Draft MTP/SCS Comments Received - sacog

SCS Health & Equity Metrics August 2011
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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