SANDAG – first California Region to produce plan under SB 375

Comments on the RTP to further the San Diego dialogue on Transit Planning

photo credit: TransformCA on flickr

Stuart Cohen,
Executive Director, TransForm
Member, SB 375 Regional Targets Advisory Committee
May 23, 2011

As SANDAG nears the end of their comment period on California’s first Sustainable Communities Strategy under SB 375, which is part of the SANDAG’s 2050 RTP, there is a strong feeling that more must be done to improve it. This analysis briefly outlines what many see as the most fundamental problem, the continued focus on freeway and arterial expansions in the RTP, and what ideally would take place instead of those expansions.

It then discusses practical constraints and considerations for changing the RTP, especially given the time frame. It concludes with nine recommendations that are divided into three sections:
I. Recommendations for improving SANDAG’s 2050 RTP
II. Commitments to develop new policies once the RTP is adopted
III. Commitments for additional analyses once the RTP is adopted

There are two primary causes of concern that are worth noting from the outset. First, the SCS barely reduces VMT per capita by 2050 compared with 2008 levels (25.66 vs. 25.34), just over a one percent reduction, yet the plan claims to reduce GHG per capita 9 % in this time frame. This plan needs to be carefully examined to determine where the reductions in GHG per capita are coming from, if not reductions in VMT, and whether these are lasting changes.

Second, while SANDAG exceeds their target for 2020, the reductions in GHG per capita then begin to decline, so that by 2050, the RTP investments only achieves a 9% reduction as compared with a 14% reduction in 2020. This is contrary to the conventional wisdom about transportation and land use planning as well as every conversation about the subject during the Regional Targets Advisory Committee process; that land use and transportation changes accrue over time to give much more substantial reductions in the 2035 and 2050 time horizons. It is of great concern if SANDAG’s SCS only achieves short term GHG reductions that are eroded over time.

Photo Credit: TransformCA on flickr, Shannon Tracy from T4

What is the problem with planning for so many roads?
1. San Diego already has an extensive arterial and highway system. As in other regions throughout the US, the primary problem is not that there is not enough road space, but that so many people want to use it at the exact same moment — primarily weekdays at 8 am and again at 5 pm.
2. Building more roads is incredibly expensive. Highway projects and connectors would consume over $22 billion (2010 dollars – RTP page 5-13) through 2050, and would require about $10 billion more for maintenance and rehabilitation.
3. Building roads subsidizes and supports a more auto-oriented development pattern and generally suppresses a shift towards development the meets the growing demand for compact, walkable transit-oriented development.
4. Building all of these roads, and especially the $6 billion worth of projects programmed over the next decade FY 2010-2020 (pg 5-11, in escalated dollars) also translates into less funding for transit, walk, bike and other modes.
5. Such auto-oriented development places a large financial burden on residents; TransForm’s Windfall for All showed that if all San Diego residents had the same level of public transit access as the quintile (20%) with the best transit access, San Diegans would be saving $3,515 per household annually or $2.8 billion as a region, and emitting 30% fewer greenhouse gases from cars and light trucks.

What would ideally happen?
While advocates for sustainability and social equity may have differing priorities, it is generally agreed that we would have fewer (and some want no) highway and arterial expansions and, to the extent road expansions are funded, to backload them later in the plan. Some select plans, like the current plan for I-5, that call for an extraordinary expansion to 14 lanes in some sections, are especially critical to scale back or stop.

Yet intense traffic congestion generates additional CO2 and leads to popular demand for more highway expansions. So given the growing population, it is imperative to reduce demand and improve operations on roads and highways in order to avoid dramatic gridlock.

Currently, SANDAG’s projected mode shift away from single occupancy vehicles is based on a future where carpools, vanpools and transit vehicles can flow freely on the RTP’s proposed HOV/carpool lanes and on a great number of new “managed lanes” that allow solo drivers into those lanes for a fee. Any plan for improving access with fewer physical road expansions would have to account for the fact that San Diego’s road system has so few carpool and managed lanes at this time.

Instead of physical expansion and new lanes, it would be ideal to move vehicles more efficiently with a combination of:

photo credit: TransformCA on flickr

1. Implementation of a more ambitious Transportation Demand Management (TDM) program. From telecommute to flex-time to transit incentives; more can always be done with TDM. Though without HOV or managed lanes the list of effective TDMs is somewhat constrained, e.g. carpool promotions and vanpooling incentives would clearly not work as well.
2. Acceleration of the Transportation Systems Management programs, including comprehensive ramp metering.
3. Acceleration of transit, bicycle and pedestrian infrastructure targeted towards the most congested commute corridors, as well as smart growth areas that are actively zoning for and attracting new walkable development.
4. Optimizing use of the existing infrastructure by:
a. Analyzing and potentially supporting the conversion of at least one mixed flow lane in each direction, at least on highways that currently have at least 8 lanes, into a managed lane. SANDAG was a pioneer with I-15 and this is the next generation of out-of-the-box ways to improve efficiency and save taxpayers money. This would allow many of the same vanpooling and other strategies to work without new lanes. It would still cost money to implement and faces a host of obstacles, but so did I-15 when it was conceived.
b. Scaling back on some of the proposed expansions — for example corridors where 4 managed lanes are proposed — considering whether that can be reduced to two new lanes by further reducing demand.
c. Analyzing innovative new practices, such as in Minnesota where buses are allowed to use existing shoulders to bypass congestion.
d. Including an equity analysis of any conversions, including provisions for funding benefits such as reduced or free transit fares, to ensure there is overall benefit to low-income commuters.

