Draft MTP/SCS Comments Received - sacog

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What are you commenting on? 

Metropolitan Transportation Plan/Sustainable Communities Strategy 

Name 

John Andoh 

Email 

jandoh@ci.rio-vista.ca.us 

Do you want a written response? 

Yes 

Address 

Comments on the MTP/SCS 

Attached are my comments on chapter 5C regarding transit. The City of Isleton has a contract with the City of Rio 

Vista for transit services within their community. I would request that the information on page 5C-2 include this 

notion. 

Does the tables and figures in Chapter 5C regarding bus ridership also include Delta Breeze ridership within 

Isleton? If not, can it be included. We have this data available. 

Upload Your Documents 

Rio-Vista-comments-to-MTP.pdf 

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eircomments sacog - Davis 5th Street between A and L Streets 

From: Jim Skeen 

To: 

Date: 12/2/2011 3:21 PM 

Subject: Davis 5th Street between A and L Streets 

I may have missed something, but it appears that there is only one project that proposes to reduce the number of 

lanes for vehicles and it is the one described in the subject line. 

It should be prioritized last. It seems motivated by politics, not rational planning. 

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eircomments sacog - Comment on the Draft MTP/SCS and EIR from 

From: MTP Comments 

To: 

Date: 12/2/2011 5:04 PM 

Subject: Comment on the Draft MTP/SCS and EIR from 



Name 

Lynn Merrick 

Email 

lynn@rocklin.com 


Yes 

Address 


At the session I attended, we all made clear that we want light rail extended to western Placer County. The plan 

does not make appropriate provisions to meet this need. 

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file://C:\Documents and Settings\CHoltzen\Local Settings\Temp\XPGrpWise... 

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1/4/2012 



To: 

Date: 12/5/2011 6:42 PM 



• Metropolitan Transportation Plan/Sustainable Communities Strategy 

Name 

Email 

Brigitte Driller 

bkdriller@ucdavis.edu 


No 


To be frank, the MTP/SCS Draft totally bummed me out. Beneath glossy discussions of sustainability, equity, and 

multi-modality, this draft appeared to promote a clear and disturbing goal: Business As Usual. 

First, I cannot understand why SACOG wants to invest so much money in new and widened roads. I bet you are 

thinking to yourself, 7 billion is really not that much to spend on transportation infrastructure. Let me rephrase my 

question: Why do you want to invest ANY money in new roadway infrastructure? The roadway network is already 

sufficiently built out (seriously, it is!). If congestion is the justification I may just roll over and die. More roads/lanes 

will not alleviate congestion in the long term. But you probably already know this, which leads me to my next point. 

I find your goal of reducing congestion problematic. The population growth in this region in the next 25-ish years will 

be immense. With this increase in population, how could congestion not increase? Regardless of whatever your 

model is telling you, you need to accept that congestion is going to increase, and I for one am looking forward to it. 

Without this increase in congestion, why would anyone choose to switch to an alternative mode? 

Most of all, I am severely disappointed in the targets set for nonmotorized transportation. You predict a mode share 

increase of less than 1% for bicycles? Really? I mean, really? If you invested zero dollars in bicycle infrastructure, 

bike mode share would still increase by more than 1%. Why? Because people are poor. They are getting poorer by 

the minute and they are going to bicycle whether you want them to or not. 

In conclusion, I hope SACOG will give some serious rethinking to this document. I beg you to be visionary! Set the 

bar high! Thanks for listening, and I look forward to a much improved final product. 

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To: 

Date: 12/6/2011 8:00 AM 




Environmental Impact Report 

Name 

Kerry Wicker 

Email 

osugmukaw@gmail.com 


Yes 

Address 


Please include in both documents an immediate plan to add transit in Yolo County that connects Route 215 in 

Madison and/or Esparto, with Winters and Vacaville (to hook up to Solano transit). Service to/from Winters/Esparto 

could start for just Friday and Saturday nights to take advantage of entertainment in Winters that might include an 

adult beverage. Avoids DUI. 

Also, please fill the service gaps of YoloBus #215 to allow workers to fully commute from Western Yolo County. As 

is, it is not possible to stay at work a full day b/c of the 4+ hour gap in service. 

Please please please put in a bicycle lane (better yet, path) right away along Hwy 16 from Esparto to Woodland. 

Also, continuing the bike lane up the Canyon from Esparto is hugely beneficial as well. I usually ride on any 

roadway, but there are too many drunks/irresponsible drivers to brave the highway. The CalTrans Hwy 16 project is 

still in litigation, but whatever comes out should be the bike lane/trail. 

All these actions will reduce carbon emissions, improve public health, accessibility, water and other air quality. 

Let me know when you plan to add these services/infrastructure. 

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Roseville Public Hearing Comments from December 6, 2011 

Anonymous Maintenance and rehabilitation funds should apply to all modes of transportation, including pedestrian infrastructure. 

David Allen The plan should have accountability to hold our region to the performance goals and metrics we set in the plan. 

Rebecca McIntyre Transit operations should be coordinated so that transitioning among systems is a smoother process. 

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Woodland Public Hearing Comments from December 8, 2011 

Anonymous I do not think a Sac. River crossing at Broadway would have a net negative impact to Southside Park in that growth in commute traffic from W. 

Sac. To Downtown Sac would begin to come through Southside Park. 

• In a spread, longer peak period with No Broadway Bridge 

Kendra Bridges 

• In a short ≤ 1 hour peak period with a Broadway Bridge 

I believe the residents of West Sacramento and Sacramento would benefit from an additional multi‐modal (auto/pedestrian/bicycle) river 

crossing South of Highway 50 in the Broadway to Sutterville area of Sacramento. This would help on both sides of the river by often avoiding the 

Downtown Sacramento area. 

The plan should look at how infill development will affect housing prices and displacement. 

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1/4/2012 



To: 

Date: 12/9/2011 7:14 PM 




Name 

Email 

Kevin Mackey 

kevin.mackey87@gmail.com 


No 


I think the ideas and goals of the MTP are excellent. As an econ major, I would like to see more financial 

information or data on how the project will be sustained and possible scenarios if budget issues continue/worsen. I 

would like to be included on a mail list for future meetings/presentations to better understand the MTP, current 

progress, and how it is adapting to current successes and setbacks. 

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Folsom Public Hearing Comments from December 14, 2011 

Lindell Price 

All weather, predawn, and dusk bicycle and pedestrian routes are crucial to achieving the mode shifts forecasted in the MTP. Bicycle and 

pedestrian routes are typically affected more severely by weather than vehicular routes, making bicycle and pedestrian travel less reliable than 

other modes, which disproportionately affects persons who cannot afford vehicular travel (EJ issue). SACOG's future funding rounds should 

include criteria that take into account the appropriateness of bicycle and pedestrian facilities for all weather, year round travel. 

Stanley Price 

The delay caused by roadway incidents should be considered in congestion computations in the MTP. Understanding collision patterns related to 

road design, intersections, speed, and connectivity is crucial to reducing collisions and the resulting impact on circulation. 

The MTP should analyze the economic impact of health co‐benefits. 

MTP modeling should include collision projections based on past data. 

The EIR should address public health issues related to bicycle and pedestrian travel, including safety concerns and the economic and health 

benefits realized from incorporating active transportation into everyday life. 

The definition of "high quality transit" is restrictive. Commuter service, which typically does not run every 15 minutes, is productive and serves 

an important role. 

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1/4/2012 



To: 

Date: 12/19/2011 8:56 PM 




Name 

Email 

Julie Nguyen 

julnguyen05@yahoo.com 


No 


I'm glad that you guys are trying to improve our community. It's nice to know the little things can make a big 

difference. 

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1/4/2012 



To: 

Date: 12/23/2011 11:08 AM 




Name 

Email 

ray tretheway 

ray@sactree.com 


Yes 

Address 

sacaramento tree foundation 

191 Lathrop Way suite D 

sacramento, California 95815 

United States 

Map It 


I believe SACOG should rethink and retool its MTP/SCS to respond to the emerging set of research and studies on 

how urban forests contribute to the vibrancy of the Sacramento region. There is growing understanding that forests 

in urban settings make positive and measureable contributions to air quality, public health and well-being, 

stormwater quality and runoff reduction, greenhouse gas reductions, urban heat island mitigation, energy 

conservation and enhance the mobility choices of pedestrians and bicyclists. 

Without a comprehenisve urban forest element in the MTP/SCS, these critical benefits will be more difficult to attain 

as the Blueprint urban areas grow in size and density. 

There are important parallels between the changing conceptualiztion of urban forests with the one taking place in 

regard to rural-urban connections. In both instances, priorities are beginning to rest with the economic vitality, 

environmental sustainability and human health and well-being of future growth patterns. 

The recognition of a more important ecological and social role for urban forests leads directly to the realization that 

policies and programs designed to maintain and enhance urban forests in the Sacramento region must expand in 

purpose and scope. There is a regional need for SACOG 's Sustainable Communities Strategy to take the lead in 

capturing this enhanced vision of urban forests; communicating it effectively to the general public and political 

leadership; and encouraging its member cities and counties to develop more functionally sophisticated programs. 

Given SACOG's proven work on minimizing negative transportation impacts on our regions' environmental health 

and community well-being, increasing the region's tree canopy as part of a larger green infrastructure network 

provides a variety of benefits to the region's mobility, environment and people. 

Region-wide the lack of tree canopy in urban and suburban settings adversely affects the health and well being of 

its residents, contributes to higher summer ambient air temperatures and to incidences of air pollution. From 

unshaded parking lots, streets and highways, sidewalks and pathways, enlarging the region's tree canopy should 

be a goal of the MTP/SCS. 

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1/4/2012 

The Sacramento Tree Foundation has enlisted the support of elected officials, and their respective 22 cities and 6 

counties, for the regional Greenprint initiative to optimize the benefits of trees throughout the region; create 

sustainable urban forests; and build community-wide appreciation for our urban forests. 

The multiple benefits of trees can be part of the solution to some of the more intractable issues facing our region 

today: 

- healthy tree canopy above our streets, sideways and bicycle paths offer an open invitation for exercise and play: 

exercise is key to combating childhood obesity. 

- expanding the region's tree canopy to 30% and greater will filter and clean the air we breathe by removing millions 

of pounds of air pollutants annually; reduce ground-level ozone up to 7%; decrease health risks during extended 

heat waves; and mitigate the negative effects of urban heat islands. 

- healthy tree canopy extends the lifespan of asphalt streets by up to 30%. 

- shaded parking spaces reduce evaporative emissions from parked cars during summer months up to 20%. 

As stated in the MTP/SCS our region is at a crossroads. We will soon begin to grow rapidly following the Blueprint 

initiative. By incorporating a comprehensive transportation approach to rebuilding and expanding our region's urban 

forests in the MTP/SCS, SACOG can reap the benefits, that far exceed the costs, in making our region's 

communities healthy and sustainable. 

We believe special attention in the MTP/SCS should be directed to the role that healthy tree canopy and civic 

engagement can play in regaining the environmental quality and health of neglected neighborhoods. Many 

neighborhoods throughout the Blueprint region are underserved and economically challenged. People living in 

these neighborhoods often have fewer opportunities or resources to secure safe, affordable housing; transit 

options; nearby employment; safe places to be active including parks and greenspaces; a healthy tree canopy; and 

most effected by the impacts of air pollution. Dirty air incurs costs from human health to environmental degradation. 

Neighborhoods that are deprived of trees are deprived of everything a neighborhood should be: safe, welcoming 

and full of vitality. Expanding and caring for a healthy tree canopy are practical ways to engage people of all ages, 

and all neighborhoods, to revitalize their communities. 

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December 23, 2011 

Board of Directors 

Sacramento Area Council of Governments 

1415 L Street Suite 300 

Sacramento, CA 95814 

Re: Metropolitan Transportation Plan/Sustainable Communities Strategy 2035 

Dear SACOG Board of Directors: 

We are pleased to offer our comments on the Draft Metropolitan Transportation 

Plan/Sustainable Communities Strategy 2035, and thank you for the opportunity to continue 

our involvement in planning for transportation and land use needs in the Sacramento region. 

The MTP/SCS moves the region in the right direction by focusing on meeting the needs of our 

growing population through compact growth, with a variety of transportation mode options, 

and with the needs of all communities in mind. 

To ensure that all residents in the region have the opportunity to thrive, the transportation 

network must be planned for all users. It must include reliable, affordable access to multiple 

modes, including transit, walking, and bicycling. It must serve all of our neighborhoods, linking 

jobs, housing options at all income levels, services, educational institutions and opportunities 

for recreation. 

The Coalition on Regional Equity (CORE) advocates for regional development that is equitable, 

sustainable and promotes public health for lower income people and communities of color in 

the greater Sacramento Region. The Coalition includes affordable housing advocates and 

developers, environmentalists, transportation advocates, homeless and anti-poverty advocates, 

social service providers, civil rights leaders and health groups. We have a vision for the 

Sacramento region that includes opportunities for all residents to live in communities rich with 

jobs, connected by transit as well as bicycle and pedestrian networks, accessible to services and 

recreation, and without threat that public investment will drive housing costs up and displace 

residents from their homes. 

The Draft MTP/SCS makes strides toward achieving this vision of a sustainable, equitable 

region. However, we respectfully recommend that SACOG strengthen and enhance the equity 

provisions of the MTP/SCS that address the transportation and planning needs of low-income 

communities, communities of color, other vulnerable populations, as well as preserve our 

natural habitat. We believe SACOG should do so for two reasons: first, it will bring the 

nd federal legal and regulatory 

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Coalition on Regional Equity MTP/SCS Comment Letter, Page 2 

obligations; second, more equitable transportation and land use planning will facilitate more 

robust and sustainable economic growth in the region. 1 recommendations to achieve 

this are as follows: 

1. Promote Affordable Housing in All Communities 

Promote affordable housing in all parts of the region. 

To this end, add a Strategy to Policy 4 to prevent gentrification and displacement of 

existing residents from transit- 

support and incentivize best practices to prevent gentrification resulting in 

displacement of existing resident, including practices that stabilize existing renters and 

lower and moderate income homeowners; create new homeownership opportunities 

for low to moderate income households; facilitate comprehensive community benefits 

packages that include good jobs and land use provisions; facilitate income and asset 

creation in affected areas; and support neighborhood-specific measures to fund the 

2 

2. Create a Jobs-Housing Fit Analysis Tool 

The importance of this tool, as specified in Strategy 4.3, cannot be over-emphasized. 

Use this new modeling tool to help create opportunities for people at all income levels 

to live where they work. 

3. Meet the Needs of Transit Dependent Populations 

Add a Strategy (or multiple Strategies) to Policy 23 that specifically addresses the needs 

of the following transit-dependent populations: low-income people and youth under 

age 18. The Strategy should include improving transit services and options for lowincome 

people and youth by employing the same mechanisms set forth in Strategy 

23.1. 

o We suggest adding the following language 

discounted monthly passes, and plan bus and other transit routes compatible 

 

o Specifically to address the needs of youth under 18, we suggest the following 

 

transit providers to ensure that district and or public bus routes enable all K-12 

 

 

low income and minority communities whose needs and concerns otherwise might be 

 

1 Notable references on the linkages between equity and economic prosperity include Just Growth: Inclusion and 

by Chris Benner and Manuel Pastor, and 

is the Superior Growth Model by PolicyLink. 

2 We refer SACOG to the tool for measurement and interventio 

Community Innovation described in Mapping Susceptibility to Gentrification, available here: 

http://communityinnovation.berkeley.edu/publications.html for further development of this strategy. 

2 

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Add a Strategy to Policy 24 that encourages transit agencies to consider and plan for 

the needs of low-income and other vulnerable populations in rural parts of the region, 

perhaps through stakeholder meetings, a speaker series or series of webinars. 

4. Promote Transportation Equity for All, Including Transit Dependent and Choice Riders 

Transit service networks should connect communities in the region to opportunities to 

live, work, recreate, access services, and worship without the need for a private 

automobile. 

Street networks should facilitate travel by all modes, necessitating prioritizing 

investment in pedestrian and bicycle infrastructure throughout communities and near 

transit stops. 

Develop specific strategies to ensure appropriate phasing of transit and active 

transportation improvements with residential development. While SB375 only requires 

quality transit to be planned within the time horizon of the MTP/SCS for residential 

projects to meet the criteria for CEQA benefits, development built without transit 

inevitably becomes car-oriented, and it is difficult to reverse this behavior. 

5. Prioritize Equity-Promoting Investments First 

 

constraints when financially feasible, with attention to restore and strengthen service to 

low-income communities and other areas where transit- 

Add to Policy 28 a Strategy to fund equity-promoting investments first. We suggest the 

 

projects that enhance equity in the region, laying the foundation for the remainder of 

 

6. Create an Equity Scenario in the Next MTP/SCS, or Integrate Equity in Every Scenario 

Strengthen the equity analysis for future plans by including an analysis to measure the 

impact of the plan on low-income communities, communities of color, and other 

vulnerable populations (Environmental Justice Communities) that live outside of the 

 

help determine true impact on these populations. 

Apply the jobs-housing fit tool to the analysis for the next MTP/SCS. 

Track the equity performance of this plan to provide the analytical foundation for future 

plans. 

Hold a series of conversations with equity partners to identify key planks of an equity 

scenario and how they can best be integrated into the next MTP/SCS scenario(s). 

Create a defined public process for CEQA streamlining determinations. SB 375 gives the 

local jurisdiction the discretion for making the determination for what level of CEQA 

exemptions a project is qualified for within the MTP/SCS, but there is no mandate for a 

public hearing or review process for this determination. A public process must be 

established to ensure that equity, health, and environmental interests are adequately 

addressed. 

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7. Improve Ecological Impact Analysis and Include Strategic Planning for Habitat and Open 

Space Conservation 

The interests of equity, public health and compact transit-oriented development are 

best served by complementary planning for natural resource and open-space 

conservation. While we applaud the work of the Rural Urban Connections Strategy to 

analyze regional agricultural viability, considerations of habitat viability and 

opportunities for outdoor recreation and education could be improved to better serve 

the needs of the region. 

Coordinated conservation strategies and tools must be developed to aide adherence to 

the MTP/SCS urban footprint and provide ample opportunity for open space 

preservation. 

We believe that these recommendations, if included in the MTP/SCS, will help the Sacramento 

region address the needs of all residents in a meaningful way. Strengthening the analysis of 

how the MTP/SCS will impact low-income communities, communities of color, other vulnerable 

populations, and natural habitat, as well as creating specific strategies to address the needs of 

these populations as the MTP/SCS is implemented, will create a more equitable, sustainable, 

and prosperous region. 

 

equitable future, and urge the SACOG Board of Directors to support the strengthening of equity 

measures and strategies in the MTP/SCS. 

The Coalition on Regional Equity- and its member organizations throughout the region- are 

committed to supporting the ongoing planning and implementation of the MTP/SCS through 

th 

constituents on ensuring that equity and opportunity for all in the Sacramento region become a 

reality. 

Thank you for considering our comments and recommendations. 

Sincerely, 


Land Use Policy Director 

Sacramento Housing Alliance 

Sarah Mercer 

Director of Government Affairs 

California Pan-Ethnic Health Network 

Efren M. Guttierrez 

Executive Director 

Chicano Consortium of Sacramento 

Jonathan Ellison 

Board President 

Environmental Council of Sacramento 

Mona Tawatao 

Regional Counsel 

Legal Services of Northern California 

Linda Deavens 

Chief Executive Officer 

Paratransit, Inc. 

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Frances Gracechild 


Resources for Independent Living 

Barbara Stanton 

Founder/Director 

RiderShip for the Masses 

Stanley Keasling 


Rural Community Assistance Corporation 

Rachel Iskow 


Sacramento Mutual Housing Association 

Rafael Aguilera 

Director 

Solistic Institute 

Alvin D. Vaughn, Jr. 

Director, Advocacy & Communications 

Ubuntu Green 

Teri Duarte 


WALKSacramento 

Mindy Romero 

Board President 

Yolo Mutual Housing Association 

Eric Vega 

Board Chair 

Sol Collective 

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Administration 

COUNTY OF PLACER 

Community Development Resource Agency 

ENGINEERING & 

SURVEYING 

MEMORANDUM 

DATE: JANUARY 4, 2012 

TO: 

FROM: 

MAYWAN KRACH, ECS 

REBECCA TABER 

SUBJECT: METROPOLITAN TRANSPORTATION PLAN / SUSTAINABLE COMMUNITY 

STRATEGIES FOR 2035 UPDATE, POLICY DOCUMENT AND DRAFT EIR 

The Engineering and Surveying Department and the Department of Public Works Transportation 

Division have reviewed the Draft Metropolitan Transportation Plan (MTP) / Sustainable 

Community Strategies (SCS) for 2035 and associated Draft EIR. The project applicant is the 

Sacramento Area Council of Governments (SACOG). 

Thank you for the opportunity to review and comment on this policy document and Draft EIR. 

We would like to provide the following comment for your consideration: 

1. Since the MTP is a long-range planning document for the SACOG region, the 

following completed projects should be omitted from Appendix A (list of projects): 

a. Douglas Boulevard Pedestrian Facilities and Landscaping. 

b. Foresthill Passing Lane Modification Project. 

c. Sheridan SRTS Project. 

2. Draft Metropolitan Transportation Plan Project List: It appears that the City of 

Lincoln Department of Public Works item on page 27 of 142 (dated October 27, 

2011) in Appendix A to widen Fiddyment Road to 4 lanes from East Catlett to 

Nicolaus Road may be in error. Fiddyment Road ends at Moore Road at its northern 

limit, and this portion of Fiddyment is within the Placer County Department of Public 

Works jurisdiction. 

3. Draft Metropolitan Transportation Plan Project List: There is an error on page 38 of 

142 in Appendix A – instead of Bell Ave., it should be Bell Road. 

cc: 

Phil Vassion, DPW Transportation 

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Sacramento Public Hearing Comments from January 4, 2012 

Amy Williams, Legal 

Services of Northern 

California 

Earl Withy Combe 

The MTP is a good plan, but the timeline is too spread out. We need improved transit service now. The California Endowment's initiative 

"Building Healthy Communities" will be completed in eight years, and SACOG should attempt to complement that initiative with increased 

transit service that will address equity issues and benefit low‐income communities. 

The MTP/SCS performance measures should include more measures related to public health and healthy communities. 

Accountability Gap: SACOG does not have the land use authority to guarantee achievement of the SCS goals, only the ability to model that 

attainment is possible. SACOG should begin a program of incentives and disincentives to encourage and incentivize local jurisdictions to adopt 

and embrace the Blueprint vision, including the siting of high‐density developments near transit. SACOG should institute a bonus point system 

in the programs, planning, and enhancement funding to give bonus point in communities where the local jurisdictions have clearly 

demonstrated that they support the Blueprint goals and they enforce those in the approval of new land use projects. Over time, SACOG should 

add a similar bonus system to other pots of funding. SACOG needs more levers to achieve the goals of the SCS. The plan is somewhat wishful 

thinking without such controls. 

Michael Monasky 

Mike Barnbaum 

SACOG should consider something akin to the 30/10 initiative that was approved in L.A. County. This initiative establishes a sales tax increase 

that will be used to bond new transit projects over a 10‐year period that would otherwise take 30 years. The SACOG region needs another 

funding option for returning transit service levels and expanding them. The region should consider an initiative like the one in L.A. 

Anything we can do to bring down GHG emissions is desirable. 

Disappointed with the public comment process. Usually, a public hearing is started and ended officially and the members who comprise the 

Board are present, but not a single Board member is present to hear comments. 

Concerned about the air quality chapter, including diesel contaminants. 

SACOG should include public health officials in public outreach. 

The MTP puts too much investment in roadway projects. Greater investment in transit projects would yield better returns for reductions in 

vehicle miles traveled and better air quality. Vulnerable populations carry more of this burden in terms of adverse health outcomes. 

GHG emissions are still growing. Roadway maintenance and rehabilitation projects (which account for $7 billion of total MTP expenditures) 

should not be included as non‐exempt projects in air quality conformity determinations because the current infrastructure is already causing 

too much GHG emissions. 

The MTP project list needs to include something about the San Joaquin corridor that runs from Oakland/Sacramento to Bakersfield. 

During the unmet transit needs process, transit needs that are found to be reasonable to meet should be specially recognized or "fast tracked" 

in the MTP/SCS to speed implementation of these services. 

The region should consider something like the 30/10 initiative approved in L.A. County. SACOG should think outside the box to help move the 

region forward.

Sacramento Public Hearing Comments from January 4, 2012 

Mona Tawatao, 

Legal Services of 

Northern California 

Ruby Avila, Youth 

Advocate Network 

for Sustainable 

Communities 

Teri Duarte, 


The draft plan moves the region in the right direction, especially considering a more challenging fiscal environment. The commitment to 

developing affordable housing and addressing equity issues is appreciated. However, the plan could and should do more to address equity issues 

throughout the region. SACOG has legal and regulatory obligations in this regard, particularly with concern for whether or not the plan promotes 

access to opportunity, lessens or exacerbates racial segregation, and avoids or mitigates potential impacts, especially to residents in 

environmental justice communities. Promoting equity in the plan also enhances economic growth. Minority populations will continue to grow 

rapidly. People and communities of color, as well as those living in low‐income areas, typically bear the burden of failed systems and 

infrastructure. We can't thrive as a region if we don't act aggressively to close these gaps and disparities. We need to treat the upcoming 

generation as an asset because the region's economic health depends on it. 

1) Jobs/housing fit should ensure that people live near where they work. 

2) Analysis of displacement of residents and potential effects of such displacement in terms of transit, service, and job access. 

3) Analysis of whether or not any part of the plan has disproportionate impacts on communities of color. 

4) Frontload transit investments. Improving transit benefits groups that are already far behind in terms of access and opportunity, and delaying 

transit investments may be too little too late to benefit these groups. 

Public transit improvements, complete streets, and more frequent transit are very important. SACOG should remember to include youth in their 

outreach efforts. 

The MTP/SCS needs a timetable to achieve complete streets. The region doesn't have a complete network of bicycle and pedestrian 

infrastructure. 

Each transportation project should go through a review to see how closely it achieves health, environmental, and equity goals of the region. 

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909 12 th Street 


Phone: (916) 444-5900 

Fax: (916) 444-6661 

staff@sacbreathe.org 

www.sacbreathe.org 

www.SceneSmoking.org 

www.sacSTAND.org 


2011 - 2012 

Sue Schooley, 

President 

Ralph Propper, 

President-Elect 

Jarvio Grevious, 

Treasurer 

Diana Proctor, 

Immediate Past 

President 

Roni Abacherli 

Paul Adams 

Peter Adams 

Jennifer Copeland 

Patricia Dean 

Jim Edelen 

Gordon Garcia, MD 

Doug Grandt 

Kristin Gray 

Helen Hernandez 

Ken Hough 

Michelle Kessel-Harbart 

Diana Parker 

Ashley Rice 

Rita Ruecker 

Arif Seyal, MD 

Jean Shaw 

Sue Teranishi 

Earl Withycombe 

Kori Titus, CEO 

Breathe California of 

Sacramento-Emigrant Trails is 

dedicated to healthy air and 

preventing lung and other airpollution 

related diseases by 

partnering with youth, advocating 

public policy, supporting air 

pollution research, and educating 

the public. 

January 9, 2012 

Chair Peter Hill 





Re: Draft Metropolitan Transportation Plan/Sustainable Communities Strategy 2035 (MTP/SCS 

2035) 

Dear Mr. Hill and SACOG Board Members, 

Breathe California of Sacramento‐Emigrant Trails (BCSET) has been active in the region since 

1917, advocating for clean air, healthy lungs, and a tobacco free future. We have developed a 

Clean Air Agenda which includes various strategies and recommendations for local jurisdictions, 

businesses, organizations and individuals that can be achieved through efficient energy and land 

use. Our mission is to ensure air quality and public health concerns are being addressed through 

minimizing mobile source pollution and promoting alternative forms of transportation such as 

walking, biking, and using public transportation. 

We commend SACOG’s enormous effort to put forth a Sustainable Communities Strategy; we 

encourage efforts to meet air quality standards and continued investment in alternative forms of 

transportation. Although we are pleased to see a 7 % increase in funding per capita for bicycle 

and pedestrian use in the 2011 MTP Draft Plan for 2035; we would like to see increased funding 

for this effort and a developed timeline to achieve a complete system of active transportation. 

BCSET is confident that increasing this investment will help the overall well being of our region by 

reducing vehicle miles traveled and encouraging residents to use alternative forms of 

transportation. 

As stated in the corresponding DEIR, our region will initiate efforts to develop an emissions 

budget for PM 2.5. In accordance to this regulation, we encourage an increase in the size of 

buffer zones from 500 feet to 1,000 feet in high‐volume roadways and land use for residents. This 

will benefit public health by minimizing the impacts to residents living near roadways and high 

traffic areas. In addition, these mitigation practices will assist our region with meeting air quality 

standards as set forth by SB 375, California’s sustainable communities and Climate Protection Act. 

We are grateful for SACOG’s staff effort and leadership to create a thorough and prosperous plan 

for 2035, and look forward to the continued development of this blueprint to better benefit air 

quality and public health in our region. As always, BCSET looks forward to continued partnership 

with SACOG staff and are thankful for your time. 

Cordially, 

Kori Titus 

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file://C:\Documents and Settings\CHoltzen\Local Settings\Temp\XPGrpWis... 

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1/10/2012 

Clint Holtzen - Comment on the Draft MTP/SCS and EIR from 


To: 

Date: 1/9/2012 4:20 PM 



Name 

Email 


• Environmental Impact Report 

Christal Waters 

chrystal2waters@yahoo.com 


Yes 

Address 

Davis Bicycles!, c/o Christal Waters 

809 Pine Lane 

Davis, California 95616 

United States 

Map It 


The following comments are submitted on behalf of Davis Bicycles! 

Davis Bicycles! appreciates the opportunity to comment on the Sacramento 2035 Metropolitan Transportation 

Plan/Sustainable Communities Strategy. Our comments are both on the 2035 MTP and the EIR. The 2035 MTP is 

complex and encourages bicycling and walking as vital modes of transportation for achieving environmentally 

sustainable regional growth. In our community, we see more people bicycling than we used to. Our downtown is 

filled with bicyclists competing for bike parking spaces. We see parents out bicycling with their children, teaching 

them safe bicycling as they ride. We are starting to see a turnaround in the historic decline of students bicycling and 

walking to school and more people are bicycling, walking and taking public transit to get to work. The 2035 

MTP/SCS could take advantage of this uptick with a jumpstart to funding more active transportation projects in the 

near future. A near-term substantial dedication to funding bicycle and pedestrian projects would greatly increase 

bicycle/pedestrian modeshare far more than a slow steady increase in those active transportation expenditures , or 

worse, delaying those expenditures and trying to play catch-up closer to 2035. Furthermore, expenditures on active 

transportation are generally lower in cost than expenditures increasing freeway and arterial capacity and can be 

undertaken when the economy is slow and budgets are tight. 

2035 MTP/SCS Questions and Comments: 

Table 4.1 on page 4-2, Summary of MTP/SCS Invdstments 

What capital inflation rate is used for these investment categories and is the inflation rate the same over all 

categories from current year to year of expenditure? If the increase in cost is measured as a percentage of current 

costs, the costs for the bike and pedestrian category increases at 43% - the largest cost increase. The other 

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1/10/2012 

categories are 40% increase for Transit and for Programs, Planning, Enhancements and 42% increase for Road 

and Capital Improvement Projects, and Maintenance and Rehabilitation. While it is true that bicycle and pedestrian 

improvements are in Maintenance and Rehabilitation Projects, the dedicated-purpose bike and pedestrian 

improvements, those usually associated with higher miles or higher costs, have a higher inflation rate. If the 

inflation rate is the same for all categories, is the higher bike/pedestrian project rate due to their implementation at a 

later date than the other categories? If so, then we don’t believe that the Plan takes advantage of the current 

economy to jumpstart an active transportation modeshare that can significantly contribute to improved air quality, 

reduced carbon emissions, and public health. 

Relationship of 2035 MTP Project List and Regional Bicycle Master Plan: 

Where does the plan discuss the relationship between the 2035 MTP Project List and the Regional Bicycle Master 

Plan? We understand that the Regional Bicycle Master Plan and the MTP form the basis for SACOG project 

funding. For Yolo County, the Alternative Transportation Corridor (ATC) appears on the project list, but only through 

right of way acquisition, not through construction, even though the year-end date of this plan is nearly 25 years out. 

(See also comment above about jumpstarting bicycle/pedestrian investment.) However, the Woodland/Davis ATC 

is only one project and there are many projects and programs in the Davis Bicycle Plan, which is part of the 

Regional Bicycle Master Plan. Other projects are being considered for inclusion into our Bicycle Plan. If to be 

eligible for SACOG MTP funding a bicycle project or program need not be directly included in the 2035 MTP Project 

list, that should be so stated, and the Regional Bicycle Plan incorporated by reference into the 2035 MTP. 

2035 MTP Project List for Davis: 

The Fifth Street Road Diet and Multimodal Parking Structure are projects that we are aware of, and we understand 

the issues related to the California Street Bridge Replacement and I-80/Richards Boulevard interchange. However, 

we do not understand why some of the other projects have been listed. For example, we do not know why the 

widenings of Covell Boulevard near Hwy 113 and Mace Boulevard with completion in 2035 are included in the plan, 

with no new development being considered or serious problems occurring along those roads, to our knowledge. 

Environmental Impact Report: 

Neither Alternative 3, nor the rejected Alternatives 4 and 5 discuss the bicycle/pedestrian community’s suggestion 

last year to accelerate funding of bicycle and pedestrian projects and programs. Alternatives 4 and 5 are rejected 

because of restrictions to funding sources. What would need to be changed in those funding sources to allow 

bicycle and pedestrian projects to receive a higher earlier priority? 

Alternative 3 seems to have been dismissed because the market, local land use plans and financial incentives do 

not currently support the land use assumptions of Alternative 3 and because under it, congestion would increase. 

Given that markets respond to constraints as well as opportunities, please give some thought to allowing 

congestion to further increase over the short term while completing the investment in complete streets, transit and 

bike/pedestrian infrastructure that could further reduce congestion over the long term. 

Thank you for the opportunity to comment on the 2035 MTP/SCS and its environmental impact report. 

/s/ 

Mont Hubbard, President 

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Sacramento Area Council of Governments January 9, 2012 

SACOG Board of Directors 

SACOG, MTP/SCS 2035 

1415 L Street, Suite 300, 


Re: 

2035) 

Draft Metropolitan Transportation Plan/Sustainable Communities Strategy 2035 (MTP/SCS 

To the SACOG Board of Directors and Executive Director Mike McKeever: 

We commend SACOG on the vision put forth in this MTP/SCS. It is clear that SACOG has incorporated 

principles that public health representatives would agree with, such as prioritizing transit, bicycling, and 

walking over driving, incorporating Safe Routes to Schools and Complete Streets as often as possible, 

preserving agricultural lands and natural resources, preserving affordability of housing while 

aggressively pursuing compact development, assessing air quality dangers of placing housing near 

freeways, ameliorating greenhouse gas emissions, improving accessibility to needed destinations such 

as jobs, schools, and parks, and supporting mitigations of motor vehicle collisions. However, after 

reviewing the plan carefully and based on many of our organizations’ experience reviewing plans from 

other regions and developing health and equity metrics, we believe there are a number of ways that this 

plan could better reflect health and equity priorities. 

As background to this letter, in the spring and summer of 2011, Human Impact Partners (HIP) worked 

with over twenty organizations and agencies statewide to prioritize 13 indicators of health and equity 

that could be incorporated into Sustainable Communities’ Strategies across California. We are attaching 

our report (Appendix C), which supplies the evidence that connects these indicators to health outcomes 

as well as suggested sources for methodology. Due to regional differences, we did not suggest 

benchmarks as we felt that would be more appropriate for organizations and agencies in each region to 

do so. HIP’s report, “Elevating Health and Equity into the Sustainable Communities Strategy Process”, 

provides the basis for suggested measurements contained in this comment letter. 

Throughout our comments, in most cases we recommend supplemental analyses, monitoring, and 

reporting to more completely incorporate health outcomes and health determinants. However, there 

are a few key areas in which we hope to push SACOG to more explicitly and fully incorporate health into 

the MTP/SCS: 

Affordability: 

o Measure Housing + Transportation costs as a percentage of household income 

for all modes of travel; 

o Disaggregate the results by income level, race, EJ vs. non‐EJ community, TPA, 

and community type. 

Respiratory health: 

o For development that is proposed near busy roadways, change the analysis 

buffer from 500 to 1,000 feet to trigger a health analysis & potentially require 

mitigations based on that analysis; 

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SCS Health & Equity Metrics August 2011 

o Measure respiratory disease caused by PM 2.5 and NO (i.e., connect modeled 

emissions with projected health outcomes). 

Physical activity: 

o Measure physical activity and chronic disease co‐benefits of transportation 

priorities, projects, policies, and changes. 

Accessibility & VMT: 

o Measure access to a more comprehensive list of goods and services 

Injuries: 

o Measure injuries per capita in addition to per 100 million VMT 

o Do EJ analysis of injuries by mapping injuries and fatalities and providing totals 

disaggregated by geography, income level, race, and disability. 

Environmental Justice: 

o Do an equity analysis for every indicator 

o Measure proportion of below market rate housing proposed within 1,000 foot 

buffer of busy roadways vs. market rate housing for analysis and mitigation 

purposes. 

Comments below follow the chapters of the MTP/SCS for easier inclusion. When alternate or 

supplemental indicators and measures are suggested, they have been printed in bold for easy 

identification. Important appendices that we have attached to this letter are: 

Appendix A – a table comparing SACOG’s performance measures to health and equity metrics 

for SCSs. This comparison table shows how the Health & Equity metrics (developed by HIP and 

over 20 other health and equity focused organizations and agencies around the state; see 

Appendix C) would fit in with existing performance measures included in the MTP/SCS. We 

recommend that SACOG consider adding some of the Health & Equity metrics to their existing 

list of performance measures. 

