sources and Expenditures
FIGURES t AMD 2 provide a summary of the plan's forecasted revenues and expenditures.
As shown in these figures, the region's budget over the next 25 years totals an estimated
$524.7 billion.
2012 Regional Transportation Plan I Executive Summary 7
TABLE 2 New Revenue Sources and Innovative Financing Strategies
(Nominal Dollars, Billions)
Bond Proceeds from
Issuance of debt against existing sales tax revenues: Los
$25.6 bil
Local Sales Tax
Angeles, Orange, Riverside, and San Bernardino Counties.
Measures
State and Federal Gas
Additional $0.15 per gallon gasoline tax imposed at the
$16.9 bil
Excise Tax Adjustment
state and the federal levels starting in 2017 to 2024—to
to Maintain Historical
maintain purchasing power.
Purchasing Power
Mileage -Based User
Mileage -based user fees would be implemented to replace
$110.3 bil
Fee (or equivalent fuel
gas tax and augment—estimated at about $0.05 (2011$)
(est.
tax adjustment)
per mile and indexed to maintain purchasing power starting
increment
2025.
only)
Highway Tolls (includes
Toll revenues generated from SR -710 Tunnel, 1-710 South
$22.3 bil
toll revenue bond
Freight Corridor, East-West Freight Corridor, segment of
proceeds)
the High Desert Corridor, and Regional Express/HOT Lane
Network.
Private Equity
Private equity share as may be applicable for key initia-
$2.7 bil
Participation
tives: e.g., toll facilities; also, freight rail package assumes
railroad share of costs for mainline capacity and intermo-
dal facilities.
Freight Fee/National
A national freight program is anticipated with the next
$4.2 oil
Freight Program
federal reauthorization of the surface transportation act.
The U.S. Senate's proposal would establish federal formula
funding for the national freight network.
E -Commerce Tax
Although these are existing revenue sources, they gener-
$3.1 bil
ally have not been collected. Potentially, the revenue could
be used for transportation purposes, given the relation-
ship between E-commerce and the delivery of goods to
California purchasers.
Interest Earnings
interest earnings from toll bond proceeds.
S0.2 bd
State Bond Proceeds,
State general obligation bonds authorized under the Bond
$33.0 bil
Federal Grants & other
Act approved by California voters as Proposition 1A in
for California High
2008; federal grants authorized under American Recovery
Speed Rail Program
and Reinvestment Act and High -Speed Intercity Passenger
Rail Program; potential use of qualified tax credit bonds;
and private sources.
Value Capture
Assumes formation of special districts including use of tax
$1.2 bil
Strategies
increment financing for specific initiatives.
8 2012 Regional Transportation Plan I Executive Summary
FIGURE 1 Revenue Sources
$524.7 Billion (Nominal Dollars) FY2011—FY2035
Additional State
$83.2(16%) _
83.2(16%)^
Core State-/
$46.8(9%)
Core Local
..995 5 1AW I
$84.3(16%)
Source: SCAG Revenue Model 2011
Note: Numbers may not add due to rounding
FIGURE 2 Expenditure Summary
$524.7 Billion (Nominal Dollars) FY2011—FY2035
Debt Service
$45.1 (9%)N
O&M Highway
$56.7(11%)
Capital Projects
$262.8 (50%)
Source: SCAG Revenue Model 2011
Note: Numbers may not add due to rounding
.M Transit
59.3 (27%)
Local Roads
$20.9(4%)
Sustainable Communities Strategy
Within the RTP, the SCS demonstrates the region's ability to attain and exceed the GHG
emission reduction targets set forth by the ARB. The SCS outlines our plan for integrating
the transportation network and related strategies with an overall land use pattern that
responds to projected growth, housing needs and changing demographics, and trans-
portation demands. The regional vision of the SCS maximizes current local efforts that
support the goals of SB 375, as evidenced by several Compass Blueprint Demonstration
Projects and various county transportation improvements. The SCS focuses the majority
of new housing and job growth in high-quality transit areas and other opportunity areas
Local in existing main streets, downtowns, and commercial corridors, resulting in an improved
0%) jobs -housing balance and more opportunity for transit -oriented development. This overall
land use development pattern supports and compliments the proposed transportation
network that emphasizes system preservation, active transportation, and transportation
demand management measures. Finally, the RTP/SCS fully integrates the two subregional
SCSs prepared by the Gateway Cities and Orange County Council of Governments.
Measuring
g �
,mn�^p
The investments inthis RTP/SCS are expected toresult in significant benefits to the
region with respect to transportation and mobility, as well as air quality, economic activity
and job creation, sustainability, and environmental justice. They wiNresult inbetter place -
making, lower overall costs, advances in public health and the environment, responsive-
ness to a changing housing market, and improved accessibility and mobility.
8'r Quality and GHGToFgnts
2012Regional Transportation Plan IExecutive Summary 9
K8oh'Ht«
Our roadways will be less congested, allowing our region's residents to spend less time in
traffic onboard obus mbehind the wheel and more time with their families.
