Comments to SANDAG on 2050 RTP and SCS

Original letter can be viewed here: CNFFSofarCommentLetterRTP

Hon. Jerome Stocks, Chairman
Board of Directors
San Diego Association of Governments
401 “B” Street, Suite 700
San Diego, CA 92101

Re: Cleveland National Forest Foundation & Save Our Forests and Ranchlands- Comments on 2050 Regional Transportation Plan and Sustainable Communities Strategy

Chairman Stocks, Members of the Board and Staff:

SANDAG begins the Draft 2050 Regional Transportation Plan (RTP) with a lofty vision:

The vision for our region’s future has evolved, changing from one that pictured steady expansion to the east, to one that placed a greater value on protecting open space, to one that now focuses on a compact urban core where more people live and use fewer resources. Local governments have been working toward this vision for decades. [SANDAG 2011 Draft 2050 Regional Transportation Plan p. 1-2]

Contained in this vision is the recognition that a change has occurred of such magnitude that it requires a massive shift in the traditional pattern of growth. In fact, as we all know the change is global and affects every aspect of our daily lives from the price of gasoline to the melting poles. Responding to this change by redirecting growth to urban centers and using fewer resources presents local leaders and the public with a profound challenge―Are we going to continue “business as usual” and forgo the enormous regional benefits that would accrue from actualizing this vision, or are we as a region going to work together to implement these bold ideals and meet the environmental and economic challenges of the twenty first century?

Unfortunately, the fine words at the beginning of SANDAG’s RTP are not adequately supported by the current prioritization of projects identified in the Plan itself. Long-term sustainability for the region cannot be achieved as the Plan is currently constituted mainly because SANDAG proposes to continue emphasizing increased highway expansion over other transit project options, especially within the first ten years of the Plan. Deferring these other critical transit infrastructure projects to later years increases the likelihood that the opportunity to realize the region’s vision for the Plan will be severely compromised.

We view the current overall planning focus to be largely a continuation of SANDAG’s auto-centric, “business as usual” policies. The region can no longer afford to take this unsustainable approach to regional transportation. SANDAG must evaluate an environmentally superior alternative that truly prioritizes transit over highways. (While the RTP EIR’s Alternative 2b is a step in the right direction, it does not go far enough in prioritizing transit over highways.)

Nationwide, San Diego is being discussed as a potential model for sustainable growth. Other metropolitan areas are observing how our region will balance economic and population growth with environmental concerns as we attempt to comply with Senate Bill 375’s requirements. California has in the past served as a model for progressive reforms, and expanding transit based infrastructure rather than highways will allow San Diego to once again be a model for regional planning by helping to reduce its reliance on the private automobile and simultaneously decrease the size of our region’s carbon footprint.

As the first metropolitan region planning to adhere to SB 375 requirements, it is unfortunate that this RTP and the Sustainable Communities Strategy (SCS) did not seek to exceed the SB 375 greenhouse gas (GHG) targets established by the California Air Resources Board, which are admittedly low to begin with. This is a rare opportunity to establish a new baseline that potentially would help guarantee future support for full implementation of all of our transit options. Unfortunately, it is not clear from the Plan’s current prioritization, how individual modalities, policies and programs will achieve the stated GHG reductions. For example, the SCS indicates there will be minimal reductions in per capita Vehicle Miles Traveled (VMT) by 2050 (less than 1%) as measured against 2008 levels and at the same time claims a corresponding reduction in GHG per capita of 9%. This discrepancy appears illogical and requires further explanation. SANDAG must explain how it intends to achieve long term GHG reduction goals, if not from reductions in VMT.

As the regional transportation authority, SANDAG should focus specifically on explaining not only how it intends to achieve the minimum GHG reduction goals, but how the Plan supports long-term reductions well beyond the levels that are counter to the region’s sustainable vision.

If history has taught us anything, it is that building freeways has done nothing to solve the region’s traffic congestion problems. Instead, it has resulted in a society that is overly dependent on automobiles. In turn, this automobile dependence has resulted in a broad array of impacts – including sprawling development, loss of agricultural and open space lands, contributions to global climate change, air quality degradation, and a disproportionate burden on our region’s low income community due to the high costs of an auto centric economy. And finally, particularly vulnerable to being crushed by this growth juggernaut is a pearl of great price – a sliver of forest wilderness in the mountains of San Diego’s east county known as the central portion of the Peninsular Range Ecosystem. This fragile mountain redoubt is still home to the mountain lion and a broad array of unique plant and animal species. We cannot afford to lose San Diego’s last remaining functioning ecosystem.