Appendix B – detailed comments on SACOG policies and strategies; and 

Appendix C – Human Impact Partners’ report entitled “Elevating health and equity in Sustainable 

Communities Strategies”, which includes our suggested metrics, measurement methodologies, 

health and equity evidence supporting their inclusion, and standards. 

We begin with comments on Appendix G‐6 because the performance measures included in this 

appendix are broad and overarching. 

Appendix G‐6: Performance Measures 

The crux of our comments have to do with outcomes; as a society, we value what we measure. As 

such, we note the absence of some important health outcomes in SACOG’s many excellent 

performance measures upon which you will be monitoring the progress of the MTP/SCS. 

Entrance into the discussion in the SACOG region by some of the groups signed onto this letter 

unfortunately came at a later stage of MTP/SCS development, which precluded early involvement 

into what performance measures should ultimately be used in the MTP/SCS. Others of us were 

involved early on and commented on MTP/SCS development from our perspective, but did not have 

specific public health indicator expertise. The undersigned together support the detailed 

suggestions put forth in this letter and we respectfully submit our comments and request that even 

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if SACOG is unable to include indicators suggested below and in attached Appendices as 

performance measures, that you do include them in a monitoring plan for the MTP/SCS, that in 

TPA planning, you consider these (or very similar) indicators, and when planning begins for the 

next MTP in two years, these health and equity indicators are incorporated. 

The health and equity indicators (Appendix C) include four actual health outcomes indicators: 

fatalities and injuries from collisions, respiratory disease from vehicle emissions, and physical 

activity due to transportation choices. Of these, SACOG is already measuring two: fatalities and 

injuries. Eight of the indicators are transportation and land use health “determinants” – or planning 

elements that we know from scientific literature predict health behaviors. SACOG is already 

measuring some of these indicators (see table in Appendix A). Finally, our last indicator is the 

measurement of all other indicators with regard to equity concerns – depending on the indicators 

SACOG chooses, many of these are already included in SACOG’s social equity analysis. In sum, we 

applaud you on what you are doing for health and equity and request that you do just a little more 

to protect the health of all people in the SACOG region, and in particular those most vulnerable to 

past planning decisions leading to environmental injustices. To see a comparison of SACOG’s 

performance measures and the Health and Equity in SCS Metrics, please see Appendix A. We are 

not suggesting that SACOG abandon the valuable and hard work you have done to prioritize and 

choose your performance measures, merely that you consider the addition of metrics we set forth 

below. 

Appendix A is for comparison purposes only. Our requests and recommendations are included in 

the body of this letter and in Appendix B. 

Chapter 2 – Planning Process 

‐ We commend SACOG for a robust public participation process that has been very participatory 

and thorough. 

Chapter 3 ‐ Land Use Forecast 

Housing 

‐ The increase in housing choices near transit and increased focus on transit is very positive. 

‐ Health evidence supports SACOG’s intention to provide a good housing choice mix in all 

community types, noting the population changes that are going to take place and housing 

choices that will be changing. The goal of providing more attached and small lot single‐family 

units for the changing demographics is beneficial. 

‐ Compact development in areas with rich mixes of commercial, residential, and retail supports 

increased physical activity, more social interaction, and decreased regional VMT and air 

emissions. One concern and recommendation about housing, particularly in the Center and 

Corridor Communities, is that development of housing within a 1,000 foot buffer to busy 

roadways be studied as to the health dangers for local residents and to help suggest 

mitigations to potentially allow such development. 

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‐ Compact development can also heighten risk and perception of crime, so SACOG can guide local 

jurisdictions to coordinate crime prevention efforts in these cases. 

‐ Introducing transit‐oriented development in communities with rich public transit options opens 

a risk for gentrification. The MTP/SCS realizes this and is measuring it in their EJ analysis. 

Another tool for measurement and intervention is the University of California‐ Berkeley’s Center 

for Community Innovation report Mapping Susceptibility to Gentrification: The Early Warning 

Toolkit. Additionally we would suggest monitoring the cost of housing + transportation for all 

incomes and all community types. 

‐ The amount of proposed housing in Developing Communities is concerning in terms of reaching 

the goal of not increasing the urban footprint. While increasing the housing to match the 

current employment centers in Developing Communities is laudable to decrease VMT, please 

develop protocols which prioritize transportation infrastructure for existing urbanization 

before Greenfield expansion. Additionally we suggest that investment is not directed away 

from existing communities to benefit new development. 

Mix of Uses 

‐ SACOG focuses, rightly, on the jobs‐housing fit in their discussion of Mix of Uses. We look 

forward to the work SACOG is doing on better measuring jobs‐housing fit within 4 miles of job 

centers. 

‐ We also suggest that SACOG conduct a mapping analysis to measure the proportion of 

households that can walk or bike (10 minutes) to meet at least 50% of their daily needs. We 

propose that public daily needs be defined as: schools, parks, healthcare institutions and 

transit. We propose that private daily needs be defined as: restaurants, grocery stores, food 

markets and childcare. Public health literature shows that having goods and services within a ½ 

mile increases the likelihood that people will use active transport to get them. 

Chapter 4 – Budget and Investments 

‐ We recommend moving up the timeline for investments in public transit and 

bicycle/pedestrian infrastructure improvements. As written in the MTP/SCS, these are delayed 

until the later years of this plan, and in order to realize the health benefits as early as possible 

from active transport, we believe that these investments should be prioritized. Specifically, we 

recommend assessing the cost and timeline for building out Complete Streets network by 2024, 

prioritizing Complete Streets and provision of transit on deserving arterials. 

‐ Also, with regard to phasing and funding of transit, we suggest that SACOG work with other 

agencies and local jurisdictions to support and hasten transit for high‐density arterial corridors, 

when sufficient density of homes or jobs has been reached; in order to do this jurisdictions 

could defer costly transit capital projects until densities have been reached. Finally, 

prioritization of costs should also defer or cancel road construction projects that could trigger 

growth outside of urban areas. 

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‐ We commend the SACOG for allocating 7.9% of the total budget for bicycle and pedestrian 

investments. This is a greater proportion than many other MPOs in the state. In addition, we 

acknowledge that per capita funding in bicycle and pedestrian investments actually increases by 

7% due to reduction in population growth estimates. 

‐ However, there is still a net decrease of 1% in funding for bicycle and pedestrian investments. 

Bicycle and pedestrian networks in the region remain deficient and incomplete, while vehicle 

roadway networks are extensive and vastly prioritized. Bicycle and pedestrian investments are 

anticipated to reduce greenhouse gas emissions, improve air quality, and improve health by 

encouraging more physical activity. In light of these tremendous benefits, which address 

overall goals of the SCS, SB375 and AB32, we recommend an increase in total funding for 

bicycle and pedestrian investments. As an example, the Los Angeles County Department of 

Public Health analyzed the funding put forth by SCAG for their pedestrian and bicycle 

infrastructure and found that in order to reach their goals they would need to increase the 

bike/ped funding more than six times. 1 

‐ Table 4‐2 displays a list of projects proposed in the SCS, in various categories (such as rail, 

bike/pedestrian, new roads, bridges, etc). We recommend also adding a list of projects and 

services that are being eliminated due to a smaller budget (if any). 

‐ There are two separate categories for vehicle/roadway‐related projects: Maintenance & 

Rehabilitation and Road Capital & Operations. In contrast, there are single categories for Transit 

and Bike/Pedestrian projects. This type of reporting understates the actual proportion of the 

budget going to vehicle roadway projects versus projects related to transit and bike/pedestrian 

projects. We recommend adding an additional table comparing the budget allocation for 

vehicles, transit, and bike/pedestrian projects. 

Chapter 5A – Transportation Trends and Performance 

‐ The evidence‐based analysis of regional factors that affect VMT, biking, walking, and transit use 

is also supported by health literature. SACOG and others use the measure of number of jobs 

within a 30‐minute commute time to establish regional accessibility, and this is shown to 

increase by almost one‐third in the MTP/SCS, which is excellent. We suggest also measuring 

number of jobs within a 30‐minute public transit and bicycle commute and a 15‐minute walk 

commute. In addition, the average commute time to work by Californians is lower than 30 

minutes, and thus we recommend reducing the status quo commute time to reflect true 

conditions as well as the aspiration for reducing rather than increasing commute time. 

‐ Mix of use is also shown to have a large impact on walking and biking. The health‐supporting 

increase in mix of use, particularly in the Developing communities, was good to see. In addition 

to the relative proportions of residential, jobs, retail and other uses as a measure, we suggest 

using the proportion of households that can walk or bike (10 minutes) to meet at least 50% of 

their daily needs. 

1 Berg N. December 23, 2011. $6 Billion for Southern California's $40 Billion Need. The Atlantic. 

http://www.theatlanticcities.com/commute/2011/12/6‐billion‐southern‐californias‐40‐billion‐need/797/ 

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‐ It is excellent to see that street pattern and urban design is being measured at all, and the 

evidence base around using number of intersections to measure this is good. Moving forward, 

for local jurisdictions seeking a more refined measure of walkability and bikeability, we 

suggest that cities and towns use the PEQI and BEQI. 2 3 These tools can help target complete 

streets improvements to the spots most requiring of infrastructure improvements for 

pedestrians and bicycles. 

‐ The improvement in average distance to transit in Center and Corridor communities, and 

overall, is encouraging. This measurement is very helpful to assess likelihood of taking transit 

and of getting more physical activity. We know that investing in public transit is a challenging 

prospect and encourage SACOG to continue your commitment. 

Chapter 5B – Roadway Congestion and Vehicle Miles Traveled 

Vehicle Miles Traveled 

‐ In order to compare this MTP/SCS with the 2002 and 2008 MTPs, SACOG uses the indicators 

VMT and VMT per capita. We recommend also including mileage traveled by other 

transportation modes as indicators (i.e., walking, biking, and transit). These additional modes 

are also important indicators of physical activity, air quality, traffic accidents and injuries, and 

greenhouse gas emissions. 

‐ As alluded to above, physical activity is not considered as an indicator or desired outcome in the 

VMT analysis. We recommend measuring changes in physical activity as an outcome of 

changes in VMT. 4 

‐ The discussion of VMT is based primarily on modeling of commute‐hour trips. We recommend 

also modeling and targeting reductions in non‐commute trips. 

‐ The SCS measures vehicle trips to transit but excludes bicycle and pedestrian trips to transit. We 

recommend including bicycle and pedestrian trips to transit as a metric. 

Roadway Congestion and Delay 

‐ The MTP/SCS philosophy of measuring the amount of under‐utilization or over‐utilization of 

roadways is superior to measuring LOS, and we commend SACOG in adopting this outlook. 

Measuring proper utilization of roadways supports efforts to decrease VMT, and ultimately 

exposure to poor air quality and improvements to increase the attractiveness of active 

transport. Focusing on “right‐sizing” projects and prioritizing inclusion of complete streets 

infrastructure while doing so will do this. 

2 San Francisco Dept. of Public Health Program on Health, Equity, and Sustainability. Bicycle Environmental Quality Index. 

Available at http://www.sfphes.org/HIA_Tools_PEQI.htm 

3 San Francisco Dept. of Public Health Program on Health, Equity, and Sustainability. Bicycle Environmental Quality Index. 

Available at http://www.sfphes.org/HIA_Tools_BEQI.htm 

4 California Dept. of Public Health. Health Co‐Benefits and Transportation‐Related Reductions in Greenhouse Gas Emissions in 

the Bay Area: A Technical Report. Available at 

http://www.cdph.ca.gov/programs/CCDPHP/Documents/ITHIM_Technical_Report11‐21‐11.pdf 

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‐ We also commend SACOG for focusing on congested VMT and how to decrease it over focusing 

on time delay; focusing on time delay creates solutions to decrease time delay (often roadway 

expansion), while focusing on congested VMT creates solutions to decrease congested VMT. 

‐ SACOG states that non‐work travel is 17% of all arrivals during peak time and only 8% during the 

highest peak time hour, which speaks to the focus on measuring commute travel. Evidence 

shows that half of all trips in metropolitan areas are three miles or less and 28% are one mile or 

less; in rural areas 30% of all trips are two miles or less. 5 Yet a majority (65 percent) of one‐mile 

trips in metropolitan areas are still made by automobile. 6 As such, we suggest also measuring 

the proportion of daily trips less than 3 miles and less than 1 mile by mode 

(walking/biking/bus and rail transit/driving). 

Chapter 5C – Transit, Bicycle and Pedestrian 

Transit 

‐ SACOG’s focus on increasing transit to its former levels and expanding it in the detailed ways 

presented shows the commitment they have to not only reduce GHG emissions but also to 

improve efficiency of the entire transportation system (roadways included) and along with that, 

improve health behaviors and reduce harmful exposures. 

‐ The assumption that transit fares will remain steady is understandable from a modeling 

perspective. However, it is unclear if that assumption will hold true. For that reason we 

recommend measuring percent of household income consumed by transportation costs. 

Ideally, we recommend measuring the percent of household income consumed by both 

housing and transportation to get a better sense of the jobs‐housing fit – which it appears that 

SACOG is doing. 

‐ SACOG’s goals for changes to the transit system are laudable, and the quantity and quality 

indicators SACOG is measuring to get there are very instructive. While the map on page 5C‐13 

is very useful, it would be better for monitoring if both the tables and data related to the map 

were available and the maps were created for a finer‐grained look at the state of transit 

currently. We suggest also measuring proportion of households and proportion of jobs within 

1/4 mile of local public transit (including both bus and rail) or 1/2 mile of a regional public 

transit, that has less than 15 minute frequencies. 

‐ SACOG expects that ridership and farebox revenues will increase, which is heartening. However, 

if it does not, there should be an adaptive management process in place for decision‐making so 

that decisions are not made on an ad‐hoc or reactive basis about cutting services or delaying 

transit improvements, but instead making evidence‐based changes that continue to support 

Blueprint and MTP/SCS goals of increased use of public transit. 

5 U.S. Department of Transportation, Bureau of Transportation Statistics. (2002). National Household Travel Survey: Daily Travel 

Quick Facts. 

6 Complete Streets Coalition. Complete streets ease congestion. Available at: http://www.sacog.org/completestreets/toolkit/files/docs/NCSC_CS%20Ease%20Congestion.pdf 

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‐ When measuring transit trips by community type, SACOG has reported out combined 

transit/bike/walk trip‐making. This makes it difficult to distinguish between these modes of 

active transport. We suggest disaggregating it in the report and in monitoring. 

‐ We further suggest measuring daily amount (in minutes) of work‐trip and non‐work trip 

related physical activity, and if possible, chronic disease outcomes due to physical activity. 

Methodology for measuring physical activity exists (see Health and Equity Metrics) and other 

MPOs in California are embracing this measure. Also, modeling chronic disease outcomes from 

physical activity changes due to transportation investments has been done by the California 

Department of Public Health. 7 

‐ SACOG bases some of their predictions of an increase in public transit use on an increase in use 

of transfers, aided in part by streamlining measures such as the policy to implement the Connect 

Card. However, should streamlining measures fail to produce an increase in transfers, SACOG 

should plan for an adaptive decision‐making process that does not automatically decrease the 

importance of public transit support strategies but revise those strategies – informed by data. 

‐ While an increase in farebox revenues would be a boon to funding public transit, we express a 

concern about which populations would be most heavily burdened. Therefore, we again 

recommend as an equity measure that SACOG monitor transportation costs as a percentage of 

household income by all forms of transportation, disaggregating and reporting it out by 

community type as well as by income levels, and monitoring this on a regular basis. 

Assumptions about farebox revenue increases are hopeful but again, adaptive decision‐making 

processes should be put in place in case predictions do not hold true. 

Bicycle and Pedestrian 

‐ We commend SACOG for the discussion of public health benefits associated with walking and 

biking, alluding to equity by describing that people with safe places to walk exercise more than 

people who live in unsafe places, and highlighting the importance of pedestrian and bike 

infrastructure (i.e., sidewalks and safe bikeways) in the choice and ability to walk. 

‐ We commend SACOG for the planned changes to the non‐motorized transportation system (i.e., 

more bicycle trails and lanes, bike/pedestrian amenities on roads, complete street connections 

within and between cities, and to transit and schools). 

‐ The measures of biking and walking used in the SCS are: 

Commuters reporting walk/bike/transit (however, commute trips that include transit 

are counted as transit trips even if they include walking and biking) 

Bike route mileage by class 

Number of bicycle person trips and walk person trips 

Weekday trips per capita by transit/bike/walk in various community types (center city, 

developing, rural, etc) 

Mode of travel for commute and non‐commute (drive alone, carpool, transit, bike walk) 

7 California Dept. of Public Health. Health Co‐Benefits and Transportation‐Related Reductions in Greenhouse Gas Emissions in 

the Bay Area: A Technical Report. Available at 

http://www.cdph.ca.gov/programs/CCDPHP/Documents/ITHIM_Technical_Report11‐21‐11.pdf 

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We agree with these metrics, and we recommend the addition of the following metrics 

associated with walking and biking: 

Proportion of households that can walk or bike (10 minutes) to meet at least 50% of 

their daily needs 

Daily amount (in minutes) of physical activity 

Per capita miles traveled by mode 

Map and count annual number of pedestrian and bicycle collisions (and severity of 

injury/fatality) 

Stratify all metrics by demographics to illuminate equity issues 

Chapter 6 – Policies and Strategies 

‐ We have some general suggestions, then comments on each section of the policies and 

strategies. Appendix B includes a detailed list of suggestions, resources, and comments that 

we look forward to your response on. Generally, we recommend: 

o Including public health representatives on the Board or performance measure selection 

committees. 

o Tying strategies of “support” or “encouragement” or “incentivizing” to methods of 

supporting and directing the reader to the larger MTP/SCS document that identifies 

specific dollar amounts of programs, if not stated. 

o Including health outcomes indicators and health determinants indicators in any 

modeling, monitoring, and reporting. 

o In places that SACOG has a strategy of educating, doing outreach, and publicizing, 

ensure that the stakeholder list include not only decision‐makers, policy‐makers, local 

staff, and other agencies, but the public and engaged CBOs, as well as media. 

o When creating efficiencies, seeking public‐private partnerships for funding, and 

increasing competition, make sure to not violate union contracts. If creating new 

bidding on new or current projects for operations or construction/maintenance, include 

first‐source hiring to employ local residents and prioritize minority‐owned businesses. 

o Moving up the timeline for investments in public transit and bike/ped infrastructure 

improvements. 

See HIP Comment Letter Appendix B: Health & Equity comments on SACOG Policies & Strategies 

Chapter 7 ‐ Environmental Sustainability 

‐ While this chapter includes a section on open space resources for recreational use, it does not 

discuss equity in access to this open space. We recommend measuring the proportion of 

households that can walk or bike (10 minutes) to parks, and including stratification by income, 

race, age, and disability, in future monitoring, in planning for Transit Priority Areas, and other 

future plans and evaluations. 

‐ While health impacts associated with air pollutants (i.e., ozone, PM 10 , PM 2.5 , and CO) are 

described (i.e., pages 7‐22 – 7‐24), we recommend modeling health impacts associated with 

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current and future emissions. For example, pre‐mature mortality attributed to traffic related 

ambient PM 2.5 , and asthma incidence and asthma exacerbations attributed to traffic related 

NO 2 should be modeled. 

‐ We commend SACOG for recommending against sensitive development within a 500‐foot buffer 

of major roadways, defined as freeways or urban roads with traffic volumes of 100,000 or more 

vehicles per day or rural roads with 50,000 or more vehicles per day (in accordance with the ARB 

Handbook). However, the percentage of the region’s population living within this buffer is still 

predicted to increase between from 2.02% to 2.4% between 2008 and 2035. We recommend 

ensuring the assessment of health impacts for developments within 1,000 foot buffer of busy 

roadways. We further recommend estimating the proportion of affordable housing units vs. 

market rate units within above identified areas. 

‐ While we commend the use of Sacramento Metropolitan Air Quality Management District 

(SMAQMD) protocol for project developers to use in assessing potential risks to residents from 

siting adjacent to major roadways (i.e., page 7‐29), we recommend the use of a 1,000‐foot 

buffer as a trigger for assessment of potential health risks and mitigations to decrease those 

health risks if development moves forward. 

‐ In the section on Travel Behavior Approach (page 7‐40), there is a statement that investments in 

public transportation infrastructure are expensive. We encourage a deeper analysis of economic 

costs and benefits of public transportation, pedestrian, and bicycle infrastructure. For example, 

bicycle infrastructure projects create 11.6 jobs for every $1 million spent and pedestrian 

projects create 9.6 jobs per $1 million, while vehicle roadway‐only projects only create 7.8 jobs 

per the same expenditure. 8 

Chapter 8 – Equity 

‐ We commend SACOG for working with the UC Davis Center for Regional Change to come up 

with enhanced criteria for designating Environmental Justice (EJ) populations, and for assessing 

inequities associated with impacts on these populations. In order to assess inequities, the 

following indicators were stratified by both EJ and non‐EJ populations: 

Mode share (public transit, walking, bicycling) 

Personal vehicle use 

Access to transit 

Transit access to jobs, medical care, higher education, and parks 

Vehicle access to jobs, medical care, higher education, and parks 

Unsurprisingly, EJ areas performed well on all of these indicators; this is likely because EJ areas 

are typically transit‐rich and near freeways. 

In addition to these indicators, we recommend measuring and stratifying the following 

additional indicators by EJ and non‐EJ designations: 9 

8 Garrett‐Peltier H (University of Massachusetts, Amherst, Political Economy Research Institute). June 2011. Pedestrian and 

Bicycle Infrastructure: A National Study of Employment Impacts. 

9 For more detail, see Human Impact Partners, August 2011. Elevating Health & Equity into the Sustainable Communities 

Strategy (SCS) Process: SCS Health & Equity Performance Metrics. 

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Annual number of pedestrian and bicycle collisions (and severity of injury/fatality) 

Proportion of households that can walk or bike to meet at least 50% of their daily needs 

Proportion of daily trips less than 3 miles and less than 1 mile by mode 

Daily amount (in minutes) of work‐trip and non‐work trip related physical activity 

Share of housing growth, proportion of projected population growth, and proportion of 

projected jobs in transit priority areas 

Percent of household income consumed by housing and transportation combined and 

separately 

For all daily trips, per capita miles traveled by mode (walking, biking, transit, vehicle) 

Pre‐mature mortality attributed to traffic related ambient PM2.5, and asthma incidence 

and exacerbations attributed to traffic related NO2. 

‐ We commend SACOG’s analysis of the proportion of residents within 500 feet of high volume 

roadways and stratification by EJ and non‐EJ populations. It is acknowledged that in both 2008 

and 2035, the percentage of the total EJ population living within 500 feet of high volume 

roadways exceeds that of non‐EJ populations by 2 to 1. Between 2008 and 2035, this proportion 

of the regional EJ population changes from 3.3% to 4%, while this proportion of the regional 

non‐EJ population changes from 1.6% to 1.8%. In addition to analyzing this within a 1,000 foot 

buffer rather than a 500‐foot buffer, as stated above, we recommend ensuring that the EJ 

population does not bear such a larger brunt of this proportional increase as compared to the 

non‐EJ population. In addition, we recommend also estimating the proportion of affordable 

housing units versus market rate units within the 1,000‐foot buffer. 

Chapter 9: Economic Vitality 

‐ SACOG’s land use strategies of focusing new housing near current jobs and new jobs near 

current housing helps to decrease the cause of the largest amount of VMT, which is that driving 

to work is usually the longest trip of the day. Other prioritized projects such as HOV lanes, 

Transportation Demand Management, improving and increasing transit, and adding Class 1 and 

2 bike lanes, also contributes to the decrease of VMT, and ultimately of the regional exposure to 

vehicle emissions, as well as encouraging physical activity. 

‐ Considering the rural community in the SACOG region separately is another success strategy 

that SACOG has employed to refine solutions for rural roads that are targeted to their needs. 

‐ The detailed analysis of the goods movement industry was good to see. The alternative routing 

decisions of truck drivers to avoid congestion is a concern, and trucks backing up local traffic as 

well as destroying pavement because of their use of rural roads. SACOG has considered some 

creative solutions, but looking toward some of the regions that have been dealing with goods 

movement for ideas about fees, fines, incentives, and other policies to enable counties and 

towns to capture costs that they are bearing would warrant investigation. 

‐ We commend the inclusion of the financial and economic development benefits of bicycle and 

pedestrian infrastructure projects, and would also include health benefits as well, especially if 

SACOG can adopt the measure of physical activity gleaned from all modes of transportation. 

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‐ We look forward to further work on the TPAs – their environmental analyses and their 

community‐driven action plans, and how they incorporate all of the measures SACOG is 

collecting for the MTP/SCS as well as the suggestions made by our health‐focused organizations. 

Chapter 9: Financial Stewardship 

‐ We appreciate the difficulty SACOG and counties, cities, and towns face with regard to financing 

maintenance and operations as well as capital projects. The detail provided about the 

replacement costs of transit and the labor costs of operations of transit are instructive, as well 

as the ways that transit operators can stretch the time of replacement due to decreased use of 

buses and other vehicles during the recession. 

‐ Understandably, many investments are slated to be implemented more fully in the 2020 – 2035 

time frame, rather than the 2012 – 2020 timeframe. In order for the region to begin realizing 

health benefits from the MTP/SCS as soon as possible, we urge SACOG to accelerate bike/ped 

improvements and phase public transit improvements with existing housing and job centers. 

‐ We are gratified to see the sensitivity to fare increases for transit‐dependent people highlighted. 

‐ SACOG has translated transportation system efficiencies (less road expansion, right‐sizing other 

capital efforts) into creative budgeting to allow for more public transit and complete streets 

infrastructure support. We agree that this will pay out in decreased VMT and increased active 

transport uptake. 

‐ Seeing road safety infrastructure continue to be prioritized is important for the most direct 

health outcome of transportation systems: fatalities and injuries from collisions. 

‐ We appreciate SACOG reporting out number of fatalities and injuries from collisions with 

vehicles, and reporting them out disaggregated by pedestrian, bicycle, truck, and auto. While 

we understand reporting of number of fatalities per 100 million VMT, it would be easier for the 

general public to digest if it were reported as a map of annual number of pedestrian and 

bicycle collisions (and severity of injury/fatality) per capita, per geographic area, by daytime 

population, and also to see the total number of vehicle, bike and pedestrian collisions per 

capita, broken down by severity: fatalities and injuries. 

‐ Finally, we also suggest that SACOG create an expenditure category for safety. In doing this, 

SACOG would be able to track safety projects as well as their effectiveness, based on a 

geographic breakdown of injuries from collisions. 

We thank you for the opportunity to submit comments on the draft SACOG MTP/SCS. Again, we applaud 

SACOG for incorporating the consideration of public health into many of the decisions, analyses, and 

goals included in this MTP/SCS. The recommendations that we’ve included in this letter reflect the 

expertise of individuals and organizations around the state that specialize in health and equity, and we 

hope you will thoughtfully consider adopting many of them in the MTP/SCS itself, in monitoring its 

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impacts in coming years, and in transit‐priority area and other decision‐making processes. 

Sincerely, 

Healthy Places Coalition 

Human Impact Partners 

WalkSacramento 

Coalition on Regional Equity 


Physicians for Social Responsibility 

Sacramento Chapter 

Physicians for Social Responsibility – Los Angeles 

Safe Routes to School National Partnership 

California State Network 

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Sacramento Area Bicycle Advocates 

California WALKS 

Appendix A: SACOG performance measures compared to health and equity metrics 

Appendix B: Health & Equity comments on SACOG Policies & Strategies 

Appendix C: Elevating Health in the Sustainable Communities Strategy: full report and 1 page 

summary of metrics of measurement methods 

Cc: 

Kacey Lizon, SACOG Senior Planner 

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Appendix A: 

Comparison Table: SACOG performance measures and Health & Equity in SCS Metrics 

In this comparison table, each Health & Equity indicator (from Human Impact Partners’ report entitled 

“Elevating Health and Equity in Sustainable Communities Strategies”; see Appendix C) is listed in the 

right hand column, in the MTP/SCS Section where HIP identified that it would most likely fit. In some 

cases, the Health & Equity indicator was very similar to an existing performance measure included in the 

MTP/SCS, and in this case it was placed beside the existing measure. The number in parentheses 

corresponds to the number of the indicator in HIP’s report (see Appendix C). The report contains 

suggested methodologies and resources. 

The purpose of this table is simply to compare SACOG’s performance measures with the Health and 

Equity in SCS Metrics. For requests and recommendations, please refer to the comment letter and to 

Appendix B. 

Section MTP/SCS performance measure Health & Equity measure 

Land Use Measures 

Housing Growth in housing units by Community Type 

Change in housing product mix by 

Community Type 

Housing growth through reinvestment 

a. Percent of household income consumed 

by housing and transportation combined; 

b. Percent of income going towards housing 

costs. (9) 

Employm Employment growth in different Community 

ent Types by sector 

Employment growth by Community Type 

Employment growth through reinvestment 

Land Use Compact development: growth in 

population compared with acres developed 

Farmland acres developed – total and per 

capita 

Vernal acres developed 

Developed acres by Community Type 

Mix of 

uses 

Jobs‐Housing balance within four‐mile radius 

of employment centers 

Mix of use by Community Type 

Proportion of households that can walk or 

bike (10 minutes) to meet at least 50% of 

their daily needs. Public daily needs defined 

as: schools, parks, healthcare institutions 

and transit. Private daily needs defined as: 

restaurants, grocery stores, food markets 

and childcare. (3) 

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TOD 

Urban 

Design 

Growth in dwelling units within half‐mile of 

quality transit (in TPA) by county 

Growth in employees within half‐mile of 

quality transit (in TPA) by county 

New housing product mix in TPA by county 

Proximity to transit by Community Type 

Change in street pattern in different 

Community Types 

Change in residential density by Community 

Type 

Transportation Measures 

Driving 

Access 

VMT 

Total jobs within 30‐minute drive by 


Total weekday VMT & average annual 

growth rates – regionally, by county, and per 

capita 

Weekday VMT by source and total 

Commute share of HH generated VMT 

Weekday VMT by source per capita or per 

job 

Total VMT per capita 

% change in VMT per capita or per job 

compared to 2008 

Weekday HH‐generated VMT per capita by 


Weekday HH‐generated VMT per capita by 

TPA 

HH‐generated commute VMT by Community 

Type and regional total 

Commute VMT per worker by Community 

Type and regional total 

a. Share of housing growth in transit 

priority areas, targeting measure of how 

many large (3‐4) bedroom units, senior 

housing, low‐income units will be built; 

b. Proportion of projected population 

growth located in transit priority areas; 

c. Proportion of projected jobs in transit 

priority areas (8) 

Proportion of households and proportion of 

jobs within 1/4 mile of local public transit 

(including both bus and rail) or 1/2 mile of a 

regional public transit, that has less than 15 

minute frequencies (4) 

Daily amount (in minutes) of work‐trip and 

non‐work trip related physical activity (6) 


by housing and transportation combined; 

c. Percent of income going towards 

transportation costs (9) 

For all daily trips, per capita miles traveled 

by mode (walking, biking, transit, vehicle) 

(10) 

Proportion of daily trips less than 3 miles 

and less than 1 mile by mode 

(walking/biking/bus and rail transit/driving) 

(5) 

Congeste 

Congested VMT total and per capita 

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d VMT 

Transit 

service 

Transit 

productiv 

ity 

Bike 

infrastruc 

ture 

Transit, 

walk and 

bike 

travel 

Roadway 

utilizatio 

n 

Commut 

e travel 

Noncommute 

travel 

Congested VMT by source – total, per capita, 

per job 

Congested VMT for HH‐generated travel by 


Increase in transit vehicle service hour per 

day by transit type 

Weekday transit vehicle service hours, 

passenger boardings, boardings per service 

hour, farebox revenues as % of operating 

cost 

Mile of bike route mileage by county 

Bike route miles per 100,000 population 

Weekday person trips by transit, walk and 

bike modes 

TWB trips per capita 

TWB trips per capita by CT 

Transit trips per capita by TPA 

TBW trips per capita by CT 

Transit trips per capita by TPA 

Underutilized, optimally utilized, overutilized 

roadways by roadway type 

Proportion of households and proportion of 

jobs within 1/4 mile of local public transit 

(including both bus and rail) or 1/2 mile of a 

regional public transit, that has less than 15 

minute frequencies (4) 

Work and non‐work trip mode share 

(including biking, walking, transit (bus and 

train), carpooling and SOV) Both at peak 

times and all day (7) 

Weekday commute tours by mode 

Commute mode share 

Weekday non‐commute person trips by 

mode 



train), carpooling and SOV)‐ Both at peak 


Non‐commute mode share 

Safety % reduction in accident rates Map annual number of pedestrian and 

bicycle collisions (and severity of 

injury/fatality): per capita, per geographic 

area, by daytime population (1) 

Environmental Measures 

Farmland Farmland conversion 

impacts Acres of impact from growth & 

transportation project by type of farmland 

% of Williamson Act contract acres impacted 

Habitat 

impacts 

% of habitat & land cover impacted 

Acres of impact from growth & trans project 

Total number of vehicle, bike and 

pedestrian collisions per capita, broken 

down by severity: fatalities and injuries (2) 

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Floodplai 

n 

develop 

ment 

Toxic air 

contamin 

ants 

by type of wildland habitat/land cover 

% of housing units expected to be 

constructed in 200‐yr floodplain 

% of population within 500 feet of highvolume 

roadway by county, region 

Proposed housing near busy roadways will 

require (12) 

a. Assessment by local air district or public 

health department of the need for 

environmental/health impact analysis 

when housing is proposed near (within 

1,000 feet) busy roadways (over 

100,000 Average Annual Daily Traffic 

(AADT)) or other significant pollution 

sources (e.g., rail yards, port terminals, 

refineries, power plants, etc); and 

b. Best practice mitigation requirements 

by local governments when the above 

assessment determines that 

environmental quality is below standard 

for such proposed housing, and if such 

housing is determined to be safe by 

local air districts and public health 

departments with identified mitigation. 

In highly urban regions, we suggest an 

alternate metric (12): 

a. Estimate the number of sensitive sites 

(homes, schools, daycares, parks, etc.) 

within 1,000 feet of freeways and other 

major pollution sources, where that 

source contributes to more than 0.3 

μg/m 3 of PM2.5 or or cancer risk of 

greater than 10 additional cases of 

cancer/ million. (Note these are based 

on BAAQMD’s CEQA thresholds.) 

b. Estimate proportion of affordable 

housing units vs. market rate units 

within above identified areas. 

Working with a local public health 

department, university or air quality 

management district: Estimate pre‐mature 

mortality attributed to traffic‐related 

ambient PM 2.5, and estimate asthma 

incidence and asthma exacerbations 

attributed to traffic related NO2. (11) 

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GHG 

emissions 

GHG emission by sector 

GHG emission reductions per capita by 

pounds per day, % 

Environmental Justice Measures 

Land Use % of EJ area and non‐EJ area population in CT 

% of EJ area and non‐EJ area population in 

TPAs by county 

Housing Housing product mix in EJ and non‐EJ areas 

by CT 

Transit 

Service 

Transit 

Accessbili 

ty 

Mode 

share 

Auto 

accessibil 

ity 

Comparis 

on of 

transit 

and auto 

accessibil 

ity 

Toxic air 

contamin 

ants 

Increases in daily transit vehicle service 

hours in EJ areas 

Accessibility from EJ and non‐EJ areas within 

30 min by transit to jobs, retail jobs, medical 

jobs, higher education, park acres 

EJ & non‐EJ area transit mode share 

Bike & Walk mode share in EJ & non EJ areas 

Accessibility from EJ and non‐EJ areas within 

30 min by car to jobs, retail jobs, medical 

jobs, higher ed, park acres 

% of jobs, retail jobs, medical jobs, higher ed, 

park acres accessibility within 30 min by 

transit vs. car from EJ and non‐EJ areas 

% of population within 500 feet of highvolume 

roadway by county, region 

Share of housing growth in transit priority 

areas, targeting measure of how many large 

(3‐4) bedroom units, senior housing, lowincome 

units will be built; (8) 


by housing and transportation combined;b. 

Percent of income going towards housing 

costs (9) 










train), carpooling and SOV)‐ Both at peak 









Housing near busy roadways (12) 

a. Estimate the number of sensitive sites 

(homes, schools, daycares, parks, etc.) 

within 1,000 feet of freeways and other 

major pollution sources, where that 

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source contributes to more than 0.3 

μg/m 3 of PM2.5 or or cancer risk of 

greater than 10 additional cases of 

cancer/ million. (Note these are based 

on BAAQMD’s CEQA thresholds.) 

b. Estimate proportion of affordable 

housing units vs. market rate units 

within above identified areas. 

Measure and stratify all indicators by 

race/ethnicity; income; geography 

(neighborhood, census block or tract, or 

Community of Concern); age; disability. (13) 

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Appendix B: Health and Equity comments on SACOG Policies and Strategies 

Strengths 

Environmental Sustainability 

Complementary strategies 

# Comment 

2.5 Continuance of the social equity analysis. 

3 All of Policy 3 further health goals 

4.3 Tool development measuring jobs/housing fit and Housing & Transportation cost analysis. 

4.5 Support for jurisdictions in overcoming impediments to fair housing. 

6 Incentives for infill and alternative modes of transit, minimizing the urban footprint, 

conserving open space and natural resources all support positive health outcomes. 

7.7 Incentives for rural land use and transportation practices that benefit the region and as 

well as local rural areas. 

