1

Comments and Responses

ADOPTED APRIL 2012
2

Index

(ALPHABETICAL)

Affiliation Submittal ID

Alliance for a Healthy Orange County 001, 002American Lung Association 003, 004American Society of Civil Engineers 005Ameron International Corporation Water TransmissionGroup 006Arroyo Verdugo Subregion 007Association of California Cities Orange County 008Automobile Club of Southern California 009BREATHE LA 010Brooks Street 011Building Industry Association of Southern California 012, 013Burbank‐Glendale‐Pasadena Airport Authority 014California Department of Parks and Recreation 015California Department of Public Health 016California Department of Transportation 017California Environmental Associates 018California Natural Gas Vehicle Coalition 019California Rural Legal Assistance, Inc. 020California Trucking Association 021Canyon Land Conservation Fund 022Centennial California 023Center for Demographic Research 024Citizens Alliance for Property Rights 025Citizens Alliance for Property Rights, Ventura County 026City of Alhambra 027City of Anaheim 028City of Brea 029City of Burbank 030City of Chino 031

Affiliation City of Chino Hills City of Colton City of Cypress City of Diamond Bar City of Glendale City of Hemet City of Highland City of Irvine City of La Canada Flintridge City of La Habra City of Lake Forest City of Los Angeles City of Newport Beach City of Ontario City of Oxnard City of Palmdale City of Pasadena City of Pico Rivera City of Rancho Santa Margarita City of Riverside City of San Clemente City of San Jacinto City of Santa Ana City of Santa Clarita City of South Pasadena City of Stanton City of Thousand Oaks, Public Works/Transit City of Tustin Clean Air Now 
3

Affiliation Submittal IDClean Energy 063ClimatePlan 064Coachella Valley Association of Governments and Western

Riverside Council of Governments 065

County of Los Angeles Board of Supervisors 066County of Los Angeles Department of Public Health 067County of Orange 068DesertXpress Enterprises, LLC 069downeygreen 070Editor, El Toro Info Site 071Environmental Protection Agency 072Four Corners Coalition 073Friends of Coyote Hills 074Friends of Harbors, Beaches, and Parks 075Gateway Cities Council of Governments 076Global Land Use and Economic Council 077Governor's Office of Planning and Research 078GRID/ECSTC Systems 079Highgrove Area Redevelopment 080, 081Hills For Everyone 082Human Impact Partners 083Imperial County Air Pollution Control District 084Kohl Ranch Company LLC 085LA 32 Neighborhood Council 086LA 32 Neighborhood Council and NELA Coalition 087Latino Health Access 088Los Angeles Alliance for a New Economy 089Los Angeles County Bicycle Coalition 090Los Angeles County Business Federation 091Los Angeles County Department of Public Health 092Los Angeles County Department of Regional Planning 093Los Angeles County Metropolitan Transportation Authority 094, 095, 096

Affiliation Los Angeles World Airports March Joint Powers Authority Mobility 21 Move LA NAIOP Natural Resources Defense Council NO 710 Action Committee Orange County (multiple agencies) Orange County Business Council Orange County Council of Governments Orange County Renewable Energy Society Orange County Transportation Authority Orangeline Development Authority Pasadena Chamber of Commerce Physicians for Social Responsibility, and Other

Organizations (collaborative letter) 

Port of Long Beach Puente‐Chino Hills Task Force of the Sierra Club Realtors Committee on Air Quality Regent Properties Regional Hispanic Chamber of Commerce Reservation Transportation Authority Riverside County Department of Public Health Riverside County Planning Department Riverside County Transportation Commission Riverside Transit Agency Safe Routes to School National Partnership San Bernardino Associated Governments San Fernando Valley Council of Governments San Fernando Valley Green Team San Gabriel Valley Council of Governments San Gabriel Valley Economic Partnership 
4

Affiliation Submittal IDSan Gorgonio Sierra Club 138San Manuel Band of Mission Indians 139Santa Monica Mountains Conservancy 140Siembab Corporation 141Sierra Club 142South Bay Cities Council of Governments 143South Coast Air Quality Management District 144Southern California Association of Non‐Profit Housing 145Southern California Business Community 146Southern California Contractors Association 147Southern California Contractors Association, Inc. 148Southern California Edison 149Southern California Gas Company 150Southern California Leadership Council 151, 152Southern California Regional Rail Authority 153Stephen W Rogers P.E. Consulting 154, 155, 156Supervisor, First District, County of Ventura 157The American Institute of Architects 158, 159The Center for Community Action and Environmental

Justice 160

The Kennedy Commission 161The Transit Coalition 162Transit Coalition 163Transportation Corridor Agencies 164Trustee, San Bernardino Community College District 165, 166, 167, 168Unitarian Universalist Legislative Ministry 169Urban and Environmental Policy Institute Occidental

College 170

Valley Industry and Commerce Association 171VCCool + Ventura Bicycle Union 172Ventura County Air Pollution Control District 173

Affiliation Ventura County Climate Care Options Organized Western States Petroleum Association Wildlife Corridor Conservation Authority WRAC No Affiliation/Individuals 
5

Index

(BY TYPE OF GROUP)

Affiliation Submittal ID

County Transportation CommissionsLos Angeles County Metropolitan Transportation Authority 094, 095, 096Orange County Transportation Authority 111, 112, 113Riverside County Transportation Commission 126, 127, 128San Bernardino Associated Governments 133SubregionsArroyo Verdugo Subregion 007Coachella Valley Association of Governments and Western

Riverside Council of Governments 065

Gateway Cities Council of Governments 076Orange County Council of Governments 109San Fernando Valley Council of Governments 134San Gabriel Valley Council of Governments 136South Bay Cities Council of Governments 143Local AgenciesCity of Alhambra 027City of Anaheim 028City of Brea 029City of Burbank 030City of Chino 031City of Chino Hills 032City of Colton 033City of Cypress 034City of Diamond Bar 035City of Glendale 036City of Hemet 037City of Highland 038City of Irvine 039City of La Canada Flintridge 040

Affiliation City of La Habra City of Lake Forest City of Los Angeles City of Newport Beach City of Ontario City of Oxnard City of Palmdale City of Pasadena City of Pico Rivera City of Rancho Santa Margarita City of Riverside City of San Clemente City of San Jacinto City of Santa Ana City of Santa Clarita City of South Pasadena City of Stanton City of Thousand Oaks, Public Works/Transit City of Tustin County of Orange Supervisor, First District, County of Ventura Association of Local AgenciesAssociation of California Cities Orange County Center for Demographic Research Four Corners Coalition Orange County (multiple agencies) 
6

Affiliation Submittal IDOther Implementing AgenciesBurbank‐Glendale‐Pasadena Airport Authority 014California Department of Transportation 017DesertXpress Enterprises, LLC 069Los Angeles World Airports 097March Joint Powers Authority 098Orangeline Development Authority 114Port of Long Beach 117, 118Riverside Transit Agency 129Southern California Regional Rail Authority 153Transportation Corridor Agencies 164Other Government AgenciesCalifornia Department of Parks and Recreation 015California Department of Public Health 016County of Los Angeles Board of Supervisors 066County of Los Angeles Department of Public Health 067Environmental Protection Agency 072Governor's Office of Planning and Research 078Los Angeles County Department of Public Health 092Los Angeles County Department of Regional Planning 093Pasadena Chamber of Commerce 115Reservation Transportation Authority 123Riverside County Department of Public Health 124Riverside County Planning Department 125San Manuel Band of Mission Indians 139South Coast Air Quality Management District 144Ventura County Air Pollution Control District 173Non‐Governmental GroupsAlliance for a Healthy Orange County 001, 002American Lung Association 003, 004American Society of Civil Engineers 005

Affiliation Ameron International Corporation Water TransmGroup Automobile Club of Southern California BREATHE LA Brooks Street Building Industry Association of Southern CalifoCalifornia Environmental Associates California Natural Gas Vehicle Coalition California Rural Legal Assistance, Inc. California Trucking Association Canyon Land Conservation Fund Centennial California Citizens Alliance for Property Rights Citizens Alliance for Property Rights, Ventura CoClean Air Now Clean Energy ClimatePlan downeygreen Editor, El Toro Info Site Friends of Coyote Hills Friends of Harbors, Beaches, and Parks Global Land Use and Economic Council GRID/ECSTC Systems Highgrove Area Redevelopment Hills For Everyone Human Impact Partners Imperial County Air Pollution Control District Kohl Ranch Company LLC LA 32 Neighborhood Council LA 32 Neighborhood Council and NELA Coalition Latino Health Access Los Angeles Alliance for a New Economy 
7

Affiliation Submittal IDLos Angeles County Bicycle Coalition 090Los Angeles County Business Federation 091Mobility 21 099Move LA 100, 101NAIOP 102Natural Resources Defense Council 103, 104NO 710 Action Committee 105, 106Orange County Business Council 108Orange County Renewable Energy Society 110Physicians for Social Responsibility, and Other

Organizations (collaborative letter) 116

Puente‐Chino Hills Task Force of the Sierra Club 119Realtors Committee on Air Quality 120Regent Properties 121Regional Hispanic Chamber of Commerce 122Safe Routes to School National Partnership 130, 131, 132San Fernando Valley Green Team 135San Gabriel Valley Economic Partnership 137San Gorgonio Sierra Club 138Santa Monica Mountains Conservancy 140Siembab Corporation 141Sierra Club 142Southern California Association of Non‐Profit Housing 145Southern California Business Community 146Southern California Contractors Association 147Southern California Contractors Association, Inc. 148Southern California Edison 149Southern California Gas Company 150Southern California Leadership Council 151, 152Stephen W Rogers P.E. Consulting 154, 155, 156The American Institute of Architects 158, 159

Affiliation The Center for Community Action and Environm

Justice 

The Kennedy Commission The Transit Coalition Transit Coalition Trustee, San Bernardino Community College DisUnitarian Universalist Legislative Ministry Urban and Environmental Policy Institute Occide

College 

Valley Industry and Commerce Association VCCool + Ventura Bicycle Union Ventura County Climate Care Options Organized Western States Petroleum Association Wildlife Corridor Conservation Authority WRAC No Affiliation/IndividualsNo Affiliation/Individuals 
8

ID Name Affiliation Comment Re

001‐01 Barry Ross Alliance for a

HealthyOrange County

We are a new organization and we are supportive of this Plan,

but we want you to understand the importance that this has in

impacting the health of Orange County, particularly in reducing

the obesity rate. We hope that the Plan will highlight the health

impact that this kind of development can have. We want to

work with the cities to help them implement the strategies, and

help them see how we can get cities to work together to

implement more complete streets, more walkable communities

because we believe it will improve the health of the community.

Comment noted. SCAG is com

jurisdictions in their developm

maintenance of local active tr

encouraging the adoption of 

002‐01 Barry Ross Alliance for a

HealthyOrange County

The Alliance urges SCAG to consider the important health

impacts of the RTP and place increased emphasis on projects

that will promote active transportation. The region does not

need a plan that allocates $22 billion on road widening and only

$6 billion on active transportation. It is critical to change

funding allocations to improve safety and public health

throughout our region.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

002‐02 Barry Ross Alliance for a

HealthyOrange County

We request that SCAG amend the Draft RTP/SCS to include the

following: 1. Increase the overall percentage of RTP funds

dedicated to active transportation from 1.3 percent of the 2012

RTP to 5‐8 percent of the total 2012 plan.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

002‐03 Barry Ross Alliance for a

HealthyOrange County

2. Prioritize active transportation funding and distribute these

funds evenly over the 25 year period of the plan so that the

benefits of active transportation are brought to Orange County

Comment noted. SCAG canno

commitments that are alread

funding for active transportat
9

ID Name Affiliation Comment Re

sooner. is largely predicated on addit

that will require future action

levels. Therefore, the plan rea

will not be available in the ne

are expected to be available i

002‐04 Barry Ross Alliance for a

HealthyOrange County

3. Incorporate the development of an Active Transportation

Finance Strategic Plan by 2014 that identifies how each CTC is

spending funds and the opportunities available to increase

funding for active transportation.

Comment noted.

002‐05 Barry Ross Alliance for a

HealthyOrange County

4. Allocate funding for bicycle and pedestrian planning and

usage counts.

Comment noted. SCAG has id

collection regarding pedestria

facility conditions, and injurie

develop a clear understandin

conditions. SCAG acknowledg

necessary to improve decisio

deficiencies and needs within 

system.

002‐06 Barry Ross Alliance for a

HealthyOrange County

5. Set aside funding in the RTP to support SCAG cities in

developing bicycle and pedestrian master plans, safe routes to

school plans and ADA transition plans. Establish a goal that 50%

of SCAG cities shall develop these plans by 2016.

Comment noted. SCAG is com

jurisdictions in the developm

maintenance of local active tr

the incorporation of Bicycle P

Plans, Safe Routes to School p

002‐07 Barry Ross Alliance for a

HealthyOrange County

6. Adopt a Regional Complete Streets by 2014: This plan will

incorporate input from local jurisdictions to prioritize complete

streets projects in programming efforts and dedicate a portion

of system preservation and maintenance funding for improving

the road conditions of all users.

Comment noted. SCAG is com

jurisdictions in their developm

maintenance of local active tr

including Complete Streets po

002‐08 Barry Ross Alliance for a

HealthyOrange County

7. Adopt Safe Routes to School regional Strategic Plan by 2014 Comment noted. The Active T

Goal 3: Increase Active Transp

Region byComment noted. Ad

Policy. SCAG is committed to 

their development, implemen

active transportation plans an

policies.

002‐09 Barry Ross Alliance for a

HealthyOrange County

8. School Siting and Joint Use Policies should be incorporated as

land use elements of the SCS.

Comment noted. The 2012‐20

address comment, as approp

002‐10 Barry Ross Alliance for a

Healthy

9. Set measurable safety and health goals for all users: Goals are

set for the reduction of greenhouse gases in the draft 2012

Comment noted. SCAG’s Tran

forth goals to reduce transpo
10

ID Name Affiliation Comment Re

Orange County RTP/SCS. Active transportation plays a pivotal role in the

reduction of these greenhouse gases. Similar measurable goals

should be set for reducing crash rates for active transportation

and for reducing the health impacts of obesity. These could

include a report on the number of children walking and bicycling

to school across the entire region as well as a report detailing

access to parks, open spaces and quality active transportation

networks.

absolute numbers. For Bicycli

roadway fatalities by 25 perce

goal is to also reduce pedestr

from their 2000 number.

002‐11 Barry Ross Alliance for a

HealthyOrange County

10. Monitoring detailed population data and metrics in

environmental justice communities.

Comment noted. A robust en

been completed and is includ

Justice Appendix. SCAG will c

environmental justice impact

002‐12 Barry Ross Alliance for a

HealthyOrange County

The lack of active transportaiton funding disproportionally

affects immigrant, lower‐income, and minority populations

because these neighborhoods have greater barriers to physical

activity and transit access, higher numbers of busy regional

arterial, poor pedestrian and bicycle infrastructure, unsafe

neighborhoods, and lack of safe storage for bicycles and safe

crossings. thus, these neighborhoods would benefit from an

increase in funding allocations (in order for SCAG to meet its

Title VI obligations) and from a detailed strategic plan.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimated 

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

002‐13 Barry Ross Alliance for a

HealthyOrange County

Compliance with the SCS requirement of SB 375 and the well‐

being, safety, and health of citizens within the SCAG region will

depend on the future development of our multi‐modal

transportation network, jobs, housing, education and healthy

environments for families to live in.

Comment noted.

003‐01 Jenny Baird American Lung

Association

Increase active transportation investments to more than $12

billion a year. While we appreciate the increase in active

transportation funding included in the draft SCS, we believe

more funding is needed. A recent study by the Los Angeles

County of Public Health estimated that up to $40 billion could

be needed to build out all of the current bicycle and pedestrian

projects in Los Angeles County alone. SCAG, in coordination

with health departments and organizations, should conduct a

comprehensive needs assessment for the Southern California

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th
11

ID Name Affiliation Comment Re

region to determine the infrastructure needs to develop a

network of bicycle and pedestrian pathways and transit

connections. Analysis is also needed of how SCAG’s bicycle and

pedestrian per capita investment compares with other regions.

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

003‐02 Jenny Baird American Lung

Association

Improve Assessment of health benefits through new modeling

approaches. Utilize the new California Department of Public

Health I‐THIM screening tool to analyze the potential chronic

disease reductions that can be achieved in the SCAG region

based on increased transportation‐related physical activity such

as walking and biking. This model was used in the San Francisco

Bay Area region to determine reductions in heart and

respiratory disease, breast cancer and other health effects

linked to active transportation scenarios. We urge SCAG to

incorporate this tool in regional planning and decision making

for transportation investments.

Comment noted. As a scenari

model was used to calculate t

automobile transportation‐re

scenario planning process. Th

and their related costs, are ca

pollutant emissions (measure

working with the American Lu

I‐THIM screening tool and it’s 

003‐03 Jenny Baird American Lung

Association

Include the attached list of 13 health and equity metrics in the

SCS and monitor over time, including expanded public health

targets. In addition to monitoring premature mortality, SCAG

should also assess reductions in asthma incidence and

exacerbations due to traffic related pollution (NOX) and other

targets through collaboration with local health departments,

the South Coast Air Quality Management District, academic

researchers and community based organizations. Improvements

to the targets should be monitored and reported to the public

every two years. Additional comments on the targets already

included by SCAG in the SCS will be sent in a separate comment

letter.

Comment noted. The perform

with extensive input from SCA

The Draft PEIR includes a mob

in Appendix F. The analysis as

corridor in each of the six cou

planning area. We look forwa

Lung Association on future ef

SCAG is interested in continu

beyond the RTP.

003‐04 Jenny Baird American Lung

Association

Focus investments on completing transit systems and building

out transit infrastructure, rather than highway expansion,

including the following:. o Doubling Metrolink ridership by 2020

and double it again by 2035 o Expanding Bus Rapid Transit and

regional bus service o Enhancing TOD planning and 1st‐mile‐

last‐mile investments near Metrolink stations o Doubling the

bicycle network to 24,000 miles and improving pedestrian

environment

Comment noted. The 2012 RT

commuter rail lines, six new r

point to point express bus ser

rise in commuter rail boardin

use policy around transit stat

authority of the local governi

City or County, depending on 

partners with Cities and othe

exercises through the Compa

Program. This program provid

SCAG staff time, financial reso

local cities, counties, SCAG su
12

ID Name Affiliation Comment Re

transportation commissions t

transportation planning.

003‐05 Jenny Baird American Lung

Association

Increase transit and transit oriented planning in Inland Empire.

Because so much of the planned growth in the Inland Empire is

relatively low density and remote from transit, SCAG should

work closely with Inland Empire governments to accelerate

expansion and frequency of transit and rail to the area and

focus more growth around transit corridors. A recent health

forum hosted by the American Lung Association in California in

Riverside highlighted the dramatic rates of respiratory illness,

heart disease and obesity in the region associated with poor

land use and sprawl development.

Comment noted. Commented 

contains three new commute

and an expansion of point to 

policy around transit stations 

authority of the local governi

city or County, depending on 

partners with cities to do land 

Compass Blueprint Demonstr

provides a mix of consultant s

resources, and technical assis

SCAG Subregions, and County 

help link land use and transpo

003‐06 Jenny Baird American Lung

Association

Front load active transportation funding. SCAG should commit

to a higher amount of transportation funding for bike and

pedestrian infrastructure, especially in the early years of the 25‐

year RTP process. SCAG should work with local transportation

agencies to prioritize bicycle and pedestrian projects and ensure

the majority of funds are spent prior to 2020.

Comment noted. The distribu

transportation investments in 

tax measure commitments ap

transportation commission adplans, limitations associated w

other previous commitments

003‐07 Jenny Baird American Lung

Association

Increase investments in zero emission freight transportation in

order to reduce diesel emissions and exposures in communities

near freight corridors and rail yards. Ensure that funding

mechanisms are in place to expedite the implementation of the

zero and near‐zero emission freight and truck strategies and

infrastructure. Prioritize spending on projects that deliver

maximum health benefits for residents of the region, especially

those living along freeways and freight corridors.

Comment noted. Emissions fr

a significant concern for the S

lane system identified in the 

facility used by zero‐emission 

opportunity to incentivize the 

technologies for regional freig

continues to support efforts b

stakeholders to address good

impacts on communities such 

Air Action Plan. SCAG also sup

freight projects listed in the 2

closely with regional impleme

completion. Further, the 2012 

Action Plan that will lead to t

technologies in the timefram

requirements.

003‐08 Jenny Baird American Lung

Association

Evaluate the number and type of new developments that could

be located in close proximity to freeways and high traffic

roadways in the SCAG region under the new RTP and potential

pollution exposures. The Environmental Justice Appendix to the

Comment noted. Data and an

Environmental Justice Appen

improvements in vehicle tech

corridors. These corridors in 
13

ID Name Affiliation Comment Re

Plan shows that approximately 25% ‐ 27% of households living

within 500 feet of freeways could face greater exposures to CO

and PM than under the base case, with high concentrations of

minority and low income residents disproportionately affected.

Work with air district, health departments and universities to

develop and implement best practice policies for developments

located near heavy traffic areas to reduce exposures to air

pollution.

and/or near‐zero emission ve

Environmental Impact Report 

includes mitigation measures 

associated with health risk w

traffic volume roadways to le

included in the Appendix also 

improvements through the im

measures. As such, emissions 

this Appendix is abundantly c

worst‐case scenario outcome

improvements had been acco

would show little or no areas 

spots”) associated with the P

available data on emissions a

households and population is 

with emissions and EJ popula

potential impacts. Neverthel

evolving information on healt

project sponsors to be cogniz

project design and delivery. C

identified and to be impleme

PEIR, SCAG will assist in disse

identifying effective strategie

level.

004‐01 Terry Roberts American Lung

Association

The Southern California Association of Governments (SCAG)

Sustainable Communities Strategy offers a transformative

opportunity to reduce unhealthy vehicle emissions while

promoting healthier, more active neighborhoods with reduced

rates of chronic disease and premature death.

Comment noted.

004‐02 Terry Roberts American Lung

Association

Health professionals support strengthening the Sustainable

Communities Strategy to improve health outcomes from

healthy land use and transportation planning with the following

recommendations: • Increase active transportation investments

to more than $10 billion a year. A recent study by the Los

Angeles County of Public Health estimated that $40 billion

would be needed to build out all of the current bicycle and

pedestrian projects in Los Angeles County alone. Analysis

needed of how SCAG’s bicycle and pedestrian per capita

investment compares with other regions.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 
14

ID Name Affiliation Comment Re

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

004‐03 Terry Roberts American Lung

Association

• Assess health benefits through new modeling approaches:

Utilize the new California Department of Public Health screening

tool to analyze the potential chronic disease reductions in the

SCAG region from increased physical activity such as walking

and biking and complete this information as soon as possible.

Comment noted. As a scenari

model was used to calculate t

automobile transportation‐re

scenario planning process. Th

and their related costs, are ca

pollutant emissions (measure

working with the American Lu

I‐THIM screening tool and it’s 

004‐04 Terry Roberts American Lung

Association

• Broaden the list of public health targets for the SCS to include

reductions in air pollution related health impacts, including

premature mortality and asthma exacerbations. Work with

public health agencies to develop other public health targets.

Comment noted. The perform

with extensive input from SCA

We look forward to working w

on future efforts to monitor p

004‐05 Terry Roberts American Lung

Association

• Focus investments on completing transit systems and building

out transit infrastructure, rather than highway expansion. o

Doubling Metrolink ridership by 2020 and double it again by

2035 o Expanding Bus Rapid Transit and regional bus service o

Enhancing TOD planning and 1st‐mile‐last‐mile investments

near Metrolink stations o Doubling the bicycle network to

24,000 miles and improving pedestrian environment

Comment noted. The RTP inc

service including Metrolink an

also includes an expansion of 

increased frequencies of loca

increase in funding for bicycle 

004‐06 Terry Roberts American Lung

Association

• Front load active transportation funding, including transit, so

that projects are completed early in the 25‐year RTP process.

Comment noted. SCAG canno

commitments that are alread

funding for active transportat

is largely predicated on addit

that will require future action

levels. Therefore, the plan re

funds will not be available in 

funds are expected to be ava

004‐07 Terry Roberts American Lung

Association

• Increase investments in zero emission freight transportation

in order to reduce diesel emissions and exposures in

communities near freight corridors and rail yards.

Comment noted. Emissions fr

a significant concern for the S

lane system identified in the 

facility used by zero‐emission 

opportunity to incentivize the 

technologies for regional freig

continues to support efforts b

stakeholders to address good

impacts on communities such 

Air Action Plan. SCAG also sup
15

ID Name Affiliation Comment Re

freight projects listed in the 2

closely with regional impleme

completion. Further, the 2012 

Action Plan that will lead to t

technologies in the timefram

requirements.

004‐08 Terry Roberts American Lung

Association

• Evaluate the number and type of new developments that

could be located in close proximity to freeways and high traffic

roadways in the SCAG region under the new RTP. Work with air

district, health departments and universities to develop best

practice policies for developments located near heavy traffic

areas to reduce exposures to air pollution.

Comment noted. Please see T

Environmental Justice Appen

in the High Quality Transit Ar

proximity to freeways and hig

005‐01 Mark Capron American

Society of Civil

Engineers

The Southern California Association of Governments’ (SCAG)

2012 Regional Transportation Plan (Plan) is an excellent

planning document based on 2005 technology. It lacks only an

update for the digital technology of 2010 and an infusion of

hope amid the many challenges. You can accomplish that

update by inserting the Arial font text at the appropriate

locations in the Plan. Any text not in Arial font is supporting

logic and documentation. SCAG may choose to insert the non‐

Arial font or use it to prepare an alternate revenue‐expense

model.

Comment noted.

005‐02 Mark Capron American

Society of Civil

Engineers

SCAG is a sufficiently large economy to drive more applications

of digital technology for transportation safety and convenience.

If SCAG does not drive digital applications, the digital

applications will drive SCAG. For example: ‐ In response to youth

surveys, General Motors is applying digital technology. For

example; small self‐driving taxis and cars which will park

themselves a mile or more from their passenger drop off or pick

up locations. Today’s tech‐savvy 0‐15‐year olds will be the

transportation consumers responding (or not) to SCAG’s

Transportation Demand Management (TDM) as the 18‐38‐year

olds of 2030. ‐ Drivers are ever more distracted by their digital

devices, so much so the National Highway Traffic Safety

Administration recommends banning all use of digital devices,

even hands free phones. Increasingly distracted drivers are

more likely to kill pedestrians and bicyclists, with more adverse

impacts on TDM and safety. ‐ Pedestrians and bicyclists are

distracted reading their digital device and oblivious to outside

sounds wearing earphones. ‐ As of 2009, anyone with a smart

Comment noted.
16

ID Name Affiliation Comment Re

phone had access to real‐time (and very distracting) visual

indications of traffic conditions on their alternate routes. The

American Society of Civil Engineers, Los Angeles Section,

Sustainability Committee encourages SCAG to drive digital

applications for transportation because digital applications

allow tremendous improvements in mobility, safety, and air

quality with relatively little use of the Earth’s natural resources.

Further, motor vehicles manufacturers are implementing digital

applications in an uncoordinated fashion motivated to sell more

vehicles: adaptive cruise control, stability control, self‐parking,

voice recognition, collision warning, General Motors’ OnStar,

etc. While these systems help protect the vehicle occupants,

they are likely to increase the rate of bicyclist and pedestrian

deaths above 21%. Our committee includes regular bicycle

commuters who often get unsolicited comments about the

dangers involved. It would seem the perception of danger is

discouraging bicycle and pedestrian transportation. It follows

that an increase in perceived safety is essential for increasing

active transportation.

005‐03 Mark Capron American

Society of Civil

Engineers

After the Mobility, Safety, Air Quality, and Financial Challenges

of Executive Summary pages 2 and 3, add: DIGITAL

OPPORTUNITIES Our electronic systems continue to improve in

reliability, performance, and cost. 2035 is as far in the future as

1986 is in the past. In 1986, mobile phones were the size of

small vacuum cleaners and anti‐lock brakes were standard on a

few luxury cars. Personal computers were the size of a desk

drawer with the power to handle word processing and simple

spreadsheets. In 2010, smart phones are smaller than a deck of

cards, are a tenth the cost of a 1986 personal computer, and

possess the power of a 1986 supercomputer. Full drive‐by‐wire

stability control systems are standard on most cars. The global

positioning system (GPS) was not fully operational with civilian

accuracy of about 30 feet until 1994. In 2010, smart phones

have GPS which can be integrated with the smart phone’s

accelerometers for precision of a few inches at highway speeds.

Our vision includes pushing the connectivity and computing

power of 2010 to address the transportation challenges of 2020,

2030, and beyond.

Comment noted. The develop

proceeding rapidly, but is still 

examined in future plans.

005‐04 Mark Capron American

Society of Civil

At the end of the Financial Plan Executive Summary pages 7 and

8, add: REDUCED INSURANCE COSTS Drivers and businesses in

Comment noted.
17

ID Name Affiliation Comment Re

Engineers the SCAG region paid about $25 billion in 2010 for vehicle

insurance. By pushing digital systems to address transportation

safety challenges, SCAG can decrease collisions from about

83,000 per year in 2010 to less than 500 per year in 2035. Digital

systems would save drivers and businesses about $240 billion

on insurance premiums over the twenty years between 2015

and 2035. Also, by pushing digital systems to address

transportation mobility challenges, SCAG can reduce the

regional person‐hours of traffic delay below 1 million hours per

year. The insurance and time savings more than justify the

increased gas tax and mileage‐based user fee suggested in Table

2 with directly offsetting savings for drivers and business.

005‐05 Mark Capron American

Society of Civil

Engineers

Change the title and add the following to pages 27 and 28:

INTEGRATED LAND USE AND DIGITALLY ENHANCED

TRANSPORTATION Digitally enhanced transportation is the

application of technology allowing: ‐ Transit users to keep

shopping, working, or playing until they receive an alarm that

they have just enough time to get to the bus stop. ‐ Bus drivers

to vary their routes and stops in real time to optimize service,

revenue, and expense. ‐ Cities to organize all the possible

parking spots (street, schools, churches, business, and individual

residences) for public‐private coordinated time‐of‐use and

membership‐based tolls and space sharing. ‐ Private drivers and

passengers to share rides on‐the‐fly as a decentralized

neighbor‐helping‐neighbor form of transit. ‐ Pedestrians and

bicyclists to be protected from motor vehicles by a virtual force

field using a $50 device which informs motor vehicles of their

location, velocity, and accelerations. The same device can offer

tips on safe bicycling and safe walking. ‐ Motor vehicles to be

protected by the same virtual force field. The virtual force field

not only prevents accidents, it negates the perceived safety of

larger vehicles. ‐ More gamification in traffic management, such

as speed camera lottery. ‐ Safely doubling road capacity while

maintaining the speed limit (no congestion delays) by applying

the same virtual force field to make vehicles super‐polite. ‐ 

Rental of bicycles, traditional cars, or self‐driving vehicles by the

minute. ‐ Cargo‐pooling for mail, hardcopy messages, tools,

equipment, food, etc.

Comment noted.

005‐06 Mark Capron American

Society of Civil

MotivationThe author’s research for the Santa Barbara Community

Comment noted.
18

ID Name Affiliation Comment Re

Engineers Environmental Council’s Fossil Free by 2033 Transportation Plan

(Free by 2033 Plan) confirmed a strong preference for

convenience when selecting transportation. The Free by 2033

Plan22 concludes increased ridesharing can reduce vehicle miles

by 20% much quicker and less expensively than can increased

use of traditional public transit. Convenience and cost factors

strongly favor ridesharing.These general facts from the Legislative Analyst’s Office23

concerning carpool lanes confirm a need to increase timesaving

and convenience aspects of public transportation:

• High Occupancy Vehicle (HOV) lanes are underused in the off‐

peak direction or during off‐peak hours, because there is little

timesavings incentive to carpool

when traffic is flowing.

HOV lanes are most effective when they provide timesaving.

HOV lanes do not

increase carpooling, unless there is traffic slowing congestion.

The summer 2008 high fuel costs followed by the fall 2008 low

fuel costs provide a price‐based example. High fuel costs

increased bus and train ridership and prompted calls for more

convenient buses and trains. At least in Los Angeles, new

summer 2008 riders generally abandoned buses and trains

when fuel prices dropped.

Further, consider how rapidly people abandon bicycles, buses,

and trains when they can barely afford a private motor vehicle

in developing countries. Witness the switch away from bicycles

in China and India.

005‐07 Mark Capron American

Society of Civil

Engineers

All this implies that transit riding must become as convenient as

single occupancy vehicles if transit riding is to increase

significantly. Rather than allowing traffic congestion to drag on

the economy, make transit more convenient. The best transit

riding increasing strategy will be super‐convenient. The

inexpensive super‐convenience of digital applications extends to

low income people unlike traditional public transit (which is not

convenient) or single occupancy vehicle tolls (which are

expensive). SCAG’s implementation of smart phone‐transit

would make SCAG’s transit system more sophisticated and 21st

Century than New York, San Francisco, London or Paris.

Comment noted.

005‐08 Mark Capron American

Society of Civil

SCAG might pay the smart phone‐transit service a fee to obtain

ridership data for adjusting routes and fares to minimize both

Comment noted.
19

ID Name Affiliation Comment Re

Engineers vehicle‐miles and passenger‐miles per‐ gallon.

005‐09 Mark Capron American

Society of Civil

Engineers

SCAG can trigger the smart phone market share race, advertise

the program, and contribute to economic opportunity with

contests and promotions. $1 million would buy about 5,000

smartphones wholesale. The smartphones can be rewards for

idea contests, student essay contests, or a recruiting contest. In

a recruiting contest, contestants sign up regular customers at

regular customer rates. The new customers’ transit use is

summed (aggregate manner to avoid privacy issues) for the

contest period. The contestants whose customers accumulatedthe most transit miles win the smartphones and year of service.

The summed miles can be displayed on a website with hourly

updates to create excitement. Note that a bus or taxi driver

with a smartphone and the service creates a participating bus or

taxi with automatic payment option and data transfer to the

agency.

Comment noted.

005‐10 Mark Capron American

Society of Civil

Engineers

Consider adding the parking meters as a smart phone feature

gradually starting in 2013. The phones will need more accurate

GPS, which can be provided using inertial navigation to improve

satellite fixes, or by providing more GPS channels within the

phone, or by providing more satellite repeaters. The accurate

within‐a‐yard phone would link to the city’s GIS (geographic

information system) whenever the car stops in any mapped

parking spot. Ergo, the smart phone becomes the parking

meter.

Comment noted.

005‐11 Mark Capron American

Society of Civil

Engineers

Background information on zero‐congestion, zero‐collision

vehicles Motor vehicles can use digital technology to avoid

crashing into each other. Commercial aircraft already use this

electronics to safely increase landings and take‐offs in less time.

It’s called the Automatic Dependent Surveillance Broadcast

System and started coordinating 9,000 helicopter flights a day

over the Gulf of Mexico in January 2010. The electronics is

robust and keeps getting better. For example, the U.S. Air Force

is developing tiny quantum‐mechanical devices that improve

your car keeping track of itself even if it loses its Global

Positioning System signals. Electronics is way cheaper than car

insurance. In 2005, General Motors engineers estimated $200

per car to upgrade OnStar to zero‐crash, zero‐congestion. Of

course, most other cars would have to be similarly outfitted for

this low‐cost approach. Example actions Allow, beginning

Comment noted.
20

ID Name Affiliation Comment Re

January 1, 2013, single driver cars with zero‐crash and zero‐

congestion technology to use car‐pool lanes. Announce such

technology will be required for the “fast” lane of 3+ lane

freeways starting January 1, 2016. Announce such technology

will be required for all but the slow lane of every freeway in

SCAG member jurisdictions starting January 1, 2020. Announce

a lottery which bicyclists and pedestrians enter by logging miles

with their zero‐crash technology equipped smart‐phone, bicyclecomputer, or pedometer.

006‐01 Richard

Mueller

Ameron

InternationalCorporationWaterTransmissionGroup

Ladies and Gentlemen: For the past two years I have been

involved with the refinement and promotion of a freight

transportation concept we call “Green Rail Intelligent

Development”, or GRID. GRID is composed of three major

components, as follows. 1) A “SuperDock” to provide highly

automated transfer of container freight directly between ships

and trains. Two types of trains would be served by the

“SuperDock”, Class 1 trains for BNSF and Union Pacific to travel

through the Alameda Corridor, and drone container trains to

and from points in southern California. 2) A freight pipeline,

essentially a tunnel for the drone trains to travel between

warehouse districts in the Los Angeles region and the Ports. 3)

Loading/unloading terminals to feed and receive drone trains

into and from the freight pipeline/tunnel. These terminals

would be strategically located near concentrations of

warehouses in downtown Los Angeles, the City of Commerce,

Rowland Heights, and Fontana. The freight pipeline would

essentially provide an unobtrusive, nearly noise‐free, electrically

powered alternative to the East West Corridor proposed in the

RTP. Initial indications are that the efficiency of the “SuperDock”

and freight pipeline system could generate a sufficient cash flow

for the system to pay for itself using current freight costs and

without any tax increases. This system has received a specific

endorsement from the Angeles Chapter of the Sierra Club. I

recognize there is insufficient time for the study of GRID that

would be required for GRID to be included as an alternative in

the current RTP. However, as soon as the draft RTP is finalized, I

encourage SCAG to participate in an investigation of GRID to

determine its viability. GRID provides an opportunity for a true

paradigm shift in freight transportation within southern

California that could significantly reduce highway congestion

Comment noted. Local, regio

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten

resulting from freight movem

efforts have included the con

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing markeissues, operational feasibility, 

stakeholders (such as the San 

among others. SCAG will cont

stakeholders and transportat

solutions to regional freight c
21

ID Name Affiliation Comment Re

and make freight transportation to and through southern

California competitive with that anywhere in the world.

Sincerely, Ameron International Corporation Water

Transmission Group

007‐01 Ann Wilson Arroyo

VerdugoSubregion

Pursuant to federal regulations, projects should not be included

in the RTP/SCS constrained plan, which have only secured a

small portion of the required funding needed to complete the

project: The RTP/SCS, according to federal regulations, in

"nonattainment and maintenance areas," must "address the

specific financial strategies required to ensure the

implementation of projects and programs to reach air quality

compliance". Projects which only have secured a small portion

of the needed funding, and which rely on speculative funding,

such as potential and/or possible tolling authority, should not

be included in the RTP/SCS, since this inclusion does not meet

the federal requirements for a fiscally constrained plan.

Comment noted. However, SC

of reasonably available sourc

federal requirements. The ful

can be found in 23 CFR 450.3

regulations clearly indicate an 

constraint requirement by inc

information for demonstratin

implemented using committe

available revenue sources, wi

federally supported transport

operated and maintained.”

007‐02 Ann Wilson Arroyo

VerdugoSubregion

Language should be included in the RTP/SCS requiring a full

cost/benefit analysis for all projects in the constrained plan:

Language should be included in the RTP/SCS that clearly states

that a full cost/benefit analysis shall be completed for each

project contained in the RTP/SCS constrained plan:

Comment noted. SCAG will co

transportation commissions a

refine performance measures 

conduct project‐level perform

and necessary.

007‐03 Ann Wilson Arroyo

VerdugoSubregion

Major highway expansion projects should not be frontloaded in

the RTP/SCS: The RTP/SCS frontloads highway modalities by

disproportionately allocating funding and anticipated

completion dates. This is evidenced by comparing Table 2.2 ‐ 

Major Highway Completion Project against Table 2.5, Major

Transit Projects, in chapter 2 of the RTP/SCS. Transit projects

are built in segments with the final project not being completed

until 2030‐2035. Expanding highways induces VMT and

therefore frontloading major highway completion before transit

projects does not comply with the tenets of SB 375 and AB 32 to

reduce greenhouse gas emissions by reducing VMT. Additionally

it is well documented that land uses adjacent to freeways are

prone to increased toxins which cause negative health impacts.

According to SCAG staff, highway projects may be more easily

financed than transit projects by borrowing against future toll

revenues. They state that this is the reason the highway

projects are frontloaded. This financial reasoning does not

justify sacrificing environmental concerns by building the

highway projects prior to transit projects.

Comment noted. The distribu

transportation investments in 

sales tax measure commitme

transportation commission ad

plans, limitations associated w

other previous commitments
22

ID Name Affiliation Comment Re

007‐04 Ann Wilson Arroyo

VerdugoSubregion

The term "SR‐710 Gap Closure" used in the plan should be

substituted with "710 North Extension": The "SR‐710 Gap

Closure" language, already used in the 2008 RTP, should be

modified to consistency with Metro's stated intent, which

should serve to ease, if not eliminate the current polarizing

language. The shift in title from "710 Nort Extension" to "710

Gap Closure" is invalid, since there is no gap. SR‐710 terminates

at Valley Boulevard. There is no northerly extension to connect

to, since the portion of the 210 interchange including Del Mar

Boulevard was built conditioned upon the fact that it "would

have no effect on the decision as to the ultimate freeway

location and will not foreclose alternatives to the proposed

ultimate... Freeway." This title seems to create a sense of

inevitability or priority for this project over competing ones and

cannot be justified.

Comment noted. References 

been revised to “SR‐710 Nort

TBD)”.

007‐05 Ann Wilson Arroyo

VerdugoSubregion

SCAG assumptions regarding the "SR‐710 Gap Closure" project

producing congestion relief and lower greenhouse gas

emissions are flawed, based upon empirical research on other

highway projects that have been built: The PEIR states that "The

Plan would increase VMT when compared to existing

conditions." (SCAG RTP/SCS PEIR p.3.2‐25). Specifically,

decreasing VMT is the goal of SB 375 and should also be the

goal of the RTP/SCS. The increase in VMT is the Plan's reliance

on freeway expansion to meet the region's mobility needs.

Notably, the RTP/SCS describes the SR‐710 tunnel as a tunnel

with 4 lanes in each direction. This is a major highway expansion

being introduced into the region. To the extent that this causes

the widening of other freeways (such as the I‐210), it will

further expand the freeway system. The region would be better

served with an alternate project which is not highway oriented

and which would potentially decrease VMT, rather than

increasing it. SCAG assumes that the SR‐710 extension will

produce congestion relief and lower greenhouse gas emissions.

These assumptions are not borne out of recent research, and

there are a host of other previous studies showing that an

increase in highway capacity increases VMT and that once the

project is built, congestion, within a few years, returns. These

SCAG assumptions are flawed.

Comment noted. Increase in t

condition is primarily due to e

people over the plan period. 

basis will decrease over this p

implemented. While the Plan 

highway improvements, incluproject, there is no evidence 

contribute to the total VMT in

The 2012 RTP identifies a mu

incorporates transit, highway

strategies as well as demand 

pricing strategies to achieve o

performance and reduction in 

375.

007‐06 Ann Wilson Arroyo

Verdugo

The definition of the SR‐710 gap closure project from one

precise point to another threatens program‐level conformity in

Comment noted. SCAG recog

environmental analysis is und
23

ID Name Affiliation Comment Re

Subregion the plan and prejudices future environmental analyses: The Plan

has modeled the SR‐710 extension from one precise point north

to another. Unfortunately, this assumption removes the low‐

build or multi‐modal solution to the congestion problem. Under

federal regulations, because of this specificity, the Plan and the

PEIR threaten program‐level conformity and prejudice future

project‐level environmental analyses.

that effort and selection of a 

SCAG will work with Metro to 

update the project descriptio

analysis.

007‐07 Ann Wilson Arroyo

VerdugoSubregion

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

008‐01 Lacy Kelly Association of

CaliforniaCities Orange

County

In general, the RTP infringes upon local control. The 2012 RTP

assumes an inability of local agencies to balance the societal

and cultural costs associated with plan objectives and instead

requires that they assume the objectives stated in the plan,

which may or may not be shared local objectives. Matters such

as reducing vehicle miles traveled, eliminating the consumption

of fossil fuels in favor of zero or near zero emission vehicles,

installing infrastructure necessary to support zero emission

vehicles (such as charging stations), reducing obesity,

environmental justice impacts, anticipating extreme weather

and related events, increasing development densities, and the

likelihood of the adoption of active transportation methods or

the practicality of necessary infrastructure improvements are

matters of intense local debate and are not appropriate

subjects for regional determination. The RTP should be based

less upon behavior management of both the public and public

agencies and more upon accurate predictions of population

patterns and future transportation requirements.

Comment noted. SCAG's SCS 

local jurisdictions and SB 375 

jurisdiction's land use policies 

with the SCS. While the SCS is 

strategy that local governmen

and generally includes the qu

each city and county in the re

jurisdictions maintain local la

008‐02 Lacy Kelly Association of

CaliforniaCities Orange

County

Funding mechanisms for the RTP need much more economic

analysis. Specifically, the identification of more than $110 billion

through the implementation of a "mileage‐based" fee is

conceptual at best; even an "adjusted gas tax alternative" is not

guaranteed. Developing a $500 billion transportation plan with

approximately 20 percent of the budget attached to a concept

requires a significant local, regional, state and federal vetting

process. We encourage SCAG to include alternative methods of

funding should such a mileage‐based fee be deemed infeasible.

Comment noted. We agree th

before the mileage‐based use

which is basis for assumption 

2025. The projected revenue 

and adjustments to state and 

combined with the core reve

sources generate less revenu

increase in state and federal t

five percent annually. Rather 

of the historical growth rate, 

requirements, we detailed sp

state and federal transportat
24

ID Name Affiliation Comment Re

with recommendations from 

established by Congress throu

insight into future funding op

plan accordingly through ame

updates as appropriate. At a 

adopted every four years.

008‐03 Lacy Kelly Association of

CaliforniaCities Orange

County

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

009‐01 Marianne Kim Automobile

Club ofSouthernCalifornia

Government, business, and user stakeholders need to work

together to implement realistic and appropriate new revenues.

The RTP assumes $220 billion in new taxes and fees (mostly

levied on motorists) and financing over the next 20+ years.

Some of these assumptions are not realistic and will not likely

happen. And other funding options, not now in the plan, might

be implemented. The region needs to work together to identify

and advance the best, most appropriate funding options to

provide needed financing for RTP priorities.

Comment noted. The RTP’s fi

assumptions, which were vet

Advisory Committee and Poli

stakeholders and documente

transparency. As we gain mor

options, we will update the fi

amendments and/or subsequ

At a minimum, an RTP is prep

years.

009‐02 Marianne Kim Automobile

Club ofSouthernCalifornia

The RTP must protect and uphold the transportation priorities

approved by voters through various local transportation sales

tax measures. Voters in five counties approved sales tax

measures to fund specific highway and transit projects. The RTP

must include and support all of these priorities and help deliver

what voters were promised and what voters approved. Failure

to do so will make approval of future funding measures nearly

impossible.

Comment noted. The RTP inc

measures and their associate

county transportation commi

009‐03 Marianne Kim Automobile

Club ofSouthernCalifornia

The 15¢ gas tax increase assumed through 2024 is reasonable if

it is paired with state and national reforms to ensure funds will

be spent efficiently on effective projects. Gas tax rates have not

changed in almost 20 years. This user tax has been the

backbone of transportation funding for decades and it will

continue to be an important resource for years to come.

Comment noted. We agree b

clarification with respect to th

the Transportation Finance A

are updated annually as desc

swap”) but remain revenue n

009‐04 Marianne Kim Automobile

Club ofSouthernCalifornia

The final draft RTP clearly rules out a previously considered

regional gas tax or gas “fee.” This is an important improvement

that should be maintained in the final plan. Gas taxes have been

implemented at the state and national level for decades.

Attempting to extend such authority to local or regional

government is not realistic and will hamper other efforts to

fund transportation. Re‐labeling the gas tax as a “fee” does not

Comment noted. A regional g

inclusion in the RTP.
25

ID Name Affiliation Comment Re

change the fact that it is a tax protected by the State

Constitution and numerous voter‐approved measures. For these

reasons the Auto Club strongly opposes any attempt to impose

local gas taxes or any form of a “fee” on gasoline.

009‐05 Marianne Kim Automobile

Club ofSouthernCalifornia

The Vehicle Miles Traveled (VMT) charge included in the RTP

should be studied further as a long‐term replacement for the

gas tax. However, the amount of the proposed VMT charge is

significant, it will not be accepted by many people, and it needs

to include assurances regarding how the funds will be spent.

The proposed VMT fee is projected to generate $110 billion

(half of the RTP’s funding shortfall). To generate this amount,

the proposed VMT charge is equivalent to a tripling of the gas

tax in addition to new tolls and other user fees. Such a large tax

increase places a significant burden on motorists without

assurances of an equivalent or proportionate benefit.

Comment noted. We agree th

before the mileage‐based use

which is basis for assumption 

2025. The projected revenue 

and adjustments to state and 

combined with the core reve

sources generate less revenu

increase in state and federal t

five percent annually. Rather 

of the historical growth rate, 

requirements, we detailed sp

state and federal transportat

with recommendations from 

established by Congress throuin the RTP, including all reven

$2.90 for every dollar investe

009‐06 Marianne Kim Automobile

Club ofSouthernCalifornia

Tolls can be an important financing tool for new general

purpose highway lanes and for allowing more vehicles to use

existing HOV lanes by making them HOT lanes. Tolls should not

be imposed on existing general purpose lanes. The user‐pay,

user‐benefit principle is an important cornerstone of

transportation funding. Charging tolls for new lanes or to allow

more vehicles to access HOT lanes provides both needed

funding for the new facilities and inherent value to users paying

the toll. However, there is no assurance that motorists will

adequately benefit from tolls or congestion fees imposed on

existing freeway lanes or surface streets. New taxes and fees

are only successful when the public understands and sees a

clear benefit for paying them.

Comment noted. No tolls are 

existing general purpose lane

009‐07 Marianne Kim Automobile

Club ofSouthernCalifornia

The RTP needs to recognize that the most realistic and effective

way to achieve desired emissions reductions has been and will

continue to be through technology advancements and not

through sweeping attempts to fundamentally alter lifestyles and

economic, geographic, and demographic patterns. Although SB

375 and its Sustainable Community Strategy are required

elements of the RTP, they are not likely to significantly reduce

Comment noted. The RTP/SC

reduce GHG including alterna

better system preservation a

intends to offer options and b

our region, which is above an

GHG reduction targets.
26

ID Name Affiliation Comment Re

GHG emissions. Improving and encouraging transit, bicycling,

and walking are appropriate and good objectives for the RTP.

However, emissions reductions from these efforts will be very

small compared to those that can and will be achieved through

other means. These other means include improving automobile

technologies, alternative fuel and energy sources, and better

system preservation and management to improve traffic flow

and safety.

010‐01 Neal Richman BREATHE LA Breathe LA supports the comments in the Climate Plan sign‐on

letter in response to the SCAG RTP/SCS for 2012. We see both

strengths and shortcomings in this planning document and hope

that, to the extent feasible, issues that are identified by the

Climate Plan coalition will be remedied before final adoption. In

addition to these recommendations, Breathe LA seeks to

express its concern that the RTP/SCS may underestimate the

actual impact of pollution in areas adjacent to freeways and

highly traveled corridors because current planning methods do

not fully consider the health consequences of ultrafine diesel

particulates. The RTP/SCS focuses on the impact of PM10 and

PM2.5. However, there is growing evidence of the adverse

health effects of ultrafine diesel particulate matter that is

composed of carbon, organic compounds, metals, and other

trace elements. For a number of reasons ultrafine particles (less

than 0.1 microns in width) are not yet regulated. Air quality

standards are based on mass concentration for particulate

matter. However, the health effect of ultrafine particles (UFPs)

seems to occur through particle number concentration, not

mass concentration. UFPs are a small proportion by mass, but a

large proportion by number. Because of their extremely small

size, UFPs can penetrate deep into the lung tissue, circulate

throughout the body, and become deposited within cellular

structures. The main sources of diesel exhaust range from

trucks and cars to locomotives, ships, and industrial equipment.

In Los Angeles County, about 70% of air quality risk is derived

from diesel particulate emissions, especially from mobile

sources. Concentrations of UFPs are greatest around freeways

with truck traffic and begin to decrease as the distance away

from freeways increases. The RTP/SCS does point out the

potential impact of roadside pollutants by noting the high

concentration of vulnerable residents who live and work in

Comment noted. SCAG will p

overall results and conclusion

for the 2012 RTP/SCS. Anticip

environmental performance 

improved from the base year

when comparing the plan to t

Information on emissions imp

highways will be included as a

Justice (EJ) Appendix.While the EJ analysis in the D

with emissions increases, this 

improvements in vehicle tech

corridors. These corridors in 

and near‐zero emission vehic

improvements had been acco

would show no hot spots asso

emissions and exposure analy

is abundantly conservative an

scenario outcomes. Even in t

after accounting for vehicle te

no reliable way to conclude h

communities. Neither the av

distribution of households an

level of geography to show w

SCAG is very much aware of t

near roadway exposures and 

result of active transportation 

research and studies to furthe

measures. Please note that t

not only the residents but als

roadway workforce including 

visitors, etc.
27

ID Name Affiliation Comment Re

areas that are adjacent to freeways and highly traveled

corridors. The RTP/SCS states: “...freeway adjacent areas

account for just 1 percent of the SCAG land area but

accommodate 5.8 percent of regional households and less than

10 percent of total SCAG region jobs. There are

disproportionately higher concentrations of Environmental

Justice Communities in the freeway adjacent areas both

currently in our 2035 projection” Moreover, as the RTP/SCS

states: “The 2012 RTP/SCS land use strategy calls for redirecting

future growth into HQTA (High Quality Transit Areas) As a

result, part of the growth will occur in areas where HQTA is

overlapping within 500 feet freeway buffer areas.” The question

remains how “high quality” can an HQTA be if it is within a 500

foot buffer area. Of particular concern is the risks posed by

incompatible land use, including sensitive receptors such as

hospitals, senior/day centers, and housing near freeway and

busy roadways. ● First, it would be helpful to idenƟfy those

portions of the HQTA’s which are healthy for new residential

development and which are not. As noted, the health risks from

fine particulate matter decrease rapidly the further the particles

are measured from a source. Some areas of the HQTA’s might

be very appropriate for development while in another location

this would not be the case. ● PorƟons of HQTAs where new

residential development is not advisable will have higher health

risk from toxic air contaminants like diesel particulate matter.

These portions can be determined by applying guidelines

developed by the California Air Resources Board (CARB) that

recommend that sensitive land uses not be sited within 1000

feet of rail yards, warehouses, and distribution centers. The

guidelines also recommend that sensitive land uses not be sited

within 500 feet of freeways, without appropriate mitigations to

minimize this risk. ● Support wise infill development by

incentivizing the development of housing and sensitive land

uses like parks and schools outside portions of HQTAs with

higher health risk from toxic air contaminants. Encourage siting

more suitable land uses such as commercial and light industrial

land uses within higher health risk portions of HQTAs. ●  

Encourage local jurisdictions to require mitigation measures for

proposed residential developments within portions of HQTAs

with the highest health risk from toxic air contaminants. The

However, regionwide air qua

comparing to either today’s c

the plan. Moreover, while the 

the freeway adjacent areas’ a

substantially. Finally, while SC

the HQTA, only 22% of the gr

500 feet roadway buffer area

The Environmental Justice ap

toolbox to minimize exposure 

feasible and appropriate. SCA

to address gentrification in th

continuing to work with envir

these important issues. The R

in population in these locatio

risk could be higher for these 

the buffer area.
28

ID Name Affiliation Comment Re

appropriate mitigation measures required to reduce health risk

posed by the proposed development should be identified based

on detailed modeling and assessment of local conditions at and

surrounding the site, including proximity to freight‐related

hazards and empirically counted amounts of diesel truck and

train traffic moving through the area. Specifically, mitigation

measures can be put in place by developers to meet the

required conditions for zoning approval. These measures range

from indoor air filtration and monitoring to site re‐design that

locates sensitive receptors as far away as possible from sources

of air pollution. To address potential adverse health impacts,

mitigation measures in proposed housing developments areas

might include: 1) Install HEPA indoor air filtration systems

designed to filter out toxic air contaminants including fine

particulate matter (PM 2.5); 2) Use triple‐paned, sealed, and

non‐operational windows that reduce the impact of vibrations

from freight traffic and minimize outdoor air contaminant flow

into indoor spaces; 3) Use green, healthy building materials that

do not off‐gas or release air toxins that compromise indoor air

quality; 4) Include adequate green space, vegetative planting,

and permeable surface area that is well‐maintained

incorporated into development design and management plans;

5) Minimize parking allocations in the development to reduce

congestion and air pollution from additional automobile traffic

and stalled freight traffic, and incentivize the use of transit, car‐

sharing, and zero‐emission electric vehicles by integrating

chargers into the design of parking garage areas; 6) Design

developments to capture polluted runoff from the sides of

buildings and other outdoor surfaces that have accumulated

diesel soot and other contaminants so that such contaminants

do not flow into green spaces in the development; 7) Design

developments to equitably distribute the health risk from toxic

air contaminants posed by the development across all units in

the development (eg do not locate affordable housing units in

the least desirable areas of the development closest to freight

transport facilities and corridors like freeways); 8) Notify

prospective residents within the deed or lease document for the

property of the hours of operation of freight transport facilities

and their related noise, air quality, light pollution, and health

impacts; Growth in HQTAs is needed, we believe that such
29

ID Name Affiliation Comment Re

measures might be ways to encourage additional density near

transit hubs while simultaneously protecting public health.

There needs to be further discussion of these types of ideas to

determine which are most appropriate and feasible in each set

of circumstances. Many of these recommendations were put

forth by public health and environmental organizations in

response to the publication of the Sustainable Communities

Strategy by the Association of Bay Area Governments. To the

greatest extent feasible, such air pollution mitigation strategies

should not be developed by each region independently, but

rather should be reflected in statewide policies that promote

health and environmental justice throughout California.

011‐01 Scott Goldie Brooks Street 1. The SCS does not appear to account for projects already in

process Brooks Street represents the owners of thousands acres

of property in southern California, and has a long history of top‐

quality developments in the SCAG region. However, we are

concerned that the SCS process has not fully accounted for

projects that are already in process. Brooks Street has projects

in southern California that are fully entitled and approved for

build‐out, as well as proposed projects with pendingapplications that represent a substantial investment of

resources to design, plan and communicate with the community

and responsible agencies. While the SCS itself states that it was

created with input from local jurisdictions (see, for example,

Draft RTP/SCS p. 111), we are concerned that the growth

projections contained in the SCS and Land Use Pattern Maps do

not in fact reflect the land use decisions that have been made

by local jurisdictions. More specifically, while the Draft RTP/SCS

indicates that it has shifted projected densities from less

developed areas to the urbanized core, nowhere does the SCS

clearly state that those shifts in density take into account

development projects that are either already approved or that

are reasonably foreseeable projects which local jurisdictions

have already spent considerable resources processing.

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

011‐02 Scott Goldie Brooks Street 2. Underlying TAZ data must be released to allow meaningful

public comment Moreover, the SCS's treatment of approved

projects is impossible to determine from the information that

SCAG has made available to the public. The 2035 Land Use

Pattern Maps, which are intended to depict projected density

and land use, are at such a large scale, with such slight color

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level. The TAZ‐le

request during the comment 
30

ID Name Affiliation Comment Re

gradations, that they cannot be interpreted in any meaningful

way. The SCS itself does not seem to contemplate that these

maps will be important to future transportation and land use

decisions. Instead, the SCS focuses on the projected density

contained in the data that underlies the maps ‐‐ data that SCAG

has not released to the public. The SCS states that the land use

projections contained in the SCS are based on the distribution of

growth forecast data to transportation analysis zones. (RTP/SCS,

p. 122.) According to the SCS, the TAZ data contains forecasted

housing, population, and employment data, which the SCS used

to create "Community Types" and more refined "Development

Types" that contain average use designations, densities, and

building intensities. The SCS states that a Development Type,

including an average residential density, has been assigned to

each TAZ for purposes of creating the SCS. (Draft RTP/SCS, p.

123.) However, it cannot be determined whether this

assignment was made in a manner that takes existing conditions

(including approved and reasonably foreseeable projects) as a

baseline for these projections, nor can it be determined how

the forecasting was done or how it was distributed across the

TAZ. Despite the critical role of the TAZ data in developing the

SCS, we are not aware that SCAG has made this data available

for public review and comment in any meaningful way. We

were able to obtain partial data, showing housing densities only,

from other agencies involved in the SCS process. These data do

not contain employment or population forecasts, and do not

contain any Community Type or Development Type

designations which, according to the SCS, have been assigned to

each TAZ. It is not possible for the public to provide meaningful

comment on the SCS without access to the underlying data on

which density and land use projections are based. In the

absence of the underlying data and modeling supporting the

proposed plan, we are substantially impaired in our ability to

provide meaningful public comment on the technical and legal

adequacy of the plan. In particular, we cannot assess whether

the underlying data adequately reflects all developments as

approved. Under the federal (5 U.S.C. § 500 et. seq.) and

California Administrative Procedures Acts (Gov. Code §§11340

et seq., including § 11346.2(b)(6)), the opportunity for public

comment must include disclosure of the data and technical
31

ID Name Affiliation Comment Re

studies in time to provide meaningful public comment. See, e.g.

Solite Corp. v. EPA, 952 F.2d 473, 484 (D.C.Cir.1991) (per

curiam). While we are not confident that the data is either

accurate or complete, we have reviewed what data we were

able to obtain. Based on our review we conclude that the

forecasted housing densities do need to be corrected, as the

numbers clearly do not reflect either existing entitlements or

pending, reasonably foreseeable projects.

011‐03 Scott Goldie Brooks Street 3. Implications of consistency with underlying TAZ data The

importance of the TAZ data is not limited to understanding how

the SCS was created. In addition to being the basis for creation

of the SCS land use projections, according to the SCS, the TAZ

data is to be relied on in future determinations as to whether a

project is consistent with the SCS. The SCS states: "SCAG

suggests that utilizing community types at the TAZ level of

geography (which an average size of 160 square acres) offers

local jurisdictions adequate information and flexibility to make

appropriate consistency findings for projects to be eligible to

receive CEQA streamlining benefits." (Draft RTP/SCS p. 122.)

"One way of determining consistency [with the SCS] is if a

proposed residential/mixed use or TPP [Transit Priority Project]

conforms with the Development Type designated for a TAZ."

(Draft RTP/SCS, page 148.) Despite these explicit statements

that the existing TAZ data will be critically important to future

decisions affecting projects, SCAG has not provided the public

the opportunity to review and comment on the TAZ data in any

meaningful way. Significantly, a project's consistency with the

SCS ‐‐ which is to be determined at the TAZ level according to

the SCS ‐‐ affects not only the availability of CEQA streamlining

incentives, but can have adverse consequences for the

availability of federal funds for transit improvements that would

serve the project. Transit improvement projects relying on

federal funding must be consistent with an approved RTP, and

with the adoption of SB 375, that includes consistency with the

Sustainable Communities Strategy portion of the RTP as well.

(40 CFR 93.102; 42 U.S.C. 7506.) Thus, if the Draft RTP/SCS has

shifted density away from approved or pending projects, those

projects stand to lose critical transit improvements. The loss of

transit improvements could impair project feasibility, or create

new unmitigated impacts if traffic mitigations become

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

impact the local entitlement 

altered small area land use as

occurring in many transit‐rich 

is intended to provide a regio

governments may consider a

quantitative growth projectio

the region going forward, loc

use authority. The TAZ‐level m

purpose of modeling perform

local jurisdictions, maintain th

determine consistency of any 
32

ID Name Affiliation Comment Re

unfunded, which could result in an unlawful taking of private

vested property rights for those projects that have already been

approved by local jurisdictions. In many cases, approved

projects also involve executed development agreements, which

means that violation of contractual rights could also result,

causing difficult situations for developers and local jurisdictions.

We are concerned that a project's inconsistency with the

growth projections contained in the SCS may have broader

implications as well. Local jurisdictions will be under

considerable pressure to conform their general plans to the

density, intensity, and land uses contained in the SCS, or risk

losing transportation funding throughout their jurisdictions.

While all the implications of a project's inconsistency with the

SCS have yet to be determined, we are concerned that by

shifting density away from locally approved and pending

projects, the SCS is creating land use policy in violation of SB

375's mandate that the SCS must not supersede the land use

authority of cities and counties. (Gov't Code 65080(b)(2)(J).)

011‐04 Scott Goldie Brooks Street 4. RTP/SCS consistency should be determined at the

jurisdictional level The TAZ maps are a modeling tool for

engaging in a regional planning and evaluation process. The

feasibility of achieving the precise results in any particular TAZ

area has not been evaluated or confirmed by any city council or

board of supervisors, and as explained above it appears that the

TAZ data and maps for 2035 do deviate from general plans and

vested entitlements that have been approved by these elected

officials. While we understand elected bodies or senior

administrative staffs of local jurisdictions may have approved

local input for the overall population and household numbers

within their respective jurisdictions, we believe they have not

approved the TAZ data or maps. Accordingly, requiring

consistency determinations concerning use designations,

density, and building intensity at the small scale of each TAZ

would be inappropriate and overly‐prescriptive. Again, SB 375

specifically precludes SCAG from interfering with local land use

decisions.1 SB 375 requires that an SCS “identify the general

location of uses, residential densities, and building intensities

within the region....” Calif. Government Code § 65080(b)(2)(B)(i)

(emphasis added). Thus there is no legislative mandate that

SCAG identify the location of land uses, densities and building

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

impact the local entitlement 

altered small area land use as

occurring in many transit‐rich 

is intended to provide a regio

governments may consider a

quantitative growth projectio

the region going forward, loc

use authority. The TAZ‐level m

purpose of modeling perform

local jurisdictions, maintain th

determine consistency of any 
33

ID Name Affiliation Comment Re

intensities within the region more precisely down to a TAZ level.

Instead, SCAG should appropriately identify these

characteristics at a level consistent with the need for reasonable

flexibility and local control. At the lowest, the level of

comparison should be at a jurisdictional level – particularly

given that there are nearly 200 jurisdictions within the SCAG

region. Accordingly, we urge SCAG to identify such

characteristics at no finer a scale than at the lesser of (i) the

jurisdiction, and (ii) the sub‐region (i.e., where unincorporated

county land is divided into sub‐regions). Despite SB 375's

mandate that the SCS not regulate land use, the draft RTP/SCS

"shifts" households "from the periphery into the urbanized

core" stating that much of this shift "will occur naturally in the

marketplace," and that this "shift" was done "per consultation

with the local jurisdictions." (Draft RTP/SCS p. 128.) However,

this shift does not "occur naturally," nor through a

"consultation" process between agency staff that excludes the

public. Instead, such a shift can only occur, if at all, as part of a

separate and lengthy discretionary development application

process involving requests to local land use jurisdictions to

amend their general plans, specific plans, areas plans, and

zoning. In short, there is no "shift" to high‐density housing in

some local jurisdictions, and away from housing density already

approved by other jurisdictions, unless and until the local land

use jurisdictions adopt the requested discretionary approvals.

012‐01 Andrew

Henderson

Building

IndustryAssociation ofSouthernCalifornia

Concerning the actual policy documents at issue (i.e., the Draft

RTP and the Draft SCS themselves), BIASC has one fundamental

concern: Page 148 of the Draft SCS suggests that local

governments should look to “transportation analysis zone”

(TAZ) maps to determine whether a particular project is

consistent with the land use designation, density, and building

intensity of the SCS. BIASC believes that this section needs to be

revised for three distinct reasons. First, BIASC is informed that

the TAZ maps break land masses up into relatively small‐scale

areas averaging perhaps only about 150 acres in size (and even

smaller in more densely populated areas). Requiring

determinations about the consistency of future land uses to the

SCS – concerning use designations, density, building intensity

and the applicable SCS policies – at that fine a scale would be

overly‐prescriptive. SCAG need not be nearly so prescriptive

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.
34

ID Name Affiliation Comment Re

because SB 375 requires only that an SCS “identify the general

location of uses, residential densities, and building intensities

within the region....” Calif. Government Code § 65080(b)(2)(B)(i)

(emphasis added). Given this legislative mandate, there is no

reason for SCAG to measure and compare land‐use

characteristics within the region at the very fine TAZ level vis‐à‐

vis policy determinations. Instead, the final RTP/SCS should

permit local agencies to measure and compare land use

characteristics with the regional strategy at a level consistent

with the need for reasonable ongoing flexibility in local land use

control. Therefore, the level of comparison should be, at the

finest, at a city jurisdictional level (including any sphere of

influence) – given that there are nearly 200 separate

jurisdictions within the SCAG region. BIASC specifically urges

SCAG to identify and compare such land use characteristics at

no finer a scale than (i) the cities (including their respective

adjoining spheres of interest), and (ii) concerning the

unincorporated areas outside of local spheres of interest, by

comparison to the rough‐scale map that indicates generally the

locations of building intensification shown in the SCS. See

Exhibit 2 to the Draft SCS Background Documentation, found at

http://rtpscs.scag.ca.gov/Documents/2012/draft/SR/2012dRTP_SCSBackgroundDocumentation.pdf.

012‐02 Andrew

Henderson

Building

IndustryAssociation ofSouthernCalifornia

Second, BIASC is concerned that any prescriptive use of TAZ

maps for policy purposes could have negative consequences vis‐

à‐vis the pending process for a required federal conformity

determination. Under the federal laws that relate to the federal

funding of regional transportation infrastructure, an RTP must

be constructed using “the latest planning assumptions.” “Using

the ‘latest’ planning assumptions means that the conformity

determination is based on the most current information that is

available to state and local planners....” U.S. E.P.A. Guidance for

the Use of Latest Planning Assumptions in Transportation

Conformity Determinations (EPA420‐B‐08‐901, December

2008), ¶ 2.2 (emphasis in the original), found at:

http://www.epa.gov/otaq/stateresources/transconf/policy/420b08901.pdf and incorporated herein by reference. If and to the

extent that SCAG’s TAZ‐level maps and the data reflected in

them are unacceptable to local planners and were not available

to them when the RTP was developed, then fine‐scale data

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.
35

ID Name Affiliation Comment Re

based upon the TAZ maps should not be incorporated into the

RTP via the SCS. They would instead need to be separated out

from the RTP and – at most – made part of an “alternative

planning scenario” (APS) under California Government Code

section 65080(b)(2)(H). We believe that any conflict between

the federally‐mandated RTP approach and the SCS TAZ‐level

maps can be avoided by making all relevant policy

determinations based on comparisons viewed at the city level

(including any sphere of influence) and by reference to the

generalized locations depicted for intensification in

unincorporated county areas (for example, in Exhibit 2 to the

Background Documentation as noted above).

012‐03 Andrew

Henderson

Building

IndustryAssociation ofSouthernCalifornia

Third, no TAZ‐level maps were provided to the public as part of

either the Draft RTP/SCS or the Draft PEIR, nor were they

included in any of the appendices that SCAG provided to the

public. Hopefully, the omission reflects SCAG’s pre‐publication

determination to forgo the use of any TAZ‐level maps for policy

purposes. If this were the case, then it appears that SCAG’s staff

inadvertently failed to revise page 148 of the Draft SCS prior to

its publication for comment; and SCAG should now revise that

page to reflect a more appropriate approach (the jurisdictional

approach suggested above). If, however, SCAG actually

intended the policy prescription that is suggested on page 148

of the Draft SCS, then SCAG must be faulted for having failed to

disclose an essential component of the RTP/SCS, which is the

new level of policy prescription that such TAZ‐level maps would

impose or induce through the implementation of SB 375. Under

judicial precedents decided pursuant to the California

Environmental Quality Act (CEQA), SCAG’s public disclosures in

the Draft RTP/SCS and the Draft PEIR would be inadequate if

they failed to disclose TAZ‐level policy prescriptions affecting

the region’s population distributions and concentrations: The

detail [of draft disclosure concerning changes induced in

population distribution, population concentration, and the

human use of the land] required in any particular case

necessarily depends on a multitude of factors, including, but not

limited to, the nature of the project, the directness or

indirectness of the contemplated impact and the ability to

forecast the actual effects the project will have on the physical

environment. Napa Citizens for Honest Government v. Napa

Comment noted. The final RT

comment. The TAZ‐level map

purpose of modeling perform

land use assumptions for the 

jurisdictional level.
36

ID Name Affiliation Comment Re

County Bd. of Supervisors (2001) 91 Cal.App.4th 342, 369

(emphasis added).

012‐04 Andrew

Henderson

Building

IndustryAssociation ofSouthernCalifornia

In short, if SCAG were planning to utilize the TAZ‐level maps as

actual policy drivers (as page 148 of the Draft SCS may suggest),

then SCAG needed to disclose the details of those TAZ maps;

and SCAG did not. See CEQA Guidelines, Tit. 14, § 15144 (“an

agency must use its best efforts to disclose all that it can”).

SCAG would also need to have analyzed environmental impacts

in much more detail than presented in the Draft PEIR, including

the thousands of direct conflicts between TAZ maps for

established communities and CEQA thresholds relating to

General Plan compliance, Quimby Act compliance, impacts to

protected greenbelts and historic resources, local congestion

and traffic safety impacts, impacts to schools and other public

services. Therefore, BIASC respectfully asks SCAG to revise page

148 of the SCS to avoid the insinuation that TAZ‐level maps

should be utilized for any future regulatory or policy purpose.

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

012‐05 Andrew

Henderson

Building

IndustryAssociation ofSouthernCalifornia

As a final additional comment on the draft policy documents,

we note that two of SCAG’s brethren metropolitan planning

organizations (one in the San Diego area another in the

Sacramento area) have each included a 2050 planning year

horizon in their respective RTP/SCS documentation. Such a long‐

term perspective seems appropriate to consider because land

use and transportation patterns evolve relatively slowly; and

they are subject to numerous variables (e.g., the economy, and

the allocation of federal funding for regional transportation

projects). Accordingly, SCAG’s ambitious vision for higher

density development patterns along transit corridors may not

be realized for many decades. In the nearer term (2020 and

2035), the statewide targets for GHG reductions which were

established pursuant to Assembly Bill 32 (2006) may be more

feasibly be realized through other measures such as renewable

energy, cleaner cars and cleaner fuels, and stationary source

controls, as the California Air Resources Board’s AB 32 Scoping

Plan explains. It is possible that, in light of analytical constraints

prescribed by CARB, the SCAG region cannot realistically attain

the 2020 and 2035 GHG emission reduction targets established

by CARB, in which case an APS may be appropriate. Therefore,

SCAG’s consideration of a longer‐term, 2050 planning horizon

may be a useful framework for informing local agencies and

Comment noted. We may con

future RTPs.
37

ID Name Affiliation Comment Re

other interested stakeholders about a more feasible, longer‐

term regional planning effort.

012‐06 Andrew

Henderson

Building

IndustryAssociation ofSouthernCalifornia

The Development Types are expressed in terms of use

designations, densities and building intensities; and, for any

given type, there is one residential density indicated. For

example, the "Town Center" Development Type reflects an

estimated average density of 22 residential units per acre.

However, it is important to note that the designation is a

potential ultimate average for the TAZ ‐‐ and is not an absolute

project‐specific requirement that must be met in order to

determine consistency with the SCS. In other words, the SCS

was not developed with the intent that each project to be

located within any given TAZ must exactly equal the density and

relative use designations that are indicated by the SCS

Development Type in order for the project to be found

consistent with the SCS's use designation, density, building

intensity and applicable policies. Instead, any given project,

having satisfied all of the statutory requirements of either a

residential/mixed‐use project or TPP as described above, may

be deemed by the lead agency to be consistent with the SCS so

long as the project achieves consistency at the jurisdictional

level, considering the does not prevent achieving the estimated

average use designations, densities and building intensities

indicated by the Development Type within the TAZ, assuming

that the TAZ will be built‐out under reasonable local planning

and zoning assumptions. SCAG's growth projection data is

available on its website for lead agencies to use to determine

whether projects are consistent with the SCS."

