As noted in a previous blog post about the EIR, the Metropolitan Transportation Commission (MTC) and the Association of Bay Area Governments (ABAG) is continuing their work on a Draft Environmental Impact Report (EIR) for Plan Bay Area. The EIR will analyze the environmental impacts of land use scenarios and transportation investments that will be considered for Plan Bay Area.
The first phase of the EIR was the “Scoping Phase” where the public was invited to attend one of five public meetings to comment on the scope and content of the environmental information that will be evaluated. The first meeting in Oakland (June 20) had some active participation from local Tea Party activist that dominated the discussion. The second meeting in San Jose (June 21) that I attended was very productive and had an audience that respected the process. The public was able to make comments and ask questions. Several members of the audience had the opportunity to ask multiple questions.
The deadline for formal written comments was July 11, 2012 and TransForm submitted its formal EIR Scoping Comment Letter to Ashley Nguyen (EIR Project Manager to email@example.com ).
Click here to read TransForm's letter. See below for the Final 5 Alternatives that were approved in a Special Meeting of the MTC and ABAG Commission on July 19, 2012. The July 19 agenda can be seen here.
TransForm submitted its formal comment letter on July 5, 2012. Here are a few highlights from our letter:
For Plan Bay Area to succeed, we believe that it needs to test of a wide range of possible policy inputs. This will allow the final plan to be constructed from the preferred scenario adopted in May plus the best elements of other alternatives tested in the EIR process. In particular, we support construction of an Equity, Environment, and Jobs (EEJ) Alternative to test the limits of Plan Bay Area. We offered the following comments. We have comments on each of the transportation-related policy measures, including multiple comments on both the Transit Network and Road Network.
Road Pricing: we are disappointed to see that the scoping meetings presented the “Project” alternative (#2) with “No Pricing.” It is unrealistic to assume no change in bridge toll revenues, and MTC’s revenue estimates already assume some revenue from New Bridge Tolls (perhaps not up to the $10 listed as Option D for Road Pricing). For the rest of the alternatives, we support testing a wide variety of pricing approaches, including several of the options listed on the staff handouts.
Road Network: We recommend that several of the alternatives include only HOV lane conversions for Express Lanes.
Transit Network: For the EEJ alternative, we support testing the impact of an alternative with transit service, funded by shifting funds from Freeway Performance Initiatives, OBAG, and Regional Express Lanes Network.
Transit Network: In conducting the EIR, MTC needs to develop an appropriate methodology to recognize that differing levels of investment in maintenance will affect regional results on a host of key measures. To date, we understand that MTC has not been able to model the difference between different levels of investment in maintenance, and we understand there are significant methodological difficulties in doing that modeling. But we suggest that it is unrealistic for the EIR to assume the same transit network regardless of how much the region invests in maintenance. If all the alternatives will have the same investment in maintenance, then figuring out this methodological problem is not as important for this EIR. But if the alternatives will have different levels of investment in maintenance, then this methodological problem is important.
Road Network & Transit Network: We were pleased to hear from MTC staff, in the June 29 meeting we participated in, that projects that are only included for study in the RTP/SCS investment package, but not for construction (e.g., SR 239, BART to Livermore), will not be included in the transportation networks studied in any of the EIR alternatives.
The five alternatives approved for analysis by the commission on July 19 are:
- The No Project alternative – This alternative begins with the 2010 land use pattern and transportation network and assumes the continuation of currently-adopted general plans through 2040. CEQA requires examination of a no project alternative.
- The “Preferred Land Use and Transportation Investment Strategy” alternative – The preferred alternative assumes a land use development pattern in which 80 percent of the Bay Area’s household growth and 66 percent of its job growth are located in “Priority Development Areas” identified by local jurisdictions. It pairs this land development pattern with the Plan Bay Area Preferred Transportation Investment Strategy, which dedicates nearly 90 percent of future revenues to maintaining our existing road and transit system.
- The Transit Priority Focus alternative – This alternative will evaluate the potential for more efficient land uses in Transit Priority Project areas, which are areas called out in Senate Bill 375 that could be developed at higher densities to support high quality transit.
- The Enhanced Network of Communities alternative – This alternative was informed by input from the business community. It seeks to provide sufficient housing for all people employed in the San Francisco Bay Area and allows for more dispersed growth patterns.
- The Environment, Equity and Jobs alternative – This alternative was developed by input from the equity and environmental community. It seeks to maximize affordable housing in opportunity areas in both urban and suburban areas through incentives and housing subsidies. The suburban growth is supported by increased transit service to historically disadvantaged communities through studying a Vehicle Miles Traveled (VMT) tax and higher bridge tolls.
The next steps in the process are as follows:
- July - December, 2012 – The agencies will prepare the Draft EIR.
- December 14, 2012 – The agencies are scheduled to release the Draft EIR and Draft Plan Bay Area for 45- and 55-day public review periods by the Joint MTC Planning and ABAG Administrative committees.
- January 2013 – The agencies will hold public hearings on the Draft Plan and Draft EIR.
- February - March 2013 – The agencies will prepare a Final EIR (including Response to Comments).
- April 2013 – MTC and the ABAG Executive Board are scheduled to certify the Final EIR and adopt the Final Plan Bay Area.
For more information on the process and how to participate please contact Manolo González-Estay from TransForm at (510) 740-3150.