8.1‐ TDM, SECAT, and Spare the Air support. 

8.3 

10 Policies and programs to reduce the environmental, health, and equity effects of goods 

movement. Any change in practice requires multiple approaches and it is good to see 

SACOG focusing at the systemic and corporate levels as well as at behavior change among 

individual drivers. We encourage prioritization among individual drivers. 

# Comment 

1.5 Have a local public health representative on the advisory team when helping local 

governments create and maintain a development activity tracking tools assessing growth 

patterns. 

2.2‐ When monitoring transportation and air quality impacts of development patterns, 

2.3 include health outcomes monitoring and equity monitoring (see attached Health and 

Equity indicators: # 1,2,6, 11, 13). Specifically, monitor respiratory disease impacts of air 

quality changes due to development; injuries/fatalities due to changed traffic patterns, 

and change in physical activity levels – and how development patterns impact race, 

ethnicity, low‐income communities. 10 

2.4 Educational materials should include health impacts of neighborhood travel behavior, 

and enlist public health departments to help create these. 

2.7 One methodology to include health impacts in review transportation projects in the 

design phase is including health impact assessment in the planning requirements, or a 

health/social checklist. 11 

12 13 

2.9 Include in the economic land use modeling ways of modeling cost of health impacts. 

10 For more detail, see Human Impact Partners, August 2011. Elevating Health & Equity into the Sustainable 

Communities Strategy (SCS) Process: SCS Health & Equity Performance Metrics. Available at 

http://www.humanimpact.org/projects 

11 For more information about Health Impact Assessment, see http://www.humanimpact.org/hia 

12 Pedestrian and Bicycle Infrastructure: A National Study of Employment Impacts. University of Massachussetts, 

Amherst, Political Economy Research Institute, June 2011. 

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2.10 When providing education and analysis to inform decision‐makers, local staff, and other 

stakeholders about open space, economic, and environmental benefits, also inform them 

of health and equity benefits. Can be done by reporting out monitoring results for health 

and equity indicators, by including public health representatives when designing 

materials. Make sure other “stakeholders” are the public as well. 

3.7 When researching and modeling to provide evidence to support parking regulation 

modification and incentivizing, take outcomes of air emissions and transportation 

circulation patterns out to respiratory health outcomes from air quality changes, 

pedestrian/bike injuries/fatalities from collisions, and changes in physical activity levels. 14 

4.1 Publicize and educate policy‐makers and the public about the RHNA results. 

4.3 One methodology to supplement SACOG’s tool measuring the jobs/housing fit is the 

Center for Community Innovation at University of California – Berkeley’s Early Warning 

Toolkit for Gentrification. 15 

4.5 Could you give more detail on how you would support overcoming common issues local 

analyses of impediments to fair housing (and regional analyses)? 

5.1 Do an equity analysis to see if the lands identified to meet goods movement needs 

disproportionately negatively impact economic justice communities. 

5.2 Studies of the land needs for goods movement and distribution should include indicators 

of health outcomes impacted by increased truck traffic such as motor vehicle collisions 

with other vehicles, pedestrians, and bicyclists; respiratory disease outcomes from 

increased exposure to diesel emissions from trucking, and noise impacts of localized and 

regional goods movement. 

5.3 Agriculture industry needs for goods movement should include in studies the size of 

farms and prioritize needs for small and mid‐size farmers, who have been hit 

disproportionately by development and by the recession. 

6.5, 

7.1, 

& 

7.4 

Local jurisdictions could use health impacts analyses to build on RUCS data and tools to 

analyze possible impacts to agriculture and natural resource from any urban footprint 

growth. HIA is a useful stakeholder‐driven methodology that can supplement other 

methods, processes, and tools. 16 Also, SACOG should foster or participate in a process to 

develop additional tools and a more comprehensive dataset of the region’s natural 

resources and examine how they contribute to purify water, mitigate urban heat island 

effect, and other public health interests. 

7.6 Local partners at University of California at Davis may be able to support the work SACOG 

is doing to support Farm to Market access. 

8.4 There are tools available to support SACOG’s support in studying localized air pollution 

impacts on health: MTC, tools from the Health and Equity metrics in SCS, and SFDPH’s 

13 Growing Healthy in Southern California. American Lung Association of California. 

http://www.lungusa.org/associations/states/california/advocacy/fight‐for‐air‐quality/smart‐growth‐forcalifornia.html 

14 HIP, ibid. Elevating Health & Equity into the Sustainable Communities Strategy (SCS) Process: SCS Health & 

Equity Performance Metrics. 

15 Chapple K. 2009. Mapping Susceptibility to Gentrification: The Early Warning Toolkit. Available at 

communityinnovation.berkeley.edu/reports/Gentrification‐report.pdf 



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modeling to guide placement of residential development and development for sensitive 

receptors). 17 

9 Policies and strategies to decrease GHG are generally good for health. Please ensure that 

any projects or programs implemented do not have unforeseen health and equity 

impacts in other areas besides the impact of GHG and air emissions on health. 

9.1 For these pilot programs, how will SACOG decide where to target them? Suggest have 

public health and equity partners on any selection committee. 

9.4 For regional climate action plan, prioritize projects and policies known to have the largest 

impact on health outcomes for vulnerable communities 

10.2 When encouraging alternative modes to move freight, study the health and equity 

impacts of how that might be done. You can do this through use of HIA or potentially use 

of prioritized health indicators in planning. 

Concerns 

# Comment 

6.4 SACOG support for reducing protections to environmentally sensitive developments, even 

at the edges of existing urbanization. These are the places where environmental injustice 

takes place. 

Strengths 

Finance 

# Comment 

Prioritizing transit investments, encouraging Complete and Green Streets and Safe 

Routes to Schools. 

13.6 Conditioning funding for regional transportation plans on implementation of mitigation 

measures. 

14.4 Helping local agencies get funding for safety programs and improvements. 


# Comment 

11.2 Make sure, when simplifying and adding flexibility to funding structures or tools, that 

simplification does not bypass protections for public health and equity such as 

environmental impact assessments. When pursuing projects that qualify for CEQA 

streamlining, continue to incorporate health and equity studies; while the effects of 

TOD and smart growth are fairly well‐accepted in terms of positive environmental 

impacts, some TOD and smart growth projects uncover tradeoffs in health outcomes. 

11.3 If promotion of competition in the interest of efficiency incurs new RFPs or bidding, put 

in place a local hire policy and minority‐owned business policy. 

14.6 Include public health agencies as one of the multiple disciplines that you coordinate 



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with in planning and actions. 

15.1 When pooling funds and programming to increase flexibility in use of funds, do not pool 

funds targeted for Environmental Justice concerns and projects. Keep these earmarked 

so as not to deprioritize them. 

16.2 Keep in mind equity concerns when looking at Value Pricing and HOV toll lanes, pay‐atthe‐pump 

auto insurance, or auto loans. 

Strengths 

System Maintenance and Operations 

# Comment 

17.3 Considering operational improvements to decrease congestion before considering road 

expansion. 

18.2 Encouraging stakeholder engagement in the development of the Corridor System 

Management Plan. 

18.4 Seeking more funding from programs such as the Sustainable Communities and 

California Strategic Growth Council. 

20.1 Improving pedestrian and bike access to public transit. 

21.2 Looking at specialty transit access to agriculture areas seasonally and for agritourism. 

This is a great equity move for agriculture workers, and could improve economic 

outcomes for farmers. 

22.1 Educational outreach on improving perception of forms of public transit. These could 

include health impacts of public transportation as well in those outreach materials. 

24 Outreach to low income and minority communities to ensure improvements are 

equitable. 

25.6 Considering how to encourage transporting freight by rail or ships instead of primarily 

trucks. 

26.2 Diverting freight traffic around the region, and not through the region ‐ must be sure to 

not incur negative impacts on other regions. 


# Comment 

17.2 When considering public‐private partnerships and competitive service contracts for 

maintenance and operations, make sure not to violate union contracts, and target new 

contracts for local hire with first source hiring rules and points for minority‐owned 

businesses. 

18.3 Include health indicators and outcomes in the modeling for travel forecasting and 

analysis associated with each CSMP. 18 

20.3 Include monitoring of actual health outcomes of pedestrian safety concerns: pedestrian 

injuries and fatalities from collisions with vehicles. 

20.5 For Connect Card universal fare card implementation, support or seek support for 



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subsidies for low‐income residents and youth. 

24.5 When mitigating transportation impacts, include Health & Equity Metric #12 19 : 

assessing need for EIA/HIA when housing is near 1,000 feet of a busy roadway and 

requiring best practice mitigation requirements when the assessment determines that 

air quality is a risk to health. Ideally, an equity analysis would be done, including 

estimating the proportion of affordable housing units vs. market rate units within 1,000 

foot buffer of busy roadways (over 100,000 AADT). 

25.1 When improving regional freight forecasting tools, including health impacts from diesel 

and other air emissions, injuries/fatalities from collisions, and health outcomes due to 

noise. 

25.2 Include members of the public and also public health advocacy and agencies on the 

goods movement advisory group. 

25.3 Include health outcomes impacts of logistics industry (not just measures of noise 

changes, air emissions changes, and safety). 

25.4 

& 

26.1 

When identifying new preferred truck access routes, conduct a health and equity 

analysis. 

Strengths 

System Expansion 

# Comment 

Health evidence supports expansion of transit over road expansion, and supporting 

expansion that supports infill development, limits to increase of the urban footprint, 

and circulation patterns that will encourage active transport. 

28.12 Encouraging supportive features that will help encourage people to take public transit. 

29.2 ‐ 

29.4 

Investing in bike/ped networks in the order identified, sharing information in order to 

increase connectivity, and funding complete streets. 


# Comment 

27.3 Ensure that new intercity rail services do not encourage sprawl. 

28.3 We commend SACOG for considering the full life‐cycle costs of transit options; does 

SACOG also do this for roadway projects? When considering the costs, is this a place to 

also consider the Housing + Transportation costs for the consumer? 

28.4 

& 

When deciding on where to develop transit corridors between communities and local 

transit and how/where to design commute transit, include a mapping and quantitative 



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28.6 measure of ¼ mile access to local transit for different communities. See methodologies 

in the Health & Equity metrics for assistance. 20 

28.10 Strengthen this strategy to better ensure that development will match rail density 

requirements. The strategy should rely on existing “local smart growth plans”, not 

simply “local smart growth planning” and developers must be held to a high standard of 

evidence that growth will happen and will support rail. 

29.1 Investing in safe bicycle and pedestrian routes is an excellent strategy. We would 

encourage mapping/measuring, monitoring changes in, and reporting out ½ mile access 

from residences to schools, worksites, shopping, and transit stops. 

30.1 ‐ 

30.3 

Have good public processes around projects that expand roads, even if they support 

effective transit services and intend to reduce congestion near infill. Processes should 

look at health and equity impacts of road expansion, include analyses of induced traffic 

(by forecasting changes in VMT and other “miles traveled” such as pedestrian and bike 

miles traveled) as a result of improvements made in conjunction with road expansion. 

Analyses should consider a wide time horizon to account for induced travel. 

30.3 When proposing to expand roads near infill, make sure to measure and model 

respiratory health impacts, equity impacts, and mode used for proportion of daily trips 

less than 3 miles and less than 1 mile by mode (auto, bike, walk). 21 

30.5 When proposing expansion of trunk arterials around job centers and freeway 

interchanges, be sure to measure and model health impacts for those in housing within 

1,000 feet of these access routes, and propose mitigations for projects which show 

negative respiratory and cardiovascular health impacts. 22 

Concerns 

# Comment 

28.9 This strategy is exemplary from a health lens. Bus service is a cost‐effective way to 

increase and improve use of public transit. 







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Appendix C 

Elevating Health & Equity into the Sustainable Communities 

Strategy (SCS) Process 

SCS Health & Equity Performance Metrics 


August 2011 

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Table of Contents 

Introduction 3 

The Metrics 

Safety 5 

Access to Goods, Jobs, and Services 7 

General Transportation 16 

Future Growth 21 

Economic 23 

Environmental Pollution 25 

Equity 36 

How to use the Health and Equity Metrics 38 

Appendix: Metrics recommended for future study 40 

References 41 

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SCS Health & Equity Performance Metrics 

INTRODUCTION 

In 2008, the California legislature passed SB375, the intent of which is to decrease emissions of 

greenhouse gases to target levels in each region of the state. Given the connection between how 

our environment is built and health behaviors, outcomes, and inequities, this is a unique 

opportunity to elevate health and equity into transportation and land use planning. 

The bodies responsible for implementation are the Metropolitan Planning Organizations 

(MPOs) in each of the 18 regions of the state, and they are planning for this change through 

their Regional Transportation Plans (RTPs), an update of transportation policies and guidelines, 

as well as guidance on the types of projects (and in some cases the actual projects) that will be 

constructed over the next 25 years. Within the RTPs, all MPOs will be developing a Sustainable 

Communities Strategy (SCS), which is the document and vision for decreasing greenhouse gas 

emissions through transportation and land use planning. 

Given the high levels of chronic disease, including obesity, diabetes, and asthma, that we are 

facing as a country, it is imperative that we address the root causes. We spend a higher percent 

of our GDP on healthcare than any other country and while access to healthcare and genetics are 

important factors that determine our health status, there is growing recognition that the land use 

and transportation systems that influence our personal behaviors affect our health status even 

more. As described below, transportation systems impact health in many ways, through injuries 

and fatalities, environmental quality (e.g., air quality and noise), physical activity, and income. 

These impacts are typically not distributed evenly across all populations, with lower income 

populations and communities of color often facing worse outcomes for a variety of reasons. 

Understanding the causes of these differences is an important piece of addressing them. For this 

reason, we believe that equity (defined here to mean the absence of systematic disparities in 

health or in the major social determinants of health, between groups with different levels of 

underlying social advantage/disadvantage 1 ) must be assessed in addition to health. 

A statewide group of public health advocates convened by Human Impact Partners has 

developed the following set of 13 performance metrics for use in the RTP/SCS processes across 

the state. In the past, public health and equity have not been fully considered in land use and 

transportation planning and many health and equity outcomes related to those plans have been 

poor. We hope to inform the discussion of performance metrics with a health perspective and 

thereby improve future health outcomes related to these planning efforts. MPOs across the state 

are including different voices in the Sustainable Communities Strategy discussions as part of their 

RTPs. Our hope is that MPOs will consider including the following metrics in their SCSs and 

including public health and equity professionals and advocates in the process of developing their 

RTP/SCS. 

This document lists the 13 health and equity performance metrics prioritized by statewide health 

experts, agencies, advocates, and transportation planners. This list of 13 was chosen from an 

original 129 indicators. 

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There were many agencies, advocates, planners, and individuals involved in choosing the Health 

& Equity metrics. Inclusion on this list does not imply a “sign-on” to the metrics, only that the 

agencies and organizations contributed to the prioritization, suggested methodologies and 

standards. 

• Climate Plan 

• American Lung Association 

• California Department of Public 

Health 

• Los Angeles County Department of 

Public Health 

• Shasta County Department of 

Public Health 

• BARHII 

• San Mateo County Health System 

• Move LA 

• Prevention Institute 

• Public Health Law & Policy 

• Reconnecting America 

• Safe Routes to Schools 

• Public Health Institute 

• PPIC 

• TransForm 

• Marin County Department of 

Public Health 

• Public Advocates 

• PolicyLink 

• Public Law Center 

• Raimi & Associates 

• Nelson & Nygaard 

• Fehr & Peers 

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Page 66 of 165

The effort was funded by the Resource Legacy Fund. 

Metrics chosen needed to be: measurable over time; evidence-based; geographically 

scale-able (measured at various scales, like local and regional, and at scales useful to 

those using them); understandable and accessible to policy-makers; stratifiable by race, 

ethnicity, place, income; relevant to health and equity; and, of course, relevant to the 

Sustainable Communities Strategy. 

The metrics are the result of an intensive 2-month collaboration with the above groups. 

The metrics will not apply equally to every region, particularly the more rural regions. It 

is our hope that in each region, local public health agencies and advocates will work with 

transportation agencies and advocates to adapt the metrics to fit their region. Human 

Impact Partners and other organizations involved are available to assist those efforts 

(see “How to Use Health and Equity Metrics” at the end of this document). 

This document does not provide recommendations of benchmarks for each metric. 

While we do provide standards, it is again our hope that agencies and advocates 

concerned about health and equity will take this document and use it to craft 

recommendations specific to their region and the politics that exist locally. 

Finally, any prioritization process cannot necessarily include all of the metrics. There 

were metrics that participants felt were important but did not make the final list. Some 

of the metrics, listed in the appendix below, were recommended for further study by the 

MPOs. 

The structure of the document includes the thirteen metrics and with each metric we 

provide the evidence that connects that metric to health and equity, a suggested 

methodology for measuring the metric, resources to help if the methodology is 

unfamiliar, limitations of the methodology if there are any, and some standards that exist 

around the metric. 

SAFETY 

METRICS: SAFETY 

1. Map annual number of pedestrian and bicycle collisions (and severity of injury/fatality): 

per capita, per geographic area, by daytime population 

2. Total number of vehicle, bike and pedestrian collisions per capita, broken down by 

severity: fatalities and injuries 

EVIDENCE BASE 

Health Impacts 

Number of collisions is directly tied to injuries and fatalities. Motor vehicle crashes are the leading 

cause of death among those ages 5-34 in the U.S. ii Areas with high levels of vehicle miles traveled per 

capita tend to have higher collision and injury rates. More time in a car means higher exposure to the 

perils of driving, including collisions. iii There is a statistically significant relationship between traffic 

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volume and the number of vehicle collisions involving a pedestrian. iv v vi vii California’s pedestrian 

fatality rates are much higher than the nation’s, with pedestrians accounting for more than 17 percent 

of motor vehicle collision related deaths in California. viii The lifetime odds of dying as a car driver or 

passenger are 1 in 261, compared to 1 in 64,596 as a bus occupant or 1 in 115,489 on a train. ix 

The risk of pedestrian injuries may discourage walking as a mode of transport, and negatively impact 

physical activity levels. The perception of collision risk may also prevent people from cycling. In a 

survey of adults in the Vancouver metropolitan area, the top deterrents to cycling were the risk of 

injury from car-bike collisions; the risk from motorists who don't know how to drive safely near 

bicycles; motorized vehicles driving faster than 50 km/hr; and streets with a lot of car, bus, and truck 

traffic. x Additionally, beyond the immediate physical consequences of a collision, an individual’s wellbeing 

can also be impacted from resulting levels of disability, high medical costs and lost 

productivity. xi 

Equity Impacts 

Pedestrian collisions are more common in low-income areas, potentially reflecting greater residential 

density, greater traffic volume, and lower automobile ownership among residents of these 

neighborhoods. xii In Alameda County, for example, the combined rate of pedestrian injury or death 

in high poverty areas is six times that in low poverty areas (12 cases per 1,000 people in high poverty 

areas vs. 2 cases per 1,000 people in low poverty areas). xiii 

There are also racial disparities in risks associated with pedestrian crashes. xiv A greater incidence of 

crashes involving pedestrians exists among minorities; African American and Hispanic race/ethnicity 

as well as uninsured status are linked to increased risk of mortality from collisions. xv 

METHODOLOGY 

In California, the Statewide Integrated Traffic Records System (SWITRS) records data for all vehicle, 

bicycle and pedestrian collusions that are reported. This data is available at the intersection level and 

therefore able to be geocoded and aggregated by census tract, neighborhood, city or region-wide. 

When calculating collisions per capita, the daytime population (when available) may be a more 

reliable denominator, however collisions before 5 AM and after 7 pm should be excluded when using 

the daytime population. Alternatively, residential population overall can be used as the denominator. 

Race/ethnicity data is largely missing from SWITRS, so stratification by race is not possible using 

this data. 

TIMS (Transportation Injury Mapping System) will map SWITRS data by census track, traffic zones, 

schools, etc. http://www.tims.berkeley.edu/ MPOs need to be careful with TIMS data as it doesn't 

include all collisions (only those that are severe or fatal). For complete data use the SWITRS site. 

RESOURCES 

Serious and fatal injuries are geocoded and available at no cost from UC Berkeley SafeTREC 

(http://www.tims.berkeley.edu/) 

Monitoring: San Francisco Department of Public Health- Healthy Development Measurement Tool: 

Indicator ST.3.c Number of bicycle collisions- http://www.thehdmt.org/indicators/view/59 

Forecasting: An example of the development and use of a multivariate, area-level regression model of 

vehicle-pedestrian injury collisions that has been applied to predict area-level change in vehiclepedestrian 

injury collisions associated with land use development and transportation planning 

decisions: 

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Wier M, Weintraub J, Humphreys EH, Seto E, Bhatia R. (2009). An area-level model of vehiclepedestrian 

injury collisions with implications for land use and transportation planning. Accident 

Analysis & Prevention, 41(1):137- 45. 

http://www.sfphes.org/transportation/Pedestrian_Injuries_and_Fatalities_SF.pdf 

LIMITATIONS 

As mentioned above, SWITRS data relies on collisions that have been reported. However, collisions 

that do not result in a serious injury and collisions resulting from poor road maintenance tend to go 

unreported. A joint study by the San Francisco Department of Public Health and the San Francisco 

Bicycle Coalition found that only 5 percent of dooring incidents (i.e., when a bicyclist is hit by a car 

door) were reported to the police. xvi In addition, neighborhoods in San Francisco with higher 

immigrant population densities may have lower reporting rates because of fear of law enforcement, 

whereas neighborhoods with a strong community police presence may be more likely to report 

collisions. xvii 

STANDARDS 

Statewide, in California in 2009: 

The motor vehicle collision fatality rate was 7.3 per 100,000 people; 

The motor vehicle collision injury rate was 425 per 100,000 people. xviii 

The pedestrian fatality rate from collisions with motor vehicles was 1.5 per 100,000 people 

The pedestrian injury rate from collisions with motor vehicles was 34 per 100,000 people. xix 

The bicyclist fatality rate from collisions with motor vehicles was 0.3 per 100,000 people; 

The bicyclist injury rate from collisions with motor vehicles was 31 per 100,000 people. xx 

Healthy People 2020 xxi 

The U.S. Department of Health and Human Services (USDHHS) Healthy People 2020 provides 

science-based, 10-year national objectives for improving the health of all Americans. By 2020, the 

following should be achieved: 

Unintentional injury prevention 

Reduce nonfatal motor vehicle crash-related injuries to 1.2 deaths per 100 million vehicle 

miles traveled; 

Reduce pedestrian deaths on public roads to 1.3 deaths per 100,000 population; 

Reduce nonfatal pedestrian injuries on public roads to 20.3 injuries per 100,000 population; 

Reduce cyclist deaths on public roads to 0.22 deaths per 100,000 population. 

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ACCESS TO GOODS, JOBS & SERVICES 

METRIC: ACCESS TO GOODS, JOBS & SERVICES 

3. Proportion of households that can walk or bike (10 minutes) to meet at least 50 percent of 

their daily needs. Public daily needs defined as: schools, parks, healthcare institutions 

and transit. Private daily needs defined as: restaurants, grocery stores, food markets and 

childcare. 

EVIDENCE BASE 


Neighborhood conditions can have a powerful effect on health. xxii A neighborhood’s physical 

characteristics may promote health by providing safe places for children to play and for adults to 

exercise that are free from crime, violence and pollution. xxiii Being within walking or biking distance 

of neighborhood goods and services promotes physical activity, reduces vehicle trips and miles 

traveled, and increases neighborhood cohesion and safety. xxiv Reducing vehicle trips and miles 

traveled can also reduce air and noise pollution, which subsequently impacts respiratory disease, 

cardiovascular disease, and other health conditions. Living in dense, mixed-use communities can also 

improve cardiovascular and respiratory health as well as reduce the risk of obesity. xxv 

PUBLIC GOODS & SERVICES (health care, schools, parks & transit): 

Access to Health Care Services and Health 

The timely use of primary care has a role in preventing morbidity and hospitalizations for a 

number of chronic diseases, including asthma and diabetes. Research has found that Federally 

Qualified Health Centers in medically underserved areas can lower preventable hospitalization 

rates. xxvi Travel distance to a health care provider and lack of transportation are well established 

barriers to receiving adequate health care. xxvi xxvii xxviii Additionally, people with a usual source 

of health care are more likely than those without a usual source of care to receive a variety of 

preventive health care services. xxix xxx Fifteen percent of adults in the U.S. lack a usual source of 

health care. This equates to more than 40 million people that have no particular doctor’s 

office, clinic, health center, or other place where they regularly go for health care advice. xxxi 

School Location, Education and Health 

Research findings indicate that the physical location of schools, in particular the distance that 

students travel to school, significantly impact health outcomes. Long travel distances to school 

are a primary barrier and have the strongest influence on the students’ decision to walk or bike 

there. xxxii xxxiii Living within a half-mile of a school greatly increases the likelihood of walking or 

biking to that school across all racial groups. xxxiv Active commuting to school can provide a 

substantial portion of children’s physical activity and has been associated with increasing levels 

of independence, social interaction and communication. xxxv xxxvi xxxvii xxxviii xxxix However, the level 

of violence in the surrounding area where a school is located can make it difficult for students 

to travel to and from school safely, discouraging them from walking or bicycling to school 

regardless of the distance or the walkability of the neighborhood. xl 

Access to and duration in school are incredibly important, as there are well-documented 

associations between education and health. xli In 1999, the age-adjusted mortality rate of high 

school dropouts between the ages of 18-64 was more than twice as large as the mortality rate 

of those with some college education. xlii Better educated individuals have healthier behaviors; 

are less like to be hypertensive and suffer from diabetes; and are more likely to exercise and 

obtain preventative care. In addition, maternal education is strongly associated with infant and 

child health; four more years of schooling lowers the probability of reporting in fair or poor 

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health by 6 percentage points; and estimates suggest that a year of education increases earnings 

by about 10 percent. xliii 

Access to Parks and Health 

People who live closer to parks are more likely to use them for physical activity. xliv Having park 

space available increases the amount of exercise that residents get. xlv For example, a 1 percent 

increase in park space can increase physical activity in youth by 1.4 percent. xlvi Nationally, 

about 30 percent of physically active people report exercising in public parks. xlvii Access to 

parks and open space is also associated with higher levels of social interaction, which has 

positive impacts on mental health through higher social support and better social networks. 

Access to Public Transportation and Health 

Public transportation that is both convenient and fast, and transit oriented development 

(meaning walkable, mixed-use communities located around transit stations) can affect travel 

activity and provide large health benefits, including reduced traffic crashes and pollution 

emissions, xlviii increased physical fitness, xlix improved mental health, l improved basic access to 

medical care and healthy food and increased affordability which reduces financial stress to 

lower-income households. li In fact, Americans who use public transit spend a median of 19 

minutes daily walking to and from transit; twenty-nine percent achieve at least 30 minutes of 

physical activity a day solely by walking to and from transit. xlix 

PRIVATE GOODS & SERVICES (food retail & childcare centers) 

Access to healthy food retail and health 

Lack of access to healthy food is one of the barriers, particularly for low-income communities, 

to healthy eating. Diet-related disease is one of the top sources of preventable deaths among 

Americans, with the burden of overweight and obesity falling disproportionately on 

populations with the highest poverty rates. lii liii It is well known that nutritious eating and 

regular physical activity aid in the prevention of chronic medical conditions, especially diabetes, 

cardiovascular diseases and cancers, and can alleviate the effects of conditions such as 

obesity. liv 

The choices that people make about what they consume on a day-to-day basis are influenced 

by the food options available at different retail locations. lv For many low-income populations 

in urban areas, accessible and affordable nutritious food remains a significant unmet need. 

Such households often buy less expensive but more accessible food at fast food restaurants or 

highly processed food at corner stores. These types of foods are usually higher in calories but 

lower in nutritional value. lvi Eating at fast-food restaurants is associated with higher caloric 

intake, lower vegetable consumption, greater consumption of sweetened beverages and higher 

rates of obesity. lvii Research has shown that where there are high numbers of fast-food 

restaurants compared to grocery stores, there are also higher rates of diabetes, cardiovascular 

disease, and cancer. lvii 

Childcare centers and health 

Today, the majority of U.S. children live in families in which all parents work. lviii Access to 

childcare is essential for working parents to maintain employment and/or education. 

Accessible high-quality childcare provides children with valuable opportunities for cognitive, 

behavioral and educational development, and results in positive physical health outcomes. 

lxii 

lix lx lxi 

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From an extensive study done about land use in Seattle, they saw that the land uses that were most 

strongly linked to the percentage of household walking trips in the Seattle area were educational 

facilities, commercial office buildings, restaurants and taverns, parks, neighborhood scale retail 

establishments, civic uses, grocery stores. They also found that the number of retail establishments 

(rather than total retail square footage) was found to be important in the decision to walk for nonwork 

purposes. For each quartile increase in the number of retail locations, walking for non-work 

trips increased 19 percent. lxiii 


Inequities exist not only in access to goods and services within certain neighborhoods, but also in the 

ability to live in neighborhoods with health-promoting conditions – an ability which varies with 

household economic and social resources. xxiii Nearly one fifth of all Americans (approximately 52 

million people) live in poor neighborhoods (i.e., neighborhoods in which at least 20 percent of 

residents are poor). xxiii Between 1970 and 2000, poor families became more likely to live in 

neighborhoods with concentrated poverty and rich families became more likely to live in 

neighborhoods with concentrated wealth. lxiv This concentrated poverty impacts inequity – according 

to a recent study, the median wealth of white households is 20 times that of black households and 18 

times that of Hispanic households, a finding most recently impacted by plummeting home values. lxv 

Individuals in minority racial or ethnic groups are more likely to live in poor neighborhoods – nearly 

half of all blacks live in poor neighborhoods, compared with only one in ten whites. lxvi 

Historic trends of reduced public spending affect poor neighborhoods more than wealthy 

communities. lxvii The influence of socioeconomic segregation as well as racial or ethnic segregation 

influences neighborhood conditions in a variety of ways, from funding and quality of public schools 

to employment opportunities, housing quality, municipal services, and hazards such as pollution, 

noise and crime. xxiii A recent study in New York revealed that low-income non-white populations are 

at a disadvantage when trying to access daily goods and services. There was a stronger relationship 

for black populations than Latino populations but both populations have less access. lxviii For lowincome 

families, the costs of childcare can consume a major portion of income, leaving less money 

for food, housing and other necessities. Finally, children with low neighborhood amenities or those 

lacking neighborhood access to sidewalks or walking paths, parks or playgrounds, or recreation or 

community centers had 20 to 45 percent higher odds of obesity and overweight, compared with 

children who had access to these amenities. lxix 

METHODOLOGY 

Use GIS to map the distribution of daily goods and services in a particular region and households 

that can access them by biking or walking. Display the proportion of parcels that can access a 

minimum of four out of the eight public and private goods/services (50 percent) by noting the 

geographic areas with access below 50 percent access and those areas above 50 percent access. This 

analysis should produce two different maps, one showing bike access and one pedestrian access, as 

well as a display of the geographic equity of distribution. 

RESOURCES 

The San Diego Association of Governments (SANDAG) has begun to develop methodology for 

mapping and quantifying neighborhood access to healthful resources. For more information, contact 

Vikrant Sood at vso@sandag.org. 

Richmond General Plan: Neighborhood Completeness Index xxiv – Moore Iacofano Gostsman, Inc. 

(2007). Richmond general plan update- Issues & opportunities paper #8: Community health and 

wellness(Draft). p23 

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http://www.cityofrichmondgeneralplan.org/docManager/1000000640/Existing%20Condictions%2 

0Report%20August%202007.pdf 

LIMITATIONS 

While geographic distance is just one dimension of accessibility, proximity to services does not 

necessarily promote increased walking and biking, reduced daily vehicle trips and miles traveled, 

increased, and increased interactions among neighbors and others on the street. While this metric 

demonstrates the geographic distribution of key public services within a neighborhood, two residents 

within the same neighborhood may have very different abilities to access goods and services, due to 

the size and topography of the neighborhood, available transportation options, affordability of goods 

and services, hours of operation, and language and cultural accessibility. lxx It is also important to note 

that accessibility is not a measure of the quality of goods/services available. 

STANDARDS 

Richmond General Plan xxiv : If a given parcel in the city is within 1⁄4 mile of at least 9 of the 18 

services listed, that parcel is considered to have good physical proximity to daily goods and services 

(service index of 0.5). A service index of 0.5 or higher relates to completeness of neighborhoods. 

Available at: 


0Report%20August%202007.pdf 

SFDPH: Proportion with access to 8 out of 11 public goods and services and 9 out of 12 key retail 

services. 

Available at: http://www.thehdmt.org/objectives/view/62 

Ahwahnee Principles for Resource Efficient Communities lxxi 

Community Principle 1. All planning should be in the form of complete and integrated 

communities containing housing, shops, workplaces, schools, parks and civic facilities essential 

to the daily life of the residents. 

Community Principle 2. Community size should be designed so that housing, jobs, daily needs, 

and other activities are within easy walking distance of each other. 

Community Principle 7. The community should have a center focus that combines commercial, 

civic, cultural and recreational uses. 

Community Principle 8. The community should contain an ample supply of specialized open 

space in the form of squares, greens and parks who frequent use is encouraged through 

placement and design. 

Available at: http://www.lgc.org/ahwahnee/principles.html 

California TOD Housing Program Guidelines lxxii . Transit-supportive land use 

This law establishes the priorities for distributing funding for TOD communities, and it gives points 

for housing that will be built near a transit stop and has access to 10 of the following uses: 

Bank, child care facility, community center, convenience store, hair care, hardware store, 

pocket park or playground, health club or outdoor recreation facility, laundry or dry cleaner, 

library, medical/dental office, pharmacy, place of worship, policy/fire station, restaurant, 

coffee shop, deli/bakery, school, senior care facility, shoe repair, grocery store, social service 

facility, theater. 

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4. Proportion of households and proportion of jobs within 1/4 mile of local public transit 

(including both bus and rail) or 1/2 mile of a regional public transit, that has less than 15 

minute frequencies 

EVIDENCE BASE 


The greatest pedestrian “capture rate” is when transit stops are within a 10 minute walk from home 

or office, have frequent headways, and are close to a dedicated transit right-of-way. lxxiii 

Accessibility of transit to both homes and workplaces provides the opportunity for a number of 

different health benefits. High per capita traffic fatality rates as well as the increase of diseases related 

to sedentary lifestyles both contribute to the poor health outcomes and high costs of care in the 

U.S.. li Recent analysis by Todd Litman of the Victoria Transportation Policy Center li of the health 

benefits of public transportation in the U.S. found that: 

Current demographic and economic trends (aging population, rising fuel prices, increasing health 

and environmental concerns, and rising medical care costs) are increasing the value of public 

transportation health benefits; 

Inadequate physical activity contributes to numerous health problems, causing an estimated 

200,000 annual deaths in the U.S., and significantly increasing medical costs. Among physically 

able adults, average annual medical expenditures are 32 percent lower for those who achieve 

physical activity targets ($1,019 per year) than for those who are sedentary ($1,349 per year); 

Public transit reduces pollution emissions per passenger-mile, and transit-oriented development 

provides additional emission reductions by reducing per capita vehicle travel; 

Traffic casualty rates tend to decline as public transit travel increases in an area. Residents of 

transit-oriented communities have only about a quarter the per capita traffic fatality rate as 

residents of sprawled, automobile-dependent communities; 

Neighborhood design features that support transit, such as walkability and mixed land use, also 

support public health. Of people with safe places to walk within ten minutes of home, 43 percent 

achieve physical activity targets, compared with just 27 percent of less walkable area residents. 

Alternatively, the more time a person spends in a car, the less time that person has to engage in 

leisure time physical activity. lxxiv Each additional hour spent in a car per day is associated with a 6 

percent increase in the likelihood of obesity. Each additional hour walked per day is associated with a 

4.8 percent reduction in the likelihood of obesity. lxxv 

Frequency of public transit service is an important predictor of whether people use and rely on 

transit as an alternative to driving alone for daily trips. Shifts from driving to transit use can decrease 

vehicle miles traveled at a regional level - with potential health benefits including reductions in air 

pollution and greenhouse gas emissions as well as injuries and deaths in motor vehicle collisions. At 

the local level, increases in transit use and decreases in personal vehicle trips can reduce local traffic 

volumes and benefit local air quality, reduce traffic related noise levels, and decrease traffic hazards to 

pedestrians and bicyclists. Shifts to transit from driving also support increases in physical activity 

through walking and biking trips to get to transit, and its related benefits to physical and mental 

health. Safe, quality public transportation systems also support social interaction and community 

cohesion. lxxvi 

Access to public transportation is currently low. Nearly 60 percent of the U.S. population lives in 

major metropolitan areas of over 1 million, but only 8.3 percent of households have access to major 

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subway service, and over 50 percent of Americans do not live within one-quarter mile of a transit 

stop. lxxvii A study in Seattle showed that for every quarter mile increase in distance from a transit stop 

to home, the odds of taking a transit trip decreased by 16 percent. A quarter mile increase in distance 

from transit to work reduced the likelihood of taking transit to work by 32 percent. lxxviii 

* For research regarding the health impacts of access to work and thus income see Metric #9- 

Percent of household income consumed by housing and transportation combined. 


While public transit use has benefits such as increased physical activity, public transit infrastructure in 

most US cities is not as convenient as vehicle transport, and those who do not have the option to 

buy a car may have a disadvantage, particularly elderly people and families with young children. 

