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Dear Chairman Nichols, 

Save Our Forest and Ranchlands (SOFAR) and the Cleveland National
Forest Foundation (CNFF), two organizations dedicated to
progressive land use planning and the protection of vital natural
resources in San Diego County, submit this letter with regards to
target setting for SB 375. 

For the last several years, we have diligently participated in the
San Diego Association of Governments’ (SANDAG) transportation
planning processes in an effort to create sustainable regional
transportation and land use for the San Diego region.  SANDAG’s
previous regional transportation plan, (the 2030 RTP), was a
failure on many levels. SOFAR, along with the Attorney General of
California, criticized SANDAG for that Plan’s continued emphasis on
funding highway capacity at the expense of transit service. Not
surprisingly, the environmental impact report (EIR) for the 2030
RTP determined that, if implemented, the Plan would have
significant unavoidable and unmitigable impacts in almost every
environmental category: 

“Significant unavoidable and unmitigable impacts would occur to
land use, visual resources, energy, and biological resources and
there would be cumulatively significant impacts to land use, visual
resources, air quality, noise, energy, global climate change,
geology/paleontology, water resources, and biological resources,
cultural resources, hazards and hazardous materials.”  Source: 
SANDAG Statement of Overriding Considerations for the 2030 RTP. 

In 2007, we were party to a settlement agreement with SANDAG
regarding the 2030 RTP.  This Agreement requires that SANDAG
prepare and include in the 2050 RTP environmental impact report an
Urban Area Transit Strategy.   The purpose of the Urban Area
Transit Study is to assess opportunities for making transit
time-competitive with the automobile, evaluate parking management
strategies that promote transit usage, develop transit mode share
goals, and to identify funding strategies for capital and
operations for new services.  

SANDAG is currently in the process of developing the 2050 RTP. 
Notwithstanding the requirement to seriously study the Urban Area
Transit Strategy and to include a Sustainable Communities Strategy
(SCS) in compliance with SB 375, SANDAG appears intent on
continuing its business as usual approach to accommodating and
encouraging the private automobile. SANDAG is not planning for
substantial change with the 2050 RTP; instead, the SANDAG Board of
Directors recently voted to use full build-out of the 2030 RTP as a
starting point for the new plan.  As a result, according to
planning experts, in the near future SANDAG will be spending
approximately 278% more money on road expansion than on transit
expansion.  Indeed, under the 2030 RTP, SANDAG proposed 20-40% more
roadway and freeway expansion than that expected to be built in Los
Angeles, San Francisco and Sacramento. 

In a time when nearly every urbanized region appears to be
promoting and planning transit-oriented development, SANDAG’s
antiquated approach to transportation planning is extraordinarily
alarming.  At the same time, SANDAG should be the leader inasmuch
as it is the first Metropolitan Planning Organization (“MPO”) to
develop a Sustainable Communities Plan pursuant to SB 375.  Yet
SANDAG is leading us down an entirely unsustainable path while its
preliminary modeling paints a deceptively rosy picture.  SANDAG’s
preliminary modeling data shows that the region could achieve
relatively high GHG reduction targets when compared to California’s
other large MPOs.  Yet something is very wrong with this picture: 
how would the 2050 RTP result in substantially reduced GHG
emissions when it uses the highway-oriented 2030 RTP as its
foundation?  It seems the answer is that SANDAG is managing freeway
capacity to achieve emissions reductions instead of making any
substantial changes to the transportation system such as
prioritizing and funding major transit initiatives such as the
Urban Area Transit Strategy. The tragedy looming over this process
is that SANDAG will potentially get a free pass on a documented
unsustainable transportation plan, while using emissions reductions
to claim sustainability. 

In San Diego, the problem with focusing on GHG emission reductions
is that that we are treating a symptom of unsustainability, rather
than addressing the cause. The environmental analysis of the 2030
RTP suggests that the fundamental cause of climate change and many
other regional issues is the region’s transportation system. 

In sum, we are extremely concerned that the San Diego region will
not make the substantial changes to our transportation
infrastructure – prioritizing transit and deemphasizing freeway and
roadway projects – that are necessary to actually meet the
challenges of SB 375 and improve the region’s quality of life. 
Unless agencies such as CARB apply pressure to MPOs to adhere to
the spirit and intent of SB375, the 2050 RTP will not result in a
sustainable region.  

For further information, please refer to our website: 
www.transitsandiego.org

In addition, you may view comment letters that we have submitted
to SANDAG, and an opinion piece that was published in San Diego on
this subject here:  
http://www.transitsandiego.org/transitsandiego/pdf/SOFAR_Letter_5.27.10.pdf

http://www.transitsandiego.org/transitsandiego/pdf/SOFARCNFF_7.16.10_Final.pdf

http://www.signonsandiego.com/news/2010/jul/16/long-term-transportation-plan-deeply-misguided/


Thank you for considering these important matters. 

Sincerely, 

Duncan McFetridge, Executive Director

Original File Name:

Date and Time Comment Was Submitted: 2010-07-20 15:37:44