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It is a matter of great importance to a concerned citizen that
there are many items in Fresno COG’s RTP/SCS proposal which raise
the question of how such a proposal can attain the AB32 targets of
greenhouse gas reduction (GGH).

There is no mention in the sustainable community strategy (SCS) of
what the term ALTERNATIVE TRANSPORTATION means.   FCOG recommends:
more roads, more bikepaths, more sidewalks and more buses.  There
is NO mention of alternative transportation modes.  Walking is
currently available and an impractical mode of alternative
transportation.  Taking a bus is currently available, albeit on a
selective time availability. The selective route mapping and
selective service time availability make it impossible for the
general public at large to use as a realistic mode of alternative
transportation.  Riding a bicycle is also currently available to
many but, the long distances to destination points in Fresno County
only allow the true bicycle enthusiasts accommodation to serve as a
commute possibility.  Driving a car is designated as the only
useable mode of transportation: it has been the foundation of our
Western Society’s land-use design orientation for the past 80+
years and is the root of unsustainable growth.

To FCOG’s statement on page 4-20: “California’s Low Carbon Fuel
Standard (LCFS) Program requires a reduction in the carbon
intensity of transportation fuels that are sold, supplied, or
offered for sale in the state by a minimum of 10% by 2020. CARB
regulations require transportation fuel producers and importers to
meet specifi ed average carbon intensity requirements for fuel.” 
Is that to be interpreted as a claim that all of California’s GHG
reductions are to be met by automobile manufactures and it renders
the entire FCOG SCS exercise irrelevant?

As for the 5% decrease as mandated by SB375; are there numbers of
supporting documentation?  Are there enough people riding bicycles
and walking to validate a significant reduction of vehicle miles
traveled (VMT)?  Or, by merely adding another bus route on Shaw
along with the two other routes that will cause increased
congestion by halting opposing traffic through traffic light
manipulation, where, or how, does this effectively reduce GHG?

Also, with all of the other Fresno County municipalities growing,
does the increase of sidewalk and bike paths along with the
additional bus route; adequately account for the automobile
increase to the outlying area automobile centric growth? 

How can one of the goals of the 2014RTP/SCS be to encourage more
compact development when the nature of Fresno’s growth is
automobile centric?  It is a tragically illogical assumption that 8
houses per acre will somehow magically reduce traffic congestion
from 4 houses per acre.  That logic is incomprehensible.  Rational
thought dictates that twice as many houses will double street
traffic load and exacerbate congestion at an appropriately
exponential rate.  Where are FCOG’s math numbers which support a
doubling of automobile traffic and exponentially increasing traffic
congestion that propose to reduce GHG?  

In following the notably popular data collected by groups
encouraging sustainable urban growth, there is a consistent theme:
sustainable urban growth occurs with Transit Oriented Development. 
Fresno does not have a fixed rail transit system and thereby all of
its growth is automobile centric.

Over the past 80 years, all of Fresno County’s land-use growth is
based on an automobile centric design.  Or am I the only one that
has ever attended a COG meeting that has noticed?  There will be NO
reduction of GHG until Fresno’s automobile centric land-use
development is curtailed by replacing the foundation of its growth
pattern.  To suggest that Fresno will reduce its GHG and achieve
the AB32 GHG reduction targets with new sidewalks, wonderful empty
bike lanes, and several  bigger buses is, excuse the harsh term
but, that concept is ludicrous.

FAX ridership caters to the impoverished.  FAX is incapable of
serving the general public as an alternative form of
transportation.  The function of its bus lines is to shuttle poor
people to government offices.  The ridership is not targeted even
for the government office workers because the long destination
arrival times take far too long for anyone that owns a car and can
afford gas money.  The point is: FAX is designed for the poor.  

Through designed ridership targeting aimed at the low income
financial segment of society, FAX has earned a reputation for
providing the community with a transportation system that is
socially segregated to serve that section of society.  Can anyone
be gullible enough to believe that bigger buses averaging 4mph
faster would be able to convince the general public to join the
social stigma and become members of the low income ridership?  

Again, what is missing from COG’s SCS?  What is missing is
addressing the key points of Fresno’s land-use design.  Fresno’s
urban land-use design is automobile centric.  There can be NO
REDUCTION of GHG without significant reduction of VMT.  Fresno’s
automobile centric land-use design can not accommodate the needed
Transit Oriented Development (TOD) without an adequate fixed rail
transit system.  Sustainable Urban Growth will not happen; it can
not happen with the automobile as the foundational component to
urban design.  

Are the Fresno Planners incompetent or is its leadership so mired
in political fear that it has to appear without the reality of
cognitive presents? 

One of the issues with FCOG’s SCS proposal is that it lacks
accounting of the available funds which support alternative
transportation options.  

COG has been presented with several opportunities to investigate
New Technology Transit options.  Each opportunity was thwarted with
hostile turn-downs from COG’s leadership.  This community needs
alternative transportation options but, the community’s non-elected
political powers operate in a very status-quo manner which promotes
its automobile centric growth.  

The automobile, however, is wholly unsustainable.    

To measure what FCOG deems is appropriate in what it calls an
alternative form of transportation; can what it proposes as an
alternative form of transportation in the SCS serve an individual
of the general public in an emergency?  Could a person get across
town to a hospital?  Could a person wait at a bus stop at 10:00pm
for a bus to the hospital?  Or could a person ride a bicycle in one
of FCOG’s new bike lanes to a hospital in an emergency?  

Again, it is a prevarication for FCOG to refer to any other form of
alternative transportation than what already exists that has caused
the need for AB32. 

As a concerned citizen, I plead with the ARB to please consider
these words.  Please allow COG to reconsider its SCS that includes
an adequate alternative mode of sustainable transportation.   

In 2006 Fresno voters passed the 1/2cent sales tax to be allocated
for transportation.  Fresno COG is responsible for the New
Technology Transit fund.  “The goal of the New Technology Reserve
Subprogram is to set-aside Measure “C” funding to finance new
transit technologies that may be developed in the future, such as
Personal Rapid Transit (PRT) or similar systems.”  This is the
alternative transportation that the 2014 RTP/SCS fails to recognize
as Fresno’s sustainable transportation alternative.  These systems
can provide the “T” for effective sustainable TODs.

Or is ARB satisfied with the FAX 34,000 average daily ridership;
where one might logically assume an additional 10,000 riders on the
proposed 3 BRT lines will give COG the 5% threshold required for
its SCS target number.  So then, is this rebuttal another useless
waste of time and forgotten?