Residents in low-income communities are less likely to own a car and more likely to rely on public 

transportation, lxxix lxxx and therefore often have longer commutes. People of color are also more likely 

to use transit and carpooling to get work, increasing the likelihood of longer commute times. lxxxi 

Costs and inaccessibility to public transit are barriers to accessing one’s workplace and other 

resources. Other barriers include poor sidewalk quality, no sidewalks, lack of proper signage, and 

absence of bus shelters or benches. As transportation expenditures continue to rise, the amount 

households have to spend on housing, food, health care, insurance, education, and other needs 

decreases. Prohibitive transportation costs can interfere with employment prospects, economic selfsufficiency, 

and access to needed goods and services including health care and food. Providing 

affordable public transportation, particularly to transit dependent and low-income communities, is 

one way to address these inequities in access that negatively impact health. lxxxii 

Of special concern also are rural communities. Two-thirds of rural Americans – 60 million people – 

are almost wholly not served by public transportation. lxxxiii 

It is therefore critical to ensure that communities not only have access to transit in order to reach 

jobs and needed services, but also that this transit is affordable. When modeling accessibility, 

different modes of public transportation, such as local buses, commuter buses, light rail and 

commuter rail, need to be disaggregated. When aggregated, the resulting analysis may suggest 

communities have access to transit that is, in actuality, high-fare and unaffordable, and rail service 

expansion may come at the cost of affordable local bus service. 

METHODOLOGY 

Enumerate both bus and rail public transit stops with less than 15 minute frequencies from local 

transit authorities; Estimate distance between stops and each household/job or intersection location. 

Using GIS network analysis so that true distance to transit is captured rather than “as the crow flies” 

will avoid underestimates of travel distance. 

MPOs should use their region-specific Travel Demand Models that include data on residents, jobs 

and transit for this performance metric and use the local transit authorities to gather information on 

transit frequency. 

RESOURCES 

Transit access and transit frequency methodologies: 

Example of transit access methodology: SFDPH-HDMT Indicator ST.2.b Proportion of households 

with 1/4 mile access to local bus or rail link http://www.thehdmt.org/indicators/view/52 

Examples of transit frequency methodologies: 

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MTC Appendix C: Regional Snapshot Analysis Detailed Methodology. 

http://www.mtc.ca.gov/planning/snapshot/Appx%20C-Detailed%20Methodology.pdf 

SFDPH-HDMT: Indicator ST.2.c Local transit service frequency, morning peak commute 

http://www.thehdmt.org/indicators/view/223 

OnTheMap is a tool by the U.S. Census's LEHD project that maps a number of different layers, 

including education, transportation and workforce categories: http://lehdmap.did.census.gov/ 

The National TOD Database is a GIS platform that includes every fixed-guideway transit system in 

the U.S. and demographic and land-use data for the half-mile radius around all stations: 

http://toddata.cnt.org/ 

LIMITATIONS 

Proximity does not necessarily equal accessibility. Lower income communities tend to rely more 

heavily on public transportation and modes of transportation used to access work are dependent 

upon numerous variables. Among many others, these may include cost, perceived and actual safety, 

lack of pedestrian facilities and signage, weather, pedestrian access and safety, traffic patterns, 

availability of bicycle lanes and racks, hours of operation, availability of parking, and availability of 

travel stipends/incentives provided by work or to low-income families. lxxxiv 

An additional concern is the aggregation of transit modes in some Travel Demand Models. 

Aggregating bus and train transit together assumes that low-income residents can afford to commute 

to jobs on high-cost transit like BART in San Francisco. As a result, when rail service increases, it is 

likely to show increased transit accessibility for low-income communities, and affordable bus services 

may be cut. 

STANDARDS 

We can look to transit-oriented design guidelines for some standards. While they do not directly 

address the metric of proportion of housing and jobs near transit, they can supply guidance. 

The Metropolitan Transportation Commission (MTC) in the Bay Area established corridor 

thresholds for amount of housing that would support different types of public transit in the MTC 

Resolution 3434 TOD policy for regional transit expansion projects. lxxxv 

BART 3,850 units 

Light Rail 3,300 units 

BRT 2,750 units 

Commuter Rail 2,200 units 

TOD Design Guidelines Matrix lxxxvi 

Average Jobs/Housing Mix 

Urban Core – 10 jobs per 1 dwelling unit 

Urban general - 5 jobs per 1 dwelling unit 

Mix of Uses (% residential, % non-residential) 

Urban Core - 20% residential and 80% non-residential 

Urban General – 50% residential and 50% non-residential 

Jobs/Acre 

Urban Core – 500 jobs/acre 

Urban General – 75-150 jobs/acre 

California TOD Housing Program Guidelines. lxxxvii Net density for housing: 

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Large city downtown: 

Urban center 

All other areas 

60 units per acre 



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5. Proportion of daily trips less than 3 miles and less than 1 mile by mode 

(walking/biking/bus and rail transit/driving) 

EVIDENCE BASE 

Analysis of national data regarding daily travel found that half of all trips in metropolitan areas are 

three miles or less and 28 percent are one mile or less; in rural areas 30 percent of all trips are two 

miles or less. lxxxviii Yet a majority (65 percent) of one-mile trips in metropolitan areas are still made by 

automobile. lxxxix Research also demonstrates that proximity to public transit helps to determine travel 

choice. xlviii 

While neighborhoods characteristics shape travel mode choice, xc the “5-D factors” xci also promote 

transit ridership when they occur near rail transit stations. The "5 Ds" include: 

1) Net-Residential Density – "denser developments generate fewer vehicle-trips per dwelling 

unit than less dense developments"; 

2) Job-Housing Diversity – "having residences and jobs in close proximity will reduce the 

vehicle-trips generated by each by allowing some trips to be made on foot or by bicycle"; 

3) Walkable Design – "improving the walking/biking environment will result in more nonauto 

trips and a reduction in auto travel" (with synergistic effects with density and 

diversity); 

4) Destinations – "households situated near the regional center of activity generate fewer 

auto trips and vehicle-miles of travel"; 

5) Distance to Rail Mass Transit Station – "transit ridership rates among station-area 

residents increase exponentially as the distance to a rail station declines. Land use and 

transportation planning that does not incorporate the above factors contributes to 

increases in miles driven in motor vehicles, along with the associated hazards from air and 

water pollutants, noise, and vehicle collisions. Heavy volumes of local vehicle traffic also 

create traffic “hotspots” and contribute to unfair burdens of air pollution, noise, and stress 

for those living adjacent to busy streets and highways, and degrade the environment for 

walking, biking, and public transit.” 

* Further discussion of the health and equity aspects of access to public transit and different mode 

share can be found in Metrics #4, 6 & 7. 


African Americans widely report low levels of leisure time physical activity. xcii xciii While the benefits 

of physical activity have been discussed elsewhere in this document (see Metric #6) one outcome of 

low levels of physical activity is an increased rate of obesity. Racial differences in risk factors are 

established early; evidence from one study found that by age 4, 13 percent of Asians and 16 percent 

of whites were obese, compared to 21 percent of blacks, 22 percent of Hispanics and 31 percent of 

American Indians. xciv In women in the U.S., body weight is inversely related to socioeconomic 

status. xcv Multiple studies have found that the lack of recreational facilities and concerns about 

personal safety can discourage exercise. xcvi xcvii 

Although the prevalence of obesity is higher for black than for white women, obesity is more 

strongly related to mortality for white than for black women. xcviii xcix One study focused on assessing 

the challenges to maintaining a healthy weight found that transportation difficulties, physical settings 

offering little opportunity for physical activity, food insecurity and rural isolation were all factors 

contributing to obesity among rural, economically disadvantaged women. c 

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Another population suffering from high rates of obesity is adolescents. Approximately 50% of U.S. 

youth do not currently meet the public health recommendations for frequency and vigorousness of 

physical activity. ci cii ciii 

METHODOLOGY 

MPOs should use their region-specific Travel Demand Models to measure this metric. 

RESOURCES 

Metropolitan Transportation Commission. Planning Section. Transportation 2035 Plan For the San 

Francisco Bay Area Travel Forecasts. Data Summary, Table E22. Oakland, CA: MTC, December 

2008. p. 121-125. 

STANDARDS 

Every decade, Caltrans conducts a statewide travel survey. civ The update is in process now, but from 

the last survey, we can provide some benchmarks. In California, the proportion of total trips made to 

and from different sources is included in the following table. While not included here, the tables also 

report out the proportion of trips that drivers make to and from different sources, and the 

proportion of “person trips” taken to and from difference sources. This source also includes the 

breakdown by MPO region for all regions in the state. 

From To Percent 

Home Other 41% 

Other Other 15% 

Home Work 23% 

Home Shop 11% 

Work Other 10% 

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GENERAL TRANSPORTATION 

METRIC: GENERAL TRANSPORTATION 

6. Daily amount (in minutes) of work-trip and non-work trip related physical activity 

EVIDENCE BASE 

Health impacts 

Walking to work helps people meet minimum requirements for physical activity. Americans using 

public transit spend a median of 19 minutes daily walking to and from transit; twenty-nine percent 

achieve at least 30 minutes of physical activity a day by walking to and from transit. xlix However, 

commuting to work makes up only 15 percent of the daily travel trips people take; forty-five percent 

of daily trips are for shopping/errands and 27 percent are social and recreational. cv Numerous health 

benefits could result if individuals walk or bike during all or a portion of these trips. The benefits of 

physical activity include a reduced risk of premature mortality and reduced risks of coronary heart 

disease, hypertension, selected cancers, obesity and diabetes. cvi cvii cviii cix cx cxi Regular participation in 

physical activity also reduces stress, depression and anxiety, improves mood, and enhances ability to 

perform daily tasks throughout the life span. cxii cxiii Additionally, walking and biking as forms of 

transportation do not contribute to noise or air pollution emissions. 

Even with all the known benefits of regular physical activity, in 2003 only 53 percent of Americans 

achieved 30 minutes of moderately vigorous activity at least 5 days a week and approximately 23 

percent of Americans had no leisure-time physical activity within the past month. cxiv Physically 

inactive people are twice as likely to develop coronary heart disease as regularly active people and 

heart disease is the leading cause of death among men and women in the United States. cxv Sedentary 

lifestyles and inactivity can also lead to overweight/obesity. cxvi Persons who are overweight or obese 

are at increased risk for high blood pressure, type 2 diabetes, coronary heart disease, stroke, 

gallbladder disease, osteoarthritis, sleep apnea, respiratory problems and some types of cancer. 

Equity impacts 

Residents in low-income communities are less likely to own a car and rely on public transportation to 

a greater extent. cxvii cxviii Nationally, people of color tend to have longer commutes than the white 

population, with a lower share of African-Americans, Asians and Hispanics enjoying commutes 

under 20 minutes and a higher share of people of color having “extreme commutes” over 60 

minutes. cxix People of color are also more likely to use transit and carpooling to get work, increasing 

the likelihood of longer commute times. cxx VMT and commute times correlate with obesity and have 

an inverse relationship to amount of physical activity. cxxi cxxii A study of adults in Chicago found that 

“people of lower socioeconomic status tend to walk more frequently, but also tend to live in 

neighborhoods that discourage walking.” cxxiii Costs and inaccessibility to public transit are barriers to 

accessing one’s workplace and other resources. 

METHODOLOGY 

Because traveling between the home and work and running errands are daily events for most people, 

and because many adults in this country do not meet the minimum requirement for daily exercise, we 

support a performance metric related to the amount of physical activity people obtain during their 

daily travel trips. 

MPOs could consider using an activity-based model to calculate the amount of physical activity from 

daily work and non-work trips. The Metropolitan Transportation Commission in the Bay Area is 

developing such a process, although it is not complete yet. More information about the MTC’s 

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Activity-based model development is available at: 

http://www.mtc.ca.gov/maps_and_data/datamart/abm/. 

We suggest MPOs using either the American Community Survey (ACS) or the National Household 

Transit Survey (NHTS) (in conjunction with regional transportation surveys, if available) to calculate 

this metric. 

Using the time distribution by mode, the ACS gives the number of persons spending a threshold 

number of minutes it takes to get to work. Using a standard threshold (e.g., 15 minute or more), 

calculate the amount of physical activity for walking and bicycling, when available. The ACS is 

collected every 3 years on the city level. 

If using the NHTS, disaggregate work and non-work trips. Calculate daily duration of walking 

and cycling trips per capita by dividing the daily minute totals by mode by the number of 

persons, yielding average trip times. Both the 2001 and 2009 NHTS data contain information 

regarding bike and pedestrian travel modes by work and non-work trips. The NHTS is available 

at the state- and Metropolitan Statistical Area (MSA)-level and conducted every 5-7 years. 

Additional add-on samples, along with random national samples collected in the add-on area, are 

available for purchase and compiled into a cleaned geocoded database for ready application to 

local planning and forecasting. 

LIMITATIONS 

Few MPOs currently have created the capability to capture this indicator using an activity-based 

model. 

ACS Limitations: The ACS only captures trips taken to work (and not all daily travel trips). If 

commute trips involve more than one mode, respondents are asked to report the mode used for 

most of the trip distance. Also, bicycling is included with motorcycling as a mode, so the ACS cannot 

give an accurate estimate of physical activity from biking. 

NHTS Limitations: Because the NHTS is a national probability sample, the data is not very reliable at 

the city level. It is possible to purchase add-on data for specific metropolitan regions, which would 

add statistical reliability to the sample. 

RESOURCES 

Journal articles using the NHTS for transportation decision-making: 

http://nhts.ornl.gov/2009/pub/Compendium.pdf 

Example calculation of bike/pedestrian physical activity using NHTS: Pucher J, Buehler R, 

Merom D & Bauman A (2011). Walking and Cycling in the United States, 2001-2009: Evidence 

From the National Household Travel Surveys. American Journal of Public Health, 101, in press 

[Epub ahead of print]. 

Example calculation of transit-associated walking times using the NHTS: Besser LM & 

Dannenberg AL. (2005). Walking to public transit: Steps to help meet physical activity 

recommendations. American Journal of Preventative Medicine, 29(4): 273–280. 

 

For more information regarding CDPH methodology (replicating the London Woodcock Active 

Transportation modeling), contact Neil Maizlish, PhD, MPH. California Department of Public 

Health at Neil.Maizlish@cdph.ca.gov 

STANDARDS 

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The Surgeon General recommends that adults engage in moderate-intensity physical activity five 

times per week for at least 30 minutes each time, or in vigorous-intensity physical activity three times 

per week for at least 20 minutes each time, in order to achieve adequate levels of physical activity. cxxiv 

Healthy People 2020 cxxv 

The U.S. Department of Health and Human Services (USDHHS) Healthy People 2020 provides 

science-based, 10-year national objectives for improving the health of all Americans. By 2020, the 

following should be achieved: 

Physical Activity 

Objective PA-2: Increase the proportion of adults who meet current Federal physical activity 

guidelines 

for aerobic physical activity of moderate intensity; 

Objective PA-13: Increase the proportion of trips made by walking; 

Objective PA-14: Increase the proportion of trips made by bicycling. 

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METRIC: GENERAL TRANSPORTATION 

7. Work and non-work trip mode share (including biking, walking, transit (bus and train), 

carpooling and SOV) – Both at peak times and all day 

EVIDENCE BASE 


Commute travel between the home and the workplace, as well as non-work related trips, is a good 

indicator of environmental impacts, physical activity, obesity, social cohesion, and mental health. The 

extent of these impacts depends on transit mode. Vehicle miles traveled are directly proportional to 

air pollution and greenhouse gas emissions. xlviii Air pollutants, including ozone and particulate 

matter, are causal factors for cardiovascular mortality and respiratory disease and other illness. cxxvi 

Greenhouse gases contribute to climate change, which may increase the following: heat-related illness 

and death, health effects related to extreme weather events, health effects related to air pollution, 

water-borne and food-borne diseases, and vector-borne and rodent-borne disease. cxxvii The more time 

a person spends in a car, the less time a person has to engage in leisure time physical activity. cxxviii 

Transportation choices impact obesity. Each additional hour spent in a car per day is associated with 

a 6 percent increase in the likelihood of obesity. Each additional hour walked per day is associated 

with a 4.8 percent reduction in the likelihood of obesity. cxxix 

Driving to work is a significant cause of stress for many people, so reduced commuting time could 

lead to decreased stress levels. cxxx Highway congestion has been associated with elevated blood 

pressure among car or bus drivers. cxxxi Some studies have looked specifically at “commute 

impedance,” such as traffic jams, and road construction. Researchers have concluded that traffic 

impedance is associated with higher blood pressure, more self-reported “tense” and “nervous” 

feelings, more self-reported colds and flu, and more days at the hospital. cxxxii 

Long commutes can distance an individual from his/her community and decrease social connectivity. 

Amount of time spent commuting impacts time for family and social activity. cxxxiii Social connectivity 

helps manage stress, and is connected with longer lifespan and access to emotional and physical 

resources. cxxxiv cxxxv Drivers in the Southern California region have especially long work trip travel 

times. For example, Los Angeles and Riverside were ranked by the U.S. Census as having the fourth 

and fifth highest percentages of people with “extreme” commutes of longer than 90 minutes per day 

(5 percent and 3 percent, respectively), cxxxvi and 20 percent of those living in the larger Los Angeles 

region commute more than 45 minutes each way to work. cxxxvii 

It is important to note that building or expanding freeways, thereby adding lane miles, has not 

proven to be a long-term solution to congestion. It can, in fact, exacerbate the problem by inducing 

travel. cxxxviii cxxxix cxl cxli cxlii 

The health impacts of biking and walking as modes of transportation are discussed above in Metric 

#6. 


The different modes of transportation used to access work, as well as other goods and services, are 

influenced by a number of factors including cost, distance, accessibility, perceived and actual safety, 

weather, pedestrian safety, traffic patterns, availability of bicycle lanes, hours of operation, availability 

of parking, and availability of travel reimbursement or incentives provided by work or to low-income 

families. cxliii Lower income, transit-dependent households who work in industries that do not have 

regular 9 to 5 working hours are much more vulnerable to reductions in off-peak transit service. Jobs 

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in the health care, retail, food and personal service, and hospitality industries, for example, have 

fewer educational requirements but also require odd hour commutes. These industries also tend to 

have less flexible working hours, making transit-dependent lower income households are more 

vulnerable to travel delays. 

Residents in low-income communities are less likely to own a car and rely on public transportation to 

a greater extent. lxxix People of color are more likely to use transit and carpooling to get work, 

increasing the likelihood of longer commute times. cxliv Costs and inaccessibility to public transit are 

barriers to accessing one’s workplace and other resources. Commute distance can be an indicator of 

travel costs: longer commutes are generally associated with higher costs of gas, vehicle wear and tear, 

and/or public transit fares. Low-income populations spend a higher proportion of their income on 

travel costs associated with commuting, and thus bear this cost burden to a greater degree. 

METHODOLOGY 

MPOs should use regional transportation surveys or region-specific travel demand models to analyze 

mode share. If MPOs do not have modeling capabilities, the National Household Travel Survey 

(NHTS) collects data on daily trips by mode. 

RESOURCES 

Monitoring & Forecasting: Forecasting pedestrian and bicycle travel demands using travel demand 

model and mode share/trip length data: http://www.bicyclinginfo.org/library/details.cfm?id=4461 

Forecasting: An M & Chen M. (2007). Estimating Nonmotorized Travel Demand. Transportation 

Research Record, 2002: 18-25. 

LIMITATIONS 

As mentioned above, because the NHTS is a national probability sample and the data is not very 

reliable at the city level. It is possible to purchase add-on data for specific metropolitan regions, 

which would add statistical reliability to the sample. 

STANDARDS 

Caltrans conducts a statewide travel survey once a decade. They are in the process of conducting the 

survey now, but using data from the 2000-2001 CA Statewide Travel Survey, we can see the weekday 

mode share split for the entire state. cxlv 

All weekday trips Commuter trips 24 hour Commuter trips 

7-9 am 

SOV trips 69% 83% 85% 

Driving with passengers 19% 10% 8% 

Public transportation 2% 3.4% 3.8% 

School bus 2% N/A N/A 

Bike 0.7% 0.7% 0.6% 

Walk 7% 2.6% 2.4% 

In 1992 when the city of San Diego was rolling out its TOD Design Guidelines, they targeted an 

“ambitious” 40 percent non-auto mode split goal. cxlvi 

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FUTURE GROWTH 

METRIC: FUTURE GROWTH 

8. Growth of population, housing, and jobs in transit priority areas 

a. Share of housing growth in transit priority areas, targeting measures of how many 

large (3-4) bedroom, senior housing, and low-income units will be built 

b. Proportion of projected population growth located in transit priority areas 

c. Proportion of projected jobs in transit priority transit areas 

EVIDENCE BASE 


Transit-oriented development (TOD) is effective for regional reducing vehicle use and associated air 

pollutant emissions (including greenhouse gas) and noise, and for improving traffic safety, access to 

goods and services, and access to schools and jobs. Provided that local air quality and traffic collision 

impacts near TOD sites are mitigated, this metric is positively associated with health. 

Transit-oriented development can increase physical activity. cxlvii In San Francisco, transit 

neighborhoods had 120 percent more trips by walking or biking to work than did auto-orientated 

neighborhoods. Mode share for work trips by pedestrians was between 1.2 and 10.6 percent 

higher for the transit neighborhoods. In Los Angeles mode share for walking to work was 1.7 to 

24.6 percent higher in the transit neighborhoods. cxlviii 

A dense mix of uses, well served by mass transportation systems, can ensure access to essential 

goods and services while reducing vehicle miles traveled (VMT), thereby reducing environmental 

and health costs associated with personal vehicle trips. cxlix 

Transit-oriented development is generally positive for health at the regional level but local health 

impacts may not always be positive. Due to decreasing amounts of urban land available for infill, 

many of these developments are now placed close to freeways and their associated air pollution and 

noise. Additionally, access to public transit stops can increase local traffic, leading to an increase in 

risk for pedestrian and bicycle injury. 

Transit-oriented development areas can be associated with increased vehicles on a local level, 

even as it reduces vehicle miles traveled overall. Consequently, high VMT per capita leads to 

higher accident and injury rates associated with vehicle-vehicle, vehicle-pedestrian, and vehiclebicycle 

collisions. cl In addition, there are typically more pedestrians in dense TOD areas, which 

leads to greater risk of pedestrian collisions. cli 

While transit-oriented development is often associated with reduced vehicle trips and VMT 

regionally, it can be associated with greater air pollution locally. clii 


Increasing the share of growth in transit accessible areas can have positive or negative outcomes for 

low-income people and people of color, depending on the other policies in place. 

Positive equity impacts include: 

Decreased transportation costs. Building more affordable housing near transit allows more 

people to take advantage of the transportation cost savings provided by these locations. cliii 

Increased economic opportunity. As more jobs are accessible by transit, low-income workers 

(who may already be living in transit-rich neighborhoods) may be able to take transit to those 

jobs. Nationally, the number of households earning $35,000 and under is 10 percentage points 

higher in neighborhoods around transit than it is in the transit zones’ host regions. cliv 

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Negative impacts are also possible if proactive policies and planning measures are not in place: 

Because many transit areas have a higher share of low-income households, negative public health 

impacts (e.g., pedestrian injuries) could have a disproportionate affect on those families. 

In addition, there are significant current and historical environmental injustices related to lowincome 

communities and communities of color having disproportionate exposures to hazardous 

air quality associated with freeways, which may be perpetuated by increasing growth in places 

with these characteristics. clv 

The demand for housing near transit is equally strong amongst all income groups. clvi New 

development, including transit-oriented development, can lead to a risk of displacement for 

existing low-income populations. This can be mitigated by providing affordable housing in TOD 

areas clvii and by stabilizing rent prices for local small businesses. 

METHODOLOGY 

Through the SB375 Sustainable Communities Strategy process, MPOs should use their regionspecific 

analysis of housing, population and workforce growth in proposed transit priority areas. 

RESOURCES 

Brookings Institute Report: State of Metropolitan America – On the front lines of demographic 

transition 

http://www.brookings.edu/~/media/Files/Programs/Metro/state_of_metro_america/metro_a 

merica_report.pdf 

This report uses the Census Bureau’s Population Estimates Program. Using data from the last 

decennial census, more recent national surveys, and administrative records at all levels of 

government, the Population Estimates Program produces annual estimates of population, and its 

“components of change” (natural increase, domestic migration, and immigration), for all 

incorporated municipalities, counties, and states nationwide. The program also estimates state and 

county populations by age and race/ethnicity annually. 

http://www.census.gov/popest/topics/schedule.html 

ABAG (The Association of Bay Area Governments) is responsible for making long-term 

forecasts or population, housing, and employment for the nine-county Bay Area. These forecasts 

assist local governments in planning for our changing environment. ABAG produces updated 

forecasts every 2 years and publishes them as Projections. In recent updates, the Projections 

forecasts have presented a realistic assessment of growth in the region, while recognizing trends in 

markets and demographics, while also recognizing local policies that promote more compact 

infill- and transit-oriented development. http://www.abag.ca.gov/planning/currentfcst/ 

STANDARDS 

See standards suggested for Metric #4. 

Frank & Pivo’s 1995 study on the impact of smart growth on modal shift clviii may offer useful 

benchmarks: 

Nearly all travel is done by car until residential density reached 13 persons per acre; 

Employment density levels greater than 75 employees per acre is necessary before there is a 

substantial increase in transit and pedestrian travel for work trips. 

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ECONOMIC 

METRIC: ECONOMIC 

9. a) Percent of household income consumed by housing and transportation combined; b) 

Percent of income going towards housing costs; c) Percent of income going towards 

transportation costs 

EVIDENCE BASE 


Income is one of the strongest and most consistent predictors of health in the public health research 

literature. clix clx As transportation and housing costs rise, the less money households have to spend on 

medical resources (health care and health insurance), healthy food, schooling costs, leisure activities 

and exercise. clxi 

Prevalence of obesity and Type 2 diabetes is higher among groups with the lowest levels of income 

and education, living in deprived areas. clxii Additionally, individuals with less income are more likely 

to report experiencing traumatic life events as well as the harmful psychosocial effects of 

neighborhood violence or disorder, residential crowding, and struggles to meet daily challenges with 

inadequate resources. 

clxiii clxiv clxv clxvi 


The distribution of income has become increasingly concentrated among a smaller segment of people 

in the United States over the past decades, and the gap between the highest and lowest-earning 20 

percent continues to grow. clxvii Racial/ethnic inequities in income are particularly striking. In 2004, for 

example, the median household income was approximately $30,000 among blacks and nearly $50,000 

among whites. clxviii 

While public officials, renters, homeowners and bankers often use 30 percent of a household’s 

income as the benchmark of affordability, this measure omits transportation costs, which can vary 

significantly by neighborhood, city and region. In order to obtain affordable housing, people often 

live far away from work, believing they’ll save money on housing costs. However, the time and 

money spent on long commutes can place further stress on tight budgets. clxix In the Los Angeles 

metro area, 46 percent of communities would be considered affordable using the standard measure 

of 30 percent of income. However, this statistic drops to only 29 percent when both housing and 

transportation costs are considered. clxx Low-income households living in the city cores of the Bay Area 

and/or near transit tend to have a much lower housing and transportation costs than households 

living in outer areas. clxxi In neighborhoods highly susceptible to gentrification, housing and 

transportation costs that are disproportionately high indicate that residents are unlikely to be able to 

stay in the absence of supportive housing policies and may be more likely to be displaced. clxxi 

The lack of affordable housing constrains choices about where families and individuals live, often 

relegating lower-income families to the periphery and/or to substandard housing in unsafe, 

overcrowded neighborhoods with higher rates of poverty and fewer resources like parks, bike paths, 

recreation centers and other health promoting activities. clxxii This type of housing instability also has 

health impacts. One study found that children living in areas with higher rates of unaffordable 

housing tend to have worse health, more behavioral problems and lower school performance. clxxiii 

METHODOLOGY 

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The Center for Neighborhood Technology (CNT), in collaboration with the Center for Transit- 

Oriented Development, has devised a methodology to estimate how much households of different 

income levels pay for both housing and transportation (H+T). clxxiv The CNT’s Housing + 

Transportation Affordability Index covers most regions in California. We recommend that MPOs 

use the CNT’s methodology in order to measure these affordability metrics. 

RESOURCES 

CNT H+T Affordability Index: http://www.htaindex.org/index.php. 

LIMITATIONS 

While a majority of California has been analyzed by CNT's H+T Affordability Index, there are some 

rural areas that have not been captured. Also, data instability at the block group level make estimates 

at that level of specificity unreliable. Therefore we recommend that MPOs use the H+T 

methodology and their region-specific data, when available. 

STANDARDS 

Housing: Federal standards for housing affordability suggests no one should spend more than 30 

percent of household income on housing (rent and utilities). Households that spend more than 50 

percent of their income on their homes are classified by the National Low Income Housing Coalition 

as severely cost-burdened. clxix 

Transportation: CNT has found 18 percent of Area Median Income (AMI) to be an attainable 

standard for transportation affordability and have set 15 percent as a goal. clxxv 

Housing & Transportation: Combining the 15 percent level with the 30 percent housing affordability 

standard, CNT recommends that 45 percent of AMI be established as the affordability target for 

combined housing and transportation costs in the U.S. clxxv Page 88 of 165 

52

ENVIRONMENTAL POLLUTION 

METRIC: ENVIRONMENTAL POLLUTION 

c. For all daily trips, per capita miles traveled by mode (walking, biking, transit, vehicle) 

EVIDENCE BASE 

Transit mode share is an indicator of how many people are driving, driving alone, taking public 

transit, or using active transportation such as biking or walking. 


There are a variety of negative health outcomes associated with increased amounts of driving. These 

include increased stress and musculoskeletal injuries as well as health outcomes associated with noise 

and air emissions, and a decrease in physical activity and social cohesion. 

For example, less driving means more time for physical activity and therefore reduced obesity 

rates. In a landmark study, each additional hour spent in a car was shown to be associated with a 

6 percent increase in the likelihood of obesity, and each additional hour walked was associated 

with a 4.8 percent reduction in obesity. clxxvi clxxvii VMT and commute times correlate with obesity 

and have an inverse relationship to amount of physical activity. clxxviii clxxix 

Also, time spent driving puts drivers at risk for musculoskeletal pain. People who drive more 

have higher odds of shoulder pain compared to those who spend less time driving. People who 

drive 9,000 – 18,000 annual miles are 75 percent more likely to have neck and back pain than 

those who travel 3,000 miles annually. clxxx 

Vehicle trips are a significant cause of stress for many people. clxxxi 

Higher VMT impacts time for family and social activity. clxxxii Social connectivity helps manage 

stress, and is connected with longer lifespan and access to emotional and physical resources. clxxxiii 

clxxxiv 

Building or expanding freeways in an effort to reduce time spent driving, and thereby adding lane 

miles, has not proven to be a long-term solution to congestion and can, in fact, exacerbate the 

problem by inducing travel. clxxxv clxxxvi clxxxvii clxxxviii clxxxix Transportation Demand Management 

strategies lead to better health outcomes than road expansions. 

Higher traffic volume increases the risk of pedestrian, cyclist and motorist injury and death, with 

pedestrians, cyclists, and motorized two-wheeled vehicle users bearing a disproportionate share 

of road injury burden. xlviii cxc 

The Environmental Protection Agency’s Greenhouse Gas (GHG) Emissions Inventory for the 

U.S. showed that in the 1990s GHGs from mobile sources increased 18 percent, primarily from 

VMT. cxci California has less coal in it’s electricity mix, so the transportation sector is the largest 

source of emissions; thus transportation was responsible for 38 percent of California’s GHG 

emissions in 2004. cxcii 

There are positive as well as negative health outcomes associated with use of alternative modes of 

transportation: 

Americans who use public transit get more exercise. 

o Public transit users spend a median of 19 minutes daily walking to and from transit; of these 

individuals, 29 percent achieve at least 30 minutes of physical activity a day by walking to and 

from transit. xlix cxciii 

o In fact, 16 percent of all recorded walking trips are part of transit trips, and these tend to be 

longer than average walking trips, according to an analysis of U.S. travel survey data. cxciv 

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o When comparing train commuters to car commuters, train commuters averaged 30 percent 

more walking, more frequently reported walking for 10 minutes or more, and were 4 times 

more likely to achieve 10,000 daily steps recommended for fitness and health. cxcv 

o Transit users average 1.05 daily miles of walking a day – ten times more than the 175 yards 

of walking averaged by non-transit users. cxcvi 

o This level of physical activity enables people to reach the Centers for Disease Control’s 

recommended amount of daily physical activity simply by taking public transit. cxcvii Meeting 

recommended levels of physical activity lowers risks for obesity, cardiovascular disease, 

diabetes, cancers, depression, and can increase strength for bone health. cxcviii Higher use of 

public transit has been shown to be beneficial for air quality and decreases greenhouse 

gases. cxcix 

More active transport increases the amount of physical activity people get. Walking and biking 

have direct health benefits, for example lower rates of premature mortality, heart disease, 

diabetes, high blood pressure, colon cancer, depression and anxiety, obesity, osteoporosis, and 

psychological well-being. cc 

Using public transportation also offers more opportunities for decreasing isolation by 

encouraging casual contact from unplanned social interactions. Mortality rates of socially isolated 

people are two or more times the rates of people with more social support. cci 

Increased use of car sharing has been shown to reduce vehicle travel by 47 percent and increased 

use of public transit, walking and cycling. ccii 

There are increased rates of crime near subway stations, however this increased risk as well as 

perception of safety can potentially be mitigated. cciii 

Active transport is associated with increased exposure to pedestrian or bicycle injury, but with 

well-designed communities, this risk can be mitigated. 


Lower income residents are less likely to own automobiles – about 26 percent of low-income 

households do not own a car compared to 4 percent of other households. Thus, lower-income 

residents are more likely to use public transportation; 5 percent of lower-income households use 

public transit vs. 2 percent of other households. Also, lower-income residents are more likely to walk; 

5 percent of lower-income households report walking to work and work-related trips vs. 3 percent 

for other households. cciv Those walking and biking and taking transit can gain all of the health 

benefits associated with those modes. 

Low-income households also spend a higher percentage of their income on transportation costs than 

high income households. ccv Car ownership can be estimated to cost a household about $5,000 

annually, including the costs of gas and insurance. Households that take more transit, or walk and 

bike, spend less than this on transportation. 

METHODOLOGY 

MPO-specific Travel Demand Models include information on per capita miles traveled by mode. 

RESOURCES 

For an example of an MPO data set and forecast of number of trips by mode by trip length, see the 

Bay Area’s Metropolitan Transportation Commission (MTC)’s Change in Motion analysis, available 

at http://www.mtc.ca.gov/planning/2035_plan/tech_data_summary_report.pdf (pg 110). This 

analysis gives some level of background methodology in the text portion and tables defining their 

performance measures for the 2009 Regional Transportation Plan: Vision 2035. Table D4 beginning 

on page 81 is also of interest for this metric. 

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STANDARDS 

Walking & biking 

The Surgeon General recommends that adults engage in moderate-intensity physical activity five 

times per week for at least 30 minutes each time, or in vigorous-intensity physical activity three times 

per week for at least 20 minutes each time, in order to achieve adequate levels of physical activity. ccvi 

Averages across California and in different regions are supplied here as a level at which to compare 

each region’s performance. 

CA: 0.8% of people biked to work (in SF county 1.7%, in LA county 0.6%, in Placer County 

0.4%) 

CA: 2.7% of people walked to work (in SF county 7%, in SF county 2.8%, in Placer County 

 

1.5%) ccvii 

Metropolitan Transportation Commission. Low-income households in the Bay Area have an 

average of 11 minutes per day of physical activity due to active transport currently. Non lowincome 

households in Bay area haveare 9 minutes per day currently. 

Public transit 

In the 2005 – 2007 American Community Survey of the U.S. Census: 5% of Californians took 

public transit. ccviii 

In 2008 in the U.S., transit participation grew between 3% – 16%. In California overall, there was 

a 6% increase in transit ridership in 2008, and a corresponding 5% decrease in VMT. A report 

about the impact of high gas prices on transit ridership suggests a “high but realistic” goal of 

increasing public transit ridership by 10%. ccix 

Vehicle Miles Traveled (VMT) 

According to Caltrans Data Branch, in 2005, the average VMT per capita in California counties 

was 5,053. ccx 

Rural counties had much higher VMT; in the 10 counties with highest VMT per capita had an 

average population of just under 23,000 people. In the 10 counties with lowest VMT per capita 

included Los Angeles, Orange, Santa Clara, Sacramento, and San Francisco. 

o Bay Area: 5,407 per capita per month 

o Solano: over 8,000 

o San Francisco: 1,752 

o Average for Los Angeles, Riverside, Orange: 4,858 

o Los Angeles: 4,034 

o Riverside: 5,861 

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d. Working with a local public health department, university and/or air quality 

management district: Estimate pre-mature mortality attributed to traffic-related ambient 

PM 2.5, and estimate asthma incidence and asthma exacerbations attributed to traffic 

related NO2. 

EVIDENCE BASE 


Epidemiologic studies have consistently found that proximity to high traffic density or flow results in 

reduced lung function and increased asthma hospitalizations, asthma symptoms, bronchitis 

symptoms, and medical visits. ccxi Children appear to be the most sensitive to adverse effects. 