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

012‐07 Andrew

Henderson

Building

IndustryAssociation ofSouthernCalifornia

Explanation: The above clarifications are required to ensure that

the SCS consistency determination is made by the local land use

agencies, not SCAG, and that CARB's assessment of that

consistency will be evaluated at the broader

jurisdictional/regional level, as anticipated by CARB in its July

2011 "Description of Methodology for ARB Staff Review of

Greenhouse Gas Reductions from Sustainable Communities

Strategies (SCS) Pursuant to SB 375," which is incorporated by

this reference. Additionally, this jurisdictional (i.e., city/county)

level is more appropriate when compared to smaller geographic

levels, such as Traffic Analysis Zones (TAZs) or parcel

assessments that would limit cities and counties' control over

Comment noted. Lead agenci

maintain their own discretion 

of any future project with the 

regarding the requested PEIR 

Addendum Section 4.0, Respo

RTP PEIR, Letter Number 4.
38

ID Name Affiliation Comment Re

land use. While the SCS sets forth forecasted development

patterns that may differ from those envisioned in various

general plans, those patterns, nonetheless, still must be

consistent with "current planning assumptions" and those

assumptions must be grounded in the local general plans and

sphere of influence boundaries. (See Gov. Code, §

65080(b)(2)(B).) Please also revise/clarify all same/similar text

found in the Draft PEIR, Section 2.0, Project Description (see, for

example, page 2‐29).

012‐08 Andrew

Henderson

Building

IndustryAssociation ofSouthernCalifornia

Explanation: At least two reasons justify revisions to the above

quoted text in order to be consistent with applicable law (i.e.,

SB 375). (Gov. Code, § 65080.) First, according to the Draft PEIR,

the forecasted land use development pattern in the SCS, in

some cases, assumes that more high‐density housing will be

built than is currently anticipated in the local general plans of

the affected counties and cities. However, SB 375 requires the

contemplated land use development pattern in the SCS ‐‐ a

component part of the RTP ‐‐ to utilize "the most recent

planning assumptions considering local general plans and other

factors." (Gov. Code, § 65080(b)(2)(B).) Unfortunately, SCAG has

deviated substantially from the locally adopted general plans,

and has made its own land use assumptions that are in conflict

with the land use plans of adopted general plans within the

region. Second, the draft SCS and associated Draft PEIR both

blur the line between regional planning (i.e., preparing the

required SCS forecasted land use development pattern) and

local land use authority and jurisdiction. The SCS is not to

directly regulate the use of land or affect the land use authority

of cities and counties within a given region. (Gov. Code, §

65080(b)(2)(K).) Additionally, the law (i.e., SB 375) does not

require that a local general plan, specific plan, or zoning be

"consistent" with the SCS. (Ibid.) Despite these legal limitations,

SCAG has made a "shift" in housing types ‐‐ deviating from the

most recent planning assumptions in the locally adopted

general plans ‐‐ stating that the shift or "switch" will "occur

naturally" in the marketplace due to shifting demands.

However, this shift does not "occur naturally." Instead, such a

shift can only occur, if at all, as part of a separate and lengthy

discretionary development application process involving

requests to local land use jurisdictions to amend their general

Comment noted. SCAG’s SCS 

local jurisdictions through mo

with local governments, dem

stakeholders; and SB 375 doe

land use policies and regulati

consistent with the SCS. In so

land use assumptions to bett

in many transit‐rich areas of t

intended to provide a regiona

may consider if they so choos

quantitative growth projectio

the region going forward, loc

use authority. For additional 

Addendum Section 4.0, Respo

RTP PEIR, Letter Number 4.
39

ID Name Affiliation Comment Re

plans, specific plans, areas plans, and zoning. In short, there is

no "shift" to high‐density housing, unless and until the local land

use jurisdictions adopt the requested discretionary approvals.

Please revise/clarify all same or similar text in the Draft PEIR

(see, for example, page 2‐30).

012‐09 Andrew

Henderson

Building

IndustryAssociation ofSouthernCalifornia

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

013‐01 Andrew

Henderson

Building

IndustryAssociation ofSouthernCalifornia

There may be a need to take a better look at some of the spacial

dispersion that’s indicated by the policy document. See if there

is a way to allow a little bit of flexibility or adjustment where it

needs to occur. You could do that without doing any real injury

to the overall benefits of the RTP/SCS in redirecting the shape of

the community in the future more towards transit orientation.

The BIA worries that there are some unintended consequences

that the methodology that lead to the spacial dispersion was in

hindsight to insular in interacting between the cities and

counties in the region without enough public vetting. And as a

consequence of that, there are perhaps some areas where there

is absolute foreseeable growth that is not well reflected in the

SCS.

Comment noted.

014‐01 Don Feger Burbank‐

Glendale‐PasadenaAirportAuthority

An important concern with the "Aviation and Ground Access"

report is the assumption that the projected annual passenger

demand for BUR would be 9.4 MAP by the year 2035. In the

November 9, 2011 response written by Mike Armstrong to our

October 4, 2011 letter (attached), SCAG took exception to our

belief that the more realistic assumption would be passenger

demand of 8 MAP or less for BUR in 2035. SCAG cites the

assumed "constraint" of a 78.9 MAP Settlement Agreement at

LAX as the driver for t his additional passenger demand at BUR.

We do not concur with that assumption. Specifically, the

passenger cap at LAX is not a legally‐enforceable access

restriction. Instead, it is a trigger for LAWA to reduce the

number of available air carrier gates. The carriers have shown

that they have the capability to increase operational efficiencies

utilizing aircraft fleet mix, scheduling, and available gate

capacity. As such, if a reduction in the number of gates did

occur, carriers could process more than 78.9 MAP. While the

Comment noted. The 2035 ai

2012 RTP/SCS will be caveate

Settlement Agreement const

that any new information pro

airport authority on legally‐al

capacity constraints at their a

aviation demand forecasts de

2016 RTP). The forecasts will 

any relaxation of the 78.9 MA

significantly impact the passe

Airport (BUR), and that Bob H

that the 2035 passenger dem

should be less than 8 MAP.
40

ID Name Affiliation Comment Re

carriers at BUR primarily handle domestic flights now and will

continue to do so in the future, it is reasonable to expect that

the carriers at LAX will structure their operations and alliances

in such a way as to accommodate the transfer of a continually‐

increasing number of international passengers, regardless of the

gate constraints they may face. The Authority is currently

underway with a new Part 150 Study, in which a new forecast of

passenger demand will be prepared. We believe that this study

will validate our earlier assumption that passenger demand in

2035 will be less than 8 MAP. That forecast will be based on the

econometrics of forecasted population growth, business

growth, and per capita income within the BUR catchment area,

and withing the larger region as a whole. That forecast will not

be based on assumptions about constraints at LAX. We ask that

this change in assumption be also reflected in the RTP.

014‐02 Don Feger Burbank‐

Glendale‐PasadenaAirportAuthority

During this process we also worked closely with OLDA in

addressing the designation of the Northern Corridor as a part of

the "Constrained Project" list in the RTP. Recently, OLDA

transmitted a letter to you dated February 7, 2012 signed by

Mr. Frank J. Quintero, Chairman of t he OLDA Board and a

member of the Airport Authority Board of Directors. We would

like to affirm our support for the comments contained in the

February 7th communication. We strongly agree that the

adoption by the SCAG Regional Council and the Metro Board of

Directors of the high speed rail project‐related MOU with the

California High‐Speed Rail Authority is a significant policy

development which should be reflected in the RTP adopted by

the Regional Council. We also support Metro's Antelope Valley

Line Infrastructure Improvement Strategic Plan and hope

preliminary results from the study can be incorportated into the

RTP.

Comment noted. As discussed 

may be added to the Constra

amendment.

015‐01 Ron Krueper California

Department ofParks and

Recreation

We offer the following suggestions regarding the Conservation

Policy: 1. Ensuring State conservancies and join powers

authorities with a conservation focus are included in the

mapping and prioritization of conservation lands. Specifically,

we recommend including the Wildlife Corridor Conservation

Authority, Puente Hills Habitat Preservation Authority, San

Gabriel and Lower Los Angeles Rivers and Mountains

Conservancy, Mountains Recreation and Conservation

Authority, and Santa Monica Mountain Conservancy among the

Comment noted. The propose

pursue a strategic planning p

resources. The intent is to inc

stakeholders, including the gr

include all applicable protecte

Language will be clarified. The 

Resources and Open Space in

of habitat linkages, preservat

crossings to minimize the imp
41

ID Name Affiliation Comment Re

entities upon whose expertise can be tapped. 2. Extending the

inventory of protected lands to include all protected lands ‐ 

Federal, State, regional and local natural lands ‐ instead of

narrowly limiting the inventory to simply Natural Communities

Plan and Habitat Conservation Plan Areas. 3. Ensuring existing

wildlife corridors and habitat linkages and highway/roadway

under‐crossings are protected and enhanced during the

evaluation of habitat lands and during construction of roadway

projects. 4. Advocating that the advanced mitigation policy

result is a net environmental benefit for the natural resource

lands after construction activities are completed.

wildlife species and habitat fr

015‐02 Ron Krueper California

Department ofParks and

Recreation

Also, large‐scale acquisition and management of lands must not

be limited to "critical habitat," (RTP, p 76, 128) as this can be

confused with the legal term used by U.S. Fish and Wildlife

Service for some federally endangered and threatened species.

To clarify, this should be replaced by text reflecting the intent,

i.e., the best available natural lands with valuable

environmental resources deserving of

conservation/preservation. State Parks looks forward to

working with SCAG on the development of the Natural Lands

Acquisition and Open Space Conservancy Strategy. This will

protect remaining resource lands and mitigate for impacts from

transportation investments. In addition to mitigation banking,

transfer of development rights, and payment in‐lieu fees, State

parks recognizes conservation easements as a powerful

preservation tool for habitat areas. Conservation easements,

and fee title transfers to open space park agencies, should be

listed in the plan alongside the other preservation mechanisms.

Comment noted. The propose

pursue a strategic planning p

resources. The intent is to inc

based on input from a wide v

has been clarified.

015‐03 Ron Krueper California

Department ofParks and

Recreation

Wildlife Crossings of Transportation Facilities: State Parks

appreciates SCAG's recognition of the impact that linear

transportation facilities have on natural areas and the need for

well‐designed wildlife crossings to partially mitigate these

effects. Wildlife crossings serve two distinct purposes: reducing

mortality and preserving genetic connectivity. Roads are the

leading direct source of human‐caused mortality for most

species in southern California and the entire country. They can

become a population sink if a significant fraction of a local

species is killed, affecting broader population distribution across

the landscape. Additionally, for highly mobile predators,

individuals crossing roads are frequently dispersing from their

Comment noted. SCAG recog

tools exist. We look forward t

Department of Parks and Rec

strategies with our regional s

will be added to denote that 

exhaustive. The mitigation pr

Open Space includes the implinkages, preservation of wild

to minimize the impact of tra

species and habitat fragment
42

ID Name Affiliation Comment Re

home range in search of new territory and mates, a vital

population dynamic that is devastating if interrupted. National

Park Service research has documented significant genetic

differences among carnivore populations on either side of the

101 Freeway in the Santa Monica Mountains. Wildlife crossings

need to be discussed in the context of habitat connectivity,

which is the broader ecological goal for conservation areas.

Wildlife crossings are but one critical tool to ensure that

indicator species are able to safely move about their

environment. While much has been learned about movement

patterns and the way in which key transportation facilities

create genetic barriers to connectivity, the measures that might

mitigate these impacts have not been thoroughly researched.

Wildlife corridor design is a field in its infancy with few

scientifically verified best practices for crossing dimensions and

landscape features. Given that this research is needed to

properly mitigate transportation impacts, SCAG should invest in

connectivity into the 2016 RTP revision. Such a program would

aggregate existing research, propose new study areas, and

develop design best practices specifically tailored to the

Southern California eco‐region.

015‐04 Ron Krueper California

Department ofParks and

Recreation

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

016‐01 Linda Rudolph California

Department ofPublic Health

The California Department of Public Health encourages regional

planning organizations to embrace the concepts outlined in the

Healthy Community framework developed by the Strategic

Growth Council’s Health in All Policies Task Force. Many

strategies that increase community sustainability can also

support improved health outcomes.

Comment noted.

016‐02 Linda Rudolph California

Department ofPublic Health

Activity time in active transport (walking, bicycling, etc.) is

indispensable as a health‐related transportation performance

measure (e.g., mean daily minutes per person of walking and

bicycling.) Attempts to monetize health co‐benefits from active

transport suggest savings of billions of dollars in health care

costs and the value of statistical lives saved. MPOs should

consider new tools that have recently become available to

quantify the health co‐benefits of active transport in SCS

scenarios and projects. This fills a gap in project performance

Comment noted. The perform

2012‐2035 RTP/SCS has been 

participation and input from 

as collaboration with other la

example, to facilitate the dial

performance measures for th

Performance Measures Subco

2011. The Subcommittee met 

from various stakeholders an
43

ID Name Affiliation Comment Re

assessment at most MPOs. As tools such as the Integrated

Transport and Health Impacts Model become available to

MPOs, health co‐benefits can be used as a criterion for a unique

project category that a priori could get a high priority score in

the project assessment methodologies used by MPOs. Using

these tools, health co‐benefits can be used as a criterion to

screen projects for cost‐benefit and other in‐depth analysis.

the Plans and Programs Tech

further discussions prior to fo

Committees.As a result of the input proce

performance measures have 

including new categories such 

continue investigating additio

updates. Also, SCAG is curren

Sustainability Tool (ST) by dev

based land use and built envi

confidential health survey inf

Angeles County, Department 

health impacts data into this 

simulation tool, users can ass

associated with changes in th

anticipates completing this w

the next round of Regional Tr

Sustainable Communities Stra

016‐03 Linda Rudolph California

Department ofPublic Health

Equity/inequity in RTPs is currently framed using Title VI of the

Civil Rights Act, concepts of “no disparate impacts” and

“increase access (to affordable housing/transit) to poor people”,

participation of communities of concern, environmental justice.

In the development of SCSs some MPOs have been exposed to a

health‐based approach which explicitly calls for ways to narrow

existing differences in health status and of determinants of

health. The Sustainable Transportation Council (LEED‐like

approach to rating transportation systems) is considering a goal

area in its transportation rating system that explicitly considers

reducing health disparities. This is a promising approach that

deserves more attention.

Comment noted. SCAG is curr

our Sustainability Tool (ST) by 

tract based land use and built 

to confidential health survey 

Angeles County, Department 

health impacts data into this 

simulation tool, users can ass

associated with changes in th

anticipates completing this w

the next round of Regional Tr

Sustainable Communities Stra

forward to learning more aboCouncil's approach and how i

efforts.

016‐04 Linda Rudolph California

Department ofPublic Health

Local health departments are highly interested and would

benefit from mechanisms that enhance their participation in

SCS development and follow‐up. It is worth exploring ways local

health departments and others interested in public health and

equity can stay engaged on an on‐going basis.

Comment noted. SCAG look

opportunities to engage local 

interested in public health an

017‐01 James

McCarthy

CaliforniaDepartment of

Transportation

Page 7 Table 2: New Revenue Sources and Innovative Financing

Strategies – The region’s budget over the next 25 years totals an

estimated $524.7 billion. We encourage SCAG to continue close

Comment noted. We agree th

stakeholders need to work to

best, most appropriate fundin
44

ID Name Affiliation Comment Re

collaboration and consensus‐building with Federal, State and

Local partners as these strategies and funding sources are

pursued.

funding for RTP priorities.

017‐02 James

McCarthy

CaliforniaDepartment of

Transportation

Page 27 Integrating Land Use and Transportation – The RTP/SCS

states that SCAG has incorporated the sub‐regional SCS

strategies of OCCOG and GCCOG into the regional SCS. It would

be helpful if the RTP explained exactly how those strategies

were incorporated.

Comment noted. The 2012‐20

address comment, as approp

017‐03 James

McCarthy

CaliforniaDepartment of

Transportation

Page 30 Public Health – The RTP/SCS recognizes the impact that

transportation and land‐use decisions have on the health of the

region’s residents. SCAG should be commended for including

studies and a discussion on this topic in the RTP/SCS which

identifies a 200% overall investment increase over the 2008

RTP.

Comment noted.

017‐04 James

McCarthy

CaliforniaDepartment of

Transportation

Pages 33‐34 Alternatives Development and Evaluation – The

chosen alternative should be clearly identified in the RTP, with

supporting information explaining the rationale for its selection.

Comment noted. As describe

alternative is the RTP/SCS (Pla

the succeeding chapters of th

017‐05 James

McCarthy

CaliforniaDepartment of

Transportation

Pages 112‐116 Creation of Land Use Scenarios – Chapter 4

explains and describes the four land use scenarios that were

developed and presented at the regional public workshops for

inclusion in the RTP/SCS however it is not clear how the

preferred alternative was chosen.

Comment noted. The SCS Ba

Appendix outlines how the 20

was chosen.

017‐06 James

McCarthy

CaliforniaDepartment of

Transportation

Page 23 ‐ Aviation and Ground Access ‐ the second paragraph

alludes to air cargo by stating that "Southern California airports

play a crucial role in international trade..," but the text does not

elaborate. If the regional roadway system becomes increasingly

congested please describe the impacts to air cargo ground

access or capacity, being that the last mile is typically

transported by truck.

Comment noted. The text of t

reflect that without improvin

system, increasing ground ac

air cargo trucks in accessing a

timely fashion.

017‐07 James

McCarthy

CaliforniaDepartment of

Transportation

Page 65 ‐ International Trade ‐ recommend changing the

sentence to read, "In the same year, $10.4 billion worth of trade

passed through the Calexico East International Port of Entry

(POE) between the U.S. and Mexico in Imperial County." Note:

of the three land POE's in the county, only Calexico East handles

commercial traffic.

Comment noted. The Calexico

crossing handles the vast maj

between the U.S. and Mexico

Algadones border crossing als

traffic. SCAG will revise the in

017‐08 James

McCarthy

CaliforniaDepartment of

Transportation

Page 65 ‐ Local Goods Movement ‐ Dependent Industry Support

‐ recommend adding agriculture as one of the supported

industry sectors. Agricultural production in the SCAG region is

significant, amounting to nearly $7 billion in 2010.

Comment noted. While agricu

Southern California, the 2012 

movement dependent indust

construction, and retail trade
45

ID Name Affiliation Comment Re

http://www.cfbf.com/counties/index.cfm

017‐09 James

McCarthy

CaliforniaDepartment of

Transportation

Page 66 ‐ Land Ports ‐ recommend changing the sentence to

read, "The Calexico East International POE in Imperial County is

the sixth busiest commercial crossing along the U.S./Mexico

border, with over 600,000 annual commercial vehicle crossings

in 2010, and a combined import/export value of over $10

billion. The primary economic drivers of cross border trade to

Imperial County are the movement of agricultural products and

the maquiladora trade industry."

Comment noted. SCAG curren

import/export value of goods 

border totals over $10 billion 

exports). While the Calexico‐E

handles the vast majority of c

U.S. and Mexico, the Andrade

also handles some commerci

information regarding the nu

appropriate.

017‐10 James

McCarthy

CaliforniaDepartment of

Transportation

Pages 71 and 72. Regional Clean Freight Corridor System. The

discussion indicates that a dedicated truck‐only freight corridor

could serve as a “platform for the introduction and adoption of

zero‐emission technologies;” however, the connections

between the East‐West Freight Corridor and clean trucks could

be stronger, and the introduction of clean trucks could be

related to the timeframe in Table 2.8 (page 72).

Comment noted. Emissions fr

a significant concern for the S

lane system identified in the 

facility used by zero‐emission 

language and revise to streng

appropriate.

017‐11 James

McCarthy

CaliforniaDepartment of

Transportation

Trip Planners: Please consider incorporating future updates of

transit route data in trip planning tools such as Google Transit or

Go511.com.

Comment noted.

017‐12 James

McCarthy

CaliforniaDepartment of

Transportation

Page 3 ‐ the following sentence needs to be corrected:

"Currently, SCRRA operates seven routes including five from

downtown Los Angeles to Ventura, Lancaster, San Bernardino,

Riverside, Orange and Oceanside, from San Bernardino to

Oceanside, and from Riverside via Fullerton or City of Industry

to downtown Los Angeles." The word in this sentence "five"

should read "six" instead. One route is missing in the list. Please

add "Orange" after Riverside.

Comment noted. The Final RT

017‐13 James

McCarthy

CaliforniaDepartment of

Transportation

Page 31‐ Connectivity measures need to include a high degree

of reliability (on‐time performance to meet connections with

other modes).

Comment noted. On‐time pe

transit connectivity opportun

017‐14 James

McCarthy

CaliforniaDepartment of

Transportation

The transit supplemental report should include how gas prices

affect the fares and ridership. Gas price is a major operating

expense in bus operations. It should also include such variables

as inflation rate, CPI, unemployment rate, to see how they are

related to fares and ridership.

Comment noted. The "State o

Appendix included a detailed 

prices and the recession on tr

years. The "System Performa

Regions" looked at variables s

on operations and maintenan

our region.

017‐15 James California It should be noted that Caltrans has not done an analysis of the Comment noted.
46

ID Name Affiliation Comment Re

McCarthy Department of

Transportation

transportation travel model work utilized with the SCS. We

would expect the California Air Resources Board to make any

comments on that topic:

http://www.arb.ca.gov/research/aaqs/aaqs2.pdf

017‐16 James

McCarthy

CaliforniaDepartment of

Transportation

In order to see the Greenhouse Gas (GHG) emission reduction

compliance table for the SCAG RTP/SCS, the reader has to find it

on page 3.6‐20 of the PEIR. This data table should be included in

the SCS Section of the RTP as well as in the PEIR.

Comment noted. The Final 20

comment.

017‐17 James

McCarthy

CaliforniaDepartment of

Transportation

Caltrans supports SCAG's RTP/SCS mitigation measures aiming

at reducing VMT and the associated GHG emissions,

encouraging sustainable land use development, and the

development and implementation of the use of multi‐modal

transportation options.

Comment noted.

017‐18 James

McCarthy

CaliforniaDepartment of

Transportation

As the owner and operator of the State Highway System (SHS)

the Department's main objective is to protect the mobility and

operational safety of the SHS. To ensure operational safety and

consistency with the Department's policies, we encourage early

consultation and coordination with local jurisdictions and

project proponents on all development projects that may have

an impact on state facilities.

Comment noted.

017‐19 James

McCarthy

CaliforniaDepartment of

Transportation

On the Project List for Orange County there is no mention of

extending the planned High Occupancy Vehicle (HOV) lane from

Avenida Pico to the Orange/San Diego County Line in both

directions.

Comment noted. This project 

the Strategic Plan portion of t

017‐20 James

McCarthy

CaliforniaDepartment of

Transportation

Project List for Los Angeles County ‐ on page 157 the Route High

Occupancy Vehicle (HOV) project, Citrus to Route 57/210, it

should be noted that the portion of Route 210 between Route

10 and Route 210 has been re‐named Route 57. This was done

to address confusion between Interstate 210 west of Route 57

and State Route 210 east of Route 57. New signage has been

recently added.

Comment noted. SCAG has ad

to the Project List as submitte

commissions through the sta

modification and FTIP databa

017‐21 James

McCarthy

CaliforniaDepartment of

Transportation

Also on the Project List for Los Angeles County ‐ please delete

the following project on page 161: Route 405 in Inglewood at

Arbor Vitae which is pertaining to constructing the south half of

the interchange. The Interstate 405 Arbor Vitae Half

Interchange Project in Inglewood has been shelved per FHWA

due to a required design exception issue.

Comment noted. SCAG has ad

to the Project List as submitte

commissions through the sta

modification and FTIP databa

017‐22 James

McCarthy

CaliforniaDepartment of

Page 15 ‐ Caltrans encourages SCAG to coordinate with Caltrans

Districts and regional partners to ensure consistency with

Comment noted. SCAG will co

Districts and regional partner
47

ID Name Affiliation Comment Re

Transportation interregional system development and operational strategies.

Examples could include project phasing and integration, the

development of HOV/HOT /Managed Lane policies, and the

alignment of on‐system transit service support strategies.

017‐23 James

McCarthy

CaliforniaDepartment of

Transportation

Page 3 ‐ under OR SR‐71 should read SR‐73 and where it says SB

SR‐210 should be I‐210.

Comment noted. Table 2 has 

210.

017‐24 James

McCarthy

CaliforniaDepartment of

Transportation

SB 391 and the California Interregional Blueprint should be

mentioned among related initiatives.

Comment noted. The Final 20

of SB 391, implementing legis

the California Transportation 

implementing the goals and r

and will mention the Californ

related initiatives.

017‐25 James

McCarthy

CaliforniaDepartment of

Transportation

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

018‐01 Kirk

Marckwald

CaliforniaEnvironmental

Associates

As an overall comment, many sections of the current draft RTP

identify possible elements of the strategy without providing

consistent information about: (1) who would fund each

measure, (2) under what authority each measure would be

undertaken, and (3) in what timeframe each measure would be

implemented. The Railroads believe it is important to furnish

that information so that all stakeholders get an accurate

perspective of the overall plan (see Table 1 in attachment). At a

minimum, the RTP should note that these issues are unresolved.

Comment noted.

018‐02 Kirk

Marckwald

CaliforniaEnvironmental

Associates

The RTP does not clearly state the issues that remain

unresolved with these technologies. For example, SCAG needs

to clarify if funds for such studies are already available. If not,

the RTP should make clear that participation in further study

and possible demonstration of these technologies will only be

undertaken if funds become available for such activities in the

future. SCAG should also clarify that these actions must be

voluntarily undertaken by all stakeholders. Neither SCAG, nor

other local, regional, and state agencies have the authority to

require the Railroads to participate in or to provide funds for

any study of electrification or any other technology. SCAG

should also clarify that the "several options for a zero emission

rail system" are not currently available, but could be pursued in

the future if additional funding, research, development, and

testing to confirm their applicability were completed. SCAG

Comment noted. Further clar

technology readiness has bee

as appropriate. We recognize 

authority to require the Railro

funds for any technology eva

was not intended to suggest a

has been clarified as appropr
48

ID Name Affiliation Comment Re

needs to clearly specify a timeframe for the continued study of

these technologies. Lastly, the Railroads question why the

recommendations on freight rail environmental mitigation are

repeated in the passenger rail section of the RTP.

018‐03 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[Page 74, sentence beginning with "For the near‐term, the

regional strategy supports the deployment of..."] As noted in

Table 1, SCAG needs to clarify which stakeholder(s) would

pursue this strategy and where funding would come from. SCAG

needs to be clear that upgrading switcher locomotive engines is

not in the resource‐constrained plan and will only be pursued if

stakeholders identify funds. Any participation by the Railroads

to upgrade switcher engines would be voluntary. The Railroads

believe that neither SCAG, nor any local or regional agencies,

have the authority to require the Railroads to deploy newer

switcher locomotives. Furthermore, the Railroads have made

significant environmental investments in the SCAG region over

the last decade or more. The progress made over the years has

been documented by the ARB in numerous public meetings. For

example, in 2005, the Railroads signed a MOU with ARB that

was estimated to reduce PM emissions by 20% by 2008 at rail

yards statewide. In 2009, ARB determined that the Railroads

had fully complied with all requirements of the 2005 MOU. In

2010, the 1998 Fleet Average Agreement was implemented.

ARB has said that the 1998 Fleet Average provided "locomotive

fleet benefits in southern California 20 years earlier than the

rest of the country."

Comment noted.

018‐04 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[Page 74, sentence beginning with "In the longer term, the

strategy focuses on a more fundamental shift in technology..."]:

As the Railroads work with other stakeholders to further reduce

rail emissions in the SCAG region, it is important that any

technology introduced does not compromise the safety,

velocity, cargo throughput, economic competitiveness, or

reliability of the goods movement system. It would be helpful to

point out that to date, stakeholders have not reached

consensus on technologies, timing, funding, or emissions

impacts of the various options SCAG examined in the RTP. Prior

to proposing a fundamental shift in implementing new

technology, SCAG and all goods movement stakeholders need

to clearly establish if and where within the existing rail system,

such "critical steps toward gradual implementation of a zero‐

Comment noted. We agree th

include the input of all stakeh

to strengthen this point. Add

technologies must not compr

movement system.
49

ID Name Affiliation Comment Re

emission or near zero‐emission freight system" could be

implemented.

018‐05 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[Page 75, Table 2.11]: SCAG should clarify the methodology

used to estimate emissions reductions from an electrified

system. SCAG needs to explain how it accounted for the

additional emissions produced as a result of the electricity

required for such a system and if it has not accounted for them,

SCAG should do so in the final version of the RTP. These

emissions have real environmental impacts and should be

addressed in any reference to electrification of a freight rail

system or the associated emission reductions. Please refer to

the attached issue briefs for more information on

electrification.

Comment noted. The method

estimates that you refer to is 

"Analysis of Freight Rail Elect

Please refer to this document 

018‐06 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[Page 70, sentence beginning with "In past RTPs, SCAG has

envisioned a system of truck‐only lanes..."]: One of the

alternatives of the East‐West Freight corridor for trucks is

proposed to be directly adjacent to a UP mainline track. As UP

has stated in discussions with SCAG staff, although off of UP

privately‐owned right‐of‐way, construction of such corridorcould limit further opportunities for businesses to become rail

served.

Comment noted. The East‐W

identified as part of the 2012 

more detail through an Enviro

other alignments would be co

analysis as part of that EIR. SC

closely with its partners and i

Railroad, on next steps relate

Corridor.

018‐07 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[EJ Appendix, page 136]: Both Exhibit 34 and SCAG's conclusion

referencing it are fundamentally flawed; the conclusions

presented are unfounded and SCAG does not provide

supporting data. First, SCAG does not clearly define how the

cancer risk shown on the map was determined, what emissions

or other environmental factors the map is intended to reflect,

or what sources (e.g. mobile or stationary or other) the cancer

risk derives from. Additionally, the data presented in the EJ

section is not consistent with, or supported by, any data in the

PEIR's Health Risk Assessment, which only modeled certain

representative highway segments and did not model rail.

Second, SCAG vaguely describes this map as an "overlay." If the

data reflecting the areas of high cancer risk in Exhibit 34 is the

same data used to generate the regional cancer risk map in

Exhibit 26, then the cancer risk was generated at the regional

level, and is therefore not directly attributable to rail emissions.

SCAG must either remove Exhibit 34 and misleading discussion

language, or substantially revise it and provide the source data.

If SCAG keeps Exhibit 34, it must present identical maps and

Comment noted. Exhibit 34 a

deleted from the Final Enviro

this map is misleading as canc

associated with sources of po

limited to rail‐related pollutio

that the cancer risk data show

Environmental Justice Appen

map shown in Exhibit 26, whi

rail and other mobile pollutio

Final Environmental Justice A

the methodology used to dev
50

ID Name Affiliation Comment Re

analyses for arterials, highways, and other transportation

sources discussed in the plan, such as airports. SCAG should

ensure that maps for each source are presented in the same

manner: at the same scale, with the same color scheme, and

utilizing the same buffer distances. [refer to letter for comment

details, pp. 10‐13]

018‐08 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[EJ Appendix]: SCAG rail impacts and highway impacts are

handled differently by SCAG, both in discussion text and in how

tables and figures are organized and displayed. When analyzing

data on potentially impacted areas, SCAG uses shorter distances

to create the geographic buffers around the highways and

arterials than it does around the rail lines. This arbitrary

selection affects not only the evaluation of local impacts from

rail, but also the assessment of whether the impacted

communities are in fact EJ communities. We would like to see

more information on how SCAG reached its conclusions that rail

disproportionately impacts EJ versus non‐EJ communities. SCAG

does not show a rational basis for these conclusions. SCAG does

not provide any justification for the difference between buffer

distances around rail versus highways and arterials used in the

analysis. SCAG should either justify the difference between the

buffers or make them the same. In the discussion of highway

and arterial impacts, SCAG compares the impacts from on‐road

sources as a result of implementing the RTP to the impacts of a

no‐plan scenario. However, this comparison is not completed

for rail impacts. The approach SCAG staff took in characterizing

the "Rail‐Related Impacts" creates the potential for an

inaccurate interpretation of rail's contribution to the region's air

quality. Further, although SCAG broadly states that rail

remissions are significant on page 131, SCAG does not quantify

actual emissions. Quantification of rail emissions and the

comparison between emissions from trucks on highways and

rail in the region is critical to understanding freight

transportation tradeoffs, the context under which rail

investments are made, and the potential shifts between

transportation modes [refer to letter for comment details, pp.

13‐14]

Comment noted. In the Final 

the buffer areas of study surr

adjusted to improve their par

report for highways and arter

related emissions has been re

018‐09 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[EJ Appendix] SCAG needs to clearly state whether the rail

mitigation measures in the EJ Appendix are a part of the

resource‐constrained plan or a part of the strategic plan. SCAG

Comment noted. SCAG exam

the Federal Highway Adminis

Mitigation Toolbox in the EJ A
51

ID Name Affiliation Comment Re

needs to clarify who would be responsible for pursuing these

mitigation measures, where the funding would come from, in

what timeframe the measures would be implemented, and

under what authority. First, SCAG recommends the acceleration

of cleaner line‐haul locomotives. At this time, these new

technologies are untested and unproven in line haul locomotive

applications. Second, the EJ appendix recommends the

installation of sound barriers and acoustical insulation. SCAG

needs to be clear about whether the RTP requires these

measures to be implemented, or if they are only recommended

actions for future consideration that do not currently have

funding identified. SCAG also needs to clarify whether the

installation of sound barriers would be on the Railroad's

property and if there would be any potential for interruption to

railroad operations. Finally, in response to the recommended

strategy to reduce speed or hours of operation, SCAG should

note that the Railroads operate 24 hours a day, seven days a

week. Limiting hours of operation would have nation‐wide

effects and could ultimately result in higher emissions in the

SCAG region if containers were shifted to truck transport.

Additionally, train speeds are dictated by track conditions and

regulated by the FRA and therefore fall outside the authority of

SCAG. Accordingly, this strategy should be removed from the EJ

appendix. [refer to letter for comment details, pp. 15‐16]

voluntary measures that coul

justice concerns, if feasible an

These recommendations wer

Draft PEIR and have been rev

to clarify that they are volunt

requirement on project spons

reference to electrification, th

locomotives, acquiring rights‐in the Environmental Justice A

construction of sound barrier

that the measures are volunt

limits on operation has been 

018‐10 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[EJ Appendix, page 145, sentence beginning with "Additionally,

the 2012 RTP proposes railroad electrification..."]: According to

the Goods Movement Appendix and the RTP, SCAG is not

proposing to implement electrification, but rather to continue

study of electrification and other ultra‐low emission strategies

in the future, if additional funds become available. Therefore,

SCAG should remove the sentence that claims "the 2012 RTP

proposes railroad electrification" and revise this section to be

consistent with the Goods Movement Appendix and the RTP.

SCAG, and other local, regional and state agencies, do not have

the authority to require the Railroads to pursue electrification.

Comment noted. SCAG will re

electrification in the EJ Appen

Mitigation Toolbox provides a 

could help address environm

projects, if feasible and applic

been added to the Environme

018‐11 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[EJ Appendix, page 131, sentence beginning with

"Environmental pollution from locomotives, rail yards and other

rail facilities..."]: SCAG does not specify what types of rail it is

referring to in the impacts assessment. Is SCAG including freight

and passenger rail? If passenger rail is included, are commuter

Comment noted. SCAG concu

proportionally a small contrib

emissions. As described in th

appendix (p 32 in the Draft En

emissions are 5% and 4% of r
52

ID Name Affiliation Comment Re

lines and urban lines accounted for? In 2010, ARB estimates

locomotives contributed less than one percent of PM2.5

emissions and less than three percent of NOx emissions in the

South Coast Air Basin. As a point of comparison, other mobile

sources such as passenger vehicles, off‐road equipment (e.g.

farm and construction), and diesel trucks in the South Coast Air

Basin contribute roughly 20%, 24%, and 27% of NOx, and 8%,

10%, and 7% of PM2.5, respectively. Despite this, SCAG portrays

rail emissions as regionally significant in the EJ appendix. Finally,

the Railroads disagree with SCAG's statement that locomotive

emissions are a national "major public health concern." The air

quality and mix of emissions sources in the SCAG region are

unique, and perhaps uniquely challenging due to the geographic

and meteorological conditions. As SCAG notes, 33% of all freight

containers in the US move through the Southern California

ports. Many of these goods travel on rail, and yet, rail is less

than 3% of NOx and 1% of PM emissions in the South Coast Air

Basin.

NOx and PM emissions, respe

clarifies that while this is a re

concentrations of rail activitie

pollution hot spots. Text in t

and will specify that analysis 

018‐12 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[EJ Appendix, page 145, sentence beginning with "The train

traffic index of each railroad segment is calculated..."]: SCAG

uses the results of the train traffic index to suggest the relative

level of impact on different rail segments. Did SCAG include

passenger trains in this index? SCAG should state whether

Exhibit 36 reflects both passenger rail and freight rail or just one

or the other. SCAG's assertions about the correlation between

"accidents" and "traffic delays" on such segments are purely

speculative and should be noted as such. Also, there should be a

discussion of the planned improvements scheduled for these

areas, through existing commitments for grade separations and

capacity improvements, such as the Colton Crossing. In addition,

SCAG fails to include a comparison of the improvements in train

traffic index over the lifespan of the RTP. SCAG should clarify

that the index provided is simply a snapshot in time for 2010.

Given that Colton Crossing is a committed and funded project,

SCAG should show relative improvement gained through

completion of Colton Crossing and other near‐term grade

separations. Furthermore, SCAG provides no information that

the "total gate down time of two grade crossings located at

both ends of the segments" has been correlated to traffic

counts on the streets with the gates down. Without traffic

Comment noted. The train tra

segment is calculated by usin

including both passenger rail 

total gate down time of two g

ends of the segment. The sec

been clarified and modified a

questions and suggestions.
53

ID Name Affiliation Comment Re

counts or the time of day data, SCAG can draw no conclusions

about the correlation between gates being down and the

impacts to human populations.

018‐13 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[Goods Movement Appendix, page 34]: SCAG needs to be clear

about which specific activities associated with the phases of

development listed in Figure 9 are in the resource‐constrained

plan, which have funds currently available, and which activities

do not have funds available. This will help clarify which activities

will only be implemented when, and if, additional funds become

available. If there is funding currently available, SCAG needs to

state that it plans to carry out the timeline presented for the

technology demonstration and potential implementation of

new freight movement technologies. If not, it should point out

that such a project could not be implemented until or unless

funding becomes available. Additionally, it is worth noting that

any full scale demonstration and/or commercial deployment

would need the full support of the Railroads, and potentially

other governmental agencies, to move forward. SCAG should

also include a provision that the Railroads will be involved in the

design of the parameters for a full‐scale demonstration. In

Figure 9, it appears that Phase 1 is already complete and

consisted of work done to develop the draft 2012 RTP. If this is

true, SCAG should clarify that point. The timeframe for Phase 2

will vary substantially depending on which technology is studied

further. SCAG should specify the technologies that would be

evaluated in Phase 2 and provide specific timeframes for each.

In any event, the timeframe identified by SCAG for Phase 2 is far

too short for the evaluation, development, completion of the

environmental review process and demonstration of an

electrified system. The desired accomplishments in Phase 3 are

unrealistic for the short time allocated. The timeline should be

revised so that any deployment or operational demonstration

would come after sufficient time has been allocated to resolve

all technical, operational, and safety issues identified for the

various low emission system options. Additionally, the timeline

for Phase 4 is unrealistic and should be lengthened to give

adequate time for zero‐emission technologies to mature and

undergo sufficient testing.

Comment noted. Funding for 

demonstration has been furth

We agree that any regional d

all stakeholders involved. We 

strengthen this point and add

concerning timeframes are no

018‐14 Kirk

Marckwald

CaliforniaEnvironmental

[Goods Movement Appendix, page 36, sentence beginning with

"Phase 2 also includes initial proof of concept..."]: SCAG should

Comment noted.
54

ID Name Affiliation Comment Re

Associates clarify under what circumstance this phase will be undertaken.

The draft RTP implies that it would only take place if future

funds are collected from the VMT tax, but it is unclear. If Phase

2 is undertaken, the Railroads believe that SCAG needs to

explicitly outline on what right‐of‐way and for what purposes

such a system could be deployed. Additionally, part of Phase 2

should include an evaluation to estimate the total capital and

operating costs for such a system, how those costs might be

passed through to customers, and if the magnitude of the costs

might cause cargo to shift either between modes or to a

different point.

018‐15 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[Goods Movement Appendix, page 39]: It would appear from

the simple language in Table 16 that the actions listed are

included in the resource constrained portion of the RTP.

However, SCAG has yet to identify what funding source would

be used, and in what timeframe the "agency action" would

occur. Specifically, SCAG should clarify whether there is funding

available for the incorporation of a "footprint" and planning for

wayside power into rail lines and/or whether there is funding

identified to support rail evaluation and demonstration efforts.

If there is not money available for such efforts, the Railroads

believe that these measures would more appropriately be

placed in the strategic plan. In any case, the timeframe for

implementing these actions (2012) is unrealistic given the lack

of funding identified to date. It is not clear how SCAG, AQMD,

and/or ARB will determine if electrified rail technologies are

feasible. The Railroads should participate in the development of

design criteria to make this determination. SCAG also needs to

clarify what is meant by "incorporate" into the 2012 Agency

Action section. Specifically: What processes would occur should

any of these elements be "incorporated" into the RTP? Would

this incorporation involve a formal amendment process? Would

the Railroads have an opportunity to comment if SCAG, AQMD,

and/or ARB were to pursue any of these implementation

actions, based on the RTP?

Comment noted.

018‐16 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[Goods Movement Appendix, page 42, sentence beginning with

"Because of the cost and potential operation challenges..."]:

SCAG staff has explicitly stated at various public meetings that

mainline electrification is not part of the resource constrained

plan or the strategic plan. Please confirm that this is the case.

Comment noted. Mainline ele

constrained or strategic plan. 

work with regional stakehold

for the region. The text was n

requirement; rather, it indica
55

ID Name Affiliation Comment Re

Additionally, SCAG should explain what is meant by the

statement that SCAG would require the "cooperation by the

BNSF and UP railways."

electrified rail system would n

railroads.

018‐17 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[Goods Movement Appendix, page 42, sentence beginning with

"Two promising technologies that are under development..."]:

SCAG should explain that neither the hybrid diesel‐electric

locomotive nor the battery electric tender car technologies are

currently available and are not part of the resource constrained

or strategic plan. Each technology would need to be designed,

developed, and tested prior to implementation, which is a

process that historically has taken between five to ten years.

Comment noted. The text ref

under development and not y

018‐18 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[RTP page 42, sentence beginning with "The RTP goods

movement strategy ensures..."]: SCAG needs to clarify what is

meant by the "planning efforts" for a "regional zero emission

freight system." These planning efforts will be, as the Railroads

understand, the continued study and evaluation of technology,

operational issues, and costs associated with various electricity‐

based options. While these technologies will likely offer some

localized emissions reductions, as cleaner diesel locomotives are

introduced into the region, including Tier 4 locomotives, the

magnitude of emission reductions will be significantly reduced.

SCAG identifies a similar trend in the potential for emissions

reductions from passenger transportation strategies on page 28

of the RTP. SCAG should also note that the magnitude of the

benefits associated with electrification activity would be

diminished with the introduction of cleaner locomotives.

Comment noted.

018‐19 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[Goods Movement Appendix, page 41, sentence beginning with

"Switcher locomotives contribute only a small share..."]: The

RTP should note that SCAG, and all other local, regional, and

state agencies, do not have the authority to require the retrofit

or replacement of Tier 0 or Tier 0+ locomotives. SCAG should

clarify that this strategy can only be implemented on a

voluntary basis, is not in the resource‐constrained portion of the

RTP, and will only be implemented if stakeholders can fund the

replacement of older switcher locomotives. Tier 4 locomotives

are not in production yet, and are not expected to become

commercially available until 2015. Therefore, it is illogical to

include a strategy to repower switcher locomotives with Tier 4

engines as they do not currently exist. Moreover, this is not a

cost‐effective strategy to reduce emissions as switcher engines

Comment noted.
56

ID Name Affiliation Comment Re

burn far less fuel than line‐haul units. The Railroads have used

public/private partnerships in the past to help reduce emissions

from switcher locomotives as opportunities arise, but future

projections out to 2023 regarding the repower of switcher

engines to Tier 4 are not realistic.

018‐20 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[Goods Movement Appendix, page 35, sentence beginning with

"Additionally, significant effort has gone into..."]: SCAG should

note that when the Ports presented their evaluation of "zero

emission" options in mid‐2011, they concluded that, "none of

the proposals were sufficiently mature to commit to a full‐scale

operational deployment or demonstrated they could deliver a

reliable and financially sustainable system..."

Comment noted.

018‐21 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[Project List Appendix, p. 422]: SCAG identifies $3,771,002,000

for ‘goods movement research and development’ as part of the

resource constrained plan in measure RRC0703. This language is

vague and potentially misleading. The funding source is unclear,

and is not mentioned in the Goods Movement appendix or in

the RTP. SCAG needs to clearly identify the source of funds and

their specific use. What technologies would "goods movement

research and development" cover? Why does the RTP ID begin

with RRC ‐ is that indicative of the intention to use these funds

for rail technology development? Where could a reader find the

write‐up of RRC0703? This vague placeholder for goods

movement research and development has the potential to be

interpreted differently by various stakeholders and needs to be

clarified to avoid future conflict.

Comment noted. Further clar

text as appropriate.

018‐22 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[Passenger Rail Appendix, p. 16, sentence beginning with "In the

SCAG Region, this plan will be complicated by drive issues."]:

Before moving forward with this part of the passenger rail

development, SCAG and/or the High Speed Rail Authority need

to address whether the overhead catenary lines will interfere

with freight railroad operations. Failure to reconcile this issue

could result in major operational issues in the SCAG region and

result in economic and environmental harm. SCAG should

identify if funding has been allocated to study the potential

issues with shared ROWs and what agency would decide if and

how facilities can be shared. The Railroads should be included in

all conversations and studies that address using rail facilities as

to not adversely affect the goods movement system.

Comment noted.

018‐23 Kirk California [Passenger Rail Appendix, p. 21, sentence beginning with Comment noted.
57

ID Name Affiliation Comment Re

Marckwald Environmental

Associates

"Currently, rail service between downtown LA and the Coachella

Valley..."]: UP has entered into an agreement with SCAG

member agencies to study the possibility of service to the

Coachella Valley that would be served by whatever Amtrak

service is currently provided in the region. There would be lost

freight capacity to UP in providing such service that would have

to be mitigated in some manner.

018‐24 Kirk

Marckwald

CaliforniaEnvironmental

Associates

[Passenger Rail Appendix, p. 19, sentence beginning with "Phase

II is from Madera to Sacramento..."]: A portion of this analysis

impacts UP owned ROWs. UP's position on this subject was best

stated in its November 23, 2009 letter to the California High

Speed Rail Authority providing scoping comments for the Los

Angeles to San Diego via Inland Empire EIR/EIS. UP owns the Los

Angeles, Alhambra, and Yuma subdivisions ROWs in fee simple

between central Los Angeles and the Colton‐San Bernardino

urban complex. UP controls and operation and maintenance of

these subdivisions. No other carrier or government agency has

the right to permit other railroads or rail operators to use any

part of this ROW. These CTC‐dispatched main lines, primarily

single‐track but with some segments of double track, form the

western end of the vital Sunset Route and are the main conduits

for movement of Pacific Rim containers out of the ports of Los

Angeles and Long Beach. The importance of these subdivisions

to the efficient movement of containers and other freight traffic

cannot be overstated. Confirming prior statements, both

written and oral, UP will not voluntarily make any part of these

subdivisions available for the high‐speed rail alignment.

Comment noted.

019‐01 Tim

Carmichael

CaliforniaNatural GasVehicleCoalition

I am writing on behalf of the California Natural Gas Vehicle

Coalition to provide comments on the Southern California

Association of Governments’ (SCAG) 2012‐2035 Draft Regional

Transportation Plan/Sustainable Communities Strategy

(RTP/SCS). The California Natural Gas Vehicle Coalition (CNGVC)

is an association of natural gas vehicle and engine

manufacturers, utilities, fuel providers and fleet operators

serving the state. We work with legislators and regulators to

develop policies that will increase alternative fuel and vehicle

use, support new initiatives and provide up‐to‐date information

on NGV technology and market developments. Our primary

concern is that the draft plan largely ignores natural gas as a

transportation fuel and its potential to be a significant part of

Comment noted. While the R

vehicle fleet assumptions in A

sought to further the implem

number of planning efforts, in

AB 118 funding. As discussed 

the RTP, the planning for a ze

of near‐term alternative fuels 

long‐term vision. For example

currently engaged with three 

encourage the use natural ga

Drayage‐ Natural Gas Truck R

replacement of old, heavy‐du

trucks powered by clean natu
58

ID Name Affiliation Comment Re

the solution for the region’s transportation, air quality, and

sustainability goals. By focusing almost entirely on “zero‐

emission” vehicles we believe SCAG is missing the opportunity

to develop a strategy that achieves the same benefits in a

shorter time frame and for significantly less cost. Over the last

two decades we have seen in California that it is very difficult to

predict which technology will succeed and even more difficult to

say when they will achieve significant market penetration. That

is why more agencies and companies are taking a portfolio

approach to developing and deploying clean transportation

technologies. Natural gas should be an integral part of your

Regional Transportation Plan. Natural gas is a very clean fuel,

available today for half the price of diesel, and it is abundant in

North America. This is why the medium‐ and heavy‐duty vehicle

markets in particular are embracing natural gas like never

before. Many public and private fleets are investing in natural

gas vehicles. Transit agencies, taxi fleets and private companies

such as Waste Management; United Parcel Service, AT&T, and

Verizon have purchased thousands of small, medium, and large

natural gas vehicles. The heavy duty vehicle sector seems to

show the greatest promise for natural gas because of the fuel

cost savings over diesel and the lack of other viable alternatives

to diesel. Recently Swift Transportation, one of the largest

trucking companies in the country, said they would be investing

heavily in natural gas trucks and could reach 30%‐40%

penetration in their fleet in 3‐4 years.

with the deployment of appro

The Liquefied Natural Gas (LN

makes the final connection be

LNG fuel infrastructure in Sou

stations being developed in U

fueling corridor along one of 

goods movement truck route

Salt Lake City, Utah. And final

CNG Truck Replacement Proje

deploy 262 natural gas trucks 

stations. There are currently 

fueling stations in developme

shown a commitment to expa

alternative fuels.

019‐02 Tim

Carmichael

CaliforniaNatural GasVehicleCoalition

Be careful about “zero‐emission”. The term is used a bit too

freely these days. Using life cycle emissions analysis California

has found that zero‐emissions at the tailpipe are only part of the

picture. It is important to consider the whole picture including

upstream emissions from production and transportation of

fuels. Some are trying to draw a bright line between “ZEV fuels

and technologies” and “non‐ZEV fuels and technologies”. We do

not see a bright line now and to the extent that there is a line

we see it fading over time. Natural gas vehicles are near‐zero

emissions today and are getting cleaner with each generation of

engines. Biomethane (aka renewable natural gas) has been

identified as one of the cleanest transportation fuels by the

California Air Resources Board. Renewable Natural Gas has 90%

less carbon emissions than gasoline. Sources include landfills,

Comment noted.
59

ID Name Affiliation Comment Re

agricultural operations like dairies, and waste water treatment

plants. Whether it is used on its own or blended with

conventionally natural gas it is likely to be one of the cleanest

fuels in transportation over the next couple of decades. For

these reasons we ask you to revise your plan to include natural

gas as a meaningful part of the solution.

020‐01 Laura Massie California

Rural Legal

Assistance,Inc.

We commend SCAG for the detailed preparation and analysis

evident in the draft RTP/SCS and accompanying documents.

Transportation planning for a region of SCAG’s size and diversity

is a challenging endeavor. The draft RTP/SCS shows an

impressive commitment not only to addressing the region’s

transportation needs but also to fulfilling the new requirements

of SB 375. However, we have some concern that the draft

RTP/SCS does not make adequate provision for the unique

circumstances of rural communities in the SCAG region,

particularly the low‐income rural communities that house the

region’s agricultural workforce. We offer the following

comments in an effort to ensure that SCAG will adopt a final

RTP/SCS that addresses the needs of low‐income rural and

farmworker communities.

Comment noted.The RTP/SCS 

communities in an equitable 

020‐02 Laura Massie California

Rural Legal

Assistance,Inc.

We recommend that SCAG add an RTP goal focused on

equitable distribution of the benefits and burdens of the

RTP/SCS. The draft RTP/SCS includes a list of RTP Goals, set forth

on p. 13 and correlated with performance measures as

described on p. 15. The RTP Goals address a number of key

concerns such as safety, air quality, goods movement, and

facilitation of transit and active transportation. However, the

RTP Goals included in the draft RTP/SCS fail to address issues of

equity, either on a socioeconomic axis (equitable distribution of

burdens and benefits across socioeconomic categories) or on a

geographic axis (equitable distribution of burdens and benefits

throughout the diverse communities of the SCAG region). Given

the size and diversity of the SCAG region, it is unlikely that such

equity will be achievable unless it is made a primary goal of the

RTP/SCS and explicitly considered at each step of the RTP/SCS

development process. We recommend that SCAG add an RTP

Goal incorporating these two axes of equity. The majority of our

remaining recommendations would support the incorporation

of such a goal into the fabric of the entire RTP/SCS.

Comment noted. The intent o

Justice Analysis is to inform tr

low‐income and minority comto participate in the decision 

equitable distribution of bene

share of burdens. The 2012 R

Appendix evaluates region‐w

demographic groups. The res

measures demonstrate the re

demographic groups are antic

the RTP. For a detailed descri

the 2012 RTP/SCS Environme

impacts are addressed in deta

environmental review, based 

regarding project specificatio

goals, the performance meas

RTP/SCS has been developed 

and input from stakeholders 

collaboration with other large 

to facilitate the dialogue and 
60

ID Name Affiliation Comment Re

measures for the 2012‐2035 

Subcommittee was establishe

met and gathered extensive i

and provided recommendatio

Technical Advisory Committe

forwarding to the Policy Com

process and deliberations, ov

have been added to the RTP/

location efficiency. In additio

developed in two types based 

alternatives evaluation and th

Building on the progress, staf

additional measures for futur

020‐03 Laura Massie California

Rural Legal

Assistance,Inc.

We recommend that SCAG further the farmland preservation

goal of SB 375 by actively planning for the transportation and

housing needs of the region’s agricultural workforce. As

acknowledged on p. 128 and in Exhibit 4.8 of the draft RTP/SCS,

SB 375 requires SCAG to include in the SCS a consideration of

resource areas and farmland. See Cal. Gov’t Code § 65080

(b)(2)(B)(v). The preservation of productive farmland will

necessarily require providing for the needs of the region’s

agricultural workforce, including the need for the creation of

appropriately sited decent affordable housing – generally at

levels affordable to extremely low‐income (ELI) households –

and transportation options, including transit, that facilitate

farmworkers’ access not only to their agricultural workplaces

but also to human services, children’s schools, medical facilities,

retail (including full‐service grocery stores), non‐agricultural

jobs for other adult members of farmworker households, and

other amenities. In the interest of preserving the region’s

farmlands, we recommend that SCAG incorporate the

consideration of these needs as a component of the

consideration required by SB 375. This recommendation will

also further SB 375’s broader goal of greenhouse gas reduction

by increasing transit accessibility to rural populations, resulting

in a reduction of vehicle miles traveled.

Comment noted. Chapter 2 o

policy for the consideration o

planning efforts. This policy in

process engaging CTCs, local 

and others. This process will l

open space resources and op

conservation for future consi

of housing, consideration of t

(including farmworker housin

the Regional Housing Needs A

and resulting draft 2014‐2021 

Also, please see the job/hous

inter‐county commuters in th

Appendix (pgs. 59‐61). SCAG 

Employer‐Household Dynami

to conduct the following anal

SCAG TAZ geographies and co

between job/worker ratio an

define both distance and trav

investigate relationships betw

pay/worker earning match an

and mode usage; (3) confirm 

inter‐county commuters usin

from the item #1 in the meth

that there is no correlation be

commuting distance. SCAG an

analysis by summer and will s
61

ID Name Affiliation Comment Re

implications with academics, 

020‐04 Laura Massie California

Rural Legal

Assistance,Inc.

Like many rural areas in the SCAG region, the Eastern Coachella

Valley is severely underserved by transit. Bus service is utterly

nonexistent for large portions of the Eastern Coachella Valley

population. A few communities in the Eastern Coachella Valley

receive bus service, but its utility is significantly diminished by

long headways and inconvenient transfers. In order to access

the educational and work opportunities of the Western

Coachella Valley – where housing costs are unaffordable to the

low‐income farmworker households of the Eastern Coachella

Valley – rural residents must budget up to four hours per day

for bus commuting. This level of service creates tremendous

obstacles to the use of transit by rural residents, perpetuating a

reliance on personal vehicles and excluding residents who

cannot afford to use personal vehicles for lengthy commutes.

Bus service to such underserved communities should be

expanded and improved in the interest of equity, environmental

justice, and greenhouse gas reduction.

Comment noted. Considerati

areas, including farmworkers 

through the Regional Housing 

methodology process, and re

major strategy of the 2012 RT

of transit service and implem

areas underserved by transit, 

transit. This goal is challenged 

operating in a recent environ

state and local sales tax recei

recommendation of the RTP/

funding for transit services.

020‐05 Laura Massie California

Rural Legal

Assistance,Inc.

We specifically recommend that SCAG consider the following

strategies: ∙ Regularly convene planning staff and governmental

decision‐makers from jurisdictions containing farmland to focus

on meeting unmet housing and transportation needs of

agricultural workers; ensure that such convenings are informed

by input from agricultural workers and/or from community‐

based organizations familiar with the transportation and

planning needs of the agricultural workforce and other rural

residents

Comment noted. Considerati

areas, including farmworkers 

through the Regional Housing 

methodology process, and re

process involved regular mee

jurisdictions throughout the r

containing farmland.

020‐06 Laura Massie California

Rural Legal

Assistance,Inc.

∙ Provide technical assistance to member jurisdictions by

conducting feasibility analyses of creative transit strategies,

such as local circulators in rural communities, to address the

unmet transit needs of farmworker families and other rural

residents ∙ Encourage the implementation of farmworker,

student, and commuter vanpools in rural areas; provide

technical assistance on vanpools by maintaining a library of

resources on such topics as project development, financing,

outreach, and project administration ∙ Explore the feasibility of

vanpools or similar programs for non‐work‐related

transportation needs such as access to medical facilities, retail,

and other services ∙ Conduct outreach to governmental

decision‐makers and community groups regarding funding

Comment noted.
62

ID Name Affiliation Comment Re

opportunities for expansion and improvement of transit in rural

areas.

020‐07 Laura Massie California

Rural Legal

Assistance,Inc.

In the interest of mitigating the impacts of gentrification and

providing adequate services to agricultural workers and other

low‐income rural residents, we recommend that certain of the

benefits proposed for HQTAs be made more widely available.

We commend SCAG for its innovative proposals to incentivize

growth in high‐quality transit areas (HQTAs). However, as is

noted at various points throughout the draft RTP/SCS and the

draft Environmental Justice Supplemental Report, there are as‐

of‐yet unanswered concerns about the likelihood ofgentrification in HQTAs, as lower‐income households find

themselves priced out of increasingly desirable housing

markets. Thus, certain HQTA‐related incentives, such as transit

fare discounts, would likely provide greater benefits to higher‐

income households than to the lower‐income households who

need such fare relief. Furthermore, certain sectors of the SCAG

region’s population – such as agricultural workers – do not

realistically have the option of living in an HQTA; HQTA

incentives should not exclude such households, whose

contribution to the region’s economy and character are

recognized in SB 375’s prioritization of farmland resources. In

order to enhance the equity of the HQTA incentives proposed in

the draft RTP/SCS, we recommend that SCAG consider the

following augmentations of those incentives: ∙ Provide local

circulator services in non‐HQTAs that are unserved by existing

transit services, including rural agricultural communities ∙ 

Consider household income, and not solely HQTA residence

status, in structuring any transit fare discount(s).

Comment noted. SCAG has sh

gentrification in the region th

(EJ) Analysis. The trends obse

and 2005‐09 American Comm

transit oriented development

will continue to evaluate and 

the framework presented in t

economy is recovering.

020‐08 Laura Massie California

Rural Legal

Assistance,Inc.

In addition, we note that certain land use and transportation

policies could result in the development of more HQTAs than

are contemplated in the draft RTP/SCS. This is particularly true

in the inland counties of Riverside, San Bernardino, and

Imperial, where very low percentages of the population

currently have access to high‐quality transit but where slight

decreases in bus headways could bring existing bus routes

within the definition of high‐quality transit. Furthermore, we

note that some of the HQTAs designated in the draft RTP/SCS

appear to be along routes with extremely limited accessibility,

such as Interstate 10 serving the Western Coachella Valley.

Comment noted. HQTAs are d

have considered and incorpo

considered by local jurisdictio

become HQTAs.
63

ID Name Affiliation Comment Re

Although such short‐headway bus routes are likely to provide

high‐quality transit to people living at designated stops along

the route, it seems highly unlikely that all persons living within

the Interstate 10 corridor will realistically enjoy such access. We

recommend that the utility and accessibility of HQTAs be

extended via the following measures: ∙ Prioritization of the

extension of HQTA status to more communities by decreasing

bus headways, particularly in the inland counties of Riverside,

San Bernardino, and Imperial ∙ Close collaboration with

community‐based groups and with county‐level planning staffand governmental decision‐makers to increase the feasibility of

developing affordable housing in rural areas at a density of

twenty dwelling units per acre (for example, through modifying

local zoning ordinances to allow densities of twenty units per

acre in mobilehome parks located on land zoned for agricultural

use), such that these areas could be eligible for HQTA

incentives ∙ Adopt a more flexible density standard for HQTAs in

agricultural areas in order to make it feasible for mobilehome

parks, which constitute the vast majority of affordable housing

in the Eastern Coachella Valley and frequently occur in dense

clusters along major thoroughfares, to qualify for incentives

such as local circulators and transit fare discounts ∙ Ensuring the

utility and transparency of the HQTA designation by defining

HQTAs based on residents’ access to transit stops, rather than

solely by proximity to a high‐quality transit route.

020‐09 Laura Massie California

Rural Legal

Assistance,Inc.

We recommend that SCAG take a leadership role in developing

non‐regressive funding mechanisms for transportation

development. We applaud SCAG for taking on the difficult

question of transportation funding and the ongoing wisdom of

relying on existing federal and state gas tax structures, including

excise taxes. However, some of the funding mechanisms on

which the draft RTP/SCS relies are likely to have regressive

and/or inequitable impacts, causing low‐income households

and communities to bear a disproportionate share of the cost of

the region’s transportation system. Point‐of‐sale revenue

sources – such as sales taxes, gasoline taxes, and farebox

recoveries – indisputably have a regressive impact on

households least able to afford them. The projected Vehicle

Miles Traveled (VMT) tax seems likely to further the goals of SB

375 by creating incentives for people to live in transit‐rich areas

Comment noted. One of the k

foundation for identifying reg

are reasonably available in de

strategies is to establish a use

the true cost of transportatio

transportation funds, and ens

costs and benefits. We recog

before the mileage‐based use

That is why we did not assum

to 2025. The inclusion of the 

recommendations from two n

by Congress through SAFETEA

transportation revenue sourc

throughout the country, we w

for the mileage‐based user fe
64

ID Name Affiliation Comment Re

close to jobs, services, and retail opportunities. However, given

the very real risk of gentrification in such neighborhoods, the

VMT is likely to have a disproportionate impact on lower‐

income households who cannot afford the higher housing costs

of desirable urban neighborhoods. Furthermore, as discussed

above, SB 375 encourages MPOs to prioritize the preservation

of farmland resources. A VMT could undermine this goal by

creating an unaffordable burden on farmworker families, who

face lengthy commutes not only to the fields and packing

houses in which they work but also to medical care, grocery and

other retail outlets, schools, human services, and other

amenities. Residents of agricultural areas have little access to

any form of transportation other than personal vehicles, and

the draft RTP/SCS does not propose expanding transit to reduce

this burden. Farmworker households should not be penalized

for failing to use transit when transit has not been made

available to them. We recommend that SCAG apply its

considerable technical expertise to devising and advocating for

more equitable mechanisms of transportation funding at thelocal, state, and federal levels. One possibility might be a VMT

tax structured to allow tax credits for lower‐income households

and/or for other households that are unable to access housing

in transit‐rich neighborhoods, such as farmworker households.

Because a VMT tax cannot be assessed at the point of sale, it is

likely to be far more flexible than a traditional gas tax and can

therefore be made more responsive to equity concerns.

Appendix. Included in the imp

evaluate and address any disp

020‐10 Laura Massie California

Rural Legal

Assistance,Inc.

We recommend that data on the environmental justice impacts

of the draft RTP/SCS be disaggregated in order to facilitate

analysis of the impacts on disadvantaged communities within

the SCAG region. Significant portions of the draft RTP/SCS,

particularly the draft Environmental Justice Supplemental

Report (draft EJ Report), analyze data at the regional level. For

example, the draft EJ Report summarizes the following data

based on its region‐wide impacts on specific income quintiles

and racial or ethnic groups: distribution of savings in travel time

and distance; accessibility to employment and services;

accessibility to parks; exposure to emissions and consequent

health risks; and exposure to noise impacts. However, the maps

presented in Exhibits 1‐14 of the draft EJ Report demonstrate

that environmental justice (EJ) populations are not distributed

Comment noted. As noted ab

Environmental Justice Appen

on various demographic grou

with California Rural Legal As

can inform local analyses.

It should be noted from the E

some locations are identified 

analysis did not account for p

technology particularly for tru

in the plan are exclusively for 

vehicles. If these emission im

for we believe the analysis wo

with the plan. As such, the em

shown in the EJ Appendix is a
65

ID Name Affiliation Comment Re

evenly throughout the region; rather, there are pockets where

certain EJ variables are extremely concentrated, with

disproportionately high percentages of poverty, minority

population, foreign‐born population, non‐English‐speakers, and

populations without a high school diploma concentrated in

communities of extreme disenfranchisement. Such communities

include not only urban pockets in and near Los Angeles, but also

the agricultural communities of the Eastern Coachella Valley

and much of Imperial County. An analysis that examines, for

example, emissions exposure encountered by the entire Latino

population of the SCAG region fails to address the ways in which

burdens of the draft RTP/SCS might or might not be

disproportionately visited on localities that struggle under the

weight of multiple categories of disadvantage. In particular, the

Eastern Coachella Valley – the population of which is over 97%

Latino – appears to realize few benefits under the draft

RTP/SCS, giving rise to an appearance of denial of service in this

area and perpetuation of historic exclusion. Based on the level

of analysis made available by SCAG in the draft EJ Report, it is

impossible to determine whether the Eastern Coachella Valley is

expected to bear a disproportionate share of the burdens of the

draft RTP/SCS, such as increased exposure to emissions and/or

noise impacts.

demonstrating worst‐case sce

event that hot spots remain a

technology improvements, th

hot spots would overlay with 

available data on emissions n

and population is at a precise 

show where they would inter

concerns and evolving inform

encourages project sponsors 

health risks in project design 

mitigation identified in the pr

in disseminating information 

to reduce risk at the project l

020‐11 Laura Massie California

Rural Legal

Assistance,Inc.

Furthermore, we note that the Environmental Justice Mitigation

Toolbox on pp. 147‐48 of the draft EJ Report does little to

address the specific risks confronted by local EJ communities.

While the Toolbox provides a number of suggestions to reduce

RTP/SCS‐related impacts throughout the SCAG region, its

recommendations do not acknowledge the heightened level of

exposure to environmental risks that is all‐too‐frequently visited

upon communities of concentrated disadvantage. In order to

minimize the chances that localities of extreme

disenfranchisement will disproportionately bear the burdens of

– and be deprived of the benefits of – the draft RTP/SCS, we

recommend that SCAG take the following steps: ∙ Use the

geographic data in Exhibits 1‐14 of the draft EJ Report to

identify local EJ communities that are subject to two or more of

the categories of disadvantage highlighted in the Exhibits ∙ 

Conduct a Performance Area Analysis (similar to the 11‐factor

Performance Area Analysis set forth in pp. 34‐146 of the draft EJ

Comment noted. The Environ

provides a voluntary set of m

considered by project sponso

will include mitigation strateg

forward to continuing to wor

the California Rural Legal Ass

can be included and analyzed 

environmental review proces
66

ID Name Affiliation Comment Re

Report) with respect to each of the local EJ communities thus

identified ∙ Monitor implementation of the RTP/SCS to quantify

actual impacts on local EJ communities.

020‐12 Laura Massie California

Rural Legal

Assistance,Inc.

We recommend that SCAG utilize a more broadly accepted

measure of economic disadvantage in conducting its

environmental justice analysis. Throughout the Performance

Areas Analysis of the draft EJ Report, SCAG relies on income

quintile as a measure of economic disadvantage. However, as

indicated on the income quintile table on p. 6 of the draft EJ

Report, this measurement is not defined in a way that accounts

for differences in household size; a one‐person household with

an income of $45,000/year falls into the same quintile as a

seven‐person household with an income of $45,000/year,

although these two households face vastly different financial

prospects. An analysis conducted on this basis will not yield an

accurate measure of economic need. We recommend that SCAG

instead use the measures of Extremely Low‐Income, Very Low‐

Income, Low‐Income, Moderate Income, and Above Moderate

Income established annually by the California Department of

Housing and Community Development based on data provided

by the United States Department of Housing and Urban

Development. These figures are a broadly accepted measure of

a household’s relative economic need and are already easily

available to SCAG due to its obligations related to the

calculation of the Regional Housing Need Allocation (RHNA). An

EJ analysis based on these figures will yield a far more accurate

portrait of the impacts of the draft RTP/SCS on households of

various levels of economic need or privilege.

Comment noted. We agree w

practices by the US Departme

Development (HUD), the Calif

Community Development (HC

poverty or income thresholds 

various social, housing, and w

Census Bureau does not prov

income distribution by house

developed a "Population SyntPUMS data to generate house

household size for each TAZ, 

only available at levels associ

household income distributio

household income distributio

correlated to the income cate

Housing Needs Assessment (R

household income without re

020‐13 Laura Massie California

Rural Legal

Assistance,Inc.

We recommend that SCAG provide more detailed analysis

regarding the expected distribution of air quality impacts of the

draft RTP/SCS. Although we commend SCAG for developing a

draft RTP/SCS that will improve overall air quality in the region,

we are very concerned to learn that 23‐29% of SCAG‐region

residents are expected to experience worse air quality. The

draft RTP/SCS and Supplemental Reports do not clarify which

portions of the region are expected to realize the greatest air

quality benefits and which will suffer the expected declines in

air quality. We recommend that SCAG provide a detailed

geographic analysis of the draft RTP/SCS’s projected air quality

impacts and include this analysis in the EJ Performance Areas

Comment noted. Data and an

Environmental Justice Appen

improvements in vehicle tech

corridors. These corridors in 

and/or near‐zero emission ve

Environmental Impact Report 

includes mitigation measures 

associated with health risk w

traffic volume roadways to le

included in the Appendix also 

improvements through the im

measures. As such, emissions 
67

ID Name Affiliation Comment Re

Analysis, subject to the revisions of the Performance Areas

Analysis recommended above. We further wish to call to SCAG’s

attention that rural areas of the Eastern Coachella Valley are

currently not subject to adequate air quality monitoring. The air

quality monitors maintained by the South Coast Air Quality

Management District (SCAQMD) for the Coachella Valley are in

urbanized areas of the Valley and do not reflect the air quality

of the rural and agricultural areas of the Eastern Coachella

Valley, which suffer from high levels of blowing dust (including

from traffic over unpaved roads), pesticide sprays, smoke from

agricultural burning (often in close proximity to residential

areas), and particulates from the drying Salton Sea. We

recommend that SCAG aggressively pursue the spirit of

transportation conformity by advocating for expansion of air

quality monitoring to the Eastern Coachella Valley and to other

areas that are subject to unique air quality stressors not

detected by SCAQMD’s air quality monitors as currently

distributed.

this Appendix is abundantly c

worst‐case scenario outcome

improvements had been acco

would show little or no areas 

spots”) associated with the P

available data on emissions a

households and population is 

with emissions and EJ popula

potential impacts. Neverthel

evolving information on healt

project sponsors to be cogniz

project design and delivery. C

identified and to be impleme

PEIR, SCAG will assist in disse

identifying effective strategie

level.

021‐01 RJ Cervantes California

TruckingAssociation

The California Trucking Association is concerned about some of

the assumptions made for the "Reasonably Available Revenues"

projections. SCAG has identified $219.5 billion in additional

revenues that according to the RTP are "... likely to materialize

within the RTP time frame" (SCAG 2012 RTP, Page 7). A

substantial portion of the $219.5 billion that has been identified

in the $110.3 billion that would be generated from a "Mileage‐

Based User Fee" set at $0.05 per mile and commencing in 2025

(2012 SCAG RTP Transportation Finance Appendix, page 15, 16).

Although SCAG notes that they've projected the fee to

commence in 2025, substantial amount of study is needed on

the feasibility of implementing such a system on commercial

motor carriers. To date, there has been little to no study done

on how a system would be administered, or what the financial

burden would be fore motor carriers and ultimately consumers.

Comment noted. We agree th

before the mileage‐based use

which is basis for assumption 

2025. The projected revenue 

and adjustments to state and 

combined with the core reve

sources generate less revenu

increase in state and federal t

five percent annually. Rather 

of the historical growth rate, 

requirements, we detailed sp

state and federal transportat

with recommendations from 

established by Congress throustudies have been conducted 

based user fee options. Neve

work would be necessary bef

efforts underway throughout 

implementation plan for the 

Transportation Finance Appe

implementation plan will be s

disproportionate impacts to u
68

ID Name Affiliation Comment Re

021‐02 RJ Cervantes California

TruckingAssociation

Although SCAG has also indicated that the revenues projected

from a mileage based user fee will be generated on a national

level, the California Trucking Association will note that it

strongly opposes the implementation of a mileage based user

fee on local or regional levels (2012 CTA Federal Transportation

Policy Guideline).

Comment noted. The RTP doe

of a mileage‐based user fee o

021‐03 RJ Cervantes California

TruckingAssociation

SCAG has also $4.2 billion in projected revenue generation from

a "Free Fee/National Freight Program" (2012 SCAG RTP

Transportation Finance Appendix, Page 7). The California

Trucking Association has supported the inclusion of the National

Freight Program in the Senate Environment & Public Works

Committee Map‐21 legislation. However, we have not endorsed

specific strategies to fund any expenditures made through the

program other than the existing Highway Trust Fund sources

(2012 CTA Federal Transportation Policy Guideline).

Comment noted. The strategy 

under a national freight prog

Congress.

021‐04 RJ Cervantes California

TruckingAssociation

The California Trucking Association also strongly opposes local,

regional or statewide freight fee proposals that would

compromise the competitiveness of California's shipping,

warehousing and commercial trucking industry. Such a system

must be explored, developed, and implemented on a national

level only.

Comment noted. The RTP doe

of local, regional, or statewid

upon the SCAG region were c

development of all funding p

021‐05 RJ Cervantes California

TruckingAssociation

SCAG has also projected $22.3 billion in revenue generation for

the region through the tolling facilities associated with the I‐710

Freight Corridor, the East/West Freight Corridor, the High

Desert Corridor, and the SR‐710 tunnel (2012 SCAG RTP

Transportation Finance Appendix, Page 34, 35). In general, the

California Trucking Association opposes tolling as a means for

revenue generation due to the high overhead cost associated

with running tolling facilities and programs, the potential for

increased congestion around tolling facilities, and the

disproportionate financial burden that is placed on the trucking

industry.

Comment noted. SCAG recog

Association’s concerns about 

revenues generated from toll 

construction (including payin

construction), as well as oper

same facilities and are not eli

or program.

021‐06 RJ Cervantes California

TruckingAssociation

In addition, the California Trucking Association is very

concerned about the toll revenue estimates that have been

associated with the East‐West Freight Corridor and the I‐710

Freight Corridor. If these proejcts are planned as zero‐emission

corridors as a part of the Goods Movement Environmental

Strategy and Action Plan as outlined by the RTP, the near term

revenues generated from these tolling facilities will not meet

the estimated projections that have been provided due to an

Comment noted. The toll reve

includes toll revenue bond pr

importance of appropriately s

accommodate phased penetr

available. As such, SCAG antic

with stakeholders, including t

goods movement initiatives.
69

ID Name Affiliation Comment Re

overestimate of zero emission technology penetration rates.

021‐07 RJ Cervantes California

TruckingAssociation

In general, the California Trucking Association's analysis of the

Project List Appendix has been positive. We are encouraged

that SCAG continues to be concerned about the degradation of

our roadway system, and is planning to invest significant

amounts of capital in maintaining our current roadway

infrastructure. We firmly believe that such efforts will improve

goods movement efficiency, reduce congestion, improve

regional economic productivity, and reduce pollution.