�rf-�tn
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W��NiUreduce greenhouse gas 8[Di83i003hV ���� ��} hv��' Not on�w0�oden�bommmmobi�,they v�Na�ob*ou�:Th�RT��
�C�emphao�
^ -'
����� h«���� on safety wiQnmu�inoigni�oon�ylower accident r�au.giving our mmidon1othe peace of
N����� -' mind totravel freely throughout the day and come home tntheir loved ones every night.
This RTP/SCS successfully achieves and exceeds our greenhouse gas emission reduc- Economy
tion targets, set byARB byachieving an8percent reduction by2O2Oand 16percent
reduction by 2035 compared to the 2005 level on a per capita basis. This RTP/SCS also
meets criteria pollutant emission budgets set by EPA. With each passing year, Southern WSwill generate 4.2 million
wn
DbS
Californians should expect tubreathe cleaner air and live healthier lives.
This air quality benefit is made possible largely bymore sustainable plannimg, integrat-
ing transportation and land use decisions to allow Southern Californians tolive closer
to where they work and play, and to high-quality transit service. As a result, more resi-
dents will be able to use transit and active transportation as a safe and attractive means
of travel.
Location Efficiency
� ~
Over �� onwm* ��N����
as [OaDV households will live
Dear high-quality transit
Share of households living in the High Quality Transit Area will more than double over the
plan period signaling a more efficient overall development pattern in the future.
Not only will the region be more mobile, it will also be more prosperous.Umplementation
of the RTP/SCS will create or sustain jobs today to build transportation infrastructure
projects for tomorrow. The 4.2 miflion total jobs over the life of the RTP/SCS equates to
an annual average of 167,900 jobs, and is not limited to the construction industry, but will
encompass a broad cross-section of industry clusters.
Investment Effectiveness
We will get $2.90
back for every $1 spent
The RTP/SCS makes dollar sense. While its overall expenditures seem like ahuge cost,
the region will recover $2.0Ofor every $1this RTP/SCS commits, which will only help
10 2012 Regional Transportation Plan I Executive Summary
Public Participation
The development of the Draft 2012 RTP/SCS involved implementation of one of the most
comprehensive and coordinated public participation plans ever undertaken by SCAG. The
public and stakeholder involvement program went over and beyond meeting the require-
ments of SB 375 and the SAFETEA-LU. SCAG engaged the widest range of stakeholder
groups, elected officials, special interest groups as well as general public, through a
series of workshops and public meetings, as well as SCAG's policy committees, task
forces and subcommittee structure. The input received through this process has truly
shaped the Draft 2012 RTP/SCS in a meaningful way. Furthermore, SCAG will continue
to involve and engage the stakeholders and the public in the process of refining and
finalizing the 2012 RTP/SCS over the next several months through the close of the formal
comment period. SCAG has developed a state-of-the-art video and interactive RTP/SCS
website called iRTP that will further enhance our capability to engage and involve the
stakeholders and the public to continue shaping the 2012 RTP/SCS.
Strategic Plan — Looking Ahead —
Beyond the Horizon
The 2012 RTP/SCS proposes investing over $500 billion over the next 25 years to improve
the quality of life of the region's residents by enhancing our transportation system.
However, additional strategies and projects are needed. The Strategic Plan identifies
additional long-term initiatives such as zero emission transportation strategies; new oper-
ational improvements; expanded transit investments and high-speed rail system; as well
as increased commitment to active transportation. Although elements of these strategies
are included in the financially constrained plan, further work is needed to ensure there is
regional consensus and commitment to fund the balance in subsequent RTPs.
REGIONAL TRANSPORTATION PLAN
2012-2035
SUSTAINABLE COMMUNITIES STRATEGY
Towards a Sustainable Future
RTP
REGIONAL OFFICES
Imperial County
1405 North Imperial Avenue
Suite 1
EI Centro, CA 92243
Phone: (760) 353-7800
Fax: (760) 353-1877
�� please recycle 2347 01.31.2012
Orange County
OCTA Building
600 South Main Street
9th Floor
Orange, CA 92863
Phone: (714) 542-3687
Fax: (714) 560-5089
SOUTHERN CALIFORNIA
ASSOCIATION of GOVERNMENTS
818 West 7th Street, 12th Floor
Los Angeles, CA 90017
Phone: (213) 236-1800
Fax: (213) 236-1825
www.scag.ca.gov
Riverside County
3403 10th Street
Suite 805
Riverside, CA 92501
Phone: (951) 784-1513
Fax: (951) 784-3925
San Bernardino County
Santa Fe Depot
1170 West 3rd Street
Suite 140
San Bernardino, CA 92418
Phone: (909) 806-3556
Fax: (909) 806-3572
Ventura County
950 County Square Drive
Suite 101
Ventura, CA 93003
Phone: (805) 642-2800
Fax: (805) 642-2260