California freeway studies show exposure levels approach background levels after a distance of 500 

feet from a freeway. ccxii Specific epidemiologic research findings include: 

Reduced lung function in children associated with traffic density, especially trucks, within 1,000 

feet and the association was strongest within 300 feet. ccxiii 

Increased asthma hospitalizations associated with living within 650 feet of heavy traffic and 

heavy truck volume. ccxiv 

Increased asthma symptoms with proximity to roadways, with the greatest risk within 300 

feet. ccxv 

Asthma and bronchitis symptoms in children associated with high traffic in a San Francisco Bay 

Area community with good overall regional air quality. ccxvi 

 

 

Increased medical visits in children living within 550 feet of heavy traffic in San Diego. ccxvii 

In a prospective study of 3399 participants in Germany, living within 150m of major roads is 

associated with an increased risk of coronary heart disease over time even after adjusting for 

individual risk factors and background air pollution. ccxviii 

Living in close proximity to busy roadways 

Children living in close proximity to busy roadways have been found to suffer from increased 

respiratory disease symptoms and asthma, and reduced lung function. ccxix ccxx ccxxi ccxxii ccxxiii ccxxiv ccxxv 

ccxxvi ccxxvii ccxxviii Studies also show higher rates of cardiovascular and respiratory disease among adults 

living near freeways, particularly for those living within 75 - 650 feet of heavy traffic and heavy truck 

volume. ccxxix ccxxx ccxxxi ccxxxii ccxxxiii Long-term exposure to traffic-related air pollution is associated with 

an increased risk of lung cancer, ccxxxiv and diabetics exposed to air pollution have an increased risk for 

heart disease. ccxxxv ccxxxvi Additionally, living in areas with high levels of air pollution is a disincentive 

to exercise, ccxxxvii and exercise reduces risks for heart disease, diabetes, osteoporosis, and stress-related 

anxiety and depression. ccxxxviii CARB recommends not locating sensitive land uses within 500 feet of a 

highway that has traffic in excess of 100,000 vehicles per day. ccxxxix 

PM 2.5 and health outcomes 

Motor vehicle emissions, power plants, and refineries are the predominant sources of fine particulate 

air pollution (PM2.5). Several large-scale studies demonstrate that increased exposure to PM2.5 is 

associated with detrimental cardiovascular outcomes, including increased risk of death from ischemic 

heart disease, higher blood pressure, and coronary artery calcification. ccxl ccxli ccxlii 

Research in some locations based on measurements of fine particulate matter (PM 2.5) has found 

that a significant share of spatial intra-urban air pollution variation in ambient levels of PM 2.5 is due 

to local traffic sources, ccxliii and that traffic density explains variation in local and regional PM 2.5 

concentrations. ccxliv ccxlv Individual epidemiological studies have linked roadway proximity or vehicle 

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emissions to impairments of lung function; ccxlvi asthma symptoms; ccxlvii ccxlviii ccxlix medical visits for 

asthma; ccl asthma prevalence and incidence; ccli cclii ccliii ccliv cclv and ischemic heart disease. cclvi cclvii 

Nitrogen Dioxide and health outcomes 

While traffic pollution comprises a diverse mix of chemicals, NO 2 is a good proxy measure for 

cumulative exposure. The Health Effects Institute states that a good surrogate for traffic should have 

the following attributes: (1) traffic should be its major source; (2) emissions vary with motor vehicle 

type; (3) it can be measured reasonably accurately at low concentrations, and is inexpensive; and (4) it 

does not have independent health effects. cclviii NO 2 can feasibly be measured at a large number of 

locations, and it has been widely used as a proxy for the mixture of traffic-related pollutants that vary 

markedly depending on distance from roadways, season, wind speed, and wind direction. cclix cclx cclxi 

Research from the Los Angeles region shows that ambient NO 2 within 150 meters was associated 

with 2.18 times the risk of new-onset asthma in children. cclxii Further research shows that there is an 8 

percent increased risk of asthma diagnosis with early life exposure to NO 2 (150 meters from highway 

and 50 meters from major road) and a 12 percent increased risk of asthma diagnosis with early life 

exposure to NO 2 . cclxiii 


Poorer residents and people of color are more likely to live near roadway sources of air pollution. In 

California, the proportion of children of color living in high traffic density blocks is inversely related 

to median family income, and children of color are three times more likely to live in high-traffic areas 

than white children. cclxiv Thus, poorer children of color are more likely to be disproportionately 

exposed to respiratory-disease causing emissions. 

METHODOLOGY 

Regarding premature mortality related to PM2.5: Find the population weighted average 

transportation-attributable PM2.5 concentration and NO 2 (either by measurement or estimate by 

modeling e.g., CAL3QHCR or AERMOD Dispersion model using local traffic volumes, vehicle 

emissions models, topography, meteorology). Estimate parcel level population as share of total area 

residential building volume. To find premature mortality, asthma incidence and asthma 

exacerbations, apply the Exposure-Response Function (ERF) to population exposure. Use California 

ARB consensus on PM2.5-Mortailty ERF. 

Regarding asthma incidence and exacerbations related to NO 2 : contact Human Impact Partners for 

further assistance and information. Kim Gilhuly, kim@humanimpact.org. 

MEASUREMENT RESOURCES/EXAMPLES 

 

 

 

SFDPH: Air Quality Measurement and Modeling: 

http://www.sfphes.org/HIA_Tools_Air_Quality.htm 

Bhatia, R & Rivard, T. (2008). Assessment and Mitigation of Air Pollutant Health Effects from 

Intra-urban Roadways: Guidance for Land Use Planning and Environmental Review. 

http://www.sfphes.org/publications/Mitigating_Roadway_AQLU_Conflicts.pdf 

BAAQMD 2010: Estimation of health effects as related to PM2.5. 

http://www.baaqmd.gov/~/media/Files/Planning and Research/Plans/2010 Clean Air 

Plan/Resource and Tec/Multi-Pollutant Evaluation Method Technical Document-April 

2010.ashx 

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CARB 2009: Methodology for Estimating Premature Deaths Associated with Long-term 

Exposure to Fine Airborne Particulate Matter in California. 

http://www.arb.ca.gov/research/health/pm-mort/pm-mort_final.pdf 

Human Impact Partners Health Impact Assessments using air modeling and health prediction 

methodology (both available at http://www.humanimpact.org/past-projects): 

- Pittsburg Railroad Ave. Specific Plan Health Impact Assessment 

- San Pablo Avenue Corridor 

SFDPH Road Pricing HIA. http://www.sfphes.org/HIA_Road_Pricing.htm 

Resource for NO2 and asthma incidence/exacerbations: Chen, Lisa C. (2011). A Method to 

estimate the cumulative impact of traffic-related pollution on childhood asthma: A meta-analysis. 

(Master's thesis) Berkeley: University of California, School of Public Health. 

For a copy of this paper, please contact Kim Gilhuly, kim@humanimpact.org 

STANDARDS 

Healthy People 2020 cclxv 

Respiratory Disease Objectives 

Reduce asthma deaths 

RD 1.1 Reduce asthma deaths in children under age 5 years 

o Baseline: There were 3.4 asthma deaths per million children under age 5 years in 

2007 

o Target: None listed; assuming target of 0 deaths for children 

RD 1.2 Reduce asthma deaths in people age 5 - 64 years 

o Baseline: There were 11 asthma deaths per million in people age 5 - 64 years in 

2007 

o Target: 6 deaths per million in children and adults age 5 - 64 years 

RD 1.3 Reduce asthma deaths in adults age 65 and over 

o Baseline: There were 43 asthma deaths per million in adults over age 65 years in 

2007 

o Target: 23 deaths per million in adults over age 65 years 

Reduce hospitalizations for asthma 

RD 2.1 Reduce asthma hospitalizations in children under age 5 years 

o Baseline: There were 41 asthma hospitalizations per 10,000 children under age 5 

years in 2007 

o Target: 18 asthma hospitalizations per 10,000 children under age 5 years 

RD 2.2 Reduce asthma hospitalizations in children and adults age 5 - 64 years 

o Baseline: There were 11 asthma hospitalizations per 10,000 in children and adults 

age 5 - 64 years in 2007 

o Target: 9 deaths per 10,000 in children and adults age 5 - 64 years 

RD 2.3 Reduce asthma hospitalizations in adults age 65 and over 

o Baseline: There were 25 asthma hospitalizations per 10,000 adults over age 65 

years in 2007 

o Target: 20 hospitalizations per 10,000 adults over age 65 years 

Reduce hospital emergency department visits for asthma 

RD 3.1 Reduce asthma hospitalizations in children under age 5 years 

o Baseline: There were 133 asthma hospitalizations per 10,000 children under age 5 

years in 2007 

o Target: 96 emergency department visits per 10,000 in children under age 5 years 

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RD 3.2 Reduce asthma hospitalizations in children and adults age 5 - 64 years 

o Baseline: There were 56 asthma hospitalizations per 10,000 children and adults 

age 5 – 64 years in 2007 

o Target: 49 emergency department visits per 10,000 in children and adults age 5 – 

64 years 

RD 3.3 Reduce asthma emergency department visits per in adults age 65 and over 

o Baseline: There were 21 asthma emergency department visits per 10,000 adults 

over age 65 years in 2007 

o Target: 13 emergency department visits per 10,000 in adults over age 65 years 

California and Federal Air Quality Standards are provided in the following table: 

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Source: CARB. 2007. California Ambient Air Quality Standards. California Air Resources Board. Available at 

http://www.arb.ca.gov/research/aaqs/aaqs2.pdf. 

The California Air Resource Board, Air Quality and Land Use Handbook: A Community Health 

Perspective ccxii provides the following recommends for locating sensitive receivers near sources of air 

pollution: 

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CARB 2005 Guidance on Preventing Air Quality—Land Use Conflicts 

Source of Air Pollution 

Air Resource’s Board Recommendations 

Freeways and High- 

Traffic Roads 

Distribution Centers 

Rail Yards 

Ports 

Refineries 

Chrome Platers 

Dry Cleaners Using 

Perchloro-ethylene 

Gasoline Dispensing 

Facilities 

Avoid siting sensitive land uses within 500 feet of a freeway, urban roads with 

100,000 vehicles/day, or rural roads with 50,000 vehicles/day. 

Avoid siting sensitive land uses within 1,000 feet of a distribution center (that 

accommodates more than 100 trucks per day, more than 40 trucks with operating TRUs 

per day, or where TRU unit operations exceed 300 hours per week). 

Take into account the configuration of existing distribution centers and avoid locating 

residences and other sensitive land uses near entry and exit points. 

Avoid siting sensitive land uses within 1,000 feet of a major service and maintenance rail 

yard. 

Within one mile of a rail yard, consider possible siting limitations and mitigation 

approaches. 

Consider limitations on the siting of sensitive land uses immediately downwind of ports 

in the most heavily impacted zones. 

Consult with local air districts for the latest available data on health risks associated with 

port emissions. 

Avoid siting sensitive land uses immediately downwind of petroleum refineries. 

Work with local air districts to determine an appropriate separation. 

Avoid siting sensitive land uses within 1,000 feet of a chrome plater. 

Avoid siting sensitive land uses within 300 feet of any dry cleaning operation. For large 

operations with two or more machines, provide 500 feet. 

Do not site sensitive land uses in the same building with perc dry cleaning operations. 

Avoid siting sensitive land uses within 300 feet of a large gas station (defined as a facility 

with a throughput of 3.6 million gallons per year or greater). A 50 foot separation is 

recommended for typical gas stations. 

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e. Proposed housing near busy roadways will require: 

a. Assessment by local air district or public health department of the need for 

environmental/health impact analysis when housing is proposed near (within 1,000 

feet) busy roadways (over 100,000 Average Annual Daily Traffic (AADT)) or other 

significant pollution sources (e.g., rail yards, port terminals, refineries, power plants, 

etc); and 

b. Best practice mitigation requirements by local governments when the above 

assessment determines that environmental quality is below standard for such 

proposed housing, and if such housing is determined to be safe by local air districts 

and public health departments with identified mitigation. 

For MPOs representing highly urban regions, we suggest an alternate metric due to the ongoing 

concern about the lack of developable land, the need for housing, and equity concerns about placing 

low-income residents near polluting emissions of cars and trucks. 

Alternate Metric 12: Working with a local public health department, university and/or air 

quality management district: 

c. Estimate the number of sensitive sites (homes, schools, daycares, parks, etc.) within 

1,000 feet of freeways and other major pollution sources, based on standards such as 

BAAQMD’s listed below (“Standards”). 

d. Estimate proportion of affordable housing units vs. market rate units within above 

identified areas. 

EVIDENCE BASE 

Health and Equity Impacts 

See Metric # 11 for health and equity evidence. 

METHODOLOGY 

1) The MPO should engage the local air district or public health department to assess need for 

environmental/health impact analysis according to protocol similar to the Bay Area’s CEQA 

guidelines for all development located within 1,000 feet of busy roadways (see Resources below for 

link to detailed methodology) 

2) The MPO should document whether local general plans and other policies require mitigations for 

housing proposed in areas with poor air quality. 

This metric has raised some concerns about the potential conflict between the health dangers of 

placing homes and other sensitive uses near busy roadways and the need and desire in urban areas of 

California to create infill development that is often near freeways, in particular affordable housing 

options. Because there has been an ongoing statewide conversation regarding this issue, an effort was 

made to solicit input about which indicator would be best. Many organizations and agencies that 

have been most involved in the statewide discussion participated in the decision on this health and 

equity metric. Those organizations and agencies were: the American Lung Association of California, 

the California Department of Public Health, the Natural Resources Defense Agency, ClimatePlan, 

the Bay Area Air Quality Management District, the Sacramento Air Quality Management District, 

Housing California, the Sacramento Council of Governments, the San Diego Association of 

Governments, the Los Angeles County Public Health Department, Human Impact Partners, the 

Environmental Health Coalition, the Coalition for Clean Air, Reconnecting America, Prevention 

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Institute, Public Health Law and Policy, the San Mateo County Health Systems, the Central Valley 

Air Quality Coalition, and East Yard Coalition for Environmental Justice. 

Methodology for Alternate Metric 12 also exists. The San Francisco Department of Public Health 

has worked closely with the Bay Area Air Quality Management District to conduct hot spot analysis 

in the City and County of San Francisco to guide healthy development. 

RESOURCES 

 

 

 

 

 

Bay Area Air Quality Management District. CEQA Guidelines. Tools and Methodology. 

http://www.baaqmd.gov/Divisions/Planning-and-Research/CEQA-GUIDELINES/Toolsand-Methodology.aspx 

Example mitigation recommendations: SFDPH HDMT (see "Policies/Design Strategies") 

http://www.thehdmt.org/objectives/view/55 

San Francisco’s Air Quality Ordinance and Frequently Asked Questions: 

http://www.sfphes.org/Policy_Air_Quality.htm 

Lepe, C. 2008. Addressing air quality related health impacts associated with siting residential 

development near high traffic roadways in California and the city of San Jose. Master’s Thesis, 

Dept. of Urban Planning. San Jose State University. For a copy of this resource email Kim 

Gilhuly at kim@humanimpact.org. 

San Francisco Department of Public Health Environmental Health: Air Quality: Assessment. 

Planning, Policy Development, and Regulation. Article 38 addition to San Francisco Health 

Code. Available at http://www.sfdph.org/dph/EH/Air/default.asp 

STANDARDS 

The Natural Resources Defense Council has compiled the following list of policies and thresholds 

for action regarding siting of housing near busy roadways. 

Geographic Scope, 

Agency, and Start 

Date 

Recommended 

Distance 

Threshold or Trigger Process 

Bay Area Air Quality 

Management District, 

2011 

San Francisco, Dept. of 

Public Health, 2008 

Sacramento Air Quality 


2011 

South Coast Air Quality 


2005 

1,000 ft of permitted 

source, a highway, or 

roadway w/ >10,000 

AADT 

150m of a road >100,000 

AADT; 100m of road 

>50,000 AADT; 50 m of 

road >10,000 AADT 

500 ft of roads with 

100,000 AADT, urban or 

50,000 AADT, rural 

“close proximity” 

0.3 ug/m 3 PM2.5; 10 

additional cases of 

cancer/million; >1.0 

non-cancer Hazard 

Index, chronic or acute. 

0.2 ug/ m 3 average 

annual exposure from 

roadway vehicles within 

150m buffer of sensitive 

receptor 

Increased individual 

cancer risk of 

276/million 

CEQA thresholds 

published in 2011: P10 - 

110 lbs/day; PM2.5 – 55 

CEQA requirements for 

screening relative to 

thresholds; Health 

Impact Assessment 

required if over 

thresholds + mitigation 

Health Effects Analysis 

and Hierarchy of 

Mitigations 

Site-specific Health Risk 

Assessment. Estimate 

cancer risk at 6 model 

receptors 50, 100, 200, 

300, 400, and 500 ft 

from source roadway. 

Report cancer risk 

publicly. 

Consider mitigations 

such as separating source 

and receptor, decreasing 

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Los Angeles County 

DRAFT General Plan 

2035 

Los Angeles City “Green 

Zones” under 

consideration by the 

Council for some EJ 

neighborhoods, 2011 

San Diego Air Pollution 

Control District (county) 

“Discourage” 

development within 500 

ft of freeway 

Select environmental 

justice neighborhoods in 

LA City 

None 

lbs/day; max increase in 

cancer risk 10/million; 

hazard index > 1.0 

N/A 

Does the proposed 

project affect a sensitive 

receptor (not defined as a 

residence) as determined 

by the environmental 

analyst? If so, use AAQS 

as guideline. 24 hr 

standard 35 ug/m 3. , 

annual arithmetic 

mean12 ug/m 3 

CARB Statewide, 2005 500 ft of roadway California and National 

Ambient Air Quality 

Standards for PM2.5; 24 

hr standard 35 ug/m 3. , 

annual arithmetic 

mean12 ug/m 3 

source emissions, siting, 

permitting and zoning 

policies, and capping 

cumulative impacts of 

various pollution 

sources. 

“Encourage mitigation” 

for sites within 1500 ft 

of freeway 

Prepare an EIR 

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EQUITY 

METRIC: EQUITY 

f. Measure and stratify all indicators by race/ethnicity; income; geography (neighborhood, 

census block or tract, or Community of Concern); age; disability. 

EVIDENCE BASE 


Neighborhoods are shaped by specific policies that guide development and, consequently, individual 

well-being. cclxvi A growing body of research demonstrates a strong relationship between health and 

the environments in which people live. The disproportionately high rates of heart disease, asthma, 

diabetes, and other chronic diseases among residents living in high-poverty neighborhoods – often 

disproportionately residents of color cclxvii – can be linked to many aspects of the built environment, 

including access to healthy foods and physical activity, quality affordable housing, and transportation 

options. Such cumulative inequities can have dire health outcomes. For example, African American 

children growing up in high-poverty urban neighborhoods (such as Harlem or Chicago’s South Side) 

are more likely to die or become disabled far before reaching old age; in these neighborhoods, onethird 

of African American girls and two-thirds of boys who reach their fifteenth birthdays do not live 

to celebrate their sixty-fifth. cclxviii cclxix In comparison, only 10 percent of girls and about 25 percent of 

boys nationwide fail to live to age sixty-five. cclxx 

Alameda County is an example of an area of California with large differences in placed-based health 

outcomes. A recent report by the Alameda Department of Public Health highlighted the ways 

inequities clustered in certain neighborhoods over time. cclxxi Through their research they found: 

Compared with a White child in the Oakland Hills, an African American born in West Oakland 

is 1.5 times more likely to be born premature or low birth weight and seven times more likely to 

be born into poverty. 

As a toddler, this child is 2.5 times more likely to be behind in vaccinations. By fourth grade, this 

child is four times less likely to read at grade level and is likely to live in a neighborhood with 

twice the concentration of liquor stores and more fast food outlets. 

As an adult, he or she will be five times more likely to be hospitalized for diabetes, twice as likely 

to be hospitalized for and to die of heart disease, and twice as likely to die of cancer. This person 

can also expect to die almost 15 years earlier than a White person born in the Oakland Hills. 

West Oakland residents also breathe air that contains three times more diesel particles than in 

the rest of the Bay area. 

Alameda County households earning less than $20,000 per year spend over half of their income 

on transportation. 

The United States spends more than any other nation in the world on health care. cclxxii Yet despite 

consistent increases in spending, health disparities among different demographic groups persist. 

David Satcher, former Surgeon General of the United States, stated that “Although critical to 

eliminating disparities, access [to health care] only accounts for 15 to 20 percent of the variation in 

morbidity and mortality that we see in different populations in this country.” cclxxiii In order to address 

the root causes that account for the other 80 to 85 percent of poor health, we must look beyond 

health care and health insurance and towards the policies that affect where we live, how we get to 

work, what we eat and the air we breath. 

Because each of the proposed Health & Equity metrics has the potential to affect various 

populations differently, and often disproportionate burdens accumulate in low-income populations 

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and populations of color, we recommend that disparities be specifically measured. We advocate that 

social equity be integrated into each performance metric, and we have built equity considerations into 

each of the recommended metrics within this analysis. We recommend stratification by 

demographics (e.g., race/ethnicity, income, age, and/or other indicators of vulnerability to health 

risks) as well as place-based (i.e., neighborhood) stratification within all performance metrics. 

METHODOLOGY 

Not only is it important to understand the equity dimensions of each metric, but also the cumulative 

impact across all the metrics. Through the Strategic Growth Council, California Department of 

Public Health has developed indicators of Healthy Communities. As part of that process CDPH has 

proposed three different composite scores that are used to demonstrate levels of equity with regard 

to race/ethnicity, income and place. Depending on data availability, each equity score can be applied 

city-, county-, or region-wide by drawing on information from census tracts and individuals. We 

suggest that MPOs use a similar analysis in order to stratify the proposed metrics by these equity 

dimensions and identify communities with high or low levels of equity. 

LIMITATIONS 

Not all data is available at the stratified level. We recommend that future data be collected so that it 

can be stratified to assess equity issues. 

RESOURCES 

For more information regarding CDPH methodology, contact Neil Maizlish, PhD, MPH. California 

Department of Public Health at Neil.Maizlish@cdph.ca.gov. 

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HOW TO USE THE HEALTH AND EQUITY METRICS 

These metrics can be used in a variety of ways to elevate the consideration of the health 

and equity impacts in the RTP/SCS processes going on around the state. 

When can I use Health and Equity Metrics? 

There are a variety of places in the SCS decision making process where you can request 

that health and equity be considered through the use of these metrics. Throughout their 

planning processes, MPOs invite stakeholder input: 

Visioning for the RTP/SCS. MPOs typically have a period of time in which 

they reach out to the public in a structured way to get input on what the 

RTP/SCS should look like. Use the health and equity metrics as a comment 

about how the RTP/SCS should consider these important outcomes. 

Performance Measures. MPOs develop a set of performance measures and 

then score alternative scenarios for their RTP/SCS, including transportation 

projects that they might fund over the next 25 years, against these measures. 

Suggest that MPOs incorporate the health and equity metrics as performance 

measures. 

Baseline analysis. The RTP/SCSs include an analysis of Existing Conditions. 

Including health and equity metrics in the Existing Conditions analysis is 

important because the RTP/SCSs gets updated every three years, and thus so 

does the Existing Conditions analysis. Evaluating the metrics regularly would 

serve as a way to show how each metric had changed based on the 

transportation projects that had been implemented. 

Release of the RTP/SCS. When the RTP/SCS is released publicly, the MPO 

will seek stakeholder and community feedback. At this time, you can evaluate 

what has been included and what still needs to be included, with regard to 

health and equity. 

Environmental Impact Review. When the RTP/SCS is ready, the MPO will 

conduct an environmental impact review of it. This is another public process 

with several different points for suggesting different ways to analyze prospective 

changes due to the proposals included in the RTP/SCS. The health and equity 

metrics can be evaluated as part of the environmental review process. 

Local planning processes. There may be ways through County 

Transportation Commissions or city planning agencies to also suggest the use of 

the health and equity metrics in evaluating individual projects. Sometimes these 

bodies make the decisions around dispersion of funds, and also require 

environmental impact analyses and community participation in planning. 

How can I interact with MPOs? 

There are many ways to interact with MPOs or other planning bodies. Every region is 

different, and thus the openness to public input varys. MPOs are required to accept 

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stakeholder input and tend to be open to doing so. They may do so through a variety of 

means, including: 

Community engagement workshops. The creation and vetting of the 

RTP/SCS is a long process that has many points along the way where MPOs 

are required to solicit stakeholder engagement. For example, in the Southern 

California Association of Governments’ RTP/SCS planning process, they are 

holding 18 community meetings in the different counties of the region to vet 

alternative scenarios. Go to a community engagement workshop and speak up 

about health and equity using these metrics. 

Subcommittee meetings. Many MPOs divide the work into separate 

committees, so researching the different subcommittees and attending their 

meetings is another way to suggest use of these metrics. 

One on one meetings with MPO staff. Finding the staff person responsible 

for the RTP/SCS and meeting with them about the incorporating the health 

and equity metrics is a powerful way to suggest use of the metrics as well as hear 

back about what is possible for the MPO. 

Meetings with MPO Board members and other decision-makers. MPO 

staff is very important and can shape suggestions to the Board members and 

subcommittees. However, ultimately the Board of the MPO will be making the 

final decisions, so reaching out to them is important as well. Boards have 

representatives from different districts and different agencies, so strategically 

planning with coalition members about how to reach them all is important. 

Comment letters. Sending in comment letters before key decisions is an 

effective way to advocate for inclusion of the metrics. MPOs are required, at 

different times, to respond to public comment. 

Media. A strategic way to reach decision-makers and staff is by placing stories 

in local or statewide media. It is not always the right strategy, as sometimes your 

message may not be conveyed clearly by a reporter. 

Who can help if I have questions? 

There are organizations that are engaged statewide in these discussions with MPOs, and 

are also connected to local public health agencies and groups in each region. These 

include: 

Climate Plan: http://www.climateplan.org/ 

American Lung Association of California: 

http://www.lungusa.org/associations/states/california/ 

Prevention Institute: http://www.preventioninstitute.org/ 

Public Health Law and Policy: http://www.phlpnet.org/ 

Natural Resources Defense Council: http://www.nrdc.org/ 

68 

Page 104 of 165

Appendix: Metrics recommended for future study 

Metric 

Population exposed to ambient 

noise >55dB (WHO community 

standard) 

Basic pedestrian and bicycle 

infrastructure 

Participation in RTP planning 

process throughout all stages. 

Pollutants generated by travel 

(CO, NOx, PM2.5, PM10, Sox, 

VOC, ozone, diesel emissions) 

Reason for exclusion and research 

recommendation 

Methodology exists to model noise exposure on a local level, 

however, it is resource intensiveness led to its exclusion, . 

MPOs should work with health experts and others to 

develop an efficient way to do this, as well as consider 

regional level noise 

If MPOs don’t measure this, they cannot plan for it. For this 

reason, we suggest that MPOs research best and most 

efficient practices for assessing pedestrian and bicycle 

infrastructure quality. It was excluded in the final version 

due to current resource constraints and lack of an agreedupon 

methodology, however models exist, such as the 

Pedestrian Environmental Quality Index and the Bicycle 

Environmental Quality Index from SFDPH. 

Have full participation in RTP planning processes. Potential 

ways of measuring this could include public documentation 

of notes from meetings including attendance (number and 

what groups/individuals attend); advocates’ scoresheets on 

participation in planning. This was excluded as partners 

recognized that this was not a “metric” but rather something 

that would be requested and monitored, but not written into 

RTP/SCS. 

Collecting pollutants is important. We recognize that 1. This 

information can be extrapolated from VMT per household 

and 2. MPOs do not collect this data sub-regionally. Thus it 

was excluded recognizing the methodological limitations 

currently. However, we recommend that MPOs partner 

with academics and other groups to investigate measuring 

methodologies that exist but might be time-consuming at 

this point, such as air quality modeling based on traffic 

counts for sub-regional prediction of pollutants. 

69 

Page 105 of 165

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cxxix Frank L, Andresen MA, Schmid TL. Obesity relationships with community design, physical activity, 

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cxxxi Wener R, Evans G, and Lutin J. (2006). Leave the driving to them: comparing stress of car and train 

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cxxxii Ibid. 

cxxxiii Putnam R. 2001. Bowing alone. Simon & Schuster. New York, NY. 

cxxxiv Berkman LF, Syme SL. 1979. Social networks, host resistance and mortality: a nine-year follow up 

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cxxxv Poortinga W. 2006. Social relations or social capital? Individual and community health effects of 

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cxxxvi U.S. Census. 2005. “Extreme” Commute Rankings: Cities. Available at 

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cxxxvii U.S. Census. American Community Survey. S0802. Means of Transportation to Work by Selected 

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cxxxviii Noland R. 2001a. Relationships between highway capacity and induced vehicle travel. 

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cxxxix Lomax T, Schrank DL. 2005. The 2005 Urban Mobility Report. College Station: Texas 

Transportation Institute, Texas A & M University. Available at http://mobility.tamu.edu. 

cxl Kang H, Scott DM, Kanaroglou PS, Maoh HF. 2009. An exploration of issues related to the study of 

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cxli Hansen M, Huang Y. 1997. Road supply and traffic in California urban areas. Transportation Research 

A 31:205-18. 

cxlii Noland R, Lem L. 2001b. A Review of the Evidence for Induced Travel and Changes in 

Transportation and Environmental Policy in the United States and the United Kingdom. Center for 

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cxliii San Francisco Department of Public Health. (2006). HDMT- Indicator ST.3.d Proportion of 

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cxliv Pisarski A. (2006). Commuting in America III: The Third National Report on Commuting Patterns 

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clxxxiv Poortinga W. 2006. Social relations or social capital? Individual and community health effects of 

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clxxxv Noland R. 2001a. Relationships between highway capacity and induced vehicle travel. Transportation 

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clxxxviii Hansen M, Huang Y. 1997. Road supply and traffic in California urban areas. Transportation 

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clxxxix Noland R, Lem L. 2001b. A Review of the Evidence for Induced Travel and Changes in 

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ccxxvi English P, Neutra R, Scalf R, Sullivan M, Waller L, Zhu L. 1999. Examining associations between 

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ccxxviii B, Janssen NA, de Hartog J, Harssema H, Knape M, van Vliet P. Air pollution from truck traffic 

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ccxlviii Lin, S. et al. “Childhood asthma hospitalization and residential exposure to state route traffic.” 

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http://www.acphd.org/user/data/DataRep_ListbyCat.asp?DataRepdivId=2&DataRepdivcatid=62 

82 

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cclxxii Office of the Actuary, Centers for Medicare and Medicaid Services (2007). National Health 

Expenditure, Data for 2007. U.S. Department of Health and Human Services. Available at: 

http://www.cms.hhs.gov/NationalHealthExpendData/02_NationalHealthAccountsHistorical.asp#T 

opOfPage 

cclxxiii Satcher D & Higginbotham EJ. (2008). The public health approach to eliminating disparities in 

health. American Journal of Public Health, 98(3): 400-403. 

83 

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Complete Streets Coalition of Sacramento 

Statement of Goals 

Sacramento Area Council of Governments (SACOG) on the 

Draft Metropolitan Transportation Plan (MTP) 


1. 20% Target for walk and bike trips: The Draft Metropolitan Transportation Plan (MTP) 

estimates that with the current project list, 12.1% of all non‐commute trips will be by 

walking or bicycling. We can do better. The plan should set a target of 20% of all trips 

by walking and bicycling. 

2. Set a timetable Complete Streets by 2024: The Draft MTP has no target for achieving 

Complete Streets in the Region. We think the Plan should achieve Complete Streets 

throughout the Region including a continuous bicycle/pedestrian network by 2024 – in 

the next 12 years! 

3. Make safety for walking and bicycling highest priority: The plan has no performance 

measures or targets for pedestrian or bicycle safety. We think safety for walkers and 

bicyclists is critical and should be integrated into all aspects of the MTP including 

performance measures for funding. 

We can do this by: 

• Investing sooner rather than later: By spending money now for pedestrian and bicycle 

infrastructure (frontloading) we can achieve the 20% or more sooner, we will all be 

healthier, and the air will be cleaner. 

• Integrating Complete Streets into all road maintenance and rehabilitation projects: By 

investing our road maintenance money prudently we can make many pedestrian and 

bicycle infrastructure improvements with minimal money. SACOG can develop a 

template for road rehabilitation programs that build in consideration of changes to the 

roadway markings – bike‐lane, pedestrian crossing markings, and even lane narrowing 

to achieve Complete Streets. 

• Learning lessons from other cities and countries: By finding out how other communities 

have achieved greater mode share, we can apply the lessons learned in our 

communities. 

• Tracking our progress: By keeping a score card of our improvements we can assess our 

progress both in infrastructure improvements and in mode change. 

• Planning for pedestrian and bicycle improvements: By developing, adopting and 

updating pedestrian and bicycle master plans in each of our Region’s jurisdictions, we 

can prioritize our investments to achieve Complete Streets jurisdiction by jurisdiction 

throughout the region. 

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Signed by: 

Argelia Leon, Policy Manager, Breathe California – Emigrant Trails 

Keith Roberts, Chair, Transportation, Air Quality and Climate Change Committee, 


Lindell Price, Resident of El Dorado County 

Marie Schelling, bicycle and pedestrian advocate 

Terry Preston, Complete Streets Coordinator, WALKSacramento 

Tricia Hedahl, Executive Director, Sacramento Area Bicycle Advocates 

Page 121 of 165


Chair Peter Hill 


Sacramento Area Council of Governments (SACOG) 



Re: Draft Metropolitan Transportation Plan/Sustainable Communities Strategy 2035 (MTP/SCS 2035) 

Dear Chair Peter Hill and Honorable Members of the SACOG Board of Directors: 

Thank you for your impressive work to advance regional planning and SB 375, California’s 

Sustainable Communities and Climate Protection Act. Beginning with its blueprint efforts and 

continuing through the current implementation of SB 375, SACOG has led the state and nation with 

cutting-edge regional planning and transportation planning. This leadership continues with this draft 

MTP/SCS 2035. Its strengths include: 

• By growing in strategic locations, and by boosting transit service along key arterial roads and in 

town centers, the plan dramatically increases the portion of jobs and housing near high quality 

transit, by around 150% and 200% respectively. Just as importantly, the jobs-housing balance will 

improve in 14 out of 15 job centers, allowing more people to walk or bike to work or to meet their 

daily needs. 

• The plan achieves SACOG’s goal of “doing more with less.” This MTP has 12.5% less funding 

than its predecessor, but through careful spending still makes great accomplishments: bike lanes 

increase by 77%; transit service nearly doubles; and transit frequencies improve to 10-15 minute 

frequencies on many key corridors, leading to weekday ridership more than doubling and 

significant increases in farebox revenues. 

• Congestion declines for the first time in any of its MTPs, by 7%, a dramatic turnaround from 

the worsening congestion planned for in 2002 (58%) and 2008 (22%). The region overshoots its 

2020 per capita greenhouse gas reduction target and achieves its 2035 target – the highest in the 

state. 

In the spirit of further strengthening a good plan and continuing one step further down the trajectory 

that this MTP/SCS creates for the region, we offer the following suggestions. 

717 K St., Suite 330 · Sacramento, CA 95814 · 916-441-0204 · info@climateplanca.org · www.climateplan.org 

Page 122 of 165

I. Ensure Transportation Projects Speed Toward a Complete Network of Transportation 

Choices for All Users 

In finalizing this Draft MTP/SCS 2035, SACOG should ensure it is doing all it can to create a 

complete system of active transportation and transit options. To achieve this goal, it should 

prioritize projects that help achieve regional goals in the early years of the plan, and align 

transportation project phasing with the timing of future development. Specifically, we 

encourage SACOG to: 

• Commit to adopting a Complete Streets Action Plan within two years, including a 

timetable and budget for completing a continuous bike/pedestrian network around the 

region. Just as SACOG does comprehensive regional planning for transit and for highoccupancy 

vehicle (HOV) lanes, we recommend that SACOG create a regional plan for a 

continuous and comprehensive network of bike/ped infrastructure. This plan should estimate a 

target completion date and a budget of funds necessary, and it should seek to have this network 

meet a stretch target for what percentage of all trips in 2035 would occur via active 

transportation. To create the Action Plan, SACOG should work with a full range of 

stakeholders to: 

o Encourage local jurisdictions to upgrade their pedestrian and bicycle master 

plans; 

o Identify high-priority active transportation improvements for local and regional 

circulation; 

o Work with local jurisdictions and other agencies to establish the desired timing 

for those improvements based on their location, value for regional connectivity, current 

and projected densities, and the location of key destinations such as schools and transit; 

o Identify the likely cost and funding gaps for those improvements; 

o Schedule regional funds to help fill funding gaps and ensure timely construction; 

o Identify policy shifts that could accelerate the timeline for those top priorities, 

such as continuing to prioritize those local bike/pedestrian circulation that will serve the 

most travelers (Strategy 29.1), and conducting systematic advance planning with local 

public works directors to ensure roadway maintenance achieves the maximum 

bike/pedestrian safety enhancement; and 

o Integrate these policies and investments into future TIPs and the next MTP/SCS, 

and fully analyze the health and air quality benefits of this comprehensive network. 

• Work with other agencies and local jurisdictions to identify and accelerate transit 

for high-density arterial corridors. In arterial corridors where transit service doesn’t currently 

exist, service would ideally begin as soon as a sufficient density of homes or jobs is built. In 

places where that density already exists, service should begin as soon as possible. SACOG 

should flag arterial corridors that currently lack this transit service or that may lack it at the 

time of housing or workplace construction, and then work with local jurisdictions and transit 

operators to find strategies and funding sources to accelerate service there. In addition, SACOG 

should carefully program its existing transportation funds to support transit expansion in these 

key corridors. SACOG assumes that new sales tax revenue will fund transit operations – an 

essential effort that we stand ready to support. In addition to working to secure additional funds 

for transit operations, in this MTP SACOG should (a) insert a strong policy commitment to 

support transit service at the time of development, (b) consider creating a placeholder for funds 


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that would specifically deploy transit equipment in new areas of growth, and (c) program 

existing transportation funds strategically to support and incentivize TOD. 

• Work with other agencies and local jurisdictions to flag and defer or cancel any 

costly transit capital projects that would begin construction before the densities would 

justify the cost. Defer these projects until sufficient densities are present and until bus service 

has proven that strong ridership demand exists, as suggested by Strategy 28.9. 