Needless to say, if efficiencies can be found in this area, funding saved by reducing the number or scope of freeway expansions could be used for TDM programs or to speed implementation of the transit, bicycle, and pedestrian improvements included in the RTP.

photo credit: TransformCA on flickr

What are some practical constraints and considerations?
Realistic recommendations for achieving an ideal transportation system that maximizes environmental and social benefits while reducing costs for taxpayers requires an understanding of the constraints SANDAG faces, and the underlying statutes governing RTPs.

At a most basic level, some major constraints and considerations include:
1. TransNet – TransNet is probably the biggest constraint in the entire RTP. TransNet projects, both highway and transit, dominate the RTP’s committed project list. While SANDAG can revisit and change many of these projects with a 2/3 vote of the board, the measure does not call for a comprehensive program review until 2019. However, SANDAG’s board can change the phasing of projects in the TransNet expenditure plan in order to prioritize those that improve sustainable transportation options and support priority growth areas.
2. Need for transit operating funds – Most sources of state and federal funding cannot be “flexed” from capital to operations. And because of federal requirements that RTPs are “financially constrained” it is not possible to simply assume more transit projects are built without a reasonable chance of being able to operate them. Thus, SANDAG can only go so far in bringing transit projects forward without a reasonable financial plan.
3. Already assuming some new funding in the plan – The passage of a new source of operating funds is already assumed as part of the constrained revenue scenario (federal requirements allow such assumptions, as long as they are reasonable). In other words, even to get to the service levels outlined in this RTP there will need to be strong collaboration and likely additional commitment from the voters. A significant reason cited for not changing the TransNet projects at this time is that SANDAG needs to show voters that they follow through on commitments, especially since SANDAG is bringing together diverse interests around a “quality-of-life” initiative. This effort may lead to a funding measure that would likely include some portion of transit operating funds, and potentially funding for parks, water quality and a host of other uses.
4. Land use projections must also be realistic – Federal guidelines require RTPs to use realistic land use assumptions that consider existing general plans and codes, though federal agencies and the state RTP guidelines explicitly allow for MPOs to deviate from local land use plans in order to account for economic trends, regional plans, or likely shifts in state and federal policy. While SB 375 does not give SANDAG any power over local land use, but creates incentives for smarter land use and a more sensible, integrated planning framework (see excerpt at bottom for how clearly this is stated in SB 375).

Given all of these realities, and the imminent adoption of the RTP, the following recommendations are divided into three sections:
• Recommendations for improving SANDAG’s 2050 RTP
• Commitments to develop new policies once the RTP is adopted
• Commitments for additional analyses once the RTP is adopted

Recommendations for improving SANDAG ’s 2050 RTP

1. Identify Specific Programs and Near-Term Funding for Active Transportation.
The proposed $2.58 billion expenditure on Active Transportation is an excellent addition to this RTP, but a significant commitment of funding should be made early in the plan (in the next 2-10 years) to maximize its long-term benefit. This commitment should be for a “pro-rata” share of funds for the RTP as a whole.

photo credit: TransformCA on flickr

TransForm applauds the development of a Regional Safe Routes to School Strategy (pg 6-52). There should also be a firm commitment to implement the recently discussed “Safe Routes to Transit” program, which promotes bicycling and walking to transit stations by making important bike/pedestrian feeder trips easier, faster, and safer. Either a new grant program should be initiated that focuses on Safe Routes to Transit, or criteria developed that further prioritizes existing smart growth or bicycle and pedestrian programs to improve access to transit. Any grant criteria should also ensure low-income communities get improved access.

2. Clarify and commit to improve transit frequency where densities and ridership warrant.
Local bus transit service is, and will remain, the workhorse of the transit system, including connecting people to regional transit. A map identifying SANDAG’s “key corridors” i.e. where local transit will have headways of 15 minutes by 2020 and 10 minutes by 2035, should be included in the final RTP.

In addition, SANDAG should review whether additional routes that have 10-minute headways assumed for 2035 could be advanced to 2020, where densities and potential ridership may justify that frequency. These headways can then be included in the unconstrained revenue scenario, and considered as part of any new funding measure. Expediting the delivery of transit projects will incentivize transit-oriented walkable development patterns which deliver per capita VMT and GHG reductions and will help SANDAG to meet its target. Waiting to fund these projects in the outer years of the SCS may mean that a greater share of development will be auto-oriented and detract from SANDAG’s efforts to achieve its land use goals and meet the GHG targets.