Comment noted.

021‐08 RJ Cervantes California

TruckingAssociation

SCAG includes $3,771,002,000 for 'goods movement research

and development' as a part of the resource constrained plan in

measure RRC0703 (2012 RTP Project List Appendix, Page 422).

We believe that this allocation is not mentioned in the Goods

Movement appendix or in the RTP. To avoid confusion or

conflict, SCAG needs to clearly identify where these funds would

come from, and specifically, what they would be used for. What

technologies and sectors would 'goods movement research and

development' cover? Where could we find the description of

RRC0703?

Comment noted. SCAG has p

Goods Movement Appendix a

021‐09 RJ Cervantes California

TruckingAssociation

Also, identified in the list is a $5 billion allocation for a "Goods

Movement Bottleneck Relief Strategy" (2012 SCAG RTP Project

List Appendix, Page 422). The California Trucking Association is

supportive of identifying and improving bottleneck choke points

that restrict the ability to move goods efficiently by trucks.

Moving forward, we urge SCAG to include industry stakeholders

in any discussions so that input can be given on the locations

which are restrictive to motor carriers.

Comment noted. As part of it

Movement Plan and Impleme

worked with regional partner

analysis aimed at identifying 

and potential solutions/proje

release of the 2012 RTP and t

Movement Plan and Impleme

continue to engage appropria

regional truck bottlenecks, in

such as the California Truckin

021‐10 RJ Cervantes California

TruckingAssociation

The California Trucking Association has not taken a position on

whether or not to endorse the East‐West Corridor. We hope to

continue having discussions with SCAG in regards to the

project's costs, access abilities, and design concepts. However,

we urge SCAG to immediately inform any and all property

owners along the project alternative alignments about the

potential for future eminent domain issues. SCAG should

account for funds that will be needed to fairly compensate

property owners that could potentially be affected.

Comment noted. Inclusion of 

the 2012 RTP allows for furth

project through an Environme

costs, accessibility concerns, 

would be identified through t

discussion of project mitigatio

through upcoming processes

preliminary analysis did consi

potential right‐of‐way impact

affected communities.

021‐11 RJ Cervantes California The members of the California Trucking Association are Comment noted. SCAG will co
70

ID Name Affiliation Comment Re

TruckingAssociation

dedicated to working with policy makers in order to enhance

the quality of life of all Californians through environmental

protection measures that are based on sound science and that

are balanced with the realities of the economic market place. In

the past decade, the trucking industry has gone through

transformative changes due to regulatory mandates and

voluntary competitive measures in order to get cleaner trucks

on the road. SCAG's Goods Movement Environmental Strategy

and Action Plan are of great interest and concern to our

members that have made substantial investments in new

technologies at dramatic costs to their companies.

industry, including the Califor

identify appropriate and prag

emissions concerns.

021‐12 RJ Cervantes California

TruckingAssociation

SCAG should acknowledge that participation of goods

movement stakeholders in any of the strategies identified by

SCAG in the Goods Movement appendix would be a voluntary

process and not mandatory. Mandating specific technologies

undermines the investments our members have made in

response to the ARB Truck & Bus Rule. The California Trucking

Association would strongly oppose any and all efforts to impose

a new timeline for truck turnover that would differentiate from

the ARB regulations.

Comment noted. Strategies id

Appendix are not intended to 

recognizes and acknowledges 

Resources Board (CARB) serve

continue to work with CARB a

including the California Truck

appropriate and pragmatic so

concerns.

021‐13 RJ Cervantes California

TruckingAssociation

SCAG provides a specific timeframe for the study and

demonstration of various zero or near‐zero emission

technologies (2012 SCAG RTP Goods Movement Appendix, Page

34). The information is presented in a way that might be

applicable for all of the technology options and all flets. In fact,

there is no significant variation in the different technologies'

stages of development. Not all technologies have been created

equal due to implementation concerns and market readiness.

SCAG should account for this reality.

Comment noted. SCAG ackno

are in differing stages of deve

written to accommodate diffe

instance, during the 20 year p

be deployed as they meet the 

established by regional stake

Goods Movement Appendix.

021‐14 RJ Cervantes California

TruckingAssociation

In order to introduce zero or near‐zero emission technologies in

private fleets, SCAG would need to work with regional company

owners by providing significant amounts of capital to meet the

goals laid out in the plan. The upfront incremental costs for

these vehicles vary from $20,000 ‐ $100,000+ over comparable

diesel powertrains. These figures do not encompass the

significant infrastructure investments and loss of operational

flexibility associated with zero and near‐zero emission

technologies. Which activities have funds currently available

and have been accounted for in the RTP's fiscally constrained

plan? SCAG needs to help identify where the funding will come

Comment noted. The 2012 RT

includes efforts to gain a bett

differentials for commercial d

will be made in the RTP conce

development and demonstra
71

ID Name Affiliation Comment Re

from in order to meet these new goals.

021‐15 RJ Cervantes California

TruckingAssociation

If there is funding currently available, SCAG needs to state that

they plan to carry out the timeline presented for the

implementation of a zero and near‐zero emission freight

system. If not, it should be pointed out that such a project could

not be implemented until or unless funding becomes available.

Comment noted. Further clar

concerning funding for resear

demonstration initiatives.

021‐16 RJ Cervantes California

TruckingAssociation

Additionally, SCAG should note that any full scale

demonstration and/or commercial deployment would need the

full support of the involved stakeholders to move forward. SCAG

should also include a provision that the business stakeholders

will be involved in the design of the parameters for a full‐scale

demonstration.

Comment noted. SCAG concu

should include the input of al

the text to strengthen this po

021‐17 RJ Cervantes California

TruckingAssociation

Furthermore, the final stages in the timeline are unrealistic and

should be lengthened to give adequate time for zero‐emission

technologies to mature and undergo sufficient testing. An

inadequate or insufficient demonstration program could result

in premature adoption and could lead to serious disruptions to

the goods movement system and thus unintended

consequences from significant job loss and economic impacts to

the region.

Comment noted. Given discu

current understanding of tech

timeframes are reasonable. If 

SCAG will adjust the timefram

021‐18 RJ Cervantes California

TruckingAssociation

As trucking companies work together with regulatory agencies

to further reduce emissions in the SCAG region, any technology

introduced must not compromise the safety, velocity, cargo

throughput, economic competitiveness, or reliability of the

vehicle.

Comment noted. SCAG concu

must meet these objectives. L

established in Phase 2 of the 

guidance.

021‐19 RJ Cervantes California

TruckingAssociation

SCAG should clearly state in the RTP that to date, stakeholders

have not reached consensus on technologies, timing, or

emissions impacts of possible the various options SCAG

examined in the Goods Movement Environmental Strategy and

Action Plan.

Comment noted. The RTP out

and better understand these 

021‐20 RJ Cervantes California

TruckingAssociation

It would be unwise to commit funding to large scale

infrastructure projects to support zero emission transportation

technologies until these technologies mature. Certain early

approaches may quickly become obsolete as heavy duty partial

hybrid electric and battery electric vehicles reach

commercialization.

Comment noted. The action p

technologies to be explored a

be selected.

021‐21 RJ Cervantes California

TruckingAssociation

SCAG should not oversell its timeline for zero emission

technology penetration rates nor can it predict how this market,

just barely in its infancy, will perform in the coming years.

Comment noted. Given discu

current understanding of tech

timeframes are reasonable. If 
72

ID Name Affiliation Comment Re

Arbitrary timelines are not a substitute for the kind of analysis

that produces good public policy and efficient government

expenditure.

SCAG will adjust the timefram

021‐22 RJ Cervantes California

TruckingAssociation

I‐710/East‐West Freight Corridors: We agree with SCAG's

observation that the zero and near‐zero emission heavy duty

vehicle market has yet to develop a fully market ready

technology as of the authroing of the 2012 RTP.

Comment noted.

021‐23 RJ Cervantes California

TruckingAssociation

I‐710/East‐West Freight Corridors: SCAG should approach the

role of the Freight Corridors in nurturing this emerging market

realistically. While exemption from tolls or other privileges

granted zero and near‐zero emission heavy duty vehicles will

play a role in incentivizing accelerated adoption, these

technologies will face significant implementation challenges out

of SCAG's control.

Comment noted. The East‐W

potential to incentivize the ad

technologies. Continuing rese

stakeholders is necessary bef

implementation policies.

021‐24 RJ Cervantes California

TruckingAssociation

I‐710/East‐West Freight Corridors: Facility restrictions that

prevent National Network terminal access for reasons other

than safety are currently prohibited by federal law.

Comment noted. Specific des

determined as part of an Env

022‐01 Ed Amador Canyon Land

ConservationFund

Under the Endangered Species Act, the United States Fish and

Wildlife Service have defined critical habitat as areas that

support endangered or threatened species that are essential to

the species' conservation. The description in the Conservation

Planning Policy section (page 76 of the Draft RTP/SCS) states

"large‐scale acquisition and management of critical habitat to

mitigate impacts related to future transportation projects". We

believe there are other habitat areas in the SCAG region worth

considering for acquisition and management and therefore

SCAG should not limit the mitigation opportunities to only

critical habitat. We suggest expanding the language to

incorporate all "important habitat lands." Thank you for

reviewing our comments and we look forward to working with

SCAG on the implementation of this policy.

Comment noted. The propose

pursue a strategic planning p

resources. The intent is to inc

based on input from a wide v

has been clarified.

023‐01 Carlene

Matchniff

CentennialCalifornia

The application for the proposed sustainable new town of

Centennial, located at the intersection of I‐5 and SR‐138 in

North Los Angeles Conty, was deemed complete by the County

of Los Angeles in 2008. The proposed $9.5 Billion direct

investment in this region over 20 years will provide 23,000

homes, approximately 27,500 construction jobs and over 30,000

permanent jobs for Los Angeles County. By providing a

pedestrian oriented, sustainable community design with a

balance of jobs and housing and the necessary density to

Comment noted.
73

ID Name Affiliation Comment Re

support public and community services for the entire region,

Centennial will complement the infill, TOD developments being

proposed in the urban cores, achieving long‐term emissionsreductions as mandated by SB375.

023‐02 Carlene

Matchniff

CentennialCalifornia

SCAG RTP/SCS and PEIR corrections – TAZs 20280.100 and

20281.100, County of Los Angeles: RTP/SCS exhibit 4.13, Land

Use Pattern Map SCAG Region 2035, correct growth pattern

shading to reflect Centennial.

Comment noted. The 2012‐20

address comment, as approp

023‐03 Carlene

Matchniff

CentennialCalifornia

SCAG RTP/SCS and PEIR corrections – TAZs 20280.100 and

20281.100, County of Los Angeles: RTP/SCS Exhibit 4.15 Land

Use Pattern Map SCAG Region 2035, correct growth pattern

shading to reflect Centennial.

Comment noted. SCAG will us

comment in the final RTP/SCS

023‐04 Carlene

Matchniff

CentennialCalifornia

SCAG RTP/SCS and PEIR corrections – TAZs 20280.100 and

20281.100, County of Los Angeles: PEIR Exhibit 3.8‐1, Regional

Distribution of Important Farmlands and Grazing Lands; need to

clarify the difference in similar colors on the legend. Centennial

is Grazing Land and should be reflected as such. Recommend

the map distinguish the colors on the legend for grazing lands

and non‐irrigated farmlands as they are difficult to distinguish

as currently presented.

Comment noted. Exhibit 4.17 

023‐05 Carlene

Matchniff

CentennialCalifornia

SCAG RTP/SCS and PEIR corrections – TAZs 20280.100 and

20281.100, County of Los Angeles: PEIR exhibit 3.8‐9, Household

Density by Census Tract, correct to correspond to the household

TAZs for the area and change exhibit to the 901‐1,500 category.

Comment noted. The title wa

tract" instead of TAZ. We hav

indicates it was categorized c

category as suggested.

023‐06 Carlene

Matchniff

CentennialCalifornia

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

024‐01 Deborah Diep Center for

DemographicResearch

1. Incorporate the Orange County Projections‐2010 Modified

Growth Projections, as adopted by the OCCOG Board of

Directors, into all documents, tables, maps, narrative, modeling

runs, and PEIR Alternatives (including Alternate C/3/Envision 2)

referencing the Orange County growth forecasts consistent with

the subregional delegation MOU between OCCOG, OCTA and

SCAG. On January 26, 2012, the update to the OCP‐2010

dataset, known as OCP‐2010 Modified, was officially approved

by the OCCOG Board of Directors and is a data amendment to

the Orange County Sustainable Communities Strategy. The

dataset includes the 2010 Census population and housing data,

along with the 2010 EDD Benchmark data, consistent with

SCAG’s updated growth forecast dataset. The dataset was

Comment noted. SCAG has in

Modified dataset into the SCA

for the 2012 RTP/SCS and upd

tables, maps, narrative, mode

(including Alternate C referen

forecasts).
74

ID Name Affiliation Comment Re

provided to SCAG staff in December 2011 and this is the formal

notice of the update which should be incorporated into the

2012 RTP/SCS, PEIR, and related documents.

024‐02 Deborah Diep Center for

DemographicResearch

2. SCAG's adoption of the growth forecast numbers should be at

the county level, consistent with past RTPs, and not at a smaller

level of geography such as city, census tract, or traffic analysis

level. The 2012 growth projections identify population, housing

and employment data for the six‐county SCAG region, from

2008 (Existing) to 2020 and 2035. These growth projections

represent the best available information from local jurisdictions,

the business community and landowners. However, as time

passes, what is feasible for any given project can change. The

triggers for change to adopted growth projections can range

from factors such as market conditions, new information or

data, infrastructure availability, changes in funding availability

(such as the dissolution of redevelopment agencies statewide),

and changes to jurisdictional boundaries resulting from future

annexations and incorporations of previously‐designated

unincorporated territory. SCAG should continue to adopt the

2012 growth projections at a countywide level, consistent with

past approvals of Regional Transportation plan growth

forecasts. A county level of geography accommodates internal

adjustments to changing conditions as described above, without

compromising the integrity of the overall growth projections.

However, approving the growth projections at any lower level

of geography, such as at the city level, would be challenged with

continual revisions and shifts to the total number of housing,

population and employment within a city, among cities, and

between cities and counties as a result of the factors described

above. Adoption of the data at a level lower than the county

would limit jurisdictional control and create inflexibility in a

regional planning document. In addition, the level of geography

in which RTP/SCS growth forecast is adopted should not be

determined by other processes. For example, the RHNAallocations must be consistent with the RTP/SCS; state law does

not require that they be identical. The RTP/SCS can be adopted

at the county level and the RHNA process may proceed

independently until it is completed after the appeals, trades,

and transfers are completed. The RHNA allocations that were

derived from the growth forecast can still be determined to be

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use deallocation being adopted at th

that the SCS be based on a ju

distribution.
75

ID Name Affiliation Comment Re

consistent with the RTP/SCS, even if changes are made to the

city totals during the appeals, trades, and transfers process.

024‐03 Deborah Diep Center for

DemographicResearch

All chapter headings should include the Chapter number on

each page for ease of reference.

Comment noted. Chapter num

024‐04 Deborah Diep Center for

DemographicResearch

Page 1, left column: “The 2012 RTP/SCS includes a strong

commitment to reduce emissions from transportation sources

to comply with SB 375, both improve public health, and meet

the National Ambient Air Quality Standards as set forth by the

federal Clean Air Act. As

Comment noted.

024‐05 Deborah Diep Center for

DemographicResearch

Page 4, right column ‐ “This region needs a long‐term,

sustainable funding plan that ensures the region receives its fair

share of funding, supports an efficient and effective

transportation system that grows the economy, provides

mobility choices, and improves our quality of life.”

Comment noted. We agree th

receives its fair share of trans

024‐06 Deborah Diep Center for

DemographicResearch

page 7, table 2 and page 95, table 3.3 ‐ Is additional $0.15 gas

tax the sum total of both state and federal taxes or $0.15 each?

Comment noted. The additio

excise gas taxes.

024‐07 Deborah Diep Center for

DemographicResearch

Page 12, right column ‐ “It also demonstrates how we can

transition from things we know to be unsustainable over the

long term and beyond the term of this RTP—such as reliance on

fossil fuels—to new technologies for the future.”

Comment noted.

024‐08 Deborah Diep Center for

DemographicResearch

Page 30, right column; page 31, right column; page 73, right

column ‐ AB 32 is global warming solutions act. SB 375 was

determined to be stand‐alone legislation. RTP document is not

forum to address global climate change and references are

unnecessary, off topic, and distract from RTP goal and purpose.

“Global warming” and “global climate change” / “climate

change” are not interchangeable phrases. References should be

removed or, where appropriate, language should be changed to

“global warming”. “The RTP/SCS includes the following actions

to address energy uncertainty and reduce the region’s

contribution to global climate change:” “Adaptation Climate

change global warming mitigation means reducing or

sequestering greenhouse gases, whereas adaptation is

preparing for known impacts of climate change global warming.

Over the coming century, some climate change studies project

that Southern California will be expected to manage extremes

of precipitation and temperature, increased storm frequency

Comment noted. The 2010 Ca

Plan Guidelines include a reco

adaptation to climate change

Transportation Plan Guideline

Regional Transportation Syste
76

ID Name Affiliation Comment Re

and intensity, and sea‐level rise. These climate changes

will/would impact streamflow, flooding, water supply, sea level,

and soil water content. These impacts will/would affect

agriculture, stormwater, wastewater treatment, wildfire risk,

roads, forest health, and biodiversity. These impacts will/would

also have consequences for public health, economic livelihoods,

the financial sector, the insurance industry, individual comfort,

and recreation. In practice, these impacts will/would mean

coping with...” “Goods movement is also a major source of

greenhouse gas (GHG) emissions that contribute to global

climate change warming.”

024‐09 Deborah Diep Center for

DemographicResearch

Page 40, left column ‐ “Strategic investments, put forth by the

private sector, that would remove barriers associated with

telecommuting are expected...”

Comment noted. The 2012‐20

address comment, as approp

024‐10 Deborah Diep Center for

DemographicResearch

Page 42, table 2.2 ‐ 241 toll road completion year is 2030 Comment noted. Table 2.2 ha

completion year of 2030.

024‐11 Deborah Diep Center for

DemographicResearch

Page 50, left column ‐ “scrip” Comment noted. This term ha

024‐12 Deborah Diep Center for

DemographicResearch

Page 54, right column ‐ “Express/HO T Lane Network Despite

our concerted effort to reduce traffic congestion through years

of infrastructure investment, the region’s system demands

continue to exceed available capacity during peak periods.”

Comment noted. The referen

been revised to clarify that ca

periods.

024‐13 Deborah Diep Center for

DemographicResearch

Page 78, right column ‐ “Greenhouse Gases On road emissions

(from passenger vehicles and heavy duty trucks) constitute 93

percent of the transportation sector total. Emissions from

passenger vehicles, which are the subject of SB 375 and this

RTP/SCS, constitute ___% of the transportation sector’s

greenhouse gas emissions total.”

Comment noted. Emissions fr

the subject of SB 375 and this 

transportation sector’s green

source: California Air Resourc

Gas Inventory for 2000‐2008.

024‐14 Deborah Diep Center for

DemographicResearch

Page 80, left column; page 82, right column ‐ Statements are

made, such as the following, "the RTP has the ability to affect

the distribution of that growth" (in population in the region).

These statements could be interpreted to be contrary to SCAG's

obligation under the Memorandum of Understanding with

OCCOG to respect the strategies and local land use policies in

the OC SCS. Please clarify how it is in SCAG's ability to affect

local change when the OC SCS is consistent with acceptance of

local land use plans and planned population and employment

Comment noted. The referen

removed in the Final RTP/SCS
77

ID Name Affiliation Comment Re

distribution? Recommended text change: “Transportation

projects including new and expanded infrastructure are

necessary to improve travel time and can enhance quality of life

for those traveling throughout the region. However, these

projects also have the potential to induce attract more of the

regional population growth in certain areas of the region. This

means that although SCAG does not anticipate that the RTP

would affect the total growth in population in the region, the

RTP has the ability to affect the distribution of that growth.” “In

addition to induced population growth, transportation projects

in the RTP also have the potential to divide established

communities, primarily through acquisition of rights‐of‐way.”

Text indicates that the RTP and projects in the RTP/SCS as

“inducing” growth. It is noted that use of the term “induced

growth” has a negative connotation and implies growth above

and beyond what would occur naturally. However, it is stated in

the RTP that the population, housing, and employment growth

totals are fixed and only the distributions may change based on

the plan. This means there will not be “new” growth and that

the RTP and SCS may simply influence and shift the growth

anticipated for the region. This moving of growth is the result of

changes in distribution that are due to changes in land use or

densities. Because of this, it is requested that references to

“induced growth” be reworded to reflect the shifting of growth

in the region. Recommended text change: “Cumulative impacts

from the projected growth induced by the RTP include

increased impervious surfaces;...”

024‐15 Deborah Diep Center for

DemographicResearch

Page 95, Table 3.3 ‐ “Mileage‐based user fees would be

implemented to replace gas tax and augment—estimated at

about $0.05 (2011$) per mile and indexed to maintain

purchasing power starting 2025.” Suggested language is from

page 31 of Growth Forecast Appendix: Current gasoline tax,

estimated at about $0.05 (2011$) per mile will increase through

2025, then in 2026 it would be replaced with a mileage‐based

user fee indexed to maintain purchasing power

Comment noted. The Growth 

updated to accurately reflect 

proposal.

024‐16 Deborah Diep Center for

DemographicResearch

Page 105, right column ‐ “While the region was once known

worldwide as the “capital of sprawl,” the region today is

projecting growth on only a small fraction of the little raw land

available in the region left to accommodate additional growth.”

Comment noted. The 2012‐20

address comment, as approp

024‐17 Deborah Diep Center for Page 106, last paragraph ‐ Please revise the text in the last Comment noted. The 2012‐20
78

ID Name Affiliation Comment Re

DemographicResearch

paragraph on page 106 to state: “These subregional SCS

documents are incorporated into the regional SCS and

represent the SCS for each of these subregions.”

address comment, as approp

024‐18 Deborah Diep Center for

DemographicResearch

Page 110, right column ‐ “Municipal water and sewer systems,

for example, ensure clean water. At the same time, concrete

stormwater runoff channels harm water quality and sprawl eats

into open space as areas become more urbanized and the

percentage of impervious surface is increased, the hydrologic

regime is dramatically altered. Drainage conveyances that once

were natural and riparian are required to be engineered as

hardened flood control channels to provide adequate

protection of private property and public infrastructure from

the increased frequency, duration, peak flow, and overall

volume of stormwater runoff. With this armoring of once

natural channels, water quality benefits from biofiltration are

lost along with opportunities for infiltration and

evapotranspiration, which can lead to hydromodifcation

downstream in sections which are not yet engineered and

hardened. Many strategies...”

Comment noted. The Final Pr

Report for the RTP/SCS includ

impacts from stormwater run

024‐19 Deborah Diep Center for

DemographicResearch

Page 127, right column ‐ “Gentrification” Comment noted. This term ha

024‐20 Deborah Diep Center for

DemographicResearch

Page 128, left column ‐ “Thus, this adjustment allowed the land

use pattern to conform more closely to local expectations

general plans, while reducing the amount of vehicle miles

traveled.” Whose/What are “local expectations?”

Comment noted. The Final 20

change "local expectations" t

024‐21 Deborah Diep Center for

DemographicResearch

Page 149, right col ‐ Revise language to clarify that SCAG intends

policies, strategies, and measures are a menu of options. “The

following tables list specific implementation strategies that local

governments, SCAG, and other stakeholders may use or

consider while preparing specific projects which would help to

successfully implement the SCS.”

Comment noted. Clarifying la

2035 RTP/SCS, as appropriate

024‐22 Deborah Diep Center for

DemographicResearch

Page 153, right column ‐ “Evaluation and Revision SCAG will also

track its own progress in implementing its RTP/SCS strategies in

conjunction with the preparation and adoption of its Overall

Work Program and Annual Budget.” Clarify if “its progress” is

SCAG’s progress or the region’s progress.

Comment noted. This statem

implementing the RTP/SCS.

024‐23 Deborah Diep Center for

Demographic

Page 166, right column ‐ “Greenfield” Comment noted. This term ha
79

ID Name Affiliation Comment Re

Research

024‐24 Deborah Diep Center for

DemographicResearch

Page 193, right column ‐ RC adopted revised PPP in January

2012

Comment noted. The text has 

Regional Council adopted Pub

No. 3 in January 2012.

024‐25 Deborah Diep Center for

DemographicResearch

page 194, right column ‐ “In addition to these targeted outreach

efforts, all regular and special meetings of the RTP task forces,

the Transportation Committee (TC), the CEHD, the EEC, and the

SCAG Regional Council are publicly noticed and ...”

Comment noted. Text amend

committees that are publicly 

024‐26 Deborah Diep Center for

DemographicResearch

Page 203, right column ‐ "...including Los Angeles Ontario

Airport, the March Inland Port..."

Should LAX and Ontario airports be named separately?

Comment noted. Los Angeles 

Ontario Airport.

024‐27 Deborah Diep Center for

DemographicResearch

Page 205, Add "Active transportation" to glossary. Comment noted. This term ha

024‐28 Deborah Diep Center for

DemographicResearch

In December 2011, Orange County provided SCAG with the

revised growth forecast dataset, OCP‐2010 Modified, per the OC

SCS MOU (official OCCOG Board action 1/26/2012).

Please incorporate OCP‐2010 Modified into all reports, tables,

exhibits, alternatives, maps, and modeling runs for final RTP.

Comment noted. SCAG has in

Modified dataset into SCAG's 

the 2012 RTP/SCS updated al

narrative, modeling runs, and 

C referencing the Orange Cou

024‐29 Deborah Diep Center for

DemographicResearch

Housing Options and Mix:

Define Larger‐lot single family in text

Comment noted. The final SC

Subregional Sustainable Com

have been updated to add cla

comment, as appropriate.

024‐30 Deborah Diep Center for

DemographicResearch

Page 53, right column ‐ Alternatives A, B, C

Names of Alternatives differ than those listed in the PEIR on

pages ES‐3 and 1‐4.

Please be consistent with naming protocol for alternatives

between two/all documents.

Comment noted. The final SC

Subregional Sustainable Com

have been updated to add cla

comment, as appropriate.

024‐31 Deborah Diep Center for

DemographicResearch

Page 71, right column ‐ “Plan Alternative (B)

... The alternative maintains city‐level forecast control totals for

both households and jobs, however, within city boundaries

shifts are made to focus a much larger share of future growth in

a more compact way around HQTAs, [add]except in Gateway

and Orange County COG subregions per their SCS delegation

agreements[/add]. Future housing market demand is expected

to shift significantly to small lot single‐family, townhomes and

multifamily [delete]hosuing[/delete] housing.”

Comment noted. The final SC

Subregional Sustainable Com

have been updated to add cla

comment, as appropriate.

024‐32 Deborah Diep Center for

Demographic

Plan Alternative (B)

Define small lot single family in text

Comment noted. The final SC

Subregional Sustainable Com
80

ID Name Affiliation Comment Re

Research have been updated to add cla

comment, as appropriate.

024‐33 Deborah Diep Center for

DemographicResearch

Plan Alternative (C)

“As a result very suburban communities may experience no new

housing or employment growth, while some urban areas with

very good access to regional transit may experience significant

increases in housing or employment growth.”

Comment noted. The final SC

Subregional Sustainable Com

have been updated to add cla

comment, as appropriate.

024‐34 Deborah Diep Center for

DemographicResearch

“While each alternative is distinctive, a number of parameters

remained constant across each alternative: the regional

RTP/SCS forecast total for population, households and jobs;...”

“Detailed forecast: the detailed distribution of population,

households, and jobs across the region...”

Comment noted. The final SC

Subregional Sustainable Com

have been updated to add cla

comment, as appropriate.

024‐35 Deborah Diep Center for

DemographicResearch

What does it mean that TAZ boundaries include city

boundaries?

Comment noted. The Tier 2 T

Technical Appendix: SCS Docu

boundaries aligned to city bo

are split between multiple cit

024‐36 Deborah Diep Center for

DemographicResearch

Alternatives A & B:

“Controlled to TAZ‐based RTP/SCS Forecast for 2020; Controlled

to city‐level RTP/SCS Forecast for 2020‐2035, except in Gateway

and Orange County COG subregions per their SCS delegation

agreements.”Add statement to table notes: Gateway and Orange County COG

subregions’ local input data will not be changed per their SCS

delegation agreements.

Comment noted. The final SC

Subregional Sustainable Com

have been updated to add cla

comment, as appropriate.

024‐37 Deborah Diep Center for

DemographicResearch

Alternatives A & B:

Add statement: Gateway and Orange County COG subregions’

local input data will not be changed per their SCS delegation

agreements.

Comment noted. The SCS Bac

was updated as part of the fin

language and address comme

024‐38 Deborah Diep Center for

DemographicResearch

“Development TypesThe alternatives are built on, and provides data at, the level of

the TAZ, which includes housing units and employment.”

Please clarify if TAZ is Tier 1, Tier 2, or both.

Comment noted. The final SC

Subregional Sustainable Com

have been updated to add cla

comment, as appropriate.

024‐39 Deborah Diep Center for

DemographicResearch

“Subregional SCSs submitted by the Gateway Cities Council of

Governments (GCCOG) and the Orange County Council of

Governments (OCCOG) will be respected unchanged and

integrated into the alternatives (with possible revisions for

Alternative C only).”

Comment noted. The SCS Bac

was updated as part of the fin

language and address comme

024‐40 Deborah Diep Center for

Demographic

Alternative AAdd statement: Gateway and Orange County COG subregions’

Comment noted. The final SC

Subregional Sustainable Com
81

ID Name Affiliation Comment Re

Research local input data will not be changed per their SCS delegation

agreements.

have been updated to add cla

comment, as appropriate.

024‐41 Deborah Diep Center for

DemographicResearch

Alternative B

Add statement: Gateway and Orange County COG subregions’

local input data will not be changed per their SCS delegation

agreements.

Comment noted. The final SC

Subregional Sustainable Com

have been updated to add cla

comment, as appropriate.

024‐42 Deborah Diep Center for

DemographicResearch

Transit Zoning Code Santa Ana 2011

Is this a duplicate of the 2010 Santa Ana project?

Comment noted. The SCS Bac

was updated as part of the fin

language and address comme

025‐01 Susan Kline Citizens

Alliance for

PropertyRights

Please note that many of our members recently attended what

was one of many so called, "Visioning" sessions. This one was

geared to our local elected officials and held at the Camarillo

Public Library on January 19, 2012. Please note that very little

public notice was given for the session. We were only made

aware of it through a third party. At the beginning of this

session we were subjected to a film clip that was little more

than "touchy feely propaganda. Adorable young tykes extolled

the virtues of "walkable" communities and public

transportation. The presentation was halted half way through

due to questions from citizens who took umbrage to the plan

that is, in truth, a one size fits all blueprint. These citizens are

well aware that, "sustainable community strategies" is a

marketing term crafted to pull the proverbial wool over the

public's eyes. That it is, in fact, a move toward regional

governance which will further distance voters from those who

they have entrusted to safeguard their interests. Further we do

believe 84 elected officials, from various cities and counties, and

do what is in the best interest of their citizens when crafting

policies for the over 18,000,000 residents residing within SCAG's

boundaries.

Comment noted. As required 

notice of public workshops an

2035 RTP/SCS including publi

the region such as the Ventur

interested parties as possible 

provide input. As SCAG’s mai

Council, comprised of 84 elec

cities, counties and county tra

represent the interests within 

Regional Council meet month

discuss and provide input on 

land use, transportation and 

025‐02 Susan Kline Citizens

Alliance for

PropertyRights

We understand that more of these sessions are planned but

that Ventura County has already had its alloted two in January.

Yet, really, how much of the public were made aware of what

you are planning? How many know that SCAG, once tasked to

plan for future growth, has now morphed into a regional

government that will alter our lifestyles and erode our freedom.

How many of the taxpaying citizens of our country would agree

to having so much of their transportation dollars funneled into

transit and away from road expansion? How many would agree

to plans for denser, expand and stack, development in what are

Comment noted.
82

ID Name Affiliation Comment Re

suburban communities?

025‐03 Susan Kline Citizens

Alliance for

PropertyRights

Citizens Alliance for Property Rights (CAPR), Ventura County,

wishes to go on record opposing the implementation of your

proposed sustainable strategies. Your plans have already

damaged our communities, hampered our valuable agricultural

industry, and caused further waste of precious taxpayer funds.

Denser development makes sense for Santa Monica, the area

you represent, Ms. O'Connor. However, it makes no sense

whatsoever in communities like Thousand Oaks and Simi Valley.

In closing, be aware we are watching you, know what a sham

the Compass Blueprint is and how your efforts are shackling the

very people you have, as elected officials, been sworn to serve.

Comment noted.

026‐01 Debra Tash Citizens

Alliance for

PropertyRights,VenturaCounty

We know there is NO global warming. That SB 375 is a farce,

along with cap and trade and we do not want our tax dollars

used any longer for visioning sessions designed to lead us to

predetermined outcomes. Nor do we want our fuel taxes

diverted to transit projects that are little more than subsidized

ridership projects, subsidized with our money. Nor do I want to

be packed and stacked into an urban jungle. I worked hard and

long to move to a rural environment. We know what you're

doing to us. You are advised that there are a growing number of

us who will fight you on implementing this every step of the

way now.

Comment noted.

027‐01 Leland Dolley City of

Alhambra

All of us are grateful for the Los Angeles County voter mandate

known as Measure "R", now passed into law and being actively

implemented. It is safe to say that without "Measure R" most all

of our sorely needed transportation projects may no have seen

a shovel raised to move the first piece of dirt. "Measure R"

provided certain amounts of money for specific projects. The

710N Gap Closure Project was named in the law and was

allocated over 700 million dollars. We concur with SCAG and our

other regional and city partners that the 710N Gap Closure

Project is appropriately designated a "constrained project" in

the 2012 RTP Constrained Plan and, further, that the 710N Gap

Closure Project has met all the federal requirements for

inclusion in said Plan. Attempts to say otherwise will be

vigorously refuted by all parties.

Comment noted.

028‐01 Sheri Vander

Dussen

City ofAnaheim

Expanded High Occupancy Toll (HOT) Lanes System – Staff

concurs with the OCTA comments identifying a need for

additional information on the HOT Lane network included in the

Comment noted. All RTP proj

level evaluation, including en

studies, before implementati
83

ID Name Affiliation Comment Re

RTP. An expansion of toll facilities in the region that is not

consistent with the Long Range Transportation Plan (LRTP)

prepared by the OCTA has been included in the RTP. Specifically,

the RTP/SCS identifies a program to allow extra capacity in High

Occupancy Vehicle lanes (HOV lanes or carpool lanes) to be sold

to single‐occupant drivers, thus converting these facilities into

High Occupancy Toll (HOT) lanes. This change is shown along

the SR‐91 from the Orange/Los Angeles County border and

connecting with the existing SR‐91 toll facilities. Several miles of

this facility are within or are partially within the City of Anaheim

and are bounded by residential neighborhoods. Because the

facility is not currently funded through the OCTA LRTP and does

not have the capacity to support a toll system, more

information is necessary to evaluate the project’s feasibility.

Request: Please include text in the RTP stating that any

expansion of the HOT lanes is tentative and would require

additional study to determine right‐of‐way impacts, community

issues, and overall feasibility.

project descriptions resulting 

may be incorporated into fut

028‐02 Sheri Vander

Dussen

City ofAnaheim

California High‐Speed Rail Authority (CHSRA) Project – Staff

concurs with the OCTA comments supporting a phased delivery

approach, which includes early investment in the existing

LOSSAN and Metrolink infrastructure, and indicating it is more

prudent to begin implementation at the “bookends” of the

system. City staff also submitted a letter to the CHSRA regarding

the Draft 2012 Business Plan (see Attachment 1), indicating that

implementing this “bookend” approach in the most urbanized

regions of the State at the onset of the project is needed to

enhance the passenger experience, reduce travel times,

improve safety and provide critical connections to the existing

passenger rail systems in these regions. It would also maximize

the investment of State and Federal funds so that these critical

improvements will be implemented.

Comment noted. The RTP sup

LOSSAN and Metrolink netwo

028‐03 Sheri Vander

Dussen

City ofAnaheim

Sustainable Communities Strategy – Under SB 375 and only

within the SCAG region, subregional councils of government

were allowed to prepare subregional SCSs that SCAG is then

required to incorporate into the regional SCS. In Orange County,

OCCOG and OCTA developed a countywide SCS (OC SCS) to be

included as the County’s contribution to the SCAG regional SCS.

SCAG notes in the RTP/SCS that it has incorporated the OC SCS

in its entirety into the regional SCS as an appendix to the

Comment noted. The subregi

GCCOG and OCCOG are incor

RTP/SCS in their entirety, and 

by the SCAG Regional Council 

RTP/SCS.As such, SCAG antici

policies included in the region

the respective sub‐region afte

2012 RTP/SCS addresses the 
84

ID Name Affiliation Comment Re

document, but it is unclear what the standing of the OC SCS is.

The OC SCS contains a set of strategies agreed upon by local

governments, agencies and other stakeholders within Orange

County and should represent the SCS that is applicable to the

Orange County region. Request: Please revise the text in the last

paragraph on page 106 to state: “These subregional SCS

documents are incorporated into the regional SCS and

represent the SCS for each of these subregions.”

028‐04 Sheri Vander

Dussen

City ofAnaheim

References to the RTP inducing growth – Several sections of the

RTP/SCS state that it has the ability to affect the distribution of

growth as well as induce growth (see page 80 under Population

and Housing as an example). This is inconsistent with the

“bottoms‐up” approach SCAG undertook in the development of

the documents wherein SCAG staff stated that they would

accept and use growth forecast data provided by local

jurisdictions. The RTP/SCS is intended to incorporate the

planned land use pattern that is expected to accommodate the

projected future growth of this region as well as the planned

transportation system that supports that growth. Therefore,

growth is not induced, it is planned for. The document

inaccurately implies a lack of coordination between land use

and transportation entities. Request: Please amend text within

the RTP/SCS, including the language on page 80, to remove the

reference to the RTP and SCS inducing growth and replace it

with language that acknowledges that the document reflects a

land use pattern that accommodates the forecast growth for

the region.

Comment noted. The referen

removed in the Final RTP/SCS

028‐05 Sheri Vander

Dussen

City ofAnaheim

Growth Forecast and Mapping Requests: 22. Please update all

documents, tables, maps, narratives, modeling runs, and PEIR

Alternatives (including the alternate referenced in the

documents, including the PEIR, as C, 3, and Envision 2) that

reference the Orange County growth forecasts with the Orange

County Projections‐2010 Modified Growth Projections, as

adopted by the OCCOG Board of Directors and consistent with

the subregional delegation Memorandum of Understanding

between OCCOG, OCTA and SCAG. 23. Please ensure that all

maps included in the adopted RTP/SCS and PEIR accurately

reflect the City of Anaheim’s data, as submitted to SCAG

between 2008 and 2011, for 2008 existing land use, zoning,

general plan land uses, and the growth forecast. 24. To ensure

Comment noted. SCAG has in

Modified dataset into SCAG's 

the 2012 RTP/SCS, and updat

maps, narrative, modeling ru

Alternative C referencing the 

Based on statutory requireme

Section 65584.04(i), subparag

Housing Needs Assessment m

RTP/SCS land use developme

being adopted at the jurisdict

SCS be based on a jurisdiction
85

ID Name Affiliation Comment Re

flexibility and reduce potential conflicts with local control in

land use matters, it is requested that SCAG adopt the growth

forecast data set at the county level and not at a smaller

geography such as a subregion, city, census tract, traffic analysis

zone or other smaller geography.

028‐06 Sheri Vander

Dussen

City ofAnaheim

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

029‐01 Laura Pierce City of Brea Brea values the dialog we have historically enjoyed with SCAG

on regional issues. We have a solid track record and

commitment to providing land use and transportation policies

which are consistent with the existing and planned regional

transportation system. We appreciate that the draft RTP/SCS

encompasses three principals: Mobility, Economy, and

Sustainability, that collectively work to significantly improve

existing transportation and air quality challenges for the region.

The inclusion of active transportation goals and funding at the

regional level is one which Brea is extremely interested in for

our "Tracks at Brea" trail program to increase non‐motorized

transportation in our community. The plan also identifies the

future bus rapid transit connection planned near the Brea Mall

that will connect Breans to additional alternative transportation

modes. We further note that our General Plan has numerous

land use and transportation goals and policies already in place

that align us well with the proposed 2012 RTP/SCS

Comment noted.

029‐02 Laura Pierce City of Brea At what project threshold and how will SCAG review the

performance of Brea and other local jurisdictions for

consistency with the 2012 RTP/SCS through the life of the plan?

Comment noted. The TAZ‐lev

the purpose of modeling perf

local jurisdictions, maintain th

determine consistency of any 

029‐03 Laura Pierce City of Brea Can you explain further how SCAG envisions directing new

housing and employment growth to High Quality Transit Areas

in Brea and Orange County? Are there any consequences if

agencies find it inappropriate to put growth in these areas, but

are achieving the Plan's goals in other areas of our City?

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as

trends occurring in many tran

the SCS is intended to provide 

local governments may build 

generally includes the quantit

each city and county in the re

jurisdictions maintain local la

SCS documents submitted by 
86

ID Name Affiliation Comment Re

incorporated into the regiona

such, the policies included ar

implementation in the sub‐re

029‐04 Laura Pierce City of Brea Public health is a concern for our residents. Does SCAG see a

conflict in placing a majority of our future housing growth for

Brea adjacent to high traffic roadways (57 Freeway) and the

potential for public health impacts (e.g. air quality) associated

with such areas?

Comment noted. SCAG prepa

the emissions exposure in are

high volume roads. It should 

emissions near these facilities 

whole. In 2035 these areas st

the region as a whole. Howev

overall decrease, the rate of d

near freeways and high volum

RTP/SCS does result in an inc

locations, and as such health 

than if they were not in the b

project level analysis and mit

going health concerns. Howe

benefits for emissions exposu

areas near freeways.

029‐05 Laura Pierce City of Brea The City supports the RTP/SCS goals for including valuable open

space land preservation within its mitigation strategies as

discussed in the Transportation Investments chapter (page 78)

of the plan. This approach is consistent with the value placed on

open space within the City's General Plan and is a key

component of a balanced land use approach for the region.

Lands within and surrounding Brea have the potential to

provide for such mitigation approaches thus assisting with GHG

reductions for the region. We welcome discussions with SCAG

on this implementation as specific projects are submitted in the

future.

Comment noted. SCAG is wor

governments for SCS implem

funding for SCAG’s Local Sust

Program (e.g., Compass Bluep

Growth Council grants.

029‐06 Laura Pierce City of Brea The Plan includes a significant portion of "New Revenue Sources

and Innovative Financing Strategies" that are not currently in

place or available. While some of the proposed revenues are

within the control of SCAG or MPOs and County Transportation

Commissions, the majority of the revenues (in terms of dollars)

require either state or federal action to implement. What might

the implications be if these new revenue sources and innovative

financing strategies do not become available, for both SB

375/SCS compliance and /or air quality conformity?

Comment noted. The determ

with fiscal constraint, as part 

requirements are made at the 

amendment. We recognize th

with certainty and therefore 

which were vetted through S

Committee and Policy Comm

the RTP. As we gain more ins

we will update the financial p

amendments and/or subsequ

At a minimum, an RTP is prep
87

ID Name Affiliation Comment Re

years.

029‐07 Laura Pierce City of Brea On page 149, it is stated that "The following tables list specific

implementation strategies that local government, SCAG and

other stakeholders can and should undertake in order to

successfully implement the SCS." Please indicate whether SCAG

has conducted any feasibility analyses to determine if all of

these strategies are feasible and what the implications are if not

all are implemented. Also, please describe what Brea's

obligations are anticipated to be as a result of adopting these

strategies as a list to be accomplished rather than a menu of

options. It is requested that the language in the sentence be

clear that it is permissive and at a minimum, change the text

"can and should" to "may".

Comment noted. Clarifying la

2035 RTP/SCS, as appropriate

029‐08 Laura Pierce City of Brea We request that internal consistency of the Land Use Pattern

map for Orange County be confirmed between the plan

document (page 145) and the technical reports or appendices.

Specifically, the Land Use Pattern Map for Orange County

(Exhibit 4.17 enclosed) shows a significant urban village

designated for northeastern Brea. This area appears to be the

location of the Olinda Landfill. Future residential development

in this area cannot occur due to its current use. We believe this

is simply an oversight as we have provided this input to SCAG in

2009 for the CLUS project. We note that the SCS Background

Documentation Appendix does not include an accurate map

(enclosed) for Orange County which should be revised in the

final document for Regional Council review and approval.

Comment noted. SCAG has co

were found in the Land Use P

between the plan document 

in the re‐designation of the u

(see the updated Exhibit 4.17 

concern about the Olinda Lan

assure you that the adopted g

County is consistent with the 

Governments (OCCOG) subre

provided by Orange County in

Olinda Landfill area during th

029‐09 Laura Pierce City of Brea We request that the adoption of the final growth forecast

numbers by the Regional Council and/or Joint Policy Committee

be at the county level consistent with past RTPs and that these

numbers be reflected in the 2012 RTP/SCS. The use of smaller

geographic levels, such as the subregional, city, census tract,

TAZ, parcel or grid cell could limit flexibility and a jurisdiction's

local control over land use decisions. The final growth forecast

numbers are a dataset which includes the 2010 Census

population and housing data, along with the 2010 EDD

Benchmark data, consistent with SCAG's updated growth

forecast dataset. The dataset was provided to SCAG staff in

December 2011 by CDR and its use would provide consistency

with the MOU on sub regional delegations between OCTA,

OCCOG, and SCAG. All documents, tables, maps, narratives,

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use de

allocation being adopted at th

that the SCS be based on a ju

distribution. SCAG has incorp

dataset into the SCAG's final g

2012 RTP/SCS and updated a

narrative, modeling runs, Alte

referencing the Orange Coun
88

ID Name Affiliation Comment Re

modeling runs, PEIR alternatives (including Alternative

C/3/Envision 2), and datasets should be updated with the OCP‐

2010 Modified numbers.

029‐10 Laura Pierce City of Brea We suggest that the final document should reference the

chapter numbers of each section of the plan in the header to

assist the reader in cross‐referencing the document.

Comment noted. Chapter num

029‐11 Laura Pierce City of Brea We suggest adding to the glossary a definition for Active

Transportation.

Comment noted. This term ha

029‐12 Laura Pierce City of Brea [PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

030‐01 Michael

Forbes

City ofBurbank

The City of Burbank has submitted comments on prior RTPs

regarding the aviation forecast. As we have asserted in prior

years, the City of Burbank continues to believe that the forecast

of 9.4 million annual passengers (MAP) for the Bob Hope Airport

is unreasonably high. Two of the primary constrains to

passenger volume at the Airport are the number of passenger

gates and the capacity of streets serving the Airport. The City

believes that neither the existing streets nor the existing 14 gate

terminal building could accommodate 9.4 MAP. The City and

Airport Authority are engaging in a joint public outreach process

to discuss the future of the airport, which may include a new

terminal building. However, it is unlikely that anything other

than a replacement terminal with the same number of

passenger gates as the current terminal would be acceptable to

residents of Burbank who must ultimately vote on whether to

approve any new terminal facility. Based on the passenger

volume trend since the airport opened in 1930, the City Council

and City staff believed that 8.0 MAP is a more reasonable

number for 2035. The City is using this number in our own

forecasts, including our 2035 General Plan update and related

EIR. This number is also consistent with the Airport Authority's

own passenger forecast.

Comment noted. For past RTP

capacity analyses for Bob Hop

capacity‐constrained airports 

enforceable constraints. This 

factor at each airport that is t

limiting demand‐serving capa

runway complex, and for Bob 

gates/aircraft parking positio

estimated the future passeng

considering a variety of facto

aircraft load factors, airport h

turnover time for carriers ser

carriers serving BUR have sign

times than the average). The 

by this analysis was compared 

BUR to confirm that the unco

Documentation of this capaci

to Bob Hope airport staff and 

both the 2001 and 2004 RTPs

in the Final 2012 RTP/SCS wil

78.9 MAP Settlement Agreem

2020, and that any new infor

individual airport authority on 

constraints at their airports w

demand forecast developed b

The forecasts will also be cav

relaxation of the 78.9 MAP fo

significantly impact the passe

that Bob Hope Airport manag

forecast for BUR should be le
89

ID Name Affiliation Comment Re

030‐02 Michael

Forbes

City ofBurbank

The 2012 RTP Financial Plan identifies two broad categories of

revenue sources to fund projects identified in the plan. Core

revenues, in the amount of $305 billion, are identified as

committed or historically‐available funding across the six‐county

region. Reasonably‐available revenues, in the amount of an

additional $226 billion, are identified as new transportation

funding likely to materialize during the plan period. These

additional funds include revenues from adjusments to state and

federal gas taxes, vehicle‐miles‐traveled user fees, tolling,

private funding, and freight fees. The plan assumes that these

reasonably‐available revenues will materialize to fund projects

in the RTP Financially‐Constrained Plan and are necessary to

meet the region's greenhouse gas and air quality reduction

mandates. However, many of these reasonably‐available

funding sources may in fact not materialize, especially given the

controversial nature of some of the proposals. In particular, it

may not be prudent to expect that VMT or mileage‐based fees

are politically feasible to implement, especially if these types of

funding sources are relied upon to implement necessary

projects in the Financially Constrained Plan. Further, the City is

unaware of any VMT fee proposal being currently discussed at

the regional or state level. The City believes that SCAG should

consider an alternative in the PEIR that does not assume the

reasonably‐available revenues identified the current draft

become available during the plan period. This alternative would

then modify the list of projects to include only those that are

funded under the core revenues and assess the air quality and

greenhouse gas impacts from this reduced plan. The City

especially notes the significant uncertainty related to funding of

the California High Speed Rial system.

Comment noted. We agree th

before the mileage‐based use

which is the basis for assump

after 2025. The projected rev

fee and adjustments to state 

combined with the core reve

sources generate less revenu

increase in state and federal t

five percent annually. Rather 

of the historical growth rate, 

requirements, we detailed sp

state and federal transportat

with recommendations from 

established by Congress throu

recognize that the future can

we therefore made reasonab

through SCAG’s Technical Adv

Committees and documented 

transparency. As we gain mo

reasonableness of our assum

plan accordingly through ame

updates as appropriate. At a 

adopted every four years.

030‐03 Michael

Forbes

City ofBurbank

Local Transit Service: The Transit and Rail policies in Section 2 ‐ 

Transportation Investments, include emphasis on encouraging

local transit operators to expand local transit services to serve

as neighborhood circulators and "last‐mile" transit connections

between regional transit systems and major residential and

employment centers. The City supports policies to encourage

expansion of local transit service; however, the plan does not

address the significant difficulty local agencies currently have in

funding these types of services with the operating funds

currently available to local jurisdictions within the region. The

Comment noted. The 2012 RT

funding sources to increase tr
90

ID Name Affiliation Comment Re

Plan should more specifically identify the additional funding

necessary to implement expanded local transit, and should

bolster policies and objectives that expand the availability of

operations funding to local transit agencies.

030‐04 Michael

Forbes

City ofBurbank

Regional Transit Projects: The City believes that there are a

number of regional transit projects in the Arroyo Verdugo Cities

subregion of Los Angeles County that should be included in the

2012 RTP, especially if additional funding sources are identified

over the next 25 years. These projects are identified in other

long‐range planning documents and, specifically, are called out

in Metro's Long Range Transportation Plan adopted in 2009 as

"Strategic Unfunded Projects". These important projects would

improve transit mobility in and around the Arroyo Verdugo

Cities region, and would especially improve east‐west travel

between the San Fernando and San Gabriel Valleys. The City

believes that the following projects should be considered for

implementation using additional reasonably‐available funding

sources as described in the Financial Plan: a. Regional transit

connection between the North Hollywood Red Line/Orange Line

Station and the Gold Line in Pasadena via Burbank and Glendale

b. Extension of the Orange Line and/or Red Line to Bob Hope

Airport c. Bus Rapid Transit (BRT) or other regional transit

connection between Downtown Burbank and Hollywood via

Universal City d. Burbank‐Glendale Light Rail (implemented as

light rail, BRT, heavy‐rail DMU, or other technology)

Comment noted. The regiona

Red Line and the Gold Line in 

and the extension of the Red 

Constrained Plan. The 2012 R

sources to fund additional tra

become available.

030‐05 Michael

Forbes

City ofBurbank

High Speed Rail: The plan identifies the California High Speed

Rail system as influencing regional and intercity travel in the

SCAG region, but does not specifically identify how this planned

transportation improvement will integrate with regional and

local systems. Integration of any intercity transit system with

existing and planned transit services is critical to ensuring the

effectiveness of this major transportation investment. The 2012

RTP should include stronger policies that support development

of regional and local connections to High Speed Rail, including

identification of future regional projects and funding needs that

support High Speed Rail connections of the local network.

Comment noted. As discussed 

California MOU in developme

county transportation commi

interconnectivity as well as sp

systems in our region. Improv

local transit systems is also a 

030‐06 Michael

Forbes

City ofBurbank

Regarding the variety of land use policies discussed in the

RTP/SCS, the City provides a general comment that for these

policies to be effective, land use control most remain at the

local level. The RTP/SCS provides blanket policies that apply

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w
91

ID Name Affiliation Comment Re

generally to the entire SCAG region and may not be appropriate

in every situation. For example, the RTP/SCS associates TransitOriented Development with higher residential densities and

multifamily or mixed‐use housing products. However, the City

of Burbank contains many single family residential

neighborhoods that are located within walking distance of

transit centers and corridors, and within walking distance of

commercial districts. The City is pleased that the RTP/SCS was

developed based on existing local General Plans and local input,

and that cities will continue to have sole authority over local

land use decisions.

altered small area land use as

trends occurring in many tran

the SCS is intended to provide 

local governments may build 

generally includes the quantit

each city and county in the re

jurisdictions maintain local la

031‐01 Mike Kellison City of Chino Transportation, Traffic & Security: The City of Chino is in support

of the Goods Movement Truck Route proposal. However, the

City has concerns with the freeway's proposed cross section and

its affect on current and future projects. The following is a list of

five affected projects within the City of Chino contained in the

"Project List" Supplemental Report: 1. RTP ID No. 4M07017‐

201133 SR 60 at Euclid Avenue ‐ Widen W/B exit ramp from 2‐3

lanes. 2. RTP ID No.4M07008 SR‐60 Ramona Avenue IC to SB I‐

15 Connector ‐ Widen auxiliary lanes in each direction, widen

connector from SB‐15 to WB‐60 and EB‐60 to NB/SB‐15, widen

ramps from one lane to two lanes. 3. RTP ID No. 4M04050 SR 60

at Central Avenue ‐ Add auxiliary lanes and widen ramps,

construct entrance loop ramp. 4. RTP ID No. 4PL07019 SR 60 at

Mountain Avenue ‐ Reconstruct interchange SR‐60 at Mountain

Avenue. 5. RTP ID No. 4120202 SR‐60 at Ramona Avenue ‐ 

Reconstruct Interchange SR‐60 at Ramona Avenue. Close

coordination between the State, County, City, and other

affected jurisdictions should be required for any project

proposal to ensure compatibility of design, including any

interchange or regional arterial highway project along a

proposed freeway route that is included in the SANBAG

Development Mitigation Nexus Study. The Development

Mitigation Nexus Study identifies fair‐share contributions from

new developments for regional transportation improvements in

the San Bernardino Valley and Victor Valley.

Comment noted. The East‐W

identified as part of the 2012 

more detail through a project

Report (EIR) and associated a

EIR. The EIR would address th

of Chino regarding potential i

future projects. SCAG intends 

its partners and industry stak

Chino, on next steps related t

to ensure that the proposed p

fully considers stakeholder in

031‐02 Mike Kellison City of Chino [PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

032‐01 Michael

Fleager

City of Chino

Hills

We have reviewed the draft Regional Transportation Plan (RTP)

for the 2012‐2035 planning period. The City of Chino Hills

Comment noted.
92

ID Name Affiliation Comment Re

supports SCAG's efforts toward increasing mobility,

sustainability and quality of life for all cities within the region.

Specifically, Chino Hills supports inclusion of the following

improvements that are included in the RTP Project List:

Improvement of Eucalyptus Drive from Peyton Drive to the

Chino Hills Community Park entrance; Improvement of Peyton

Drive from English Road to Eucalyptus Drive, consisting of the

widening of Peyton from 4‐6 lanes with marked bike lanes in

each direction; and, Improvement of Peyton Drive fromEucalyptus Drive to SR 142, consisting of the widening of Peyton

to 2‐4 lanes with marked bike lanes in each direction. As

previously indicated in our October 11, 2011, resolution to

SCAG, the City of Chino Hills is reserving its support of the

proposed dedicated truck lane along the SR‐60 freeway corridor

until such time as substantial study has been completed and

provided to potentially effected cities, including Chino Hills.

033‐01 Mark Tomich City of Colton Ms. Margaret Lin: Please see attached comments from the City

of Colton regarding local arterial improvement strategies and

commuter rail station feasibility study. Mark Tomich

Development Services Director City of Colton

Comment noted. Regarding t

station in Colton, decisions re

generally under the purview o

commission, and SCAG would 

and necessary, should a feasi

Regarding the arterial improv

addressed all modification re

submitted by county transpo

standard RTP long‐range proj

database update processes.

034‐01 Doug Bailey City of Cypress On behalf of the Cypress City Council, I am contacting you to

urge adoption of the comments made by OCCOG in their

February 14, 2012 letter (attached) regarding the current

RTP/SCS process and its corresponding/associated PEIR. The

work done by OCCOG was exhaustive, well considered and

clearly demonstrates the commitment made by the member

agencies to meaningfully participate in the preparation and

review of a supportable and balanced RTP/SCS. We are all

aware of the scope and long term importance of these

documents. The incorporation of the attached comments will

contribute greatly to the viability of SCAG's efforts in this area

and will result in an enhanced final product.

Comment noted. Please see s

comments.

035‐01 James

DeStefano

City ofDiamond Bar

While the overall goal to reduce both the congestion impacts

and environmental impacts is admirable, we continue to have

Comment noted. Inclusion of 

the 2012 RTP/SCS allows for f
93

ID Name Affiliation Comment Re

significant concerns regarding the component of the 2012 RTP

to designate only the Pomona (SR 60) Freeway as and East‐West

Freight Corridor ("Corridor") and the continued focus on the

placement of 4 lanes of truck traffic within the San Jose Creek

Wash ("SJC") which is located immediately adjacent to homes

and businesses of many cities, including Diamond Bar.

through a project‐level Enviro

Specific costs, accessibility co

alignments would be identifie

Additionally, further discussio

would be addressed through 

noted, however, that prelimin

land uses and potential right‐

continue to work with affecte

Bar, on this project.

035‐02 James

DeStefano

City ofDiamond Bar

We believe it is pre‐mature to identify the SR 60 and the SJC

Wash alignments as a viable Corridor project in the 2012 RTP.

We have the following specific concerns: 1. No studies have

been conducted regarding the localized air, noise, vibration, or

visual impacts along the Corridor. Such studies may conclude

that the impacts are significant, resulting in objections from

surrounding communities and the need for costly mitigation

(including ROW acquistion). 2. While the SR 60 and the SJC are

identified as "preferred" alignments, further studies may find it

more practical/beneficial to select another alignment. There are

pros/cons to each alignment, but selecting a final alignment will

need to consider the results of the detailed studies for SR 60

and SJC, which have not yet been performed. Many of the

possible routes were rejected in the planning process due to

excessive ROW impacts. Further studies may find that the ROW

impacts along SR 60 and the SJC (due to air, noise, vibration

and/or visual) are as great or greater than other corridors. 3.

The desired electric technology does not have any large‐scale

application to verify that it is feasible for this vision. Even if it

did exist, it is not clear what would motivate truck

owners/operators to convert? SCAG's Corridor planning

documents acknowledge that most of the truck traffic in this

corridor is not going to/from the ports, so it is hard to believe

that all of the independent truck owners would elect to convert.

Furthermore, does the RTP specifically allow use of the truck‐

only freight corridor, from day one and thereafter, by only new

technology, zero emission, "clean" trucks?

Comment noted. The specific 

Corridor project, including loc

visual impacts, would be dete

a project‐level Environmenta

potential alignments along al

considered and analyzed inclu

SR‐91. This was in addition to 

corridor as noted above, hybr

acquisition was only one crite

the proposed alignment of th

Among other criteria conside

manufacturing facilities, ware

movement dependent indust

residents and businesses, and 

emissions technologies curre

for passenger rail) and it is a r

technologies would be adopt

West Freight Corridor. SCAG a

continuing analyses and dialo

035‐03 James

DeStefano

City ofDiamond Bar

Given the above facts regarding the significant unknowns and

that further studies are needed, it is our assertion that SCAG has

under‐stated the environmental impacts of the RTP by: 1.

Inappropriately including the Corridor in the financially‐

Comment noted. SCAG maint

analyses have been undertak

the East‐West Freight Corrido

freight corridor concept is exp
94

ID Name Affiliation Comment Re

constrained plan. Given the huge uncertainties in its actual cost,

it is not reasonable to assume the Corridor can be afforded

within the constrained monies. The RTP guidelines were

changed several years to prevent agencies from including

projects that could not reasonably be afforded in the planning

horizon. The "constrained" plan should only include projects

that, in aggregate, can be demonstrated as affordable within

the available revenues. The costs of the Corridor cannot be

estimated with any credibility, given the lack of technical studies

and corresponding lack of knowledge regarding right‐of‐way or

mitigation costs. How the proposed Corridor connects to the SR

57/60 interchange is also undefined, which has potentially

enormous cost. Much of the segment east of SR‐57, within the

SR‐60 corridor, is severely constrained. It is not clear how the

truck lane would be accommodated in this stretch; therefore,

no reasonable estimate of cost can be derived. The following

citations support the above claim and are from the 2010 RTP

Guidelines, CTC: 1. Page 98 ‐ "Fiscal constraint is the

demonstration of sufficient funding (Federal, State, local and

private) to operate and maintain transportation facilities and

services and to implement planned and programmed

transportation system improvements." 2. Page 100 ‐ "If FHWA

and FTA find and RTP or FTIP to be fiscally constrained and the

planned/programmed projects are included based on outdated

or invalide cost estimates, then FHWA/FTA will not make

funding or environmental approval actions for the listed

project(s)......." 3. Page 101 ‐ ".....costs of future transportation

projects must use "year of expenditure dollars" rather than

"constant dollars" in cost and revenue estimates to better

reflect the time‐based value of money."

completion of a project‐level 

(EIR). To date, cost analysis h

right‐of‐way constraints/impa

accordance with federal requ

2012 RTP (including costs for 

Year of Expenditure (YOE or n

percent annual inflation facto

035‐04 James

DeStefano

City ofDiamond Bar

Attempts to focus truck lanes on the SR‐60 and the SJC are not

new. This type of proposal has been previously pursued. The

City of Diamond Bar and other cities and communities along the

proposed Corridor are concerned about being put in another

adversarial position. Based on past actions our constituents

have been strongly opposed to proposals that require the SR‐60

and the SJC "shoulder the burden" of east‐west truck

movements and have been willing to "go the distance" in our

efforts against such a proposal. We respectfully request the

2012 RTP and PEIR to consider all possible routes to serve the

Comment noted. Analysis com

Corridor indicate that areas a

benefit from reduced congest

of the use of zero‐emission ve

jobs in adjacent areas where 

industries and employers are 

alignments of the East‐West F

determined through an altern

of a project‐level Environmen

scoping workshops with affec
95

ID Name Affiliation Comment Re

ever‐increasing demands of the est‐west goods movement

between I‐710 and I‐15. It is unreasonable to designate the SR‐

60 and SJC as the singular east‐west route.

Diamond Bar.

035‐05 James

DeStefano

City ofDiamond Bar

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

036‐01 Scott Ochoa City of

Glendale

Under the Transit and Rail policies the RTP encourages local

transit operators to expand and provide connections to planned

rail and regional transit services as well as the major

employment centers. While the City of Glendale supports such a

policy, the plan fails to recognize the additional funding that will

be necessary to fund such services by local agencies. Local

transit operators currently provide key connection to the

existing commuter rail, light rail, and BRT services using local

transit funds. Any further expansion of these services although

important in improving mobility, will create a hardship on local

agencies.

Comment noted. The 2012 RT

funding in order to increase t

036‐02 Scott Ochoa City of

Glendale

Under Los Angeles Metro's 2009 Long Range Plan, the following

projects were included as "Strategic Unfunded Projects": a.

Extension of the Orange line and Red Line to Bob Hope Airport.

b. East‐West Connector between North Hollywood Red

Line/Orange Line and the Pasadena Gold Line via Burbank and

Glendale to provide a "missing link" between San Fernando

Valley and San Gabriel Valley. c. Burbank ‐ Glendale Light rail to

Union Station or expansion/enhancement of the Metrolink

service. The above key transit projects should also be

considered for implementation by using the "reasonably

available" revenues similar to RTP Financially Constrained Plan.

Comment noted. The extensi

airport is in the Constrained P

between North Hollywood an

036‐03 Scott Ochoa City of

Glendale

The California High Speed Rail (CHSR) in the RTP is included as

currently being planned. However, the RTP fails to again address

the impact of such a system on the local transit system such as

the Beeline Service and the lack of funding for service

connections to the High Speed Rail stations. Considering the

tremendous capital and operating cost of the CHSR, we

recommend implementation of alternatives such as increasing

interregional connectivity of the existing systems (commuter

rail, light rail and bus rapid transit) to improve mobility in the

sub‐regions at a lower cost and more immediate before the

CHSR is constructed.

Comment noted. The 2012 RT

to our region's existing rail se

High‐Speed Train becoming o

are included in the Constraine

036‐04 Scott Ochoa City of

Glendale

The RTP only allocates a little more than 1% of the funding to

Active Transportation. We believe that SCAG should consider

Comment noted. The 2012‐20

approximately $6.7 billion tow
96

ID Name Affiliation Comment Re

increasing the funding for Active Transportation to between 5%‐

8% of the total funding in the RTP.

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

036‐05 Scott Ochoa City of

Glendale

The 2012 RTP Financial Plan assumes that the "core revenues"

and the "reasonably‐available revenues" will fund the RTP's

Financially Constrained Plan. The following are key issues that

need to be addressed in the Financial Plan: a. As stated above,

there are no provisions for funding local transit services as a

result of planned expansion of rail and commuter services. b.

The "reasonably‐available revenues" category in the amount of226 billion dollars is in our opinion optimistic as to the possible

adjustment to state and federal gas taxes, revenues from TOLL

roads, and freight fees. There are no details about the

controversial "vehicle mile user fees" that regional and local

agencies have to enact to raise funding. c. Highway projects are

front loaded as they are easiest to finance in comparison to

transit projects by borrowing against future toll revenues.

Highway project increase in Vehicle Miles Traveled (VMT)

consequently raises compliance issues with SB375 to reduce

greenhouse gas emissions. It is our recommendation that transit

(bus and rail), bicycle and pedestrian projects take priority over

highway projects as they can improve mobility and reduce

emissions as well. d. It is recommended that the RTP/SCS

Financial Plan include a full benefit/cost ratio analysis and a

Performance Criteria for major highway and rail projects

contained in the "Constrained Financial" Plan. Overall, we are

concerned that the RTP's assumption regarding the

"reasonably‐available revenues" is optimistic and the PEIR

should consider alternatives in the draft plan that identifies only

projects that can be funded as part of the "core revenues" to

make the plan more realistic with priority given to transit

Comment noted. a. The distri

transportation investments in 

tax measure commitments ap

transportation commission ad

plans, limitations associated w

other previous commitments

Appendix provides additional 

revenue sources included in t

regional and local agencies ar

mileage‐based user fee. The p

mileage‐based user fee and a

gas excises taxes when comb

forecast for state and federal 

than the historical average in

transportation revenues sour

Rather than simply assume a 

growth rate, which is consiste

detailed specific steps necess

transportation revenue sourc

recommendations from two n

by Congress through SAFETEA

for different transportation in

option sales tax measure com

county transportation commi

transportation plans, limitatio

revenues sources, and other 

note that the RTP/SCS meets 

reduction targets established 
97

ID Name Affiliation Comment Re

projects. investments in the RTP, includ

return of $2.90 for every doll

future cannot be known with 

reasonable assumptions, whi

Technical Advisory Committe

documented in the RTP to en

more insight into the future a

assumptions, we will update 

through amendments and/or 

appropriate. At a minimum, a

every four years.

036‐06 Scott Ochoa City of

Glendale

Lastly, as cited on p.3.12‐25 of the DEIR, "Locally‐developed

county transportation plans have identified projects to close

these (highway network) gaps and complete the system, and

they are included in the Plan. These projects include...the SR710

Gap Closure in Los Angeles County...". The position of the City of

Glendale remains consistent with Resolution No. 09‐111

approved by the Glendale City Council on July 28, 2009, which

addresses both the tunnel "gap closure" alternative as well as

the general subject of "gap closure" alternatives for the SR‐710

freeway between the I‐10 and SR‐134/I‐210 freeways. On behalf

of the City Council and the citizens of Glendale, I wish to

reiterate our opposition to any "gap closure" alternative that

has or could be developed. In addition, I wish to express our

opposition to the continue effort and expenditure of tax‐payer

onies in exploring, studying, and developing any means to

facilitate this "gap closure". It is Glendale's belief and desire that

efforts instead be directed to the development of alternatives

that more effectively and more thoroughly address the

concerns of mobility, congestion, and the movement of goods in

the SR‐710 corridor, particularly from our ports. Such

alternatives should expand mass transit systems, improve

existing infrastructure, and limit the long‐distance movement of

cargo/freight from the ports to rail. The City of Glendale has

opposed this project and recommends the development of a

multi‐modal solution in lieu of further consideration of this

project.

Comment noted. The 710 pro

approved Measure R sales tax 

Range Transportation Plan, as 

SCAG recognizes that a projec

underway. Upon the complet

preferred alternative by Metr

amend the RTP as necessary t

and associated modeling ana

036‐07 Scott Ochoa City of

Glendale

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

037‐01 Deanna Elliano City of Hemet Two Major Highway projects of major interest to the City of Comment noted. The referen
98

ID Name Affiliation Comment Re

Hemet are the realignment and widening of SR 79 from

Domenigoni Pkwy to Gilman Springs Road (FTIP ID RIV62024)

and the completion of the Mid‐County Parkway (FTIP ID

RIV031218). The City's long term growth projections,

employment base, housing conditions, and overall economic

health depend in large part upon the completion of these two

thoroughfares. Specifically: Exhibit 2.1 Major Highway

Improvements does not show the realigned SR 79 through the

Hemet area and connecting to major east west corridors to the

north, or the Mid‐County Pkwy. The City requests that these

critical roadway improvements be included on Exhibit 2.1. Table

2.2 shows a list of Major Highway Projects in the region. For

Riverside County, the CETAP Intercounty Corridor A is noted,

however our understanding is the planning for that corridor is

delayed. We suggest that Table 2.2 be updated to reflect more

essential projects that are a higher priority for Riverside County,

such as the Mid‐County Pkwy and the SR‐79 Realignment.

include the Mid County Parkw

Table 2.2 has been revised to 

Corridor A with the SR‐79 rea

Scott to Nuevo.

037‐02 Deanna Elliano City of Hemet In the Highways and Arterials report, Exhibit 4 and Exhibit 9

should be corrected to include the SR79 and Mid‐County Pkwy

road projects, as noted above. In Addition, Exhibits 11 and A16

also do not appear to include these critical roadways, although

the scale of the map makes it difficult to determine if these

roadways are included, or if the map reflects improvements to

existing local arterials in the area. Please verify the highway

improvements included on these exhibits and update the

exhibits as needed to address these roadways.

Comment noted. Exhibits 4 a

Appendix has been revised to 

the Mid County Parkway.

037‐03 Deanna Elliano City of Hemet In the Financially constrained RTP list of projects, Warren Road

from Domenigoni Pkwy to Esplanade Ave (ID RIV 3A01WT041)

should be shown as widening from 2 lanes to 6 lanes, consistent

with the City of Hemet's updated General Plan Circulation

Element.

Comment noted. We have ad

to the Project List as submitte

commissions through the sta

modification and FTIP databa

037‐04 Deanna Elliano City of Hemet The City strongly supports the extension of a commuter rail line

to Hemet. It will reduce vehicle miles traveled considerably and

help spur residential and economic growth in the valley.

However, the proposed Perris Valley Line (RTP ID 3CR0702)

does not indicate a station in Downtown Hemet. Our recently

adopted General Plan 2030 includes a high‐density transit

oriented development strategy based upon the siting of a

Metrolink station in the downtown area. In addition, SCAG

previously prepared a Compass Blueprint project for a transit

Comment noted. The location 

for the extension of the Perri

Riverside County Transportat
99

ID Name Affiliation Comment Re

village surrounding a future station in Downtown Hemet. We

request consideration of adding a station to this project in

Downtown Hemet. In addition, as noted in the RTP (ID 3CR0702)

a station is proposed at the Hemet Ryan Airport. These locations

immediately around the airport are constrained by the existing

development and environmental factors. The city requests that

the " Hemet Airport; Sanderson Ave @ Stetson Rd" location be

replaced with "west Hemet @ Stetson Rd." This location is

consistent with the recently adopted update update to the City

of Hemet's General Plan that anticipates transit oriented

development and mixed use residential, commercial, and

business park uses in the West Hemet area, adjacent to the

Perris Valley Line. The city would like to co‐locate a bus transit

center with the Hemet Downtown Metrolink station. FTIP ID RIV

041030 on page 75 of the FTIP Project List indicates the location

of the transit center at the 700 Scaramella Circle. This is the site

of the RTA bus yard, and not appropriate for passenger use.

Please reference "in the vicinity of Sate Street and Devonshire

Ave" as the location for the new Hemet Transit Center in the

FTIP. The City is currently working with RTA on locating a transit

center at this location in Hemet's Downtown area which would

be adjacent to a Future Metrolink station, as well as a proposed

Courthouse facility and mixed use Transit Village.

037‐05 Deanna Elliano City of Hemet The City is committed to the SCS tenets and concepts. We

recently updated our general plan and incorporated many

sustainability and mixed use development measures in

accordance with these principles. However, it appears that the

only way to determine on‐going consistency with the SCS is to

use the Local Sustainability Planning tool (LSPT), which is not

practical for us. Our jurisdiction does not have the resources to

access or use the tool, although we did submit our comments

and revisions to the map during the local input process. We are

not able to completely ascertain whether our comments have

been integrated into the SCS land use model and mapping,

based upon the regional scale of the maps provided to date in

the SCS. WE are also unclear as to whether consistency with the

SCS is determined on the basis of the revised city‐wide Growth

Forecast numbers submitted and approved by Hemet and the

WRCOG's member jurisdictions, or a land use distribution

pattern that has been aggregated and shown in the SCS maps in

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.
100

ID Name Affiliation Comment Re

very broad terms? We have only recently become aware of

growth maps based on TAZ data that has not been confirmed by

the City of Hemet or other WRCOG jurisdictions, and have

concerns regarding the land use accuracy and future application

of these maps in determining consistency with the SCS or our

adopted General Plan. the City of Hemet concurs with and

supports the comments submitted by WRCOG in their comment

letter dated February 13, 2012 regarding the use of TAZ data

and mapping for anything other than scenario modeling

purposes. Please provide a clarification as to the use of TAZ data

and additional review time to analyze the recently released

maps at a scale that we can determine consistency with our

existing and future land use patterns.

037‐06 Deanna Elliano City of Hemet Thank you for recognizing that Hemet and other cities on the

region's periphery have less housing capacity than the original

forecast assumptions. We sincerely appreciate SCAG's effort to

revise the Growth Forecast numbers and continue to support

the Revised Growth Forecast for the City of Hemet, as adopted

by WRCOG, and the 2035 build out projections.

Comment noted.

037‐07 Deanna Elliano City of Hemet Per the comments noted above for the locations of Metrolink

and Transit Station in the City pf Hemet, exhibit 4.9 of the SCS

needs to be updated to reflect the appropriate transit locations.

In addition, it appears that the HQTA nodes shown do not align

with the actual rail line locations. Again, it is difficult to

determine at the scale of the map provide in the SCS.