• Work with other agencies and local jurisdictions to ensure road construction does 

not trigger growth outside existing urban areas. Carpool lane extensions or other road 

widening at the urban edge should occur later in the plan, to ensure that they are not built 

prematurely but only after housing or workplace construction in the corridor has created 

transportation demand. Premature roadway construction could induce expansionary, inefficient 

growth patterns at the outer fringe and have substantial negative impacts. This can and should 

be avoided by carefully scheduling any road construction. 

• Continue to improve service for transit-dependent populations. SACOG should 

continue its efforts to help provide mobility for transit-dependent populations, including youth, 

seniors, lower-income, and disabled people. New policies should commit SACOG to work with 

transit providers toward better service for youth, to direct early MTP funding to projects or 

programs that advance regional equity, and to restore transit service to low-income 

communities and other areas where transit-dependent populations live and work. 

• Commit to a full transportation project review in the next MTP/SCS similar to 

MTC’s Project Performance Review, which examines how each project helps achieve the 

region’s health, equity and environmental goals. 

II. 

Measure What Matters 

A strong regional plan will not only reduce greenhouse gases but improve air quality and help regions 

become more equitable, healthier, and more sustainable. We are grateful that this MTP/SCS forecasts 

the outcomes of this plan on a number of these important indicators. Yet, other important measures 

were not included. SACOG should improve its ability to understand the wide-ranging impacts of land 

use and transportation decisions as follows: 

• Measure the draft plan’s impact on a wider range of performance measures. We believe that 

this MTP/SCS will likely result in significant public benefits that have not been identified; such 

analyses could help SACOG communicate the benefits of the plan – and help spur its successful 

implementation. Letters from the Coalition on Regional Equity and a collaborative of health 

organizations offer details on potential performance measures to examine. These might particularly 

include additional analyses around active transportation and the shorter trips and nearby services 

that make it possible; households within 1000’ of highways; housing plus transportation costs; 

daily amount (in minutes) of transportation-related physical activity; and an expanded equity 

analysis. To the extent possible, these analyses should be conducted prior to the plan’s adoption. 

• Commit to monitoring a broad set of indicators during the plan’s implementation in an 

annual or mid-cycle State of the Region report. Before ratifying this plan, SACOG should 

commit to monitoring a full suite of health, equity, and environmental indicators, such as injuries to 

cyclists and pedestrians, jobs-housing fit, the combined cost of housing and transportation, 


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gentrification/displacement, air quality and respiratory illness, transportation-related physical 

activity; and others. This should particularly include emerging performance measures that are 

difficult to forecast accurately. Monitoring these indicators could bolster implementation of the 

many positive steps in this MTP/SCS by showing the benefits it is creating for the region. 

• Commit to developing additional health and equity analysis tools to use in developing the 

next MTP/SCS. SACOG deserves praise for committing to develop several important tools, such 

as one for jobs-housing fit, and should strengthen this by committing to their availability by the 

next MTP/SCS cycle. SACOG should work to better understand and convey its decisions’ impacts 

on public health such as the impact of emissions on respiratory disease and on disadvantaged 

people throughout the region. 

• Commit to developing improved natural resource data and conservation strategies for 

integration into the next MTP/SCS. While RUCS is an innovative and impressive program, it is 

focused almost exclusively on agriculture alone, and habitat and other ecosystem services do not 

receive the same level of analysis in the MTP/SCS or corresponding DEIR. Considering historical 

development trends in the Sacramento region, the Blueprint will best be adhered to with the aide of 

corresponding strategies and incentives for preserving the lands outside of the anticipated urban 

footprint. Improved data and tools are needed to inform planning decisions and efficient investment 

for mitigation, conservation and development. 

III. 

Use Transit Priority Area Planning As A Springboard For Advancing Regional Goals 

Implementing this plan should be a high priority for the region, and SACOG deserves applause for its 

approach to implementation. The plan identifies and studies transit priority areas (TPAs) where transitoriented 

development will have the greatest impact. This effort will provide SACOG staff with greater 

knowledge about what best promotes health, equity, and sustainability around regional transit hubs. To 

leverage this work, we recommend SACOG commit to: 

• Include experts in promoting health, equity, and sustainability on each TPA’s action 

planning team to help community leaders find successful strategies for key goals. These teams 

should include expertise in these subjects, among others: safe active transportation; affordable 

housing, transportation justice; gentrification / displacement avoidance; community benefits of 

development; ensuring nearby access to daily needs; and public health. 

• Ensure each TPA Action Plan addresses a full range of important issues. SACOG plans to help 

each neighborhood set its own goals and create an action plan to achieve it. SACOG should 

complement this with a checklist of issues that it asks each team to consider, created through an 

inclusive public process, to ensure TPAs discuss key health, equity, and sustainability issues. This 

checklist should be created via public input and should include: 

o building new affordable housing; 

o creating safe routes to transit for children and adults, via an active transportation inventory; 

o stabilizing existing renters, homeowners, and local businesses; 

o facilitating community benefits such as income and asset creation; 

o helping higher-density infill projects receive community support, thereby removing 

pressure to develop natural areas and farmlands; and 

o exploring parking pricing options to remove the costs from those who choose to not drive. 


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• Identify a short set of performance measures and indicators to be used during Transit 

Priority Area planning. These should be a subset of the overall regional performance measures 

mentioned in the previous section, and should particularly focus on measures that are especially 

relevant to neighborhood-scale planning, such as gentrification/displacement, and households 

within walking distance of daily needs. 

• Identify and share lessons learned with local officials and stakeholders around the region. 

• Explore resources to speed the adoption of particularly important policies. SACOG should 

stand ready to provide funding or staff assistance to those jurisdictions who wish to adopt essential 

policies and meet certain performance thresholds. 

We again express our appreciation and gratitude to the Board and staff. Your efforts to implement SB 

375 can help reduce climate change and ensure that future generations of Californians have cleaner air 

and water, healthier places to live, a stronger and more resilient economy; and greater opportunity for 

people across the economic spectrum. 

Sincerely, 

Carl Anthony and Paloma Pavel, PhD 

Co Directors 

Breakthrough Communities 

Marice Ashe, JD 


Public Health Law & Policy 

Matthew Baker 

Habitat Director 


Autumn Bernstein 

Director 

ClimatePlan 


Land Use Policy Director 

Sacramento Housing Alliance 

Craig K. Breon 

Regional Climate Change Project Director 

Sierra Nevada Alliance 

Jeremy Cantor, MPH 

Program Manager 

Prevention Institute 

Stuart Cohen 


TransForm 

Terry Davis 

Director 

Mother Lode Chapter Sierra Club 

Teri Duarte, MPH 



Jonathan Heller 

Executive Director and Co-Founder 


Bonnie Holmes-Gen 

Executive Director, Air Quality & Public Health 

American Lung Association in California 

Matthew Marsom 

Vice President, Public Health Policy & Advocacy 

Public Health Institute 

Jessica Meaney 

California Policy Manager 

Safe Routes to School National Partnership 


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Liz O’Donoghue 

Director of Infrastructure and Land Use 

The Nature Conservancy 

James J. Provenzano 

President 

Clean Air Now 

Shamus Roller 


Housing California 

Dan Silver 


Endangered Habitats League 

Dave Snyder 


California Bicycle Coalition 

Jim Stone 


WalkSanDiego 

Ron Sundergill 

Sr. Director Pacific Region 

National Parks Conservation Association 

Cristina Tirado 

Director 

Center for Public Health & Climate Change 


Page 127 of 165

S A C R A M E N T O A R E A B I C Y C L E A D V O C A T E S 



SACOG Board of Directors 

SACOG, MTP/SCS 2035 

1415 L Street, Suite 300 


Subject: Draft MTP/SCS 2035 and Draft EIR on MTP/SCS 2035 

Dear SACOG Board of Directors and Executive Director Mike McKeever: 

Thank you for the opportunity to comment on both the Draft MTP/SCS 2035 

and its Draft EIR. We applaud SACOG for the extraordinary effort that has 

gone into conducting the analyses underlying the MTP/SCS and in 

presenting extensive amounts of information to the public. Particularly 

impressive was the advance in integrating land-use and transportation 

planning. 

We appreciate that per capita funding for bike/pedestrian projects has 

increased by 7% since the last MTP and that many of the roadway 

maintenance and rehabilitation projects are to include bike and pedestrian 

facilities. However, we are concerned by the very small increase in 

bike/pedestrian mode share that is projected over the 27-yr life of the plan 

(e.g. non-commute bike/pedestrian mode-share increases only from 10.6% 

to 12.1%; see Table 5C.7). Figure 5C.6 shows that the MTP/SCS 2035 does 

not accelerate the growth trend of historical “bike+walk” person trips between 

2008 and 2035. 

We understand that the MTP/SCS is a forecast, not a regulatory program. 

The MTP/SCS stands, however, as a valuable planning and implementation 

tool that can have great impact on actual conditions for bicyclists and 

pedestrians. Additionally, it guides the nature of projects that will be funded 

by SACOG. We have 3 key recommendations for improving the MTP/SCS 

2035 for bicycling in the region: 

1. We suggest that the MTP/SCS 2035 state an ambitious goal for 

bike/pedestrian mode-share of 20% for non-commute trips by 2035 

to reflect the broad and direct importance of non-vehicular travel options 

for improving community health, travel safety, air quality, energy 

efficiency, and overall mobility of all transportation-system users. In 

stating an ambitious goal for mode-share increase, the MTP/SCS 2035 

should focus on planning and investing in bicycle and pedestrian 

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infrastructure in those communities and with the types of facilities that will result in 

the biggest increases in mode-share. 

The following strategies will help achieve a 20% non-commute bike/pedestrian 

mode-share by 2035: 

Invest in bicycle and pedestrian infrastructure as soon as possible and 

during the planning period to begin reaping benefits in mode-share increase 

as soon as possible. 

 

 

 

Set an equally aggressive goal for increasing the densities of urban land use 

to make bike and pedestrian travel more viable, 

909 12 T H STREET, SUITE 116 SACRAMENTO, CA 95814 (916) 4 44-6 600 WWW.SACBIKE.ORG 

Focus funded projects on communities with high mode-shift potential 

such as mixed-use, high-density, and transit-priority areas. For example, 

Environmental Justice Areas have the highest existing mode share for 

bicycling and walking. EJA mode share is forecast to increase at 4 times the 

rate of the increase in bike/pedestrian mode-share in non EJAs (Table 8.9). 

Therefore, roadway and bike and pedestrian projects in EJA areas should 

receive much higher priority for early funding. 

Prioritize bicycle infrastructure improvements on low-volume/low-speed 

roadways and streets that will be much more attractive for bicycling by a 

broader swath of our population than on high-speed/high-volume arterials. 

2. The MTP/SCS 2035 should strengthen the Policies and Supportive Strategies 

presented in Chapter 6 to better focus on assuring “Complete Streets” are 

implemented wherever possible throughout the region. We believe that most 

MTP/SCS funded projects should have complete street elements and follow 

complete street principles. Nearly all transportation projects can have positive or 

negative impacts on travel by foot, bike, or transit and therefore should be planned 

with complete-street considerations, including all surface-street projects and all 

maintenance and rehabilitation of surface streets. Even freeway projects that create 

wide interchanges with high vehicle volumes and speeds should be required to 

install extraordinary protections for bicyclists and pedestrians in otherwise hostile 

environments (for example, the Hwy 50/Watt Avenue interchange project has 

required special bike and pedestrian infrastructure so that bicyclists and pedestrians 

can get safely travel through the interchange area). 

Expanding Complete Streets in the region is a critical way to address the Guiding 

Principles of the MTP/SCS. However, Complete Streets are not the subject of any of 

the 31 policies (and only a few of the strategies) presented in Chapter 6 of the 

MTP/SCS. 

We recommend that SACOG better define the extent and purpose of adopting a 

Complete Streets policy as mentioned in Strategy 9.1 (page 6-7). Strategy 9.1 

supports a policy to help reduce greenhouse gas emissions. The MTP/SCS 2035 

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should also recognize the many other benefits of Complete Streets such as 

improving community health and safety, energy efficiency, travel mobility, and air 

quality. 

We believe this is best accomplished through a stand-alone policy under the policy 

category of Land Use and Environmental Sustainability to address ways to greatly 

expand Complete Streets in the SACOG region. An expanded policy should 

recognize the many co-benefits of making streets safe and desirable for all 

travel modes. We recommend the Complete Streets policy include these 

specific strategies: 

 

 

 

 

 

 

Establish a definition for what would qualify any street to be a complete 

street (using multi-modal level of service estimates), 

Develop a goal for what proportion of a jurisdiction’s surface streets 

should ultimately qualify as Complete Streets (we believe this proportion 

should be near 100%), 

Establish a timetable by when local jurisdictions and the region will 

achieve specified proportions of making all streets complete (perhaps 50% of 

potential streets complete by 2025 and 100% by 2035), 

Develop and promote a template for local jurisdictions to use in 

considering how to make any surface street into a Complete Street, either 

during construction or as part of maintenance and rehabilitation, 

Offer incentives, both technical and financial, to encourage local 

jurisdictions to upgrade their surface streets into Complete Streets, and 

Review and comment on transportation project designs to enhance their 

complete-street qualifications. 

1. The MTP/SCS 2035 should invest in planning and implementing continuous 

and direct bike networks between key destinations to promote local circulation 

within Community Types that have greater land-use densities. Because of higher 

densities, the Center, Corridor, and Established Community Types have the greatest 

potentials for substantial increases in bike mode share. 

Much of Policy 29 (in Chapter 6) encompasses strategies to invest in connectivity for 

local and regional circulation. We recommend that an additional strategy be 

adopted to support Policy 29 that aims to define how a bike network for local 

circulation can qualify as safe, comfortable, continuous, and direct for 

potential bike riders of all ages and abilities. 

Bike networks are safe and desirable for riders of all ages and capabilities (from 

school children to grandparents) when they consist of bikeways that have low traffic 

volumes and speeds and are continuous and direct between key destinations. Such 

networks can be comprised of combinations of Class I paths, Class II lanes, and 

Class III routes but they also have special protection for bicyclists when crossing 

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high speed/high volume arterials or other barriers and have signage to direct riders 

to their intended destinations. Facilities such as protected/painted bike lanes, cycle 

tracks, bike boxes (for left turns and congested intersections), and special 

signalization may also be needed. 

Key destinations include residential neighborhoods, schools, shopping and dining 

areas, community centers and parks, as well as job concentrations. Comfortably 

bike-able key destinations will typically be within distances easily traveled on a 30- 

minute bike ride (about 3-5 miles) for most people. 

For example, continuous and direct bikeways do not currently exist between the 

inner “Park” neighborhoods of Sacramento and the downtown core of commercial 

and government offices, a distance of about 3 miles. Although current bike facilities 

are a gradually expanding, they are typically a patchwork of bike lanes and Class 3 

routes and often these bikeways are interrupted by high volume/speed arterials 

without adequate protection for bicyclists and pedestrians to cross them. Even 

arterials with bike lanes may not feel safe for bicyclists if a high speed differential 

exists between vehicles and bicyclists. 

In addition to our three key requests discussed above, we have these specific questions 

and comments: 

1) Draft MTP/SCS page 4-6, 1 st paragraph: 

Please discuss why only 5 percent of “maintenance and rehabilitation” projects is spent 

on bicycle and pedestrian facilities. We believe every roadway maintenance and 

rehabilitation project should consider what measures and features can make the 

roadway safer for bicyclists and pedestrians. 

2) Draft MTP/SCS page 4-7, 1 st paragraph: 

Please state the criteria for defining Complete Streets and discuss why only 33% of 

MTP/SCS projects qualify as Complete Streets. 

3) Draft MTP/SCS page 5C-29, Table 5C.6: 

Please explain the lack of increase in commute mode share for carpools between 2008 

and 2035, even with the huge investments in carpool lanes shown in Table 4.2. 

4) Draft MTP/SCS page 10-17, 3 rd paragraph: 

We request that the MTP/SCS 2035 provide more safety performance measures and 

information for bicyclists and pedestrians because vehicle collisions with such travelers 

have much higher risk of fatality. Specifically, these collision, fatality, and injury data 

should be reported per capita and disaggregated by mode and type of street or roadway 

of occurrence (e.g. high speed arterial, local street). 

5) DEIR page 16-60 in Chapter 16 – Transportation, 1 st paragraph: 

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The first paragraph lists ways that roadway projects may interfere with the bicycle or 

pedestrian system. The first bullet should be modified to state (added text underlined): 

“Roadway improvement projects or land use changes which result in higher vehicle 

volumes or speeds adjacent to Class 1 paths or Class 2 lanes, or on Class 3 routes.” 

The second bullet should similarly be modified to mention Class 3 routes (which do not 

have painted lanes but sometimes signage, sharrows, or other markings on roadway). 

Thank you for the opportunity to comment on the draft MTP/SCS 2035. We look forward 

to further progress with this process and again commend SACOG, its officers, and staff 

for their attention and hard work in making the Sacramento region a safe and desirable 

place to live, work, and play. 

SABA works to ensure that bicycling is safe, convenient, and desirable for everyday 

transportation. Bicycling is the healthiest, cleanest, cheapest, quietest, most energy 

efficient, and least congesting form of transportation 

Sincerely, 

Tricia Hedahl 


CC: 

Kacey Lizon, SACOG Senior Planner 

Lacey Symons-Holtzen, SACOG Assistant Planner 

Page 132 of 165

Attachment: Specific Comments about MTP/SCS 2035 

Chapter 6 “Policies and Supportive Strategies” 

Strategy 2.1: Providing computer software and technical assistance should include 

tools for estimating and projecting Multi-Modal Level of Service for complete-street 

improvements. 

Strategy 2.3: Monitoring and reporting commute patterns should cover all modes of 

transportation. 

Strategy 2.7: Assessment of transportation projects should ensure full provision of 

Complete Streets features. 

Strategy 3.5: Providing connections for bicyclists and pedestrians should address 

connections across freeways and high speed/high volume arterials in addition to gated 

communities, walls, and cul-de-sacs. 

Strategy 3.7: Travel modeling studies should be shared with active transportation 

groups in addition to local governments and air districts. 

Policy 17: “Preservation of the existing road and highway system as top priority for local 

public works agencies and Caltrans” must acknowledge that it is also high priority that 

that system be modified and enhanced to provide complete-street features to serve all 

transportation modes throughout the system. 

Strategy 19.2: Supporting seamless trips should also address the “last mile problem” by 

providing bicycle improvements such as bike-share programs, directional signage, and 

bike storage facilities. 

Strategy 20.1: Improving transit access should include providing designated bike routes 

and signage around transit stops. 

Policy 22: Supporting “proactive and innovative education and transportation demand 

management” should include 1) a strategy to consider congestion pricing and parking 

management, and 2) a strategy to support active transportation groups in producing 

bicycle-route maps, delivering pedestrian and bicycling education, and in completing the 

bikeway network. 

Policy 24: Outreach to low income and minority communities must include a strategy 

that sets a high priority on establishing continuous and direct bicycle networks to key 

destinations in Environmental Justice Areas because these communities currently use 

active transportation modes at a much higher rate than other communities and will 

respond with the greatest increases in bike mode share if adequate facilities exist. 

Page 133 of 165

Policy 26: “Providing additional capacity for local and regional traffic on major arterials” 

must ensure that mobility for bicyclists and pedestrians on such arterials is enhanced 

and that barriers to biking and walking are not created. 

Strategy 29.2: The word “eventual” modifying “creation of a regional bicycle and 

pedestrian network” must be replaced by the word “rapid” to demonstrate the high 

priority, front-loaded necessity of investing in this network, especially in Environmental 

Justice Areas, not just where good local circulation networks already exist. 

Policy 30: Giving primary priority to “road expansion” violates the MTP/SCS Guiding 

Principle of Equity and Choice (i.e. provide real, viable travel choices for all people . . .). 

Instead this policy should state that selective road expansions will be considered if they 

enhance Complete Streets infrastructure and enhance mobility options for all 

transportation modes. As stated, this policy encourages single-occupancy vehicle 

travel. 

Page 134 of 165



Board of Directors and staff 



Re: 

Draft Metropolitan Transportation Plan/Sustain 

nable Communities Strategy 2035 

Update 

Dear SACOG Board 

of Directors and staff: 

WALKSacramento is 

pleased to 

comment 

on the October 27, 2011 draft Metropolitan 

Transportation Plan/ /Sustainable Communities Strategy 2035 Update. The 

more we read 

and delvee into the draft MTP and its appendices, the more we appreciate the breadth 

and 

depth of the work of SACOG’s dedicated staff. 

We commend SACOG for its intention to increase thee level of pedestrian and bicycle 

infrastructure in the region with its commitment to fund $2.8 billion in new bicycle and 

pedestrian projects or 7.9% of MTP investments. Ass well, the draft MTP anticipates 

Completee Street features will be 

as much as 16% of its investments in Road Capital & 

Operations Projects. 

This would bring the 

region’s overall percentage of regional 

investment in pedestrian and bicycle improvements over the next 23 years 

to as high as 

11.3% of total funds. Truly SACOG is leading the nation. 

We offer several recommendations for strengtheningg the MTP’s 

provision for Complete 

Streets to 

support increased walking and bicycling in this letter and in our attached 

comments and recommendations on the specific provisions of the MTP and its key 

appendices. 

We have participated 

in the collaborative work of Climate Plan and Human 

Impact 

Partnership helping to craft their recommendations related to walking, bicycling and health. 

We support the thorough review 

and recommendations of both of these efforts. 

WALKSacramento began its existence as part of the Lung Association of Sacramento 

Immigrant Trails’ involvement in 

the 1997 MTP planning process. At that time walking 

was 

largely ignored by transportation planners both at thee local and regional level. We believed 

then that the provision of safety 

for pedestrians wouldd go a long 

way toward addressing 

some of the region’s 

transportation needs. 

We are pleased thatt what was true in 1997 is no longer true. SACOG and 

the region’s 

cities and 

counties recognize the needs of 

pedestrians and bicyclists – and 

the needs 

of a 

diverse population of young and 

old, able bodied andd disabled. However, while the 

policies are there, particularly in 

our most urban areas, there are 

still many, many 

Page 135 of 165

oadways that are unsafe for both pedestrians and bicyclists. This hinders our freedom to 

get to nearby destinations on foot and bicycle; it limits our ability to take transit; it limits our 

ability to reduce VMT by substituting walking and bicycling trips for vehicle trips; and it 

handicaps our ability to support our health by incorporating physical activity into our daily 

lives. 

Now more than ever it is critical to plan and implement transportation projects that support 

walking and bicycling – for all ages. To strengthen the MTP’s provision for walking and 

bicycling we recommend the following: 

1. Set Timetable for Achieving Complete Streets 

SACOG’s draft MTP lacks an overall goal of completing the system for walking and 

bicycling. We urge that the MTP include such a goal of Complete Streets by 2024. 

The MTP does not compare funding for bicycles and pedestrians with what is needed to 

achieve a complete system including a continuous bicycle / pedestrian network. The plan 

does not achieve Complete Streets throughout the region even within the life of the plan 

(25 years). 

A complete system for bicycles and pedestrians would allow a significantly greater 

proportion of the population to utilize “active transportation” to obtain physical activity on a 

daily basis for both utilitarian and recreational trips. From a public health perspective, this 

is critical, because the most common causes of chronic illness and death today are related 

to widespread physical inactivity. The high cost of health care today is due in part to the 

increasing numbers of people requiring medical treatment for conditions that could be 

alleviated with regular exercise. 

Replacement of shorter trips (less than three miles) with walking and bicycling would also 

reduce emissions of air pollutants, especially given that the shorter vehicle trips are the 

most polluting, mile per mile. The Sacramento Valley air basin is one of the most top ten 

polluted in the nation, causing elevated rates of asthma and other conditions related to 

high concentrations of ozone and particulate matter. Vehicles are the primary source 

(about 70%) of these air pollutants. 

Why 12 years? Twelve years is three more MTP cycles. During the first plan cycle, 

SACOG’s cities and counties could develop or update their bicycle and pedestrian master 

plans. The next two cycles would provide for plan implementation. By spending money 

now for pedestrian and bicycle infrastructure (frontloading) we can achieve higher levels of 

walking and bicycling, we will all be healthier, and the air will be cleaner. 

We realize that SACOG and the region’s cities and counties are at the end of a 

deliberative process and that a major shift in focus may not be possible with this MTP. 

That said, we do believe it is possible to make changes that will assure that we move at a 

reasonable and accelerated pace to achieve Complete Streets – Safe Routes For All on 

our major roadways. We think this can be accomplished by adopting the concept of a 

“Plan for a Plan” – a plan to create a plan to achieve Complete Streets. We urge that 

SACOG’s include its intention to do this work as part of this MTP and its work-plan for the 

909 12 th Street, Suite 122, Sacramento, CA 95814 

(916) 446-9255 / www.walksacramento.org 

Page 136 of 165

next four years so that the next MTP will include the implementation strategies to achieve 

the Complete Streets in the Region. 

2. Establish a 20% target for all non-commute walk and bike trips. 

Of all trips in the region, most (80%) are for reasons other than the commute to work and 

most of those are relatively short distances. The plan estimates that with the current 

project list, by 2035, 12.1% of all non-commute trips will be by walking or bicycling. This is 

a very modest 14% increase from the current (2008) 10.6% share by walking and 

bicycling. This compares with the draft MTP’s estimate of a transit mode share increase 

from .8% to 1.8% or a more than 125% increase. (The transit commute mode share 

increase is estimated at 193%.) A stretch goal for walking and bicycling should be 

included with this plan as well. 

We recommend a “stretch” target of 20% of all non-commute trips by walking and 

bicycling, including walking and bicycle to transit. We believe this target could be 

achievable through incorporating provision for walking and bicycling into SACOG’s funding 

policies and funding programs. 

We offer additional suggestions for accomplishing this in our comments on the MTP’s 

specific provisions (Attachment 1). 

3. Integrate Complete Streets into road maintenance and rehabilitation projects 

We appreciate the extensive work SACOG staff has accomplished “doing more with less” 

in these difficult economic times. Integrating consideration for Complete Streets into road 

maintenance and rehabilitation projects is another way to achieve “more with less”. Many 

pedestrian and bicycle infrastructure improvements such as improved street markings can 

be incorporated with minimal funds into ongoing maintenance and rehabilitation. 

Adding bike-lane markings on streets as a part of rehabilitation is one example. Many 

streets have overly wide lanes which if narrowed can provide room for bike-lanes. 

Another important example is providing marked crosswalks at both signalized and nonsignalized 

intersections. Many marked crosswalks were removed in the 1970’s and 1980’s 

particularly at un-signalized intersections as a result of limited research that led to the 

conclusion that marked crosswalks give pedestrians a false sense of security. New 

research has provided much sounder basis for how to mark uncontrolled intersections to 

provide the pedestrian greater safety and the driver greater knowledge of the presence of 

pedestrians. Using this new research, traffic engineers can assess their intersections to 

determine the most effective treatments for providing pedestrian accessibility and safety. If 

done in advance of road rehabilitation, these striping treatments can be incorporated into 

the rehabilitation work with minimal additional cost. 

SACOG working with its member jurisdictions can develop a template for “best practices” 

road rehabilitation programs that build in time for evaluating, planning and engineering for 

changes to the roadway markings – bike-lane, pedestrian crossing markings, and even 

lane narrowing to achieve Complete Streets. This is a very cost-effective way to increase 

the miles of Complete Streets. 



Page 137 of 165

4. Incorporate specific pedestrian and bicycle projects in the MTP’s transportation 

project list. 

The MTP’s Project List is largely vehicle and transit related. That gives the impression to 

many that projects that serve pedestrian and bicycle modes are not included. While it is 

noted in the plan that a significant portion of SACOG’s funds will be spent on pedestrian 

and bicycle projects, it is a separate funding process. 

We recommend that each jurisdiction identify its high priority bicycle-pedestrian projects 

just as it does for its other projects as part of the project identification stage. This will allow 

the community to know what the jurisdiction’s priorities for pedestrian and bicycle 

improvements are in the context of its other transportation priorities. 

In hindsight we realize that one of the most critical steps in the MTP’s development is the 

determination of what projects will be included in the final plan. We urge that this step be 

made more explicit in the outreach process so that citizens can make their project 

recommendations along with their scenario recommendations. 

Additionally, the MTP project list is large and difficult to review. It would be helpful if it 

were divided into county subsets with information included to identify which projects will 

add to Complete Streets. 

5. Set performance measures for pedestrian and bicycle safety and health 

outcomes associated with transportation-related physical activity. 

The plan has no performance measures or targets for pedestrian or bicycle safety. Safety 

for walkers and bicyclists is critical and should be integrated into all aspects of the MTP 

including performance measures for funding. Consider utilizing the safety metrics in the 

SB375 Health and Equity Metrics developed by Human Impact Partners 

(www.humanimpact.org) 

Potential health outcome performance measures could include: 

• Increase the average daily time walking or biking per person for transportation by 60% 

(for an average of 15 minutes per person per day). Note that this includes time walking 

to transit (not noted in other transportation statistics). 

• Improvements in population health status that could be made with the adoption of a 

complete system for walking and bicycling. 

6. Incorporate the promotion of walking and bicycling into the greenhouse gas 

reduction strategies 

The transportation sector is the biggest contributor overall to GHG emissions, yet the plan 

does not incorporate strategies to increase to replace car trips with walking and bicycling 

for the short trips. A significant increase in walking and bicycling trips may enable the 

achievement of a further reduction in total GHG emissions. 



Page 138 of 165

We appreciate working with SACOG, its staff and elected leaders, on this latest MTP and 

new Sustainable Communities Strategy. Thank you for your consideration of our 

comments. 

Sincerely, 

Teri Duarte, MPH 


Anne Geraghty 

Policy Consultant 



Page 139 of 165

Attachment 1 – January 9, 2011 

WALKSacramento’ 

’s comments on the specific provisions of the 

2011 Draft SACOG Metropolitan Transportation Plan/Sustainable 

Communities 

Strategy 

2035 Update 

Chapter 1 – Introduction 

n: Building a Sustainable 

System 

The 20111 Draft MTP‐SCuse, performance‐based planning that began a decade ago. WALKSacramento has 

participated in the process of this evolution since SACOG’s Transportation Roundtable of 2002. 

SACOG is 

to be commended for the steady progress toward this integration including the 

is a milestone in SACOG’s progress toward integrated transportation 

and land 

improved 

outcomes of this plan. 

The summary providedd in this chapter illustrates how SACOG, 

step by step, has developed incremental and 

significant improvements to the plan, most 

notably the Blueprint approach and most recently the Rural‐Urban Connections 

Strategy and SB 

375. 

• We urge thatt SACOG’s next area of focus should be on Complete Streets. We ask that 

SACOG to develop a Complete Streets focus for the next plan 

iteration by developing 

and implementing a work‐plan that focuses on how Complete Streets can be achieved in 

our region and how this will improve 

the region’ s economic and environmental 

sustainability. 

Chapter 2 – Planning Process 

This chapter outlines 

the reasons for preparing a MTP ncluding to assure the region’s eligibility 

to receive federal transportationn funds. Any 

project that would receive federal funding must be 

included in the project list of the 

MTP. The deadline of April 2012 iss mandated by SB 375. 

WALKSacramento has a seat on the SACOG Bike/Ped Advisory Committee and has worked 

informally with SACOG staff as part of the Complete Streets Coalition. WALKSacramento 

participated with the 

Safe Routes for All Coalition in thee nine region‐wide workshops in October 

2010 on the draft scenarios. We 

advocated for a “4 th Scenario” thatt would support completing 

the bicycle – pedestrian network. At several of the workshops, participants supported even 

greater emphasis on walking and 

bicycling beyond the most intensive 3 rd scenario. Anecdotally, 

it appeared that there was a region‐wide desire by mostt participants no matter 

which scenario 

they favored that walkable and bikable communities be incorporated into all scenarios. 

909 12 th Street, Sacramento CA 958144 916‐446‐9255 

1 

Page 140 of 165

We note that the work to develop the project list was primarily a SACOG‐local government staff 

to staff process with little public input. In the future, greater involvement of the public in the 

development of the project list would lead to a greater likelihood that the project list reflects 

the true desires of the community. 

Chapter 6 – Policies and Supportive Strategies 

This chapter provides the policy framework that supports the MTP beginning with the MTP’s Six 

Guiding Principles adopted by the SACOG Board of Directors in 2005: 

1. Smart Land use 

2. Environmental Quality and Sustainability 

3. Financial Stewardship 

4. Economic Vitality 

5. Access and Mobility 

6. Equity and Choice 

Thirty‐one policies are grouped under 4 policy/strategy areas: 

1. Land Use and Environmental Sustainability Policies and Strategies (1‐10) 

2. Finance Policies and Strategies (11‐16) 

3. System Maintenance & Operations Policies and Strategies (17‐26) 

4. System Expansion Policies and Strategies (27 – 31) 

The chapter outlines the existing adopted policies and strategies of the prior plan and targeted 

modifications “to reflect new projects, research, and conditions since the last MTP, such as the, 

Rural‐Urban Connections Strategy (RUCS) and Lifeline Transit Study.” Additionally changes 

necessitated by SB 375 including requirements to “open a path for qualifying residential/mixeduse 

projects to use the CEQA streamlining benefits” of SB 375 are included. 

Complete Streets policies are incorporated throughout the policies and strategies though there 

is no specific policy devoted to Complete Streets. It would be helpful to have a section fully 

devoted to Complete Streets with some additional strategies not now included under the MTP’s 

31 draft policies such as: 

• Developing a regional Complete Streets Plan with a goal and a timeframe for achieving a 

system of Complete Streets throughout the region. 

• Developing an inventory of Complete Streets and an annual or biannual progress report 

on progress toward a complete system. 

• Encouraging all cities and counties in the region to develop and adopt pedestrian and 

bicycle master plans and project lists. 


2 

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• Training for local and regional staff on the latest pedestrian and bicycle quantification, 

engineering and planning methodologies. 

• Consideration of the development of a regional levee maintenance and rehabilitation 

plan that includes multiuse trail development. 

There is no specific policy related to safety but a few of the strategies do address the issue of 

safety. We think this is an area that deserves greater focus, especially the safety of pedestrians 

and bicyclists. 

We offer the following suggested additions and/or changes to underscore the importance of 

Complete Streets and the provision of pedestrian and bicycle infrastructure: 

1. Land Use and Environmental Sustainability Policies and Strategies 

Policy 1: Information, tools & incentives – 

• We recommend a new Strategy 1.6: “Create and invest in a Complete Streets strategy 

and program to achieve Complete Streets/Safe Routes for All throughout the region 

consistent with the Blueprint Principles.” 

Policy 2: Education 

• 2.3: Add the underlined to this strategy: Monitor and report on commute patterns, 

traffic levels, transit use, and bicycle & pedestrian mode share compared with the 

projections in this MTP/SCS. 

• 2.4: Add to this strategy: “Additionally, provide training on the latest analytic methods 

related to pedestrian and bicycle planning, modeling, data collection, and infrastructure 

design.” 

Policy 3: Community activity centers & transit. 

While not mentioned in the policy, we appreciate the emphasis on complete streets in some of 

the strategies. It might be useful to rename this policy so that complete streets are given 

greater emphasis. 

Policy 7: Rural‐Urban Connection Strategy 

• Strategy 7.4: Add to this strategy the following: “Additionally, consider how rural land 

use strategies affect access by active transportation (walking and bicycling).” 

Policy 8: Reducing vehicle emissions to achieve clean air and better public health 

• Add a new Strategy 8.5: “Study and document the emission reduction benefits of 

Complete Streets infrastructure and the potential for increased emission reductions 

from increased walking and bicycling.” 


3 

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Policy 9: Greenhouse Gas emission reductions 

• Modify Strategy 9.1 (as noted by underlines): Adopt a transportation pricing policy, 

adopted a Safe Routes to School policy and implement a pilot program, expand public 

access to travel information through 511 program, and adopt a Complete Streets policy 

and implementation program. 

2. Finance Policies and Strategies 

Policy 11: Pursue sustainable funding sources … 

• Add Strategy 11.5: “Advocate for funds to complete the streets for the region so that 

residents can walk and/or bicycle to locations within 10‐30 minute distance from 

housing and workplaces.” 

Policy 13: SACOG’s investments of federal and state funds … 

• Add new Strategy 13.6: “Study, coordinate discussions, and explore options for 

establishing a region‐wide program dedicated to funding the full implementation of 

Complete Streets including pedestrian and bicycle infrastructure necessary for a fully 

interconnected Complete Streets system.” 

Policy 14: SACOG seeking special funding 

• Add new Strategy 14.8: “Work with local, state and federal agencies to develop new 

sources of transportation funding based on improving public health including new 

sources of funding for expanding pedestrian and bicycle infrastructure.” 

Policy 15: Manage state and federal funding 

• Add new Strategy 15.5: “Work with local agencies to improve and accelerate project 

delivery, especially of bicycle and pedestrian infrastructure project.” 

3. System Maintenance & Operations Policies and Strategies 

This grouping of policies and strategies is particularly relevant to cost‐effectively maximizing the 

current system for walking and bicycling. We recommend adding the following paragraph after 

the first paragraph: 

• “Road and highway maintenance and rehabilitation can be an economical way to 

increase Complete Streets and mobility for walking and bicycling. The addition of bike 

lanes, the consideration of lane restriping to make room for bike lanes and sidewalks, 

and the addition of crosswalk markings and other crossing enhancements can greatly 

expand the pedestrian and bicycle network with minimal investment. By reviewing in 


4 

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advance the roadways programmed for maintenance and rehabilitation, the specific 

plans can incorporate provision for walking and bicycling at a low cost compared with 

retrofits completed at a later date.” 

Policy 17: Acknowledge preservation as top priority and help secure funding 

• Add new Strategy 17.5: “Assist local agencies in developing multi‐year maintenance and 

rehabilitation programs than enable early identification of cost‐effective enhancements 

to improve pedestrian and bicycle access and safety.” 