3. Improve Project Phasing by funding key commute routes earlier.
While operating funds are constrained, SANDAG could identify where Bus Rapid Transit (BRT) and “Rapid” routes in key urban corridors could be advanced earlier. As with recommendation #2 above, SANDAG should specify the incremental amount of funding needed to bring it forward. Include these projects in the constrained revenue scenario if feasible. Specific suggestions include:
— Move BRT 640 from 2020 to before 2018 (I-5 – San Ysidro to Downtown and Kearny Mesa via I-5 shoulder lanes/HOV lanes, Downtown, Hillcrest/Mission Valley Guideway);

— Move Rapid Route 30 from 2030 to 2020 (Old Town to Sorrento Mesa via Pacific Beach, La Jolla, UTC)

— Move Rapid Route 11 forward from 2035 to 2020 (Spring Valley to SDSU via SE San Diego, Downtown, Hillcrest, Mid-City)

4. The Sustainable Communities Strategy should include a map and narrative detailing how existing and planned transit serve “Smart Growth” Opportunity Areas.
SANDAG should clarify how its plan is internally consistent. Its assumptions about percentage of new development in multi-family configurations near transit are impressive and appropriate for its Sustainable Communities Strategy. It should clarify how its transportation investments will support the implementation of this land use pattern.

Commitments to develop new policies once the RTP is adopted

5. Develop a Transit-Oriented Development Policy as part of the upcoming dialogue on strategies to support transit.
Regions and jurisdictions across the country have developed policies that save taxpayers money and improve the efficiency of the transportation system by more closely linking transit investment with supportive land use policies. Phoenix, for example, limits auto-oriented land uses from being built within walking distance of light rail stations. The Bay Area’s Metropolitan Transportation Commission only commits regional funding to a transit corridor once the communities along the project have plans for supportive land use near the stations.

SANDAG will soon be considering a broad range of parking and land use strategies to support transit, and this dialogue should include the development of a regional TOD policy that is fashioned to meet San Diego’s particular needs.

6. Commit to implementing parking policies, including funding innovative programs.
SANDAG deferred consideration of transit-supportive parking policies and programs until after the current RTP is adopted. Since research has shown that more supportive parking policies are critical to transit’s success, SANDAG should set out a specific timeline for this review, and commit to funding innovative parking programs (out of smart growth incentive or other funding streams). The most effective and innovative programs could then be brought to scale as part of the 2015 RTP.

Commitment for additional analyses once the RTP is adopted

7. Identify and model a maximum TDM/TSM/Transit alternative as part of SANDAG’s upcoming discussion on strategies to support transit.
SANDAG has committed to considering a wide range of transit-supportive strategies once the SCS is adopted. To understand the potential synergistic benefits of maximizing these demand management strategies with other system management and pricing strategies, SANDAG should conduct an exercise that starts with the existing system as a base, and see what mix of projects and programs can have the biggest impact.

This may include concepts that are not widely supported at this time – such as converting certain mixed-flow lanes, especially where at least 8 exist on a corridor, into managed lanes. (This would be consistent with RTP page 6-66 “Consider congestion pricing as an alternative whenever new highway capacity is added – responsible parties: SANDAG and Caltrans”.) This exercise could create a huge payoff as we try to find low-cost, effective ways to increase access and mobility.

SANDAG should include an analysis of arterials in these scenarios, seeking to maximize TDM and TSM strategies as a way to limit the demand for physical arterial expansions. This analysis could involve the two SANDAG working groups that currently focus on local roads and arterials. Findings should be presented to the cities and county (as they are the ones that generate plans for arterials) and tied to funding and grant programs.

photo credit: TransformCA on flickr

8. Improve Performance Targets, Project Performance Measures and Assessment Tools.
SANDAG did more than ever with this RTP to set a broad range of environmental, health and social equity goals. There was also a methodology created for ranking highway and transit projects. While laudable, there were various weaknesses; including not creating quantifiable targets for public benefits such as health and open space. Ideally each transportation project would be evaluated for its potential to either achieve or detract from these targets as MTC is currently doing. Such analysis can provide critical information to decision-makers and the public as they decide not just on projects to include in plans, but in what order they are funded.

SANDAG should commit to revisiting their methodology, reviewing what other regions have done, and having a more transparent method for developing and illustrating project performance assessment, and show how these projects link to regional goals.

9. Use Scenario Planning to Identify Impacts of Major Land Use Trends
As SANDAG undertakes an update of its Regional Comprehensive Plan (that outlines future projected land uses) it should undertake some analysis and scenario planning for areas that are generating excessive vehicle trips. While much of the SB 375 focus is on integrating planning for housing, it seems that the design and locations of future job centers, primarily in North County, are part of the reason the GHG reductions degrade over time. Employment growth, as well as residential locations, should be an important part of this analysis.

Additional information including a short SB 375 fact sheet could be found at
For suggested changes please contact Stuart at

Thanks to Move San Diego for including this letter in their MoveNews – highly recommend signing up to be on their informative email list.

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