Comment noted.

038‐01 John Jaquess City of

Highland

This letter is to officially inform you that the City of Highland is

in support of SANBAG's comments concerning the subject Draft

RTP/SCS and DEIR as outlined in their February 14, 2012 letter

(see attached). In addition, the City respectfully request SCAG

make additional adjustments to the City's Growth Distribution

as presented by SANBAG and illustrated on the attached Table.

Adjustments are highlighted in "Bold". No adjustments to the

City's Growth Forecast is requested, only the "distribution" of

Growth.

Comment noted. SCAG has in

dataset into the final growth 

RTP/SCS and updated all relat

narrative, modeling runs, and 

039‐01 Sean Joyce City of Irvine The City of Irvine concurs with the Orange County Council of

Governments (OCCOG) and Orange County Transportation

Authoirty comments. The City of Irvine concurs with the

comments SCAG will receive from the OCCOG and the Orange

County Transportation Authority (OCTA). The City requests that

SCAG respond to all of the comments detailed in the OCCOG

Comment noted.
101

ID Name Affiliation Comment Re

and OCTA letters and to act upon any changes advocated by

OCCOG, of which the City is a member agency.

039‐02 Sean Joyce City of Irvine SCAG's adoption of the growth forecast numbers should be at

the county level, consistent with past RTPs, not at a smaller

level of geography such as city, census tract, or traffic analysis

zone level. The growth projections provided to SCAG represent

the best available information from local jurisdictions, the

business community, and landowners. However, as time passes,

what is feasible for any given project can change. A county level

of geography accommodates internal adjustments to changing

conditions, without compromising the integrity of the overall

growth projections. Approving the growth projections at any

lower level of geography, such as the city level, would be

challenged with continual revisions and shifts to the total

number of housing, population, and employment within a city,

among cities, and county would also limit local jurisdictional

control and create inflexibility in a regional planning document.

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use deallocation being adopted at th

that the SCS be based on a ju

distribution.

039‐03 Sean Joyce City of Irvine The Orange County Sustainable Communities Strategy (OC SCS)

should be fully integrated into the regional RTP/SCS. Language

should be incorporated into the document that indicates the OC

SCS represents the SCS for the Orange County Subregion. The

RTP and appendices include numerous references to the OC SCS

and SCAG's total use of the document in the regional RTP/SCS.

yet numerous other references suggest SCAG may have

modified elements of the OC SCS data. SCAG shall include a

statement and should document all maps, tables, charts, and

other information that is necessary to confirm all of the OC SCS

land use, socioeconomic, and transportation data was

incorporated into the regional RTP/SCS without changes. This

would be consistent with statements made by SCAG staff to the

OCCOG Board of Directors and at the 2012 RTP Workshops that

the OC SCS data has not been and will not be altered.

Furthermore, there should be a statement indicating that the

OC SCS represents the SCS for the Orange County subregion in

total and that anything to the contrary in the regional 2012

RTP/SCS shall have no standing for Orange County.

Comment noted. The subregi

GCCOG and OCCOG are incor

in their entirety, and as such, 

the regional plan for impleme

strategies included in the RTP

apply region‐wide. The final S

and Subregional Sustainable C

Appendices has been updated 

039‐04 Sean Joyce City of Irvine One City of Irvine project, which has both local and regional

significance, does not appear to be included in the RTP/SCS. This

project is identified in the Long Range Transportation Plan

(LRTP) for Orange County with the Orange County

Comment noted. This project 

under FTIP #ORA000118.
102

ID Name Affiliation Comment Re

Transportation Authority (OCTA) as lead agency. It is, therefore,

requested that the following project be added to the RTP/SCS:

Sand Canyon Grade Separation Project.

039‐05 Sean Joyce City of Irvine All documents, tables, maps, narrative, modeling runs, and PEIR

Alternatives (including Alternative C/3/Envision 2 referencing

the Orange County growth forecasts) should be updated with

Orange County growth forecasts) should be updated with

Orange County Projections 2010 Modified Growth Projections

(OP‐2010 Modified), as adopted by the OCCOG Board of

Directors and consistent with the subregional delegation MOU

between OCCOG, OCTA, and SCAG. Orange County Projections

2010 Modified (OCP‐2010 Modified) was approved by the

OCCOG Board of Directors on January 26, 2012 and is data

amendment to the OC SCS. The dataset includes the 2010

Census population and housing data, along with the 2012

Employment Development Department Benchmark data,

consistent with SCAG's updated growth forecast dataset.

Comment noted. SCAG has in

Modified dataset into the SCA

for the 2012 RTP/SCS and upd

tables, maps, narrative, mode

Alternative C referencing the 

039‐06 Sean Joyce City of Irvine [PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

040‐01 Ann Wilson City of La

CanadaFlintridge

Pursuant to Federal Regulations, projects should not be

included in the RTP/SCS constrained plan which have only

secured a small portion of the required funding needed to

complete the project: The RTP/SCS according to federal

regulations, in "nonattainment and maintenance areas," must

"address the specific financial strategies required to ensure the

implementation of projects and programs to reach air quality

compliance". Projects which only have secured a small portion

of the needed funding, and which rely on speculative funding,

such as potential and/or possible tolling authority, should not

be included in the RTP/SCS, since this inclusion does not meet

the federal requirements for a fiscally constrained plan.

Comment noted. However, SC

of reasonably available sourc

federal requirements. Under 

financial constraint requirem

financial information for dem

plan “can be implemented us

reasonably available revenue 

assurance that the federally s

being adequately operated an

040‐02 Ann Wilson City of La

CanadaFlintridge

Language should be included in the RTP/SCS requiring a full

cost/benefit analysis for all projects in the constrained plan:

Language should be included in the RTP/SCS that clearly states

that a full cost/benefit analysis shall be completed for each

project contained in the RTP/SCS constrained plan. These cost

benefit analyses should then be used, in an era of limited

financial resources, to prioritize projects. A model for the

cost/benefit analysis of every project in the RTP/SCS should be

built and put into the Plan. The RTP/SCS should reflect this

Comment noted. A benefit‐co

RTP. The investments in the R

every dollar invested. An ana

the RTP is also provided in th

Analysis of the 2012 RTP/SCS 

transportation investments in 

tax measure commitments ap

transportation commission adplans, limitations associated w
103

ID Name Affiliation Comment Re

process and model in its language. other previous commitments

040‐03 Ann Wilson City of La

CanadaFlintridge

Major highway expansion projects should not be frontloaded in

the RTP/SCS: The RTP/SCS frontloads highway modalities by

disproportionately allocating funding and anticipated

completion dates. This is evidenced by comparing Table 2.2 ‐ 

Major Highway Completion Project against Table 2.5, Major

Transit Projects, in chapter 2 of the RTP/SCS. Transit projects

are built in segment with the final project not being completed

until 2030‐2035, Expanding highways induces VMT and

therefore frontloading major highway completion before transit

projects does not comply with the tenets of SB 375 and AB 32 to

reduce greenhouse gas emissions by reducing VMT.

Additionally, it is well documented that land uses adjacent to

freeways are prone to increased toxins which cause negative

health impacts. According to SCAG staff, highway projects may

be more easily financed than transit projects by borrowing

against future toll revenues. They state that this is the reason

the highway projects are frontloaded. This financial reasoning

does not justify sacrificing environmental concerns by building

the highway projects prior to transit projects.

Comment noted. The distribu

transportation investments in 

sales tax measure commitme

transportation commission ad

plans, limitations associated w

other previous commitments

040‐04 Ann Wilson City of La

CanadaFlintridge

The term "SR‐710 Gap Closure" used in the plan should be

substituted with "710 North Extension": The "SR 710 Gap

Closure" language, already in the 2008 RTP, should be modified

to consistency with Metro's stated intent, which would serve to

ease, if not eliminate, the current polarizing language. The shift

in title from "710 North Extension" to "710 Gap Closure" is

invalid, since there is no gap. SR‐710 terminates at Valley

Boulevard. There is no northerly extension to connect to, since

the portion of the 210 interchange including Del Mar Boulevard

was built conditioned upon the fact that it "would have no

effect on the decisions as to the ultimate freeway location and

will not foreclose alternatives to the proposed ultimate...

Freeway." This title seems to create a sense of inevitability or

priority for this project over competing ones and cannot be

justified.

Comment noted. References 

been revised to “SR‐710 Nort

TBD)”.

040‐05 Ann Wilson City of La

CanadaFlintridge

SCAG assumptions regarding the "SR‐710 Gap Closure" project

producing congestion relief and lower greenhouse gas

emissions are flawed based upon empirical research on other

highway projects that have been built: The PEIR states that "The

Plan would increase VMT when compared to existing

Comment noted. Increase in t

condition is primarily due to e

people over the plan period. 

basis will decrease over this p

implemented. While the Plan 
104

ID Name Affiliation Comment Re

conditions." (SCAG RTP/SCS PEIR p. 3.2‐25). Specifically,

decreasing VMT is the goal of SB 375 and should also be the

goal of the RTP/SCS. This increase in VMT is the Plan's reliance

on freeway expansion to meet the region's mobility needs.

Notably, the RTP/SCS describes the SR‐710 tunnel as a tunnel

with 4 lanes in each direction. This is a major highway expansion

introduced into the region. To the extent that this causes the

widening of other freeways (such as the I‐210), it will further

expand the freeway system. The region would be better served

with an alternative project which is not highway oriented and

which would potentially decrease VMT, rather than increasing

it. SCAG assumes that the SR‐710 extension will produce

congestion relief and lower greenhouse gas emissions. These

assumptions are not borne out by recent research, and there

are a host of other previous studies showing that an increase in

highway capacity increases VMT and that once the project is

built, congestion, within a few years returns. These SCAG

assumptions are flawed.

highway improvements, incluproject, there is no evidence 

contribute to the total VMT in

The 2012 RTP identifies a mu

incorporates transit, highway

strategies as well as demand 

pricing strategies to achieve o

performance and reduction in 

375.

040‐06 Ann Wilson City of La

CanadaFlintridge

The definition of the SR‐710 Gap Closure project from one

precise point to another threatens program‐level conformity in

the plan and prejudices future environmental analyses: The Plan

has modeled the SR‐710 extension from one precise point north

to another. Unfortunately, this assumption removes the low‐

build or multi‐modal solution to the congestion problem. Under

federal regulations, because of this specificity, the Plan and the

PEIR threaten program‐level conformity and prejudice future

project‐level environmental analyses. In addition, this definition

differs significantly from that used by the Los Angeles County

Metropolitan Transportation Authority, which is current

conducting the EIR for the project and is the lead agency. Metro

says, "We are beginning with a fresh perspective to initiate an

environmental review process that will focus on a range of

solutions to specifically evaluate the effects of the SR 710 gap.

This process involves an education and public involvement

program to seek both regional and community‐based solutions

that are suggested by you, your friends and family, your

neighbors, and everyone else in your community. As our public

involvement program name (SR‐710 Conversations) suggests,

the process for identifying these solutions will be through

dialogue and conversation. These solutions from you can come

Comment noted. A project sp

underway by the lead agency

impacts including environme

impacts, and identify mitigati

completion of this effort and 

by Metro, SCAG will work wit

necessary to update the proje

modeling analysis.
105

ID Name Affiliation Comment Re

in any possible form ‐ from maintaining the status quo to

considering new infrastructure, from single‐modal to multi‐

modal approaches." This project should not be characterized as

a single solution. The solution to the congestion problem in the

area of the proposed project should be multi‐fold. It could

include the Green Rail Intelligent Development (GRID) project,

for example, along with better bus service, a multimodal

approach, a low‐build option, better traffic light

synchronization, a better intersection of the SR‐710 and the I‐

10, or other projects. The SCAG "project" should reflect the

same process being currently used by Metro.

040‐07 Ann Wilson City of La

CanadaFlintridge

The SR‐710 "Gap Closure Project" should be taken out of the

RTP/SCS altogether due to empirical evidence of health impacts

on children and adults once the project is constructed: Dr. Rob

McConnell, representing the USC Kreck School of Medicine

stated, "The increase in truck and automobile traffic on the I‐

210 freeway resulting from the proposed SR‐710 extension

would increase the exposure of surrounding communities to

vehicular pollutants that may cause asthma and other

respiratory diseases." Supported by empirical research, USC has

also stated that there is an "emerging scientific consensus that

residential or school proximity to major traffic corridors is

associated with respirator impairment in children and in adults."

Further, it has been shown, in a 12‐community Southern

California study that a group of pollutants associated with

residential proximity in a strong predictor of "debilitating lung

disease and mortality in later life." The City of La Canada

Flintridge has twelve schools in close proximity to the I‐210,

which would likely be impacted by the "SR‐710 Gap Closure"

project. These schools existed prior to the freeway being

constructed and would be adversely impacted in the worst

possible way by increased vehicular pollutants. The Preliminary

Final Draft of a SCAG study, done for the Arroyo Verdugo

Region, called the "SR‐710 Missing Link Truck Study," conducted

by Iteris, Inc. Traffic Engineers, showed that there would be a

25% increase in daily traffic volumes on the I‐210, that 30,000

incremental vehicles would go through the communities of La

Canada Flintridge, Pasadena, La Crescenta and Glendale, and

that 2,500 of these would be heavy duty trucks in peak hours. It

can also be concluded from that study that 75% of local streets

Comment noted. A project sp

underway by the lead agency

impacts including environme

impacts, and identify mitigati

completion of this effort and 

by Metro, SCAG will work wit

necessary to update the proje

modeling analysis.
106

ID Name Affiliation Comment Re

in the region, such as Fair Oaks Avenue, Fremont Avenue, Los

Robles Avenue and Atlantic Boulevard would still be over

capacity, as well as twelve arterial streets which would actually

experience higher traffic volumes regional as a result of the

project. Additionally, the study showed that there would be

more delay, gas consumption and air pollution as a result of the

study. It can also be concluded as a result of the study that the

system‐wide, regional benefit would only be an increase of .6

miles per hour. Importantly, the study showed that motorists

would still be driving farther and spending more time on the

road if the tunnel is built.

040‐08 Ann Wilson City of La

CanadaFlintridge

Regionally, a Metro study concluded that "in the peak

(northbound) direction, the gap closure is projected to operate

at LOS F..." This means gridlock in the proposed tunnel and

idling at the portals where congestion and air pollution already

exist and shoudl be alleviated rather than exacerbated. The

previously discussed SCAG conclusions that there would be

lower greenhouse gas emissions and that congestion relief

would be produced appear to lack foundation, in the face of one

of its own studies, along with the other citied.

Comment noted.

040‐09 Ann Wilson City of La

CanadaFlintridge

The City of La Canada Flintridge wants to see the regional

congestion problem resolved in a way that is the best solution

for all stakeholders. We believe that this all‐stakeholder

congestion relief is possible, if you implement our comments,

and particularly if you eliminate the "SR‐710 Gap Closure" as the

primary (if not the only) alternative in this particular region for

congestion relief. Congressman Adam Schiff said, "I believe the

next logical step should be to consider a broad range of

transportation options that might provide the same congestion

relief and improvement in the quality of life for residents of the

region at a cost equal to or lower than the amount Metro

estimates it would take to build one of the five tunnel

alternatives." We concur with this statement.

Comment noted. SCAG recog

environmental analysis is und

that effort and selection of a 

SCAG will work with Metro to 

update the project descriptio

analysis.

040‐10 Ann Wilson City of La

CanadaFlintridge

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

041‐01 Carlos

Jaramillo

City of LaHabra

Issue: Growth Projections: The 2012 growth projections identify

population, housing and employment data for the six‐county

SCAG region, from 2008 (existing) to 2020 and 2035. These

growth projections represent the best available information

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use de
107

ID Name Affiliation Comment Re

from local jurisdictions, the business community and

landowners. However, as time passes, what is feasible for any

given project can change. The triggers for change to adopted

growth projections can range from factors such as market

conditions, new information or data, infrastructure availability,

changes in funding availability (such as the dissolution of

redevelopment agencies statewide), and changes to

jurisdictional boundaries resulting from future annexations and

incorporations of previously‐designated unincorporated

territory. SCAG should continue to adopt the 2012 growth

projections at a countywide level, consistent with past

approvals of Regional Transportation plan growth forecasts. A

county level of geography accommodates internal adjustments

to changing conditions as described above, without

compromising the integrity of the overall growth projections.

However, approving the growth projections at any lower level

of geography, such as at the city level, would be challenged with

continual revisions and shifts to the total number of housing,

population and employment within a city, among cities, and

between cities and counties as a result of the factors described

above. Adoption of the data at a level lower than the county

would limit jurisdictional control and create inflexibility in a

regional planning document. In addition, the level of geography

in which RTP/SCS growth forecast is adopted should not be

determined by other processes. For example, the RHNA

allocations must be consistent with the RTP/SCS; state law does

not require that they be identical. The RTP/SCS can be adopted

at the county level and the RHNA process may proceed

independently until it is completed after the appeals, trades,

and transfers are completed. The RHNA allocations that were

derived from the growth forecast can still be determined to be

consistent with the RTP/SCS, even if changes are made to the

city totals during the appeals, trades, and transfers process.

Growth Projections Recommendation: SCAG's adoption of the

growth forecast numbers should be at the county level,

consistent with past RTPs, and not at a smaller level of

geography such as city, census tract, or traffic analysis level.

allocation being adopted at th

that the SCS be based on a ju

distribution.

041‐02 Carlos

Jaramillo

City of LaHabra

Issue: OCP‐2010 Modified: On January 26, 2012, the update to

the OCP‐2010 dataset known as “OCP‐2010 Modified” was

officially approved by the OCCOG Board of Directors and is a

Comment noted. SCAG will in

dataset into the SCAG's final g

2012 RTP/SCS.
108

ID Name Affiliation Comment Re

data amendment to the OC SCS. The dataset includes the 2010

Census population and housing data, along with the 2010 EDD

Benchmark data, consistent with SCAG’s updated growth

forecast dataset. The dataset was provided to SCAG staff in

December 2011 and this letter also serves as the formal notice

of the update that should be incorporated into the 2012

RTP/SCS, PEIR, and related documents. OCP‐2010 Modified

Recommendation: All documents, tables, maps, narrative,

modeling runs, PEIR Alternatives (including Alternate

C/3/Envision 2 referencing the Orange County growth forecasts)

should be updated with the Orange County Projections‐2010

Modified Growth Projections, as adopted by the OCCOG Board

of Directors and consistent with the subregional delegation

MOU between OCCOG, OCTA and SCAG.

041‐03 Carlos

Jaramillo

City of LaHabra

Issue: 2012 Draft RTP/SCS: The RTP/SCS identifies strategies to

reduce greenhouse gas emissions from cars and light duty

trucks. Because counties, jurisdictions and agencies have

different needs and feasibility of implementation, we believe

these strategies should be clearly identified as a menu of

options that can be used to achieve the goal of reduced GHG

emissions. However, the document can be construed to suggest

that each of the strategies listed in the table on pages 150‐153

are necessary to successfully implement the SCS, many of which

are beyond SCAG’s purview or control. It is requested that the

language be clear that it is permissive.

Comment noted. The final RT

clarifying language.

041‐04 Carlos

Jaramillo

City of LaHabra

2012 Draft RTP/SCS Requests: 1. Revise language on page 149:

“The following tables list specific implementation strategies that

local governments, SCAG, and other stakeholders may use or

consider while preparing specific projects which that help

[delete] can and should undertake in order [/delete] to

successfully implement the SCS.”

Comment noted. The final RT

that actions and strategies pr

menu of options that local jur

implement at their discretion

041‐05 Carlos

Jaramillo

City of LaHabra

Please provide SCAG analysis supporting the strategies in the

Draft RTP/SCS Chapter 4.

Comment noted. The SCS Bac

contains analysis that suppor

Chapter 4.

041‐06 Carlos

Jaramillo

City of LaHabra

Please describe what municipal obligations are anticipated as a

result of adopting these strategies as a list to be accomplished

rather than a menu of options.

Comment noted. The final RT

that actions and strategies pr

menu of options that local jurimplement at their discretion

041‐07 Carlos

Jaramillo

City of LaHabra

Issue: OC SCS Strategies: There are strategies in the Orange

County SCS that are not included in the regional SCS. Similarly,

Comment noted. The subregi

GCCOG and OCCOG are incor
109

ID Name Affiliation Comment Re

there are some strategies in the regional SCS that are not

consistent with the strategies in the OC SCS. This creates

confusion and clarification is needed.

in their entirety, and as such, 

the regional plan for impleme

strategies included in the RTP

apply region‐wide.

041‐08 Carlos

Jaramillo

City of LaHabra

Under SB 375 and only within the SCAG region, subregional

councils of government were allowed to prepare subregional

SCS’s that SCAG is then required to incorporate into the regional

SCS. In Orange County, the Orange County Council of

Governments (OCCOG) and the Orange County Transportation

Authority (OCTA) developed a countywide or subregional SCS

(OC SCS) that was to be incorporated in whole into the SCAG

SCS. Local agencies in Orange County developed the OC SCS and

approved it in June 2011. SCAG has incorporated the OC SCS in

its entirety into the regional SCS as an appendix to the regional

SCS, but it is unclear what the standing is of the OC SCS. The OC

SCS contains a set of strategies that were agreed upon by local

governments, agencies and other stakeholders within Orange

County and was accepted by SCAG and should represent the

SCS that is applicable to the Orange County region.

Comment noted. The subregi

GCCOG and OCCOG are incor

in their entirety, and as such, 

the regional plan for impleme

strategies included in the RTP

apply region‐wide.

041‐09 Carlos

Jaramillo

City of LaHabra

On Page 8 discussion is provided regarding the Sustainable

communities strategy 2012‐2035 plans to SB 375 integrate the

transportation network with new development but minimal

discussion is provided as to how that will be achieved and how

it will be funded.

Comment noted. Chapter 3 p

2012 RTP/SCS.

041‐10 Carlos

Jaramillo

City of LaHabra

Discussion of the need for cities to dramatically increase the

reach of transit in our communities is provided on Page 13 but

no definition of what “dramatically” means is provided. La

Habra has no transit centers.

Comment noted. The RTP sup

transit service in to markets w

utilized and cost effective.

041‐11 Carlos

Jaramillo

City of LaHabra

High speed rail is discussed on Page 21 but no approved

alignment has been reached. It is very likely the BNSF right‐of‐

way will be utilized. This being the case, very little benefit will

be forthcoming to the City of La Habra due to the distance to

the rail line.

Comment noted. The CA High

alignments are in the environ

locally preferred alternative h

041‐12 Carlos

Jaramillo

City of LaHabra

The RTP suggests planning for electrification of the vehicle fleet

and supporting new automobile technology on Page 30 but no

discussion is provided as to how the improvements will be

funded.

Comment noted. SCAG is cur

process to prepare Southern 

of Plug‐In Electric Vehicles (P

address AB 32 and SB 375, an

Southern California. SCAG rec

perspective is necessary to ad

In order to better understand 
110

ID Name Affiliation Comment Re

in the region, SCAG has coord

utilities, subregional councils 

jurisdictions and other key re

included PEV related actions 

that would support and expa

In June 2011, SCAG, in conjun

applied for two PEV planning 

applications. The first grant, a

Energy (DOE) has as its prima

Regional PEV Readiness Plan 

Coast Air Quality Managemen

statewide application in partn

Quality Management District, 

Collaborative, and Clean Citie

awarded $1 million to PEV Re

$300,000 going to SCAG.

The second successful grant a

California Energy Commission 

collaborative effort between 

with SCE, the Western Rivers

(WRCOG), and South Bay Citie

(SBCCOG). This grant has bee

purpose of the project is to d

subregional plans in collabora

These subregional plans will s

subregions as they begin to d

Plans.SCAG will continue to work w

new planning effort and will p

additional stakeholders as the 

041‐13 Carlos

Jaramillo

City of LaHabra

On page 53 there is discussion of making deficient sidewalks

accessible to all. The City supports such action but minimal

funds are made available to accomplish the task.

Comment noted.

041‐14 Carlos

Jaramillo

City of LaHabra

The RTP notes on page 80 that the transportation and safety

mitigation program includes: increasing ride share and work at

home opportunities, invest in land use transportation

connection projects, investments to reduce heaving duty truck

delays, enhance transportation infrastructure practices to

enhance security and working to enhance emergency

preparedness. There is no discussion as to how the

Comment noted. A detailed d

be found in Chapter 3 of the 

please see Table 3.4.1 Core a

Projections—Local Revenue S

Billions).
111

ID Name Affiliation Comment Re

improvements will be funded.

041‐15 Carlos

Jaramillo

City of LaHabra

The City of La Habra is limited to bus service as a means of

regional transportation. Alternative modes of transportation, as

per page 81, to communities like La Habra need to be discussed

further and how those improvements will be funded.

Comment noted. The RTP sup

areas currently underserved b

incentive to single‐occupant v

miles travelled. The RTP also 

to fund transit.

041‐16 Carlos

Jaramillo

City of LaHabra

State or County agencies should be mandated to publish lists of

contaminated properties where new development would

disturb contaminants and provide them on a yearly basis to

cities as suggested on Page 83.

Comment noted.

041‐17 Carlos

Jaramillo

City of LaHabra

A discussion of Measure M in Orange County should be included

on page 133.

Comment noted. Chapter 3: F

Finance Appendixe have a mo

revenue sources including Me

041‐18 Carlos

Jaramillo

City of LaHabra

Page 139 discusses bringing the majority of sidewalks and

intersections into compliance with ADA. The City of La Habra

continues to make improvements to intersections when street

improvements are proposed. What presents a challenge to the

City are continued changes to the accessibility requirements

which make recently completed improvements obsolete.

Comment noted.

041‐19 Carlos

Jaramillo

City of LaHabra

Page 139... The plan also suggests improved traffic signal

synchronization projects but how those improvements will be

funded are not discussed.

Comment noted. Chapter 3 p

2012 RTP/SCS, in which fundi

are discussed, including fundi

signal synchronization.

041‐20 Carlos

Jaramillo

City of LaHabra

The City is limited to regional bus transportation. The land use

growth strategies discussed on page 149 revolve around

transportation centers typically associated with rail lines. Should

the gold line be extended to Whittier, the proposed line could

be extended into La Habra and onto Fullerton where it could

connect to the Fullerton transit center then making it possible

for a transit center in La Habra.

Comment noted.

041‐21 Carlos

Jaramillo

City of LaHabra

The conversion of the City’s fleet to electric or other zero‐

emission transportation technologies as noted on page 153

could be possible if funds were made available for the

construction of the infrastructure and vehicles themselves.

Comment noted. Funds have 

California Energy Commission 

Energy to assist the region in 

zero and near zero transporta

Cities Coalition will be involve

expended and will contact loc

encourage you to sign up as a 

follow SCAG's electric vehicle 

learn about future funding op
112

ID Name Affiliation Comment Re

041‐22 Carlos

Jaramillo

City of LaHabra

OC SCS Strategies Recommendation: Please revise the text in

the last paragraph on page 106 to state: “These subregional SCS

documents are incorporated into the regional SCS and

represent the SCS for each of these subregions.”

Comment noted. The 2012 RT

address comment, as approp

041‐23 Carlos

Jaramillo

City of LaHabra

7. RTP/SCS Policies Please ensure that the discussion of the

policies represented by the RTP/SCS in the draft PEIR is

consistent with the policies actually in the RTP/SCS. In

particular, the bullet list on the page 2‐3 is stated to represent

the land use strategies of the plan; however, the strategies

listed are not specifically identified in the regional SCS. Including

different language in the PEIR implies additional policy. RTP/SCS

Policies Recommendation: Amend the land use strategies

identified on page 2‐3 of the Project Description, under the

section Purpose and Need for Action to reflect the strategies

included in the SCS chapter of the RTP.

Comment noted. In regard to 

does not intend to dictate mi

SCAG addressed these conce

PEIR revision approach, as pr

Council and Policy Committee

February 21, 2012.

The reference to induced gro

RTP/SCS.

041‐24 Carlos

Jaramillo

City of LaHabra

In addition to the above comments, detailed technical

comments, language changes, and questions on the RTP/SCS,

Appendices, and PEIR documents are included in Attachment 2.

Comment noted.

041‐25 Carlos

Jaramillo

City of LaHabra

Conclusion We recognize the immense efforts it took to prepare

these documents. They are incredibly complex documents

establishing important and far‐reaching policy for the region.

However, because of this importance and complexity, we would

like to express concern about the timing of the release of the

documents and hope that preparation of future RTP/SCS

documents will take into account the need to accommodate

adequate review, discussion and revision time for all of the

documents. The timeline of document releases, public comment

period, and time allowed for the response to comments results

in an inability to have credible discussion regarding possible

changes because the timeline does not allow for recirculation or

full discussion of requested changes. The documents were

released over the holiday season and included the release of

draft PEIR document on December 30, 2011. The minimum 45‐

day public comment period closes on February 14, 2012. Only a

few weeks are provided to prepare responses to comments and

amend the documents to ensure that the Regional Council may

consider the certification of the PEIR and the approval of the

draft RTP/SCS on April 4, 2012.

Comment noted. The 55‐day 

period for the Draft 2012‐203

and Sustainable Communities 

14, 2012, and complies with f

gathering public comments fo

two years, SCAG staff engage

the regional stakeholders, inc

transportation commissions, 

representatives from the priv

development of the draft RTP

041‐26 Carlos

Jaramillo

City of LaHabra

1) RTP General. All chapter headings should include the Chapter

number on each page for ease of reference.

Comment noted. Chapter num

RTP/SCS.
113

ID Name Affiliation Comment Re

041‐27 Carlos

Jaramillo

City of LaHabra

2) RTP p. 1, left col – “The 2012 RTP/SCS includes a strong

commitment to reduce emissions from transportation sources

to comply with SB 375, improve public health, and meet the

National Ambient Air Quality Standards as set forth by the

federal Clean Air Act.” 3) RTP p. 4, right col ‐ “This region needs

a long‐term, sustainable funding plan that ensures the region

receives its fair share of funding, supports an efficient and

effective transportation system that grows the economy,

provides mobility choices, and improves our quality of life.”

Comment noted. The 2012‐20

address comment, as approp

041‐28 Carlos

Jaramillo

City of LaHabra

2) RTP p. 1, left col – “The 2012 RTP/SCS includes a strong

commitment to reduce emissions from transportation sources

to comply with SB 375, improve public health, and meet the

National Ambient Air Quality Standards as set forth by the

federal Clean Air Act.

Comment noted. The 2012‐20

address comment, as approp

041‐29 Carlos

Jaramillo

City of LaHabra

3) RTP p. 4, right col ‐ “This region needs a long‐term,

sustainable funding plan that ensures the region receives its fair

share of funding, supports an efficient and effective

transportation system that grows the economy, provides

mobility choices, and improves our quality of life.”

Comment noted. The additio

excise gas taxes.

041‐30 Carlos

Jaramillo

City of LaHabra

5) RTP p. 40, left col ‐ “Strategic investments, put forth by the

private sector, that would remove barriers associated with

telecommuting are expected...”

Comment noted. The 2012‐20

address comment, as approp

041‐31 Carlos

Jaramillo

City of LaHabra

6) RTP p. 42, Table 2.2 ‐ 241 toll road completion year is 2030 Comment noted. Table 2.2 ha

completion year of 2030.

041‐32 Carlos

Jaramillo

City of LaHabra

7) RTP p. 50, left col – “scrip”, Please define in text and add to

glossary.

Comment noted. The 2012‐20

address comment, as approp

041‐33 Carlos

Jaramillo

City of LaHabra

8) RTP p. 54, right col ‐ “Despite our concerted effort to reduce

traffic congestion through years of infrastructure investment,

the region’s system demands continue to exceed available

capacity during peak periods.”

Comment noted. The 2012‐20

address comment, as approp

041‐34 Carlos

Jaramillo

City of LaHabra

9) RTP p. 70, 78 ‐SCAG seems to rely on CEQA to achieve the

"maximum feasible" reductions in emissions from

transportation. However, this is not consistent with the intent

of SB 375’s goal of achieving specific thresholds of 8% by 2020

and 13% by 2035 through a sustainable communities strategy

plan. Please provide clarification to this section indicating if the

air quality and greenhouse gas CEQA mitigation measures

obligate regional agencies and project developers to undertake

more strategies, programs and mandates beyond those

Comment noted. Demonstrat

the SB 375 requirements, the 

8% reduction target and exce

target. It is not SCAG's intent 

undertake more strategies, p

those included in the OC SCS. 

GHG emissions from the tran

the final RTP/SCS. In regard to 

does not intend to dictate mi
114

ID Name Affiliation Comment Re

included in the OC SCS. 10) RTP p. 78, right col ‐ On road

emissions (from passenger vehicles and heavy duty trucks)

constitute 93 percent of the transportation sector total.

Emissions from passenger vehicles, which are the subject of SB

375 and this RTP/SCS, constitute ___% of the transportation

sector’s greenhouse gas emissions total.” 11) RTP p. 80, left col ‐ 

Statements are made, such as, "the RTP has the ability to affect

the distribution of that growth" (in population in the region).

These statements could be interpreted to be contrary to SCAG's

obligation under the Memorandum of Understanding with

OCCOG to respect the strategies and local land use policies in

the OC SCS. Please clarify how it is in SCAG's ability to affect

local change when the OC SCS is consistent with acceptance of

local land use plans and planned population and employment

distribution? Recommended text change: “Transportation

projects including new and expanded infrastructure are

necessary to improve travel time and can enhance quality of life

for those traveling throughout the region. However, these

projects also have the potential to attract more of the regional

population growth in certain areas of the region. This means

that although SCAG does not anticipate that the RTP would

affect the total growth in population in the region, the RTP has

the ability to affect the distribution of that growth.

Transportation projects in the RTP also have the potential to

divide established communities, primarily through acquisition of

rights‐of‐way.”

language has been added to t

removal of specific reference

041‐35 Carlos

Jaramillo

City of LaHabra

RTP p. 82, right col ‐ Text indicates that the RTP and projects in

the RTP/SCS as “inducing” growth. It is noted that use of the

term “induced growth” has a negative connotation and implies

growth above and beyond what would occur naturally.

However, it is stated in the RTP that the population, housing,

and employment growth totals are fixed and only the

distributions may change based on the plan. This means there

will not be “new” growth and that the RTP and SCS may simply

influence and shift the growth anticipated for the region. This

moving of growth is the result of changes in distribution that are

due to changes in land use or densities. Because of this, it is

requested that references to “induced growth” be reworded to

reflect the shifting of growth in the region. Recommended text

change: “Cumulative impacts from the projected growth include

Comment noted. Clarifying la

RTP/SCS, including the remov

growth.
115

ID Name Affiliation Comment Re

increased impervious surfaces;...”

041‐36 Carlos

Jaramillo

City of LaHabra

12) RTP Ch. 3 ‐ SCAG’s Financial Plan includes a significant

portion of “New Revenue Sources and Innovative Financing

Strategies” that are not currently in place or available. While

some of the proposed revenues are within the control of SCAG

or MPOs and County Transportation Commissions, the majority

of the revenues (in terms of dollars) require either state or

federal action to implement. Please explain what the

implications are if these new revenue sources and innovative

financing strategies do not become available? 13) RTP p. 95,

Table 3.3 – Delete “Mileage‐based user fees would be

implemented to replace gas tax and augment—estimated at

about $0.05 (2011$) per mile and indexed to maintain

purchasing power starting 2025.” Suggested language is from

page 31 of Growth Forecast Appendix: “Current gasoline tax,

estimated at about $0.05 (2011$) per mile will increase through

2025, then in 2026 it would be replaced with a mileage‐based

user fee indexed to maintain purchasing power.”

Comment noted. The determ

with fiscal constraint as part o

requirements, are made at th

amendment. We recognize th

with certainty and therefore 

which were vetted through S

Committee and Policy Comm

the RTP/SCS. As we gain more 

options, we will update the fi

amendments and/or subsequ

At a minimum, an RTP is prep

years. The Growth Forecast A

accurately reflect the mileage

041‐37 Carlos

Jaramillo

City of LaHabra

14) RTP p. 105, right col ‐ “While the region was once known

worldwide as the “capital of sprawl,” the region today is

projecting growth on only a small fraction of the raw land

available in the region.” 16) p. 106 ‐ SCAG indicates that the OC

SCS has been incorporated into the regional SCS. OCCOG was

one of two subregions that undertook the arduous task and

obligation of preparing an SCS. Please add clarifying text that

these subregional SCSs, including the OC SCS, represent the

Sustainable Communities Strategies applicable to those

subregions. 17) p. 110, right col ‐ “Municipal water and sewer

systems, for example, ensure clean water. At the same time, as

areas become more urbanized and the percentage of

impervious surface is increased, the hydrologic regime is

dramatically altered. Drainage conveyances that once were

natural and riparian are required to be engineered as hardened

flood control channels to provide adequate protection of

private property and public infrastructure from the increased

frequency, duration, peak flow, and overall volume of

stormwater runoff. With this armoring of once natural channels,

water quality benefits from biofiltration are lost along with

opportunities for infiltration and evapotranspiration, which can

lead to hydromodifcation downstream in sections which are not

Comment noted. The 2012‐20

address comment, as approp

data can be found in the final 
116

ID Name Affiliation Comment Re

yet engineered and hardened. Many strategies...” 18) p. 112,

117 ‐ The SCS documents the development of four scenarios to

explore basic aspects of future growth. These scenarios were

used in public outreach and the SCS and the associated

Appendix states that “Using the public dialogue and feedback

from the analysis of the SCS Scenarios, SCAG developed the

2012 RTP/SCS Plan alternatives.” (Similar references are also

include at RTP/SCS p. 117, and SCS Background Documentation

p. 71). The RTP/SCS and Appendix then describes a process that

led to the Plan alternatives. Neither the RTP/SCS, Appendix or

PEIR expressly state or illustrate the fundamental land use and

socioeconomic foundation for the SCS. In order to confirm

consistency with the OC SCS, it is requested that SCAG include

appropriate tables, graphics and maps that provide the detail

that confirm this consistency.

041‐38 Carlos

Jaramillo

City of LaHabra

19) p. 113, 122 ‐ The regional SCS states that the

scenarios/alternatives were developed using the Local

Sustainability Planning Tool (LSPT). The LSPT is a sketch planning

tool that flattens geographical areas to a 5‐acre grid cell. The OC

SCS land use data was provided at much greater level of detail

in that specific parcel data and detail were provided by each

jurisdiction. A cursory review of some LSPT data reveals

inconsistencies regarding interpretation of Orange County land

uses. It is acknowledged that the regional SCS states, "Land use

inputs for OCCOG SCS were unchanged". Yet use of the LSPT

and SCAG Development and Community Types presented in the

SCS leave open the question as to whether the OC SCS was

altered, as noted above. Please provide confirmation that theunderlying OC SCS land use data was used without significant

alteration and LSPT flattening and interpretation in the

development of the regional SCS Plan and alternatives. 20) p.

127, right col – “Gentrification”, add to glossary 21) p. 128, left

col ‐ “Thus, this adjustment allowed the land use pattern to

conform more closely to local general plans, while reducing the

amount of vehicle miles traveled.” Whose/What are “local

expectations?” 22) p. 149, right col ‐ Revise language to clarifythat SCAG intends policies, strategies, and measures are a menu

of options. “The following tables list specific implementation

strategies that local governments, SCAG, and other stakeholders

may use or consider while preparing specific projects which

Comment noted. The subregi

GCCOG and OCCOG are incor

in their entirety, and as such, 

the regional plan for impleme

strategies included in the RTP

apply region‐wide. Land use i

were not changed per their s

final SCS Background Docum

Sustainable Communities Stra

updated to include clarifying 

as appropriate.
117

ID Name Affiliation Comment Re

would help to successfully implement the SCS.” 23) p. 150‐152 ‐

The OC SCS was accepted by SCAG and represents the set of

strategies and the growth distribution that outlines the best

approach for how the requirements of SB 375 would be met

within the subregion. Specifically, the OC SCS included 15

specific Sustainability Strategies, reflecting a menu of 222

practices and actions that OC agencies have agreed to pursue

(or continue to pursue) to achieve GHG reductions that support

SB 375. Why doesn’t the regional SCS specifically acknowledge

these 15 strategies yet include other strategies and

performance measures not included in the OC SCS (e.g.,

Locational Efficiency)? 24) p. 166, right col – “Greenfield”, add

to glossary

041‐39 Carlos

Jaramillo

City of LaHabra

25) p. 194, right col ‐ “In addition to these targeted outreach

efforts, all regular and special meetings of the RTP task forces,

the Transportation Committee (TC), the CEHD, the EEC, and the

SCAG Regional Council are publicly noticed and ...”

Comment noted. Text was am

committees that are publicly 

041‐40 Carlos

Jaramillo

City of LaHabra

26) p. 201 ‐ Please clarify whether the text stating “Long‐term

emission reduction for rail, with a goal of zero‐emissions rail

system” is intended to reflect a zero‐emissions freight rail

system, or whether this goal also applies to passenger rail.

Comment noted. This text ref

movement. However, any pla

system could apply to the reg

case of shared tracks. Further

discussed elsewhere in the RT

041‐41 Carlos

Jaramillo

City of LaHabra

27) p. 202‐203, Table 7.1 ‐ Unfunded operational

improvements, of which several are listed on page 203, Table

7.1, include transit station improvements in Irvine, Fullerton,

and Santa Ana, bus rapid transit (BRT) in Orange County, and

high speed rail (HSR) Phase II. Please confirm that these are

consistent with the OC SCS.

Comment noted. The subregi

OCCOG is incorporated into t

and as such, the policies and 

regional plan for implementa

041‐42 Carlos

Jaramillo

City of LaHabra

28) p. 207 ‐ Strategic Finance. Please explain what will happen if

reasonably foreseeable revenue sources of approximately $200

million do not become available?

Comment noted. The determ

with fiscal constraint as part o

requirements are made at the 

amendment. We recognize th

with certainty and therefore 

which were vetted through S

Committee and Policy Comm

the RTP/SCS. As we gain mor

options, we will update the fi

amendments and/or subsequ

minimum, a new or updated 

041‐43 Carlos City of La 29) p. 205 – “Active transportation”, add to glossary Comment noted. This term ha
118

ID Name Affiliation Comment Re

Jaramillo Habra

041‐44 Carlos

Jaramillo

City of LaHabra

Growth Forecast Appendix, p. 23, Table 13 ‐ In December 2011,

Orange County provided SCAG with the revised growth forecast

dataset, OCP‐2010 Modified, per the OC SCS MOU (official

OCCOG Board action 1/26/2012). Please incorporate revised

Orange County numbers (i.e. OCP‐2010 Modified) into all

reports, tables, exhibits, alternatives, maps, and modeling runs

for final RTP.

Comment noted. SCAG has in

Modified dataset into SCAG's 

the 2012 RTP/SCS updated al

narrative, modeling runs, and 

C referencing the Orange Cou

041‐45 Carlos

Jaramillo

City of LaHabra

PM Appendix p. 1 ‐ The document states, “The performance

measures are used to evaluate how well the RTP/SCS addresses

the adopted goals and performance outcomes.” Is there any

formal role for the performance measures? ARB will evaluate

for SB 375 compliance not based on these measures but based

on ARB process. Please include language clarifying that this is a

requirement to demonstrate compliance with federal

requirements and not for the obligations under SB 375. PM

Appendix p. 1, end of first paragraph ‐ Add statement:

“Performance measures and expected outcomes will be used to

monitor the RTP/SCS at the regional level; these measures and

outcomes are not proposed for use at the subregional or

project‐specific level.” PM Appendix p. 1, col 2 ‐ The document

states, “The Regional Council will formally adopt the goals and

outcomes as part of the final 2012 RTP/SCS.” Does this bring any

formal obligation to meet goals? Goals are general, flexible, and

aspirational rather than specific, as on p.1.

Comment noted. The Perform

describe and demonstrate qu

and impacts of the actions pr

regional scale, including meet

requirement under SB 375 to 

per capita basis by 8% in 2020 

condition. The proposed perf

with the best practices and co

requirements. The Performan

revised to state that the RTP/

not required for use at the su

041‐46 Carlos

Jaramillo

City of LaHabra

[PM Appendix] p. 13, Table 8 ‐ The RTP/SCS claims an extra 2%

CO2e emissions reduction in 2035 from the NHTS post‐

processing analysis. While the RTP/SCS meets the ARB SB375

goal without the extra 2%, we would like to note that the extra

2% could be important if the attorney general raises concerns

about backsliding. Consequently, the reliability of the extra 2%

reduction should be checked. Questions on the NHTS model are

below. It would be useful to know the answers to better judge

the quality, although we do note that the report does look like it

meets the standards or best practice. p. 9 ‐ NHTS Model

Documentation Report. Are the auto and bus accessibility

variables included in the regression models for 30‐mile rings? In

“Number of trips” model – is number of cars, included as an

independent variable, the actual or predicted value? The same

question applies to other models. p. 23, Table 10 ‐ NHTS Model

Comment noted. 1) The two g

indicators, with travel time as 

calculated: auto accessibility 

in the VMT model, and local b

mode choice model. Zone‐to‐

accessibility calculation reflec

transportation network, whic

based modeling analysis. 2) T

number of household vehicle 

using the model to estimate t

number of vehicles is estimat

Model” (predicted). 3) It is ca

averaged the result. 4) The 20

the 2012 RTP.
119

ID Name Affiliation Comment Re

Documentation Report. Were the elasticties for the SCAG NHTS

study calculated at sample means, or for each observation and

then averaged for the sample? p. 24, Test 3 ‐ NHTS Model

Documentation Report. (Compare Trip‐Based and NHTS Model):

The final test was to compare the results of the Trip‐Based

Model and the NHTS Model for the same scenarios. Please

describe the scenarios tested.

041‐47 Carlos

Jaramillo

City of LaHabra

Finance Appendix – What are the implications if revenues other

than core revenues do not become available? Please describe

any implications to the ability of the region to meet SB 375 GHG

emission reduction targets or the federally required air quality

conformity?

Comment noted. The majorit

available revenues (excluding 

to be available until the latter 

determination of the RTP’s co

part of meeting air quality co

at the time of plan adoption o

the future cannot be known w

reasonable assumptions, whi

Technical Advisory Committe

well documented in the RTP. 

funding options, we will upda

through amendments and/or 

appropriate. At a minimum, a

every four years.

041‐48 Carlos

Jaramillo

City of LaHabra

[SCS Background Appendix] p. 53, right col ‐ Housing Options

and Mix: Define Larger‐lot single family in text. p. 71‐74, 80‐83 ‐ 

Alternatives naming: A, B, C. Names of Alternatives differ than

those listed in the PEIR on pages ES‐3 and 1‐4. Please be

consistent with naming protocol for alternatives between

two/all documents. p. 71, right col ‐ “Plan Alternative (B)... The

alternative maintains city‐level forecast control totals for both

households and jobs, however, within city boundaries shifts are

made to focus a much larger share of future growth in a more

compact way around HQTAs, except in Gateway and Orange

County COG subregions per their SCS delegation agreements.

Future housing market demand is expected to shift significantly

to small lot single‐family, townhomes and multi‐family

housing.” [“housing” misspelled] p. 71, right col ‐ Plan

Alternative (B). Define small lot single family in text. p. 71, right

col ‐ Plan Alternative (C). “As a result very suburban

communities may experience no new housing or employment

growth, while some urban areas with very good access to

regional transit may experience significant increases in housing

Comment noted. The final SC

Subregional Sustainable Com

have been updated to add cla

comment, as appropriate.
120

ID Name Affiliation Comment Re

or employment growth.” p. 72, left col ‐ “While each alternative

is distinctive, a number of parameters remained constant across

each alternative: the regional RTP/SCS forecast total for

population, households and jobs;...” “Detailed forecast: the

detailed distribution of population, households, and jobs across

the region...” p. 72, Table D1 ‐ Alternatives A & B: “Controlled to

TAZ‐based RTP/SCS Forecast for 2020; Controlled to city‐level

RTP/SCS Forecast for 2020‐2035, except in Gateway and Orange

County COG subregions per their SCS delegation agreements.”

Add statement to table notes: Gateway and Orange County COG

subregions’ local input data will not be changed per their SCS

delegation agreements. p. 74, Table D2 – Alternatives A & B:

Add statement: Gateway and Orange County COG subregions’

local input data will not be changed per their SCS delegation

agreements. p. 75, right col ‐ “Development Types. The

alternatives are built on, and provides data at, the level of the

TAZ, which includes housing units and employment.” Please

clarify if TAZ is Tier 1, Tier 2, or both.

041‐49 Carlos

Jaramillo

City of LaHabra

[SCS Background Appendix] p. 79, right col ‐ “Subregional SCSs

submitted by the Gateway Cities Council of Governments

(GCCOG) and the Orange County Council of Governments

(OCCOG) will be unchanged and integrated into the alternatives

(with possible revisions for Alternative C only).” p. 79 ‐ The

section includes the following language: “Subregional SCSs

submitted by the Gateway Cities Council of Governments

(GCCOG) and the Orange County Council of Governments

(OCCOG) will be respected and integrated into the alternatives

(with possible revisions for Alternative C only).” Please clearly

indicate what the “possible revisions” are and what process

would be used to coordinate with Orange County should

changes to the socioeconomic data contained in the OC SCS be

proposed? p. 80 ‐ Alternative A. Add statement: “Gateway and

Orange County COG subregions’ local input data will not be

changed per their SCS delegation agreements.” p. 81 ‐ 

Alternative B. It is not clear whether Alternative B is the SCS

land use plan. If it is, statements in the appendix lead one to

believe the OC SCS foundation has been altered. For example,

adjustments made to land uses to locate proximate to High

Quality Transportation Areas (HQTA) and intensification of

residential and employment development in HQTA that diverge

Comment noted. The subregi

GCCOG and OCCOG are incor

in their entirety, and as such, 

the regional plan for impleme

strategies included in the RTP

apply region‐wide. Land use i

were not changed per their s

final SCS Background Docume

Sustainable Communities Stra

include clarifying language.
121

ID Name Affiliation Comment Re

from local General Plans as well as implementation of a vehicle

user fee are not part of the OC SCS. Is Alternative B the SCS land

use plan? Add statement: “Gateway and Orange County COG

subregions’ local input data will not be changed per their SCS

delegation agreements.” p. 115, left col ‐ Transit Zoning Code

Santa Ana 2011. Is this a duplicate of the 2010 Santa Ana

project?

041‐50 Carlos

Jaramillo

City of LaHabra

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

042‐01 Gayle

Ackerman

City of LakeForest

Concern with the timeline. We recognize the immense efforts it

took to prepare these documents. They are incredibly complex

documents establishing important and far‐reaching policy for

the region. However, because of this importance and

complexity, we would like to express concern about the timing

of the release of the documents. The timeline of document

release, public comment period, and time allowed for the

response to comments results in an inability to have credible

discussion regarding possible changes because the timeline

does not allow for recirculation or full discussion of requested

changes. The documents were released over the holiday season

and included the release of draft PEIR document on December

30, 2011. The minimum 45‐day public comment period closes

on February 14, 2012. Only a few weeks are provided to prepare

responses to comments and amend the documents to ensure

that the Regional Council may consider the certification of the

PEIR and the approval of the draft RTP/SCS on April 4, 2012.

Comment noted. The 55‐day 

period for the Draft 2012‐203

and Sustainable Communities 

14, 2012, and this process co

state requirements. During th

engaged in extensive outreac

the regional stakeholders, inc

transportation commissions, 

representatives from the priv

development of the draft RTP

that the comment period cou

to schedule constraints dictat

federal transportation confor

042‐02 Gayle

Ackerman

City of LakeForest

Growth Forecasts: It is requested that the adoption of the

growth forecast numbers by the Regional Council and/or Joint

Policy Committee be at the county level, consistent with past

RTPs. Planning documents need to be flexible. Smaller

geographic levels, such as at the subregional, city, census tract,

TAZ, parcel, or grid cell would limit jurisdictional control over

land use.

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use de

allocation being adopted at th

that the SCS be based on a ju

distribution.

042‐03 Gayle

Ackerman

City of LakeForest

The OCCOG Board approved the update to the OCP‐2010

dataset used in the OC SCS. OCP‐2010 Modified was officially

approved by the OCCOG Board on January 26, 2012 and is a

data amendment to the OC SCS. The dataset includes the 2010

Census population and housing data, along with the 2010 EDD

Benchmark data, consistent with SCAG's updated growth

forecast dataset. The dataset was provided to SCAG staff in

Comment noted. SCAGhas inc

Modified dataset into the SCA

for the 2012 RTP/SCS, and up

tables, maps, narrative, mode

Alternative C, referencing the 
122

ID Name Affiliation Comment Re

December 2011 and this is the formal notice of the update

which should be incorporated into the 2012 RTP/SCS, PEIR, and

related documents. To be consistent with the MOU on

subregional delegation between OCTA, OCCOG, and SCAG, all

documents, tables, maps, narratives, modeling runs, PEIR

alternatives (including Alternative C/3/Envision 2), and datasets

should be updated with the OCP‐2010 Modified numbers.

042‐04 Gayle

Ackerman

City of LakeForest

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

043‐01 Miles Mitchell City of Los

Angeles

LADOT has prepared the attached list of approximately 90

projects that the City is requesting to be added to the Strategic

Plan.

Comment noted. Projects pro

Strategic Plan have been add

043‐02 Miles Mitchell City of Los

Angeles

[LADOT] The City wishes to emphasize that, for future RTP/SCS

project lists, the City, Metro and SCAG need to continue the

effort to improve connectivity between various transit systems.

For example, in South Los Angeles County, there needs to be

greater emphasis placed on the development of feeder systems

to connect and support the Blue, Green, Expo and Crenshaw

lines. These systems would include, but not be limited to,

expanded Bus Rapid Transit and improved bicycle and

pedestrian linkages.

Comment noted. The RTP rec

between different transit mo

service and Active Transporta

reduce vehicle miles travelled

043‐03 Miles Mitchell City of Los

Angeles

LADOT wishes to draw attention to both the Los Angeles Bicycle

Plan and Mobility Hubs initiatives (a First Mile/Last Mile

strategy). These efforts support both the Active Transportation

and Transportation Demand Management strategies of the RTP.

The RTP includes numerous references to expanded bicycle

facilities and other First Mile/Last Mile strategies, and therefore

these strategies are presumably included with likely funding in

the Financially Constrained Plan. However, to the extent these

initiatives are not included in the Constrained Plan they should

be added to the Strategic Plan.

Comment noted.

043‐04 Miles Mitchell City of Los

Angeles

[Dept. of City Planning] (RE: Exhibits 2.5 and 4.11, Regional

Bicycle Network) It appears that the City's recently adopted

2010 Bicycle Plan for 1,684 miles of bike facilities across Los

Angeles is not included in this Exhibit. Some segments of this

bicycle network are in development and have been identified

for funding, and are therefore included in the 2012 RTP list of

transportation investments. Including the full proposed bicycle

network will support the long‐term commitment to pursue

resources for development of the network. The City

Comment noted. The Propose

has been revised to include th

Los Angeles' 2010 Bicycle Plan
123

ID Name Affiliation Comment Re

recommends that the SCS include the bicycle facilities identified

in the City's 2010 Bicycle Plan.

043‐05 Miles Mitchell City of Los

Angeles

[LADOT] Because the SCS will emphasize increased

development within 1⁄2 mile of either a “major transit stop or

high‐quality transit corridor” there may be an increased need

for transportation infrastructure in these areas. LADOT is

concerned that CEQA streamlining could allow development to

occur with impacts on transportation infrastructure. LADOT

staff has consulted with staff of DCP and the City Attorney

regarding the impact of CEQA streamlining on the City’s

development review process. Input received from these sources

indicates that although CEQA streamlining of various types will

occur following adoption of the RTP/SCS, the City may retain

some degree of “discretionary approval” authority over

development projects that are subject to CEQA streamlining.

LADOT believes that this area deserves further study. This is a

complex and important subject, and the City should carefully

evaluate and prepare for the impact of CEQA streamlining

following adoption of the RTP/SCS.

Comment noted. The TAZ‐lev

the purpose of modeling perf

local jurisdictions, maintain th

determine consistency of any 

043‐06 Miles Mitchell City of Los

Angeles

[Dept. of City Planning] Under SB375, the requirement to

prepare a SCS was coupled with incentives to encourage

sustainable development and implementation of an SCS. As any

proposed development is considered by local jurisdictions, this

CEQA relief is at the discretion of local jurisdictions. However, as

written, the RTP/SCS can be construed to indicate that CEQA

relief is part of the land use plan and is available by right to all

development that meets the qualifications. The City

recommends that the SCS better reflect the opportunity for

CEQA streamlining incentives through the following changes: 1)

In the discussion of the mandate to prepare an SCS (p. 106),

amend last sentence of the second to last paragraph to read: "In

addition, some projects consistent with the SCS may be eligible

for streamlined environmental review." 2) In Exhibits 4.1, 4.2,

and 4.3, remove the depiction of Transit Priority Project (TPP)

areas. Depicting this in these exhibits is confusing because a TPP

is not defined. Depiction of TPP boundaries detracts from the

purpose of the exhibits, which is to show where growth is

directed over the planning period of the RTP/SCS. 3) In

discussion of TAZs and development types (p. 122) remove

discussion regarding CEQA streamlining and adequacy of TAZ‐

Comment noted. The SCS Bac

has been updated to include 

comment, as appropriate.
124

ID Name Affiliation Comment Re

level land use information. This point is difficult to understand

as presented and requires further explanation. It pertains to

incentives available to jurisdictions/developers, not to the

modeling analysis. It detracts from the purpose of the section.

Delete the sentence beginning with, "Additionally, SB375 offers

local governments potential ..." and delete the following

sentence, "SCAG suggests that utilizing community types..." 4) A

reference to the summary of the CEQA incentive (p. 148) should

be included under the section "RTP/SCS Next Steps" and the

summary should be moved to follow this because the incentive

can be used to encourage/facilitate implementation of the SCS

and is therefore better understood as a next step. The summary

should include a discussion regarding a jurisdiction's discretion

in certifying the environmental review for a project, regardless

of eligibility for streamlining. 5) In the SCS Background

Documentation, a summary of the CEQA exemption (p. 84)

should include description of a jurisdiction's discretion in

certifying the environmental review for a project, regardless of

eligibility for streamlining.

043‐07 Miles Mitchell City of Los

Angeles

[Dept. of City Planning] The HQTA boundaries encompass all

neighborhoods within a 1/2 mile radius and appear the indicate

that growth will take place throughout the area, including low

density single‐family neighborhoods and industrial district. In

fact, the City is far more discriminating, and adopted land use

plans reflect carefully studies areas where growth can be

absorbed. Generally, land use changes to accommodate growth

are typically at transit stops and on parcels fronting transit

corridors. Single‐family neighborhoods are generally preserved.

The City recommends that additional explanation be included

on pages 112‐113 to better describe where growth is

accommodated. [Append to the discussion of HQTAs under the

first bullet "Development Location (Dispersed Growth vs.

Focused Development)" the following text]: "Within these

boundaries, growth within a given jurisdiction is consistent with

the integrated growth forecast for that jurisdiction and is

distributed according to the jurisdiction's land use plans. Thus,

while areas within 1/2 mile of a transit stop or corridor are

walkable in relation to transit, not all such areas are targeted for

growth and/or land use changes."

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

043‐08 Miles Mitchell City of Los [Dept. of City Planning] Exhibit 4.5, Urban Centers SCAG Region, Comment noted. Exhibit 4.5 s
125

ID Name Affiliation Comment Re

Angeles depicts the locations of urbanized core areas, or core centers.

However, these urban centers do not appear to align with the

urban centers identified in Exhibit 4.15 for areas within the City

of Los Angeles. The City recommends that the relationship

between Exhibit 4.5 and Exhibit 4.15 be clearly described. If the

two exhibits are intended to illustrate the same urbanized

areas, staff recommends that the color scheme used in Exhibit

4.15 also be used in Exhibit 4.5.

urban centers within the SCA

strategies such as compact co

development, redevelopmen

housing variety, and addition

more likely to succeed. Exhib

identifies the RTP/SCS overal

Los Angeles County. Urban ce

Community Types.

043‐09 Miles Mitchell City of Los

Angeles

[Dept. of City Planning] The SCS projects higher density in urban

centers, and anticipates growth in transit rich areas throughout

the City of Los Angeles in order to demonstrate a decrease in

GHG emissions by 2035. Staff compared the city's General Plan

Land Use to the SCS Land Use Pattern Maps and has found that

in general the SCS is consistent with the City's land use density

and land use designations. However, in closely examining 76 rail

and bus transit station areas, staff has found instances of

inflated density, which innaccurately reflects the General Plan

distribution of growth. Exhibit 21 Land Use Pattern Map 2035

identifies urban centers with densities that are not consistent

with community plans for these areas. Such centers would have

residential densities ranging from 82 to 120 housing units or

more per acre. This density is typical in the Central City and

some adjacent neighborhoods, and is proposed for Warner

Center, but is generally not appropriate throughout the rest of

the city. In addition, the following issues were found in multiple

station areas. Multi‐Family neighborhoods ‐ densities up to 178,

145, or 61 units/acre that are too high for may sites; densities

too high in areas adjacent to single‐family neighborhoods.

Single‐Family neighborhoods ‐ increase in density in strictly

single‐family areas that are stable and where no growth is

anticipated; parcels and corridors in HPOZ reflect density

designations that are too high, these areas are stable with no

projected change; residential uses reflected as commercial.

Commercial corridors ‐ density projections are too high.

Industrial land use ‐ industrial areas that are to be preserved as

industrial are inaccurately represented as commercial or retail;

industrial areas that show residential designations are an

inaccurate reflection as these sites are preserved. Public

facilities ‐ land use changes at school sites that are not

projected to change; high residential densities or commercial

Comment noted. In some cas

use assumptions to better ref

many transit‐rich areas of the 

to provide a regional strategy 

consider if they so choose, an

quantitative growth projectio

the region going forward, loc

use authority.
126

ID Name Affiliation Comment Re

uses projected on public facilities such as along freeways,

county jail, open space. The City recommends that more

appropriate representations of land use around station areas be

made, which can be identified on detailed annotation maps of

the station areas and provided under separate cover.

043‐10 Miles Mitchell City of Los

Angeles

[LAWA] Use of Airport Funds ‐ LAWA's first priority is to

maintain safe and efficient airports. All airports have a

tremendous demand for capital improvements. As such, most

airports depend on financial support from the FAA via grant

funds for eligible construction and noise mitigation projects. In

return for federal grant monies, the FAA includes grant

assurances that limit use of airport revenue solely for aviation‐

related uses on airport property. Using airport funds for non‐

airport functions violates federal law and jeopardizes the

airport's ability to receive federal grants. Nevertheless, LAWA

seeks to partner with SCAG to find solutions to support ground

access improvements to airports, other primary transportation

facilities, and "secondary" airports in the region. Use of Airport

Express Buses ‐ the RTP includes an "action step" which would

plan and promote a regional system of airport express buses,

modeled in part on the FlyAway service currently operating at

LAX. LAWA agrees that express buses are a promising solution

to certain ground access problems. However, it has been

LAWA's experience that express buses are most effective at

airports with high passenger demand and in cities with

concentrated populations of passengers and employees. Even

then, high fares or significant subsidies have been required to

maintain an effective level of service. LAWA invites SCAG to

continue examining ways to bring similar projects to other

airports, but cautions that these services, by themselves, may

not be effective in increasing passenger demand at "secondary"

airports. Aviation activity constraints ‐ LAWA agrees that the

aviation activity constraints in the region, and potential

dispersion of that activity at other airports, should be re‐

examined in subsequent regional plans. 2011 Air Passenger

Survey ‐ the 2006 LAX Air Passenger Survey was used to create

several data points within this section of the RTP. LAWA is

hoping to unveil the results of its 2011 Air Passenger Survey in

February of this year. SCAG should consider updating its

Appendix with this new data as it finalizes the RTP. LAWA will

Comment noted. SCAG recog

currently places strict limitati

for off‐airport purposes. To a

adopted regional aviation pol

that allows for more flexible u

airport ground access project

operators, and this policy con

RTP/SCS. SCAG welcomes con

coordination with LAWA in de

regional airport ground acces

buses are most effective at ai

demand, as discussed in the A

the 2012 RTP/SCS Aviation T

“FlyAways” serving airports o

have a significant impact on f

distributions. SCAG looks forw

identifying sites for viable new 

aviation activity constraints a

SCAG’s next (2016) Regional T

and resources constraints SCA

from LAWA’s recently release

into the 2012 RTP/SCS Airpor

Aviation Appendix. However, 

future updates to this report.
127

ID Name Affiliation Comment Re

post the results of this survey on our website (www.lawa.org)

once the report is completed.

043‐11 Miles Mitchell City of Los

Angeles

[LAWA] SCAG has reported a number of vehicle trips to LAX

under existing conditions and future 2035 forecast, citing the

LAX Master Plan EIR/EIS. However, the numbers reported do

not correspond to data that LAWA has previously reported or

used in any environmental analysis. LAWA requests clarification

on these data points. LAWA recommends the following changes

to Tables 4‐6 and 4‐7. In Table 4‐6, the following projects should

be included in the list of projects completed since the project

notice of preparation in 2008 (footnote 1): Douglas St, La

Cienega Blvd, Lincoln Blvd (all), Nash St, Sepulveda Blvd (both),

the I‐105 westbound off‐ramp at Sepulveda Blvd, and the I‐405

at SR‐90. Two other projects on Table 4‐6, Arbor Vitae St, and

the I‐405 from I‐10 to SR‐101, are under construction as of

January 2012. In Table 4‐7, Project LAX‐19, which includes

Lincoln Blvd improvements, has already been completed. LAWA

recommends that SCAG include in the RTP a portion of the

project referred to as LAX‐10, widening Aviation Blvd from

Century Blvd to Manhattan Beach Blvd to 3 lanes in each

direction.

Comment noted. The vehicle 

Master Plan EIR/EIS were not 

RTP/SCS Airport Ground Acce

prepared for different years (

the report, and were general

traffic volumes rather than da

trips shown in the Airport Gro

estimated using data and fact

variety of sources, including t2006 LAX air passenger surve

Aviation Cooperative Researc

Research Program. In genera

plan was used to approximate 

airport that was applied to th

project future traffic volumes

Access Report has been clarif

The Airport Ground Access Re

Appendixof the 2012 RTP/SCS 

the recommended changes to 

in Table 4‐6 and Table 4‐7.

044‐01 Brenda

Wisneski

City ofNewportBeach

It is requested that the adoption of the growth forecast

numbers by the Regional Council andlor Joint Policy Committee

be at the county level, consistent with past RTPs. Planning

documents need to be flexible . As time passes, what is possible

and feasible for any given project changes. These changes can

be due to market conditions, new information or data, or

infrastructure available that may shift when and where

development is possible. Smaller geographic levels, such as at

the subregional, city, census tract, TAZ, parcel, or grid cell would

limit jurisdictional control over land use. The OCCOG Board

approved the update to the OCP‐2010 dataset used in the OC

SCS. OCP‐2010 Modified was officially approved by the OCCOG

Board on January 26, 2012, and is a data amendment to the OC

SCS. The dataset includes the 2010 Census popu lation and

housing data, along with the 2010 EDD Benchmark data,

consistent with SCAG's updated growth forecast dataset The

dataset was provided to SCAG staff in December 2011, which

should be incorporated into the 2012 RTP/SCS, PEIR, and

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use de

allocation being adopted at th

that the SCS be based on a ju

distribution. SCAG will incorp

into the SCAG's final growth f

RTP/SCS/PEIR. The incorporat

might need to update all rela

narrative, modeling runs, PEI

C/3/Envision 2 referencing th

forecasts).
128

ID Name Affiliation Comment Re

related documents. To be consistent with the MOU on

subregional delegation between OCTA, OCCOG, and SCAG, all

documents, tables, maps, narratives, modeling runs, PEIR

alternatives (including Alternate C/3/Envision 2), and datasets

should be updated with the OCP‐201 0 Modified numbers.

044‐02 Brenda

Wisneski

City ofNewportBeach

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

045‐01 Chris Hughes City of Ontario We understand and have supported SCAG's efforts to

incorporate city growth plans into the regional planning

process. However, as in the past, we believe that the RTP/SCS

growth forecasts should be adopted at the county level, not the

city or sub‐city (TAZ) level. This would allow more flexibility in

dealing with inevitable changes in socio/economic trends within

the region and subregion.

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use de

allocation being adopted at th

that the SCS be based on a ju

distribution.

045‐02 Chris Hughes City of Ontario We have questions regarding the use of TAZ level data in the

CEQA Incentive program discussed on page 148. We are not

convinced that the land use scenarios and development types

created by SCAG for each TAZ are accurate. We would also like

to clarify that the only use of TAZ level data to be used by SCAG

in the future would be for the CEQA Incentive program and not

for growth projections.

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

045‐03 Chris Hughes City of Ontario In a separate letter (dated February 13, 2012, from Jerry Blum,

Planning Director) we requested that two important projects for

Ontario be included in the 2012 RTP. These projects were

requested via SANBAG and SCAG's consultant previously.

Comment noted. We have ad

to the project list as submitte

commissions through the sta

modification and FTIP databa

045‐04 Chris Hughes City of Ontario [PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

046‐01 Jason Samonte City of Oxnard Thank you for the opportunity to review the 2012‐2035

Regional Transportation Plan (RTP). The document presents a

comprehensive plan to accommodate future transportation

needs for the Southern California Region utilizing limited

resources. For the Ventura County Region the projections

indicate increasing congestion along the 101 Freeway Corridor

between Los Angeles and Ventura Counties. The surveys also

indicate that a majority of commuter in the Ventura County

Region commute alone. If this trend continues, it stands to

reason that an increase in population will be accompanied by an

increase of drive alone commuters. I support the investment in

Comment noted.
129

ID Name Affiliation Comment Re

transit and commuter rail services to encourage an alternate

form of transportation between Los Angeles and Ventura

Counties.

046‐02 Jason Samonte City of Oxnard As the economy expands in the region, there will be added

demand to transport goods by rail. This added demand will

result in lengthened cargo trains that will increase delay where

streets intersect railroad tracks at‐grade. Additional money

should be allocated for grade separations along primary arterial

roads. Grade separating will improve safety for vehicles, bicycles

and pedestrians as well as eliminate the need for the train to

blow their horn. It is doubtful that we can ever expand the

freeways sufficiently to fully accommodate the Regions vehicle

demands.

Comment noted. The amount 

RTP horizon are expected to i

increased delays, emissions, a

road/railway crossings. SCAG 

Transportation Commissions, 

Corridor East (ACE) Construct

regional grade separations. R

identified by these partners a

project list.

047‐01 Michael Behen City of

Palmdale

The City worked diligently with SCAG to develop the growth

projections for population, housing and employment data for

the 2008 (existing), 2020, and 2035 years. These growth

projections represent what we feel is a realistic growth rate

projection based upon the information available to us as well as

our understanding of City and Antelope Valley growth related

issues. Further, these numbers also reflect our draft RHNA

allocations. Therefore, it is our position that the adoption of the

growth forecast numbers continue to be done at the local level

and not at a larger subregional or county level.

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

047‐02 Michael Behen City of

Palmdale

The RTP does not mention the Palmdale Energy Action Plan

(PEAP) and we feel that there should be some type of reference

and/or acknowledgement of the City's efforts to address GHG

reduction. This issue was mentioned at several sub‐regional

coordinator meetings in which SCAG indicated that they would

include this in the document but did not.

Comment noted. SCAG comm

forward‐thinking Energy Actio

Chapter 2 of the Final RTP/SC

047‐03 Michael Behen City of

Palmdale

The RTP/SCS identifies strategies to reduce greenhouse gas

emissions from cars and light duty trucks. The City has concerns

related to the implementation of these proposed strategies.

These strategies should not be required individually but with

several discretionary options made available to the City to

satisfy GHG emission reduction goals.

Comment noted. While the S

policy foundation that local g

so choose, local jurisdictions 

047‐04 Michael Behen City of

Palmdale

The SED disaggregation at the TIER II TAZ level does not

correlate with the City's land use plan. Provide clarification on

methodology used. How will our city be able to make the

necessary consistency findings for projects that are eligible for

CEQA streamlining benefits if the modeling results do not match

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.
130

ID Name Affiliation Comment Re

our locally adopted General plan? this shall be clarified.

047‐05 Michael Behen City of

Palmdale

Page 156 of Aviation and Airport Group Access supplemental

document should be updated to reflect the reflect the California

High Speed Rial Authority's January 12, 2012, decision to

discontinue the study of the Grapevie alignment and to

continue the final study of an Antelope Valley Alignment and

station in the City of Palmdale.

Comment noted. The Airport 

Aviation Technical Appendice

been revised to incorporate t

proposed alignments for the 

047‐06 Michael Behen City of

Palmdale

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

048‐01 Bill Bogaard City of

Pasadena

The City of Pasadena supports the policies included in the RTP

to encourage the the expansion of local transit service to serve

as feeder systems to the regional transit to serve as feeder

systems to the regional transit network. However, the RTP does

not address the limited funding resources that local agencies

have in providing these important services. We would like the

RTP to identify additional funding resources to expand local

transit services and include policies that expand the availability

of funding for local transit providers.

Comment noted. The distribu

transportation investments in 

tax measure commitments ap

transportation commission adplans, limitations associated w

other previous commitments

048‐02 Bill Bogaard City of

Pasadena

I believe you are aware of the active role Pasadena has played

over a long period regarding any freeway connection that

traverses our community. The issueof the 710 North extension,

albeit being a tunnel alternative as opposed to a surface

freeway, continues to be a sensitve topic amoung our elected

officials, neighborhood groups, and city residents. We request

that the RTP recognize the on‐going environmental study for

this facility and not presuppose the ongoing studies by defining

the route for the 710 north extension project.

Comment noted. SCAG recog

environmental analysis is und

that effort and selection of a 

SCAG will work with Metro to 

update the project descriptio

analysis.

048‐03 Bill Bogaard City of

Pasadena

The City of Pasadena would like the regional transit connection

between the North Hollywood Red Line /Orange Line Station

and the Gold Line in Pasadena via Burbank and Glendale

included in the RTP. This is an important transit project for our

sub‐region, and should be included in the RTP and should be

considered for implementation using reasonably available

funding sources described in the RTP Financial Plan.

Comment noted. This transit 

Strategic Plan as project ID #S

049‐01 Arturo

Cervantes

City of Pico

Rivera

East‐West Freight Corridor Program: The City supports the

proposal for the East‐West Freight Corridor Program. The City

agrees the Southern California regional freeway system

represents one of the highest volume goods movement

corridors in the United States and is of major importance to the

Comment noted. SCAG’s anal

identified alignment would p

facility away from neighborho

versus other routes that were 

note that the alignment ident
131

ID Name Affiliation Comment Re

distribution of consumer goods. We understand major freeways

such as Interstate 605 and State Route 60, are impacted by high

volumes of truck traffic and truck volumes that will increase

through 2035 by 260% or more. For this reason, the City

supports the East‐West Freight Corridor Program as the solution

address the goods movement in the region. We recognize that

the RTP/SCS identifies and recommends a corridor concept that

would connect to the north end of the I‐710 freight corridor,

roughly parallel the Union Pacific Railroad (Los Angeles

Subdivision) before finally following a route adjacent to SR‐60

east of SR‐57. This grade‐separated concept considers the use

of the Union Pacific Railroad Corridor (UPRR Corridor), between

I‐710 and I‐605, through the City of Pico Rivera. The RTP/SCS

further states that the potential use of two non‐roadway routes

provides an opportunity to move the facility away from

neighborhoods and closer to the industrial activities that it

would serve. This could not be further from the truth, especially

when considering the existing land use along said Corridor is

residential. The statement that this alignment provides an

opportunity to move the facility away from neighborhoods is

erroneous as it relates to the City of Pico Rivera. The proposed

dedicated truck lanes, forecasted to carry from 58,000 to 70,000

trucks per day, will result in the rerouting of truck traffic from

major freeways through the City of Pico Rivera. In effect, the

program would build a new freeway through Pico Rivera

dedicated to truck traffic (truck dedicated freeway). The City of

Pico Rivera opposes any corridor alignment that includes the

segment of the UPRR Corridor between the 710 Freeway and

the 605 Freeway. This proposal splits the City in half, requires

significant residential, industrial, and commercial property

acquisition, and has aesthetic impacts unacceptable to the City.