Policy 19: Ensure coordination among all forms of transit services 

• Add new Strategy 19.3: “Support development of plans and investment strategies for 

prioritizing pedestrian and bicycle access‐to‐transit infrastructure projects.” 

Policy 21: Rural transit services 

• Add new Strategy 21.3: “Enhance access to rural transit through planning for safe 

bicycle and pedestrian access.” 

Policy 23: Service to transit‐dependent populations and attracting new riders who now drive 

• Add Strategy 23.3: “Increase the attractiveness of transit by involving the community in 

improving the environment of transit stops and stations and the pedestrian and bicycle 

access to those transit stops and stations.” 

4. System Expansion Policies and Strategies 

Policy 28: Transit investments for transit‐dependent and choice riders 

• Add Strategy 28.13: “Support strong collaboration between city and county 

transportation and land use planners and transit planners to achieve optimum 

pedestrian access within ½ mile of transit routes and stations and bicycle access within 3 

miles of transit routes and stations.” 

Policy 30: Road expansion to support infill development and reduce midday congestion 

• Modify Strategy 30.1 as follows (recommended additional wording underlined). Pursue 

strategic road expansion that improves reduces congestion, and supports effective 

transit services and maximizes provision for Complete Streets – access for walkers and 

bicyclists. 

• Modify Strategy 30.2 as follows: Expect that feasibility and corridor studies, project 

study reports, and environmental studies will consider high‐quality transit and 

pedestrian and bicycle investments when examining how to provide additional capacity 

on main highway or bridge corridors. 


5 

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• Modify Strategy 30.4 as follows: Give priority for roadway and intersection expansion to 

routes where midday demand approaches existing capacity or excessive peak period 

demand threatens to spill over into midday, so no part of the system fails to function 

continuously for much of the day fully considering the safety and level of service of all 

modes utilizing the new multi‐modal level of service analysis methods. 

Chapter 7 – Environmental Sustainability 

• This chapter would benefit from more information on specific communities – how much 

VMT and emissions they contribute. This would help to increase awareness on the 

importance of land use and complete streets. 

Chapter 8 – Equity and Choice 

One of the key aspects addressed in this chapter is access to transit which is critical for 

individuals without access to a personal motor vehicle. Yet while mentioned briefly, pedestrian 

and bicycle access is also critical to people without cars. Walking and bicycling are low cost and 

health promoting. 

In WALKSacramento’s “Los Rios Transportation Connections” study and plan completed in 2008 

we learned that there are significant opportunities to reduce students’ economic burden with 

transportation improvements. For example, over ½ of students of American River College live 

within 5 miles of the college. Yet access by bicycling in this area of Sacramento’s 

unincorporated area is unsafe and walking in the vicinity of the college is difficult because of 

the lack of sidewalks on many streets. Parking is low cost and most students drive to the 

campus. If students were able to forgo the costs of a car, they would in effect have as much as 

a $8,000 bonus which could assist them with their other college expenses. 

• We urge that access to walking and bicycling be addressed more comprehensively in this 

chapter. 

Chapter 9 – Economic Vitality 

We appreciate the note on Page 9‐24 that “Increased interest in bicycling and walking has had 

additional economic benefits.” 

• We suggest this aspect of economic vitality be expanded. 

• Additionally we suggest that this chapter address the economic importance of health 

and the costs of our health care as it related to transportation. What would be the 


6 

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economic benefits of the development of a truly walkable and bikable region contribute 

to our health and the reduction of health care costs? 

Chapter 10 – Financial Stewardship 

As we have mentioned in our letter and in our policy recommendations, we believe there is a 

significant financial stewardship opportunity to increasing the cost‐effectiveness of our road 

rehabilitation funds by incorporating early consideration and planning for Complete Streets 

improvements to those roads that are integrated into the rehabilitation when it occurs. 

• We urge SACOG to include this concept in its Financial Stewardship approach. 

It is suggested on page 10‐7 that the MTP/SCS assumes a reliance on sales taxes anticipating a 

new ½ cent “Measure B” sales tax in Sacramento County beginning in 2014 – and assumes that 

this new revenue would be split between transit and capital needs. What portion of this 

potential new funding will be used for road rehabilitation? 

• We urge Sacramento’s elected leaders to include provision for Complete Streets as part 

of any new sales tax measure. 

Pedestrian safety is a critical issue in this region. Though pedestrian trips are a relatively small 

portion of all trips, they are a significantly greater proportion of all traffic fatalities. As noted on 

page 10‐17, pedestrian fatalities from motor vehicle collisions exceed 18% of all fatalities in the 

State – much higher than in the national as a whole. In 2009, 18% of traffic fatalities in this 

region were pedestrian fatalities. In Sacramento County in 2009 pedestrian fatalities were 25% 

of total fatalities (source, California Office of Traffic Safety website). 

While roadway fatalities have gone down overall in the state, we believe that pedestrian 

fatalities have not declined. 

• We urge that the section on Roadway fatalities in the SACOG region include statistics on 

pedestrian fatalities. 

The greater proportion of pedestrian fatalities in the region and particularly in the region’s 

urban areas underscores the need for improved transportation infrastructure for safe 

pedestrian mobility. 


7 

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PO Box 1526 • Sacramento, CA • 95812 (916) 444-0022 

 



Sacramento Area Council of Governments (SACOG) 



Re: 

Draft Metropolitan Transportation Plan/Sustainable Communities Strategy, and 

corresponding DEIR 

Honorable Board Members and Executive Director Mike McKeever: 

The Environmental Council of Sacramento (ECOS), Habitat 2020, and the California Heartland 

Project are unified in our support of SACOG's first joint Draft Metropolitan Transportation Plan / 

Sustainable Communities Strategy (MTP/SCS). The plan is a visionary approach to the SB 375 

objective to link regional land use and transportation planning to reduce greenhouse gas 

emissions. We applaud the direction of the SACOG Board and the efforts of SACOG staff to 

produce a scenario that, if adhered to, will certainly make significant steps towards regional 

sustainability. 

Considering the financial constraints of this planning cycle, we are impressed with SACOG's 

ability to do "more with less" by directing investment to areas that maximize impact by the cost 

effectiveness of smart growth and active transportation. Some of the impressive anticipated 

outcomes we support include: 

o Meeting the CARB GHG reduction targets (10% by 2020, 16% by 2035) 

o Declines in congested VMT (6.9%) 

o Increases in transit service hours, system productivity, and access overall, and 

more so for Environmental Justice Areas 

o More homes, jobs, and amenities near high-frequency transit 

o 8% proportion of funding to active transportation, with additional bike/ped 

improvements integrated into road maintenance funds 

While we strongly commend the modeling outcomes the MTP/SCS presents, there is also room 

for strengthening the plan to help ensure these outcomes are achieved. We fully support the many 

suggestions offered in the letters of ClimatePlan, Human Impact Partners, and the Coalition On 

Regional Equity. But, for the purposes of this letter, we are obliged to highlight some key areas of 

weakness that we feel could, in the long-term, be a detriment to the successful implementation of 

this valuable plan. We recognize that the following, in some cases, deals with processes that 

require further coordination with local jurisdictions, and are not necessarily in the sole control of 

SACOG. Given that, we offer these observations for your ongoing consideration in future work. 

Page 147 of 165

Transportation: 

It has long been a concern of ECOS and others that, too often, housing and commercial 

development takes place without adequate transit, and that when and if transit is put in place, it is 

then difficult to change car-oriented behavior. It is understood that SB375 only requires quality 

transit to be planned within the time horizon of the MTP for residential projects to meet the 

criteria for CEQA benefits, and we are pleased with SACOG's approach to targeting 

transportation projects that will maximize effects of investment. Yet we feel that more specific 

strategies are needed to ensure appropriate phasing of transit and active transportation 

improvements with residential development. 

We hope to see SACOG review transportation project phasing in relationship to current densities 

and the timing of future development, working with other agencies and local jurisdictions to 

establish protocols which: identify and accelerate transit for high-density arterial corridors and 

existing urban areas that currently lack adequate service: flag and defer or cancel any costly 

transit capital projects that would begin construction before the densities would justify the cost 

(as suggested by Strategy 28.9): Flag, defer or cancel road and transit construction that would 

trigger premature peripheral growth. 

Land Use: 

The land use forecast in the MTP/SCS represents an improvement over previous regional 

planning efforts. The MTP/SCS anticipates accommodating expected growth with a vision 

toward more efficient land use and a smaller expansion of the regional development footprint. 

There are a variety of factors that help to make this MTP update a promising step toward a 

sustainable future for the Sacramento region, including the first-time incorporation of SB 375 

requirements, SACOG’s advanced modeling tools, and extensive public outreach to help define 

the MTP/SCS preferred scenario for land use and transportation. 

Despite these improvements, the MTP/SCS includes key assumptions that, if adopted, could 

hinder the region’s ability to achieve important land use and transportation objectives. 

The single most important assumption in the MTP/SCS land use forecast that should be reviewed 

is the overestimation of demand for single-family large-lot housing. Although this type of 

housing has dominated residential development throughout the region for the past several 

decades, independent studies consistently show that demographic changes are reducing the 

demand for this type of housing. The MTP/SCS acknowledges that “…there will be significant 

demand, especially by the large, retirement age baby boomer generation and the even larger 

Generation Y echo-boomer cohort (those born between 1978 and 1994), for new housing, 

including rentals and small lot homes…” 1 . Despite this, Table 3.9 of the MTP/SCS shows that 28 

percent of new housing in 2035 is single-family large-lot. 

This contrasts sharply with at least one recent study concluding that the Sacramento region 

already has enough single-family large-lot residential supply to meet demand through 2035. 2 

1 SACOG, Draft MTP/SCS 2035, November 10, 2011, p. 3-13. 

2 Nelson, Arthur C. The New California Dream: How Demographic and Economic Trends May 

Shape the Housing Market. Washington, D.C.: Urban Land Institute, 2011, Table 4.4, p. 43. 

Page 148 of 165

This study by the Urban Land Institute estimated that over half of the residential demand between 

2010 and 2020 will be for attached units; and by 2035, about 60% of demand will be for attached 

units. The MTP/SCS predicts a lower share of attached units. 

This result of this overemphasis on single-family large-lot development is significantly more 

developed acreage than necessary to meet demand, and the less-compact land use form results in 

greater vehicle trip lengths and greenhouse gas emissions. Table 3.11 of the MTP/SCS shows 

that 45 percent of additional developed acres between 2008 and 2035 are in Developing 

Communities – where much of the single-family large-lot development would occur. 

The fundamental cause of this problem is the MTP/SCS assumption that 42 percent of forecasted 

housing demand and 18 percent of employment demand will be in Developing Communities. 3 

Not surprisingly, the largest increase in housing units by community type between 2008 and 2035 

is in Developing Communities, where the share of housing units increases from three percent in 

2008 to 13 percent in 2035. 

To remedy this problem, we recommend that SACOG work with individual jurisdictions to refine 

the demand analysis and land use distribution to reduce the 2035 forecasted housing unit 

allocation for Developing Communities by at least 50% (to a total of not more than 75,000 units) 

and reallocate the remainder to Center and Corridor Communities. 

In addition, we encourage SACOG to develop a guidebook that provides clear examples of the 

key characteristics of the various development types in the MTP/SCS. The Guidebook could be 

developed similar to the Title 24 guidebook that was published shortly after the Title 24 standards 

were adopted in 1978. 

Finally, SACOG’s 2020 and 2035 GHG reduction targets are difficult to consider at the Plan or 

Project level because there is currently no method/model that could evaluate plan or project 

performance at meeting the targets. We encourage SACOG to work with ARB, local air districts, 

educational institutions, and others to develop technical tools (similar to CalEEMod) that would 

provide the ability to evaluate individual projects and their contribution to regional targets. 

CEQA Streamlining Determination Process: 

SB 375 gives the local jurisdiction the discretion for making the determination for what level of 

CEQA exemptions a project is qualified for within the SCS, but, while it is suggested, there is no 

mandate for a public notice, hearing or review process for this determination (PRC 21155.1). In 

most cases, the usual required CEQA process would ensue after the determination, but of course; 

the determination affects what will be reviewable in that process. Further, after that 

determination, the ability to challenge findings is made more difficult, being raised to the 

"substantial evidence" standard. And with no precedence, it remains unclear if it is possible to 

challenge the determination itself. And, in the event that a project is dubbed to be a "sustainable 

communities" project, qualifying for a full CEQA exemption, then there will be no ensuing 

process. 

Page 3-36 of the plan states, “To determine a project’s consistency with the SCS, a jurisdiction 

must find it consistent with the general land use, density, intensity, and any applicable land use 

3 SACOG, p. 3-15. 

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policies of the SCS. Additional information by jurisdiction and community type is provided in 

Appendix E-3.” 

The jurisdictional narratives of anticipated growth in Appendix E-3, in conjunction with the 

primary map of the plan by community type (Figure 3-2, MTP/SCS, p. 3-11) and the breakdown 

of qualifications for the levels of CEQA benefits in Table 2-16 (DEIR, p. 2-60) offer a very broad 

net for jurisdictions to make the interpretation of "consistency" with the SCS, or judge the 

impacts that have been addressed by the programmatic SCS EIR. We understand that SACOG 

does not have the capacity to provide oversight for all regional project-level determinations, but 

lacking this oversight or a more specific guide for land-use designations, it is extremely important 

that there be a public process before these determinations are made. At the very least, an 

opportunity for public input should be established in coordination with the local jurisdictions to 

ensure that equity, health, and environmental interests are adequately addressed. 

Natural Resources: 

We are greatly concerned about the continued trend of greenfield development in the region. We 

support the reduced growth footprint of this MTP/SCS, yet there remains a substantial amount of 

greenfield development within the footprint (that will now receive CEQA exemptions). And 

further, there are currently many thousands of acres of proposed development outside of the plan 

that will endanger the plan's future success. Growth outside of the plan in one area will need to be 

absorbed by the rest of the region and inhibit the growth of other jurisdictions, in subsequent 

MTPs. And it is feared that much more than the CEQA benefits provided by the SCS will be 

needed to incentivize smart growth and adherence to the plan. 

The centerpiece of the plan's natural resource element is the Rural Urban Connection Strategy. 

We cannot understate our praise for the work of the RUCS program since the last MTP in 

analyzing the broad range of factors that affect viability of the region's rural communities. And 

we commend RUCS's demonstration of the economic imperatives to preserve the regions 

agricultural base. 

SACOG highlights performance in this area with the projection that, by 2035, 37,000 acres of 

agricultural land will be converted to urban development--compared to 200,000 acres converted 

since 1988, (despite a greater projected population increase by 2035). This is certainly a great 

departure from the past that we support. Clearly, RUCS is an innovative and impressive program, 

yet it is essentially an economic viability study for agriculture alone, and the sophisticated 

analysis does not extend equally to habitat impacts, or other ecosystem services (i.e. carbon 

sequestration, groundwater recharge). 

For plant and wildlife habitat viability, the SCS relies mostly on the presumed completion of the 

region's Habitat Conservation Plans. But these plans, alone, do not address critical regional 

connectivity, and, in some cases, do not at this point show certainty of successful completion. 

The total acreage of newly developed land in the SCS is generally represented to be 53,266- 

53,914 (EIR 2-25; 19-20). Within the newly developed areas, 36,392 acres of agriculture 

(MTP/SCS, 7-6), 5,602 acres of designated forest (EIR,4-44), and 37,681 acres of habitat are 

impacted (Table 7-5, MTP/SCS 7-17). Obviously, there are overlaps of these 79,675 acres of 

agriculture, forest, and habitat to add up to the ~53,500 figures. Table 6-6 (EIR, 6-35) adds up the 

impacts to 53,914 - showing only 16,233 acres of agriculture beyond the 37,000 of habitat. But 

how or where the other 24,000 acres overlap is not clearly indicated or shown spatially to be able 

to adequately analyze impacts. 

Page 150 of 165

Further, while SACOG has used the best data currently available, it is roundly recognized that 

comprehensive, accurate, up-to-date natural resource data does not exist for the region to do 

sufficient analysis of these impacts. 

The lack of data is demonstrated by the plan's simple justification that the 37,500 acres of habitat 

impacted represents only "one percent of the 2,543,519 acres of habitat and land cover in the 

region today," (MTP/SCS, 7-16). However, the vast majority of this regional habitat resides in the 

National Forest in the mountains, while the vast majority of the impacts are in the valley and 

foothills where viable habitat differs greatly and is much more sparse. In the future, a 

proportionate analysis of habitat impacts on the valley must be undergone, at a regional level, to 

adequately assess environmental sustainability of the MTP/SCS. 

We believe that the interests of equity, public heath, and economic prosperity in compact transitoriented 

urban planning are best served by complimentary planning for natural resource and 

open-space conservation. Improved natural resource data, analysis and conservation strategies 

need to be developed to compliment the SCS, to further incentivize adherence to the valuable 

urban plan that SACOG has developed. 

In the future, this data could be used: 

As a public decision-support tool for targeting responsible and efficient investment for 

development and conservation. 

To enable participation in/development of a Regional Advanced Mitigation Program 

To demonstrate co-benefits for ecology, public health, recreation and education, as well 

as the economic imperatives for habitat/open-space conservation 

To demonstrate co-benefits and economic imperatives to preserve ecosystem services, 

(ie. carbon sequestration, flood management and groundwater recharge) 

Conclusion: 

To reiterate, we applaud SACOG's first joint SCS/MTP, and we hope the above comments are 

constructive to implementation of the plan. We also commend the extensive efforts of SACOG 

staff to engage the public throughout the MTP process. We greatly appreciate the time and 

attention that has been provided us in addressing our concerns and suggestions in development of 

this plan, and we look forward to our continued work with SACOG moving forward. 

Sincerely, 

Jonathan Ellison, President 

ECOS Board of Directors 

Page 151 of 165

LEGAL SERVICES OF •.-• N ORTH E R N CALf FOR N IA 

of Directors 

Board 

Area Council of Governments 

Sacramento 

promotes quality affordable and 

SHA 

housing and enhanced opportunities for lower income households and homeless individuals. 

accessible 

and works in collaboration with its many community partners to create opportunities 

advocates 

fair and equitable access to quality transportation, jobs, and food, particularly for the 

for 

lower income residents, homeless people, communities of color, people with 

region's 

and other vulnerable or disenfranchised populations. Accordingly, SHA focuses 

disabilities 

these communities. SHA views application of SB 375 and other laws and regulations 

for 

the MTP/SCS process as an opportunity to ensure that the region's disenfranchised 

governing 

and communities reap the benefits of the Plan and are not disproportionately 

residents 

or disadvantaged by its implementation, as is too often the case with intended 

burdened 

demonstrates that SACOG continues to play a 

house gas reduction targets; that strives, to a 

1SHA also oins in the comments the Coalition on Regional Equity submitted to SACOG on December 23, 2011. 

SACRAMENTO COUNTY OFFICE 515 12TH STREET SACRAMENTO CA 95814 

VOICE: (916) 551-2150 FAX: (916) 551-2196 WEB: 


L Street, Suite 300 

1415 

CA 95814 

Sacramento, 

Re: Draft Metropolitan Transportation Plan/Sustainable Communities Strategy 2035 

Dear SACOG Board of Directors: 

Services of Northern California submits these comments on SACOG's current Draft 

Legal 

Transportation Plan/Sustainable Communities Strategy 2035 ("MTP/SCS" or "Plan") on 

Metropolitan 

behalf of the Sacramento Housing Alliance ("SHA"). 1 

Consistent with this mission, SHA, and its 

project, the Coalition on Regional Equity (CORE), also 

these comments on ensuring that the MTP/SCS promotes equity in 

housing and transportation 

transportation and land use reform. 

SHA believes the Draft MTP/SCS moves the region in 

the right direction and 

leadership role nationally in transportation and 

use planning. Faced with the challenge of a 5 percent- decrease in per capita funding, 

land 

has drafted a plan that endeavors to meet the 2035 and exceed the 2020 regional green 

SACOG 

significant extent, to make much-needed 

improvement in 

access to transit service and active modes of transportation; and that utilizes 

Page 152 of 165

from SHA to SACOG re MTP/SCS 2035 

Letter 

9, 2012 

January 

among Hispanics and 

be 

Sacramento County is already a so-called "majority-minority" with Yolo County close 

Asians. 

with a population at 50-50 white-minority. And, it is an unfortunate fact that as with 

behind 

regions across the state and country, people and communities of color disproportionately 

other 

the burden of the region's failed systems and infrastructure, and that racial wealth and 

bear 

gaps have worsened many fold due to the housing and financial crises. Thus, it makes 

income 

2£19 and Appendix G-5 of the Plan detail many of the state and federal requirements 

Page 

SACOG must meet in developing and implementing its MTP/SCS. However, important 

that 

entered into with HUD as a condition of receiving a 

Partnership for Sustainable 

SACOG 

Grant, SACOG "represent[ed], warrant[ed], and certifie[d] that it Shall comply 

Communities 

Title VI of the Civil Rights Act of 1964 (Nondiscrimination in Federally Assisted HUD 

1. 3 [why isn't there reference to FTA or.DOT?]); 

Programs 

Title of the Education Amendments of 1972, .as amended (Nondiscrimination on the 

2. IX 

Sex in Education Programs Activities); 

or of Basis 

3. Section 504 of the Rehabilitation Act of 1973 (Nondiscrimination Based on Handicap) 

http•//www.p•io/•ink.•rg/site/c.•k•xLbMNJrE/b.7843•37/k.B35B/Equity-Summit-2•11:htm.• 

statutes and laws listed here refer to and govern programs or activities receiving federal financial assistance. 

All 

and expansive approaches to promoting equity outcomes, particularly in 

innovative 

Justice ("E J") areas. 

Environmental 

SHA believes that SACOG can and must strengthen and enhance the equity 

However, 

of the MTP/SCS. Doing so will bring the Draft MTP/SCS into better compliance with 

provisions 

state and federal legal and regulatory obligations and, equally important, facilitate 

SACOG's 

robust and sustainable economic growth in the region. To the latter point, the Plan 

more 

predicts that greatest population growth over the plan period will 

sense from an economic standpoint to make significant investments benefiting disenfranchised 

and communities, which, based on SACOG's predicted growth trends, will comprise a 

groups 

in the region at or near the end of the plan period. The region simply cannot thrive as 

majority 

a whole if a significant portion of its population is not thriving. 2 SHA urges SACOG to make 

changes to the Plan that will better promote equity, and in 

turn, will promote economic 

opportunity and growth for all. 

Necessity for a Complete Legal and Regulatory Requirements List/Description 

requirements designed to promote equity are missing from the list. 

Under the agreement 

with all 

applicable Federal statutes, regulations and requirements relating to non,discrimination 

and equal opportunity identified in 

HUD's regulations at 24C.F:R. Sec. 5.105(a).. including the 

following [and their implementing regulations] :" ....... 

America's Tomorrow: Equity is the Superior Growth Model, Polio/Link 201i at 

See 

Page 153 of 165


Letter 

9, 2012 

January 

Title II of the Americans with Disabilities Act of 1990; 

4. 

The Fair Housing Act; 

5. 

Executive Order 11063, as amended by Executive Order 12259 (Nondiscrimination and 

6. 

Opportunity in Housing); and 

Equal 

7. The Age Discrimination Act of 1974 (Nondiscrimination on the Basis of Age). 

Additionally and importantly, SACOG warranted and certified as a 

manner that affirmatively further fair housing", 2) to "ensure that employment, contracting 

a 

other economic opportunities generated by the [Grant] shall, to the greatest extent 

and 

HUD in its nondiscrimination and equal opportunity compliance activities that are 

assist 

to maintain and submit racial, ethnic, disability, and other demographic data pursuant 

required 

to HUD's nondiscrimination and equal opportunity regulations[.]" 

(E J) communities. The framework section references Title Vl of the Civil Rights Act, 

Justice 

prohibits exclusion from participation, denial of benefits and discrimination under any 

which 

or activity receiving Federal financial assistance on the basis of race, color, national 

program 

gender, religion and disability, and related federal guidances, as well as Title Vl's broader 

origin, 

state law counterpart, Government Code Section 11135. MTP/SCS, pp. 8 1, 2. 

California 

this framework is very helpful in guiding SACOG and the public regarding SACOG's 

While 

with respect to EJ areas designated in the Plan, it might be misinterpreted to imply 

obligations 

Title VI and related laws apply only to the EJ areas, when this is not the case. Indeed, 

that 

need to... enhance their analytical capabilities to ensure that the long-range 

"MPOs 

plan and the transportation improvement program (TP) comply with Title VI." 

transportation 

1 and 2 of the Plan should also be listed on page 2-19 and Appendix G-5. 

as SACOG is aware, as a recipient of the HUD Partnership for Sustainable 

Finally, 

Grant, it must complete a Regional Fair Housi•ng Equity Assessment ("RFHEA"). 

Communities 

See HUD OSHC Terms and Conditions for FY 2010 NOFA, pp. 17 18. 

condition of receiving 

the HUD Sustainable Communities Regional Planning Grant funds to administer its grant; 1) 

"in 

be directed to low- and very low-income persons pursuant to Section 3 of Housing 

feasible, 

Urban Development Act of 1968" and implementing regulations, and 3) "to cooperate and 

and 

at the beginning of Chapter 8 on Equity and Choice, the MTP/SCS sets forth a 

Laudably, 

framework for planning for and addressing the needs of•the, region's Environmenta 

legal 

[emphasis added] 4. 

Accordingly, Title Vl and the related laws, regulations set forth on pages g 

The required components of this assessment are detailed below. 

The obligation to prepare this 

4Federal Highway Administration, 

An Overview of Transportation and Environmental Justice at 

http://www.polic¥1ink.orR/site/c.lklXLbMNJrE/b.7843037/k.B35B/Equit¥ Summit 

2011.htm. 

Page 154 of 165


Letter 

9, 2012 

January 

should be listed as well on page 2-19 and Appendix G-5, as well as set forth 

assessment 

Chapter 8 of the MTP/SCS in the Legal Framework section. 

explicitlyin 

Providing a 

is not a technical exercise. Rather, it is as essential to ensure that SACOG will have 

MTP/SCS 

comprehensive guidance to carry out its MTP/SCS activities in a manner consistent with 

the 

obligations, and to provide the transparency required to keep the public fully informed 

these 

able to monitor and participate in MTP/SCS development, implementation and activities. 

and 

Conform pages 2-19 and Appendix G-5 of the MTP/SCS to pages 17 and 18 

Recommendation: 

the HUD OSHC Terms and Conditions for FY 2010 NOFA and pages 8- I and 2 of the Plan 

of 

Improvements and Enhancements to Methodologies and Measures to Ensure 

Suggested 

and Properly Measure the Impact of the MTP/SCS on Protected Communities 

Equity 

appreciates the Draft MTP/SCS provisions intended to improve transit service, 

SHA 

the provisions to increase service by 44% per capita, reduce distance to the nearest 

including 

to 70 by 2035. Commendably, SACOG also endeavors to bring more transit to EJ Areas by 

hour 

bus service hours by 82 percent and rail and bus by combined 88 percent on routes 

increasing 

serve EJ. And, SHA supports the sections of the Draft MTP/SCS in which SACOG goes 

that 

the Federal Highway Administration EJ order 5 requirements by including sections on 

beyond 

transportation needs and opportunities to improve transportation services for the senior, 

the 

and youth populations. With respect to the Environmental Justice areas analysis, SHA 

disabled 

well-being of residents in EJ areas. 

of Title VI of the Civil Rights Act and the federal Fair Housing Act, and related 

requirements 

mandates within the context of the MTP/SCS may help put SHA's comments and 

equity 

Federal Highway Administration Environmental Justice Order 6640•23 (1998) at 

SSee 

23.htm• 

http://www.fhwa.dot.gov/legsregs/directives/orders/6640 

complete list of SACOG's legal and regulatory obligations related to the 

make explicit reference to the RFHEA so that SACOG and the public have complete and 

and 

guidance on SACOG's legal and regulatory obligations, including those that will 

accurate 

promote equity, regarding MTP/SCS implementation and activities. 

station f•om about ¾ to ½ a 

mile; and to increase passenger boardings from 33.3 per service 

is 

pleased that SACOG has added the current Draft MTP/SCS performance measures developed 

in 

with the Center for Regional Change ("CRC"), which are designed to provide a 

conjunction 

comprehensive picture of impact that the MTP/SCS will have on the health and overall 

more 

SHA believes SACOG can and should do much more to advance equity 

However, 

th"e Plan and hence, offers the recommendations below. An explanation of the 

through 

recommendations into context. 

4 

Page 155 of 165


Letter 

9, 2012 

January 

federal Fair Housing Act prohibits discrimination in a broad range of activities that 

The 

housing opportunities based on race and national origin, as well as religion, sex, familial 

impact 

and disability. 6 The Act prohibits not only intentionally discriminatory actions, but those 

status 

have a "disparate impact" on a protected group as well. 7 The Act prohibits discrimination 

that 

the form of exclusionary land use practices and policies 8, as well as practices or policies that 

in 

minorities from one community or concentrate minorities in another community. 9 

exclude 

Fair Housing Act further requires that federal programs and funds related to 

•he 

and urban development promote "truly integrated and balanced living patterns. "1° This 

housing 

in their jurisdiction; (2) take actions to overcome the effects of these impediments; 

opportunity 

(3) keep records of the analysis and actions. 11 This affirmative obligation requires recipients 

and 

federal funds to take actions necessary to both identify and break down existing patterns of 

of 

and other barriers to fair housing. 

segregation 

fair housing obligations are enhanced by the requirements of both Title VI of the 

These 

Rights Act, which prohibits discrimination by recipients of federal funds, lz and its state 

Civil 

federal and state requirements. 

HUD's recently released guidance on how this kind of analysis 

42 U.S.C• § 3604. 

6 

See, 

7 Pfaj•v. U.S. Dept. of Housing and Urban Development, 88 F.3d 739 (9th Cir. 1996); Keith v. Volpe, 858 

e.g,, 

467 (gth Cir. 1988). 

F.2d 

E.g., San Pedro Hotel Co. 

8 

City of Los Angeles, 159 F.3d 470, 475 (9th Cir. 1998); see generally Metropolitan 

v. 

Dev. Corp. v. Village of Arlington Heights, 558 F.2d 1283, 1291 (7th Cir. 1977). 

Hous. 

See, 

9 

Inclusive Comm. Project, Inc. v. Tex. Dep'tofl-lous. & Comm. Dev., 749 F. Supp. 2d 486, 500 (N.D. Tex. 

e.g., 

2010). 

Tra•icante lo 

Metro. Life Ins. Co., 409 U.S. 205, 211 (1972) (quoting 114 Cong. Rec. 3422 (1968) (statement of 

v. 

Mondale); The Fair Housing Act, § 808(d), (e), 42 U.S.C. § 3608(d), (e). The Housing Element Law also requires 

Sen. 

jurisdiction to adopt a series of actions "promote housing opportunities for all persons regardless of race, 

each 

11 

13 See 24 C.F.R. § 91.225. 

12 

42 U.S.C § 2000d. 

13 Cal. Go•. Code § 11135(a); Cal. Code Regs. tit. 22, § 98101. 

5 

to "affirmatively further fair housing", which SACOG has certified to HUD it will meet, 

obligation 

SACOG must (1) analyze impediments to integrated housing patterns and access to 

means 

counterpart, California Government Code § 

11135, which prohibits discrimination by recipients 

of state funds. •3 

A thorough fair housing analysis of the Draft MTP/SCS is 

essential to comply with these 

sex, marital status, ancestry, national origin, color, familial status, or disability." Cai Gay. Code § 

religion, 

65583(c)(S). 

Page 156 of 165


Letter 

9, 2012 

January 

fair housing opportunity should be conducted would help SACOG ensure that its MTP/SCS 

of 

not perpetuate existing racial and ethnic segregation patterns. 14 

does 

Indeed, SACOG set a 

deadline of December 31, 2011 by which to complete such assessment, is 

access to opportunity and d•mographic changes, and the strength of fair housing 

impact 

and activities. Specifically, HUD recommends utilizing three measures of segregation: 

services 

a dissimilarity index that measures the evenness with which white residents and residents of 

(1) 

are distributed across a jurisdiction or region (2) predicted racial and ethnic composition, 

color 

employed a 

fact that only 57 percent of households in Marin would be non-Hispanic white in an equal 

the 

housing market in contrast to Marin's actual 72 percent white population and that 

opportunity 

percent white. •6 SACOG, in conducting its required fair housing assessment and regional 

58.5 

housing analysis, should consider utilizing this methodology to see where in the region 

fair 

However, a 

14. and 

Source of data: 2005-2009 American Community Survey 5-Year Estimates, Tables B19001 and 

16 

B19001H. 

See also, Kirwan Institute Opportunity Mapping at http://www.kirwaninstitute.org/research/opportunit¥- 

17 

as SACOG is aware, all recipients of HUD's Partnership for Sustainable 

Relatedly, 

grants are required to conduct a Regional Fair Housing and Equity Assessment. 

Communities 

assessment must include analyses of segregation patterns, racially/ethnically concentrated 

The 

of poverty, access to existing areas of high opportunity, major public investments that 

areas 

(3) ethnically concentrated areas of poverty. HUD also recommends an analysis of access to 

and 

areas of high opportunity. Regarding the second metric, Bay Area equity advocates 

existing 

methodology that calculates what one would expect the race and ethnic diversity 

a city to be if all households regardless of race or ethnicity were free to live where others at 

of 

income level live. Application of this methodology produced interesting results, including 

their 

City of Pleasanton, which is 

70.8 percent non-Hispanic white, would be expected to be only 

exclusive housing patterns lie and take steps to address these patterns in its MTP/SCS. 17 

8 of the MTP/SCS appropriately focuses the "equity and choice" analysis on EJ 

Chapter 

in Sacramento. However, the MTP/SCS should also state clearly that most of the equity 

areas 

related to ensuring fair housing and transportation access governing the Plan 

mandates 

and implementation apply to the Plan in its entirety, not just EJ areas. 

development 

concern regarding the EJ analysis is that that it is•purely place-based, as 

Another 

people-based. A geographic unit may provide a proxy for some of the protected 

opposed•to 

categories of persons under Title Vl 

and the Fair Housing Act, such as race and ethnicity. 

purely place-based analysis does not directly analyze the Plan based on race nor 

http://www.hud.gov/offices/fheo/ima•es/fho•.pdf. 

14See 

Sacramento Region Consortium Sustainable Communities Planning Grant Project description/timeline, pp. 9, 10 

is 

communities/maooinz/. 

Page 157 of 165


Letter 

9, 2012 

January 

SACOG predicts will represent the greatest population growth between now and 2035 

which 

Hispanics and Asians). MTP/SCS, p. 8 7. As it stands, "minorities" are currently in the 

(among 

which is problematic in terms of SACOG's compliance with its Title VI, fair housing and 

analysis, 

obligations. Similarly, with respect to developing the criteria for the EJ areas, SHA 

related 

the MTP/SCS' inclusion of additional variables developed by the Center for Regional 

applauds 

however questions setting the "minority" population threshold at 70 percent. This 

Change, 

appears to have been set too high simply to keep the EJ areas within a manageable 

threshold 

percent. SHA urges SACOG to consider setting the threshold at 60 percent, which would 

26.5 

not only avoid and remediate disparate impacts, but affirmatively further fair housing. 

must 

cannot take necessary remedial and affirmative steps to ensure Title VI and fair housing 

SACOG 

compliance without a 

are several places in the Draft MTP/SCS that call forfurther equity analysis. For 

There 

the MTP/SCS plans to increase the proportion of small-lot and attached homes to 57 

example, 

EJ aiea, especially in terms of potential displacement and increases in housing costs. See 

the 

p. 8 -16. SHA urges SACOG to amend the plan to assure that in its entirety, the Plan will 

Plan, 

includes a 

is not made on the basis of race or other protected classes, it is incomplete visa vis 

analysis 

VI and fair housing obligations. 

Title 

the disproportionately "minority" residents in EJ a•eas, by SACOG's definition, 

Finally, 

a higher housing cost burden, lower education attainment, and are more 

experienc• 

isolated, among other barriers to economic stability and opportunity, as compared 

linguistically 

residents in whiter, non-EJ areas. And, the income and wealth gap between whites and non- 

to 

account for or consider the overall growth in 

the minority population throughout the region, 

in Sacramento County and comprise 50 percent of the population in Yolo County. 

majority 

Table 8 1, p. 8 6. Thus, under SACOG's current analytical model, the MTP/SCS's 

MTP/SCS, 

impact on •i 

significant part of the region's "minority" population will not be part of the equity 

capture more of the populations the MTP/SCS is 

obligated to analyze and for which SACOG 

sufficient and proper underlying analysis. 

percent.o• housing stock in EJ areas and 39 percent of the new housing options in non-EJ 

new 

has value, but SACOG must also consider what this shift means for people already living in 

areas 

benefit and not disproportionately burden 

protected classes. 

In the section of Chapter 8 of the MTP/SCS on Transportation and Accessibility, SACOG 

number of important categories of analysis, including transit access to jobs, medical 

care, higher education and parks. 

However, the analysis itself does not adequately measure for 

For example, if the increase in transit access to jobs is the same from EJ areas as it is 

equity. 

non-EJ areas, does this not create or perpetuate a disparate adverse impact on 

from 

"minorities" depending upon the relative place where each type of area started? 

And, since the 

whites has grown exponentially due to the financial and housing crises which have hit the 

7 

Page 158 of 165


Letter 

9, 2012 

January 

region particularly hard. 18 SACOG has both a legal obligation to utilize its MTP/SCS 

Sacramento 

its fullest capacity to close this gap, as well as an economic interest in ensuring that all 

to 

jurisdictions and neighborhoods are thriving and that the region does not devolve 

SACOG 

into an unequal, more racially and economically segregated and divided region due to 

further 

the adopted policies. 