For many years, SANDAG and Caltrans have over invested in highways while under-investing in public transit options. Consequently, the region has an extensive highway system that serves any possible automobile trip in the region, but a transit network which is poor in both area of coverage and quality of service. We’ve given highway building a fair chance. Now it is time to give an equal chance to public transportation.

We agree with Sustainable San Diego when they state: “The opportunity presented by the requirements of SB 375 was to generate the possibility of a fundamental re-assessment and adjustment of our region’s transportation planning focus. This did not materialize. The current and projected priorities within the plan and the assumptions which support them are not anticipated to substantially change what is essentially a “highway first” model for regional transportation planning.”

Without a comprehensive, well integrated transit system, public transportation has been incapable of meeting the region’s transportation mobility needs. We need to break this cycle and build, initially in the urban core, a transit system that is capable of effectively replacing the automobile as the primary transportation option. Transit investments in the Urban Area Transit Strategy Area will encourage compact, urban development. This will result in a virtuous cycle where transit investments encourage transit-oriented development, boosting transit ridership, and encouraging more transit investments. We recommend, therefore, that SANDAG focus its priorities on building a world-class, comprehensive transit system beginning in the urban core and expanding throughout the region, implemented within the next decade. Only after this is achieved, will it be possible to appropriately assess the true need for further highway expansion.

A New Plan and a New Direction

An alternative to SANDAG’s transportation plan, which we will be submitting is: the “50-10 Transit Plan: A World Class Transit System for the San Diego Region.” This Plan calls for 50 years of transit infrastructure be constructed within a 10-year period. This Plan looks at the region’s transportation options not as separate entities, but part of an extensive system that focuses on the links between land use policy, economic realities, environmental protection and community development. As such it promotes: (1) that most new development should occur in compact, walkable mixed use development based on sustainability planning and design principles; and (2) that a comprehensive, integrated transit system initially focused on the urban core, the Sprinter and the Coaster is critical to the long-term success of a sustainable future. This comprehensive transit network would be constructed prior to any additional spending on new freeway and/or tollway capacity because further roadway expansion would simply undermine any investment in transit by encouraging decentralized auto-focused development. Therefore, an equally critical element of the Plan calls for a modification of the TransNet program to ensure transit infrastructure projects are prioritized and receive necessary funding, rather than furthering highway expansion projects.

TransNet: Funds for Change

TransNet monies come from local taxpayers and are currently spent disproportionately on road and freeway building. This presents local elected officials and the public with a tremendous opportunity because local funds are subject to local control and therefore can be changed to reflect the resource challenges of our community. There is every indication that the public would support a change in the TransNet formula and invest more money in transit infrastructure projects. In an authoritative survey, voters overwhelmingly (73%) supported transit over freeway construction. In light of these facts, the retort by politicians that they cannot change TransNet “because the people voted for it” is indefensible. It is abundantly clear that voter opinion has changed in this matter, and therefore, if a vote of the citizens of this County is necessary to reprioritize these funds, it should be their choice to do so. The world has changed, voters’ opinions have changed, and it is time that TransNet reflect that change.

We believe that the 50-10 transit vision is superior to the current draft RTP for many reasons, including but not limited to: it reduces the environmental impacts of the RTP (including substantially greater reduction in GHG emissions and criteria air pollutants), lays the foundation for compact, infill development, recognizes the region’s natural resource limitations, and is more beneficial to the public’s health. The 50-10 Plan needs to be considered as an alternative to the current draft RTP. When comparing the two, it is obvious that the 50-10 Plan provides a more realistic approach to achieving the RTP’s own vision as it would set the track for San Diego to grow in a sustainable direction. Therefore, per CEQA requirements, the 50-10 plan needs to be considered as a feasible alternative.


/Duncan McFetridge/

Save Our Forest and Ranchlands (SOFAR)
Duncan McFetridge, President
Cleveland National Forest Foundation (CNFF)
Duncan McFetridge, Ex Officio