This proposal is unacceptable to the city and we oppose it. The

City respectfully requests that potential routes for the East‐

West Freight Corridor be limited to freeway routes only, and the

non freeway routes not be further considered. The subject

UPRR Corridor segment can be supplanted with the segment of

the State Route 60, between the Interstate 710 and the

Interstate 605. SCAG should effectively evaluate the connection

between the two freeways to make this option feasible. As

stated in the enclosed City Council Resolution approved on

would be analyzed in greater 

Impact Report (EIR). Appropr

completed through the EIR w

the East‐West Freight Corrido

adjacent local facilities. Placin

concept in the 2012 RTP allow

to continue to work closely w

such as Pico Rivera.
132

ID Name Affiliation Comment Re

October 25, 2011, the City of Pico Rivera supports the East‐West

Freight Corridor Program and supports alternative regional

goods movement plans that equitably distribute truck traffic

between the Interstate 710 and Interstate 15 through the

expansions of the existing freeway system. However, for the

reasons stated above, the City of Pico Rivera opposes any SCAG

proposal for dedicated truck lanes along the Union Pacific

Railroad Corridor, in the City of Pico Rivera.

049‐02 Arturo

Cervantes

City of Pico

Rivera

California High Speed Rail: The RTP/SCS includes options for

high speed rail. The City is concerned about the feasibility of

such a project in California. We understand that discussions are

ongoing among SCAG, the County Transportation Commissions,

and the California High Speed Rail Authority regarding levels of

available funding for rail infrastructure improvements within

the SCAG region. We look forward to further details about the

specific investments that will be made in Southern California's

rail infrastructure under the RTP/SCS, particularly those that

affect the City of Pico Rivera. At this time, the RTP/SCS proposes

three Passenger Rail strategies that will provide additional

travel options for long‐distance travel within the region and to

neighboring regions. The City understands these improvements

to be to the Los Angeles‐San Diego (LOSSAN) Corridor,

improvements to the existing Metrolink system, and the

implementation of Phase I of the California High‐Speed Train

project. The City would support such improvements only if to

enhance the existing rail system through Pico Rivera, and not

add supplementary rail lines within new corridors that would

require significant residential/industrial/commercial property

acquisition.

Comment noted.

049‐03 Arturo

Cervantes

City of Pico

Rivera

Goldline Eastside Transit Corridor Phase II: The RTP/SCS

estimates that the Goldline Eastside Transit Corridor will be

completed by 2035. However, the need for mass transit in the

eastside area is greatly underestimated and should be included

as a high priority project. The Goldline Eastside Transit Corridor

was also included as a project in the regional SCS as it will

greatly help to reduce the effects of greenhouse gases. As such,

the City of Pico Rivera requests that the Goldline Eastside

Transit Corridor be a high priority project both in the RTP/SCS

and in the bienniel 2011 Federal Transportation Improvement

(FTIP) update.

Comment noted. Project com

2012 RTP/SCS by project spon

transportation commission. I

Eastside Transit Corridor Phas

supplied by the Los Angeles C

Transportation Authority (Me

with Metro to amend any fina

yet to be selected Locally Pre

findings from the yet forthco

documents into the RTP.
133

ID Name Affiliation Comment Re

049‐04 Arturo

Cervantes

City of Pico

Rivera

Financial Plan: Table 3.3, New Revenue Sources and Innovative

Financing Strategies of the RTP/SCS Financial Plan lists Mileage‐

Based User Fee as a replacement to the gasoline tax. This is a

new fee that may affect lower‐income residents within the

Gateway Council of Governments region. Please advise how the

fees would be implemented and how they may affect lower

income residents.

Comment noted. The project

based user fee and adjustme

taxes when combined with th

and federal sources generate 

average increase in state and 

sources of five percent annua

continuation of the historical 

with federal requirements, w

to stabilize state and federal t

consistent with recommenda

commissions established by C

addition to efforts underway 

lay‐out an implementation pl

in the Transportation Finance 

implementation plan will be s

disproportionate impacts to u

050‐01 Nate

Farnsworth

City of Rancho

SantaMargarita

Concern with the timeline. We recognize the immense efforts it

took to prepare these documents. They are incredibly complex

documents establishing important and far‐reaching policy for

the region. However, because of this importance and

complexity, we would like to express concern about the timing

of the release of the documents. The timeline of document

release, public comment period, and time allowed for the

response to comments results in an inability to have credible

discussion regarding possible changes because the timeline

does not allow for recirculation or full discussion of requested

changes. The documents were released over the holiday season

and included the release of draft PEIR document on December

30, 2011. The minimum 45‐day public comment period closes

on February 14, 2012. Only a few weeks are provided to prepare

responses to comments and amend the documents to ensure

that the Regional Council may consider the certification of the

PEIR and the approval of the draft RTP/SCS on April 4, 2012.

Comment noted. The 55‐day 

period for the Draft 2012‐203

and Sustainable Communities 

14, 2012, and this process co

state requirements. During th

engaged in extensive outreac

the regional stakeholders, inc

transportation commissions, 

representatives from the priv

development of the draft RTP

that the comment period cou

to schedule constraints dictat

federal transportation confor

050‐02 Nate

Farnsworth

City of Rancho

SantaMargarita

It is requested that the adoption of the growth forecast

numbers by the Regional Council and/or Joint Policy Committee

be at the county level, consistent with past RTPs. Planning

documents need to be flexible. As time passes, what is possible

and feasible for any given project changes. These changes can

be due to market conditions, new information or data, or

infrastructure available that may shift when and where

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use de

allocation being adopted at th

that the SCS be based on a ju

distribution.
134

ID Name Affiliation Comment Re

development ins possible. Smaller geographic levels, such as at

the subregional, city, census tract, TAZ, parcel, or grid cell would

limit jurisdictional control over land use.

050‐03 Nate

Farnsworth

City of Rancho

SantaMargarita

Please define what is meant by various terms in the RTP/SCS

and draft PEIR. Because mitigation measures are intended to be

implementable and measurable in order to evaluate the

effectiveness of the measures, it is important for the measures

to clearly indicate what actions are expected to be undertaken.

These include, but are not limited to: o Urban Growth Boundary

o Parking Cash Out o References to benchmarks o Smart growth

principles o SCRIP o Active Transportation o Gentrification o

Greenfield o Open space

Comment noted. Several of t

glossary.

050‐04 Nate

Farnsworth

City of Rancho

SantaMargarita

The OCCOG Board approved the update to the OCP‐2010

dataset used in the OC SCS. OCP‐2010 Modified was officially

approved by the OCCOG Board on January 26, 2012 and is a

data amendment to the OC SCS. The dataset includes the 2010

Census population and housing data, along with the 2010 EDD

Benchmark data, consistent with SCAG's updated growth

forecast dataset. The dataset was provided to SCAG staff in

December 2011 and this is the formal notice of the update

which should be incorporated into the 2012 RTP/SCS, PEIR, and

related documents. To be consistent with the MOU on

subregional delegations between OCTA, OCCOG, and SCAG, all

documents, tables, maps, narratives, modeling runs, PEIR

alternatives (including Alternate C/3/Envision 2), and datasets

should be updated with the OCP‐2010 Modified numbers.

Comment noted. SCAG has in

Modified dataset into the SCA

for the 2012 RTP/SCS update

maps, narrative, modeling ru

Alternate C referencing the O

050‐05 Nate

Farnsworth

City of Rancho

SantaMargarita

Finally, the City has participated in providing comments through

the OCCOG Technical Advisory Committee (TAC). Rather than

incorporating those comments into this comment letter

verbatim, the City requests that the comments provided by the

OCCOG TAC be incorporated into the City's comments by

reference.

Comment noted.

050‐06 Nate

Farnsworth

City of Rancho

SantaMargarita

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

051‐01 Steve Hayes City of

Riverside

1. The SCS includes projected land use patterns for 2035 using

High Quality Transportation Corridors. In the City of Riverside,

this includes Bus Rapid Transit (BRT) and Metrolink Lines similar

to the City’s General Plan 2025. However, the land use patterns

in the SCS were applied at the Transportation Analysis Zones

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.
135

ID Name Affiliation Comment Re

(TAZ), which incorporate large areas of land that may contain

drastically varying land uses or developable land. Using this map

for consistency with the City’s General Plan 2025 would be very

problematic. For instance, maintaining land use consistency

between the General Plan and the prescribed TAZ map along

the Alessandro Boulevard BRT corridor would force the City to

direct growth to areas such as the Sycamore Canyon Wilderness

Park (a natural open space conserved by the County Multiple

Species Habitat Conservation Plan) and along hillsides and

arroyos, which have already been developed to their maximum

density based upon their natural characteristics. The area near

the La Sierra Metrolink Station is another part of the City where

increasing density using the prescribed TAZ map would result in

directing density into a protected area. The City’s Greenbelt, a

protected agricultural area which lacks the infrastructure to

support the proposed density, encompasses a large section of

the City in this area and would be impacted by the proposed

growth.

051‐02 Steve Hayes City of

Riverside

Generally, the SCS map is in conformance with the City’s

General Plan 2025 and its intent. However, using TAZ’s rather

than parcels and following the logistics of the City’s natural

characteristics causes some problems in creating General Plan

consistency.

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

051‐03 Steve Hayes City of

Riverside

Page 148 of the RTP/SCS describes how consistency within a

TAZ can be averaged. However, the projected growth in some of

the TAZ’s located within the City of Riverside is not feasible due

to various constraints, including a lack of infrastructure, habitat

conservation efforts, and topography. The City’s General Plan

accounts for these constraints and is consistent with the overall

intent of the SCS, however it directs density to where it is

appropriate along these same corridors. This is consistent with

Smart Growth principles, which advocate for protecting

sensitive open space areas and placing density in urban areas

where infrastructure already exists.

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

051‐04 Steve Hayes City of

Riverside

The City aims to be consistent with the SCS but cannot achieve

this at the TAZ level. Is there another option? Especially since

the City’s General Plan 2025 currently meets the overall intent

of the SCS, but does so based upon the City’s natural

characteristics.

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

051‐05 Steve Hayes City of Socio‐economic Data for Riverside County was revised by SCAG Comment noted. SCAG has in
136

ID Name Affiliation Comment Re

Riverside based upon the 2010 Census. These revisions were presented to

the Executive Committee of WRCOG and approved in December

of 2011. Will the plans and Draft PEIR be updated to reflect this

new information?

dataset into the final growth 

RTP/SCS and updated all relat

narrative, modeling runs, and 

051‐06 Steve Hayes City of

Riverside

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

052‐01 George

Scagborough

City of San

Clemente

The City concurs with the OCCOG and OCTA comments. The City

of San Clemente concurs with the comments SCAG will receive

from the OCCOG and the Orange County Transportation

Authority (OCTA). The City requests SCAG to respond to all of

their comments and to act upon any changes advocated by

OCCOG, of which the City is a member agency.

Comment noted.

052‐02 George

Scagborough

City of San

Clemente

The General Plan and Zoning maps for the City are not accurate.

SCAG's website allows member agencies to review the maps

that would be used for the Draft RTP/SCS and PEIR. We

reviewed the latest map files and concluded they are not

accurate. The City worked closely with SCAG staff on several

occasions to ensure SCAG has accurate maps for the City of San

Clemente. Please update the map files to reflect the comments

we previously provided.

Comment noted. The map file

have been updated to addres

052‐03 George

Scagborough

City of San

Clemente

Growth forecast numbers should be at the county level

consistent with previous RTPs. The 2012 RTP‐SCS, like other

planning documents, has been written based on assumptions,

market conditions, forecasts, project lists, budgets, datasets,

public opinion, and other information that can change after the

2012 RTP‐SCS is adopted. Therefore, it is important for the 2012

RTP‐SCS to project growth at the county level so cities and

counties have the flexibility to respond to these changes when

future land use decisions are made. If smaller geographic levels

are used (e.g. subregions, cities, census tracts, Transportation

Analysis Zones, parcels, or grid cells), it is less likely the 2012

RTP/SCS will forecast actual growth patterns. Therefore, please

keep all growth forecast numbers at the county level. This has

been the precedent for previous RTPs.

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use de

allocation being adopted at th

that the SCS be based on a ju

distribution.

052‐04 George

Scagborough

City of San

Clemente

OCP‐2010 modified numbers should be used. On January 26,

2012, the OCCOG Board of Directors approved an updated

version of the OCP‐2010 dataset for use in the OC SCS. The

dataset includes the 2010 Census population and housign data,

along with the 2010 EDD Benchmark data, consistent with

SCAg's updated growth forecast dataset. The updated OCP‐2010

Comment noted. SCAG has in

Modified dataset into the SCA

for the 2012 RTP/SCS update

maps, narrative, modeling ru

Alternate C referencing the O
137

ID Name Affiliation Comment Re

dataset was provided to SCAG staff in December 2011. The City

requests for all 2012 Draft RTP/SCS/PEIR documents, tables,

maps, narratives, modeling runs, PEIR alternatives (including

Alternate C/3/Envision 2), and datasets to be updated with the

latest OCP‐2010 numbers per the OCTA/OCCOG/SCAG

Memorandum of Understanding (MOU) that established Orange

County's subregional delegation.

052‐05 George

Scagborough

City of San

Clemente

The OC SCS should be fully integrated into the regional RTP/SCS.

The RTP and appendices include numerous references to the OC

SCS and SCAG's total use of the document in the regional

RTP/SCS. Yet numerous other references suggest SCAG may

have modified elements of the OC SCS data. SCAG should

include a statement maps, tables, charts, and other information

that is necessary to confirm all of the OC SCS land use,

socioeconomic, and transportation data was incorporated into

the regional RTP/SCS without changes. SCAG staff told the

OCCOG Board (at several meetings) the OC SCS data has not

been and will not be altered. the OC SCS is to be integrated into

the regional SCS without changes per the Memorandum of

Understanding (MOU) between OCCOG and SCAG.

Comment noted. The subregi

GCCOG and OCCOG are incor

in their entirety, and as such, 

the regional plan for impleme

strategies included in the RTP

apply region‐wide. Land use i

were not changed per the MO

delegated subregions. The fin

Documentation, and final Sub

Strategies Appendices have b

language.

052‐06 George

Scagborough

City of San

Clemente

Mileage‐based user fee. The draft RTP suggests $127.2 billion of

the approximately $219.5 billion regional shortfall can be

addressed through actions at either the state or federal level

with a $0.15 gas tax increase between 2017 and 2024. After

that, the draft RTP assumes the state or federal government

would either replace the gas tax with an indexed mileage‐based

user fee of $0.05 per mile, beginning in 2025, or further

increase fuel taxes to generate revenues equivalent to the

mileage‐based user fee. The City of San Clemente cannot

support an increase in fees, including the introduction of a

mileage‐based user fee, until further economic analysis is

completed and presented to the City for discussion. In addition,

when considering support for any kind of a new user‐based fee

program, an emphasis must be placed on the need for a return‐

to‐source criteria, as well as a process for recognizing and

rewarding areas which commit additional local revenues.

Comment noted. The project

based user fee and adjustme

taxes when combined with th

and federal sources are less t

in state and federal transport

percent annually. Rather than 

the historical growth rate, wh

requirements, we detailed sp

state and federal transportat

with recommendations from 

established by Congress throu

economic impacts of the RTP 

RTP/SCS, Economic and Job C

coordinate with SCAG staff to 

present this matter to the Cit

return‐to‐source and rewardi

substantial strides to obtainin

items for any new revenue so

052‐07 George

Scagborough

City of San

Clemente

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P
138

ID Name Affiliation Comment Re

053‐01 Tim Hults City of San

Jacinto

Thank you for the opportunity to comment on the 2012‐2035

Draft RTP/SCS. Please consider this an official position of

support for Amendments 11‐03 and 11‐06, and especially

Project ID RIV62024. Should have any questions or comments,

please contact me at the number listed below.

Comment noted.

054‐01 Rosa Barela City of Santa

Ana

The growth forecast numbers included in the draft 2012 RTP

should allow for reasonable market flexibility. Thus, it is

recommended that the growth projections be incorporated and

adopted at a County level. Adoption of population, employment

and housing growth projection at any smaller geography could

introduce unnecessary and unintended challenges for cities and

the development community to make reasonable adjustments

to land use approvals; and potential inconsistency with the

adopted Regional Transportation Plan.

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use de

allocation being adopted at th

that the SCS be based on a ju

distribution.

054‐02 Rosa Barela City of Santa

Ana

The Orange County Projections (OCP) are developed every three

to four years in cooperation with each individual jurisdiction in

Orange County, to reflect the anticipated growth for our

communities. We respectfully request that the Regional

Transportation Plan be refined to include the latest "OCP 2010‐

Modified" version that incorporates the 2010 Census and more

recent State employment data.

Comment noted. SCAG will in

dataset into the SCAG's final g

2012 RTP/SCS.

054‐03 Rosa Barela City of Santa

Ana

The City of Santa Ana appreciate the significant resources and

collaborative efforts required to develop the 2012 SCAG RTP;

particularly with the SB 375 requirement to incorporate a SCS to

integrate land use and transportation planning to promote

sustainable communities.

Comment noted.

054‐04 Rosa Barela City of Santa

Ana

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

055‐01 Julie Skinner City of Santa

Clarita

On behalf of the Santa Clarita City Council, I am writing to

request that the Orange Line Development Authority's Northern

Corridor be included within SCAG's RTP Constrained Projects

List. The Orange Line Development Authority, of which the City

of Santa Clarita is a member, is committed to the development

of a high speed, grade separated, environmentally friendly and

energy efficient transportation system. In recent months, the

OLDA Northern Corridor, from downtown Los Angeles to Santa

Clarita, has been the focus of intense review and investment.

These activities position OLDA's Northern Corridor to be placed

within the Constrained Project's List, as opposed to the RTP's

Strategic Plan.

Comment noted. For a projec

the constrained RTP, the proj

have reasonably available fun

construction and right of way 

concurrence of the relevant c

commission/s. As discussed w

Authority, the Northern Corri

inclusion in to the future RTP 

conditions are satisfactorily m

section of the Passenger Rail 

developments brought up in 
139

ID Name Affiliation Comment Re

055‐02 Julie Skinner City of Santa

Clarita

Los Angeles County Metropolitan Transportation Authority is

currently conducting the Antelope Valley Line Infrastructure

Improvement Strategic Plan. This plan anticipates the

identification of specific projects which can be undertaken in

the corridor to enhance service and safety. This study will be

completed in spring 2012.

Comment noted. The Antelop

Improvement Strategic Plan i

Passenger Rail appendix; as it 

will be incorporated into subs

055‐03 Julie Skinner City of Santa

Clarita

The Regional Council's approval earlier this month of a

Memorandum of Understanding with the California High Speed

Rail Authority and transportation commissions paves the way

for placement of the statewide high speed rail project within

the RTP Constrained Projects List, as the alignment for the high

speed rail project falls within the OLDA Northern Corridor.

Furthermore, the $1 Billion included within the Memorandum

of Understanding contemplates expenditures within the OLDA

Northern Corridor during the 2012 RTP horizon. It is also widely

anticipated that some of the recommendations identified in the

Antelope Valley Line study will also be incorporated into the

project list that serves as the implementation of the MOU.

Comment noted.

055‐04 Julie Skinner City of Santa

Clarita

Finally, the Ground Access Study being conducted by the

Burbank‐Glendale‐Pasadena Airport Authority and OLDA

focuses on multi‐modal transportation improvements that will

enhance the linkage between the airport, the OLDA Northern

Corridor, and communities, such as Santa Clarita, located within

the corridor. Clearly, the current study activity along the OLDA

Northern Corridor, coupled with specific inclusion of the

California High Speed Rail Authority's proposed project along

the same corridor, demonstrates that the OLDA Northern

Corridor meets the critera for being included within the RTP

Constrained Projects List. Within the forseeable future, it is

reasonable to conclude that significant investments will likely be

made in the corridor, in conformance with SCAG's criteria for

inclusion of projects within the Constrained Projects List. On

behalf of the Santa Clarita City Council, In encourage SCAG staff

and the Regional Council to include the OLDA Northern Corridor

within the 2012 RTP Constrained Projects List.

Comment noted. As discussed 

Development Authority, the N

the Constrained Plan through 

However, the Orangeline sect

will reflect the developments 

056‐01 Julie Skinner City of Santa

Clarita

The purpose of the RTP is to provide a blueprint for future

transportation projects and strategies throughout the SCAG

region through 2035. Included within the RTP is a financial plan

that identifies funding available to support the region's

transportation investments, including transit, highways, local

Comment noted. We acknow

needed before the mileage‐b

effective, which is basis for as

begins after 2025. The inclusi

based on recommendations f
140

ID Name Affiliation Comment Re

road improvements, system preservation, and demand

management goals. Central to the financial plan is the

identification of funding resources the RTP identifies as

"reasonably available" for future projects. The City has prepared

the following comment regarding the financial plan included

within the RTP (Chapter 3): Based on its identification as a

"reasonably available" funding resource, the City requests

additional information on increased gas taxes on mileage‐based

user fees as mandatory action items. Over 50 percent of

commuters that live in the City work outside of the Santa Clarita

Valley. As a result, an increase in gas tax or a mileage‐based

user fee could result in significant financial impacts on the local

labor pool (Page 95, table 3.3).

established by Congress throu

sustainable transportation re

efforts underway throughout 

implementation plan for the 

Transportation Finance Appe

implementation plan will be s

disproportionate impacts to u

056‐02 Julie Skinner City of Santa

Clarita

As required by AB 32 and SB375, this cycle's RTP includes a SCS.

The SCS functions as a mechanism to ensure the SCAG region

can achieve mandated GHG reductions of 8% per capita by 2020

and 13% per capita by 2035. The draft SCS included in the RTP

concludes these targets can be met through a specific land use

scenario, called Scenario 2. The scenario was compiled using a

variety of data inputs, including a series of workshops hosted by

SCAG in a number of communities throughout the region and by

working directly with staff at local jurisdictions. The SCS then

models GHG based on a variety of factors. Central to Scenario 2

is a shift from larger lot residential development to smaller lot

residential development, including more emphasis on

multifamily housing. In addition, the scenario assumes a much

higher level of infill and mixed‐use development than historical

development patterns. The City has prepared the following

questions and comments regarding the SCS (Chapter 4 of the

RTP): For clarity, the scenarios in the RTP should be titled in a

consistent manner with the alternatives included in the

Sustainable Communities Strategy background documentation.

The City assumes "Scenario 2" from the RTP is the same as

"Alternative B" in the SCS Background documentation.

Comment noted. Plan "Altern

sketch "Scenario 2." The Fina

to address comment.

056‐03 Julie Skinner City of Santa

Clarita

Throughout the chapter, the RTP refers to Appendix 19. SCAG

staff has indicated Appendix 19 is now referred to as the "SCS

Background Documentation," however, this is not reflected in

the current draft (page 112).

Comment noted. The Final 20

address the comment.

056‐04 Julie Skinner City of Santa

Clarita

Whereas, Santa Clarita agrees with the assumptions contained

in the land use Scenario 2 for the region, it should be noted it is

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 
141

ID Name Affiliation Comment Re

unlikely a similar pattern will occur in the Santa Clarita Valley.

Although the City's new General Plan, adopted in June 2011,

stresses mixed‐use and transit‐oriented development,

significant green‐field development is still contemplated within

the time horizon of the RTP (Page 115, Figure 4.3)

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as

trends occurring in many tran

the SCS is intended to provide 

governments may consider if 

includes the quantitative grow

county in the region going for

local land use authority. Lead 

jurisdictions, maintain their o

consistency of any future pro

056‐05 Julie Skinner City of Santa

Clarita

It is unclear how the two areas identified in Ventura County can

be considered "urban areas" on par with those identified in Los

Angeles, Orange, Riverside and San Bernardino counties. By

comparison to those areas identified in Ventura County, the

State Route 14 corridor between the cities of Santa Clarita,

Palmdale, and Lancaster services a local population of over

700,000 residents and represents a substantial proportion of

the new growth in Los Angeles County (Page 125, Exhibit 4.5).

Comment noted. The urban c

examples of areas in each cou

compact community design, m

redevelopment of aging retai

and additional transit service 

056‐06 Julie Skinner City of Santa

Clarita

One of the three High Quality Transit Areas referenced in the

exhibit is the Downtown Newhall area. This area is defined by

the Downtown Newhall Specific Plan and is the primary focus of

the City's former Redevelopment area. However, given the

uncertainty surrounding former redevelopment areas, it is

unlikely this location will be able to provide the same type of

transit‐oriented development and infill contemplated by the

Downtown Newhall Specific Plan (Page 134, Exhibit 4.9).

Comment noted. While the S

strategy that local governmen

and generally includes the qu

each city and county in the re

jurisdictions maintain local la

that the elimination of RDAs 

to finance various local plans 

the policies in the 2012 RTP/S

funding resources for local go

056‐07 Julie Skinner City of Santa

Clarita

The RTP includes future projects in at least two sections: the

Constrained List, which is comprised of projects that have

identified funding, and the Strategic Plan, which is comprised of

projects requiring more study and which lack identified funding.

The City has prepared the following comment regarding

projects included in the Strategic Plan and not included in the

Constrained Plan (Chapter 7): SCAG should consider including

the Orangeline High‐Speed Transit Project (Union Station to

Santa Clarita) in the Constrained List rather than the Strategic

Plan, due to the fact the Los Angeles County Metropolitan

Transportation Authority has recently accelerated the

evaluation of rail improvements along the Antelope Valley Line

Comment noted. For a projec

the constrained RTP, the proj

have reasonably available fun

construction and right of way 

concurrence of the relevant c

commission/s. As discussed w

Authority, the Northern Corri

inclusion in to the future RTP 

conditions are satisfactorily m

section of the Passenger Rail 

developments brought up in 
142

ID Name Affiliation Comment Re

(Page 196, Table 7.1).

056‐08 Julie Skinner City of Santa

Clarita

As part of our review, the list of Constrained Projects was

compared to the schedule of projects included on page nine of

the "Measure R Highway Program" report released in January

2012 by the Los Angeles County Metropolitan Transportation

Authority. The City has identified two discrepancies between

the two documents and is seeking clarification. The

discrepancies are as follows: Metro's list of highway projects

indicates completion of Interstate 5 truck lanes (Phase 1) from

SR‐14 to Pico Canyon Road by 2014, while the Financially‐

Constrained RTP Project List indicates completion of this same

project by 2016 (RTP Technical Appendices, page 154).

Comment noted. The comple

List is consistent with Metro's 

Program (TIP) submittal, whic

be consistent with. We will w

future RTP Amendment.

056‐09 Julie Skinner City of Santa

Clarita

Metro's list of highway projects indicates completion of I‐5 truck

lanes and HOV lanes (Phases 2 and 3) from SR‐14 to Parker Road

by 2025, while the Financially‐Constrained RTP Project List

indicates completion of this same project by 2017 (RTP

Technical Appendices, page 155).

Comment noted. Thank you f

our attention. Unfortunately, 

time as the project is current

Improvement Program (TIP) w

indicated in the Draft 2012 RT

reflect the most current TIP in 

SCAG will work with Metro in 

the future TIP and RTP Amen

appropriate.

056‐10 Julie Skinner City of Santa

Clarita

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

057‐01 Dennis Woods City of South

Pasadena

The City of South Pasadena strongly supports a robust multi‐

modal option. The City of South Pasadena feels that the

inclusion of the SR‐710 North is flawed and therefore should be

removed from the RTP. It is flawed in a couple of areas. By the

inclusion of a freeway, evidence is show both from research and

actual data on the ground from real life examples, that

expanding freeways does not improve Vehicle Miles Traveled

(VMT) and does not elevate congestion in the long term. It is

also flawed in assuming that it has reasonable funding. We do

not believe reasonable funding is through the VMT travel tax

and or through the tolls that SCAG is proposing as reasonable.

We do not believe it meets the real tenants of SB 375 or AB 32,

particularly in regards to reducing VMT. It does not reduce VMT

by addition of the SR‐710 North. In conclusion, the City of South

Pasadena requests that the RTP and the PEIR remove the 710

North extensions. With this inclusion in the Plan it has not been

demonstrated that it meets two of the four required tests for

Comment noted. Increase in t

condition is primarily due to e

people over the plan period. 

basis will decrease over this p

implemented. While the Plan 

highway improvements, inclu

project, there is no evidence 

contribute to the total VMT in

The 2012 RTP identifies a mu

incorporates transit, highway

strategies as well as demand 

pricing strategies to achieve o

performance and reduction in 

375.
143

ID Name Affiliation Comment Re

conformity. Sufficient financial resources for the project have

not been demonstrated and assumptions regarding regional

emissions are flawed. The report impact of the Plan network is

based on suspect assumptions. Inclusion of the project at this

time will also bias the future project level NEPA and CEQA

review that is being done by LA Metro who has not decided on a

preferred alternative.

058‐01 Michael

Cacciotti

City of SouthPasadena

SCAG's welcome deletion of a surface SR‐710 north extension

should be accompanied by a land‐use action to require State

disposition of the hundreds of properties now surplus to the

surface route.

Comment noted.

058‐02 Michael

Cacciotti

City of SouthPasadena

SCAG should follow the State's designation of an unbuilt SR‐710

project as an extension and not a gap closure.

Comment noted. References 

been revised to “SR‐710 Nort

TBD)”.

058‐03 Michael

Cacciotti

City of SouthPasadena

The Plan and DEIR do not meet the legal requirements of the

Clean Air Act, the National Environmental Protection Act or Title

23 of U.S. Code: Test 1 Financial Constraint; Test 2: Regional

Emissions Analysis

Comment noted. Regarding r

RTP/SCS meets these require

Transportation Conformity re

constraint requirements set f

regulations and guidance, inc

strategies for ensuring availab

identified. See 23 CFR 450.32

in part, that the RTP includes 

demonstrating that projects i

using committed, available, o

sources. See 23 CFR 450.104. 

be funded by both core (Mea

available revenues. SCAG esta

sources identified for the SR‐

available. As such, strategies 

implementation steps for ens

new revenues are discussed i

Appendix.

058‐04 Michael

Cacciotti

City of SouthPasadena

By erroneously specifying only one SR‐710 extension

alternative—a straight line tunnel—the Plan and DEIR threaten

program‐level conformity and unlawfully prejudice future

project‐level environmental analyses.

Comment noted. SCAG recog

environmental analysis is und

that effort and selection of a 

SCAG will work with Metro to 

update the project descriptio

analysis.

058‐05 Michael

Cacciotti

City of SouthPasadena

Even though the proposed RTP and its shift of truck traffic to

the East‐West Corridor vitiates the asserted need for an SR‐710

Comment noted. An efficient 

critical to the goods moveme
144

ID Name Affiliation Comment Re

tunnel, the plan and draft PEIR should emphasize elimination of

non‐local truck traffic in preference to a direct rail loading at the

ports.

feasible to move all goods by 

generally serve different mar

to distant areas outside the r

able to use rail from the San P

destination. Goods moving fr

regional manufacturers to loc

international border with Me

as a result of cost, lack of acc

first‐mile/last‐mile issues, or 

movement system is complex 

single mode of transportation

058‐06 Michael

Cacciotti

City of SouthPasadena

The City of South Pasadena requests that the SCAG RTP and

PEIR remove the SR‐710 north extension. With its inclusion, the

Plan has not demonstrated that it can meet two of the four

required tests of conformity—sufficient financial resources for

the project have not been demonstrated, and assumptions

regarding regional emissions are flawed. The reported impacts

of the planned network are based on suspect assumptions.

Inclusion of the project at this time will bias future project‐level

NEPA and CEQA review if and when an SR‐710 tunnel alignment

becomes LA METRO's preferred alternative. Finally, while the

circulating draft RTP and PEIR vitiate the need for any SR‐710

extension that will produce tolls and relieve congestion, SCAG

must discard its emphasis on accommodating any truck traffic

from the ports and redraw its plan and assessments to

anticipate the direct ship‐to‐rail transport that enables air‐

quality conformity and successful port competition.

Comment noted. The RTP/SC

710 North Extension project, 

requirements. SCAG recogniz

environmental analysis is und

completion of that effort and 

alternative by Metro, SCAG w

RTP as necessary to update th

associated modeling analysis

of conformity can be found in 

responses to comments rega

review, as well as truck traffic 

above.

059‐01 Omar

Dadabhoy

City of Stanton IT is requested that SCAG continue to utilize growth projection

data at the County level as it has done in previous RTP

processes. The growth projections for the RTP identify

population housing and employment data for the six county

SCAG region, from 2008 (existing) to 2020 and 2035. These

growth projections represent the best available information

from local jurisdictions, the business community and

landowners. However, as time passes, what is feasible for any

given project can change. .. SCAG should continue to adopt

growth projections for the 2012 RTP at a countywide level,

consistent with past approvals of RTP growth forecasts.

Adopting of the data at a lower level than the county would

limit jurisdictional control and create inflexibility in a regional

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use de

allocation being adopted at th

that the SCS be based on a ju

distribution.
145

ID Name Affiliation Comment Re

planning document. In addition, the level of geography in which

the RTP/SCS growth forecast is adopted should not be

determined by other processes. For example, the RHNAallocations must be consistent with the RTP / SCS; state law

does not require that they be identical. The RTP/SCS can be

adopted at a county level, and the RHNA process can proceed

independently until it is complete after the appeals, trades, and

transfers are completed. The RHNA allocations that were

derived from the growth forecast can still be determined to be

consistent with the RTP/SCS, even if changes are made to the

city totals during the appeals, trades, and transfers process.

059‐02 Omar

Dadabhoy

City of Stanton In regards to the projection data used in the RTP/SCS and the

PEIR, on 1/26/2012, the update to the Orange County

Projection (OCP‐2010) data‐set known as the ("OCP‐2010

Modified") was officially approved by the OCCOG Board of

Directors and is a data amendment to the OC SCS. The dataset

includes the 2010 Census population and housing data, along

with the 2010 EDD Benchmark data, consistent with SCAG's

updated growth forecast dataset. The dataset was provided to

SCAG staff in December 2011, and this letter serves as the

formal notice of the update that should be incorporated into

the 2012 RTP/SCS, PEIR, and related documents.

Comment noted. SCAG has in

Modified dataset into the SCA

for the 2012 RTP/SCS and upd

tables, maps, narrative, mode

(including Alternate C referen

forecasts).

059‐03 Omar

Dadabhoy

City of Stanton As part of the SCAG SCS, it was indicated that the OC SCS was

incorporated in its entierty without modification. However,

there are strategies in the Orange County SCS that are not

included in the regional SCS. Similarly, some of those strategies

are not consistent with the OC SCS. ..Please clarify the role of

the OC SCS in the regional SCS, and when there are

inconsistencies in the regional SCS and the OC SCS, whether the

OC SCS would be the prevailing document for the Orange

county sub‐region.

Comment noted. The subregi

GCCOG and OCCOG are incor

in their entirety, and as such, 

the regional plan for impleme

strategies included in the RTP

apply region‐wide.

059‐04 Omar

Dadabhoy

City of Stanton [PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

060‐01 Tammy

Williams‐Anderson

City ofThousandOaks, Public

Works/Transit

Can you send me a copy of the presentation prepared since I

was not able to hear it?

Comment noted. All RTP/SCS 

been made available on SCAG

http://www.scag.ca.gov.

061‐01 John Nielsen City of Tustin It is stated on page 80 of the Draft RTP/SCS that “the RTP has

the ability to affect the distribution of that growth.” This

statement appears to contradict SCAG’s agreement pursuant to

Comment noted. The final 20

specify that land use inputs fr

changed per the MOUs betwe
146

ID Name Affiliation Comment Re

the Memorandum of Understanding with the Orange County

Council of Governments (OCCOG) that the strategies and local

land use policies of the Orange County SCS will be respected.

The RTP/SCS should acknowledge that the local land use plans

in Orange County will not be changed through the RTP/SCS.

subregions.

061‐02 John Nielsen City of Tustin The Draft RTP/SCS suggests that $127.2 billion of an

approximately $219.5 billion regional shortfall can be addressed

through actions at either the state or federal level with a $0.15

gas tax increase between 2017 and 2024. After that, the report

assumes that the state or federal government would either

replace the gas tax with an indexed mileage‐based user fee of

$0.05 per mile, beginning in 2025, or further increase fuel taxes

to generate revenues equivalent to the mileage‐based user fee.

The City of Tustin cannot support an increase in fees, including

the introduction of a mileage‐based user fee, until further

economic analysis is completed and until and unless there can

be an explanation of the return to source principles which will

be used for the distribution of funds collected thereunder. In

addition, when considering support for any kind of a new user‐

based fee program, an emphasis must be placed on a process

for recognizing and rewarding areas which commit additional

revenues.

Comment noted. The project

based user fee and adjustme

taxes when combined with th

and federal sources are less t

in state and federal transport

percent annually. Rather than 

the historical growth rate, wh

requirements, we detailed sp

state and federal transportat

with recommendations from 

established by Congress throu

economic impacts of the RTP 

Job Creation Analysis of the 2

that return‐to‐source and rew

substantial strides to obtainin

items for any new revenue so

061‐03 John Nielsen City of Tustin The Draft RTP/SCS proposes a number of investments that

affect Orange County and go beyond the Long‐Range

Transportation Plan (LRTP). The City will only consider

additional investments after revenues are identified to account

for these commitments. The regional strategies identified by

SCAG do not have clear funding mechanisms, and it must be

made clear that their inclusion in the RTP/SCS does not

constitute a commitment to fund and/or implement the

improvements.

Comment noted. The RTP/SC

decisions are made at the loc

regional strategies in the RTP

061‐04 John Nielsen City of Tustin The Sustainable Communities Strategy (“SCS”) is recognized as a

key portion of the 2012 RTP/SCS, and serves to meet

responsibilities associated with SB 375. It is clear the SCS “Goals

and Benefits” involve significant local jurisdiction participation

and efforts. It is critical for the RTP/SCS to recognize the need to

sufficiently fund local agency efforts to assure successful

outcomes.

Comment noted. Table 4.3 in

action/strategy, "Seek partne

local agencies to acquire fund

planning projects." In additio

incentives for local governme

including additional funding f

Planning Assistance Program 

Region) and Strategic Growth 

061‐05 John Nielsen City of Tustin Tables 4.3 ‐ 4.7 of the RTP/SCS identify “Action/Strategy” efforts Comment noted. Table 4.3 in
147

ID Name Affiliation Comment Re

related to the SCS, with local jurisdictions being identified as

responsible parties for many of the tasks. Without proper

funding for local jurisdiction efforts we believe the effectiveness

of the “Action/Strategy” measures will be compromised.

action/strategy, "Seek partne

local agencies to acquire fund

planning projects." In additio

incentives for local governme

including additional funding f

Planning Assistance Program 

Region) and Strategic Growth 

061‐06 John Nielsen City of Tustin In general, current policies and goals of the RTP/SCS identify

projects and funding necessary to successfully implement

elements of the RTP/SCS. There are also RTP/SCS goals which

essentially require development “from the ground up” at the

local level. We agree the most efficient and effective efforts

toward meeting these RTP/SCS goals will begin with the local

jurisdictions. There needs to be sufficient levels of funding

(which do not appear to be addressed in the current RTP/SCS

draft) to allow local jurisdictions to adequately initiate these

specialized efforts. From a practical perspective, this funding

would be expected to yield some of the most immediate and

timely results in meeting RTP/SCS goals. They would consider

measures which could include, but not be limited to: Programs

for improved use of public transit; Responsiveness to

demographic changes; Improved management of existing

transportation infrastructure and roadways; Employer‐based

Transportation Management Plans; Trip‐reduction efforts

including promotion of telecommuting; Carpool/transit parking

near transportation corridors; Better “place marking” which

includes an increase of walkable environments; Support of

bicycle programs including bicycle storage and bike lanes;

Bridging gaps between mass transit options and shipping and

service centers; Programs for new construction; and

reconstruction of non‐motorized transportation paths Measures

to reduce vehicle miles traveled will involve local jurisdictions

and employers to implement many strategies which include but

are not limited to measures such as: Increasing rideshare and

work‐at‐home; Investing in non‐motorized transportation

facilities; Developing appropriate land use strategies o

Encouraging universal employee transit access passes;

Synchronizing traffic signals; Using LED technology for new

traffic signals and street lights; Allocating convenient parking

areas, loading areas and larger parking spaces for vans and

Comment noted. The distribu

transportation investments in 

tax measure commitments ap

transportation commission ad

plans, limitations associated w

other previous commitments
148

ID Name Affiliation Comment Re

HOV; Creating ride‐sharing programs and provide parking near

public transportation; Enhancing safety and cleanliness at

transit stations; Providing shuttles to transit; Providing

incentives, education and publicity to encourage use of transit It

will be necessary to provide funding to local jurisdictions for

implementation and/or management of these and other

associated measures.

061‐07 John Nielsen City of Tustin Table 3.6 shows that the 2012 RTP/SCS anticipates relatively low

levels of funding for local streets and roads, including $1.1

billion for FY2011‐FY2015, $1.1 billion for FY2016‐FY2020, and

$1.2 billion for FY2021‐2025. Funding is increased to $7.9 billion

for FY2026‐FY2030 and $9.6 billion for FY2031‐FY2035.

However, local street and road improvements offer the best

opportunity for quickly improving mobility and realizing

RTP/SCS goals. They also provide economic benefits which could

translate into additional funding in the future. Funding for these

programs should be increased and accelerated in the near

future.

Comment noted. The funding 

operations and maintenance 

in FY 2026 due to the assump

beginning in that year (see Ta

these improvements would re

dedicated to other projects a

061‐08 John Nielsen City of Tustin One City of Tustin project which has both local and regional

significance does not appear to be included in the RTP/SCS. It is

therefore requested that the following project be added to the

RTP/SCS: o Tustin Ranch Road extension from Walnut Avenue to

Warner Avenue, including a new grade separation over Edinger

Avenue and the OCTA/SCRRA Railway.

Comment noted. The Tustin R

Avenue to Valencia Avenue, i

Avenue and the OCTA/SCRRA 

List under RTP ID# ORA55244

061‐09 John Nielsen City of Tustin The RTP/SCS should identify the regional transportation

infrastructure deficiencies broken down by county for purposes

of transparency.

Comment noted. The Highwa

discusses system preservatio

on distressed lane miles and s

county.

061‐10 John Nielsen City of Tustin [PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

062‐01 James

Provenzano

Clean Air Now The issue of revenue generation to rely on the State budget for

resources is risky, there is support for local generation of

revenues. I strongly urge keep that in mind and look at those

sources and possibly move forward with some action that will

help you obtain revenues from local sources.

Comment noted. Comment n

cannot be known with certain

assumptions, which were vet

Advisory Committee and Poli

documented in the RTP. As w

funding options, we will upda

through amendments and/or 

appropriate. At a minimum, a

every four years.
149

ID Name Affiliation Comment Re

062‐02 James

Provenzano

Clean Air Now The access to mass transit, allowing people to access mass

transit by being able to walk to mass transit or drive fewer miles

to mass transit is critical in the overall scheme to the RTP/SCS.

Please listen to the comments from the public to help improve

what you have done and move the Plan in the right direction

that is palpable to everyone that will be impacted by the RTP.

Comment noted.

063‐01 Todd Campbell Clean Energy Upon review of the proposed RTP/SCS, we felt compelled to

comment on the document in its current form as it appears to

overemphasize electric and zero emission vehicle strategies

without any apparent back up documentation regarding the

cost‐effectiveness and feasablity of such strategies. Clean

Energy strongly recommends that SCAG meet with Clean Energy

to discuss our experience within the Industry and share with

you how we, as a company, intend to help SCAG reach regional

air quality attainment.

Comment noted. The RTP env

Southern California goods mo

accommodates growth in wa

economic vitality and the qua

discussed in the Goods Move

planning for a zero and near z

use of near‐term alternative f

the long‐term vision. We look 

Energy to discuss these impo

063‐02 Todd Campbell Clean Energy We strongly urge SCAG to modify its current draft RTP/SCS to

specifically highlight natural gas vehicles, in addition to electric

and hybrid options, amongst the near zero‐emission to zero

emission technologies that will help the region meet its criteria

air emissions goals under the federal Clean Air Act and

greenhouse gas emissions goals under the state's AB 32 ‐ The

Global Warming Solutions Act of 20066. Not only does Clean

Energy believe that NGVs will continue to be some of the

cleanest options, particularly for medium‐ and heavy‐duty

vehicles, on the road, they will most likely will also benefit from

hybridized platforms, biomethane and hydrogen‐blending, and

other advancements that may come to market over the next 20

years. We would like to formerly offer an invitation to senior

SCAG staff to visit our offices in an effort to better understand

our plans to help the region meet its clean air and greenhouse

gas goals prior to the finalization of the RTP/SCS.

Comment noted. While the R

vehicle fleet assumptions in A

sought to further the implem

number of planning efforts. A

Movement section of the RTP

future includes the use of nea

technologies as bridge to the 

SCAG Clean Cities Coalition is 

activities for three projects th

natural gas as an alternative f

Truck Replacement Project in

heavy‐duty diesel drayage tru

clean natural gas engines, cor

of approximately 180 natural 

Gas (LNG) ‐ Corridor Expansio

connection between the exist

infrastructure in Southern Ca

being developed in Utah, pro

corridor along one of the nat

movement truck routes betw

Lake City, Utah. And finally, th

CNG Truck Replacement Proje

deploy 262 natural gas trucks 

stations. There are currently 

fueling stations in developme
150

ID Name Affiliation Comment Re

shown a commitment to expa

alternative fuels. SCAG welco

forward to working with Clea

064‐01 Carey Knecht ClimatePlan Please find attached our comment letter about SCAG's Draft

RTP/SCS Congratulations on the successful completion of a draft

Regional Transportation Plan and Sustainable Communities

Strategy (RTP/SCS). This represents the culmination of three

years of hard work by your staff, committees, and Regional

Council to understand and merge together the land use and

transportation plans of hundreds of local governments and

agencies. This is a very significant effort that can substantially

improve the quality of life, public health, long‐term economic

competitiveness, and environmental sustainability of the region.

Southern California has made some impressive strides in this

direction, as reflected in these successes of the plan: • Meets

the greenhouse gas reduction targets established by the

California Air Resources Board • Reduces overall traffic

congestion and allows residents to spend less time in their

cars • Triples spending on bike and pedestrian projects and

increases transit investments by 13% • Meets the projected

economic market demand by planning for a diversity of housing

types, including a more adequate number of small‐lot single

family homes and dwellings in mixed‐use, walkable

neighborhoods • Addresses habitat loss via planning for more

cost‐effective future environmental mitigation As organizations

that work across the state, we want to recognize and thank

SCAG for the enormous progress that Southern California has

made in recent years. This is a large and diverse region that has

long lacked a transit system with regional reach. Yet Southern

California is taking actions that can be a model for regions

elsewhere in the state. For example, Los Angeles County’s

Measure R will generate up to $40 billion, most for transit, and

an effort is now underway to accelerate those 30 years of

spending into the early years, when jobs are most needed.

SCAG has proactively engaged many communities to create a

vision for smart growth, first through the Compass Blueprint

program and now with the creation of this SCS. This regional

plan builds on an innovative model program from Orange

County that will address potential habitat impacts in a way that

improves environmental benefits while reducing costs through

Comment noted.
151

ID Name Affiliation Comment Re

careful, upfront planning. The success of this plan is built upon

just these instances of great local and regional leadership.

However, amidst this plan’s successes, there are important

ways that this plan can make additional strides. The plan as

written reveals that on the current course, there are parts of

the region making significant investments in transit, bicycle, and

pedestrian infrastructure and thereby receiving great benefits,

while other areas are making lesser investments, particularly

those in Inland Empire counties.

064‐02 Carey Knecht ClimatePlan We believe SCAG should pursue additional strategies to expand

transit and active transportation opportunities that could have

great economic and health benefits for the entire region. We

are also concerned that several vulnerabilities in this plan may

cause it to not succeed at the level it intends.

Comment noted.

064‐03 Carey Knecht ClimatePlan I. Create greater opportunity for all Southern Californians As

noted above, the growth and investments in this plan have

many benefits for the region as a whole. However, transit and

active transportation investments are uneven, and as a result,

not everyone in the region will receive the same opportunities

and benefits. For instance, this plan reveals that per capita,

residents in Los Angeles and Orange County will cut the time

they spend driving by about 20%, while residents of Imperial,

San Bernardino, and Riverside will receive reductions that are

half that, or less. In addition, vulnerable populations across the

region will face greater risks. Before finalizing the plan, we ask

that the Regional Council and staff take some simple steps to

allow the region to move forward together. Expand transit

service in key areas: This plan expands a network of transit

choices, giving many people easier access to multiple

transportation options, and taking cars off of the roads so that

those who do drive spend less time stuck in traffic. Augmenting

these with some additional transit investments would provide

more options in currently less‐served parts of the region.

Expanding bus service levels is the least expensive transit

option, and well over 80 percent of those riding transit now do

so on bus. The fast‐growing Inland Empire counties could

particularly benefit from this strategy. The plan shows that only

10% of Riverside County will be served by high‐quality bus

service (buses every 15 minutes during peak periods). But since

about 40% of residents will live near bus lines with a slightly

Comment noted. Projects 712

identified as region wide expa

to point express bus service, 

productive corridors, for a tot

the life of the plan.
152

ID Name Affiliation Comment Re

lower level of service (15‐30 minute headways), increasing bus

travel frequencies would be a relatively low‐cost way to greatly

expand the number of residents within walking distance of high‐

quality public transportation. This would not only help those

who choose to take the bus, but it will also relieve traffic for

those who still need to drive. Rural parts of the region, such as

the eastern Coachella Valley and the North Shore of the Salton

Sea, have particularly low access to transit choices even as

housing and jobs begin to move into those rural areas.

Extending existing bus service to currently unserved rural areas

of the Coachella Valley, or exploring options such as local

circulators to meet unmet transit needs in rural areas, would

also improve access to services and decrease vehicle miles

traveled for farmworkers and other rural residents. Additionally,

extending planned BRT from Indio to Coachella would make it

possible to address the needs of a growing population to access

health care, groceries, or good jobs via public transit. Finally,

enhancing and expanding the region’s MetroLink system, as

well as the BRT and bus system that connect to it, can bring to

the full Southern California region the world‐class

transportation network that it deserves. Such enhancements

could create greater economic Finally, enhancing and expanding

the region’s MetroLink system, as well as the BRT and bus

system that connect to it, can bring to the full Southern

California region the world‐class transportation network that it

deserves. Such enhancements could create greater economic.

064‐04 Carey Knecht ClimatePlan Expand funding and policies for bicycles and pedestrians: This

plan could also take one step further toward providing residents

with safe routes for walking and biking. While the plan does

triple the previous expenditures, it still devotes less than 1.5%

of its funds to safe streets, despite the fact that over 20% of all

travel trips in the region are on foot or by bike. According to a

poll of Southern California voters by Move LA, NRDC, and the

American Lung Association last year, if given the choice, voters

would spend significantly more of the region’s transportation

dollars on bicycle and pedestrian investments. The L.A.

Department of Public Health recently reported that the funding

need could be as high as $40B, yet this plan currently devotes

$6B and estimates another $4B is available. This gap should be

reduced by increasing regional combined bike and pedestrian

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour
153

ID Name Affiliation Comment Re

funding to at least $12B, in addition to the estimated additional

$4B. These funds should create “first mile / last mile” linkages

near transit, address safety problems in areas of high injury and

fatality rates, provide sidewalks and bike lanes in places with

lower car ownership rates or where basic infrastructure is

currently lacking, and help children use Safe Routes to Schools.

064‐05 Carey Knecht ClimatePlan In addition, we ask SCAG to commit to working with its local

governments and agencies to embed a "complete streets"

policy in local and regional transportation project planning, to

systematize the inclusion of pedestrian and bicycle safety

features in road construction and maintenance projects. Doing

so will make cost‐effective use of these limited funds.

Comment noted. SCAG is com

jurisdictions in the developm

maintenance of their local ac

includes the adoption of Com

064‐06 Carey Knecht ClimatePlan Finally, we ask that SCAG undertake a regional bike/ped master

planning effort, similar to the assessment of unmet road

maintenance costs that SCAG currently manages. Before the

next RTP, SCAG should work with partner agencies and

jurisdictions to identify local needs, funding strategies, and

revenue sources to create a completed network of safe routes

for walking and biking.

Comment noted. SCAG has de

Bikeway Network to address 

network. SCAG is committed 

in the development, impleme

active transportation plans an

the 2016 RTP.

064‐07 Carey Knecht ClimatePlan Further study and aggressively address disparate exposure to air

pollution and noise: While this plan would improve air quality in

the region overall, we are greatly concerned that air pollution

levels would still be highest in areas close to freeways, and that

levels in some places could be higher than the “business as

usual” or baseline scenario. The Environmental Justice Appendix

to the Plan shows that 25% ‐ 27% of households living within

500 feet of freeways could face greater exposures to CO and

PM, with high concentrations of minority and low income

residents disproportionately affected. The Appendix further

highlights that all environmental justice populations except the

elderly currently have higher risk of cancer and respiratory

disease than the region as a whole, and that the “highest areas

of respiratory risk are the segments that closely follow major

freeways in the most urbanize portions of the region.” Non‐

English‐speaking, foreign born populations have the highest risk.

Before finalizing this plan, SCAG needs to study where and how

disproportionate impacts will occur, by providing a map

showing where this will be happening, and then identify a

complete suite of mitigations to ensure that air pollution and

noise impacts do not get worse for the most vulnerable while

Comment noted. Data and an

Environmental Justice Appen

improvements in vehicle tech

corridors. These corridors in 

and/or near‐zero emission ve

Environmental Impact Report 

includes mitigation measures 

associated with health risk wi

traffic volume roadways to le

included in the Appendix also 

improvements through the im

measures. As such, emissions 

this Appendix is abundantly c

worst‐case scenario outcome

improvements had been acco

would show little or no areas 

spots”) associated with the P

available data on emissions a

households and population is 

with emissions and EJ popula

potential impacts. Neverthel
154

ID Name Affiliation Comment Re

getting better for others. One possible tool is the list of model

“Health and Equity metrics,” including a methodology for

calculating those metrics, created by Human Impact Partners in

partnership with other health experts and organizations.

evolving information on healt

project sponsors to be cogniz

project design and delivery. C

identified and to be impleme

PEIR, SCAG will assist in disse

identifying effective strategie

level.

064‐08 Carey Knecht ClimatePlan Monitor the plan’s impacts on key indicators of health and

equity, and improve tools for future planning: Addressing

inequalities requires understanding them. Particular trends that

this plan has a limited ability to project and mitigate – such as

the risk of gentrification and displacement near transit stations,

injuries / fatalities to pedestrians and cyclists, asthma incidence

and exacerbations due to NOx, and the balance of wages to

housing costs – should be actively monitored. To carry this out,

SCAG should monitor these issues at a regional scale and also

identify particular places to monitor, including areas near transit

stations – where shifting demographics suggests that

gentrification may already be underway – and also a selected

group of areas known to have particularly vulnerable

populations. In addition to tracking this plan’s performance,

SCAG should commit to developing specific tools to project

future plans’ impact on critical issues, such as the fit between

job wages and housing costs; physical activity; the health

impacts of the physical activity and air quality created by the

plan; and other measures from the “Health & Equity metrics”

mentioned above.

Comment noted. (1) SCAG is 

gentrification in the region th

(EJ) Analysis. Trends observed 

2005‐09 American Communit

oriented developments (TOD

are inconclusive. SCAG will co

based on the framework pres

coming years. (2) SCAG is con

based development/growth a

and safety indicators for futu

previous Regional Transporta

Plan, hot spots of emissions a

presented, and mapped in th

SCAG will take the comment 

to expand its existing efforts 

monitoring program to focus 

areas and communities of con

process of enhancing our Sus

parcel and Census tract based 

data that correlate to confide

obtained from the Los Angele

Health. SCAG anticipates com

ST prior to the next round of 

/ Sustainable Communities St

064‐09 Carey Knecht ClimatePlan II. Ensure the Regional Transportation Plan’s Strengths Become

Reality This plan has much good news for the region, and the

recommendations below are designed to help the plan’s

strengths become reality. Ensure revenues materialize:

Significant new resources are needed for the plan to come to

fruition. We ask SCAG to take a leadership role in convening

other agencies and jurisdictions to generate the revenues that

this plan depends on for success. In developing this plan, the

region was faced with a large funding shortfall. The Regional

Comment noted. We agree th

stakeholders need to work to

best, most appropriate fundin

funding for RTP priorities. The 

mileage‐based user fee and a

gas excises taxes when comb

forecast for state and federal 

than the historical average in

transportation revenues sour
155

ID Name Affiliation Comment Re

Council made the policy decision not to cut projects but to find

additional revenue sources to pay for its infrastructure plans.

The current plan assumes that these needed funds will come

from state and federal governments, but as history shows, this

is not guaranteed. We hope the region will focus on what it can

do to raise money via a combination of regional and local fees

or taxes. These new revenue sources should be chosen to avoid

adverse impacts to the region’s lower‐income populations. As

funding gaps are likely to continue over the long run, we would

also recommend that the region follow the example of other

regions in considering how to systematically prioritize those

expenditures that most contribute to a sustainable, healthy, and

equitable region. Between now and the next SCS, SCAG and its

partner agencies could develop a systematic method for

prioritizing projects, such as the Project Performance

Assessment conducted at the Bay Area’s Metropolitan

Transportation Commission.

Rather than simply assume a 

growth rate, which is consiste

detailed specific steps necess

transportation revenue sourc

recommendations from two n

by Congress through SAFETEA

conducted nationally to evalu

options. SCAG concurs that fu

before implementation. In ad

throughout the country, we w

for the mileage‐based user fe

Apppendix. Included in the im

evaluate and address any disp

also recognize that the future 

certainty and we therefore m

which were vetted through S

Committee and Policy Comm

RTP to ensure transparency. A

funding options, we will upda

through amendments and/or 

appropriate. At a minimum, a

every four years.

064‐10 Carey Knecht ClimatePlan Frontload and expand funds for transit and bike / pedestrian

linkages, and for road and bridge safety projects: We ask that in

collaboration with its partner agencies and jurisdictions, SCAG

lead an effort to accelerate the transit, bike/ped, and road

maintenance projects that are essential to meeting the region’s

goals into earlier years when revenue is more reliable. Making

transportation investments in a timely way ensures that they

have maximum impact. Yet, this plan accelerates road

construction projects while delaying essential investments in

road maintenance, bike and pedestrian safety, and transit to the

late years of this 24‐year plan. Delaying road repairs is a bad

idea, because deferred maintenance leads to increasingly costly

repair needs. Also, delay endangers road and bridge users – in a

region where more drivers already cross structurally‐deficient

bridges than anywhere else in the United States.1 Delaying

projects that can create a multimodal network with a variety of

transportation options also concerns us, because future

revenues in this plan are less certain. Transportation

Comment noted. SCAG canno

commitments that are alread

funding for active transportat

is largely predicated on addit

that will require future action

levels. Therefore, the plan re

funds will not be available in 

funds are expected to be ava

evaluating funding for Active 

funding sources in future RTP 
156

ID Name Affiliation Comment Re

investments that not only support driving but also create

convenient public transit options and safe routes for walking

and biking are essential for achieving the region’s traffic

reduction and air quality goals.

064‐11 Carey Knecht ClimatePlan Help local governments plan the transit neighborhoods of the

future: We ask that SCAG help local governments plan the

diverse transit‐oriented or transit‐ready neighborhoods that this

plan relies upon by making a firm commitment to funds for

Compass Blueprint. The draft RTP/SCS assumes that many of the

region’s homes and jobs will grow as real estate market trends

predict they will, in walkable neighborhoods surrounding transit

corridors and light rail stations. But many cities are still in the

process of updating land use plans to allow that kind of

development. Without those plans in place, it is much more

difficult for builders to get projects approved and begin

construction. With local governments’ planning funds at historic

lows, funds to finish this planning may not exist. That makes it

essential that the region expands its Compass Blueprint

incentive grant program to help local governments plan the kind

of neighborhoods that this plan needs to succeed. SCAG should

make a clear financial commitment that this will happen. In

doing so, SCAG should use these grants first to fund those local

governments that stand ready to create healthy, walkable

neighborhoods for households at a range of income levels.

SCAG should update its Compass Blueprint grant criteria to

ensure that neighborhoods near present or future transit

stations or corridors will have safe streets for walking and

biking, and a mix of housing types to allow people of a range of

incomes to live and work near transit.

Comment noted. Through the 

SCAG has worked with and pr

to 94 separate jurisdictions in

profits, and transportation ag

applications will focus on loca

strategies, and will prioritize 

Transit Areas (HQTA). In addit

funding agencies have begun 

principles into their discretion

continue to pursue dedicated 

important voluntary program

064‐12 Carey Knecht ClimatePlan SCAG’s environmental justice appendix shows that areas near

transit are already losing low‐income populations. Lower‐

income households are more likely to utilize transit services that

are available to them, so building housing affordable to those

households near transit will maximize the benefit of the region’s

infrastructure investments. As growth patterns become more

compact, SCAG should also carefully monitor and seek

resources that could ameliorate and improve rural housing

stock.

Comment noted.

064‐13 Carey Knecht ClimatePlan Address gaps in the link between growth and transportation

planning: The success of all regional Sustainable Communities

Comment noted. After adopt

to work with member agencie
157

ID Name Affiliation Comment Re

Strategies depends on a well‐coordinated link between where

growth will happen and where transportation infrastructure will

be provided. In places where this link remains weak, SCAG

should host conversations between local governments and

transportation agencies that will better align transit planning

with future growth and housing. Where growth does occur as

greenfield development, SCAG should make sure that this

habitat and farmland loss is adequately mitigated by ensuring

regional mitigation planning includes not only critical habitat

and lands within Habitat Conservation Plan / Natural

Communities Conservation Plan Areas but all important

undeveloped lands, through an inclusive public process. Finally,

to make sure the region’s analysis rests on a solid foundation,

SCAG should ensure that its High Quality Transit Area

calculations accurately includes only the geography around bus

stops, not the entire corridor adjacent to a highway that a bus

travels along. Thank you very much for your consideration of

these comments, designed to strengthen and support the

success of your work in Southern California. We want to again

express our appreciation and gratitude to SCAG’s Regional

Council, committees, 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.

in implementing the strategie

065‐01 Tom Kirk/Rick

Bishop

CoachellaValleyAssociation ofGovernmentsand Western

RiversideCouncil ofGovernments

CVAG, WRCOG and our respective member jurisdictions worked

with SCAG representatives to develop growth projections for

the Coachella Valley and Western Riverside County subregions,

and we appreciate SCAG's acceptance of our local input on

these overall growth projections. These growth forecasts for

population, housing, and employment in Riverside County

underwent extensive review by both Agencies’ members. Both

the CVAG Executive Committee and the WRCOG Executive

Committee adopted subregional growth forecasts at the

jurisdictional (i.e. City and County) level. The Riverside County

Board of Supervisors also approved growth forecasts for

Riverside County at the jurisdictional level. Neither CVAG,

WRCOG, nor the Board of Supervisors have endorsed or

approved subregional growth projections at the TAZ level, nor

were any more ambitious TAZ level plans made generally

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.
158

ID Name Affiliation Comment Re

available to and generally accepted by the local planners in

Riverside County. We acknowledge SCAG’s usage of TAZ‐level

data for scenario modeling purposes during the development of

the Draft 2012 RTP/SCS. However, we did not anticipate the TAZ

data that was recently released by SCAG; nor do we agree that

they depict a realistic land use pattern that can or will be

achieved in Riverside County by 2035. In most cases, the 2035

TAZ maps substantially deviate from our jurisdictions’ adopted

General Plans, and also deviate from other land use approvals.

We are also concerned that these maps were only recently

made available to us for review. Due to the schedule of the

Draft RTP/SCS public comment and review period, CVAG and

WRCOG were not given substantial time to analyze this

information and consult with our member jurisdictions

regarding the potential implications of the growth projections

depicted in the 2035 TAZ maps. Accordingly, although CVAG and

WRCOG support the use of the underlying projected population,

household, and employment counts for policy purposes at

jurisdictional levels, we do not support the use of the counts

reflected in the recently‐disclosed TAZ maps as a basis for CEQA

streamlining or SCS consistency review under CEQA. Nor do we

support the use of these maps for purposes of determining

future infrastructure planned in Riverside County. Furthermore,

we do not support the use of this information for the purpose of

land use regulation or regulatory purposes of any kind. Finally,

CVAG and WRCOG do not support SCAG's use of the TAZ maps

and... [continued in next comment]

065‐02 Tom Kirk/Rick

Bishop

CoachellaValleyAssociation ofGovernmentsand Western

RiversideCouncil ofGovernments

[continued from last comment]...supporting data for

determining future allocation of Compass Blueprint Program

funds or any other funding incentives administered by SCAG or

others. We strongly urge that SCAG clarify that the use of TAZ‐

level data is for SCS modeling purposes only, and remove any

language and policy statements from the Draft 2012 RTP/SCS

that otherwise strengthen the standing of these unapproved

data.

Comment noted. The TAZ‐lev

the purpose of modeling perf

local jurisdictions, maintain th

determine consistency of any 

final RTP/SCS has been updacomment.

066‐01 Michael

Antonovich

County of LosAngeles Board

of Supervisors

As a Los Angeles County Supervisor, Vice‐Chair of the Los

Angeles County Metropolitan Transportation Authority (MTA),

and SCAG Board Director, it is my pleasure to request that this

subcommittee recommend to the SCAG Regional Council the

inclusion of a high speed rail study within the proposed High

Comment noted. The environ

component within the High D

and Palmdale has been includ

the final RTP/SCS (Constraine
159

ID Name Affiliation Comment Re

Desert Corridor project between Victorville and Plamdale as

part of the Constrained Regional Transportation Plan.

066‐02 Michael

Antonovich

County of LosAngeles Board

of Supervisors

The importance of the High Desert Corridor has been well‐noted

by the federal government, which designated the project as a

"Corridor of National Significance" with its "E‐220" designation

in SAFETEA‐LU. Support for this project started with the

Counties of Los Angeles and San Bernardino partnering to

create a Joint Powers Authority (JPA) to oversee the

development of this corridor. Since this time the project has

also been endorsed in the constrained portions of the SCAG's

Regional Transportation Plan, the Regional Transportation

Improvement Plan, and the MTA Long Range Transportation

Plan. the potential for this corridor to divert car and truck trips

from the heavily‐populated, congested and emissions‐plagued

Los Angeles and San Bernardino baisns has gained national

attention as a vital solution to the confluence of local, regional

and national car and truck traffic within the region's current

freeway system.

Comment noted.

066‐03 Michael

Antonovich

County of LosAngeles Board

of Supervisors

The High Desert Corridor JPA Board of Directors has always

envisioned this corridor as a public‐private partnerrship that

would require multiple elements to create a multi‐modal

corridor that met the region's needs for car, truck and transit

infrastructure improvement. Inclusion of a high‐speed rail

component within the right‐of‐way of the High Desert Corridor

reflects the desire of the JPA Board of Directors to connect

Palmdale and Victorville with at minimum an enhanced 110

mile‐per‐hour high speed Metrolink corridor, and potentially a

220 mile‐per‐hour high speed rail corridor compatible with both

the California and DesertXpress High Speed Rail systems.

Currently the JPA Board has not entered into any agreement

with Metrolink, California High Speed Rail, Amtrack or

DesertXpress to partner with the JPA in operating service on this

high speed rail corridor. Rather, the JPA will remain partner‐

neutral until which time the Public‐Private Partnership Request

for Proposals process calls for a decision to be made by the High

Desert Corridor JPA and its partners in MTA and SANBAG.

Comment noted.

066‐04 Michael

Antonovich

County of LosAngeles Board

of Supervisors

By combining the environmental study of this high speed rail

component of the High Desert Corridor into the current

environmental work for the highway portion of the project, the

JPA Board strives to provide a cost‐effective manner of

Comment noted. The environ

component within the High D

and Palmdale has been includ

the final RTP/SCS (Constraine
160

ID Name Affiliation Comment Re

implementing this transit aspect of the project as cost‐

effectively as possible while staying within SCAG's envelop of

$8.2 billion in the proposed Regional Transportation Plan. By

including a vital high speed rail component, the High Desert

Corridor stands poised to become a model public‐private

partnership project which captures the multi‐modal

requirements of AB 32 and SB 375 while leveraging private

capital and improving the national movement of truck freight as

encouraged by federal transportation policy. Thank you for your

support of the inclusion of the High Desert Corridor, including

the environmental study of a high speed rail component within

its right‐of‐way, in the Constrained portion of SCAG's Regional

Transportation Plan.

067‐01 Paul Simon County of Los

AngelesDepartment ofPublic Health

Target and increase investment for active transportation. We

applaud SCAG's proposed increased investment in active

transportation, from $1.8 billion in the 2008 RTP (less than .5%)

to $6 billion (1.3%) in the current draft plan.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

067‐02 Paul Simon County of Los

AngelesDepartment ofPublic Health

DPH strongly encourages that the final plan: (1) Prioritize (i)

first‐mile/last‐mile connections to transit stations which will

help support the increased investment in the transit system; (ii)

projects that close gaps in key bicycle and pedestrian corridors;

and (iii) communities with high numbers of bicycle and

pedestrian injuries and high rates of chronic disease; (2) Front

load active transportation funding so it is available to

jurisdictions to build walkable and bikeable communities early

on in the 25 year RTP period; and (3) Provide funding and

technical assistance for cities to create bicycle and pedestrian

plans and city‐wide safe routes to school plans. Offer support to

CTCs and local jurisdictions to adopt a complete streets policy

so that pedestrian and bicycle improvements can be made

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu
161

ID Name Affiliation Comment Re

routinely and more economically when streets are improved or

built.

and pursue new funding sour

067‐03 Paul Simon County of Los

AngelesDepartment ofPublic Health

In addition, the plan should include further investments in

active transportation to create 1) basic bicycle and pedestrian

infrastructure in key areas in every city in the SCAG region; 2)

bikeable and walkable neighborhoods within 1/2 mile of all

TODs, existing and planned; 3) complete routes to public

schools throughout the region that children can walk and bike

to; 4) sidewalks repair throughout the region; and 5) improved

continuity in county bike networks. Given that cities' bicycle and

pedestrian master plans have a range of costs for proposed

improvements, we present a range for the estimated amount of

active transportation funding needed to generate these

improvements across the region, from a low of $37 billion

(7.1%) to a high of $60 billion (11.4%) over 25 years, adjusted

for inflation. We recognize that there are many factors that

must be considered in your resource allocation decisions and,

therefore, do not provide these estimates as a recommendation

for funding.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

067‐04 Paul Simon County of Los

AngelesDepartment ofPublic Health

Build healthy neighborhoods around transit stations that

protect existing low‐income residents. The area around rail

stations offers a unique opportunity to create safe access to

transit and to address key community needs such as mixed‐

income housing and business/retail corridors within a walkable

and bikeable community setting. However, without careful

planning, the people in neighborhoods adjacent to rail stations

can be displaced as real estate prices rise in response to new

development, triggering corresponding increases in residential

and commercial rents for low‐income families and small

business owners. DPH encourages that the plan: Prevent

displacement of existing low‐income residents, fund

jurisdictions to create transit‐oriented development plans that

include policies to preserve existing affordable housing and

small business store fronts and to ensure the provision of

affordable housing and small business store fronts in new

developments; Whenever possible, locate housing, child care

facilities, schools, and other sensitive‐use development far

enough away from sources of pollution to decrease exposure

that can negatively affect health.

Comment noted. SCAG has sh

gentrification in the region th

(EJ) Analysis. Trends observed 

2005‐09 American Communit

oriented developments (TOD

continue to evaluate and mo

as the economy is recovering

work with environmental just

on strategies to prevent displ

to working with public health 

reduce pollutant exposure to 

Environmental Justice Appen

health impacts on children 5 

recognition of this important 

067‐05 Paul Simon County of Los Strengthen public health modeling and monitoring. We Comment noted. Consistent w
162

ID Name Affiliation Comment Re

AngelesDepartment ofPublic Health

encourage SCAG to measure the public health impacts of

transportation investments. For example, the RTP could be

analyzed for its potential to reduce chronic diseases in the SCAG

region, such as heart disease and breast cancer, based on

increases in walking and biking, linked to active transportation

scenarios. Specifically, DPH encourages SCAG to: Measure the

health benefits of transportation plans by integrating health

outcomes into SCAG's modeling approaches; Measure and

report on additional public health indicators including but not

limited to: bicycle and pedestrian injuries and collisions by

geographic areas; percentage of households that can walk or

bike within 10 minutes to reach their daily destinations, e.g.

transit, schools, childcare, parks; percent of income consumed

by housing and transportation costs; and Conduct targeted

analyses in neighborhoods adjacent to rail stations to determine

if displacement of existing residents is occurring as

development occurs.

stakeholder requests, SCAG h

based metrics not previously 

explore further improving the 

active transportation and oth

RTP/SCS updates.

068‐01 Thomas Mauk County of

Orange

Orange County Sustainable Communities Strategy In 2010, the

Orange County Council of Governments (OCCOG) requested

delegation to develop a subregional Sustainable Communities

Strategy (SCS) for Orange County. OCCOG entered into a

Memorandum of Understanding (MOU) with SCAG that has

allowed OCCOG to develop the Orange County Sustainable

Communities Strategy (OC SCS) which will be incorporated into

SCAG's 2012 RTP/SCS. The OC SCS, approved by the OCCOG

Board of Directors on June 23, 2011, describes the policies and

programs that Orange County local jurisdictions will implement

to reduce greenhouse gas (GHG) emissions to 2005 levels by the

year 2035 and reflects current land uses, existing entitlements,

proposed development (e.g., general plans, zoning maps, etc.)

and forecasted population, housing and employment growth in

Orange County (i.e., Orange County Projections [OCP] 2010‐ 

Modified, January 2012). Pursuant to the MOU between SCAG

and OCCOG, the OC SCS is to be fully incorporated without

change. Although there are several references to the OC SCS in

both the RTP/SCS and PEIR, it remains unclear whether the data

contained in the OC SCS has remained unchanged in each

proposed alternative. Without the underlying data for each

alternative available for review, this cannot be confirmed. It is

requested that language, maps, tables, and charts be added to

Comment noted. The subregi

GCCOG and OCCOG are incor

in their entirety, and as such, 

the regional plan for impleme

strategies included in the RTP

apply region‐wide. Land use i

were not changed per their s

final RTP/SCS SCS Background 

Sustainable Communities Stra

updated to include clarifying 

requirements of SB 375 (Gove

subparagraphs (1) and (3)) th

Assessment must be consiste

development pattern. The RH

the jurisdictional level necess

jurisdictional level growth dis
163

ID Name Affiliation Comment Re

demonstrate that the underlying land use, socioeconomic, and

transportation data for Orange County (OCP 2010‐ Modified)

has been incorporated into the regional RTP/SCS and each of its

plan alternatives without alteration as agreed to in the MOU. It

is also requested that the adoption of the growth forecast

numbers by SCAG's Regional Council and/or Joint Policy

Committee be at the county level, consistent with past RTPs. A

review of the policies and strategies contained in the RTP/SCS

has revealed the potential for inconsistency with land use

policies and/or County operations in the unincorporated area.The County requests that the RTP/SCS include language that

acknowledges and incorporates the fifteen "OC SCS

Sustainability Strategies A through O," contained in Chapter

Three, and the "Sustainability Strategies," contained in

Appendix F, of the OC SCS as specifically appropriate for the

Orange County Subregion.

068‐02 Thomas Mauk County of

Orange

SB 375 Considerations The County is deeply concerned with the

broadness of the PEIR and RTP/SCS. At a presentation held at

the CEHD meeting on January 8, 2009, SCAG then interpreted

SB 375 to only include VMT associated with vehicles and light

trucks, and went on record that green buildings, energy

efficiency, municipal operations, waste management, water and

technology programs and measures were not within the

purview of the SCS. The draft RTP/SCS and PEIR, however

address all of these subject areas. We believe that SCAG's

original 2009 interpretation is the legally correct one under SB

375 and that SCAG should amend the document to delete all

references and measures to items outside of SB 375 that do not

directly relate to VMT from vehicles and light trucks. The

RTP/SCS and PEIR should not be used as an umbrella document

for all things SCAG considers sustainable. The legislative text of

SB 375 states that state transportation funding will be

prioritized and allocated to those local agencies that are

consistent with an approved SCS. The actual SB 375 statutes do

not specifically state how this will be done and what exact

funding will be subject to SCS prioritization. There has been no

follow‐up legislation or other policy of which the County is

aware that clarifies this issue. Due to this, SB 375 enforcement

is unclear. We believe that SCAG should clarify and elaborate on

its understanding of this issue. Much more information is

Comment noted. It is not SCA

governments in Orange Coun

programs and mandates beyo

All the land uses, growth fore

the Orange County Council of 

Sustainable Communities Stra

in SCAG's RTP/SCS.
164

ID Name Affiliation Comment Re

needed as to the process, if any, that SCAG will employ to make

SCS consistency findings. Will SCAG make SCS consistency

findings for individual programs and projects? Will a subregional

delegate who has prepared its own SCS, like OCCOG has with

the OC SCS, have the authority to make such findings? Will the

local programs and projects within Orange County boundaries

also be subject to consistency findings by SCAG under its

approved SCS? What types of local programs and projects will

be subject to a SCS consistency review? These questions and

many other must be answered prior to effective

implementation of the policies set forth in SB 375.