• 

Include language in Chapter 8 that clarifies that the MTP/SCS must comply with Title 

• 

Consistent with the HUD-required Regional Fair Housing Assessment and SACOG's 

other fair-housing obligations, conduct a 

and future MTP/SCS and make policy, methodology and implementation 

current 

adjustments to ensure the Plan decreases segregation and affirmatively 

measure 

fair housing throughout the region. SHA recommends a deadline of June 30, 

furthers 

2012. 

• Continue to collaborate closely with equity organizations such as the Center for 

Direct significant investment into projects and policies that have the greatest 

• 

to promote and achieve equity in the first 5 to 10 years of the planning 

potential 

period. 

Add a Strategy to Policy 4 to address potential segregation and gentrification in 

• 

transit-rich areas throughout the SACOG region. 

comments submitted to SACOG on December 23, 2011.) 

Equity's 

Absent clear evidence of absence of bias in sources or studies, remove language in 

• 

Additional recommendations regarding specific changes and additions to MTPlSCS 

• 

and strategies, consistent with SHA's comments above, are attached. 

policies 

See Wealth Gaps Rise to Record High Between Whites, Black, Hispanics: Twenty to One (Pew Charitable Trust, 

18 

26, 2011) at http://www.pews•cia•trends.•rg/2•11/•7/26/wea•th-gaps-rise-t•-rec•rd-hi•hs-between-whites- 

July 

jump in third quarter, October 29, 2011 at http://www.sacbee.com/2011/09/15/3911662/after- 

foreclosures 

years-lull-sacramento-area.html#ixzz:lfdQRTWsD. 

19 SHA's concern is that such language in the MTP/SCS will form the basis for land use and housing policy decisions 

Recommendations: 

VI and the federal Fair Housing Act in its entirety, in addition with regard to EJ areas. 

comprehensive fair housing analysis of the 

Regional Change and the Coalition on Regional Equity to assess the current 

MTPISCS, 

and SACOG's performance under it, 

against federal and state equity mandates and 

Plan methodologies, metrics and implementation actions accordingly to 

improve 

compliance with these mandates. 

ensure 

(See the Coalition on Regional 

that suggests that families of certain races and ethnicities primarily double- 

MTPlSCS 

or crowd into fewer housing units overall for cultural reasons or for other reasons 

up 

other than out of economic choice. (See Plan, pp. 8 12 and 8 16.) 19 

blacks-hispanics/; Rick Daysog, Sacramento Bee, Foreclosures surge in 

region, September 15, 2011; New 

that perpetuate biases to the detriment of people and communities of color. 

8 

Page 159 of 165


Letter 

9, 2012 

January 

the Provisions in the MTP/SCS Related to Promoting and Increasing the Sm)•)lv of 

StrenRthen 

Housing Across the SACOG Region and Within Each Local Jurisdiction 

Affordable 

strongly recommends that SACOG add language to Policy 4 that gives more explicit 

SHA 

of affordable housing need across the region and in every jurisdiction within 

consideration 

model that would measure the degree to which a geographic area's housing actually "fits" 

fit 

affordable to) the types of jobs workers in that area have, since SACOG had committed to 

(is 

Consortium Sustainable Communities Planning Grant Project description/timeline, pp. 

Region 

14. SHA urges SACOG to move more aggressively toward developing this model so as to 

10, 

whether the MTP/SCS truly facilitates development of affordable housing across the 

assess 

as a whole as well as within specified jurisdictions or other geographic units. 

region 

• Amend Policy 4 as follows: SACOG supports every local jurisdiction's efforts to 

• 

Adopt a Policy or Strategy in the MTP/SCS that set a target date for completion of the 

as CRC and CORE throughout the process of developing the jobs-housing fit 

such 

and the process of making necessary changes to the current or next MTP/SCS 

model 

Ensure that the MTP/SCS Promotes Transportation Equity 

with Title Vl, by insuring that its federally funded activities, including development and 

comply 

of the MTP/SCS, do not discriminate implementation the basis of race, color or other 

on 

appreciates the MTP/SCS' relative level of investment in transit and increase in 

SHA 

the 2008 level of service--by 2035. However, SHA is concerned about the 

service--doubling 

SACOG. 

SHA is 

pleased to see strategies in the MTP/SCS that reference creating a jobs-housing 

create such a model by April :1, 201:1. See Plan, Chapter 6, Strategies 2.9 and 4.3; Sacramento 


facilitate development of housing in all 

price ranges, to meet the housing needs of the 

workforce and population, especially lower-income populations, and forestall 

local 

for long external commuting to work and essential services. 

pressure 

fit model. SHA proposes June 30, 2012. 

jobs-housing 

Collaborate closely with equity and affordable housing partners and stakeholders, 

• 

based on application of the model. 

Cognizant of the funding challenges SACOG faces in 

its efforts to promote 

efficiency and equity, SHA believes that the MTP/SCS must and transportation do much 

can 

to promote equity. Again, as a recipient of federal transportation funds, SACOG must 

more 

protected categories. 

9 

Page 160 of 165


Letter 

9, 2012 

January 

of the MTP/SCS, but not until 2020. P. 10-6. This, unfortunately, is opposite of the 

years 

of equity investment approach that SHA supports and recommends. SHA is 

"front-loading" 

that deferring investment into transit to late in the plan period will have a disparate 

concerned 

adverse impact on low-income communities, communities of color, people with disabilities 

and 

mechanisms through the MTP/SCS to address any adverse impact, including 

Develop 

Ensuring that decision regarding routes and times of services are 

• 

is a business approach to what is a social service. In times of 

levels 

resources, SACOG should prioritize the transit funding it has on 

limited 

Ensuring that the proceeds from Measure B in Sacramento County 

• 

in 2014 support transit operational and capital needs that 

beginning 

promote equity; 

also 

Ensuring that the anticipated shift of more than $2 billion of flexible 

• 

from road to transit over the planning period occurs in the 

revenue 

part of the remainder of the plan period; 

earlier 

to support systems expansion and restoration of routes and 

revenues 

times earlier in the plan period. 

running 

In collaboration with regional transit operators, transit users and equity 

• 

consider and analyze potential revenue generating measures, 

partners, 

road maintenance and 

timing of transit such investment as compared to investments in 

rehabilitation. 

Draft MTP/SCS states that "the limited growth in transit services for the first ten 

The 

dueto revenue constraints" means that there will be more robust growth in the later 

years 

and other populations that are disproportionately transit-dependent. 


the impact that the timing of the Draft MTP/SCS' transportation 

Analyze/measure 

priorities will have on populations in the SACOG region protected under Title VI 

investment 

and related equity mandates, and if the impact is 

disparate and negative, take affirmative 

steps to avoid and/or mitigate such impacts. 

determined by level of need--not level of ridership. 

Using ridership 

the communities who are in most need of reliable transit services. 

. 

Analyzing the potential for increased ridership, through lowering of 

• 

of limited income transit-dependent riders, to increase transit 

fares 

such as the City of Los Angeles' 30/10 Initiative, which would create a 

revenue source to develop 12 key mass transit projects in 

10 years, 

rather than 30. This is consistent with the concept of front-loading 

10 

Page 161 of 165


Letter 

9, 2012 

January 

to achieve transit equity in the earlier part of the remainder 

investment 

the SACOG Plan period. 

of 

you for considering our comments and recommendations. SHA looks forward to 

Thank 

engagement and collaboration with SACOG to ensure that the MTP/SCS meets its 

continued 

Tawatao 

Mona 

Counsel 

Regional 

fullest potential to advance sustainability, equity and economic growth for all 

in the SACOG 

region. 

Sincerely, 

11 

Page 162 of 165


Letter 

9, 2012 

January 

help MTP/SCS updates and local discussions on development patterns, including transportation 

to 

measures and opportunities related to accessibility, equity, public health, a• youth, 

performance 

Strategy: During the design phase, review transportation projects to assess whether they foster 

2.7 

choices, improve local community circulation and provide access to areas of hiqh 


or divide and further seqreqate communities, and either avoid or mitigate negative impacts 

opportunity 

those to public health;safety; air quality; housinq quality, affordability and stability; and the 

(including 

Strategy: Encourage adequate supply of housing at a variety of price ranges in the region, to meet 

4.3 

demand and prevent the export of housing to adjacent regions and the exacerbation of 

local 

Strategy: Provide support for jurisdictions to overcome common issues identified in local analyses of 

4.5 

to fair housing, such as racial and ethnic seqreqation, and a regional analysis funded by 

impediments 

Strategy: Help air districts and local agencies study localized air pollution impacts on health and the 

8.4 

particularly in EJ areas and areas of hiqh poverty and/or racial/ethnic concentration, 

environment, 

air toxins, by providing analysis and information from SACOG's planning work. Support public 

including 

efforts to raise awareness of these connections. 

information 

Strategy: Examine, analyze and steer funds and resources toward addressinq commute pattern 

24.3 

needs of those in job placement programs such as CaI-WORKS, those working nontraditional 

travel 

shifts, and those with reverse commutes as-a-guide-• for transit and supplemental travel 

employment 

imp'rovements. 

service 

Strategy: Ensure through examination, context sensitive design, and avoidance or mitigation of 

24.5 

system impacts wherever feasible, particularly displacement of residents, localized air 


ATTACHMENT TO SACRAMENTO HOUSING ALLIANCE'S COMMENT LEI-rER ON DRAFT MTP/SCS 2035 

2.5 Strategy: Continue to develop and apply social equity analysis methods and performance measures 

racial/ethnic inteqration and de-concentration of poverty. 

environment). 

racial/ethnic seqreqation and poverty concentration. 

federal grant funding from HUD. 

quality and noise impacts, when building improvements in 

low-income and minority communities 

adjacent to freeways, major roadways, and railroad corridors. 

12 

Page 163 of 165


Page 1 of 2 

1/10/2012 



To: 

Date: 1/9/2012 7:16 PM 




Name 

Email 

Rick Bettis 

rckbettis40@gmail.com 


No 


I believe the MTP/SCS is cvery comphrensive and apparently technically sound. SACOG staff should be 

commended on ther inclusive process and thoroughness of their work. 

I do have a few comments on some elements of the Plan that are primarily my view on priorities and emphasis. 

1. The growth projections should be monitored during implementation of the Plan to insure that the additions to the 

planned develoment are not made prematurely. 

2. SACOG is commendedfor ahieving increased per capita transit ridership even though the transit funding per 

capita has been reduced. This is due to emphasis on the Transit Priority Areas. It is important that these areas 

continue to recive priority treatment. 

3. Transit improvements such as the extention of LRT should begiven priority over road expansions such as HOV 

lanes or new roads such as the Placer Parkway. 

4.I agree that regulatory reforrm should be a priority so that good transit oriented compact mixed use development 

can be expedited. 

4. To facilitate compact mixed use infill significant public education efforts will continue to be necessary.This 

education should include the imprtance of environmental justice and equity. 

5.conjestion reduction as comtemplated in the Plan is a demonstration of what can result from good planning. We 

should deemphasize 'level of service" criteria and focus on motivating the public to use transit. 

6. There should a continued emphasis on funding transit operation and maintence of transit. 

7.Parking pricing and management should be used as a tool to motivate transit and bike-ped use and should not be 

considered as a means of funding other projects such as be considred by the city of Sacramento for a sports 

entetainment facility. 

8.Housing to meet the needs of all social economic levels should be facilitated. There should be a integrated and 

Page 164 of 165


Page 2 of 2 

1/10/2012 

inclusinary mix of housing types. 

9. A jobs housing fit methology needs to be developed and emphasized. 

9. Bike-ped connectivity and complete streets should be given a high priority. 

10. Goods movement needs to improved including the possible reestablishment of local short line freight rail. 

11. SACOG and local governments should be active in advocating for low emmisions vehicles and clean fuels that 

are under the regulatory jurusdiction of the State and Federl governments. 

12. In the Equity Chapter the access to facilities should include more emphasis on access by means of walking and 

transit. This is especially true for parks which should e accessible in all communities by walking. 

13. For new and replacement pavements considration should be given light colored "cool' pavements to reduce 

heat bulidup. 

14.Implementation of the forward thinking RUCS progam need continued emphasis. food trnsport is a major source 

of GHG and pollutant emmisons. 

15. SACOG should work with education providers to aquint the young with the importance of emmisions reduction 

to our health, economy and environment. 

Thank You Very Much for Your considration. 

rRck bettis 

Natural Resources Director League of Women Voters of Sacramento County 

Policy co-Chair Beathe Ca.- Sacramento 

Conservation-Co chair and Climate Change Chair Sierra club Sacramento and Mother Lode Chapter 

. 

Page 165 of 165


Page 1 of 1 

1/18/2012 



To: 

Date: 1/11/2012 5:10 PM 




Name 

Email 

Becky Wood 

bwood@teichert.com 


No 


There is a concept in the State guidance documents referred to as "distance maters". The idea being that the 

distance you need to transport material is important - to air quality, greenhouse gas production, congestion, vmt, 

etc. To help with minimizing the distance trucks move material you should plan for and protect your natural 

resources that are needed for build out of your plan. Therefore the plan should address aggregate resources 

needed for the life of the plan and the closest locations to supply the material. It should ensure that truck routes to 

those resources are protected and zoning includes the MRZ overlay. Otherwise enacting the plan will have a larger 

impact than necessary Please contact me if you need additional information to include in your plan..

NATURAL RESOURCES DEFENSE COUNCIL 


Chair Susan Peters 





Re: Comments on Draft MTP/SCS 2035 

Dear Chair Peters: 

We appreciate the opportunity to comment on SACOG’s 2035 MTP/SCS. This plan truly 

implements the intent of SB 375 by designing a transportation network and land use pattern to be 

mutually reinforcing to reduce emissions, and your staff should be commended. In particular, the 

following achievements are of note: 

• By employing land use as a transportation demand management strategy, this plan 

achieves a remarkable 7% reduction in congested vehicle miles traveled per capita, a 

noteworthy first for the region. While regions across the country have widened their 

roads in vain attempts to alleviate congestion, SACOG demonstrates that the more lasting 

and effective approach is to reduce the distances between homes and daily needs and 

provide real transportation choices for local travel. This is such an important 

accomplishment it can hardly be overstated. 

• This plan responds to the strong and growing demand for real transportation choices by 

increasing transit service hours by 98% and bike lanes by 77%. 

• Job accessibility improves by 31% on average, with jobs-housing balance improving in 

14 out of 15 major employment centers. SACOG’s innovative approach of focusing new 

housing around existing employment centers stands as a model for other regions to 

consider. 

In the spirit of collaboration and continual refinement, we offer our thoughts below on the areas 

in which this plan could be improved. 

Ensure that SACOG’s Housing Product Mix Meets Market Demand and Strengthens the 

Regional Economy 

As noted in the MTP/SCS, the 28 cities and counties of the SACOG region have been working 

voluntarily to incorporate the Blueprint plans and policies into their local general plans, and thus 

the housing mix SACOG assumes with this MTP/SCS is far different than the original Blueprint 

base/case scenario. Both the local general plans and SACOG’s analysis of housing market trends 

www.nrdc.org 

111 Sutter Street NEW YORK ⋅ WASHINGTON, DC ⋅ LOS ANGELES ⋅ CHICAGO ⋅ BEIJING 

20 th Floor 

San Francisco, CA 94104 

TEL 415 875-6100 FAX 415 875-6161

seem to suggest a preference for a greater variety of housing choice—in particular, increased 

demand for attached and smaller lot single family product nearer amenities and with greater 

transportation choices. Compared to the current available housing choices, the MTP/SCS moves 

the region in the right direction. 

But when considering the latest available housing market studies, it appears that the SACOG 

MTP/SCS may not go far enough in the right direction. A November, 2011 report from the 

Urban Land Institute (ULI) entitled The New California Dream compares the current (2010) 

supply of various housing product types to future (2035) market demand in California’s four 

largest regions i . The ULI report makes two particularly relevant findings for the Sacramento 

region: 

1. The 2010 supply of large lot single family housing (>1/8 th acre) in the SACOG region 

exceeds the projected demand for this housing type in 2035. Stated more clearly: the 

SACOG region already has more of this product type than will be needed in 2035, even 

assuming population growth. By contrast, the demand for small lot single family and 

attached products is strong and exceeds current supply by approximately 453,000 units, 

illustrated below in Figure 4.1. 

2. The projected 2035 demand for homes near transit is so strong that even if all new units 

constructed in the SACOG region between 2010 and 2035 were located near transit, the 

2035 demand would still outstrip supply, as depicted in Figure 4.2, below. 

2

Consideration of this information—which arguably represents the most detailed supply and 

demand analysis of SACOG’s housing market conducted to date—casts a new light on 

SACOG’s land use pattern. The ULI study admits that, while the best available market 

information finds little to no new demand for large lot single family homes, there will be some 

exceptions to this trend in niche markets. However, the general conclusion, which seems to be 

consistent across all four regions, is that there is a surplus of large lot single family homes in 

2010 as compared to 2035 demand: in SACOG’s case, that surplus is projected to be the 

equivalent of 193,000 homes. By contrast, the MTP/SCS projects that 29% of all new growth 

between 2008 and 2035 will be in the form of large lot single family homes. When compared 

with a robust market study that claims very little to negative demand for this housing type, 

SACOG’s housing mix appears a cause for concern. 

In addition to the threat posed to valuable natural resources by proposing to house nearly a third 

of the next increment of growth in large lot single family homes, there is an economic risk. 

Overbuilding a product type which appears to already be oversupplied, even assuming 23 years 

of robust population growth, can threaten the value of existing homes of this product type. We 

strongly urge the SACOG board to take note of this and other similar market studies and to 

consider the broader regional economic impacts. 

Second, the study finds a robust demand for homes near transit. In 2008, only 14 percent of 

housing units and 27 percent of employees were within SACOG’s definition of transit priority 

areas. Over the life of the plan, SACOG locates 38 percent of new dwelling units and 39 percent 

of new employees in these areas. SACOG’s investment in new transit service brings high quality 

service to an additional 152,216 existing dwelling units and 240,013 existing employees. While 

the provision of new transit to both new and existing units is the equivalent of serving all new 

growth with transit, the fact remains that with this next increment of growth, SACOG locates 

fewer than half of new homes and jobs near transit. As SACOG continues to monitor 

implementation of this SCS and prepare for either a mid-cycle update or the next SCS, we would 

strongly encourage you to focus development in areas that provide people with real 

transportation choices. 

3

We acknowledge that the ULI report is just one market study out of many and that all such 

projections are by nature uncertain. Still, a report that projects a future surplus of nearly 200,000 

housing units of a product type that SACOG continues to build should be given some serious 

consideration. Prior to its next RTP, we would encourage SACOG to conduct or continue to 

refine its own market study to ensure SACOG’s next 20 years of growth are appropriate to the 

market demand and help to strengthen the regional economy. 

Invest Transportation Dollars Strategically to Deliver Real Results 

SACOG puts its money in the right places, and critically, operates within its means. The new 

plan spends 12.5% less than the existing one, but the decrease is spread intelligently: a 20% 

decrease in capital projects versus only a 9% decrease in O&M, consistent with a “fix-it-first” 

investment strategy. It proposes to spend 8% of total revenues for bike and walk projects, plus 

include bike lane and sidewalk features on most arterial projects, dwarfing other region’s efforts 

to promote active transportation. The plan spends only 3% of revenues on state highway 

improvements, which no other region has done in 50 years of RTPs. SACOG’s fiscal constraint 

should be a model for other California regions, some of which simply assume new revenues to 

meet an ever growing appetite for new projects. And yet, in spite of this sound investment 

strategy, unfortunately 85% of all trips in the SACOG region by 2035 are still made by car. 

Below we make recommendations for strategies SACOG might consider to improve the return 

on its transit investments. 

• Prioritize transit investments in high-density arterial corridors. High density arterial 

corridors with no or limited transit service present strategic investment opportunities and 

should be prioritized to receive funding. SACOG should flag any sufficiently dense 

arterial corridors that currently lack this transit service and work with local jurisdictions 

and transit operators to accelerate service there. In arterial corridors where transit service 

doesn’t currently exist, service introduction should be timed with a sufficient density of 

homes or jobs along these arterial corridors. 

• Ensure sufficient densities and strong ridership potential prior to initiation of costly 

capital transit projects. As suggested by strategy 28.9, bus transit may be a less 

expensive and more practical investment in key new transit corridors prior to capital 

intensive rail projects. It may make sense to defer some of these rail projects until bus 

service has proven that strong ridership demand exists in these corridors. 

• Schedule road construction to occur later in the plan to avoid triggering growth 

outside existing urban areas. Any capacity increases at the urban edge should be phased 

to occur during the plan’s later years to ensure they are not growth-inducing, but rather 

demand management strategies. Construction of these costly capital facilities should be 

initiated only once demand is strong enough to warrant their development. 

• Improve parking policies to support walkable communities and transit use. Chapter 

3 specifically notes that parking policies may be a barrier to realization of SACOG’s 

desired land use pattern. Strategies 3.7 and 16.1 can help to address what is surely one of 

the most powerful drivers of the decision to drive in the SACOG region--the abundance 

of free and available parking--and we strongly support prioritizing these research efforts, 

and moving towards implementation of their findings. Modifying current parking 

4

egulations can help to ensure that developers are able to deliver the walkable, transitoriented 

housing the market is demanding. Well designed, parking pricing policies can 

help pay for business improvement districts and shuttles, boost returns for local merchant, 

and support increased transit use. 

Additional Policies and Recommendations 

In addition to detailing its proposed investments and land use pattern, this plan includes an 

excellent chapter on additional policies and strategies to ensure effective implementation. This 

chapter could be strengthened by providing more detail on the state policies which will be 

necessary to realize the promise of this plan. The recent Supreme Court decision on the 

elimination of redevelopment agencies, for example, provides a significant complication for 

implementation of this plan. 

This plan can take a step towards achieving its goals by articulating clearly for state policy 

makers which additional tools will be necessary for implementation. 

In particular, Strategy 1.2 calls for regulatory reform at the state, national and local levels to 

encourage Blueprint-style growth. More detail on the nature of such reforms would help guide 

policymakers. Strategy 18.4 mentions working with the state Strategic Growth Council. We 

would strongly recommend that SACOG work closely with the Council, the Governor, and the 

Legislature to advocate the necessary reforms to ensure this plan delivers on its promise. This 

collaboration should begin with a presentation to the Council with recommendations for 

administrative and legislative solutions to remove barriers. 

We thank you for your continued excellence in leadership and look forward to working with you 

in the weeks and months to come. 

Sincerely, 

Amanda Eaken, Deputy Director for Sustainable Communities 

Natural Resources Defense Council 

Meea Kang, President 

California Infill Builders Association 

i http://www.uli.org/ResearchAndPublications/~/media/ResearchAndPublications/Report/ULI%20Voices%20Nelson%20The%20New%20Califor 

nia%20Dream.ashx 

5

Yuba County Elected Official Information Session Public Comments from January 25, 2012 

Jim Seif 

Process is a sham. Decisions are already made by developers; we didn’t get to 

sit at the table when plans were being made. 

He and others are not being properly represented at SACOG by their local 

elected who sit on SACOG board; local SACOG representatives don’t record or 

report back their SACOG actions. 

SACOG says we have local control, but SB 375 says communities will be sued if 

not incompliance with regional plan. 

SACOG is deciding how, where, and when people should live and that’s wrong. 

Yuba and Sutter are different from Sacramento and our elected officials aren’t 

hearing us say we don’t want this. 

Process should include real public input for all citizens. If citizens could vote on 

SACOG Board, they would vote to get out of SACOG. 

The comments here are summaries of the oral testimonies provided at this public meeting.


Debbie Gaylord 

Disappointed the staff presentation didn’t get into meat of plan because did go 

through it to come up with real questions and concerns after reviewing plan. 

Reference page 2-9 related to Public Participation Plan for stakeholders 

representing social equity, bicyclists, pedestrians, etc., but is wondering about 

people like me who want to drive my car and live on ¼ acre. This plan doesn’t 

allow for that. . 

Beale doesn’t pay sales tax to county so the county has no authority over their 

air emissions; seems detrimental to Yuba County to have to consider them an 

established community in the county (in the same way as other established 

communities). 

Referenced page 3-13, real estate forecasts for small lot, mixed use, and 

commercial use and is concerned that mixed-use housing cannot be financed. 

Would like the source for information on that page. 

Referenced pages 3-18 and 3-19 regarding number of houses on a large lot, 

attached and detached. This says you can put 5-8 homes on a large lot and 8-25 

homes on a large lot. This can’t be done, I have asked developers and they say 

you can’t build 25 detached houses on one acre. Yuba and Sutter county 

residents don’t want to live that way. Many of the residents came to Yuba and 

Sutter counties for affordable housing. 

Referenced page 3-20 regarding jobs-housing fit measure to assess the fit at 

smaller geographic scale for local workers and affordable housing. This sounds 

like Yuba and Sutter counties would only get help attracting low-wage jobs and 

that’s not what they want. 

Have questions and would like answers. 



John Larimer 

United Nations has propagated global warming hoax. United Nations has 

abandoned global warming. Agenda has percolated to local level. Agenda 21. 

Commenter read resolution approved by Republican National Committee on 

January 13- Resolution Exposing United Nations Agenda 21. 

We have AB 32, SB 375 all to control greenhouse gas emissions. Why? Because 

CARB is trying to control carbon emissions and climate change. CARB figured out 

most emissions are from freeways so they want to change fuels and restrict 

driving. Carbon emissions are not causing any trouble at all, temperatures are 

not rising even a half a percent. 

In the process of trying to fix global warming, which is non-existent, they want to 

stack us and pack us, take away automobiles, telling us where to live, sticking us 

in the projects. If you want to see where this is going look at Siskiyou County. 

Water rates have gone up 800%, farmers are literally being driven off their land. 

Concerned that the MTP is an extension of United Nations Agenda 21 and fears 

loss of personal freedoms and property rights if this plan is supported/adopted. 



Carla Verga 

Upset this is supposed to be a meeting for Elected Official and that there are not 

very many officials from Yuba County. Concerned plan is being rubberstampedupset 

to see people supposed to be representing us selling us up the river. 



Bob Sweringen 

This plan is part of agenda 21. Agenda 21 is about forcing people to live in high 

density housing. One way doing that is by coming to counties like this and 

offering incentives or money to implement this so counties are agreeing because 

they need money. If you go to northern California the people there will tell you 

they are destroying their land. Can’t access forest lands anymore, no longer 

allowed as recreation areas. 

Ultimately what they want is for everyone to live on corridors. Want to take 

agriculture and move it to other countries so if you’re a farmer in America, they 

will change what can happen on your land. Bottom line, start learning about 

Agenda 21. Understand what you are buying into and committing us to. 

This plan is telling you that you will live in apartments. They are telling us that 

the number of single family homes will be less. What if we don’t want to live in a 

high rise apartment? 



Larry Berga 

Agenda 21 defines sustainable development, this presentation just skimmed over 

it. Can you tell me what sustainable development means as referenced in this 

plan. 



Chuck Miller 

Believes plan has direct relationship with United Nations Agenda 21. Believes 

Agenda 21 is implementing communism and that the first thing communist 

regimes do is get rid of old people. These folks are doing what the law is telling 

them (AB 32 and SB 375) to do and there is something wrong with that. 



Vera Correa 

As part of the plan she has seen infrastructure, sidewalks, signs that tell kids 

where they can walk safely. Need to make it so much safer for children and 

pedestrians and we need this money, the county doesn’t have it. This is 

something that we as citizens need to do, it’s not about Republicans or 

Democrats. 



Jerry Antonetti 

Worked at Caltrans before there was a SACOG. Cities and counties used to 

decide where money was spent. George Bush started these MPOs. Caltrans had 

never administered money like this. Now we see SACOG is involved is in Agenda 

21. 

Does not see how this plan works with city councils and other local governments 

that are able to provide the necessary infrastructure in the transportation plans 

with air quality maintenance districts regarding air pollution and contamination. 

Believes it is now a matter of land use planning via air quality controls. AQMD is 

really the true power behind this. Land Use and transportation planning by air 

quality controls. 

AQMD has very divisive factor here, people will die from cholesterol at 

McDonalds before they die of GHGs. Spoke to new auto technology. 

Believes this is all based on false science and premises. I’m involved in Agenda 21 

lawsuit against US Forest Service and Bureau of Land Management regarding 

shutting down trails and access to forest land. 



Pat Miller 

Referenced reading from Agenda 21 where private property rights go against 

what is good for society over all with the goal for society not the individual. 

Believes government will start taking away freedoms and then next put people in 

stack and pack houses, dictate what people drive, and take people's property 

and guns. 

To get the federal funds for sidewalks and signs you have to cooperate with 

executive order and environmental section which is form of bribery. 



Dot Sweringen 

If it is not broken, why are we doing it? 



Bob McClard 

To get to the point this is forcing or encouraging people to live more densely 

packed. By getting people to live closer together and closer to work. Were 

people asked if they wanted to live in denser housing? 



Anonymous 

Where will funding for high density housing come from? Is it all government 

subsidized? 



Anonymous 

Wanted to say thank you. Lot of these other commenters are older; they 

won’t be here in 20 years. My son will. Appreciate planning for better air 

quality. 


Lincoln Community Meeting Comments from January 9, 2012 

Anonymous 

Comment about which jurisdictions may have abstained from supporting the MOU 

for the MTP/SCS. 



Anonymous 

This is a republic not a democracy. 



Anonymous 

Principle disagreement about federal/state/regional influence on local land use. 



Bob Rafighi 

All of the beauty we have, you are telling me we have to change. It is not clear 

what part of the city or region are included in the drawings, mixed circles and 

color scheme. How do you draw a circle on private property without infringing on 

my property rights? 

The commenter voted for city council members and thinks he is being told he has 

to accept funds and other aspects of plan. He doesn't want to go forward. He 

hasn't seen any buses go around area with more than 2 people in them. Believes 

there is also an assumption about transportation needs for older people. He is 75 

years old and doesn't want to be told how to travel and live. 



John T. Larimer 

The "right to notice" is a fundamental right and that the plan was not adequately 

noticed. The plan that he was only able to download on Sunday was dated 

December 10, 2011. The earliest comment was December 19. The plan was put 

on the internet in a form that he was not able to download on his computer. 

Concerned about command economy and control of his property and rights. 

This is reminiscent of communist countries of which he listed countries by 

example. The high language in the plan talking about utopia is more like 

enslavement; even if we have our property will not be able to enjoy it. 

Expressed concern about the comment period during the holidays. 

Don’t know how you can have an environmental impact report without clarity of 

what the report is studying. 

Water price increases for farmers and ranchers have gone up 800% in 

anticipation of four damns being blown up. Cost is astronomical. If we want to 

be able to eat, can’t be having waters stolen for salmon and trout. 

Concerned government is creating a bureaucratic monster with decisions that 

won’t be made by local council members and Board of Supervisor. Concerned 

about the authority that planners and the rest of this bureaucracy will have. 

1033 pages. Has the mayor read this? 

Elected officials are relying on the planners to tell them what to do. You are 

picking winners and losers in this action. 

At a time when state, federal, counties and cities are broke, government 

planners and NGO employees are spending tons and tons of money and hours to 

steal freedom and destroy prosperity. 

They are planning on increased population while we see thousands of people 

leaving California. 



Jim Ricketts 

What is the source of the power in addition to the local laws and legislation and 

the power to disburse funds from the public purse? Concerned that this 

authority allows for funding expenditures to projects that serve narrow interests 

and that funds are taken from citizens and passed onto the interests of those 

authorities. Funds always come with strings attached. 

Concerned that government will take away single family homes and ability for 

people to use private autos as well as freedoms to live, work, and shop where 

people want. We will decide where and how we are going to live not SACOG. 



Kathy Dorsey 

Question regarding Financial Stewardship and list of various funds on overhead 

and portion attributed to Placer County. How was the portion apportioned to 

Placer County calculated? 



Pat Patterson 

Helpful to listen and ask what is applicable to me. Ask the dear Lord to give me 

guidance to do the important thing even if it will cost me my life in order to do 

what is right and moral. 



Judy Roberts 

What are our abilities to assess the efficiencies of public transit services that we 

have right now? 

Fair to say it (transit service) operates at a deficit? 

Highways are a need with demand, but rail and transit runs at a deficit. In the 

future there will be a transit cost that is greater and will require more funds be 

taken from people or their cars will be taken away. 

Road congestion question about carpool lanes and inquired about the 

efficiencies of carpool lanes to reduce congestion. Would seem that after seeing 

so many of years of this inefficiency, it would seem that this isn’t where funds 

should be spent. 



Lois Engle 

New resident of Placer County with property on Sierra College Boulevard. Was 

not told when she purchased it that there were planned changes that would 

impact her grazing lands. Real estate and the Town of Loomis should have 

provided her information for what was the potential for the land she purchase. 



Cynthia Atkinson 

It is dishonest to plan meeting to take place during the holidays because you get 

the smallest outcome of input from the smallest number of people and therefore 

go forward. Meeting should have been scheduled during a time when the 

majority of people would be able to attend. 

Believes that the suggestions and guidelines for the disabled in the MTP were 

developed before being given to the disabled. Difficult for an elderly person to 

take the bus to a meeting or service. When you are disabled, how will you feel 

about going out yourself in that fashion and looking for your public 

transportation and then waiting and trying to get on as an older man? Lots and 

lots of people use the scooters for mobility. Most of the elderly are projected to 

need more help than to be dropped off at a bus. 

As a social worker, believes that there is a misappropriation of funds to whatever 

small group at the top decides is the priority for funds. Generally concerned that 

government is deciding what to spend money on and believes it is the people 

who should decide how money is spent. 



Judi Caler 

Wanted to encourage the residents of Lincoln to drop out of this activity and 

appreciate that you have not accepted the funding. 

Where are these funds coming from if our country, state, county and cities are 

broke? 

Seem to think that funds from the federal government is free. Funds from 

stimulus projects and grants will deplete any savings or inflation that we have 

worked for. Need ability to opt out of this free money. 

Concerned that the plan is a recipe to take over society. Doesn't believe the plan 

is about protect the environment but about taking control of people. 

Believes global warming is a joke and a lie. Research since 1990 has failed to 

substantiate any direct man made cause for global warming. A consensus is 

nothing more than an absence of recorded disagreement. 

Believes that local representative government is almost obsolete. When 

government wants the public involved, it is to give the appearance of public 

participation and to marginalize any opposition to its plans. These are called 

visioning meetings with unreasonable alternatives as choices. 

It is audacious of planners to determine that they are better than the rest of us 

to make decisions better than the rest of us. In Lincoln, stand up for your rights 

and the constitution which makes laws for the common good. 

Concerned that traveling by transit will be the only travel option. 

Concerned local governments are using federal monies which come with strings 

attached for stack and pack housing which may not be of all of our choosing. 



Ruth Crone 

Is this a map of what you want it to look like in the future or what you want it to 

look like now? Question specific of rural residential communities in Yolo County. 

What is the difference between current map and the map you want us to be on? 

Map is still assuming that our region will be growing. Heard several references to 

state and federal statutes, and legal foundation at SACOG, asked if SACOG staff 

could elaborate so public could understand. 

SACOG and its plan create another level of separation because local jurisdictions 

joined into this regional function with support of state and federal government in 

some cases. 


Colfax City Council Meeting Comments from February 8, 2012 

Neil Wilson 

Concerned about loss of private property rights, freedom and judgment with 

everything being planned by government. 



Ed Duffek 

Does not understand how priority development areas, sustainable living is going 

to take place. Are we going to be forced to do this? Is he going to move into a 

stack building? The map showing that there will be very little rural development. 

Does not understand how moving a lot of people into a little city will conclude 

the global warming. 



John Larimer 

This plan is stacking and packing housing and development. 

This planned ties in with United Nations Agenda 21 and that ICLEI is the United 

Nations' private organization immediately beneath and apart of Agenda 21. 

There is no such thing as greenhouse gases. 



Judy Caler 

Encouraged the city council to continue avoiding this scheme. 

Government has its eyes set on money that it believes is theirs when it really 

belongs to the people. Bureaucrats are unknowingly threatening our freedoms. 

How do planners know better than us? To projection that the population will 

increase is an insult to us. 

Where in this document is any authority given to private property rights? 



RayAnn Vowell 

Sustainable development sounds very good. What it really is a leading to an 

abolition of private property rights. They are trying to get people off their farms 

and off their lands. Most Americans do not know or understand the integrated 

policy of sustainability. 

Concerned that this plans has ties with United Nations Agenda 21 and will lead to 

control over land, water use, energy use, food production, and number of 

children families can have. 



Bob Refugi 

Problem with the word sustainability is that everything is supposed to be 

sustainable. We have always had everything we need in this country. Suddenly 

we have this agenda that is appearing before everyone in the US that says we 

have problems with water, endangered species, utility meters...everything has to 

be sustainable. 

I don’t think my utility meter needs to be smart. It is a fabricated crisis that we 

are jumping against. Do you think we are going to be here in 2035 to cut 

ribbons? 

Where is the transportation to forests and farmland? Concerned about not 

having access to forests and farmland. Local land use and property rights will be 

taken away. 



Dwayne Armstrong 

Disagreed with the outcome that SACOG was proposing. If you put people into 

confined areas, major pollutions are going to go up. There will be impacts to 

sewer system, crime will increase and government is going to control the water. 

A lot of cities are going to reclaim water. 

By 2035, SACOG’s agenda is going to change. How can you come up with a 

conclusion when you do not have all the facts? 

Technology is going to replace the fossil fuel burning. 



Pat Patterson 

Concerned about being able to grow own food and that government may take 

that away. We need to be extremely careful and watch the details.

Draft MTP/SCS Comments Received - sacog

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