068‐03 Thomas Mauk County of

Orange

Chapter 2‐Transportation Investments, Page 60‐62: Information

is presented on airport ground access and airport financial and

marketing strategies. These strategies identify potential sources

of funding such as: a) charging fees for private vehicles picking

up and dropping off passengers at congested airports; b) a

regional funding mechanism using revenues generated at

congested airports to support facilities and development at

alternate airports (requiring new legislation); and c) funding a

region‐wide marketing effort through sources such as airport

parking and rental car transactions. Including these specific

strategies in the RTP document may raise expectations that

these strategies are supported by airports in the region.

However, due to the competitive nature of most airports, it may

be difficult to achieve such support. It may also be challenging

to garner airline and FAA support. It is suggested that the

airport strategies text be revised to recognize that any

incentives or funding mechanisms that are proposed, and which

affect other airports in the region, should be developed through

regional consensus. Although many of the SCS "Airport Policies

and Action Steps" suggest such an approach, this should be

stated in the strategies text as well, and it should be clear that

while these strategies may be explored, they may or may not be

pursued. Additionally, SCAG should invite the FAA and airline

representatives to be part of any discussions which address the

concept of using revenues from one airport to benefit another.

Comment noted. Additional l

referenced section that will e

consensus in order to implem

marketing strategies.

068‐04 Thomas Mauk County of

Orange

Chapter 2‐Transportation Investments, Page 61: A revision to

the Airport Ground Access Strategy section (end of the first

paragraph) is suggested as follows: "Potential sources of

funding could include charging fees for private vehicles picking

Comment noted. This section 

description of the referenced 

impact on airport revenues.
165

ID Name Affiliation Comment Re

up and dropping off passengers at the congested airports. This

[delete]would not adversely impact existing airport revenues

and would[/delete] could have a number of advantages ..... "

This revision is proposed because, with respect to the third

bullet, a case could be made that although there are advantages

to passengers using public transportation, it is possible that

parking revenues would be adversely impacted.

068‐05 Thomas Mauk County of

Orange

Chapter 2‐Transportation Investments, Page 61: The Airport

Financial Strategy section should be revised to avoid making

inferences that an issue "should not be controversial,"

especially related to a strategy that identifies a requirement for

legislative changes allowing funds from one airport to be used

at another airport(s) not operated by the same entity. It should

also be clarified that such legislative changes would be needed

at both the state and federal levels.

Comment noted. This section 

description of the referenced 

controversial.

068‐06 Thomas Mauk County of

Orange

Chapter 2‐Transportation Investments, Page 62: The Airport

Marketing Strategy section suggests that SCAG work with

regional stakeholders to develop region‐wide marketing efforts

to promote alternatives to the use of congested airports. A

variety of funding sources is suggested; however, airport

parking and rental car transactions are specifically mentioned.

These funding sources may or may not be supported by airports

in the SCAG region and should be thoroughly discussed and, as

stated in the document, a consensus of the region's airports

should be developed before proceeding with such a strategy.

Comment noted. Language h

section to emphasis the need 

airports in order to implemen

strategy.

068‐07 Thomas Mauk County of

Orange

Chapter 2‐Transportation Investments, Page 62: The Airport

Policies and Actions Steps identify certain actions that are

recommended by SCAG. The sub‐section, Airspace Planning and

New Technologies, identifies policies related to modifications to

the regional airspace system, and airspace capacity and

constraints. It is suggested that the wording, "in coordination

with the FAA," be added to each of the bullet points in this

section.

Comment noted. The involve

twice in the action steps for t

Technologies policies, which w

and eventually approved by S

Committee over a series of m

implementation of these poli

close coordination with the F

068‐08 Thomas Mauk County of

Orange

Chapter 1‐Vision, Page 15, Table 1.3: Note, via additional check,

connection between "Safety and Health" and "Encourage land

use and growth patterns that facilitate transit and non‐

motorized transportation."

Comment noted. Table 1.3 is 

between RTP/SCS goals and t

that end, the linkage between 

is more directly expressed by 

and Health" and "Protect the 

residents by improving air qu

transportation".
166

ID Name Affiliation Comment Re

068‐09 Thomas Mauk County of

Orange

Chapter 2‐Transportation Investments, Page 53: The collection

of additional data on active transportation, including greater

specificity in destinations, geographic detail, and types of active

transportation, is important in ensuring data driven

transportation systems.

Comment noted.

068‐10 Thomas Mauk County of

Orange

Chapter 2‐Transportation Investments, Page 53: The proposed

expansion of bikeways represents an exciting opportunity to

facilitate active transportation, improve air quality, and reduce

chronic disease risk. The connectivity of such an expanded

bikeway network with transit systems, centers of employment,

and residential areas, particularly those most likely to use and

benefit from such assets, is also an important part of such a

plan.

Comment noted.

068‐11 Thomas Mauk County of

Orange

Chapter 2‐Transportation Investments, Page 53: The

improvement of sidewalk infrastructure proposed in the

RTP/SCS is likely to facilitate walking as sidewalk quality can be

a key factor affecting walkability.

Comment noted.

068‐12 Thomas Mauk County of

Orange

Chapter 2‐Transportation Investments, Page 54: Safe Routes to

School: Besides their benefits in reducing congestion related to

the drop‐off and pick‐up of students, Safe Routes to School

initiatives can facilitate important daily incidental walking and

biking, which can substantially increase the chances of children

meeting daily physical activity recommendations. Though the

draft RTP/SCS recognizes the importance of Safe Routes to

School, it could better detail how Safe Routes to School

programs, assets, and principles will be integrated into the plan.

Comment noted. SCAG is com

jurisdictions in their developm

implementation of local activ

policies such as Complete Str

068‐13 Thomas Mauk County of

Orange

Chapter 2‐Transportation Investments, Page 54: SCAG's

encouragement of Complete Streets is important to the local

implementation of Complete Streets policies consistent with

AB1358. Augmented and explicit support in the RTP/SCS for

physical and engineering changes that facilitate safe multi‐

modal, multi‐user roadway utilization may be beneficial.

Consider increasing regional coordination in Complete Street

policy implementation to facilitate continuity across local

jurisdictions.

Comment noted. SCAG is com

jurisdictions in their developm

maintenance of Complete Str

068‐14 Thomas Mauk County of

Orange

Chapter 4‐Sustainable Communities Strategy, Page 150, Table

4.3: We would be excited to participate in the Action/Strategy,

"Collaborate with the region's public health professionals to

enhance how SCAG addresses public health issues in its regional

planning, programming, and project development activities."

Comment noted. The 2012‐20

address comment, as approp
167

ID Name Affiliation Comment Re

The inclusion of "Local Jurisdictions" in the "Responsible

Parties" field would further bolster local collaborations,

including those with Public Health Departments.

068‐15 Thomas Mauk County of

Orange

Chapter 4‐Sustainable Communities Strategy, Page 150, Table

4.3: The Action/Strategy "Consider developing healthy

community or active design guidelines that promote physical

activity and improved health" has considerable promise. The

inclusion of "State" in "Responsible Parties" would bolster

coordination, collaboration, and support in generating

guidelines.

Comment noted. SCAG has ad

"State" in "Responsible Partie

068‐16 Thomas Mauk County of

Orange

Chapter 4‐Sustainable Communities Strategy, Page 150, Table

4.3: In reference to "Engage in a strategic planning process to

determine the critical components and implementation steps

for identifying and addressing open space resources," please

consider including increasing / preserving park space,

specifically in park‐poor communities.

Comment noted. The 2012‐20

address comment, as approp

068‐17 Thomas Mauk County of

Orange

Chapter 4‐Sustainable Communities Strategy, Page 150, Table

4.4: Perhaps the Action/Strategies "Encourage the

implementation of a Complete Streets policy" and "Emphasize

active transportation projects as part of complying with the

Complete Streets Act (AB 1358)" could be tied together

somehow given they will likely be implemented in concert.

Comment noted. SCAG has ad

the actions/strategies.

068‐18 Thomas Mauk County of

Orange

Chapter 4‐Sustainable Communities Strategy, Page 150, Table

4.4: The Action/Strategy "Develop infrastructure plans and

educational programs to promote active transportation

options" may benefit from engaging local public health

departments, walking/biking coalitions, and/or Safe Routes to

School initiatives, who may already have components of such

educational programs in place.

Comment noted. The final RT

comment, as appropriate.

068‐19 Thomas Mauk County of

Orange

Chapter 4‐Sustainable Communities Strategy, Page 150, Table

4.4: We also had some additional suggested language. The

additions are underlined: 1. Perform and support studies with

the goal of identifying innovative transportation strategies that

enhance mobility and air quality, and determine practical steps

to pursue such strategies. [add]Engage local communities in

planning and prioritization efforts.[/add] 2. Continue to work

with neighboring Metropolitan Planning Organizations to

provide alternative modes for interregional travel, including

Amtrak and other passenger rail services, [add]and an enhanced

bikeway network, such as on river trails.[/add] 3. Prioritize

Comment noted. The final RT

comment, as appropriate.
168

ID Name Affiliation Comment Re

transportation investments to support compact infill

development that includes a mix of land uses and housing

options, [add]including park space[/add], where appropriate, to

maximize the benefits for existing communities, especially

vulnerable populations, and to minimize any negative impacts.

068‐20 Thomas Mauk County of

Orange

Chapter 4‐Sustainable Communities Strategy, Page 152, Table

4.5: We also had some additional suggested language...:

Sustainable Support work‐based programs that encourage

emission reduction strategies and [add]incentivize active

transportation commuting or ride‐share modes.[/add]

Comment noted. The 2012‐20

address comment, as approp

068‐21 Thomas Mauk County of

Orange

Chapter 4‐Sustainable Communities Strategy, Page 162, Table

5.1: Augment Safety and Health indicators within RTP

performance measures. Consider measures of obesity, non‐

motorized commuting, walking and biking behavior, asthma

hospitalization rates, etc.

Comment noted. The perform

2012 RTP/SCS was developed 

and input from stakeholders collaboration with other large 

to facilitate the dialogue and 

measures for the 2012‐ RTP/S

Subcommittee was establishe

met and gathered extensive i

and provided recommendatio

Technical Advisory Committe

forwarding to the Policy Com

process and deliberations, ov

have been added to the RTP/

location efficiency. In additio

developed in two types based 

alternatives evaluation and th

Building on the progress, staf

additional measures for futur

068‐22 Thomas Mauk County of

Orange

Chapter 4‐Sustainable Communities Strategy, Page 110: The

goals and benefits of the SCS listed here go above and beyond

the requirements of SB 375. The provisions of SB 375 require

the development of a SCS that focuses on a reduction of vehicle

miles traveled by cars and light trucks, and greenhouse gas

emissions. A presentation made by SCAG in January 2009

indicated that "SB 375 is not about: green buildings, energy

efficiency, municipal operations, waste management, water,

technology." However, all of these items have been

incorporated into the RTP/SCS and PEIR.

Comment noted. The co‐bene

illustrate the potential benefi

contained in the RTP/SCS far 

traveled, and consequently G

the actions and strategies inc

menu of options that local jur

discretion to successfully imp

is intended to provide a regio

governments may build upon 

jurisdictions maintain local la

068‐23 Thomas Mauk County of

Orange

Chapter 4‐Sustainable Communities Strategy, Page 119: SCAG

indicates that the policies of its Compass Blueprint program will

Comment noted. Transit proj

state or federal sources will n
169

ID Name Affiliation Comment Re

be used to determine consistency of private development and

public infrastructure projects with the SCS. A statement should

be added that will clarify whether or not a project that is

determined to be inconsistent with the policies of the SCS (i.e,

Compass Blueprint) will be deemed ineligible for transportation

funding.

as a result of any adopted SCS

Compass Blueprint principles 

policies served only as a foun

use development pattern. Lea

jurisdictions, maintain their o

consistency of any future pro

068‐24 Thomas Mauk County of

Orange

Chapter 4‐Sustainable Communities Strategy, Page 148:

Throughout the document the RTP is described as having

"growth inducing impacts." In past iterations of the RTP, its

purpose was to mitigate the impacts of growth. If

transportation projects identified in the RTP are seen as

inducing growth, then the lead agency may be required to

mitigate the impacts of perceived subsequent related growth.

Comment noted. Clarifying la

final RTP/SCS to address this 

068‐25 Thomas Mauk County of

Orange

There are several terms contained throughout the RTP/SCS and

PEIR that need to be clearly defined including the following: ‐ 

Urban Growth Boundary ‐ References to benchmarks ‐ SCRIP ‐ 

Gentrification ‐ Open space ‐ Parking Cash Out ‐ Smart growth

principles ‐ Active Transportation ‐ Greenfield

Comment noted. These term

068‐26 Thomas Mauk County of

Orange

The alternatives discussed in the RTP/SCS, PEIR and SCS

Background Document have been inconsistently named. The

alternatives are labeled either: 1, 2 and 3, or A, B and C. The

appropriate name should be determined for each and these

documents revised to ensure consistency.

Comment noted. For purpose

PEIR, SCAG developed alterna

were alternately closer to the 

dispersed development patte

single‐family homes compare

aggressively shifted toward in

PEIR alternatives are similar, 

alternatives developed for pla

not use the same names. In p

used the same growth and la

Alternatives, but did not inclu

components at the same leve

068‐27 Thomas Mauk County of

Orange

Chapter 4‐Sustainable Communities Strategy, Pages 82‐83: The

RTP/SCS describes the following measures contained in the

"water resources mitigation program:" 1. "Utilizing advanced

water capture and filtration techniques, showing a preference

for naturalized systems and designs to control stormwater at

the source;" 2. "Avoiding any new construction of impervious

surfaces in non‐urbanized areas, such as wetlands, habitat

areas, parks and near river systems;" 3. "Avoiding any new

construction that provides access to flood‐prone areas, such as

alluvial fans and slide zones;" and 4. "Expansion of (natural

Comment noted. Pursuant to 

requirements, metropolitan l

discussion of potential enviro

including activities that may h

restore and maintain the env

the RTP. As such, the RTP incl

environmental mitigation me

requirement. Additionally the 

of example measures lead ag

discretion to reduce project‐s
170

ID Name Affiliation Comment Re

flood control systems, such as wetlands and riparian buffers) in

areas where they do not currently exist". It is unclear how such

measures would be implemented if they are included in this

document. If they are to be viewed by local jurisdictions as

either goals or suggested policies, they could be implemented

on that basis to the extent they were deemed feasible in any

given case. On the other hand, if listing such measures indicates

they are deemed reasonable and feasible to be applied by

municipalities in all new road projects, that is quite another

matter and not supportable. For example, while it may be

desirable to utilize advanced water capture and filtration

techniques, there is little documented experience with

engineered on‐site capture and filtration to support a

preference for "naturalized systems and designs" in every case.

Similarly, the strongly worded measures against new

construction in wetlands, habitat areas, parks, near river

systems, and flood‐prone areas may be desirable, but should

not constitute an outright prohibition, with hundreds of vacant,

older but long‐established legal building sites situated in such

settings. The word "any" should be removed from the

mitigation measures to address these concerns. Finally, the

suggested expansion of natural flood control systems, such as

wetlands and riparian buffers, in areas where they do not

currently exist is supportable, as long as it does not in any way

mandate removal of existing engineered channel stretches as

"mitigation" for road‐building. In many cases, the only reason a

new road can be built at all is that engineered channels have

reduced flood hazards to that area.

additional response, please se

RTP/SCS, Chapter 4, Response

Letter Number 34.

The mitigation section of the 

revised to clarify that mitigat

discretion of lead agencies.

068‐28 Thomas Mauk County of

Orange

Chapter 4‐Sustainable Communities Strategy, Page 110: One of

the "Benefits to Public Health and the Environment" regards

municipal water and sewer systems. The statement " ...

concrete stormwater channels harm water quality and sprawl

eats into open space" is misleading, and is subject to Regional

Water Quality Control Board regulations that vary by region.

The following alternative language is suggested: Public health

and environmental protection have long been linked to the way

our region is planned and the way public services are delivered.

Municipal water and sewer systems, for example, ensure clean

water. At the same time, [delete]concrete stormwater runoff

channels harm water quality[/delete] [add]as areas become

Comment noted. The 2012‐20

address comment, as approp
171

ID Name Affiliation Comment Re

more urbanized and the percentage of impervious surface is

increased, the hydrologic regime is dramatically altered.

Drainage conveyances that once were natural and riparian are

required to be engineered as hardened flood control channels

to provide adequate protection of private property and public

infrastructure from the increased freguency, duration, peak

flow, and overall volume of stormwater runoff. With this

armoring of once natural channels, water quality benefits from

biofiltration are lost along with opportunities for infiltration and

evapotranspiration, which can lead to hydromodifcation

downstream in sections which are not yet engineered and

hardened. Many strategies contained in the RTP/SCS will

provide widespread benefits within the region for both public

health and environmental protection.

068‐29 Thomas Mauk County of

Orange

Programmed Commitments, Page 2, Table 1: With respect to

Orange County, Sample Major Highway Projects listed in Table 1

for in the FTIP identify improvements to I‐5 (HOV Lanes from

South of Avenida Pice to South of Avenida Vista, completion

year 2020) and I‐405 (Mixed Flow Lanes from SR‐73 to I‐605,

completion year 2018). It is presumed that Caltrans is lead on

these projects and there is no local match/investment

requirement.

Comment noted. FTIP project

to SCAG by the Orange Count

which is responsible for provi

funding levels and sources. Th

agency identification, is publi

available at http://www.scag

068‐30 Thomas Mauk County of

Orange

Programmed Commitments, Page 3, Table 2: In Table 2,

additional county commitments are identified. Therein, there is

reference to: 1. HOV Lanes‐ Reconfiguring the Avenida Pico

Interchange at the I‐5 in San Clemente‐ completion year 2014.

2. Toll Lanes‐ Constructing HOV/HOT connectors for SR‐

91/SR241 –completion year 2018. 3. Mixed Flow Lanes ‐ 

Reconfiguring the interchanges at Avery Parkway and La Paz in

Mission Viejo ‐ completion year 2020. There is also mention of

improving the interchange at SR‐91/SR‐55 and Lakeview Avenue

in Anaheim‐ completion year 2023. It is presumed that Caltrans

is lead on these projects and there is no local match/investment

requirement. (These projects are not listed in OC Public

Works/7‐year Transportation Capital Improvement Program,BOS Approved on 6‐28‐2011.)

Comment noted. FTIP project

to SCAG by the Orange Count

which is responsible for provi

funding levels and sources. Th

agency identification, is publi

available at http://www.scag

068‐31 Thomas Mauk County of

Orange

Page 2, Federal Transportation Improvement Program (FTIP)

Project List: 1. FTIP ORA120357‐ Orange County, Traffic signal

Synchronization for Bus Rapid Federal Transit Corridors, Route

0 • Is funding tied to OC Public Works/Road's Antonio Parkway

Comment noted. FTIP project

to SCAG by the Orange Count

which is responsible for provi

funding levels and sources. Th
172

ID Name Affiliation Comment Re

Corridor Traffic Signal Synchronization programmed for FY

2012‐13? Coordination between Program OCTA and OC Public

Works/Road is recommended. 2. FTIP ORA120326 Route 5 and

FTIP ORA000152, FTIP 120506 and ORA120507 on Route 74 •

Comment/Question: Is funding tied to OC Public Works/Road's

La Pata Avenue (Engineering) and La Pata Avenue NEPA

(permitting) projects programmed for FY 2011‐12, Pata Avenue

Land Acquisition programmed for FY 2012‐13 and La Pata

Avenue (construction) programmed for FY 2013‐14? 3. FTIP

2A0804 and ORA082401 Route 0, Cow Camp Road from FTC to

Ortega • Is funding tied to OC Public Works/Road's Cow Camp

Road Segment 1 (Engineering) programmed for FY 2011‐12,

Cow Camp Road‐ Segment 1 (Construction) and Cow Camp Road

Segment II (Engineering) programmed for FY 2012‐13, and Cow

Camp Road‐ Segment II (Construction) programmed for FY

2013‐14 4. FTIP ORA82406 Antonio Parkway Build Out between

Ladera Planned Communities to Ortega Highway • Not shown

listed in OC Public Works/? ‐year Transportation Capital

Improvement Program, BOS Approved on 6‐28‐2011. 5. FTIP

ORA120505 Alton Parkway Improvements ‐Irvine Blvd toCommercentre Drive • Not shown listed in OC Public Works/? ‐

year Transportation Capital Improvement Program, BOS

Approved on 6‐28‐2011. • Coordination with County required ‐

Adjacent to James A Musick Branch Jail

agency identification, is publi

available atComment noted.

http://www.scag.ca.gov/ftip/

project information should be 

needed changes should be su

accordance with established 

068‐32 Thomas Mauk County of

Orange

Page 2, Federal Transportation Improvement Program (FTIP)

Project List (continued): 6. FTIP ORA 120523 on Route 0,

Placentia‐ Richfied Ave. ‐Atwood Channel Bridge Widening •

Coordination with OCFCD required. 7. FTIP ORA020826 on

Route 0, Tustin Ave/rose Drive Grade Separation • Coordination

with County and OCFCD required. 8. FTIP ORA100603 on Route

0, Santa Ana River Trail • Coordination with OCFCD required. 9.

Financially‐Constrained RTP Projects, 210 10. RTP ORA 120357

Orange County Traffic signal Synchronization for Bus Rapid

Transit Corridors‐ see FTIP Projects above 11. RTP ORA120326

Route 5‐ see FTIP Projects above 12. RTP ORA 120523 Richfield

Avenue‐ see FTIP Projects above, completion FY 2012 13. RTP

2A0705 Signal Synchronization Program ‐see FTIP ORA 120357

above, completion FY 2035 14. RTP 2L220 Non‐motorized,

completion FY 2035 • No projects are identified in OC Public

Works/Road 7 year CIP. 15. RTP 2A0804 Cow Camp Road,

Comment noted. FTIP project

to SCAG by the Orange Count

which is responsible for provi

funding levels and sources. Th

agency identification, is publi

available at http://www.scag

about FTIP project informatio

any needed changes should b

accordance with established 
173

ID Name Affiliation Comment Re

completion FY 2018‐ see FTIP Projects listed above Laguna

Canyon Road Projects identified in OC Public Works 7 year CIP

for FY 2011‐12 (SR‐73 to I‐405 and SR‐73 to El Taro Road) were

not identified in the report nor was that for the El Taro Road

widening from Glen Ranch Road to Live Oak Canyon currently

programmed for FY 2014‐15.

068‐33 Thomas Mauk County of

Orange

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

069‐01 Andrew Mack DesertXpress

Enterprises,LLC

Chapter 1: Vision, page 21. Passenger and High Speed Rail ‐ 

Request adding a discussion of DesertXpress. Although included

in the Strategic Plan, as a federally licensed and approved

interstate passenger railroad, DesertXpress will help to achieve

the vision for high speed passenger rail in Southern California.

Comment noted.

069‐02 Andrew Mack DesertXpress

Enterprises,LLC

Chapter 2: Transportation Investment, page 44. Strategically

Expanding our System ‐ Suggest adding language describing that

by diverting automobiles, high speed rail increases the goods

movement capacity of the freeway system.

Comment noted. To the exte

automobile trips, any roadwa

from this diversion would be 

movement (trucks) but for m

automobiles and buses.

069‐03 Andrew Mack DesertXpress

Enterprises,LLC

Chapter 2: Transportation investments, page 50. Passenger and

High Speed Rail ‐ Request adding that a connection to the

DesertXpress system between Victorville and Palmdale would

effectively expand passenger rail service providing interstate

high speed rail connectivity.

Comment noted.

069‐04 Andrew Mack DesertXpress

Enterprises,LLC

Chapter 2: Transportation investments, page 52. Rail Policies ‐ 

Suggest adding language to explain that DesertXpress is

committed to building an interoperable system and welcomes

the support of SCAG in working with us to ensure that

interoperability between systems is achieved. The MOU

between SCAG, LAMETRO, CAHSRA, SANBAG, SANDAG etc.

should be referenced.

Comment noted. The Memor

discussed on pages 11 and 16 

SCAG supports working with 

providers to work on interope

069‐05 Andrew Mack DesertXpress

Enterprises,LLC

Chapter 4: Sustainable Communities Strategy, page 106. Table

4.4: Transportation Network Actions and Strategies ‐ Suggest

including language in table to encourage connectivity with

DesertXpress.

Comment noted.

069‐06 Andrew Mack DesertXpress

Enterprises,LLC

Chapter 7: Strategic Plan, page 201. Chapter 7: Strategic Plan ‐ 

Suggest adding electrified passenger rail in addition to freight

rail as a strategy for emission reduction.

Comment noted.

069‐07 Andrew Mack DesertXpress

Enterprises,

Chapter 7: Strategic Plan, page 204. Ultimate Vision for a High‐

Speed Rail System ‐ Suggest adding more detail regarding

Comment noted. This comme

Passenger Rail Appendix.
174

ID Name Affiliation Comment Re

LLC DesertXpress. DesertXpress is a Federally approved and licensed

high speed passenger railroad that connects Las Vegas with

Southern California. With its Southern California station initially

in Victorville, an extension of DesertXpress to Palmdale, 50

miles West, would provide for a cross platform connection to

the Metrolink commuter rail system with station stops

throughout Southern California. Fully interoperable high speed

service would be achieved over the California high speed rail

project or upgraded Metrolink system. Environmental work has

already begun to analyze and clear the rail connection between

Victorville and Palmdale as part of the High Desert Corridor

project. The High Desert Corridor Joint Powers Authority

(comprising San Bernardino County, Los Angeles County, City of

Adelanto, City of Hesperia, City of Palmdale, and City of

Victorville) passed resolutions of support for DesertXpress in

May 2010 and June 2011. The DesertXpress project specific EIS

is complete with the following Federal actions: July 8, 2011:

Federal Railroad Administration Record of Decision (ROD)

October 26, 2011: Surface Transportation Board issued

Certificate of Public Convenience and Necessity. October 31,

2011: Bureau of Land Management ROD November 18, 2011:

Federal Highway Administration ROD On December 7, 2011,

DesertXpress executed a lease agreement with BLM for the

alignment and facilities located on federal land. Application for

a federal loan under the Railroad Rehabilitation and

Improvement Financing program currently under review by US

Department of Transportation.

069‐08 Andrew Mack DesertXpress

Enterprises,LLC

Supplemental Report: Aviation and Airport Ground Access, page

112. 2.3.2 Role of California High‐Speed Rail System in Regional

Airport Ground Access ‐ Suggest adding discussion of potential

for DesertXpress connection at the Palmdale Airport.

Comment noted.

069‐09 Andrew Mack DesertXpress

Enterprises,LLC

Supplemental Report: Passenger Rail, page 8. Table 2: High

Speed Rail Matrix ‐ Suggest revising as follows: PROJECT:

DesertXpress PROJECT DESCRIPTION: Las Vegas to Victorville

with no intermediate stops generally along I‐15 corridor. Phase

2 would connect Victorville with Palmdale. Top speed of 150

MPH using Tier III compliant electric multiple unit trains.

PROJECT READINESS: Project specific EIS is complete and federal

interstate operating license has been issued. July 8, 2011:

Federal Railroad Administration Record of Decision (ROD).

Comment noted. The Final RT

this comment.
175

ID Name Affiliation Comment Re

October 26, 2011: Surface Transportation Board issued

Certificate of Public Convenience and Necessity authorizing

DesertXpress as an interstate railroad. October 31, 2011:

Bureau of Land Management ROD. November 18, 2011:

California and Nevada Federal Highway Administration RODs.

December 7, 2011, DesertXpress executed a lease agreement

with BLM for the alignment and facilities located on federal

land. PROJECT CONSENSUS: High ‐ as evidenced by the

completed NEPA process, agreements in place with the State of

California, Certificate of Public Convenience and Necessity from

the Surface Transportation

069‐10 Andrew Mack DesertXpress

Enterprises,LLC

Supplemental Report: Passenger Rail, page 18. the Strategic

Plan: Our Ultimate Vision for High Speed Rail ‐ Suggest adding

DesertXpress and connection to California High Speed Rail and

upgraded Metrolink service as a key component of the Ultimate

Vision for High Speed Rail.

Comment noted. The Final RT

this comment.

069‐11 Andrew Mack DesertXpress

Enterprises,LLC

Supplemental Report: Passenger Rail, page 19. Strategic Plan

Projects ‐ DesertXpress is a Federally approved and licensed

high speed passenger railroad that connects Las Vegas with

Southern California. Travelling between Las Vegas, NV and

Victorville, CA at a top speed of 150 MPH, DesertXpress will use

next generation steel wheel on steel rail fully electric high speed

trains. There are no intermediate stops. The DesertXpress

project specific EIS is complete: ∙ July 8, 2011: Federal Railroad

Administration Record of Decision (ROD) ∙ October 26, 2011:

Surface Transportation Board issued Certificate of Public

Convenience and Necessity. ∙ October 31, 2011: Bureau of Land

Management ROD ∙ November 18, 2011: Federal Highway

Administration ROD ∙ On December 7, 2011, DesertXpress

executed a lease agreement with BLM for the alignment and

facilities located on federal land. With its Southern California

station initially in Victorville, an extension of DesertXpress to

Palmdale, 50 miles West would provide for a cross platform

connection to the Metrolink commuter rail system with station

stops throughout Southern California. Fully interoperable high

speed service would be achieved over the California high speed

rail project or upgraded Metrolink system. Environmental work

has already begun to analyze and clear the rail connection

between Victorville and Palmdale as part of the High Desert

Corridor project. The High Desert Corridor Joint Powers

Comment noted. The Final RT

this comment.
176

ID Name Affiliation Comment Re

Authority (comprising San Bernardino County, Los Angeles

County, City of Adelanto, City of Hesperia, City of Palmdale, and

City of Victorville) passed resolutions of support for

DesertXpress in May 2010 and June 2011. Application for a

federal loan under the Railroad Rehabilitation and Improvement

Financing program currently under review by US Department of

Transportation.

070‐01 Lars

Clutterham

downeygreen Downeygreen is a non‐profit partnership advocating

sustainability in the City of Downey. As such, we have actively

participated in the development of this RTP/SCS over the past

year, including its progress at the subregional level through the

Gateway Cities COG.

Comment noted.

070‐02 Lars

Clutterham

downeygreen We want to forcefully underline the need to strengthen the

active transportation objectives set forth in the RTP/SCS.

Comment noted.

070‐03 Lars

Clutterham

downeygreen We further support the additional commitment requested in its

letter by the Safe Routes to School National Partnership, which

calls for increasing the proposed RTP investment in active

transportation to as much as five through eight percent of the

total 2012 plan.

Comment noted.

070‐04 Lars

Clutterham

downeygreen We also agree with Safe Routes to School that the RTP should

equalize disbursements to active transportation over the entire

course of the RTP/SCS through 2035.

Comment noted.

070‐05 Lars

Clutterham

downeygreen As we stated at the public hearing on February 2, the City of

Downey, in the heart of the SCAG region, is a city locked into

the transportation and land use culture of the 1950's and '60's.

Despite giving lip service to developing bicycle transportation in

its current General Plan and in its 2010 Downtown Specific Plan

(which received a Compass Blueprint Award), the City of

Downey offered no contribution to the active transportation

projections of the Gateway Cities COG sub‐regional SCS through

2035.

Comment noted.

070‐06 Lars

Clutterham

downeygreen Moreover, the City of Downey has just approved a major

shopping center development which, according to current

plans, prioritizes the automobile and lacks transit access.

Therefore, we feel it is especially important that SCAG continue

to show strong leadership in promoting the necessary evolution

to new transportation paradigms in southern California.

Comment noted.

070‐07 Lars

Clutterham

downeygreen The Draft RTP/SCS includes one very brief appendix on Vehicle

Technology which mentions Electric Vehicles. Yet Southern

Comment noted. Chapter 4, S

includes a discussion of Regio
177

ID Name Affiliation Comment Re

California Edison projects between 400,000 and one million

Electric Vehicles in the region by 2020. We believe some

mention of EV technology should be made in the body of the

2012 RTP/SCS, and we hope that SCAG will begin to plan to

promote the development of an EVSE infrastructure in southern

California for the 2016 RTP.

Clean Vehicle Technology. Sp

response to PEV market forec

work program to prepare for 

with the South Coast Air Qua

California Edison, Western Ri

(WRCOG), the South Bay Citie

(SBCCOG) and a wide array of 

SCS includes two strategies fo

support and promote zero or 

including the introduction of 

emission/near zero‐emission 

SCAG is currently engaged in 

Southern California for the fo

Vehicles (PEV), which will red

and SB 375, and attract green 

SCAG recognizes that a region

necessary to adequately addr

better understand the on‐goi

region, SCAG has coordinated 

utilities, subregional councils 

jurisdictions and other key re

included PEV related actions 

that would support and expa

In June 2011, SCAG, in conjun

applied for two PEV planning 

applications. The first grant, a

Energy (DOE) has as its prima

Regional PEV Readiness Plan 

Coast Air Quality Managemen

statewide application in partn

Quality Management District, 

Collaborative, and Clean Citie

awarded $1 million to PEV Re

$300,000 going to SCAG.

The second successful grant a

California Energy Commission 

collaborative effort between 

with SCE, the Western Rivers

(WRCOG), and South Bay Citie

(SBCCOG). This grant has bee
178

ID Name Affiliation Comment Re

purpose of the project is to d

subregional plans in collabora

These subregional plans will s

subregions as they begin to d

Plans.SCAG will continue to work w

new planning effort and will p

additional stakeholders as the 

071‐01 Leonard

Kranser

Editor, El Toro

Info Site

The 2035 RTP Aviation Plan is based on assumptions that the

legal restrictions on the capacity of existing urban airports ‐ Los

Angeles International, John Wayne, Bob Hope and Long Beach ‐ 

will continue unchanged through 2035. Consequently, growing

future demand is forecast by SCAG to be met at remote airports

that have been shown to be unpopular with many passengers

and air carriers. Ontario Airport has seen a substantial decline in

traffic and Palmdale was unable to generate enough volume to

become sustainable, even with government subsidies. The Table

2.7 2035 Airport Forecasts are unrealistic. The plan uses

assumptions about levels of future demand and should also

incorporate reasonable assumptions about changes in the

future constraints on the urban airports. The negotiated

agreements that limit the utilization of the region's most

accessible airports will expire well before 2035. It is

unreasonable to assume that the FAA, funding sources, airlines

and the traveling public will not insist that the limits be relaxed

in order to accommodate future demand. With newer, quieter

and less polluting aircraft, it should become more politically

acceptable to handle more flights at these existing facilities.

Unrealistic assumptions about which airports will serve the

region, and to what degree, may lead to unrealistic assumptions

about ground access needs.

Comment noted. The 2035 re

forecasts in the Draft 2012‐20

Sustainable Communities Stra

legally‐allowable and defined 

constrained urban airports in

and John Wayne. SCAG recog

agreements at both LAX and J

2015‐2020 time period, and t

settlement agreement constr

significantly impact forecast a

other airports in the regional 

difficult to determine whethe

established at current or high

after the existing settlement 

expire. Future updates of the 

will incorporate any new info

airport authorities on revised 

constrained airports.

072‐01 Connell

Dunning

Environmental

ProtectionAgency

Section 6001 Safe, Accountable, Flexible, Efficient

Transportation Equity Act: A Legacy for Users (SAFETEA‐LU)

directs metropolitan planning organizations to consult with

resource agencies while developing long‐range transportation

plans. It also states that long range transportation plans must

include “a discussion of types of potential environmental

mitigation activities and potential areas to carry out these

activities, including activities that may have the greatest

potential to restore and maintain the environmental functions

Comment noted.
179

ID Name Affiliation Comment Re

affected by the plan.” EPA provides the following comments in

support of compliance with these requirements.

072‐02 Connell

Dunning

Environmental

ProtectionAgency

Environmental Justice and children ‘s Health The Draft RTP

provides a summary of public involvement efforts and a

thorough Environmental Justice Analysis including

recommendations from the public outreach meetings. The

Environmental Justice Analysis finds many potential disparate

impacts on minority, low‐income, and other sensitive

communities. These impacts are a result of gentrification, air

quality impacts, and noise. The Draft RTP provides evidence that

environmental justice communities in the SCAG Region are

already heavily burdened as a result of exposure to air pollution

from transportation related activities. The communities willcontinue to be impacted with the many projects planned in the

SCAG Region. Therefore, all impacts, even seemingly small ones,

are important to consider and mitigate in order to offset the

project related impacts to the local communities. EPA is

encouraged to see that, new to the 2012 RTP, the 1

Environmental Justice Analysis considers cancer and respiratory

risks and air quality impacts along freeways and highly traveled

corridors. Children as Sensitive Age Group The Environmental

Justice Analysis includes one age variable: population 65 years

old and older. Children are another sensitive age group that

should be included in the Environmental Justice analysis.

Environmental contaminants may harm children more than

adults. Minority and low‐income children may be exposed to

more pollution and therefore, may face higher health risks from

exposures. An important indicator in screening for potential

environmental justice concerns is the percent of the population

under five years old.” 2There is a growing body of evidence that

environmental justice communities are disproportionately

exposed and more vulnerable to pollution impacts than other

communities. 3As discussed in EPA ‘s Frameworkfor Cumulative

Risk 4disadvantaged, underserved, and overburdened

communities are likely to come to the table with pre‐existing

deficits of both a physical and social nature that make the

effects of environmental pollution more, and in some cases,

unacceptably, burdensome. Thus, certain subpopulations may

be more likely to be adversely affected by a given stressor than

is the general population. • EPA recommends that the

Comment noted. Additional a

Final Environmental Justice (E

health and emissions impacts 

of age. Included in this sectio

respiratory risk for areas with 

children, along with projected 

RTP/SCS on young children fo

the region’s freeways and hig
180

ID Name Affiliation Comment Re

Environmental Justice Analysis in the Final RTP, and included

health analyses, include percent of the population under five

years old as a variable to elucidate how young children in

environmental justice communities will be impa

072‐03 Connell

Dunning

Environmental

ProtectionAgency

Environmental Justice Mitgation Toolbox The Draft RTP provides

an Environmental Justice Mitigation Toolbox with

recommended mitigations for noise impacts, air quality, rail

related impacts, and road pricing mechanisms. The mitigations

are recommendations and are not required through the Draft

RTP. The Draft RTP uses the language that the project sponsors

should “to the extent feasible and practicable” apply these

mitigations to the project. The recommended mitigations are

critical to protecting the health of the environmental justice

communities in the SCAG region. EPA recognizes the

importance of these mitigations and recommends that the

project sponsors not only apply these mitigations but also seek

out further recommendations from the affected community.

The current mitigation toolbox provides a list of broad

mitigations that are specific to project construction and

implementation. • Community identified mitigations could

include more holistic approaches to protecting health including:

o Fund proactive measures to improve air quality in neighboring

homes, schools, and other sensitive receptors; o Provide public

education programs about environmental health impacts to

better enable residents to make informed decisions about their

health and community; and o Engage in proactive measures to

train and hire local residents for construction or operation of

the project to improve their economic status and access to

health care. • EPA also recommends that the list of available air

quality tools in the Environmental Justice Toolbox ‐ Air Quality

Impacts be revised to include near‐term advanced technology

deployment measures, such as: o zero emissions heavy‐duty

trucks (20 13+); o Tier 4 marine engine repowers and

replacements (20 14+); and o Tier 4 and zero emissions railyard

equipment (2015+). o See

http://www.dieselnet.com/standards/us/marine.php and

http://www.dieselnet.com/standards/us/loco.php. Future

Project‐level Environmental Justice Analyses Additionally, the

Environmental Justice Appendix provides detail on how the

Environmental Justice Analysis was performed, with the analysis

Comment noted. SCAG will p

in the both the EJ appendix a

quality impacts. Please refer t

outlines more potential mitig

quality impacts of transportat

throughout the region. In the 

mitigation programs may also 

initiatives as a means for redu

quality and emissions on the 

committed to improving the q

Californians and will continue 

environmental mitigation in t
181

ID Name Affiliation Comment Re

conducted with input from the community. • EPA recommends

that the Final RTP acknowledge that project sponsors should

provide a similar level of analysis to identify the Environmental

Justice impacts of each project. With consistency in analysis and

meaningful involvement from the affected community,

mitigation measures can be identified to best address the

project’s impacts.

072‐04 Connell

Dunning

Environmental

ProtectionAgency

Sustainable Communities Strategy and Regional Zero Emissions

Freight System The Draft RTP recognizes that that SCAG region

has substantial mobility and air quality challenges, with the

most congested roadways in the nation and the worst air

quality in the nation. The Draft RTP also identifies its region as

the largest international trade gateway in the U.S., supported by

marine ports, air cargo facilities, railroads, regional highwaysand state routes. SCAG has a great opportunity to face these

challenges with planning efforts that are underway to establish

a regional zero emission freight system and the RTP’s inclusion

of a Sustainable Community Strategy (SCS), intended to reduce

greenhouse gas (GHG) emissions from automobiles and light

trucks through integrated transportation, land use, housing and

environmental planning. • EPA encourages SCAG to use the

current needs for efficient and cleaner freight movement as a

catalyst for initiating the most advanced technological solutions

to freight movement, including zero emissions technologies, in

this transportation planning effort. Part of SCAG’s Regional Zero

Emissions Freight System includes a system of truck‐only lanes

extending from the San Pedro Bay Ports to downtown Los

Angeles along the 1‐7 10, connecting to an east‐west segment,

and finally reaching the 1‐15 in San Bernardino County. Truck‐

only lanes add capacity in congested corridors, improve truck

operations and safety by separating trucks and autos, and

would provide a platform for the introduction and adoption of

zero‐emission technologies. The 2012 RTP identifies an East‐

West Freight Corridor concept (Exhibit 2.9 Potential East‐West

Freight Corridor shows lanes along the 1‐710, SR 60, and 1‐15 to

just north of 1‐10), carrying between 58,000 and 70,000 trucks

per day, with trucks removed from adjacent general purpose

lanes and local arterial roads.

Comment noted.

072‐05 Connell

Dunning

Environmental

Protection

SCAG’s SCS focuses the majority of new housing and job growth

in high‐quality transit areas and other opportunity areas in

Comment noted. The estimat

established science and some 
182

ID Name Affiliation Comment Re

Agency existing main streets, downtowns, and commercial corridors,

resulting in an improved jobs‐housing balance and more

opportunity for transit‐oriented development. EPA is pleased to

see that the RTP provides a greater investment in transit

projects and an allocation of over $6 billion for active

transportation projects, a 200‐percent increase from the 2008

RTP. EPA supports the investment of a greater share of

transportation resources to promoting public transit and other

alternative modes instead of facilitating single‐occupant vehicle

use. Efforts to expand transit service, increase rideshare, and

integrate bicycle and transit nodes offer the opportunity to

support the region’s goal of reducing growth in vehicle miles

traveled (VMT) and in turn, improve air quality. The emphasis

on planning for additional housing and jobs near transit will also

assist in decreasing VMT and related pollutant emissions. While

intended to relieve congestion, freeway capacity expansion

projects such as truck‐only lanes and HOV/Toll Lanes, may have

initially beneficial congestion relief that erodes over time,

potentially resulting in increased VMT and auto emissions. •

Since the RTP includes several projects that expand freeway

capacity, EPA recommends that the Final RTP include a

discussion of induced travel to ensure that these projects do not

counter the very VMT and emission benefits expected from

SCAG’s SCS and Regional Zero Emissions Freight System.

tools and models. However, o

capacity projects are found in 

increases in congestion. The 2

strategy that incorporates tra

transportation strategies as w

congestion pricing strategies 

system performance. SCAG w

of induced demand in future 

072‐06 Connell

Dunning

Environmental

ProtectionAgency

Technologies for Transportation Investments This section of the

plan cites several compelling strategies, which presumably will

result in significant emissions reduction. However, the Draft RTP

does not clearly outline what the requisite technologies are in

relation to emissions standards for the relevant source

categories. • EPA recommends including clearer descriptions of

the technologies listed in the Transportation Investments

section of the RTP. Definition of “clean truck” EPA suggests

defining the term “clean truck” in relation to current vehicle

emissions standards. This term is listed in the Vision and

Transportation Investments sections of the RTP, as well as in the

Goods Movement supplemental report. One option for defining

this technology would be to compare its emissions to the EPA

2010 heavy‐duty truck standard.

Comment noted. Further clar

appropriate for RTP documen

additional details as suggeste

reports for SCAG’s Comprehe

Plan and Implementation Stra

072‐07 Connell

Dunning

Environmental

Protection

Measuring Environmental Results of the RTP The Draft RTP has

identified criteria pollutant and greenhouse gas emissions as its

Comment noted. The perform

2012‐2035 RTP/SCS has been 
183

ID Name Affiliation Comment Re

Agency sole performance measure and indicator for environmental

quality. Given that the region has experienced significant losses

to species and habitat from development encroachment and

transportation construction, EPA encourages SCAG to consider

sensitive habitat as a performance standard and indicator for

environmental quality when updating the RTP. • EPA

recommends SCAG consider demonstrating the RTP’ s

effectiveness at protecting species, wildlife or wetland habitat,

and/or open space. If additional performance standards are not

possible during the 2012 RTP update given the already

extensive efforts to develop the identified performance

outcomes and measures, the Final RTP should describe if there

are appropriate performance standard surrogates, such as land

consumption under Location Efficiency, to measure the RTP’s

success in protecting sensitive habitat.

participation and input from 

as collaboration with other la

example, to facilitate the dial

performance measures for th

Performance Measures Subco

2011. The Subcommittee met 

from various stakeholders an

the Plans and Programs Tech

further discussions prior to fo

Committees. As a result of th

over 20 new performance me

RTP/SCS including new catego

addition, performance measu

types based on their intended 

evaluation and the other for o

this progress, staff will contin

performance measures includ

EPA for future plan updates.

072‐08 Connell

Dunning

Environmental

ProtectionAgency

RTP Environmental Mitigation Program SAFETEA‐LU Section

6001 requires long range transportation plans to include a

discussion of potential environmental mitigation activities and

potential areas to carry out these activities that may have the

greatest potential to restore and maintain the environmental

functions affected by the plan. The Draft RTP acknowledges that

the PEIR includes three categories of mitigation measures

(regional, local, and project‐specific, as described on p.76);

however the Draft RTP identifies a separate, broad strategy to

link transportation planning to the environment, such as

planning transportation routes to avoid and minimize a number

of biological impacts and regional mitigation strategies such as

mitigation banking, improving! retaining habitat linkages,

preserving wildlife corridors and wildlife crossings to minimize

the impact of transportation projects on wildlife species and

habitat fragmentation. The Draft RTP notes that maps of

protected and unprotected areas, representing SCAG’s open

space infrastructure (from SCAG’s 2008 Regional

Comprehensive Plan), will be updated as a function of post‐RTP

planning efforts, that areas that are “unprotected” could be

possible locations for mitigation, and that SCAG will continue to

work with its regional partners to help facilitate conservation. •

Comment noted. The propose

pursue a strategic planning p

resources. The intent is to inc

based on input from a wide v

intent to defer to the county 

other local agencies to determ

mechanism for its region with 

guidance from the resource a

welcomes input from EPA in t

process.
184

ID Name Affiliation Comment Re

While EPA is supportive of many of the broad mitigation

strategies identified, EPA recommends that the environmental

mitigation discussion in the Final RTP incorporate specific

information from the Regional Comprehensive Plan that will

inform regional avoidance and minimization strategies when

planning regional transportation networks and possible

locations for mitigation. • The Final RTP should also provide

additional information on post‐RTP comprehensive and

conservation planning efforts and describe how anticipated

outcomes and products will be incorporated into long‐term

planning for transportation infrastructure.

072‐09 Connell

Dunning

Environmental

ProtectionAgency

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

073‐01 Gwenn

Norton‐Perry

Four Corners

Coalition

The Four Corners Coalition has a 20 year history of supporting

regional solutions to the transportation challenges that occur in

the heart of Southern California. The jurisdictional coordination

where four of your six counties come together can be a

challenge. We are very pleased with the cooperation that has

occurred in the region over the past several years and the

continuing efforts that are represented in the Regional

Transportation Plan (RTP). For example: the Universal Transit

Fare Cards (Smart Cards)are the exact type of regional

alignment that is necessary for increasing the overall

effectiveness of our transportation system. We would suggest

that the various TSM strategies capture the essence of this by

adding such phrases as: Multi jurisdictional traffic signal

synchronization, and Region wide advanced traveler

information, Multi agency improved data collection

Comment noted.

073‐02 Gwenn

Norton‐Perry

Four Corners

Coalition

We also support the principles outlined by the Global land use

and Economics committee of SCAG: Provides Positive Economic

Impacts – Pro Economic Growth and Job Creation Provides Local

Control: Any new transportation revenues or fees collected

must be under the control of the local transportation

agency/authority o Cities, counties and local transportation

agencies must maintain appropriate control and flexibility in

managing decisions and resources related to land use and

transportation Is CEQA Compliant and Defensible – The RTP/SCS

is built to withstand a CEQA Challenge Is Balanced – The plan’s

call for New Revenue is balanced with Performance Measures,

Comment noted. We agree th

consideration for any new rev

assume nor would it result an

transportation revenues that 

transportation agency/autho

powers to SCAG. The Transpo

additional detail and explanat

included in the RTP. We cons

principles as a foundation for 

revenues that are reasonably 

financial strategies: • Establis
185

ID Name Affiliation Comment Re

Reforms and Guarantees that assure the RTP is Effective,

Efficient and Responsible Align the plan investments and

policies with improving regional economic development and

competitiveness. Avoid costly projects like a light rail desert

connect that helps move money out of the southern California

region to Nevada and does not address the immediate needs of

the region’s existing transportation needs. Maximize the

productivity of our transportation system. Look at peak time

pricing and transportation demand management (TDM) cost

recovery approach.

reflects the true cost of trans

protection for transportation 

distribution of costs and bene

programs that include return

maintaining flexibility to rewa

commit substantial local reso

funding with innovative finan

expansion of TIFIA) to attract 

project delivery. • Promote fu

federal commitment to the n

recognizing the pivotal role th

and international trade. The i

return of $2.90 for every doll

073‐03 Gwenn

Norton‐Perry

Four Corners

Coalition

We continue to support the improvements to those freeways

that carry significant intra‐county traffic flow: SR 71, SR 57 up to

and including the SR 60 / SR 57 intersection, SR‐91, I‐15, I‐10.

The following improvements are listed: SR‐71‐Addition of one

HOV lane in each direction from I‐10 to SR‐60 • SR‐71‐Addition

of one HOV lane in each direction from I‐10 to SR‐60 • SR‐91‐

Addition of one HOV lane in each direction from Adams to SR‐

60/21 • I‐10‐Addition of one HOV lane in each direction from

Haven to Ford • Addition of HOT lanes on I‐10 • SR‐91‐

Convertion of HOV lanes to tolled express lanes and addition of

direct connector • SR‐91‐Addition of one eastbound mixed‐flow

lane from SR‐91/55 connector to SR‐241 and one westbound

mixed‐flow lane from SR‐241 to Imperial Highway • SR‐91‐

Addition of one mixed‐flow lane in each direction at various

locations from SR‐241 to Pierce Street • I‐15 Construction of

New Schleisman Rd IC and ramps with a NB/SB Auxiliary lane

between Schleisman Rd IC and Limonite Rd IC. • SR‐71‐ Pine

Avenue connector from the SR‐71 off‐ramp to Pine/Schleisman

Road for convertibility to the I‐15, through Chino and Eastvale

Comment noted.

074‐01 Constance

Spenger

Friends ofCoyote Hills

Thank you for the opportunity to comment on the Southern

California Association of Governments (SCAG) 2012 Regional

Transportation Plan (RTP) and Sustainable Community Strategy

(SCS). Friends of Coyote Hills is based in Fullerton, and our

mission is to permanently protect all 510 acres of West Coyote

Hills, one of the last remaining natural open spaces in north

Orange County, from development through acquisition, to

ensure a lasting public park for recreation and enjoyment. Our

Comment noted.
186

ID Name Affiliation Comment Re

organization includes support from 20,000 residents in Orange

and Los Angeles Counties. We are writing to provide comments

on the Draft 2012 RTP/SCS and the Draft Program

Environmental Impact Report (PEIR). We are so pleased to see

an advanced mitigation component in the Draft 2012 RTP/SCS.

This is a remarkable first step to creating a program that

thoughtfully mitigates impacts to our natural environment from

transportation projects. As you know, Orange County and San

Diego have similar programs that have met great success. By

incorporating this strategy into your policy document, the many

benefits of this large‐scale conservation approach will be

realized. Thank you for your leadership.

074‐02 Constance

Spenger

Friends ofCoyote Hills

Under the Endangered Species Act, the United States Fish and

Wildlife Service have defined critical habitat as areas that

support endangered or threatened species that are essential to

the species’ conservation. The description in the Conservation

Planning Policy section (page 76 of the Draft 2012 RTP/SCS)

states “large‐scale acquisition and management of critical

habitat to mitigate impacts related to future transportation

projects” [emphasis added]. We believe there are other habitat

areas in the SCAG region worth considering for acquisition and

management and therefore SCAG should not limit the

mitigation opportunities to only critical habitat. We suggest

expanding the language to incorporate all “important habitat

lands.” Because this program is directly tied to the

implementation of transportation projects there is a clear

connection to the County Transportation Commissions (CTCs).

We do however, respectfully request that conservation‐focused

organizations and conservation focused state agencies,

conservancies, and joint power authorities be included in the

discussions regarding setting priority conservation areas. For

example, Friends of Coyote Hills has specific knowledge about

lands and linkages in and near West Coyote Hills. We offer our

expertise to you during this process. In addition, we also believe

targeted outreach efforts in each of the SCAG counties would

create an open and transparent process for setting priorities.

This recommendation also applies to the limited scope of

“agencies” in the Resource Areas and Farmlands section (page

128 of the Draft 2012 RTP/SCS).

Comment noted. The propose

pursue a strategic planning p

resources among a wide varie

include all applicable protecte

clarified.

074‐03 Constance Friends of Locations for Mitigation (pg. 78 of the Draft 2012 RTP/SCS) On Comment noted. The propose
187

ID Name Affiliation Comment Re

Spenger Coyote Hills page 78 of the Draft 2012 RTP/SCS , the document mentions the

2008 Regional Comprehensive Plan that inventoried protected

and unprotected areas in relationship to wildlife linkages,

linkage designation areas, park and recreation areas. We were

pleased that SCAG completed this Plan showing what areas are

protected and critical to maintaining functioning habitat

reserves. We agree that the planning efforts SCAG undertakes in

the future should involve updating the maps, but recommend

expanding the language in this section to include all forms of

protected lands. By limiting the acquisition and management

opportunities of conservation lands to just Natural Communities

Conservation Plan (NCCP) or Habitat Conservation Plan (HCP)

areas, decisions about priority conservation areas will be

misinformed. In fact, it no longer demonstrates a

comprehensive plan because of the limited scope (of pre‐

established mitigation sites, which are likely unrelated to

transportation projects). Protected areas (e.g., National Forests,

State Parks, Regional Parks, etc.) not in an NCCP/HCP are

excluded from the big picture, yet they have extensive benefits

to the entire open space system and often times link important

habitat areas throughout the region. Consequently, we

recommend having this updated map and mitigation site

locations expanded to include more than just NCCP/HCP areas

and instead include all levels of protected lands (federal, state,

regional, and local).

pursue a strategic planning p

resources. The intent is to inc

not just NCCP/HCP areas, bas

stakeholders. Language has b

074‐04 Constance

Spenger

Friends ofCoyote Hills

We hope you utilize the experience and expertise of already‐

established programs in both Orange and San Diego Counties.

The language, as it exists now (“achieved through already‐

established programs”) implies no other transportation agency

in the region can adopt or implement an advanced mitigation

program. We recommend rephrasing this sentence to be more

clear about the eligibility of transportation agencies and utilizing

the experience existing regional programs.

Comment noted. The intent o

build upon already‐establishe

input from stakeholders. Lang

074‐05 Constance

Spenger

Friends ofCoyote Hills

On page 79 of the Draft 2012 RTP/SCS we were encouraged to

see SCAG recognize the benefits of reducing transportation

impacts to sensitive lands and encouraging smart land use

decisions. We believe landscape level advanced mitigation will

become a statewide planning policy. Planning future

transportation projects with a comprehensive mitigation

program ensures our open space infrastructure can continue to

Comment noted. The mitigat

Resources and Open Space in

of habitat linkages, preservat

crossings to minimize the imp

wildlife species and habitat fr
188

ID Name Affiliation Comment Re

function and maintain viable habitats, linkages, and species

populations in perpetuity. Unfortunately, we noticed the lack of

inclusion of wildlife linkages in this section. Orange County’s

transportation measure language included wildlife linkages and

we recommend SCAG include linkages as well.

074‐06 Constance

Spenger

Friends ofCoyote Hills

Renewed Measure M in Orange County incorporated language

that demonstrates a net environmental benefit in conjunction

with a net benefit in the delivery of transportation

improvement projects. Some of the environmental benefits

include: landscape level acquisition, restoration, and

management. Some of the transportation benefits include:

streamlined permitting, involvement of the resource and

permitting agencies, and reduced project delays. We believe

there is an opportunity to incorporate similar “net

environmental benefit/net benefit of transportation projects”

language in the Draft 2012 RTP/SCS. To that end, we

recommend the language from the Orange County

Transportation Authority’s Ordinance #3 Section 2, Item A.5.iii

(page B‐5) as a starting place.

Comment noted. It is SCAG’s 

determine the best conservat

appropriate public input and 

permitting agencies.

074‐07 Constance

Spenger

Friends ofCoyote Hills

We appreciate SCAG’s effort to create a strategic planning

process that would document important conservation lands in

the region. We believe there is an important opportunity with

this concept to also create a Southern California Greenprint. By

completing a Greenprint a comprehensive view of our open

space land attributes would be documented. Such attributes

include: recreation priorities, agricultural lands, scenic values,

historic preservation, and more. A Greenprint would give a

more complete picture of both opportunities and challenges,

while at the same time respecting property rights.

Comment noted. A Greenprin

mitigation program that will b

stakeholders in the future.

075‐01 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

Thank you for the opportunity to comment on the Southern

California Association of Governments (SCAG) 2012 Regional

Transportation Plan (RTP) and Sustainable Community Strategy

(SCS). Friends of Harbors, Beaches, and Parks (FHBP) is based in

Newport Beach and we work to protect the natural lands,

waterways, and beaches of Orange County. Our organization

includes support from more than 80 conservation and

community groups in the regional and thousands of Orange

County residents. FHBP would like to applaud SCAG’s efforts to

include a regional advanced mitigation component in the

RTP/SCS. This letter serves to offer suggestions mainly to

Comment noted.
189

ID Name Affiliation Comment Re

strengthen this component, which closely links with the

sustainability principle listed in the document’s vision

statement. We do, however, offer a few other suggestions as it

relates to other projects we are interested in.

075‐02 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

Active Transportation (p. 21 of the Draft 2012 RTP/SCS) In 2011,

FHBP completed a study documenting the Walk Score for the

city hall of each Orange County city as well as the city‐wide

average. Walk Score measures how easy it is to live a car‐lite

lifestyle—not how pretty the area is for walking. According to its

website, WalkScore.com uses Google maps to compute the

distance between residential addresses and nearby

destinations. The algorithm looks at 13 categories and awards

points for each between 1⁄4 to 1 mile. Amenities within 1⁄4 mile

receive maximum points, while no points are awarded for

amenities further than one mile. The categories include grocery

store, coffee shop, movie theatre, park, bookstore, drug store,

clothing and music store, restaurant, bar, school, library, fitness,

and hardware store.1 See attachment #1 for the results of this

Walk Score study. Recommendation #1 We recommend utilizing

this tool as a measurement of how and where walkable, bikable

communities may be most relevant. This information may serve

SCAG well in determining or prioritizing funding for more active

transportation opportunities. Of course, we understand that

many factors are at play including site development, existing

stable neighborhoods, transit areas and more, but including as a

metric how communities are doing already is helpful

information to have in the overall analysis.

Comment noted. SCAG will co

other metrics in future plann

075‐03 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

Regional HOT Lane Network (p. 58 of the Draft 2012 RTP/SCS)

We disagree that the Toll Road Agencies proposed extension of

the 241 South be included in the Regional HOT Lane Network.

The RTP includes the proposed 16‐mile Foothill‐South Toll Road

extension, which would run through the heart of San Onofre

State Beach Park, a beloved and popular recreation spot in

south Orange County that serves more than 2.4 million visitors

each year. Both the California Coastal Commission and the U.S.

Department of Commerce have rejected the Foothill‐South

project on the basis of its devastating projected impacts on

coastal resources. Recommendation #2 The continued inclusion

of this unbuildable project as a baseline roadway changes the

transportation modeling for southern Orange County

Comment noted. The SR‐241/

committed Transportation Co

RTP/SCS and is programmed 

Improvement Program (FTIP)

Agencies (TCA) as the respect

forward with the first segmen

Oso Parkway to the vicinity o
190

ID Name Affiliation Comment Re

transportation projects. The Foothill‐ South should be

eliminated from the baseline scenario and removed from the

RTP, especially since it is in the unconstrained plan of the

Orange County Transportation Authority’s Long Range

Transportation Plan.

075‐04 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

Conservation Planning Policy (p. 76 of the Draft 2012 RTP/SCS)

While we wholeheartedly support the concept of the

conservation planning policy, which helps demonstrate progress

and safety in SAFETEA‐LU requirements, however we do not

agree large‐scale acquisition and management of critical habitat

be the only type of mitigation opportunity utilized. We note

however, this may simply be a word choice issue. According to

the U.S. Fish and Wildlife Service: “when a species is proposed

for listing as endangered or threatened under the Endangered

Species Act (Act), we must consider whether there are areas of

habitat we believe are essential to the species’ conservation.

Those areas may be proposed for designation as “critical

habitat.”2 Essentially, we firmly believe there are other

important natural lands deserving of conservation/preservation,

but do not or may not contain a “critical habitat” designation (as

defined by the Service). Recommendation #3 With this in mind,

we suggest changing the reference from critical habitat to

important natural lands. This comment also applies to the

Resource Area and Farmland section (pg. 128 of the Draft 2012

RTP/SCS).

Comment noted. The propose

pursue a strategic planning p

resources among a wide varie

include all applicable protecte

clarified.

075‐05 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

Engage in a Strategic Planning Process We would also like to

offer that it may be an important first step to create a regional

Greenprint in addition to a map of regional priority conservation

areas. According to Oregon State University: “A Greenprint is a

non‐regulatory vision to help communities make informed

decisions about land conservation, scenic values, and recreation

priorities. Components include: ∙ A comprehensive overview of

important natural resources, wildlife habitat, historic sites,

scenic values, and potential/existing trail connections in the

region ∙ Maps that highlight the ecological and recreation

priorities of the region, while respecting property rights and

creating awareness around public access ∙ An inclusive vision to

foster discussion of the diverse conservation and recreation

needs of the region.”3 Recommendation #4 We request a

region‐wide Greenprint be conducted to document the natural,

Comment noted. A Greenprin

mitigation program that will b

stakeholders.
191

ID Name Affiliation Comment Re

recreational, agricultural, and other resources in the SCAG

jurisdiction as part of the conservation policy planning.

075‐06 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

Identify Map Priority Conservation Areas and Engage Various

Partners: While we understand the RTP is directly related to

County Transportation Commissions (CTCs) we would

respectfully request that conservation organizations and other

related agencies, conservancies, and joint power authorities,

like the Santa Monica Mountains Conservancy, Mountains

Recreation and Conservation Authority, and the Wildlife

Corridor Conservation Authority, be included in determining

priority conservation areas and plan development. CTCs, with all

due respect, do not tend to focus on conservation of natural

lands. As the Orange County Transportation Authority will

confirm, it relied upon many sources for establishing its priority

conservation areas under the Environmental Mitigation

Program of Renewed Measure M. To that end, FHBP would like

to offer its assistance with Orange County’s potential

conservation lands as we’ve created a county‐wide map, the

Green Vision Map, that documents important conservation

lands and existing privately or publicly protected lands. In

addition, we believe there are similar conservation non‐profit

organizations and entities throughout the SCAG region that

could provide useful, beneficial, and relevant information about

their on‐the‐ground priorities. Recommendation #5 We

recommend that SCAG incorporate public workshops and

outreach to effectively gather information from conservation

organizations and other related agencies on conservation

priorities. This recommendation also applies to the limited

scope of “agencies” in the Resource Areas and Farmlands

section (pg. 128 of the Draft 2012 RTP/SCS).

Comment noted. SCAG will co

conservation organizations. T

only refer to data compilation 

for the RTP/SCS. The propose

a strategic planning process f

resources. The intent is to inc

stakeholders, including the gr

075‐07 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

Locations for Mitigation (pg. 78 of the Draft 2012 RTP/SCS) We

are pleased that SCAG has already inventoried the locations of

the protected and unprotected areas in relationship to wildlife

linkages, linkage designation areas, park, and recreation areas.

We agree the maps should be updated as a function of the post‐

RTP planning efforts but qualify this statement with the caveat

that not all of the protected, or undeveloped unprotected lands,

in Southern California are within a Natural Communities

Conservation Plan (NCCP) or Habitat Conservation Plan (HCP)

area. Recommendation #6 We recommend not only updating

Comment noted. The propose

pursue a strategic planning p

resources. The intent is to inc

not just NCCP/HCP areas, bas

stakeholders. Language has b
192

ID Name Affiliation Comment Re

the maps to include more recent acquisitions in the NCCP/HCP

areas, but also recommend including preserved lands not in the

NCCP/HCP areas. For example, most of Chino Hills State Park is

not included in an NCCP/HCP but this park offers more than

14,100 acres of natural lands to the inventory. To exclude non‐

NCCP/HCP lands would misinform decisions about conservation

priorities and exclude an entire network of preserved lands

outside of, but often times critical to the functioning of, our

entire open space system.

075‐08 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

In addition, the Orange County Transportation Authority has

created a county‐wide NCCP/HCP for its Environmental

Mitigation Program. This new NCCP/HCP is above and beyond

the existing NCCP/HCP areas (Central/Coastal and Southern). By

limiting the view of where mitigation can occur (to only existing

NCCP/HCP areas), SCAG is considerably reducing its potential

mitigation sites especially in light of the broad and expansive

nature of the RTP. Freeways crisscross the entire SCAG region

and have impacts that cannot or may not be able to be

mitigated in an existing NCCP/HCP, nor may SCAG or CTCs be

able to add themselves as a partner this late in the NCCP/HCP

process. Recommendation #7 Instead of dictating the

conservation mechanism or program to be used by the

individual CTCs, we recommend allowing the implementing CTC

determine the best conservation mechanism for its region with

appropriate public input and guidance from the resource and

permitting agencies.

Comment noted. It is SCAG’s 

determine the best conservat

appropriate public input and 

permitting agencies.

075‐09 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

We agree SCAG does not have the authority to purchase or

manage these conservation lands, but disagree that the

conservation areas will be “achieved through already‐

established programs.” This statement limits the opportunities

for conservation to just Orange County as it is the only

transportation agency in the SCAG region to have an advanced

mitigation component. Should you mean you will use already‐

established programs to build upon SCAG’s efforts, we agree

with this approach, but it is not clearly stated and should be

revised. Recommendation #8 We recommend augmenting the

statement to include not only already‐established programs, but

also programs that may be developed in the future or created

within existing transportation measures (where appropriate).

Additionally, it may be a good exercise to understand what

Comment noted. The intent o

build upon already‐establishe

input from stakeholders. Lang
193

ID Name Affiliation Comment Re

modifying existing transportation measures to incorporate a

regional advanced mitigation program would entail.

075‐10 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

Types of Mitigation Activities (pg. 79 of the Draft 2012 RTP/SCS)

By reducing transportation impacts to sensitive lands and

encouraging smart land use decisions SCAG is moving in a

direction that we believe will become the norm and an adopted

policy at the statewide level–planning our transportation

projects with a comprehensive mitigation program that ensures

our open space infrastructure can continue to function and

maintain viable habitats, linkages, and species populations in

perpetuity. Recommendation #9 We did notice the lack of

mention of wildlife linkages in this section and based on our

experiences in Orange County recommend their inclusion.

Wildlife linkages are also an important conservation component

to ensure the health of our open space areas.

Comment noted. The mitigat

Resources and Open Space in

of habitat linkages, preservat

crossings to minimize the imp

wildlife species and habitat fr

075‐11 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

We are pleased to say that the Renewed Measure M Ordinance

defines Programmatic Mitigation as “permanent protection of

areas of high ecological value, and associated restoration,

management and monitoring, to comprehensively compensate

for numerous, smaller impacts associated with individual

transportation projects. Continued function of existing

mitigation features, such as wildlife passages are not

included.”4 In other words, if freeway projects impact existing

wildlife corridors, funding to ensure its continued function may

not come from the programmatic mitigation component. In

addition, the program will establish an “accounting process for

mitigation obligations and credits that will document net

environmental benefit from regional, programmatic mitigation

in exchange for net benefit in the delivery of transportation

improvements through streamlined and timely approvals and

permitting” [emphasis added]. Recommendation #10 We do,

therefore, recommend that maintaining existing and future

wildlife corridors or linkages be included as a type of mitigation

activity and that the advanced mitigation program incorporates

language to ensure a net environmental benefit as there will be

a net benefit in completing the transportation projects.

Recommendation #11 While we recognize there are many

options to how the mitigation program gets developed, we do

recommend that the summary language acknowledges that the

list of types of measures is not exhaustive.

Comment noted. The mitigat

Resources and Open Space in

of habitat linkages, preservat

crossings to minimize the imp

wildlife species and habitat fr

language has been added to d

is not exhaustive.
194

ID Name Affiliation Comment Re

075‐12 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

Farmland and Agricultural Resources We urge you to consider

adding farmland and other agricultural resources to the

conservation policy. In comparing acreages of farmland in the

SCAG region, there was a loss of nearly 64,000 farmland acres

because of its conversion to urban uses between 2002 and

2008. There was also a 47,000 acre decline in prime statewide

important and unique farmlands (as designated by the Farmland

Mapping and Monitoring Program classification system).6

Urban uses generally equate to additional greenhouse gas

emissions due to auto‐centric developments and therefore go

against the mandate of SB 375. We believe existing agricultural

lands play into the larger network of open spaces. Farmlands,

like natural lands, create opportunities for natural recharge of

the groundwater, reduce the effects of urban heat islands, and

provide refuge and foraging areas for wildlife. Of course,

agricultural lands also provide food production (worth $4.6

billion per year in the SCAG region) and jobs (67,000 with an

annual payroll of $800 million), while producing many times less

greenhouse gases than the urban development that has been

supplanting them.

Comment noted. Agricultural 

previously mapped through p

on page 78. Agricultural resou

mitigation for biological resou

programs. It is SCAG’s intent 

appropriate public input and 

permitting agencies.

075‐13 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

General Mapping: It unfortunately seemed to be a trend that

the maps in the RTP/SCS were illegible in both printed and

digital form. It would be helpful to revise the maps contained

within the documents so that the public can accurately read and

understand what the maps are trying to show. We were

particularly interested in the following maps but our comments

are limited due to readability (pixelation) issues: the projected

population growth (Exhibit 4.1), housing growth (Exhibit 4.2),

employment growth (Exhibit 4.3), natural resource areas

(Exhibit 4.6), open space (Exhibit 4.7), and farmland maps

(Exhibit 4.8).

Comment noted. Exhibits ma

paper size, however high reso

request and were provided u

period.

075‐14 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

Forecasted Growth: We applaud your goal of the RTP/SCS to

focus on (among other goals): A land use growth pattern that

accommodates the region’s future employment and housing

needs, and protected sensitive habitat and natural resource

areas. We agree land use, transportation AND habitat

protection can all be achieved through innovative, smart and

new programs like the proposed advanced mitigation policy. We

also appreciate that the land consumption of the greenfield

areas consumes 408 square miles less than the baseline. And

Comment noted.
195

ID Name Affiliation Comment Re

yes, we agree it is more expensive to develop in greenfield areas

because of the lack of infrastructure and services. We are

pleased to see SCAG promoting infill projects and protecting our

remaining greenfields through compact development and

improved land use planning. We believe these concepts are all

moving in the right direction toward achieving our mutual goals

and the goals outlined in the RTP/SCS for mobility, economy,

and sustainability.

075‐15 Melanie

Schlotterbeck

Friends ofHarbors,Beaches, and

Parks

Rapid Fire Model Rapid Fire Model Regional Scenarios Summary

which outlines the results of the impacts of varying land use

patterns, transportation investments, and policy directions on

greenhouse gas emissions, air pollution, water and energy use,

land consumption, and infrastructure cost is an excellent

method to evaluate how decisions will impact the region. We

are pleased to see SCAG utilizing this tool.

Comment noted.

076‐01 Raymond

Dunton

Gateway Cities

Council ofGovernments

We understand that SCAG staff is recommending that the

growth forecast be adopted at the city level rather than at the

county level, which has been the practice in the past. We

request that SCAG continue the past practice of adopting the

growth forecast at the county level to allow for much‐needed

flexibility as local jurisdictions implement their general plans.

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use de

allocation being adopted at th

that the SCS be based on a ju

distribution.

076‐02 Raymond

Dunton

Gateway Cities

Council ofGovernments

The draft Financial Plan includes over $110 billion to come from

new mileage‐based user fees that would be implemented to

replace and augment gasoline taxes. This is the largest single

element of the overall new revenue sources anticipated for the

RTP. We would like additional information on how these fees

might affect lower‐income residents of the SCAG region,

particularly since many such residents are concentrated within

the Gateway Cities. The Financial Plan envisions a future split

among local, state, and federal funding sources that is quite

different from the current split, in which over 70% of all

transportation funding is of local origin. In the future, the Plan

shows 22% from federal and 25% from state, leaving only 53%

from local sources. Can SCAG present a chart or plan showing

how and when this transition would occur between 2012 and

2035? Table 3.4.1 presents Core and Reasonably Available local

sources of revenue and includes development mitigation fees

for Orange and Riverside Counties. Does the revenue estimate

include any assumption of funds from the potential adoption of

Comment noted. The project

based user fee and adjustme

taxes when combined with th

and federal sources generate 

average increase in state and 

sources of five percent annua

continuation of the historical 

with federal requirements, w

to stabilize state and federal t

consistent with recommenda

commissions established by C

addition to efforts underway 

lay‐out an implementation pl

in the Transportation Finance 

implementation plan will be s

disproportionate impacts to u

Appendix provides additional 

revenue sources included in t
196

ID Name Affiliation Comment Re

a development fee in Los Angeles County? assume any revenues associa

fee feasibility study currently 

of a proposed restructuring o

Program.

076‐03 Raymond

Dunton

Gateway Cities

Council ofGovernments

Exhibit 2.1 and Exhibit 4.12 show major highway projects under

the Regional Transportation Plan. Some major Gateway Cities

projects ‐ notably those along I‐5 between I‐605 and the County

line ‐ are not indicated on these exhibits. We understand that

this is because the exhibits show only Plan projects and do not

show projects in the current Federal Transportation

Improvement Program (FTIP). We suggest that the exhibits be

amended to include FTIP projects over a certain cost threshold

so as to show a more complete picture of regional highway

infrastructure investments.

The HOV lane improvements 

County line are included in Ex

mixed‐flow lane improvemen

mixed‐flow lane improvemen

for the Final RTP/SCS docume

076‐04 Raymond

Dunton

Gateway Cities

Council ofGovernments

We understand that discussions are ongoing among SCAG, the

County Transportation Commissions, and the California High

Speed Rail Authority regarding levels of available funding for rail

infrastructure improvements within the SCAG region. We look

forward to further details about the specific investments that

will be made in Southern California's rail infrastructure under

the 2012 RTP, particularly those that affect the Gateway Cities.

Comment noted.

076‐05 Raymond

Dunton

Gateway Cities

Council ofGovernments

Table 2.6 lists several potential routes for Express/HOT Lane

development. Two of these run through the Gateway Cities: I‐

405 from I‐5 to the LA/OC County line; and SR‐91 from I‐110 to

SR‐55. What is the anticipated timeframe or years of

construction and completion for these projects? Will mixed‐flow

lanes be added or removed in order to provide the HOT lanes?

Comment noted. The two Exp

in the comment are assumed 

purposes of the RTP, the Expr

conversion of the existing HO

existing mixed‐flow lanes. Im

Regional Express/HOT lane ne

Express Travel Choices Phase 

076‐06 Raymond

Dunton

Gateway Cities

Council ofGovernments

Exhibit 2.8 displays "rising truck volumes in the SCAG region."

However, the assumptions underlying the data in this exhibit

are not clear, and should be explained in the text. For example,

how do these figures relate to the cargo forecast being

projected by the San Pedro Bay Ports or the figures assumed in

the I‐710 Corridor and 91/605/405 Corridor processes? Are the

figures in the exhibit based on SCAG's revised truck model?

Also, would different truck volumes be found under different

RTP alternatives? To avoid local impacts to member cities, the

Gateway Cities respectfully request that the potential routes for

the East‐West Freight Corridor be limited to freeways only, and

that non‐freeway routes not be further considered. The tables

Comment noted. The “rising t

baseline forecast scenario for 

based on SCAG’s updated He

recent data collected. Furthe

and assumptions has been pr

RTP/SCS as appropriate.
197

ID Name Affiliation Comment Re

relating to the proposed East‐West Freight Corridor present a

confusing picture of the plan for implementing reduced‐

emission vehicles on the corridor. Table 2.8, Benefits of an East‐

West Corridor Strategy, mentions "50% clean truck utilization"

under Environment, but also lists "Zero‐emissions technology"

under Community. Table 2.11, Environmental Benefits, shows

an "East‐West Freight Corridor with 100% Zero‐Emission

Vehicles." It would be helpful to clarify the timeline on which

SCAG anticipates low‐ or zero‐emission trucks would be phased

in specifically on the East‐West Freight Corridor. This

implementation timeline should be the same on the East‐West

Corridor as on the I‐710 Corridor through the Gateway Cities,

and both should employ 100% zero‐emission vehicles.

076‐07 Raymond

Dunton

Gateway Cities

Council ofGovernments

Page 79 of the SCS Background Documentation report states

that "Subregional SCSs submitted by the Gateway Cities Council

of Governments (GCCOG) and the Orange County Council of

Governments (OCCOG) will be respected and integrated into the

alternatives (with possible revisions for Alternative C only)."

Since the PEIR alternatives are designated by number (1, 2, 3)

rather than by letter (A, B, C), please clarify whether this

statement refers to Alternative 3, called the "Envision 2

Alternative" in the PEIR. Also, we would appreciate having

specific information on where, if anywhere, revisions may have

been made to the Gateway Cities' jurisdictional input as

reflected in our subregional SCS.

Comment noted. The subregi

GCCOG and OCCOG are incor

in their entirety, and as such, 

the regional plan for impleme

strategies included in the RTP

apply region‐wide. Land use i

were not changed by SCAG pe

the delegated subregions.

Alternative C examined poten

on maximizing the region’s tr

2012‐2035 RTP/SCS is similar 

Alternative in the PEIR.

077‐01 Recyl

Chapman

Global LandUse andEconomicCouncil

As a body representative of Southern California's broader

business community, the GLUE Council recognizes the crucial

roles that transportation and infrastructure play in maintaining

the region's economy and quality of life. That is why throughout

the RTP/SCS process the GLUE Council has focused on the plan's

ability to deliver economic recovery, job recover, and CEQA

streamlining to the region. The following key policies and

principals are recommended by the GLUE Council for evaluating

the plan as they represent the qualities of a good and sound

RTP/SCS: 1. Provide Positive Economic Impacts ‐ A plan that is

pro economic growth and pro job creation ‐ The RTP/SCS must

undergo a true economic cost/benefit analysis so that economic

impacts are understood and known by SCAG Regional Council

members (and stakeholders) before making a final decision on

the RTP/SCS.

Comment noted. The Econom

Appendix has been updated t

assessment of the benefits an

RTP/SCS.
198

ID Name Affiliation Comment Re

077‐02 Recyl

Chapman

Global LandUse andEconomicCouncil

2. Provides Local Control: Any new transportation revenues on

fees collected must be under the control of the local

transportation agency/authority in order to assure local

accountability. Cities, counties and local transportation agencies

must maintain appropriate control and flexibility in managing

decisions and resources related to land use and transportation.

Comment noted. We agree th

consideration for any new rev

assume nor would it result an

transportation revenues that 

transportation agency/autho

powers to SCAG.

077‐03 Recyl

Chapman

Global LandUse andEconomicCouncil

Assures Revenue Sources are Fair, Understandable and Good for

the Economy ‐ Transportation revenue concepts within the

RTP/SCS must undergo cost/benefit and other appropriate

analysis to assure that they are good for a recovering economy

and future growth. They must also be fair and understandable,

meaning that an appropriate nexus exists between who/what is

being taxed and what is being paid for to assure that new

revenues are drawn fairly and proportionally from those who

benefit from the related transportation infrastructure or

improvement.

Comment noted. The Transpo

additional detail and explanat

included in the RTP. We cons

principles as a foundation for 

revenues that are reasonably 

financial strategies: • Establis

reflects the true cost of trans

protection for transportation 

distribution of costs and bene

programs that include return

maintaining flexibility to rewa

commit substantial local reso

funding with innovative finan

expansion of TIFIA) to attract 

project delivery. • Promote fu

federal commitment to the n

recognizing the pivotal role th

and international trade. The i

return of $2.90 for every doll

077‐04 Recyl

Chapman

Global LandUse andEconomicCouncil

Is Balanced and Accountable: Revenues should be balanced with

performance measures, reforms and guarantees that assure the

RTP is effective, efficient and responsible to the citizens and

taxpayers of Southern California.

Comment noted. The 2012 RT

multi‐modal plan that incorpo

transportation strategies to a

performance.

077‐05 Recyl

Chapman

Global LandUse andEconomicCouncil

Economic Analysis ‐ Throughout the RTP/SCS process, the GLUE

Council has asked for and encouraged SCAG to focus on the

plan's benefits and impacts on the regional economy and job

creation. The GLUE Council has argued that, done right, the

RTP/SCS can be a major catalyst for the region's economic and

jobs recovery. Likewise, if not done right, the RTP/SCS could

delay recovery or possibly even worsen the region's struggling

economy. With this in mind, early on the GLUE Council called

for a complete economic analysis for the RTP/SCS, inclusive of a

true cost benefit analysis.

Comment noted. SCAG engag

economic experts and they h

2012RTP/SCS provides a signi

region’s economy. The Econo

Appendix has been updated 

assessment of the benefits an

Please see the Economic and 

the Final 2012‐2035 RTP/SCS 

077‐06 Recyl Global Land GLUE Council appreciates SCAG's dedicating resources to fully Comment noted.
199

ID Name Affiliation Comment Re

Chapman Use and

EconomicCouncil

articulate the net economic benefits of the 2012‐2035 RTP/SCS

and supports the findings: ‐ Every $1 spent on infrastructure

investments yields a return of $2.90 ‐ The projected cost per

day/per capita is less than $2.00 ‐ The projected benefit per

day/per capita exceeds $5.00 ‐ The plan generates an average of

166,000 jobs per year from construction and maintenance

expenditures ‐ Improved transportation benefits in commuting,

accessibility and congestion relief yeilds 354,000 annual jobs

GLUE Council has reviewed the work of SCAG's economic team

and their analysis of the RTP/SCS and finds that it does show the

plan to be one that "provides positive economic impacts", which

is one of the GLUE Council's key qualities of a good plan.

077‐07 Recyl

Chapman

Global LandUse andEconomicCouncil

Phase II of the Economic Recovery Strategy ‐ As part of the

adoption of the RTP/SCS, the GLUE Council recommends that

the SCAG also adopt Phase II of the Economic Recovery

Strategy. The adoption could happen simultaneously with the

adoption of the RTP/SCS or at the adoption of the RTP/SCS,

SCAG could commit to a subsequent adoption of the Phase II

Strategy (within six months). The Phase II Economic Strategy

would be a way for SCAG to take business community concerns

with the RTP and turn them into a positive partnership. Working

together, SCAG, GLUE and other stakeholders could develop the

Phase II Strategy as a way to focus SCAG and local government

on critically necessary regulatory reforms and strategies for new

out of the box financing, especially in light of the dissolution of

redevelopment agencies. The Phase II Strategy would also give

SCAG and GLUE a vehicle for establishing a true Regional

Economic Plan to go along with SCAG's other regional plans

such as the RTP, the SCS and RHNA. Update adoption of the

RTP/SCS and the Phase II Economy Recovery Strategy, GLUE

Council looks forward to partnering with SCAG on actions to

encourage increased business investment in Southern

California, in order to retain the current business base, to

identify opportunities for expediting project delivery, to reduce

costs and to realize accelerate plan benefits.

Comment noted.

077‐08 Recyl

Chapman

Global LandUse andEconomicCouncil

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

078‐01 Chris Ganson Governor's Performance based planning. We are encouraged by SCAG’s Comment noted.
200

ID Name Affiliation Comment Re

Office ofPlanning and

Research

efforts to develop a plan based on quantitative measures of

projected outcomes, or “performance metrics”. We encourage

SCAG to continue to develop its capacity to employ

sophisticated scenario modeling, and to use that information to

enable even better‐informed decision‐making. Models used in

regional transportation planning are increasingly important in

informing transportation and land use decisions. Transparency

of models is therefore a prerequisite to transparency in the

planning process and decision‐making. We encourage MPOs to

display as much information as possible, including model inputs,

to help members of both lay and technical public understand

and compare model assumptions and results. Similarly, the

model code itself should also be made available to members of

the technical public for analysis. Consistent with the RTP

Guidelines, SCAG has appropriately made its modeling work

available for public review. We appreciate SCAG’s efforts in

providing this information.

078‐02 Chris Ganson Governor's

Office ofPlanning and

Research

Applying performance metrics to inform policy. SCAG’s RTP also

relies on and discusses useful metrics, and provides clear

descriptions of their meaning (example, “reliability” and “lost

productivity”). We suggest that SCAG provide additional context

when using some metrics. For example, death rate listed per

VMT (p. 19, fig 1.2) captures factors such as roadway design, but

masks the safety benefits of reducing VMT. Similarly, metrics of

delay (pp. 164‐165) do not distinguish between long and short

trips. Such metrics can penalize a short commute in traffic as

compared to a long commute on the open highway. Congestion

metrics therefore do not capture the benefits to the

transportation system of land use planning strategies that

shorten trip lengths. While we believe the RTP would benefit

from inclusion of trip length in the metrics used to describe the

functioning of the transportation network, we note that the RTP

captures these by using separate land use metrics. We

encourage SCAG to include another key metric, health benefits

resulting from active transportation, such as walking and

bicycling, in the evaluation.

Comment noted. The perform

2012‐2035 RTP/SCS has been 

participation and input from s

as collaboration with other la

the dialogue and developmen

2012‐2035 RTP/SCS, a Perform

was established in May 2011. 

gathered extensive input from 

provided recommendations t

Technical Advisory Committe

forwarding to the Policy Com

process and deliberations, ov

have been added to the RTP/

categories. Performance mea

based on their intended uses

and the other for on‐going m

staff will continue investigatin

those suggested, as well as m

monitoring for future plan up

078‐03 Chris Ganson Governor's

Office ofPlanning and

Research

A VMT fee: a funding source with potential additional benefits.

We appreciate SCAG’s efforts in modeling and evaluating a VMT

Fee as part of the RTP‐SCS analysis. SCAG’s consideration of

effects of a well‐administered VMT fee, including reducing

Comment noted.
201

ID Name Affiliation Comment Re

congestion, and possible co‐benefits to human health and the

environment (e.g. reducing GHG emissions, improving air

quality, and reducing collisions), is beneficial for decision‐

makers and the public. We appreciate SCAG’s work in this area.

078‐04 Chris Ganson Governor's

Office ofPlanning and

Research

Quantify the benefits of Active Transportation. We note that

the RTP highlights the link between active transportation and

human health (p. 30). We recommend that future planning

efforts quantify health benefits of active transportation, so

those benefits can be more specifically factored into the

transportation planning process. We note that the RTP includes

discussions delineating active mode share and accident/fatality

rate for cyclists and pedestrians, and elsewhere in the

document the expenditure share on active transportation. We

recommend that these factors be considered together with

active mode health benefits for a comprehensive analysis of this

component of transportation

Comment noted.

078‐05 Chris Ganson Governor's

Office ofPlanning and

Research

System preservation. For long‐run fiscal health, it makes sense

to fund full upkeep of existing roadway and highway

infrastructure before building more capacity. In this light, we

appreciate SCAG’s commitment of $217 billion (nearly half of

total expenditures) to system preservation, maintenance, and

operation.

Comment noted.

078‐06 Chris Ganson Governor's

Office ofPlanning and

Research

Protecting the natural environment. The RTP discusses the

direct impact of roadway construction and operation on

sensitive species via road wildlife strikes (p. 78). We note that

the development that will be served by these roads could have

a much greater geographic footprint than the roads themselves.

As a result, the RTP should consider the potential indirect

impact roadway construction can have on land development,

and in turn the impact of development on habitat. We

encourage SCAG’s continued engagement and facilitation in

implementation of regional conservation plans.

Comment noted. The propose

pursue a strategic planning p

resources. Furthermore, the p

and Open Space includes exa

improvement/retention of ha

wildlife corridors and wildlife 

of transportation projects on 

fragmentation.

078‐07 Chris Ganson Governor's

Office ofPlanning and

Research

On page 174, the RTP presents the following definition of

sustainability: “A transportation system is sustainable if it

maintains its overall performance over time with the same costs

for its users.” The RTP should use a broader definition of

sustainability that encompasses the environmental, social and

economic metrics used elsewhere in the plan.

Comment noted. The 2012 RT

were developed with input fr

agencies. As with previous cy

the sustainability measure, an

measures, with the next RTP/

078‐08 Chris Ganson Governor's

Office of

Implementation monitoring tracks results of the planning

process. The RTP anticipates substantial achievement that will

Comment noted. SCAG curren

for monitoring implementatio
202

ID Name Affiliation Comment Re

Planning and

Research

be measured by a number of metrics. In order to determine

whether these anticipated achievements occur, we suggest

SCAG employ an implementation‐monitoring program. Such a

program would assess the extent to which local jurisdictions

within SCAG approve development in accordance with the plan.

It would test the assumptions used in the planning process,

allowing for corrections to the plan so that it can continue to

track a course towards stated targets. Also, it would check the

assumptions made in the planning process, allowing calibration

with empirical results.

periodic reports on State of t

Performance Monitoring and 

household travel survey and 

consider further strengthenin

RTP/SCS in the next RTP/SCS 

078‐09 Chris Ganson Governor's

Office ofPlanning and

Research

SCAG’s RTP appropriately describes several key co‐benefits in

the RTP (pp. 175‐176). Further, the RTP also quantifies and

monetizes those benefits so that they can be considered in cost

benefit analyses. We encourage SCAG to clarify how those co‐

benefits are factored into the decision‐making process, and also

to expand the scope of co‐benefit analyses in its future planning

processes.

Comment noted. Co‐benefits 

presented during all of the 18 

as a basis to seek public input

estimated for each of the alte

its significance, SCAG will con

analysis of co‐benefits for fut

example, investigating the he

transportation.

079‐01 David Alba GRID/ECSTC

Systems

In the span of my experience and research seeking solutions to

great challenges involving goods movement, the first and most

profound discovery emerging obvious and opportune is that

over decades of industrial growth, container logistics is no

longer “port centric”. Rather today, goods movement has

shifted to become “region centric”. That is to say logistics

activity at consolidated warehousing, use of freeway networks

and surface freight rail has exploded to support the volumes (in

millions of containers each year) emanating from the Ports of

Los Angeles and Long Beach. The region now bears the brunt of

goods movement and with this brunt comes negative

environmental impacts. This image on the previous page was

taken from page 3 (exhibit 1) from the SCAG Goods Movement

Supplemental Report illustrating warehousing locations (in blue

dots). We have added the 15 mile radius red rings to illustrate

where the vast majority of local truck deliveries emanate from

the ports. Ideally, if containers could be delivered in a new

method of freight transmission to the center of these areas of

delivery density, the freeway trucking component could be

completely eliminated decongesting freeway traffic measured in

the millions of truck trips and in the hundreds of millions in

truck vehicle miles travelled (VMT). The idea of a 100% freight

Comment noted. Local, regio

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten

resulting from freight movem

efforts have included the con

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing markeissues, operational feasibility, 

stakeholders (such as the San 

among others. SCAG will cont

stakeholders and transportat

potential solutions to regiona
203

ID Name Affiliation Comment Re

dedicated right of way connecting the ports to the Inland

regions is the core motivation of the proposed GRID Freight

Pipeline system and transportation network. Among the 2012‐

2035 Regional Transportation Plan’s (RTP), by far, the most

ambitious proposed projects specific to goods transportation is

the proposed elevated or double decked, East West Freight

Corridor. This project calls for a freeway network dedicated to

truck drayage from the 710fwy connecting to the IH‐15

ultimately linking to areas in the Inland Empire where a high

density of container deliveries to consolidated freight service

(CFS) warehousing and intermodal yards. This image on the

previous page justifies the central argument for the critical need

for a freight dedicated corridor crossing the region through the

areas where the highest frequency of port truck deliveries are

occurring by the thousands every day here and now. Therefore,

this public comment is to agree and concur with SCAG’s

determination that an east west freight corridor is critical to

reduce traffic congestion on surface freeways where our

commuter cars use our freeway network.

079‐02 David Alba GRID/ECSTC

Systems

However, the proposed conventional project solution,

connecting forty miles, estimated to cost $15B, is to build an

entirely new freeway network for the purpose of decongesting

another parallel freeway network. To some elected officials this

project proposal leaves causes for concern. In fact, this

proposed mega‐project has already received pushback from

elected officials whose cities run through these proposed new

freeway routes. To begin, fifteen billion dollars to fund this

single project in an RTP involving literally thousands of projects

represents 10% of the $155B dollars SCAG proposes to raise

revenues in the form of a future gas tax increases at $0.30 per

gallon or impose a vehicle miles travelled (VMT) tax. These gas

tax increases will fill the current gap of budgeting within the

RTP’s total $450B plan. The certainty that passage of a national

gas tax or VMT is imminent as a solution is considered by some

to be somewhat optimistic. The following link referencing these

specific issues is an article from the San Gabriel Valley Tribune.

LINK: http://www.sgvtribune.com/news/ci_19327611 Another

significant issue that rapidly growing concern and in some cases

firm opposition from elected and city staff officials of cities,

especially those positioned within or nearing the route to the

Comment noted.
204

ID Name Affiliation Comment Re

proposed surface solution that describes the proposed design of

the E/W Freight Corridor. The following link describes the

aligning opposition beginning with the cities of Diamond Bar,

Walnut, West Covina, Chino Hills, Montebello, South El Monte,

and Pico Rivera. Article from the Whittier Daily News. LINK:

http://www.whittierdailynews.com/news/ci_19261687 Thecentral motivation of this public comment is to reach out to

SCAG strongly urging staff to take bold forward thinking steps,

shifting its regional plan with focus to gravitate towards

environmentally superior alternatives that actually have

superior efficiency and platforms using 21st Century thinking to

solutions specific to streamlining, even potentially

undergrounding the transmission of millions of containers from

the 5th largest container trade gateway on planet earth

significantly decongesting freeway networks on our urban

surfaces where human multi‐modal transportation is given

precious space.

079‐03 David Alba GRID/ECSTC

Systems

The GRID Project is now participating in its 3rd public comments

on proposed major transportation infrastructure where one

project replaces not one, rather multiple projects. Among the

most appealing facets of GRID is that the project pays for itself

(economically sustainable). The first three projects GRID has

addressed in comment are; 1. Public Comment on the Port of

Long Beach Pier S DEIR/DEIS where the SuperDock makes this

billion dollar project obsolete 2. The BNSF Southern California

International Gateway (SCIG) Project DEIR/DEIS making this

controversial development having significant community and

environmental justice group and NRDC opposition (saving

railroad companies $500M) with a superior operating facility

called GRID SuperDock). 3. The SCAG 2012‐2035 RTP where

GRID proposes a “Freight Pipeline” connecting the ports to

inland areas where containers would emerge from this network

of freight tunnels emerging at the center of where the highest

concentration of containers are delivered. Referencing the

earlier SCAG image on page 1, the pipeline follows a route were

freight warehouse volume density is most concentrated. To

date, the GRID Project has been presented to SCAG senior staff.

Also GRID proposers were recently invited to present at the

Arroyo‐Verdugo SCAG Subregion meeting where the central

agenda involved issues pertaining to the 2012‐2035 RTP. We

Comment noted. Local, regio

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten

resulting from freight movem

efforts have included the con

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing marke

issues, operational feasibility, 

stakeholders (such as the San 

among others. SCAG will cont

stakeholders and transportat

potential solutions to regiona
205

ID Name Affiliation Comment Re

submit for SCAG and committee members consideration a

conclusion from a recent CARB/CEPA sponsored study entitled;

“Development of a California Geospatial Intermodal Freight

Transport Model with Cargo Flow Analysis” Contract no: 07‐314

(PDF available on CARB website). The Conclusion of the report

states the following; “The Case Study provides two primary

insights. First, the Case Study quantifies port‐related intermodal

goods movement through the state of California and beyond.

Second, the idealized use of least‐CO2 routing constraints

illustrates how emissions savings can be achieved through

modal shifts. In terms of savings in emissions, it is estimated

that a total of ~60% reduction in CO2 emissions is achievable by

a modal switch from road to rail. Both of these insights have

relevance for consideration of system‐wide improvements that

may achieve energy savings, CO2 reductions, and associated

benefits for air quality”.

079‐04 David Alba GRID/ECSTC

Systems

We urge committee members to please consider ensuring that

SCAG staff will agree to draft language within the E/W Freight

Corridor section in the 2012‐2035 Regional Transportation Plan

clearly communicate that the East/West Freight Corridor

description within the RTP; 1) Consist of other design

alternatives beyond those of only truck with road and freeway

expanding solutions. 2) Include rail guideway systems

infrastructure to carry freight from the same point to point

destinations that define the East/West Freight Corridor even in

the form of superior environmental alternative. 3) Include rail

guideway systems having an underground component

consisting of tunneling and/or “freight pipeline” networks

included in the RTP language. 4) Include design alternatives that

appear to have superior environmental alternatives to consider

as required by CEQA and NEPA legislation as expressed under

section 101 of the National Environmental Policy Act. In this

most perfect storm of economic, environmental, and political

drive to create new jobs and industries, SCAG can create a

Goods Movement RTP squarely focused on sustainable

alternatives both green and economic. We hope that leaders in

the region will join other leaders in further investigating the

GRID project and grow inspired to its purpose in redefining

transportation, smart urban use and economic benefits to the

region.

Comment noted. Local, regio

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten

resulting from freight movem

efforts have included the con

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing marke

issues, operational feasibility, 

stakeholders (such as the San 

among others. SCAG will cont

stakeholders and transportat

potential solutions to regiona
206

ID Name Affiliation Comment Re

080‐01 Barney

Barnett

HighgroveAreaRedevelopment

It is unfortunate that the Highgrove location continues to be

downplayed for such a long period of time. For over 10 years,

surrounding cities, civic organizations and local residents have

requested a Metrolink station at Highgrove. But city resolutions,

letters, and the public comments made at the RCTC meetings

continue to be ignored. RCTC now owns the property at

Highgrove and according to Ann Mayer, Executive Director of

the RCTC, they bought the 17.22 acres of vacant land to enable

the Perris Valley Line railroad track to connect to the BNSF main

line track. The excess land that RCTC does not need would be an

ideal location for the SCAG RTP for commuters between Sand

Bernardino County and Riverside County. On Jan.18, 2012 I

spoke at the SCAG Regional Transportation Plan meeting in San

Bernardino under public comments and submitted written

documentation that contained 29 items that included a colored

map, city resolutions and letters of support from elected

officials and local residents. Some of these items date back to

2001. This information was given to Justine Block who is SCAG’s

Deputy Legal Council in Los Angeles.

Copies of the above e‐mail have been sent to SCAG, prior to the

Feb. 14, 2012 deadline for public input for their Regional

Transportation Plan. The above list is also being sent to RCTC

and SANBAG representatives.

Please look at the new map and the related information on:

www.highgrovehappenings.net that shows the Highgrove

Metrolink Station north of the proposed curved track. RCTC’s

property at Highgrove should be use for the SCAG Regional

Transportation Plan due to the ideal location, existing

commuter trains, and growth potential due to hundreds of

acres of nearby lots ready for homes. This location is way too

important to continue to be ignored!

Comment noted. Station‐stop 

a local issue, and is the respo

within each county.

080‐02 Barney

Barnett

HighgroveAreaRedevelopment

Points made at SCAG public hearing in San Bernardino on Jan.

18, 2012 by R. A. “Barney” Barnett: 1. Location efficiency: The

Highgrove Metrolink Station will be an ideal and efficient

location for SCAG’s Regional Transportation Plan for commuters

between Riverside and San Bernardino counties and beyond. 2.

Land use: The vacant 17.22 acre property at Highgrove is

already owned by the Riverside County Transportation

Commission. 3. New Station Location: The request for a station

platform has been moved north of the proposed curved track

Comment noted. Station‐stop 

a local issue, and is the respo

within each county. All suppo

commenter have been includ

Consultation Appendix to the 
207

ID Name Affiliation Comment Re

that will connect the Perris Valley Line to the BNSF main line.

This location is still on the same property owned by RCTC and

will not interfere with their plan to run future trains between

Riverside and Perris. 4. Vacant 1,555 acres: Highgrove has 1,555

acres of vacant buildable land for future homes and businesses

including the Spring Mountain Ranch project. 5. $250 Million:

One mile east of the Highgrove Metrolink station location is the

Spring Mountain Ranch housing project where $250 Million

dollars have already been spent on infrastructure for 2,500 new

homes. 6. Existing residents: Even before any new homes are

built in the Spring Mountain Ranch area there are already

30,777 residents within a 2 mile radius of the Highgrove

location that could have been using the existing Metrolink

trains. (Riverside EDA figures) 7. Existing trains: On July 15, 2006

Metrolink trains through Highgrove went from 5 days a week to

7 days a week. Each year 3,224 commuter trains pass through

Highgrove without stopping. All that is needed is to have

parking on RCTC’s property next to these existing trains and a

station platform to buy tickets. The construction of the Colton

Flyover will allow even more future commuter trains through

Highgrove but RCTC has no plan to stop any of the existing or

future trains at Highgrove! 8. Location: The Highgrove location

is 1⁄2 mile from the Center St. exit of the I‐215 freeway and 1⁄4

mile south of the Riverside/San Bernardino county line. 9.

Website: Please look at our website: highgrovehappenings.net

There is a map and 10 years of written support for a Metrolink

Station at Highgrove but this location has been opposed by

RCTC for 10 years.

081‐01 R.A. "Barney"

Barnett

HighgroveAreaRedevelopment

Regarding a commuter rail station in Highgrove: We have an

ideal location. We've got the tracks, we've got the property and

we've got the support.

Comment noted. Commuter 

Valley Metrolink line are dete

Transportation Commission.

082‐01 Claire

Schlotterbeck

Hills ForEveryone

Safety and Security First (pg. 37 of the Draft 2012 RTP/SCS) We

applaud your efforts to ensure Southern California’s residents

are both safe and secure on the region’s transportation system.

We were also pleased to see one of your two main goals for

safety and security is to “prevent, protect, respond to, and

recover from major human‐caused or natural events in order to

minimize the threat and impact to lives, property, the

transportation network and the regional economy” (p. 37). HFE

Comment noted. Local agenc

departments, have the techn

examine causes and appropri

freeways.
208

ID Name Affiliation Comment Re

has just completed a near 100 year analysis of fires in the four‐

county area surrounding Chino Hills State Park. See Attachment

1, which documents the fire frequency of the Chino Hills. What

we’ve found is that proximity of roads to natural lands directly

increases the likelihood for fires to ignite and burn both habitat

and homes. For example, as it relates to the 91 Freeway at the

juncture of Riverside and Orange Counties, we have provided to

you an analysis of the fire perimeters and points of origin for

fires that burned in and near Chino Hills State Park. Along this

freeway alone, there are 48 separate fires that ignited/burned.

From 1914 – 1963 (49 years), 1963 being when the freeway

opened, we have records of six fires. Since 1963 – 2012 (49

years), after the freeway opened, there were nearly seven times

as many fires recorded (41). The average fire size for recorded

fires was 6,263 acres. It is clear to us that the safety and security

of residents along this one transportation corridor are being

significantly impacted because of 91 Freeway, not to mention

disruption of mobility due to road closures because of fires and

evacuations. Recommendation #2 With additional roadway and

other projects planned in and around the Puente‐Chino Hills

Wildlife Corridor on the 57, 91 and 71 Freeways, we ask that

SCAG analyze potential fire prevention measures along

freeways that bisect natural lands. For example, one fire

prevention measure would be the creation of hardscape along

the roadway edges so that dry brush cannot ignite when

transportation‐related fires begin. Reducing the fire frequency

and duration not only protects habitat, but also allows

continued and uninterrupted operation of the major

transportation corridors and, importantly, protects life and

property of local residents.

082‐02 Claire

Schlotterbeck

Hills ForEveryone

Biological Resources and Open Space (pg. 79 of the Draft 2012

RTP/SCS) We reiterate the importance of acknowledging the

impact of wildland fire with a transportation generated point of

origin on our natural lands. Though wildlife fatalities, habitat

fragmentation, and other habitat impacts are important—if the

habitat can no longer regenerate in its natural and native state

due to excessive fire frequency the long term preservation of

the land has been lost. Recommendation #3 As previously

mentioned, we recommend incorporating fire prevention

strategies along natural areas bisected by major transportation

Comment noted. The Program 

includes mitigation measures 

wildland fire. See the Final PE

Responses to Comments on t

39.
209

ID Name Affiliation Comment Re

corridors. For example, the 91, 57, 71 Freeways all bisect

natural lands and not only inhibit natural migration and

movement of large animal species, they become areas prone to

fire ignition and therefore habitat destruction.

082‐03 Claire

Schlotterbeck

Hills ForEveryone

Growth in the SCAG Region (2035) (Exhibits 4.1, 4.2 and 4.3) We

appreciate that SCAG has included a projected population,

employment, and housing growth maps as exhibits, but are

dismayed that the maps are illegible. In order to appropriately

comment on this map it must be readable. From what we can

decipher, the area of the Puente‐Chino Hills Wildlife Corridor,

known as the Missing Middle, is shown as adding 2000 – 3500

people per square mile. This area is designated as a Significant

Ecological Area (SEA) in the Los Angeles County General Plan,

thereby acknowledging its significant natural resource values.

The owner, Aera Energy, has attempted to achieve entitlements

on this property twice without success because of the SEA

designation. Ironically, this particular development proposal’s

population, employment, and housing growth areas contradict

the goals of SB 375 and its requirement for reduced vehicle

miles traveled (VMT) since the location of the development is

no where near transit; does not include a major employment

center but instead focuses on large single family residential

units; encourages dependency on the automobile and will,

when combined, increase VMTs, not reduce them. In addition,

related to Exhibit 4.2, there are no employment centers

approved or proposed on the Aera Energy property in Los

Angeles County. As noted in your Integrated Growth Forecast

(p. 111) the “RTP/SCS depends heavily on accurate and credible

forecast for future growth in population, housing and

employment.” It is therefore misleading to show growth when

residential units are the only documented development feature.

And likewise it is inaccurate to show such a large population

growth in an area protected under the County’s own SEA

program.

Comment noted. The Exhibits 

to fit the paper size, but the h

electronic format is available 

have been developed for the 

growth figures allocated to th

received from projects submi

governmental Review (IGR). S

jurisdictions going forward on 

ensure that the identified Aer

represented.

082‐04 Claire

Schlotterbeck

Hills ForEveryone

Advanced Mitigation Policy While we understand the RTP is

directly related to County Transportation Commissions (CTCs)

we would respectfully request that conservation organizations,

like HFE, and other related agencies, conservancies, and joint

power authority’s (e.g., the Santa Monica Mountains

Conservancy, Mountains Recreation and Conservation

Comment noted. The propose

pursue a strategic planning p

resources among a wide varie

include applicable protected 

based on input from a wide v

has been be clarified.
210

ID Name Affiliation Comment Re

Authority, and the Wildlife Corridor Conservation Authority) be

included in determining priority conservation areas and plan

development. CTCs, with all due respect, do not tend to focus

on nor do they specialize in conservation of natural lands. As

the Orange County Transportation Authority will confirm, it

relied upon many sources for establishing its priority

conservation areas under the Environmental Mitigation

Program of Renewed Measure M. To that end, HFE would like to

offer its assistance with potential conservation areas in the four‐

county region. In addition, we believe there are similar

conservation non‐profit organizations and entities throughout

the SCAG region that could provide useful, beneficial, and

relevant information about their on‐the‐ground priorities.

Recommendation #5 We recommend that SCAG incorporate

public workshops and outreach to effectively gather

information from conservation organizations and other related

agencies on conservation priorities. This recommendation also

applies to the limited scope of “agencies” in the Resource Areas

and Farmlands section (pg. 128 of the Draft 2012 RTP/SCS).

Communities Conservation Plan/Habitat Conservation Plan

(NCCP/HCP) areas to acquire, protect, and preserve land in

perpetuity. Recommendation #6 We recommend that SCAG

expand the possible mitigation sites to include any undeveloped

natural lands in its inventory as this would be a more inclusive

list than just focusing on NCCP/HCP lands, which by their very

nature are limited to particular areas of each county (where

established) and related to specific residential developments,

not transportation projects (the Orange County Transportation

Authority’s NCCP/HCP is the exception).

082‐05 Claire

Schlotterbeck

Hills ForEveryone

Adaptation (pg. 31 of the Draft 2012 RTP/SCS) HFE agrees

Southern California will be faced with extremes in precipitation

and temperature, increased storm frequency, and intensity and

sea‐level rise. However, we feel it is critical to include the

impact of fire, especially as more people and roads come to the

region. Much of California is facing significant and extended fire

seasons, which have tremendous impacts on both the natural

environment and the developments nearby. In essence, we

have planned our entire infrastructure system (e.g., flood plains,

water networks, transportation methods) on the climate being a

certain way and now that climate baseline is changing. Since

Comment noted. The Program 

includes mitigation measures 

fire and sea‐level rise. Chapte

Investments, discusses SCAG'

including how to prevent, pro

major human‐caused or natu

threat and impact to lives, pr

network, and the regional eco
211

ID Name Affiliation Comment Re

1986 the number of major forest fires in California has

quadrupled due to more days with summer‐like and generally

hotter temperatures.1 This increase in fires has numerous

implications, including but not limited to: increased firefighting

costs, increased danger to residents near the wildland urban

interface, and a transition of habitat types to more flammable

vegetation due to increased fire frequency. We recommend

that as a part of the SCS in the Adaptation section of the

document, SCAG provide examples of how it and local

jurisdictions plan to adapt to these new risks, especially in

regard to wildland fires, through better land use choices. For

example as it relates to fires, fire officials, planners, developers,

transportation agencies, and others must shift the focus from

primarily a reactionary fire plan (i.e., fighting fires when they

occur) to a preventative fire plan (e.g., creating buffers between

communities and natural lands). What other steps will SCAG be

taking to adapt to climate change and to ensure public health,

economic livelihoods, the financial sector, the insurance

industry, individual comfort, natural lands and recreation areas

will be protected?

082‐06 Claire

Schlotterbeck

Hills ForEveryone

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

083‐01 Kim Gilhuly Human Impact

Partners

Performance Measure: Asthma incidence and exacerbation: We

were glad to see this included but believe the data point could

be strengthened by using NOx as an exposure measurement to

better tie this outcome to vehicle emissions and monitor over

time. SCAG is currently measuring exposure to NOx and has an

accepted methodology to enable this analysis and

quantification.

Comment noted.

083‐02 Kim Gilhuly Human Impact

Partners

Performance Measure ‐ Analysis of percent of environmental

justice households living within 500 feet from high‐volume

roadways: We request analysis of the percent of environmental

justice households and potential health outcomes within 1,000

feet to better reflect research demonstrating health impacts

within that area, particularly in environmental justice

communities. Protocols for addressing impacts are also needed.

We also would request a measure of how many households are

below market rate (BMR) vs. market rate (MR), as with the

analysis in the EJ appendix.

Comment noted. Data and an

Environmental Justice Appen

improvements in vehicle tech

corridors. These corridors in 

and/or near‐zero emission ve

Environmental Impact Report 

includes mitigation measures 

associated with health risk w

traffic volume roadways to le

included in the Appendix also 

improvements through the im
212

ID Name Affiliation Comment Re

measures. As such, emissions 

this Appendix is abundantly c

worst‐case scenario outcome

improvements had been acco

would show little or no areas 

spots”) associated with the P

available data on emissions a

households and population is 

with emissions and EJ popula

potential impacts. Neverthel

evolving information on healt

project sponsors to be cogniz

project design and delivery. C

identified and to be impleme

PEIR, SCAG will assist in disse

identifying effective strategie

level.Information on emissions imp

highways has been included a

Environmental Justice (EJ) Ap

of regional households, a rela

in the EJ Appendix: household 

Below market households ge

income quintiles. Market rate 

quintile. Above market rate h

highest two income quintiles.

083‐03 Kim Gilhuly Human Impact

Partners

Performance Measure: Premature deaths due to PM 2.5 Thank

you for including this performance measure.

Comment noted.

083‐04 Kim Gilhuly Human Impact

Partners

EJ Performance Measure: Jobs‐housing imbalance SCAG was

responsive to stakeholders in measuring a jobs‐housing

imbalance, but the measurement could be improved by using

methodology that UC‐Davis and the Sacramento Council of

Governments has developed. Theirs is a relatively simple

methodology to do a jobs‐housing fit by creating a 4‐to‐5‐mile

buffer zone around major job centers, and comparing wages

provided by those jobs to cost of housing within the buffer zone

to see if there is a good fit. UC‐Davis is developing this tool to be

able to project the jobs‐housing fit into the future, which would

enable SCAG to show how the Plan will impact this performance

measure.

Comment noted. Please see t

analysis for the inter‐county c

Environmental Justice Appen

the same Longitudinal Emplo

data as SACOG/UC Davis to co

convert LEHD data to SCAG TA

correlation analysis between 

distance/time; (2) define both 

by modes to investigate relat

job pay/worker earning matc

time and mode usage; (3) con

conclusion for inter‐county co
213

ID Name Affiliation Comment Re

The initial result from the item 

above showed that there is n

ratio and commuting distance

the entire analysis by summe

policy implications with acade

parties.

083‐05 Kim Gilhuly Human Impact

Partners

EJ Performance Measure: Gentrification & displacement We

applaud this measure and request ongoing monitoring and

development of mitigation measures. SCAG’s analysis indicates

that with ongoing concentration of new housing in High Quality

Transit Areas (HQTA), gentrification EJ and displacement will

happen. While this can be discerned from the analysis of what

has happened with the indicators historically, they do not

project change with these indicators. It would strengthen this EJ

analysis to see how many market‐rate vs. below‐market rate

units are planned for each TAZ, and the EJ Toolbox could be

strengthened by suggesting displacement mitigation measures.

Comment noted. SCAG has sh

gentrification in the region th

(EJ) Analysis. Trends observed 

2005‐09 American Communit

oriented developments (TOD

continue to monitor the infor

presented in the EJ analysis in 

recovering. Population and ho

for the RHNA planning period 

jurisdiction such that the req

category, and affordability ca

housing element updates ‐ w

the adoption of Final RTP/SCS 

083‐06 Kim Gilhuly Human Impact

Partners

EJ Performance Measure: Access to employment and services

(45‐minute auto access) Kudos for measuring this, but we would

like to see measurements for walking and biking access and

recommend using a 30‐minute walking or biking travel time. An

alternative method would be to map 1⁄2 mile access to

employment and services for walking and cycling. The cut‐off

choice of 45‐ minute auto access time does not show, from a

health lens, how people could be more likely to use active

transport methods to access jobs and services.

Comment noted. The distanc

a 3‐mile and 5‐mile radius for 

population group (see Figures 

Environmental Justice Appen

destinations that can be reac

under different travel times. W

provide the imputed travel tim

reach any destination within 

minutes by walking, 8‐12 min

under 5 minutes by auto.

083‐07 Kim Gilhuly Human Impact

Partners

EJ Performance Measure: Access to parks ‐ Similar comments to

access to employment and services, above [comment 6]. It is

not clear for either measure what “average” access is.

Comment noted. Average acc

and parks represents the perc

opportunities measured by jo

measured areas) that can be 

transportation modes and wi

example, in Figure 21 on Page 

Draft Environmental Justice A

job accessibility by auto for 4

job opportunities, while by bu

opportunities.

083‐08 Kim Gilhuly Human Impact EJ Performance Measure: RTP project investment share This Comment noted. Please refer 
214

ID Name Affiliation Comment Re

Partners analysis does not detail what kinds of investments are targeted

for each quintile, i.e., will there be more rail investment in

higher or lower income quintiles, for example. This analysis was

a step in the right direction but more detail would help

determine if the type of investment is targeted for the mode

usage of each income level and/or ability/disability.

the Draft Environmental Justi

transportation investments b

transportation investments b

not broken down further by i

page 48 in the Draft Environm

information on overall transp

and by income and Figure 10 

mode and by ethnicity.

083‐09 Kim Gilhuly Human Impact

Partners

EJ Performance Measure: Air pollution and noise exposure The

analysis showed clearly that risks are higher for EJ populations,

and that more current and future housing near freeways and

busy roadways is targeted for lower‐income residents and

minorities. We were pleased to see that a mitigation measure in

SCAG’s toolbox is to do a corridor‐level analysis for proposed

projects in areas where roadway air quality impacts are

concentrated among EJ communities. We request more

indicators that measure actual health outcomes. Respiratory

risk was not well‐defined. Also, mapping in smaller geographies

would be useful as the maps were unable to show much at the

regional level. With regard to noise, we see that highway noise

reductions will not benefit EJ communities as much as non‐EJ

communities. We appreciate the noise mitigations suggested in

the Toolbox.

Comment noted. The RTP/SC

various demographic groups. 

Justice analysis for the 2012 R

exposure to ozone, concentra

emissions, cancer risks, respir

addition, the Program Enviro

RTP/SCS included a Health Ris

Please note that the Environm

revised to include health imp

below, as further recognition 

issue. Further, staff will clarify 

contained within the Environ

of our future efforts to addre

planning, SCAG is currently w

Sustainability Tool (ST) by dev

based land use and built envi

confidential health survey inf

Angeles County, Department 

health impacts data into this 

simulation tool, users can ass

associated with changes in th

anticipates completing this w

the next round of Regional Tr

Sustainable Communities Stra

083‐10 Kim Gilhuly Human Impact

Partners

EJ Performance Measure: Share of household and employment

growth in High Quality Transit Areas (HQTA) Would like to see

household growth, job growth, and population growth. Would

also like to see how many large (3‐4 bdr) units, how much senior

housing, and below market rate (BMR) units projected for

HQTA.

Comment noted. For househo

Quality Transit Areas (HQTA), 

in the Draft Environmental Ju

and households by income gr

are provided to each local jur

housing by type, income cate

addressed through housing e

jurisdictions. This piece of the 
215

ID Name Affiliation Comment Re

months after the adoption of 

2013).

083‐11 Kim Gilhuly Human Impact

Partners

SCAG stated that the following recommended metrics would be

targeted for a future RTP/SCS if data became available. We

would encourage SCAG to continue researching ways to

measure and report out these indicators earlier than in the next

RTP/SCS.

Comment noted. We look for

Impact Partners on future eff

performance.

083‐12 Kim Gilhuly Human Impact

Partners

RTP/SCS Performance Measure: Percent of households with

walk access to neighborhood services SCAG states further

research is needed. SANDAG has pioneered mapping strategies

for this, and SCAG has laid the groundwork for this analysis in

the Environmental Justice appendix.

Comment noted. SCAG is con

data and technical approache

patterns of the region’s 18 m

measure, further research is 

residential location and nearb

population groups, in particu

who identify as some other ra

083‐13 Kim Gilhuly Human Impact

Partners

RTP/SCS Performance Measure: Percent of existing and new

BMR rental housing units in TOD areas. SCAG states further

research needed, yet has measured a similar indicator above as

“Share of growth in High Quality Transit Areas”.

Comment noted. After Plan a

to identify appropriate metric

assumptions and outcomes.

083‐14 Kim Gilhuly Human Impact

Partners

RTP/SCS Performance Measure: Percent of Jobs within 15

minutes walk of transit ‐ SCAG states that this is pending

available data, but it is unclear why this is not included since

they are measuring growth of jobs and households in high

quality transit areas. Also we are interested in proportion of

jobs and households within 1⁄4 mile of local public transit (bus

and rail) and within 1⁄2 mile of regional public transit.

Comment noted. The Final RT

appendices) will include this m

proxy.

083‐15 Kim Gilhuly Human Impact

Partners

RTP/SCS Performance Measure: Percent of population within 1⁄2

mile of high frequency transit stop ‐ SCAG states that this is

pending available data, but we note that SCAG has assigned this

task to their GIS team, which is a great sign. It is unclear what

data is needed beyond what SCAG has access to since they have

measured the share of household and employment growth in

high quality transit areas.

Comment noted. The Final RT

appendices) will include this m

proxy.

083‐16 Kim Gilhuly Human Impact

Partners

RTP/SCS Performance Measure: Percent of residents within 1⁄2

mile walk to parks and open space (pending available data)

(new research measure) ‐ SCAG states this is pending available

data but did perform a distance to parks analysis in the EJ

appendix, so it appears this data is available.

Comment noted. The results 

indicate very limited accessib

time. Within a 1/2 mile radius

space is likely expected to be 

However, in the future SCAG 

information on the percent o

mile of parks or open space.
216

ID Name Affiliation Comment Re

083‐17 Kim Gilhuly Human Impact

Partners

RTP/SCS Performance Measure: Percent of households living

with >65 decibels of noise ‐ SCAG states that further research is

needed, but this data is collected for the EJ appendix and

appears to be available.

Comment noted. The roadwa

Environmental Justice Appen

from the Federal Highway Ad

advises that noise impacts oc

dB along roadways where no

be in the future, above 66 dB

using this definition, staff me

impacts of noise in surroundi

selected roadways. In order t

noise levels in excess of 65 de

however, detailed noise cont

geographic extent of noise im

information was not available 

083‐18 Kim Gilhuly Human Impact

Partners

We encourage SCAG to incorporate these additional

performance measures, which were not included.

Comment noted. See respons

083‐19 Kim Gilhuly Human Impact

Partners

RTP/SCS Performance Measure: Daily amount (in minutes) of

work and non‐work trip related physical activity ‐ Methodology

exists to predict this as the MTC has done.

Comment noted.

083‐20 Kim Gilhuly Human Impact

Partners

RTP/SCS Performance Measure: Chronic disease resulting from

changes in physical activity due to transportation project

expenditures ‐ Methodology exists to predict this via the

California Department of Public Health.

Comment noted. To address 

and stakeholder requests, SC

based metrics not previously 

explore further improving the 

active transportation and oth

RTP/SCS updates.

083‐21 Kim Gilhuly Human Impact

Partners

RTP/SCS Environmental Justice Performance Measure: Injuries

and fatalities from motor vehicle collisions, including from

trucks, for pedestrians, bicyclists, as well as motor vehicle

operators ‐ While this is measured for performance measures,

there is no EJ analysis.

Comment noted. The key to c

justice (EJ) analysis for region

investments is the availability 

analysis for accidents and inju

transportation modes, SCAG 

items from the California Hig

accident data by location, (2) 

modes by location and their a

income, and (3) correlations o

with built environment and tr

investment by location. SCAG 

funding and resources to this 

building the staff, data/tools, 

to conduct this analysis in pre

Transportation Plan (RTP) / S

(SCS).
217

ID Name Affiliation Comment Re

083‐22 Kim Gilhuly Human Impact

Partners

RTP/SCS Environmental Justice Performance Measure: SCAG

looks at air quality and some EJ respiratory health issues, but

the health effects of changes in air quality due to transportation

expenditures would be clearer if premature mortality were

measured and reported specifically in environmental justice

communities. SCAG measures particulate matter, and so could

do the calculation to attribute premature mortality to mobile

sources of PM2.5.

Comment noted. Quantificati

premature mortality) that res

requires the establishment of 

functions. PM emissions wou

quality concentrations in term

that the associated health eff

consultation with the South C

District (SCAQMD), SCAG can

this time that are solely attrib

will continue to collaborate w

Resources Board (ARB), and t

Agency (EPA) to develop tool

assessments of PM concentra

next round of the RTP, due in 

083‐23 Kim Gilhuly Human Impact

Partners

RTP/SCS Environmental Justice Performance Measure: Physical

activity gained from active transport for EJ communities. SCAG

considers accessibility to parks, employment and services,

which all tie into why someone would walk/bike/take public

transit to get to these services. We request that the health

benefits from transportation decisions be made explicit by

measuring them.

Comment noted. SCAG is curr

our Sustainability Tool (ST) by 

tract based land use and built 

to confidential health survey 

Angeles County, Department 

health impacts data into this 

simulation tool, users can ass

associated with changes in th

anticipates completing this w

the next round of Regional Tr

Sustainable Communities Stra

084‐01 Emmanuel

Sanchez

ImperialCounty Air

PollutionControlDistrict

The list of transportation investment projects found in page 5

and 6, calls for many beneficial projects within the SCAG region

which would ultimately reduce VMT, traffic congestion and

vehicle emissions. On top of the priority list and one of the most

expensive projects is the passenger high speed rail system

which is schedule to provide services to most of the SCAG

region with the exception of Imperial County. As indicated in

Table 1.7 found on page 28 of the RTP, the Imperial County is

currently classified as non‐attainment for 2008 8‐hour Ozone

standard, as well as non‐attainment for the PM10 and PM2.5

standards which is why it is very important and crucial that

projects such as the high speed rail system are built and tied

into the Imperial County to alleviate the same issues other SCAG

regions are having and expected to have in future years. As it

stands, the Air District will not benefit from the emission

Comment noted. The commu

and intercity passenger rail p

2012 RTP/SCS were selected 

Subcommittee of the Transpo

forwarded to the Transportat

Council for inclusion as fiscall

2012 RTP/SCS. The selected p

Policy Committees and Regio

productivity assumptions esti

Rail Authority's Draft 2012 Bu

the 2012 RTP/SCS. To the ext

resource for the 2012 RTP /SC

project delivery strategies in 

"blended approach." Staff wi

to find solutions for meeting 
218

ID Name Affiliation Comment Re

reductions a high speed rail system can provide. For this reason,

the Air District would like to request a cost‐feasibility analysis

and/or a detailed explanation which demonstrates why tying a

high speed rail system to the Imperial County is not beneficial.

084‐02 Emmanuel

Sanchez

ImperialCounty Air

PollutionControlDistrict

The current financial plan found on page 7 calls for an estimated

$110.3 billion revenue source from a proposed mileage‐based

user fee beginning in 2025. If this revenue source is ultimately

approved and implemented, Imperial County residents will be at

an enormous disadvantage and end up paying more into this

funding source due to the county's geographical location and

lack of transportation resources available in the area (currently

high‐speed rail not proposed). Even though the Imperial

County's population has continued to grow at a fast rate during

the last couple of years (page 17), it still continues to heavily

rely on goods and services that are mainly provided in

metropolitan areas such as San Diego, Riverside and L.A.

Counties. As mentioned in the first comment, the Air District is

in desperate need of transportation improvements that will not

only allow easier, faster and safer services to other SCAG

regions but that it will also reduce air emissions in the Imperial

County region.

Comment noted. The propose

existing state and federal gas 

the amount of transportation 

based user fee would charge 

existing gas excise taxes charg

consumed. The amount of ga

product of the total number o

implementation of the mileag

any drivers to increase the nu

provide additional revenue to 

improvements that would all

travel options in Imperial Cou

region. In addition to efforts 

we will lay‐out an implement

user fee in the Transportation 

implementation plan will be s

disproportionate impacts to u

084‐03 Emmanuel

Sanchez

ImperialCounty Air

PollutionControlDistrict

The Air Quality section on page 79 provides several measures

that are necessary to address air emission necessary to achieve

RTP goals. One of the measures is to have "ARB measures set

new on‐road and off‐road engine standards and accelerate

turnover of higher emitting engines from the in‐use fleet"

among others. It is important for SCAG to continue working with

the California Air Resource Board and to discuss these types of

measures in a consistent basis to ensure new engine standards

and the turnover of higher emitting engines will be feasible for

both the private and public sector in upcomming years. In 2008,

CARB adopted the Truck and Bus regulation which requires

diesel trucks and buses that operate in California to be

upgraded to reduce emissions. Heavier trucks must be

retrofitted with PM filters beginning January 1, 2012, and older

trucks must be replaced starting January 1, 2015. By January 1,

2023, nearly all trucks and buses will need to have 2010 model

year engines or equivalent. Ultimately, the Air District would

like to know if the emission reductions found on Table 3.2:

Criteria Pollutant Emission by County ‐‐ Existing Conditions

Comment noted. The criteria 

Table 3.2 are based on the RT

2012 and 2035 Plan) that are 

emission inventory.

See the Final PEIR Addendum 

Comments on the Draft RTP P
219

ID Name Affiliation Comment Re

(2012) vs Plan (2035) have been approved by CARB and will be

included in their emissions inventory.

084‐04 Emmanuel

Sanchez

ImperialCounty Air

PollutionControlDistrict

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

085‐01 Stephanie

Cohen

Kohl RanchCompany LLC

As explained below, we are concerned that the draft RTP/SCS as

proposed would result in an an inappropriate use of the

regional growth forecast planning effort to encroach on local

land use authority and jurisdiction.

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as

trends occurring in many tran

agencies, including local juris

discretion in how to determin

with the SCS. While the SCS is 

policy foundation that local g

so choose, and generally inclu

projections from each city an

jurisdictions maintain local la

085‐02 Stephanie

Cohen

Kohl RanchCompany LLC

We therefore request that SCAG (1) extend the comment period

and make TAZ data available for public review and comment;

Comment noted. The TAZ‐lev

request during the comment 

085‐03 Stephanie

Cohen

Kohl RanchCompany LLC

(2) correct the TAZ data and maps to accurately reflect current

local planing decisions including entitled projects; and

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as

trends occurring in many tran

TAZ level maps have been de

modeling performance. Lead 

jurisdictions, maintain their o

consistency of any future pro

085‐04 Stephanie

Cohen

Kohl RanchCompany LLC

(3) revise the SCS so that consistency determinations are not

made at the small‐scale level of a TAZ but at the jurisdictional

level to allow reasonable flexibility and appropriate land use

decision making authority at the local level.

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

085‐05 Stephanie

Cohen

Kohl RanchCompany LLC

1. The SCS does not appear to account for projects already in

process. Kohl Ranch owns over 2200 acres of land in Southern

California. However, we are concerned that the SCS process has

Comment noted. SCAG’s grow

are primarily based on the bo

However, SCAG also reviews 
220

ID Name Affiliation Comment Re

not full accounted for projects are are already in process.Regent

has severl projects i nthe area that are fully entitled and

approved for build‐out, as well as proposed projects with

pending applications that represent a substantial investment of

resources to design, plan and communicate with the community

and responsible agencies.

through the Intergovernment

information received from th

incorporates the growth from 

their impacts on the regional 

add to the 2012 RTP/SCS Gro

description of how to evaluat

IGR projects into small area s

2008 RTP growth forecast rep

085‐06 Stephanie

Cohen

Kohl RanchCompany LLC

While the SCS itslef states that it was created with input from

local jurisdictions (see Draft RTP/SCS p. 111), we are concerned

that the growth projections contained in the SCS and land use

pattern maps do not in fact reflect the land use decisions that

have been made by local jurisdictions.

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as

trends occurring in many tran

085‐07 Stephanie

Cohen

Kohl RanchCompany LLC

More specifically, while the Draft RTP/SCS indicates that it has

shifted projected densities from less developed areas to the

urbanized core, nowhere does the SCS clearly state that those

shifts in density take into account development projects that

are already approve or that are reasonably foreseeable projects

which local jurisdictions have already spent considerable

resources processing.

Comment noted. SCAG identi

plans, projects, and programs 

Review (IGR). SCAG typically a

project areas to assess their i

transportation system. In cas

the IGR data, the local jurisdic

085‐08 Stephanie

Cohen

Kohl RanchCompany LLC

2. Underlying TAZ data must be released to allow meaningful

public comment. Moreover, the SCS's treatment of approved

projects is impossible to determine from the information that

SCAG has made available to the public. The 2035 Land Use

Pattern Maps, which are intended to depict projected density

and land use, are at such a large scale, with such slight color

gradations, that they cannot be interpreted in any meaningful

way.

Comment noted. The TAZ‐lev

the purpose of modeling perf

local jurisdictions, maintain th

determine consistency of any 

TAZ‐level dataset was provide

comment period.

085‐09 Stephanie

Cohen

Kohl RanchCompany LLC

The SCS itself does not seem to contemplate that these maps

will be important to future transportation and land use

decisions. Instead, the SCS focuses on the projected density

contained in the data that underlies the maps‐‐data that SCAG

has not released to the public.

Comment noted. The TAZ‐lev

the purpose of modeling perf

local jurisdictions, maintain th

determine consistency of any 

TAZ‐level dataset was provide

comment period.

085‐10 Stephanie

Cohen

Kohl RanchCompany LLC

The SCS states that the land use projections contained in the

SCS are based on the distribution of growth forecast data to

TAZs (RTP/SCS, p 122). According to the SCS, the TAZ data

contains forecasted housing, population and employment data,

which the SCS used to create "Community Types" and more

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as
221

ID Name Affiliation Comment Re

refined "development types" that contain average use

designations, densities and building intensities. The SCS states

that a development type, including an average residential

density, has been assigned to each TAZ for purposes of creating

the SCS (Draft RTP/SCS p 123). However, it cannot be

determined whether this assignment was made in a manner

that takes existing conditions (including approved and

reasonably foreseeable projects) as a baseline for these

projections, nor can it be determined how the forecasting was

done or how it was distributed across the TAZ.

trends occurring in many tran

TAZ‐level maps have been de

modeling performance. Lead 

jurisdictions, maintain their o

consistency of any future pro

085‐11 Stephanie

Cohen

Kohl RanchCompany LLC

Despite the critical role of the TAZ data in developing the SCS,

we are not aware that SCAG has made this data available for

public review and comment in any meaningful way.

Comment noted. The TAZ lev

request during the comment 

085‐12 Stephanie

Cohen

Kohl RanchCompany LLC

We were able to obtain partial [TAZ] data showing housing

densities only, from other agencies involved in the SCS process.

These data do not contain employment or population forecasts,

and do not contain any community type or development type

designations which, according to the SCS, have been assigned to

each TAZ.

Comment noted. The TAZ‐lev

request during the comment 

085‐13 Stephanie

Cohen

Kohl RanchCompany LLC

It is not possible for the public to provide meaningful comment

on the SCS without access to the underlying data on which

density and land use projections are based.

Comment noted. The TAZ‐lev

request during the comment 

085‐14 Stephanie

Cohen

Kohl RanchCompany LLC

In the absence of the underlying data and modeling supporting

the proposed plan, we are substantially impaired in our ability

to provide meaningful public comment on the technical and

legal adequacy of the plan.

Comment noted. Modeling an

upon request.

085‐15 Stephanie

Cohen

Kohl RanchCompany LLC

In particular, we cannot assess whether the underlying data

adequately reflects all developments as approved. Under the

federal (5 U.S.C. S500 et. seq) and California Administrative

procedures Acts (Gov. Code SS11340 et. seq., including S

11346.2(b)(6)), the opportunity for public comment must

include disclosure of the data and technical studies in time to

provide meaningful public comment. See e.g. Solite Corp v. EPA

952 F.2d 473, 484 (D.C. Cir. 1991( (per Curiam).

Comment noted. The TAZ‐lev

request during the comment 

085‐16 Stephanie

Cohen

Kohl RanchCompany LLC

While we are not confident that the data is either accurate or

complete, we have reviewed what data we were able to obtain.

Based on our review, we conclude that the forecasted housing

densities do need to be corrected, as the numbers clearly do

not reflect either existing entitlements or pending, reasonably

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as
222

ID Name Affiliation Comment Re

foreseeable projects. trends occurring in many tran

085‐17 Stephanie

Cohen

Kohl RanchCompany LLC

3. Implications of consistency with underlying TAZ data. The

importance of the TAZ data is not limited to understanding how

the SCS was created. In addition to being the basis for creation

of the SCS land use projections, according to the SCS, the TAZ

data is to be relied on in future determinations as to whether a

project is consistent with the SCS. The SCS states: "SCAG

suggests that utlizing community types at the TAZ level of

geography (which an average size of 160 square acres) offers

local jurisdictions adequate information and flexibility to make

appropriate consistency findings for projects to be eligible to

recei CEQA streamlining benefits (Draft RTP/SCS P. 122.) "One

way of determining consistency [with the SCS] is if a proposed

residential/mixed use of TPP [transit priority project] conforms

with the development type designated for a TAZ." (Draft

RTP/SCS, p. 148.)

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

085‐18 Stephanie

Cohen

Kohl RanchCompany LLC

Despite these explicit statements that the existing TAZ data will

be critically improtant to future dcisions affecting projects,

SCAG has not provided the public the opportunity to review and

comment on the TAZ data in any meaningful way.

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level. The TAZ‐le

request during the comment 

085‐19 Stephanie

Cohen

Kohl RanchCompany LLC

Significantly, a project's consistency with the SCS‐‐which is to be

determined at the TAZ level according to the SCS‐‐affects not

only the availability of CEQA streamlining incentives, but can

have adverse consequences for the availability of federal funds

for transit improvements that would serve the project. Transit

improvement projects relying on federal funding must be

consistent with an approved RTP, and with the adoption of

SB375 that includes consistency with the Sustainable

Communities Strategy portion of the RTP as well (40CFR93.102;

42USC7506). Thus, if the Draft RTP/SCS has shifted density away

from approved or pending projects, those projects stand to lose

critical transit improvements. The loss of transit improvements

could impair project feasibility, or create new unmitigated

impacts if traffic mitigations become unfunded, which could

result in an unlawful taking of private vested property rights for

those projects that have already been approved by local

jurisdictions.

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level. Transit pr

state or federal sources will n

as a result of any adopted SCS

085‐20 Stephanie

Cohen

Kohl RanchCompany LLC

We are concerned that a project's inconsistency wit hthe

growth projections contained in the SCS may have broader

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 
223

ID Name Affiliation Comment Re

implications as well. Local jurisdictions will be under

considerable pressure to conform their general plans to the

density, intensity and land uses contained in the SCS, or risk

losing transportation funding throughout their jurisdictions.

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as

trends occurring in many tran

the SCS is intended to provide 

governments may consider if 

includes the quantitative grow

county in the region going for

local land use authority.

085‐21 Stephanie

Cohen

Kohl RanchCompany LLC

While all the implications of a project's inconsistency with the

SCS have yet to be determined, we are concerned that by

shifting density away from locally approved and pending

projects, the SCS is creating land use policy in violation of

SB375's mandate that the SCS must not supersede the land use

authority of cities and counties. (Gov Code 65080(b)(2)(J).

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as

trends occurring in many tran

TAZ‐level maps have been de

modeling performance. Lead 

jurisdictions, maintain their o

consistency of any future pro

land use assumptions for the 

adopted at the jurisdictional s

085‐22 Stephanie

Cohen

Kohl RanchCompany LLC

4. RTP/SCS consistency should be determined at the

jurisdictional level. The TAZ maps are a modeling tool for

engaging in a regional planning and evaluation process. The

feasibility of achieving the precise results in any particular TAZ

area has not been evaluated or confirmed by any city council or

board of supervisors, and as explained above, it appears that

the TAZ data and maps for 2035 do deviate from general plans

and vested entitlements that have not been approved by these

elected officials.

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

085‐23 Stephanie

Cohen

Kohl RanchCompany LLC

While we understand elected bodies or senior administrative

staffs of local jurisdictions may have approved local input for

the overall population and household numbers within their

respective jurisdictions, we believe they have not approved the

TAZ data or maps.

Comment noted.

085‐24 Stephanie

Cohen

Kohl RanchCompany LLC

Accordingly, requiring consistency determinations concerning

use designations, density and building intensity at the small

scale of each TAZ would be inappropriate and overly‐

prescriptive.

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

085‐25 Stephanie Kohl Ranch Again, SB375 specifically precludes SCAG from interfering with Comment noted. The TAZ‐lev
224

ID Name Affiliation Comment Re

Cohen Company LLC local land use decisions. SB375 requires that an SCS "identify

the general location of uses, residential densities within the

region..." California Gov Code S65080(b)(2)(B)(i). Thus there is

no legislative mandate that SCAG identify the location of land

uses, densities and building intensities within the region more

precisely down to a TAZ level.

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

085‐26 Stephanie

Cohen

Kohl RanchCompany LLC

Instead SCAG should appropriately identify these characteristics

at a level consistent with the need for reasonable flexibility and

local control. At the lowest, the level of comparison should be

at a jurisdictional level‐particularly given that there are nearly

200 jurisdictions within the SCAG region. Accordingly we urge

SCAG to identify such characteristics at no finer a scale than at

the lesser of (i) the jurisdiction, and (ii) the sub‐region (i.e.

where unincorporated county land is divided into sub‐regions).

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.

085‐27 Stephanie

Cohen

Kohl RanchCompany LLC

Despite SB375's mandate that the SCS not regulate land use, the

draft RTP/SCS "shifts" households "from the periphery into the

urbanized core" stating that much of this shift "will occur

naturally in the marketplace," and that this "shift" was done

"per consultation with the local jurisdictions." (Draft RTP/SCS P

128) However, this shift does not "occur naturally" nor through

a "consultation" process between agency staff that excludes the

public.

Comment noted. SB375 does 

land use policies and regulati

Regional Transportation Plan 

Strategy. In some cases, SCAG 

assumptions to better relfect 

transit‐rich areas of the regio

series of planning sessions wi

relevant land use and transpo

required to formulate the SCS

on‐one discussions and Geog

software, the local governme

information including growth 

and measures, transportation 

measures, transportation sys

measures and other local tran

085‐28 Stephanie

Cohen

Kohl RanchCompany LLC

Instead, such a shift can only occur, if at all, as part of a separate

and lengthy discretionary development application process

involving requests to local land use jurisdictions to amend their

general plans, specific plans, area plans and zoning. In short,

there is no "shift" to high‐density housing in some local

jurisdictions and away from housing density already approved

by other jurisdictions, unless and until the local land use

jurisdictions adopt the requested discretionary approvals.

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as

trends occurring in many tran

the SCS is intended to provide 

governments may consider if 

includes the quantitative grow

county in the region, local jur

authority.
225

ID Name Affiliation Comment Re

085‐29 Stephanie

Cohen

Kohl RanchCompany LLC

4. Conclusion The draft RTP/SCS represents a substantial and

important regional planning effort. We believe the current draft

needs to be corrected to reflect current local land use planning

decisions and to ensure that the regional growth projection

process is not implemented in a manner that infringes on either

vested property rights or the land use authority of local

jurisdictions.

Comment noted. SCAG based 

assumptions in the RTP/SCS o

197 local jurisdictions. In som

land use assumptions (within 

better reflect recent trends o

of the region. While the SCS i

strategy that local governmen

and generally includes the qu

each city and county in the re

local land use authority.

086‐01 Tom Williams LA 32

NeighborhoodCouncil

High Desert Corridor – If you look at the population,

employment, and land use plans there are no plans for the High

Desert Corridor. Will the High Desert Corridor influence the

population and especially the employment along a 56 mile area

because it is not reflected in the population growth, nor in the

employment, which is 2035. You have the Corridor going

through a lot of agricultural land however. it does not indicate

that the Corridor is going to do anything to that farmland. One

of the reasons I am interested in that is, freight. You sometimes

call it goods, cargo, or freight but most common is freight

containers. Those come from the ports including Hueneme

however, let’s look at Port of LA and Long Beach. They project

44 million TEU’s. A lot of people do not know what a TEU is

because things have changed but your projects do not reflect

that sort of change that is already going on in the maritime

industry. That is, there are container ships, right now, that can

take a 53’ container and they are increasing. This is important

because right now the predominant trade in trucks is to take a

40’ container and break it into one 53’ container by rearranging

it. Then you have to stack to empty 40’s someplace. Because of

this there is a complex maritime freight going on. The Draft RTP

does not reflect this because in the South Bay area, Gateway

Cities, there may be fewer trucks based on the fact that they

can load a 53’ container on to either rail or onto trucks. If you

look at the Port of LA and Long Beach combined they will

produce about 45‐50 thousand trucks a day but SCAG has

trucking on the east west Corridors of 210, 10, 60 and others, of

over a 100 thousand trucks. Where do they all come from?

Based upon the available information in both the primary and

the appendices of the RTP, we do not know. This is a major flaw,

Comment noted. The High De

2.2 and Exhibit 2.1 of the RTP
226

ID Name Affiliation Comment Re

it is an incomplete and inadequate description of the freight

movements from the urban areas into the High Desert Corridor.

The Corridor is a basic Measure R, fully funded, probably the

most profitable of any of the Measure R public/private

partnerships. It is all toll system but it is not depicted in your

RTP.

086‐02 Tom Williams LA 32

NeighborhoodCouncil

One of the reasons I am interested in that is, freight. You

sometimes call it goods, cargo, or freight but most common is

freight containers. Those come from the ports including

Hueneme however, let’s look at Port of LA and Long Beach.

They project 44 million TEU’s. A lot of people do not know what

a TEU is because things have changed but your projects do not

reflect that sort of change that is already going on in the

maritime industry. That is, there are container ships, right now,

that can take a 53’ container and they are increasing. This is

important because right now the predominant trade in trucks is

to take a 40’ container and break it into one 53’ container by

rearranging it. Then you have to stack to empty 40’s someplace.

Because of this there is a complex maritime freight going on.

The Draft RTP does not reflect this because in the South Bay

area, Gateway Cities, there may be fewer trucks based on the

fact that they can load a 53’ container on to either rail or onto

trucks. If you look at the Port of LA and Long Beach combined

they will produce about 45‐50 thousand trucks a day but SCAG

has trucking on the east west Corridors of 210, 10, 60 and

others, of over a 100 thousand trucks. Where do they all come

from? Based upon the available information in both the primary

and the appendices of the RTP, we do not know. This is a major

flaw, it is an incomplete and inadequate description of the

freight movements from the urban areas into the High Desert

Corridor. The Corridor is a basic Measure R, fully funded,

probably the most profitable of any of the Measure R

public/private partnerships. It is all toll system but it is not

depicted in your RTP.

Comment noted. Some ocean 

containers for moving cargo u

53‐foot container does not cu

international standards. New 

container ship designed to ca

containers, are measured by 

equivalent units (TEUs) they w

premature to assume a signif

utilizing twenty‐ and forty‐foo

containers to the use of 53‐fo

assuming a shift by ocean car

containers, the impacts on th

the region would remain unk

limited to: 1) Considerable vo

the region are domestic freig

San Pedro Bay Ports 2) Transl

deconsolidate cargo from TEU

containers, often provide add

besides repackaging 3) Not ev

goods all destined for the sam

the SCAG region have varied 

discusses the numerous pote

including international impor

Pedro Bay Ports, imports and 

border crossings, air cargo, lo

and goods movement depend

High Desert Corridor in the 20

with stakeholders as appropr

086‐03 Tom Williams LA 32

NeighborhoodCouncil

710, Extension – There is in fact a federal injunction right now

that says you cannot do any design, but if you take all of the

little pieces you have within your RTP, specifically the cost, how

do you get five significant digits of cost from one. There is no

reference as to what the source was and right now the most

current source was maybe going up to 2, 3, or 4 billion, nobody

Comment noted. The project 

based upon the cost for this p

Long Range Transportation P

expenditure dollars as require

Administration for all project 
227

ID Name Affiliation Comment Re

knows. You have an unreferenced significant cost in the project

list. Where did you get the numbers? You must have had a

design, concept, or otherwise.

087‐01 Tom Williams LA 32

NeighborhoodCouncil and

NELA Coalition

Where are the appendices referenced in the RTP Table of

Contents and throughout the Report??? The Supplemental

Reports are not technical supports for the RTP. See attached for

RTP references and table of contents copies. Please withdraw

the Draft RTP, revise, upgrade with technical appendices, and

recirculate.

Comment noted. The append

serve to support the 2012‐20

can be downloaded in their e

http://scag.ca.gov.

088‐01 Dolores

Gonzalez‐

Hayes

Latino Health

Access

We thank the Southern California Association of Governments

(SCAG) and its staff for the hard work on the Regional

Transportation Plan/Sustainable Communities Strategy

(RTP/SCS). Latino Health Access is particularly pleased to see

that important health and equity indicators were included in the

strategy positively impacting the health of our community. The

high levels of air pollution and health problems experienced in

the Southern California region require strong action to

transform transportation and land use planning. The Los

Angeles region continues to be rated as the most polluted area

for ozone in the country by the American Lung Association and

the public health toll remains high.

Comment noted.

088‐02 Dolores

Gonzalez‐

Hayes

Latino Health

Access

We trust and rely on the research by the American Lung

Association in California. The agency quantified the respiratory

health benefits of smart growth strategies in the Southern

California region. Their analysis showed that the six‐county

Southern California region could avoid over $16 billion in

cumulative health and societal costs through smart growth

strategies that reduce the growth in the region’s vehicle trips by

20 percent by 2035. While large, these benefits may represent a

small fraction of the greater benefits that accrue with more

physically active transportation options, as envisioned and

quantified by the California Department of Public Health’s I‐

THIM modeling project. Understanding the potential benefits of

given planning scenarios will help to identify plans that provide

the greatest reductions in harmful emissions and chronic

illnesses.

Comment noted.

088‐03 Dolores

Gonzalez‐

Hayes

Latino Health

Access

As an agency we see firsthand the effects that obesity and

diabetes has on the lives on our clients and recognized the need

for greater focus on a shift to active transportation modes like

walking, cycling and transit that reduce pollution emissions and

Comment noted.
228

ID Name Affiliation Comment Re

gets people out of their cars and into a more physically active

lifestyle. We join the American Lung Association in offering the

following comments and recommendations to ensure that the

Sustainable Communities Strategy and future transportation

investments place sufficient emphasis on promoting active

transportation modes and transit oriented development,

measuring and improving health progress, and ensuring that

health and equity are imbedded in the decision making process

for this plan and future planning efforts.

088‐04 Dolores

Gonzalez‐

Hayes

Latino Health

Access

Increase active transportation investments to more than $12

billion a year. While we appreciate the increase in active

transportation funding included in the draft SCS, we believe

more funding is needed. A recent study by the Los Angeles

County of Public Health estimated that up to $40 billion could

be needed to build out all of the current bicycle and pedestrian

projects in Los Angeles County alone. SCAG, in coordination

with health departments and organizations, should conduct a

Comprehensive Needs Assessment for the Southern California

region to determine the infrastructure needs to develop a

network of bicycle and pedestrian pathways and transit

connections. Analysis is also needed of how SCAG’s bicycle and

pedestrian per capita investment compares with other regions.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

088‐05 Dolores

Gonzalez‐

Hayes

Latino Health

Access

Improve Assessment of health benefits through new modeling

approaches. Utilize the new California Department of Public

Health I‐THIM screening tool to analyze the potential chronic

disease reductions that can be achieved in the SCAG region

based on increased transportation‐related physical activity such

as walking and biking. This model was used in the San Francisco

Bay Area region to determine reductions in heart and

respiratory disease, breast cancer and other health effects

linked to active transportation scenarios. We urge SCAG to

incorporate this tool in regional planning and decision making

for transportation investments.

Comment noted. The perform

2012‐2035 RTP/SCS has been 

participation and input from 

as collaboration with other la

the dialogue and developmen

2012‐2035 RTP/SCS, a Perform

was established in May 2011. 

gathered extensive input from 

provided recommendations t

Technical Advisory Committe

forwarding to the Policy Com

process and deliberations, ov

have been added to the RTP/

categories. Performance mea

based on their intended uses

and the other for on‐going m

staff will continue investigatin
229

ID Name Affiliation Comment Re

methods and tools for analys

updates.

088‐06 Dolores

Gonzalez‐

Hayes

Latino Health

Access

Include the attached list of 13 health and equity metrics in the

SCS and monitor over time, including expanded public health

targets. In addition to monitoring premature mortality, SCAG

should also assess reductions in asthma incidence and

exacerbations due to traffic related pollution (NOX) and other

targets through collaboration with local health departments,

the South Coast Air Quality Management District, academic

researchers and community based organizations. Improvements

to the targets should be monitored and reported to the public

every two years. Additional comments on the targets already

included by SCAG in the SCS will be sent in a separate comment

letter.

Comment noted. To address 

and stakeholder requests, SC

based metrics not previously 

explore further improving the 

active transportation and oth

RTP/SCS updates.

088‐07 Dolores

Gonzalez‐

Hayes

Latino Health

Access

•Focus investments on completing transit systems and building

out transit infrastructure, rather than highway expansion,

including the following: o Doubling Metrolink ridership by 2020

and double it again by 2035 o Expanding Bus Rapid Transit and

regional bus service o Enhancing TOD planning and 1st‐mile‐

last‐mile investments near Metrolink stations o Doubling the

bicycle network to 24,000 miles and improving pedestrian

environment

Comment noted. The 2012 RT

commuter rail lines, six new r

point to point express bus ser

rise in commuter rail boardin

use policy around transit stat

investments.

088‐08 Dolores

Gonzalez‐

Hayes

Latino Health

Access

Front load active transportation funding. SCAG should commit

to a higher amount of transportation funding for bike and

pedestrian infrastructure, especially in the early years of the 25‐

year RTP process. SCAG should work with local transportation

agencies to prioritize bicycle and pedestrian projects and ensure

the majority of funds are spent prior to 2020.

Comment noted.

SCAG cannot unilaterally chan

that are already in place. Sign

active transportation propose

predicated on additional reve

require future actions at the s

Therefore, the plan realistica

not be available in the near te

expected to be available is 20

The 2012‐2035 RTP/SCS alloc

towards regional Active Trans

response to the overall feedb

on final reconciliation of our f

note that the funding for Acti

been increased by $700 millio

released for public review an

increase of more than 270% o

2008 RTP. Furthermore, this d
230

ID Name Affiliation Comment Re

$4.1 billion, we believe the lo

on Active transportation over 

current expenditure pattern. 

funding for Active Transporta

sources in future RTP updates

SCAG is committed to assistin

development, implementatio

transportation plans.

088‐09 Dolores

Gonzalez‐

Hayes

Latino Health

Access

Increase investments in zero emission freight transportation in

order to reduce diesel emissions and exposures in communities

near freight corridors and rail yards. Ensure that funding

mechanisms are in place to expedite the implementation of the

zero and near‐zero emission freight and truck strategies and

infrastructure. Prioritize spending on projects that deliver

maximum health benefits for residents of the region, especially

those living along the freight corridor.

Comment noted. Emissions fr

a significant concern for the S

lane system identified in the 

facility used by zero‐emission 

SCAG also continues to suppo

address goods movement em

communities. Further clarifica

text regarding funding for de

of zero/near zero‐emission te

088‐10 Dolores

Gonzalez‐

Hayes

Latino Health

Access

Evaluate the number and type of new developments that could

be located in close proximity to freeways and high traffic

roadways in the SCAG region under the new RTP. Work with air

district, health departments and universities to develop and

implement best practice policies for developments located near

heavy traffic areas to reduce exposures to air pollution.

Comment noted. SCAG prepa

the emissions exposure in are

high volume roads. It should 

emissions near these facilities 

whole. In 2035 these areas st

the region as a whole. Howev

overall decrease, the rate of d

near freeways and high volum

RTP/SCS does result in an inc

locations, and as such health 

than if they were not in the b

project level analysis and mit

going health concerns. Howe

benefits for emissions exposu

areas near freeways.

088‐11 Dolores

Gonzalez‐

Hayes

Latino Health

Access

As health and medical organizations and professionals, we

recognize that strong government policies to control harmful

emissions and that dramatically increase options for active

transportation are critical to improving public health and quality

of life in Southern California. We stand ready to assist you in

implementing a truly health protective, equitable and

sustainable plan for Orange County and all of Southern

California.

Comment noted.
231

ID Name Affiliation Comment Re

089‐01 Jackelyn

Cornejo

Los Angeles

Alliance for a

New Economy

Thank you for the opportunity to comment on the 2012 Draft

Regional Transportation Plan/Sustainable Communities Strategy

(RTP/SCS). We have specific concerns regarding statements and

recommendations made in the document regarding how

transportation improvements can increase economic

competitiveness in the SCAG region. LAANE is an advocacy

organization dedicated to building a new economy for all.

Combining dynamic research, innovative public policy and the

organizing of broad alliances, LAANE promotes a new economic

approach based on good jobs, thriving communities and a

healthy environment. We strongly believe that infrastructure

investment is crucial to our region's economic recovery and to

increase mobility options for workers. However, at the same

time families should earn middle‐class wages, with health andpension benefits, as it also essential to stimulating our

economy. Solid infrastructure investment and good jobs go

hand‐in‐hand in being able to maximize public investment. We

find it very troubling that an agency, such as SCAG, would

recommend or suggest that lowering workers' wages would

make the region more economically competitive, as stated in

the Economic and Job Creation Analysis Appendix. Public

investment that is tied to increasing worker standards;

workforce training programs and targeting communities

disproportionately affected by poverty and unemployment will

make us more economically competitive. SCAG should look

towards models already existing, for example in Los Angeles

County, to guarantee efficiency in infrastructure projects and

put people back to work.

Comment noted. The referen

Job Creation Analysis “How T

Competitiveness,” number 2 

statement on wages. The info

the economic impact modelin

be added.

089‐02 Jackelyn

Cornejo

Los Angeles

Alliance for a

New Economy

Draft Analysis Comments 1. On Page 8, the draft Economic and

Job Creation analysis states: SCAG could take this

recommendation one step forward by identifying strategies

which ensure the creation of good‐middle class job creation and

project delivery. One such tool are Project Labor Agreements

(PLAs), in which public agencies can use to attract a highly‐

skilled workforce to complete construction projects on‐time and

on‐budget. PLAs, used in both the public and private sector, are

pre‐bid, collective‐bargaining agreements between a developer

(or agency) and the construction trade unions to set out wages,

standards and benefits for workers on a construction project. In

exchange, both parties agree to refrain from strikes or lockouts.

Comment noted.
232

ID Name Affiliation Comment Re

Because they are traditionally used on large‐scale, multi‐year

projects, they provide excellent opportunities to develop jobs

programs for communities. LAANE has pushed for a more

comprehensive approach by advocating for Construction

Careers Policies, which combine a PLA and a targeted hire

program, which requires contractors to set aside a percentage

of construction jobs to individuals who live in communities most

affected by high unemployment and poverty, and with barriers

to employment, PLA are an increasingly popular project delivery

tool in the SCAG region. Construction Careers policies have

been approved at the following agencies: City of Los Angeles

Community Redevelopment Agency, City of Los Angeles

Department of Public Works and Port of Los Angeles. Recently,

Construction Careers Policies have been applied to

transportation‐related construction projects. In March 2011, the

Exposition Line Construction Authority passed such a policy for

Phase II of the light rial project. In January 2012, the Los Angeles

County Metropolitan Transportation Authority Board of

Directors unanimously approved an agency‐wide policy that

includes a PLA and targeted hire program for projects greater

than $2.5 million, which includes many projects funded by

Measure R. Metro is the first transit agency in the country to

approve such a policy. This approach can serve as a valuable

tool for transit agencies throughout the SCAG region that are

dealing with the twin problems of congestion and

unemployment. In February 2011, the Federal Transit

Administration approved the use of targeted hire on projects

receiving federal dollars. The FTA approval sets a national

precedent for targeting disadvantaged workers on transit

projects.

089‐03 Jackelyn

Cornejo

Los Angeles

Alliance for a

New Economy

2. "How Transportation Improves Economic Competitiveness"

Section (P.8) This section of the draft plan analysis "outlines five

paths through which transportation improvements can increase

regional economic competitiveness." We find it troubling that

SCAG suggests that, under number 3, "Reduced Congestion

Reduces Employees' Asking (or Reservation) Wage." It states,

"Metropolitan areas, all else equal, lure more migrants into the

region due the amenity value of lower traffic congestion. This

increases the supply of available labor, driving wages down."

These statements suggest that congestion reduction alone

Comment noted. The referen

Job Creation Analysis, How Tr

Competitiveness, was not int

wages. The information was p

impact modeling results. SCA

closely with public and privat

development of the 2012 RTP

Land Use & Economic Counci

sectors including Southern Ca

Orange County Business Coun
233

ID Name Affiliation Comment Re

would encourage people to move into the SCAG region, as

opposed to other more essential factors such as major

industries that are rooted in the local economy ‐‐‐ goods

movement, tourism, construction, entertainment, etc. We

should be looking to strengthen industries that are vital to our

economy, not creating low‐road career options for residents. It

is also highly problematic to have a policy objective to lower

wages when the SCAG region has high levels of poverty,

unemployment, sluggish growth, and high levels of income

inequality. SCAG has provided an analysis that essentially

implies that lowering wages are a benefit to the region, and that

the agency can help achieve that through the 2012 RTP

congestion reduction interventions, projects and policies. For

example, the SCAG region: ranked last in average wage per job

at about $44,379 among the nine largest metropolitan areas,

has the highest poverty rate among the nine largest

metropolitan regions in the nation, and in 2006, had the highest

housing cost burden among the nine largest metropolitan

regions in the nation, with 53 percent of owner households

paying 30 percent or more of their incomes on housing. The

seven counties that are part of the SCAG region are grappling

with significant challenges that have been further exacerbated

by the recession. When workers spend less on transportation

costs, a benefit of reduced congestion, they are able to spend

their earnings in other ways, stimulating the regional economy.

Given that housing prices in the SCAG region, especially in Los

Angeles County, are very high, congestion reduction alone will

not address affordability and supply, and how current income

earnings play a role in where workers choose to live.

Partnership developed an Eco

and was adopted by SCAG's R

of the Strategy's emphases is 

the region's key industries.

089‐04 Jackelyn

Cornejo

Los Angeles

Alliance for a

New Economy

We suggest the following recommendations be considered in

revising the RTP: Delete language in the 2012 RTP/SCS or

appendices that suggest that lower wage rates in the SCAG

region are a benefit of congestion reduction strategies included

in the plan; Include tools, such as project labor agreements with

targeted hire, that allow government agencies to ensure that

investment in transportation infrastructure also creates middle‐

class careers, especially in construction; Include an analysis on

what the economic benefits of congestion reduction in

improving the quality of life of workers in the SCAG region,

which includes how the diversion of earnings from

Comment noted. The referen

Job Creation Analysis, How Tr

Competitiveness, was not int

wages. The information was p

impact modeling results.
234

ID Name Affiliation Comment Re

transportation costs to other vital services and industries can

stimulate our economy. We hope that the agency takes these

recommendations seriously and develops a blueprint for the

region that improves the quality of life of working families

through effective infrastructure investment and the creation of

good middle‐class career opportunities.

090‐01 Alexis Lantz Los Angeles

County BicycleCoalition

It is critical that the 2012 RTP set tangible and measurable goals

to improve the safety of all community members, especially our

most vulnerable road users, those walking and bicycling. We are

concerned that the SCAG staff report to the Regional Council

and Policy Committees, dated October 20th, failed to provide

measurable goals in regards to Safety and Active

Transportation. We encourage SCAG to be specific as to how

the 2012 RTP/SCS will improve the safety of people walking and

bicycling and how SCAG and the six County Transportation

Commissions can work to address and achieve policies listed

such as: "making transit more bike friendly" and how to

"encourage implementation of a Complete Streets policy across

the region," (as stated on page 11 of 10/20 staff report).

Creating a more multimodal transportation network in the SCAG

region requires the RTP to be specific about how investments in

active transportation will be funded, planned, prioritized,

measured and developed in collaboration with partners and

interested stakeholders. With those key principles in mind, we

respectfully submit the following recommendations for your

consideration:

Comment noted. Please see t

which recommends 69 action

complement the 152 actions 

Safety Plan.

090‐02 Alexis Lantz Los Angeles

County BicycleCoalition

1. Fund: Increase Funding Levels for Bicycle and Pedestrian

Infrastructure: Currently close to 21 percent of all trips in the

SCAG Region are done via walking and bicycling (2009 National

Household Travel Survey) and 25 percent of all SCAG roadway

injuries and fatalities are pedestrian and bicyclists (2008

SWITRS). The Region's last RTP, adopted in 2008, allocated only

0.46 percent of its total funding for these modes.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour
235

ID Name Affiliation Comment Re

090‐03 Alexis Lantz Los Angeles

County BicycleCoalition

We respectfully request that the 2012 RTP includes strategies to

significantly increase the proportion of funds allocated to active

transportation so that over time, such funding reflects the

proportion of trips made by walking and biking.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

090‐04 Alexis Lantz Los Angeles

County BicycleCoalition

We recommend the following: Preliminary estimates show a

funding need in the range of $22B to $36B throughout the life

of the 2012 RTP to fund the build‐out of high priority pedestrian

and bicycle investments as identified by local jurisdictions.

Given the mode split, safety and collision trends, public health

concerns and many other co‐benefits we recommend that 5‐8

percent of the 2012 RTP fund active transportation projects.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

090‐05 Alexis Lantz Los Angeles

County BicycleCoalition

All future SCAG Regional Transportation funding strategies

should allocate 10 percent of all revenue towards walking and

biking improvements and investments to help meet the unmet

funding gap for active transportation.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu
236

ID Name Affiliation Comment Re

will continue to evaluating fu

and pursue new funding sour

090‐06 Alexis Lantz Los Angeles

County BicycleCoalition

Recommend the formation of an Active Transportation Funding

Committee to assist in the next six months while the RTP

continues its development and scheduled adoption in May

2012.

Comment noted.

090‐07 Alexis Lantz Los Angeles

County BicycleCoalition

We recognize going from 0.46% to 5%‐8% is a significant jump in

investments, however we maintain that there is tremendous

unfunded need to make our streets safer and usable for all

users. Many from around the region would be interested in

assisting with identifying strategies for unmet active

transportation funding needs, as we would be happy to play a

leadership role in this Committee.

Comment noted.

090‐08 Alexis Lantz Los Angeles

County BicycleCoalition

Plan and Economics: Integrate Bicycle and Pedestrian

Improvements into all Transportation System Preservation

Projects: Road maintenance and the first and last mile

connections to transit are crucial for creating a connected and

sustainable transportation system. System preservation is

inherently important to people walking, biking, and connecting

to transit; there needs to be enhancements for complete streets

‐ ensuring that when maintenance opportunities arise or are

scheduled, that the region is leveraging its limited resources to

enhance our multi‐modal transportation network. Currently the

potential benefits to of the Transportation System Preservation

category fail to address how these investments will improve the

safety and access of people walking and biking ‐ it only outlines

benefits to drivers.

Comment noted. The Active T

the need for active transporta

transportation planning prog

090‐09 Alexis Lantz Los Angeles

County BicycleCoalition

Therefore we recommend: Embed a Complete Streets Policy

within the Transportation System Preservation category that

requires any investments into system preservation on surface

streets include improvements for pedestrians and bicyclists, and

those accessing transit. Funding for Transportation System

Preservation of highways needs to include bicycle and

pedestrian safety improvements at on/off ramps to ensure

greater safety of people using those modes of surface streets

that connect with ramps and help knit communities, that have

been adversely impacted by freeway on and off ramps, back

together. Adopt a Complete Streets checklist that requires

County Transportation Commissions to demonstrate how each

project is addressing all modes. This checklist should be

Comment noted. Goal 3: Incr

in the SCAG Region, Objective 

Streets Policy includes two po

jurisdictions to prioritize and 

comply with ADA requiremen

jurisdictions to develop and im

Policies.
237

ID Name Affiliation Comment Re

included in the 2012 RTP to be implemented in 2014. This will

assist in prioritizing projects that are critical in achieving

regional goals.

090‐10 Alexis Lantz Los Angeles

County BicycleCoalition

Plan: Do Bicycle and Pedestrian Planning: Improving the walking

and biking environments in our region cannot be done without

adequate planning at the local level. Unfortunately, many SCAG

cities do not have bicycle or pedestrian master plans; in Los

Angeles County, for example, only approximately 11 of 88 cities

have bicycle master plans and four cities have pedestrian plans.

Additionally, current station area plans fail to take into account

the first and last mile of transit trips, which are usually done on

foot or by bicycle. This lack of planning is a significant

impediment to improving infrastructure for people who rely on

bicycling and walking to connect to transit, work, school, and

their daily needs. As such we recommend: Expand the Compass

Blueprint program to support SCAG cities in the development of

bicycle, pedestrian, Safe Routes to Schools, Safe Routes to

Transit, and ADA Transition plans. It is estimated that it would

require approximately $200,000 per city to develop these plans

(95 cities at $200,000). Identify and secure funding sources in

order to set aside at least $19M in the 2012 RTP to support

these planning efforts. Establish a goal of 50 percent of SCAG

cities having completed at least one plan by 2016 in order to

prepare for the 2016 RTP.

Comment noted. SCAG is com

member counties and cities t

plans and policies. SCAG will w

development of Pedestrian S

conducting workshops; and a

maintenance of their local ac

may consider expanding the C

transportation plans in the fu

090‐11 Alexis Lantz Los Angeles

County BicycleCoalition

Prioritize: Safety and Equity: Bicyclists and pedestrians account

for 25% of all roadway fatalities and injuries in the SCAG Region

(2008 SWITRS), yet these modes are currently receiving less

than 0.46% of all available funding (2008 SCG RTP).

Comment noted. Goal 1 of th

is to decrease bicyclist and pe

working with local jurisdiction

environment in the SCAG reg

090‐12 Alexis Lantz Los Angeles

County BicycleCoalition

Studies also show that a disproportionate amount of those

injuries and fatalities occr in low‐income communities (Traffic

Injury Prevention 09/11). It is critical that we are doing all we

can to ensure safety for all community members, regardless of

where they live or how they travel. Earlier this month, the Los

Angeles Times wrote a compelling article on 2 young girls

walking to school who were severely injured when a car struck

them. It is imperative that our transportation plans are doing all

they can to make sure these tragedies, and the high number in

which they occur in the SCAG region, end.

Comment noted. Goal 1 of th

is to Decrease Bicyclist and Pe

SCAG will work with local juri

transportation environment i

with local jurisdictions to pro

all road users, direct enforcem

and walking safety to reduce 

with local advocacy groups an

provide bicycle‐safety curricu

090‐13 Alexis Lantz Los Angeles

County Bicycle

For these reasons, we recommend that the RTP take the

following steps to increase safety and equity: Analyze bicycle

Comment noted. In the Trans

5% collision locations in the S
238

ID Name Affiliation Comment Re

Coalition and pedestrian collision data to understand where high rates of

collisions in the six‐county region are happening and if collision

rates are increasing or decreasing each year.

Highways, interchanges and l

addition, SCAG had obtained 

California Highway Patrol as 

Traffic Records System and ge

locations where collisions inv

090‐14 Alexis Lantz Los Angeles

County BicycleCoalition

SCAG staff should present a yearly report to the SCAG Board to

help inform the public and the Board on the state of walking

and bicycling safety, and Safe Routes to School programs in the

region.

Comment noted. SCAG will co

basis.

090‐15 Alexis Lantz Los Angeles

County BicycleCoalition

Many of the counties in the SCAG region are working to support

local efforts and investments ‐ these projects are increasing

safety and improving the mode split, and addressing community

concerns.

Comment noted.

090‐16 Alexis Lantz Los Angeles

County BicycleCoalition

The RTP should set a goal of working towards zero deaths and

should prioritize improve the safety of all transportation modes.

Comment noted. Goal 1 of th

is to Decrease Bicyclist and Pe

SCAG will work with local juri

transportation environment i

with local jurisdictions to pro

all road users, direct enforcem

and walking safety to reduce 

with local advocacy groups an

provide bicycle‐safety curricu

090‐17 Alexis Lantz Los Angeles

County BicycleCoalition

Utilize Transportation Injury Mapping System (TIMS) in the 2012

RTP. Allocate greater resources to cities with little or no

bicycle/pedestrian infrastructure and/or plans, high rates of

collisions (using TIMS data), and significant populations of low‐

income residents. Identify these communities in the 2012 RTP in

order to allocate resources for technical assistance and

prioritize planning and infrastructure resources. Expand the

"Toolbox Tuesdays" programs to include bicycle safety design,

pedestrian safety design, ADA design, and training on how to

use the TIMS program for staff from the 190 SCAG cities, to

expand understanding of where collisions are happening, how

to improve the safety for people walking and bicycling, and

enhance local jurisdiction HSIP, SRTS, and other grant

opportunity applications.

Comment noted. In the Trans

5% collision locations in the S

Highways, interchanges and l

addition, SCAG had obtained 

California Highway Patrol as 

Traffic Records System and ge

locations where collisions inv

In addition, SCAG will work w

safe transportation environm

with local jurisdictions to pro

all road users, direct enforcem

and walking safety to reduce 

with local advocacy groups an

provide bicycle‐safety curricu

090‐18 Alexis Lantz Los Angeles

County BicycleCoalition

Measure: Conduct Pedestrian & Bicycle Usage Counts: We must

increase documentation of bicycle and pedestrian usage and

demand by regularly assessing numbers of people walking and

biking. Without such figures, it is difficult to forecast usage or

Comment noted. SCAG has id

collection regarding pedestria

facility conditions, and injurie

develop a clear understandin
239

ID Name Affiliation Comment Re

measure the positive benefits of investments in these modes. conditions. SCAG acknowledg

necessary to improve decisio

deficiencies and needs within 

system.

090‐19 Alexis Lantz Los Angeles

County BicycleCoalition

Create and fund a regional bicycle and pedestrian count

program at SCAG establishing yearly usage counts at key

locations in cities throughout the SCAG region.

Comment noted.

090‐20 Alexis Lantz Los Angeles

County BicycleCoalition

Use the data collected to establish trends, set goals, evaluate

fund requests for facility improvements, prioritize

improvements, and show the impacts of recent improvements.

Set aside funds in SCAG's 2012/2013 OWP to create and

maintain this program in future years.

Comment noted.

090‐21 Alexis Lantz Los Angeles

County BicycleCoalition

The RTP should set a target for increasing the amount of all trips

made by bicycle and the amount of walking to transit trips

(measuring the 1st/last mile).

Comment noted. Goal 3 of th

is to increase Active Transpor

adopting a Safe Routes to Sch

Policy.

090‐22 Alexis Lantz Los Angeles

County BicycleCoalition

Collaborate: Review Local Input, Provide Opportunities for

Stakeholders to Engage and Incorporate Feedback: There are

growing voices all over the six county SCAG region in support of

safe walkable and bikeable neighborhoods for users of all ages

and abilities. Safe Routes to School programs and investments is

an example of a broad spectrum program that while focusing on

improvements to ensure the safety of our youth, ultimately

benefits the whole neighborhood.

Comment noted. SCAG is com

stakeholders to develop a saf

throughout Southern Californ

090‐23 Alexis Lantz Los Angeles

County BicycleCoalition

Many of these individuals, community members, professional ‐ 

and more, have concerns about the fundamental change

needed in our region.

Comment noted.

090‐24 Alexis Lantz Los Angeles

County BicycleCoalition

SCAG conducted valuable and well run workshops this summer,

and we commend those efforts, however we are concerned

there has not been a report compiled and presented on the

feedback received in those workshops. We understand SCAG

staff is working on this. We urge these findings to be shared in a

timely manner with the Board, so that they may understand

their constituents. We ask that the staff to report on what was

heard and how these comments are addressed in the draft 2012

RTP.

Comment noted. Feedback re

workshops was analyzed and 

Committees and Regional Cou

purposes of developing the D

090‐25 Alexis Lantz Los Angeles

County BicycleCoalition

We recognize there is a significant increased level of

investments and policies outlined in this document, this is built

on the demand, interest and support for active transportation

Comment noted.
240

ID Name Affiliation Comment Re

happening all over the SCAG region. With increased

opportunities for stakeholders to weigh in on the Region's

Transportation Plan, we believe this will strengthen the RTP and

its ability to be successfully implemented over the coming years.

091‐01 Tracy Rafter Los Angeles

CountyBusinessFederation

For the past three years, business and industry representatives

from throughout Southern California have participated in the

Southern California Association of Government's extensive

process used to develop the region's Draft 2012 Regional

Transportation Plan (RTP), which includes an inaugural

Sustainable Communities Strategy (SCS). Our interest in this

process has been particularly keen given both the significant

economic challenges currently facing our region's economy and

the fact that the inaugural SCS could ‐ if not considered from

many viewpoints ‐ have unforeseen negative consequences. In

light of our ongoing participation and understanding, we

appreciate the tremendous effort that SCAG's staff and leaders

have put into the process that led to the Draft 2012 RTP/SCS &

PEIR. The development of this RTP/SCS followed an inclusive

approach with SCAG holding hundreds of meetings with SCAG's

public and private stakeholders. We also appreciate the

extensive economic analysis that SCAG has performed on the

Draft RTP/SCS in order to provide all stakeholders and SCAG's

Regional Councilmembers with an understanding of the

financial impacts of the plan. As representatives of Southern

California's broader business community, we recognize the

crucial roles that transportation and infrastructure have in

maintaining our region's economy and quality of life.

Accordingly, through this letter, we join together to provide

SCAG with general comments regarding remaining significant

concerns about the contents of both (i) the Draft 2012 RTP/SCS,

and (ii) the Draft Program Environmental Impact Report (PEIR).

Comment noted.

091‐02 Tracy Rafter Los Angeles

CountyBusinessFederation

Foster economic growth and job creation in a balanced and

accountable manner and in recognition of foreseeable regional

population growth;

Comment noted. Please see R

Chapter 1, Vision.

091‐03 Tracy Rafter Los Angeles

CountyBusinessFederation

Utilize all revenue sources very efficiently, and utilize new

revenue sources only if they are economically sound and

equitable;

Comment noted. The Transpo

additional detail and explanat

included in the RTP. We cons

principles as a foundation for 

revenues that are reasonably 
241

ID Name Affiliation Comment Re

financial strategies: • Establis

reflects the true cost of trans

protection for transportation 

distribution of costs and bene

programs that include return

maintaining flexibility to rewa

commit substantial local reso

funding with innovative finan

expansion of TIFIA) to attract 

project delivery. • Promote fu

federal commitment to the n

recognizing the pivotal role th

and international trade. The i

return of $2.90 for every doll

091‐04 Tracy Rafter Los Angeles

CountyBusinessFederation

Honor the prerogatives that local governments – as the level of

government with the greatest understanding of and sensitivity

to community interests and context – should continue to enjoy

concerning land use and community development;

Comment noted. SCAG based 

assumptions in the RTP/SCS o

197 local jurisdictions. In som

land use assumptions (within 

better reflect recent trends o

of the region. While the SCS i

strategy that local governmen

and generally includes the qu

each city and county in the re

jurisdictions maintain local la

091‐05 Tracy Rafter Los Angeles

CountyBusinessFederation

Comply with the California Environmental Quality Act (CEQA)

and federal environmental laws and regulations (e.g., federal

Clean Air Act conformity); and ‐ Allow for expeditious review

and approval of projects that are consistent with a sound and

reasonably accommodating RTP/SCS.

Comment noted. The RTP/SC

requirements including SAFET

Transportation Plan Guideline

091‐06 Tracy Rafter Los Angeles

CountyBusinessFederation

Turning to the substance of the RTP/SCS as a policy matter, we

have the following additional general comments: 4) The

RTP/SCS is undergirded by analysis which shows the dispersion

of populations and employment shown and categorized at the

level of sub‐jurisdictional “transportation analysis zones” (TAZs).

The TAZ level of detail is, we believe, too small and precise a

level at which to prescribe the spatial dispersion of

development and redevelopment, particularly in light of the

regional nature of the RTP/SCS. Page 148 of the SCS should

therefore be clarified to indicate that questions of consistency

with the RTP/SCS should be substantively measured and

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.
242

ID Name Affiliation Comment Re

determined at a jurisdictional or sub‐regional level, not at a TAZ

level.

091‐07 Tracy Rafter Los Angeles

CountyBusinessFederation

5) The RTP/SCS should aim to reflect and accommodate both

the short‐term future of the SCAG region and its longterm

future. For example, the RTP should better anticipate the need

for and reasonable likelihood of a gradual transition in the

region’s overall vehicle fleet (e.g., gradually towards alternative

fuels) and the ongoing need for enhancements to vehicular

mobility even as more mass transit comes to fruition.

Comment noted. The 2102 RT

document that accounts for v

both near‐term and long‐term 

going need for enhanced mob

091‐08 Tracy Rafter Los Angeles

CountyBusinessFederation

6) More detail, clarity and explanation are needed concerning

the new revenue sources that are outlined within the plan

document. New revenues account for $219.5 billion out of the

total $524.7 billion needed for the transportation plan, yet

there is very little detail explaining these significant new fees

and impositions (see page 95 & 96 of the Draft RTP/SCS). To

fully and fairly evaluate these proposals, the business

community and all stakeholders need the benefit of additional

detail and explanation. In particular, we need clarity and

assurance regarding the following: a. The new revenue concepts

assumed within the RTP/SCS must be fair, equitable and

economically sound, meaning that an appropriate nexus exists

to assure that new revenues are drawn fairly and proportionally

from those who benefit from the related transportation

infrastructure or improvement. b. The new revenue sources

within the RTP must be effectively allocated, meaning the plan

should clearly articulate how resources will be efficiently and

responsibly allocated so that there is the best possible return on

investment for the expenditure of these new transportation

funds. SCAG needs to show that it will be a responsible,

accountable and innovative steward of the new revenues that it

is proposing.

Comment noted. The Transpo

additional detail and explanat

included in the RTP. We cons

principles as a foundation for 

revenues that are reasonably 

financial strategies: • Establis

reflects the true cost of trans

protection for transportation 

distribution of costs and bene

programs that include return

maintaining flexibility to rewa

commit substantial local reso

funding with innovative finan

expansion of TIFIA) to attract 

project delivery. • Promote fu

federal commitment to the n

recognizing the pivotal role th

and international trade. The i

return of $2.90 for every doll

091‐09 Tracy Rafter Los Angeles

CountyBusinessFederation

8) In the RTP, SCAG should identify and highlight the significant

economic contributions of the goods movement sector to the

regional and state economy. Specifically, the RTP should

acknowledge that, as business stakeholders work with

regulatory agencies to further reduce emissions in the SCAG

region, any technology introduced must not compromise the

safety, velocity, cargo throughput, economic competitiveness,

or reliability of the goods movement system. It would be helpful

for SCAG to state clearly in the RTP that, to date, stakeholders

Comment noted.SCAG clearly 

contribution of the goods mo

state economy. We concur th

must not compromise the saf

economic competitiveness, a

movement system. Further cl

development, stakeholder inv

provided in the text of the RT

all goods movement stakeho
243

ID Name Affiliation Comment Re

have not reached consensus on technologies, timing, funding,

or emissions impacts of the various options that SCAG examined

in the RTP. For example, SCAG discusses long‐term steps

towards a "Zero Emissions Container Movement System"

(ZECMS). If SCAG chooses to pursue such a fundamental shift in

new technology, it would need to work with all goods

movement stakeholders to clearly establish whether and, if so,

when and where within the transportation infrastructure a

ZECMS option could be demonstrated and evaluated without

negatively effecting the velocity and throughput of the system.

technology options.

091‐10 Tracy Rafter Los Angeles

CountyBusinessFederation

9) With the recent elimination of redevelopment agencies, the

ability of local jurisdictions to meet the densification of urban

centers in the near term is challenged, given the costs related to

aging or inadequate infrastructure capacity and high

development costs for higher density projects. The elimination

of redevelopment agencies also threatens the availability of

sufficient housing options necessary to meet the needs of a

dynamic workforce. In fact, since the passage of SB 375, the

State of California has stripped local governments of funds that

were previously available for transit, transportation and

redevelopment. This follows many years in which the state

diverted revenues from gasoline, sales, income and other taxes

needed for local government programs. Local governments

cannot help to fulfill the 2012 RTP/SCS without increased, not

decreased, state support. SCAG should emphasize the need for

the state to restore support for planning, transit, transportation

and redevelopment or other necessary funding to pre‐SB 375

levels in order to speed the attainment of mandated goals.

While we find many very positive aspects in the plan, especially

related to principles and direction, these significant issues need

to be addressed. The short list of general concerns set forth

above is not meant to be exhaustive. Many of the organizations

that subscribe to the above‐stated comments will be

commenting more robustly in separate writings. We join here,

however, to express our unity in finding the Draft 2012 RTP/SCS

and PEIR to be in need of significant clarification and correction.

We are also jointly committed to completing this process and,

over the remaining weeks, working closely with SCAG to

develop and adopt a smart, flexible, accountable, and

economically sound RTP/SCS.

Comment noted. SCAG condi

regional targets on 11 recom

restoring previous levels of st

also included mileage‐based 

and federal gas excises taxes 

to stabilize state and federal t

which will help ensure we hav

state and federal mandates.
244

ID Name Affiliation Comment Re

091‐11 Tracy Rafter Los Angeles

CountyBusinessFederation

7) New revenues from fees on businesses operating in the SCAG

region – and particularly the “Freight Fee/National Freight

Program” listed on page 96 of the Draft RTP – need to be

developed and implemented at the federal level, not the local

and regional level. Unless such fees are imposed on a national

scale, the region’s competiveness will be compromised.

Comment noted. The RTP doe

of local, regional, or statewid

SCAG region or its member e

disadvantage were critical co

development of all funding p

091‐12 Tracy Rafter Los Angeles

CountyBusinessFederation

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

092‐01 Jean

Armbruster

Los Angeles

CountyDepartment ofPublic Health

We applauded SCAG for a job well done and embrace the many

aspects of the RTP which will improve public health including

expanding public transit, reducing , increasing bike pad funding,

and I’m very excited to hear from the presentation increasing

bike pad planning, that’s really good news.

Comment noted.

092‐02 Jean

Armbruster

Los Angeles

CountyDepartment ofPublic Health

To support SCAG in making resource allocation decisions our

department developed an estimate suggestive of the need for

bike and pedestrian improvements in the SCAG region. This was

actually a very lengthy analytical process, we reviewed the cost

data in existing cities bike and pedestrian plans in L.A. County

and the Caltrans

_______

disclosed grants in L.A. County. We

looked at the cost of sidewalk repairs in the City of Los Angeles

which is quite significant. We also looked at the cost for building

pedestrian and bicycle improvement in transit oriented districts

which is all about the First Miles, Last Mile issue. We then used

this data to extrapolate the needs for the entire region. Given

that this bike and pedestrian plans have a range of cost for

proposed improvements we actually looked at a corresponding

range for the cost of active transportation funding. We came up

with low of 37 billion to a high of 60 billion over twenty give

years and this is adjusted for inflation as per the RTP. This is not

a recommendation for funding, but we do feel like given the

region’s long standing under investment in bike and pedestrian

infrastructure and over investment in highways, arterials, etc.,

that we really need to be thinking about this as an appropriate

range for investment options in the RTP. An investment of this

magnitude could yield for our region basic bike and pedestrian

infrastructure in key areas of every city in the SCAG region. It

could yield bikeable and walkable neighborhoods within a half

mile of all transit oriented districts existing. It could yield public

Comment noted. The 2012‐2

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

committed to working with lo

active transportation friendly 

SCAG region.
245

ID Name Affiliation Comment Re

schools throughout the region that children can walk and bike

to. Sidewalks that are repaired throughout the region and

improved continuity in county bike networks.

092‐03 Jean

Armbruster

Los Angeles

CountyDepartment ofPublic Health

Our recommendations for the RTP include: • Front loading the

act of transportation funding so it is available early on to

jurisdictions in the twenty‐five year period.

Comment noted. The distribu

transportation investments in 

tax measure commitments ap

transportation commission ad

plans, limitations associated w

other previous commitments

092‐04 Jean

Armbruster

Los Angeles

CountyDepartment ofPublic Health

• Targeting active transportation investments in TOD’s creating

First and Last Mile connections to transit.

Comment noted.

092‐05 Jean

Armbruster

Los Angeles

CountyDepartment ofPublic Health

Targeting investments to close the GAP’s in the key bike pad

corridors.

Comment noted. The 2,012.2 

Network aims to close gaps in 

may be used to increase bicyc

within the SCAG region.

092‐06 Jean

Armbruster

Los Angeles

CountyDepartment ofPublic Health

• Providing funding and technical assistance for cities to create

bike and pedestrian plans and to build out those plans.

Comment noted. SCAG is com

jurisdictions with assistance i

implementation of their activ

092‐07 Jean

Armbruster

Los Angeles

CountyDepartment ofPublic Health

• Funding jurisdictions to create TOD plans to provide incentives

for housing and business, to low income people, and to prevent

displacement of existing low income tenants.

Comment noted. Although th

and displacement is inconclus

resources to address gentrific

look forward to continuing to 

would encourage these proje

Compass Blueprint.

092‐08 Jean

Armbruster

Los Angeles

CountyDepartment ofPublic Health

• Citing housing and other sensitive use development far

enough away from sources of pollution to decrease exposures

that can negatively affect health.

Comment noted. There is sub

on health risks related to air p

infrastructure included in bot

Appendix and in the Program 

Staff will provide further anal

several comments.

092‐09 Jean

Armbruster

Los Angeles

CountyDepartment ofPublic Health

• Integrating complete streets into all transportation projects

and including health criteria when improving projects.

Comment noted. The Active T

the concept of Complete Stre

Transportation Usage in the S

Adoption of a Complete Stree

Encourage local jurisdictions t

projects/policies to comply w
246

ID Name Affiliation Comment Re

Encourage local jurisdictions t

Complete Streets Policies.

092‐10 Jean

Armbruster

Los Angeles

CountyDepartment ofPublic Health

• Measuring how benefits of transportation plans and

incorporating health performance metrics and health outcomes

into SCAG’s modeling

Comment noted. SCAG is cur

our Sustainability Tool (ST) by 

tract based land use and built 

to confidential health survey 

Angeles County, Department 

completing this work for the 

round of Regional Transporta

Communities Strategy (SCS) i

092‐11 Jean

Armbruster

Los Angeles

CountyDepartment ofPublic Health

• Adopting transportation policies that discourage people from

driving and include strategies such as congestion pricing and

incentives for non‐auto forms of transportation.

Comment noted. SCAG's Tran

Appendix includes recommen

single occupancy vehicles, inc

strategies, rideshare, active t

The Congestion Management 

containing various TDM/TSM 

metrics.

093‐01 Richard

Bruckner

Los Angeles

CountyDepartment ofRegionalPlanning

We are concerned that the Draft RTP/SCS states that the growth

forecast is based on local input. The overall land use pattern

maps for Los Angeles County (Part A of the SCS background

documentation appendix of the SCS Chapter) reflect land use

patterns that are not part of the County's local input. In

particular, the land use pattern for the northwest corner of the

unincorporated Antelope Valley reflects significant growth by

2020. A review of the TAZ level socioeconomic data for that

area shows projections of over 10,000 new households by 2020,

and over 22,000 new households by 2035. The area is a

greenfield designated Non‐urban by the Antelope Valley Area

Plan. The area also consists of environmental and hazard

constraints. Another concern is the land use pattern in

Unincorporated Rowland Heights, and unincorporated South

Diamond Bar along SR‐57, particularly the designation of this as

a HQTA by 2035. This area is vacant, designated open space or

low density, and also consists of hazard and environmental

constraints.

Comment noted. SCAG’s grow

are primarily based on the bo

also reviews regionally signifi

Intergovernmental Review (IG

received from the IGR project

incorporates the growth from 

their impacts on the regional 

add to the 2012 RTP/SCS Gro

description of how to evaluat

IGR projects into small area s

2008 RTP growth forecast rep

093‐02 Richard

Bruckner

Los Angeles

CountyDepartment ofRegionalPlanning

It is our understanding that SCAG assumed growth within these

areas based on knowledge of pending large‐scale projects

through the CEQA IGR process. The assumption of growth based

on pending individual projects is not explicitly described in the

Draft RTP/SCS as part of SCAG's growth forecast methodology.

Comment noted. SCAG review

through the Intergovernment

information received from th

incorporates the growth from 

their impacts on the regional 
247

ID Name Affiliation Comment Re

In addition, assuming growth based on individual and pending

projects is of concern given the uncertainty of projects that

have not been considered by a decision making body and he

public, and the significant time and complex issues entailed in

processing large scale projects. The projects mentioned above

will require legislative acts by the LA County Board of

Supervisors, and this action should not be assumed. In addition,

assuming a pending project in the growth forecast puts local

governments in a difficult position and causes confusion when

the project is actually considered for public hearing.

Furthermore, as large‐scale projects are often built in phases,

assuming full build‐out for an individual project within the

horizon of the RTP may not always be appropriate—in

particular, assuming over 10,000 new households by 2020 and

over 22,000 new households by 2035 in one particular TAZ.

These projections are not consistent with historical data. The

Antelope Valley absorbs less than 200 new units per year. Even

if 100% of the growth were in this one area, these projections

would far exceed historic patterns.

add to the 2012 RTP/SCS Gro

description of how to evaluat

IGR projects into small area s

2008 RTP growth forecast rep

093‐03 Richard

Bruckner

Los Angeles

CountyDepartment ofRegionalPlanning

Given the outlined concerns, we recommend the following

amendments to the Draft 2012 RTP/SCS: 1. Amend the Overall

Land Use Pattern maps and adjust the associated TAZ‐level

socioeconomic data to redistribute the growth assumed to

occur due to pending large scale IGR projects to areas where

the County encourages growth in the General Plan Update, such

as Transit Oriented Districts; and 2. As an alternative to using

pending large scale IGR projects to inform growth distributions

in the Draft RTP/SCS, add a separate section to the Draft

RTP/SCS that acknowledges pending large‐scale IGR projects

throughout the SCAG Region and their potential to impact

future growth forecasts upon approval and adoption by the

local jurisdiction. Consistency between the General Plan Update

and Draft RTP/SCS is an important part of advancing the goals of

the RTP/SCS at the local level. We acknowledge that several

large projects are in the entitlement process, and at the time

projects are approved it would be appropriate to amend the

RTP/SCS.

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level. SCAG will 

forward on small area growth 

094‐01 Lori Abrishami Los Angeles

CountyMetropolitan

We commend SCAG for the significant and unprecedented

outreach to MTA, sub‐regional agencies, and the public in the

development of the Draft 2012 RTP/SCS. We also acknowledge

Comment noted. We are grat

MTA played in the developme

forward to continuing our pa
248

ID Name Affiliation Comment Re

TransportationAuthority

the extensive and dedicated effort on the part of SCAG to craft a

Southern California approach to the new SCS requirements of

SB 375. We are pleased that the Draft 2012 RTP/SCS has been

able to meet both the air quality conformity requirements of

the federal Clean Air Act, and greenhouse gas emission (GHGe)

reduction requirements necessary to comply with SB 375.

the RTP/SCS.

094‐02 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

a) We appreciate the working relationship between SCAG and

MTA staff necessary to integrate our 2009 Long Range

Transportation Plan (LRTP) projects, programs, and financial

assumptions into the Draft 2012 RTP. It appears that the Draft

2012 RTP includes all projects and programs funded by MTA in

the 2009 LRTP. We note that SCAG has identified a number of

projects and programs that are beyond funding levels of the

LRTP. We assume that these projects and programs will be

funded through new or innovative funding programs that SCAG

has identified in the Draft 2012 RTP as “reasonably available”

funding sources over the life of the RTP. Examples of projects

beyond the funded LRTP include: East‐West Freight Corridor

between the I‐710 and the I‐15; Phase I of the California High

Speed Rail Authority (CHSRA), pending an agreement between

CHSRA, Metrolink and LOSSAN to identify funds to bring local

systems up to high speed (110+ MPH) where possible; A

regional Express/HOT Lane Network that expands our Fast

Lanes pilot project to include the I‐405 and SR‐91; Various

modal programs, including bus and rail expansion, TDM, TSM,

bicycle, pedestrian, and operations and maintenance. b) MTA

has proposed and is advocating a program known as America

Fast Forward (formerly known as the 30/10 Initiative) to look at

federal loan and bonding mechanisms which could accelerate

the completion of 12 transit projects in 10 years instead of 30

years. We believe that such a program is beneficial to Southern

California counties that have a tradition of self‐help local sales

tax mechanisms, and that those self‐help traditions should be

rewarded through new federal bonding or loan assistance

programs. Clearly this program would assist the region in the

earlier attainment of federal and state air quality conformity

and GHGe reduction requirements. We would recommend that

a section be included in the Draft 2012 RTP regarding America

Fast Forward, and that this section include SCAG policies and

actions to partner with MTA and other county transportation

Comment noted. a) We likew

working relationship between 

assumptions regarding fundin

programs beyond the LRTP ar

reasonably available sources 

America Fast Forward is spec

the Draft RTP and additional 

supportive of this effort and w

other county transportation c

existing revenue sources and 
249

ID Name Affiliation Comment Re

commissions to support and advocate for federal enactment of

this program.

094‐03 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

We note that page 50, paragraph 3 states that “our region has

virtually no bus lanes, especially compared to other major

metropolitan areas.” We would suggest that this reference be

revised to acknowledge that MTA has opened the highly

successful Orange Line busway, has federal approval of a Very

Small Start Grant to implement bus lanes on Wilshire Blvd, and

that the MTA Board has recently directed staff to conduct a

countywide transit study to identify a minimum of five

additional bus lane candidate projects. Additionally, we have

been operating dedicated bus service for some time on the El

Monte Busway and on the Harbor Transitway.

Comment noted. The text has 

has few existing bus lanes, bu

Orange Line, Harbor Transitw

Additional candidate corridor

future RTP cycles.

094‐04 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

The Transit Policies on page 50 and the SCS chapter make

reference to High Quality Transit Opportunity Areas (HQTAs).

We would encourage SCAG to identify in the Draft 2012 RTP the

specific areas that will be designated as HQTAs and the benefit

of this designation.

Comment noted. Appendix: S

identifies specific areas that a

geographic areas within a hal

planned major transit stop or 

frequency of service interval 

morning and afternoon peak 

projects proposed in these ar

relief if they meet a number o

094‐05 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

On page 66, in the paragraph on “Logistics activities – including

warehouse and distribution facilities”, we would suggest adding

that warehouses and distribution centers also perform value‐

added services to prepare goods for retail sale, such as

packaging and adding of accessories. These services also create

jobs for the SCAG region.

Comment noted. Warehousin

provide value‐added services

mobility for regional resident

“Continued Expansion of War

bullet point. The point is also 

Goods Movement Appendix t

recognition of the impact of v

the regional warehousing and 

final 2012 RTP.

094‐06 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

On page 67, in the section “Components of the Regional Goods

Movement System”, we would encourage SCAG to add rail

intermodal facilities (ICTF, Hobart, etc.) as a separate bullet

point for two reasons. First, they play a significant role in the

goods movement system, while also generating traffic and

environmental impacts. Second, they are mentioned as a

component of the rail improvement strategy (ICTF and SCIG are

specifically mentioned).

Comment noted. SCAG has in

facilities.

094‐07 Lori Abrishami Los Angeles

County

On page 71, it should clarify in the text that even though the

specific alignment has yet to be determined, the east‐west

Comment noted.
250

ID Name Affiliation Comment Re

MetropolitanTransportationAuthority

freight corridor would generally parallel the UP Los Angeles

subdivision/SR‐60 between the I‐710 and I‐605, San Jose

Creek/SR‐60 between the I‐605 and SR‐57, and the SR‐60 east of

the SR‐57.

094‐08 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

On page 71, the text states the benefits of an east‐west

corridor, but SCAG may also want to state why this corridor was

selected over the 210, 91, and 10 using information contained

in the Comprehensive Goods Movement Study.

Comment noted. Staff will ad

per your comment.

094‐09 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

On page 71, SCAG may want to highlight that the east‐west

freight corridor is envisioned to be a clean freight corridor

similar to that which would be built on the I‐710.

Comment noted. The introdu

Corridor is titled “Regional Cl

notes that the EWFC would “

introduction and adoption of 

emissions technologies”. How

additional language to clarify 

Corridor is expected to be a c

The zero‐emission concept fo

more clearly explained in the 

including a discussion in the g

section regarding near‐ and lo

technologies that may be con

zero‐emission freight corrido

094‐10 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

On page 72, we suggest that the bottleneck relief strategy

report should be included in the technical appendix and

footnoted in the “Bottleneck Relief Strategy” section. On page

72, SCAG may want to add another paragraph on smaller‐scale,

near‐term goods movement improvements, such as truck

climbing lanes on the I‐5 and arterial improvements throughout

the region.

Comment noted. SCAG includ

improvements, such as truck 

arterial improvements throug

Project List.

094‐11 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

On page 74, under Key Rail Projects in the Draft 2012 RTP, we

encourage SCAG to highlight the ACE San Gabriel Trench, as it is

the largest and most significant ACE grade separation project

($498 million).

Comment noted. These grade 

in the 2012 RTP Project List. 

Goods Movement Appendix.

094‐12 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

We concur that the Orangeline High‐Speed Transit corridor

improvement from Union Station to Palmdale is in the Strategic

(unfunded) portion of the Draft 2012 RTP/SCS.

On page 207 of the main RTP/SCS document, in the last

paragraph, that refers to America Fast Forward, please add "and

14 highway projects" in the third sentence after the phrase "to

Comment noted. We have ad

requested and have modified 

provided by MTA regarding A
251

ID Name Affiliation Comment Re

build 12 key mass transit projects".

094‐13 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

a) We suggest that SCAG add a definition of the acronym

“LOSSAN”. b) To clarify which draft CA HSR Business Plan is

being referred to, SCAG may want to add the 2012 date. c)

SCAG may want to indicate that the CA HSR is estimated to

reach our region with the Initial Operating Segment (IOS) in

2021, and the Bay to Basin phase in 2026. Furthermore, it

should be clarified in other locations in the document that the

IOS will connect to southern California’s network in 2021. d)

Since the actual speeds for the system will vary by location,

SCAG may want to remove the reference to the definition of

110 mph for the CA HSR system. e) On page 51, subsection

“Implementation of Phase 1 of the California High‐Speed Train

(HST) Project”, SCAG may want to define which “Authority” is

being discussed. f) We request that SCAG clarify that Prop. 1A

will allocate $9.95 billion in funding for the project (the current

Draft reads almost $1 billion less: “$9 billion”). g) We suggest

that SCAG state that the $950 million in funding needs to be

allocated by the State. Furthermore, a Memorandum of

Understanding is anticipated between the CAHSRA and

southern California agencies to identify funds for the region for

advance investment in high speed rail corridors and

connections. h) On page 52, we suggest that SCAG provide a

definition or description of “grade closures”. i) We suggest a

source of where the LOSSAN strategies are from, to provide

clarity. j) Starting at the bottom of page 52, in the section

“Improvements to the Existing Metrolink System”, we note that

positive train control is not a “strategy”, it is mandated by

Federal law. SCAG may want to add that Metrolink will

incorporate this developing technology two to three years

ahead of the rest of the nation’s passenger railroads. k) The

term “speed capacity improvements” needs to be clarified:

either it is a “speed improvement” or a “capacity

improvement”. l) The second paragraph on page 53 suggests

that Metorlink will be connected in 2035 when the HST reaches

the Central Valley. We suggest rewording the paragraph to be in

accordance with Metrolink’s operational area and the California

High Speed Rail Authority’s Business Plan. m) Furthermore, the

final sentence in this paragraph implies that it is known what

would be needed for travel times of one hour. This is under

Comment noted. Comments 

page 51, with a more detailed 

the Passenger Rail Appendix. 

CA HSR Business Plan indicate

Sylmar until 2034. D.) The de

rail refers to the FRA definitio

Authority is defined in the pre

G.)Comment noted. The MO

Appendix. H.) Text changed to 

LOSSAN strategies are from t

Implementation Plan effort, a

noted. K.) “Speed capacity im

and service improvements”. L
252

ID Name Affiliation Comment Re

study regarding the feasibility for Metrolink operations. We ask

that SCAG state that there may be significant costs and impacts

of such an option.

094‐14 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

It appears that all strategic projects from the Supplement #1

Strategic Plan to the 2009 LRTP were added, but the original

strategic projects from the 2009 LRTP were not added.

Comment noted. We have ad

requested and have modified 

provided by MTA regarding A

094‐15 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

In the Transportation Safety Appendix, we suggest using the

term "people [or persons] with disabilities" for describing

members of the public for whom the Americans with Disabilities

Act applies.

Comment noted. Recommen

Transportation Safety Append

094‐16 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

The SCS Background Technical Appendix should include the

methodology for calculating GHG emission reductions

associated with the RTP/SCS alternatives, including assumptions

and discussion of off‐modeling analysis. The SCS Background

Technical Appendix should provide some discussion of the

relative benefit of various transportation and land use strategies

toward reducing regonal greenhouse gas emissions. For

example, how much of the reduction is attributable to the VMT

fee, TDM measures, TSM measures, etc. Moving forward, this

information would be useful for cities and other agencies

seeking to reduce GHGs in local Climate Action Plans and

transportation planning efforts.

Comment noted. Additional i

calculation of GHG emission r

Final RTP. SCAG is evaluating 

strategies and will make this 

completion.

094‐17 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

In the Aviation and Ground Access Technical Appendix: on page

126, Table 4‐8, under the Exposition Light Rail Phase II, the

description currently reads that it will "connect" to the

Exposition Light Rail Phase I, and it should be corrected to say

that it will "extend the Exposition Light Rail Phase I"; and, the

same Table 4‐8 should include the Slauson Light Rail: Crenshaw

Corridor to Metro Blue Line Slauson Station (RTP# 1120003)

because it provides additional access to LAX.

Comment noted. The Airport 

Aviation Technical Appendice

been updated to include this 

Light Rail Line and the Slauso

Metro Blue Line Station.

094‐18 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

On pages 7, 95 and 100, we request that SCAG replace the word

"tunnel" with "transportation improvement options".

Per the 2009 Metro Long‐Ran

updated the language to read 

(alignment TBD)".

094‐19 Lori Abrishami Los Angeles Project List Appendix: On page 27, delete description for the Comment noted. The Project 
253

ID Name Affiliation Comment Re

CountyMetropolitanTransportationAuthority

13th entry and replace with, "Route 710: Study to evaluate

transportation improvement options and prepare alternatives

analyses, engineering and environmental studies" (EA#187901

and PPNO#2215). On page 162, delete the description for the

fifth entry and replace it with, "Route 710: Study to evaluate

transportation improvement options and prepare alternatives

analysis, engineering and environmental studies" (EA#187901

and PPNO#2215). On page 163, in the first entry, delete the

description and replace it with, "Develop transportation

improvement options". On page 430, the fifth entry, delete the

alternatives to the SR‐710 tunnel option and replace it with,

"SR‐710 transportation improvement options". On page 432,

the sixth entry, delete the description and replace it with, "SR‐

710 transportation improvement options".

Highways and Arterials Appendix: On page 3, the first entry

under Toll Lanes heading, delete the description and replace it

with "Develop transportation improvement options".

environmental studies is the 

Federal Transportation Impro

description changes must be 

FTIP database update process

Metro Long‐Range Transport

710 Gap Closure” have been 

(tunnel) (alignment TBD)”.

094‐20 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

Passenger Rail Appendix: a) Page 1, reference is made to Amtrak

service. It should be stated that all Amtrak service other than

the Pacific Surfliner are intercity and long distance routes that

connect LA County and adjoining counties with destinations

throughout California and the US. Also, the Antelope Valley Line

is part of the LOSSAN Corridor between Burbank Junction and

LA Union Station. b) The Passenger Rail document should

eliminate reference to Maglev and the SCAG HSRT as this

creates confusion and appears to indicate that the technology

and proposed corridor are still under consideration. As written,

it appears as if the Maglev technology and the CA High Speed

Rail program are in competition with each other. It is unclear

why this is heavily covered in this document when the

conclusion is that the project is no longer planned. c) The vision

for rail service in the So. Cal. region should provide a stronger

emphasis on intermodal linkages at the three regional airports

that will be physically or temporally linked to the CA High Speed

Rail. These airports include Palmdale, Bob Hope and Ontario.

Each of these airports already has passenger rail accessibility,

but this will be strengthened as a result of current planning and

system development efforts. d) The document should amplify

on the role of regional rail integration and service/operating

improvements in meeting regional greenhouse gas reduction

Comment noted. Comments 

incorporate this comment. B.

the SCAG HSRT Maglev projec

of SCAG’s high‐speed rail plan

to show it is no longer consid

Speed Rail Subcommittee vot

RTP/SCS, as reflected later in 

Discussions of intermodal link

the appendix, but also in Cha

D.)Comment noted. E.)Comm

is included in “The Strategic P

Speed Rail” section beginning 

G.)Comment noted. This com

Agreements” beginning on pa

Antelope Valley Line Study is 

The other projects are include

project list. I.)Comment noted

the Grapevine alignment aga

K.)Comment noted. The Auth

appendix.
254

ID Name Affiliation Comment Re

and vehicle miles traveled/vehicle trip reduction goals. Further,

the document should identify the passenger rail station areas as

candidate locations for land use intensification that address the

regional jobs/housing imbalances. e) The discussion of the

statewide HST system and what it means for So. Cal. is

fragmented. There should be a clearer definition of the

technology, routes, and what it means for regional connectivity.

f) The document should make clearer the desired effect of the

Early Infrastructure Investment initiative both to develop the

way for HSR and to incrementally upgrade existing

infrastructure to support higher speed, more efficient and safer

passenger rail service linking the region to the HSR system. This

could include reference to the use of shared corridors and

shared corridor/shared track scenarios that will help improve

existing passenger service and enhance service integration

across the region. (continued)

094‐21 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

(continued) g) The discussion of the Pacific Surfliner should refer

to the recent efforts to develop the business plan for the

corridor and the addressing of short term improvements, also

include the efforts to create synergy in the corridor and to move

towards local governance. The discussion should include the

advantages of this. h) The discussion of Metrolink should

include capital studies in LA County that are underway.

Specifically: Antelope Valley Line Study ‐ this is a comprehensive

study of the Antelope Valley Line for capital improvements and

enhancements to overall safety. The study will address capacity

and travel time issues, grade crossing upgrades and grade

separations. The proposed improvements will be modeled and

from that a prioritization and funding strategy will be developed

for implementation of the improvements. CP Raymer to CP

Bernson Double Track ‐ this is Preliminary Engineering and

Environmental work (PE/NEPA) to double track this segment of

the Ventura Line. This project will complete the double tracking

of the LOSSAN Corridor from Chatsworth to Orange County.

Metro received an ARRA grant for this work and is partnering

with Metrolink to complete it. Metro is pursuing funding for

construction. Van Nuys Station ‐ this station on the LOSSAN

Corridor is used by Amtrak and Metrolink. It is a single platform

station that is an operational bottleneck in the system. Metro

received an ARRA grant to perform PE/NEPA work for a second

Comment noted. The Final RT

these comments.
255

ID Name Affiliation Comment Re

platform at this station. Strategic Studies ‐ Metro is moving

forward with strategic studies of other Metrolink lines in LA

County. Metro will be working with the other member agencies

on shared lines to develop overall strategic priorities. i) On page

15, regarding the discussion of decision points after

construction of the Initial Construction Segment, there will not

be a decision to continue the project. That will be an ongoing

discussion prior to that. Prior to the completion of that segment

there will be discussion regarding proceeding north or south.

The document should not discuss decision points for the

system. This will be an ongoing process for CHSRA and will be

based on business models and funding opportunities. Also, on

this page the various stages should use the term "extend"

rather than "build". (continued)

094‐22 Lori Abrishami Los Angeles

CountyMetropolitanTransportationAuthority

(continued) j) Note that the CHSRA has decided to move

forward with a Palmdale station and not move forward with the

I‐5/Grapevine alternative. This should be mentioned and the

discussion should include what this means for the Palmdale

area. k) Page 17 refers to the "Authority's draft 2011 Business

Plan". This may be the California High Speed Rail Authority but it

is noted within the Metrolink discussion and can confuse the

reader. We suggest stating the specific Authority involved.

Comment noted.

095‐01 Avital Shavit Los Angeles

CountyMetropolitanTransportationAuthority

Metro would like to request modifications to the TCM Timely

Implementation Report that we have submitted to SCAG staff

via e‐mail on 2/14/2012

Comment noted. Appropriate 

Final 2012 RTP TCM Timely Im

096‐01 Herman

Cheng

Los Angeles

CountyMetropolitanTransportationAuthority

LACMTA is commenting on the "Project List" appendix. We

would like to request modifications to the project list that we

have submitted to SCAG staff through the standard FTIP

database update process. Major project modifications include: ∙ 

LAF1197 ∙ LA0G451 ∙ LAF3114 ∙ LA0G406 ∙ LAF1136 ∙ LA0D441 ∙ 

LA0D442 ∙ LA0D465 ∙ LA0F010 ∙ LA0C8086 ∙ LA0D145 ∙ 

LA0D145B ∙ LA0D747 ∙ LA996347 ∙ LA0D399 ∙ LA0D450 ∙ 

LA0D480 ∙ LAF3434 ∙ LAF1455 ∙ LA990305 Major project

additions include: ∙ LA0G774 ∙ LAF5309 ∙ LAF5306 ∙ LAF5302 ∙ 

LA0G814 ∙ LAF5307 ∙ LAF5101 ∙ LAF5100 ∙ LAF5300 ∙ LAF5115 ∙ 

LAF5310 ∙ LAF5314 ∙ LAF5315 ∙ LAF5316 ∙ LA996345 ∙ LAF5305 ∙ 

LAF5301 ∙ LAF5129 ∙ LA0G726 ∙ LA0G754 ∙ LA0G755 ∙ LAF5303 ∙ 

LAF1343 ∙ LA0G830 ∙ LA0G598

Comment noted. We have ad

to the project list as submitte

commissions through the 201
256

ID Name Affiliation Comment Re

097‐01 Diego Alvarez Los Angeles

World Airports

Use of Airport Funds: LAWA's first priority is to maintain safe

and efficient airports. Our revenues and expenditures are used

to support that effort and fulfill our commitment to supporting

the national airspace system. All airports have a tremendous

demand for capital improvements. As such, most airports

depend on financial support from the FAA via grant funds for

eligible construction and noise mitigation projects. In return for

federal grant monies, the FAA includes grant assurances that

limit use of airport revenue solely for aviation‐related uses on

airport property. Using airport funds for non‐airport functions

violates federal law and jeopardizes the airport's ability to

receive federal grants. Nevertheless, LAWA seeks to partner

with SCAG to find solutions to support ground access

improvements to airports, other primary transportation

facilities, and "secondary" airports in the region.

Comment noted. SCAG recog

currently places strict limitati

for off‐airport purposes. To a

adopted regional aviation pol

that allows for more flexible u

airport ground access project

operators, and this policy con

2012 RTP/SCS. SCAG welcome

coordination with LAWA in de

regional airport ground acces

097‐02 Diego Alvarez Los Angeles

World Airports

Use of Airport Express Buses: The RTP includes an "Action Step"

which would plan and promote a regional system of airport

express buses, modeled in part on the Fly Away service

currently operating at LAX. LAWA agrees that express buses are

a promising solution to certain ground access problems.

However, it has been LAWA's experience that express buses are

most effective at airports with high passenger demand and in

cities with concentrated populations of passengers and

employees. Even then, high fares or significant subsidies have

been required to maintain an effective level of service. LAWA

has spent a great deal of resources carefully studying the

feasibility of establishing new FlyAway routes to serve LAX.

However, even for LAX, with its extensive market area and

passenger base, it has been a challenge to find station locations

that are both viable and successful. LAWA invites SCAG to

continue examining ways to bring similar projects to other

airports, but cautions that these services, by themselves, may

not be effective in increasing passenger demand at "secondary"

airports.

Comment noted. We agree th

effective at airports with high 

in the Airport Ground Access 

Aviation Technical Appendice

airports other than LAX are n

impact on future regional air 

looks forward to working with 

viable new “FlyAways,” and r

constraints at LAWA‐operate

Regional Transportation Plan

097‐03 Diego Alvarez Los Angeles

World Airports

Aviation Activity Constraints: LAWA agrees that the aviation

activity constraints in the region, and potentially dispersion of

that activity at other airports, should be re‐examined in

subsequent regional plans.

Comment noted. SCAG looks 

re‐examining aviation activity 

airports for SCAG’s next (2016

097‐04 Diego Alvarez Los Angeles

World Airports

Additional Technical Clarifications: LAWA also wants to offer the

following technical clarifications to the RTP: SCAG has reported

Comment noted. The vehicle 

Master Plan EIR/EIS were not 
257

ID Name Affiliation Comment Re

a number of vehicle trips to LAX under existing conditions as

well as under a future forecast for 2035, citing the LAX Master

Plan EIR/EIS as a justification for those trip numbers. However,

the numbers reported do not correspond to data that LAWA has

previously reported or used in any environmental analysis.

LAWA requests clarification of those data points. LAWA

recommends the following changes to Table 4‐6 and 4‐7 in the

Aviation and Airport Ground Access sections of the RTP. In Table

4‐6, the following projects should be included in the list of

projects completed since the project notice of preparation in

2008 (footnote 1): Douglas St., La Cienega Blvd., Lincoln Blvd.

(all), Nash St., Sepulveda Blvd. (both), the I‐105 westbound off

ramp at Sepulveda Blvd., and the I‐405 at SR‐90. Two other

projects on Table 4‐6, Arbor Vitae St., and the I‐405 from I‐10 to

SR‐101, are under construction as of January 2012. In Table 4‐7,

Project LAX‐19, which includes Lincoln Blvd. Improvements, has

already been completed. LAWA recommends that SCAG include

in the RTP a portion of the project referred to as LAX‐10,

widening Aviation Blvd. from Century Blvd. to Manhattan Beach

Blvd. to 3 lanes in each direction.

RTP/SCS Airport Ground Acce

prepared for different years (

the report, and were general

traffic volumes rather than da

trips shown in the Airport Gro

estimated using data and fact

variety of sources, including t

2006 LAX air passenger surve

Aviation Cooperative Researc

Research Program. In genera

plan was used to approximate 

airport that was applied to th

project future traffic volumes

Access Report will be clarified 

Comment noted. The Airport 

Aviation Technical Appendice

been revised to incorporate t

ground access projects listed 

097‐05 Diego Alvarez Los Angeles

World Airports

2011 Air Passenger Survey: Lastly, the 2006 LAX Air Passenger

Survey was used to create several data points within this section

of the RTP. LAWA is hoping to unveil the results of its 2011 Air

Passenger Survey in February of this year. SCAG should consider

updating its Appendix with this new data as it finalizes the RTP.

LAWA will post the results of this survey on our website once

the report is completed.

Comment noted. Due to time 

unable to incorporate data fr

LAX Air Passenger Survey into 

in the Aviation Technical App

However, this new data will b

this report.

098‐01 Dan Fairbanks March Joint

PowersAuthority

Exhibit 4.18, Land Use Pattern Riverside County (2035) identifies

a "High Quality Transit Opportunity Area" located along

Alessandro Blvd in proximity to I‐215, within the City of

Riverside, City of Moreno Valley, unincorporated Riverside

County and March Joint Powers Authority. The concentration of

high density residential and/or high density commercial uses

along portions of the Alessandro corridor would conflict with

the airport Accident Potential Zones as defined in the 2005

March Air Reserve Base Air Installation Compatibility Use Zone

(AICUZ) study, and further conflict with the recommended

airport compatibility provisions identified in the draft Joint Land

Use study currently undergoing environmental review by the

Riverside County Airport Land Use Commission. While transit is

Comment noted. We agree th

use densities that lie within a

and/or conflict with airport la

and standards should be anal

impacted airports and approp

Commissions.
258

ID Name Affiliation Comment Re

encouraged by these plans, the proposed increase in

densities/intensities in this area of high noise and airport safety

concerns necessitates detailed analysis, best performed by the

Riverside County Airport Land Use Commission and March Air

Reserve Base.

099‐01 Marnie

Primmer

Mobility 21 Mobility 21, Southern California’s transportation advocacy

coalition, respectfully submits these comments as part of the

ongoing efforts of Southern California Association of

Governments (SCAG) to produce a comprehensive 2012

Regional Transportation Plan (RTP). Mobility 21, being

comprised of both business and government entities is uniquely

positioned to provide insight into the RTP process. We

recognize SCAG staff’s diligence in crafting an RTP that will meet

the requirements of the federal process and of the newly‐

required SB375 legislation. Mobility 21 also appreciates the

open process and intensive outreach SCAG has undertaken

during the development of the 2012 RTP. Nevertheless, we

share these ideas regarding the RTP as currently laid out and

thoughts on reforming the RTP process for future success. First

and foremost, our goal is to assist SCAG with ensuring the final

adopted RTP is both comprehensive and defensible, provides

flexibility to the county transportation agencies responsible for

delivering projects under the program, and supports a strong

private sector economic engine. We have five recommendations

to provide to SCAG at this time:

Comment noted. See respons

comments.

099‐02 Marnie

Primmer

Mobility 21 Protect Locally‐Approved Sales Tax Measures: The program of

projects submitted to SCAG by the county transportation

commissions consist in part of projects promised to voters as

part of locally‐approved sales tax measures. Mobility 21

reminds SCAG that these projects individually and together

constitute a contract with the taxpayers that must be respected

and implemented as voters approved. Local taxpayers have

prioritized the distribution of funds in their respective sales tax

measures to a complete, multi‐modal program of projects to

meet local needs. Changes cannot and should not be made

without taxpayer approval. The RTP should strengthen and

enhance the ability of the counties to deliver these projects,

while at the same time supporting their efforts to deliver non‐

sales tax projects that will provide greater mobility, congestion

relief, and air quality benefits. The RTP needs to bolster the

Comment noted. The RTP inc

measures and their associate

county transportation commi
259

ID Name Affiliation Comment Re

efforts of local transportation agencies, and the business

community that supports them, to protect this essential

covenant with voters and taxpayers. Failure to do so will make

approval of future funding measures nearly impossible.

099‐03 Marnie

Primmer

Mobility 21 Thorough Economic Analysis: As yet, the impact of the

elimination of redevelopment agencies is unknown in terms of

the delivery of transportation projects. Some business groups

have also expressed concern over the feasibility of several of

the proposed financial options and mitigations included in the

RTP. Mobility 21 strongly urges SCAG to incorporate a thorough

economic analysis into the development and approval of the

RTP so that all elements of the final approved plan support the

economic growth of this region.

Comment noted. Economic a

updated to provide a more co

benefits and impacts of the 2

099‐04 Marnie

Primmer

Mobility 21 Locally Sensitive Context: This RTP is the first of its kind. SCAG

has done a yeoman’s job of working to produce Sustainable

Community Strategies, housing analysis and transportation

projections in the RTP. However, Mobility 21 remains concerned

that intensifying development in the urban core may impact

future housing availability, choices and affordability.

Recommendations regarding land‐use should take into account

the region’s disparate communities, geographies, market forces,

and take a flexible approach to protect the diversity of the

region.

Comment noted. The land us

through more than two years 

governments, demographers

stakeholders. A robust enviro

completed and is included in 

Appendix.SCAG has shown a commitme

region through its Environme

observed in data from the 20

Community Survey (ACS) in a

developments (TODs) are inc

evaluate and monitor this inf

economy is recovering. SCAG 

for gentrification. We look fo

environmental justice and pu

strategies to prevent displace

household figures by income 

period are provided to each l

required housing by type, inc

can be addressed through loc

which will be due 18 months 

(around October 2013).

099‐05 Marnie

Primmer

Mobility 21 Protect Region’s Economic Competitiveness: A large share of

our regional economy is dependent upon the flow of goods

from our ports, through the counties and to the rest of our

nation. Infrastructure improvements related to goods

movement are vital for Southern California to remain

Comment noted. Strategies id

intended to ensure the contin

regional goods movement act

air quality, environmental, an

worked very closely with regi
260

ID Name Affiliation Comment Re

economically competitive. As other options become available

both nationally and globally for cargo movement, Mobility 21 is

concerned that components of the RTP could put the region at a

disadvantage, such as implementing new technologies before

they are feasible or imposing fees on businesses operating in

the SCAG region. New revenue sources should be developed

and implemented at the federal level, not the local and regional

level.

potential solutions to achieve 

the strategies articulated in t

region appropriate and feasib

improve its current advantag

responsible manner. The RTP 

implementation of local, regio

Ensuring that the SCAG regio

an economic disadvantage w

the development of all fundin

Further, considerable analyse

over the course of the last se

global logistics supply chain a

diversion. We have learned th

imposition of fees as well as f

could impact cargo growth an

SCAG’s proposed freight and 

the 2012 RTP carefully take in

099‐06 Marnie

Primmer

Mobility 21 Reform the Process: Mobility 21 recognizes that federal and

state transportation planning processes are imperfect and that

SCAG must work within the proscriptive requirements of

existing laws and regulations. We therefore propose to identify

systemic weaknesses in the process and work to reform the

flaws in the RTP process that consume substantial resources,

but add little or no value. Our intent is to help reduce the time

and cost expended on the process and to remove regulatory

hurdles that inhibit the development and delivery of effective,

efficient, and timely transportation projects and services.

Specifically, Mobility 21 encourages changes in state legislation

that would enable MPO’s to use low and no‐cost alternatives to

reach out to the public in lieu of resource‐heavy public

meetings. Additionally, since 83% of the funding for projects in

the RTP comes from non‐federal sources, Mobility 21 believes

that empowering the federal government to veto a locally

approved financially constrained RTP unnecessarily jeopardizes

federal funding needed to complete projects. Mobility 21

therefore will seek modifications to federal legislation that

would enable MPO’s with over 75% local funding to self‐certify

that an RTP is financially constrained. Again, Mobility 21

applauds SCAG for the open and transparent process used to

develop the 2012 RTP. We look forward to working with SCAG

Comment noted.
261

ID Name Affiliation Comment Re

staff in the final stages of RTP implementation to ensure the

strongest possible document is delivered to the Regional

Council in April.

100‐01 Beth Steckler Move LA We congratulate the leadership and staff of the Southern

California Association of Governments and its Regional Council

members on the agency’s first‐ever Sustainable Communities

Strategy and Regional Transportation Plan that meets the 2020

and exceeds the 2035 greenhouse gas reduction targets,

achieves Clean Air Act conformity, and reduces vehicle miles

traveled and traffic congestion— despite projected population

growth of about four million residents by 2035.

We applaud SCAG staff for their leadership and for their

collaboration with local governments, county transportation

commissions and a wide range of non‐governmental

organizations. This effort was particularly challenging given it is

the first time anyone in the region has put together an SCS. In

the spirit of creating a stronger RTP/SCS this year and in future

years we offer these recommendations.

Comment noted.

100‐02 Beth Steckler Move LA 1. Ensure adequate funding to carry out the RTP/SCS. We

applaud SCAG’s goal of bringing all roads to a “state of good

repair,” and understand the policy decision to look for new

revenue sources rather than to eliminate transportation

projects in order to address the RTP’s projected $200 billion

shortfall. We understand that it may be more politically

palatable for the Regional Council at this time to project

reliance upon expanded federal sources, such as indexed gas tax

or a transition to an equivalent VMT fee, but that does not

make it more achievable.

Comment noted.

100‐03 Beth Steckler Move LA a. Emphasis should be on more achievable revenue sources

such as local voter approved fees or taxes rather than more

speculative federal sources

The recent history of voter response to county‐based

transportation funding measures in the SCAG region suggests a

more promising local direction. The experience with Measure R

in LA County and the recent extension of sales tax measures in

other SCAG counties demonstrates to us that regional voters

are not as tax‐averse as some believe, especially when voting on

measures to fund well defined local transportation investment,

if they have confidence in the agencies and are clear about

investment priorities. Voters in Los Angeles County approved

Comment noted.The projecte

user fee beginning in 2025 an

gas excises taxes when comb

forecast for state and federal 

than the historical average in

transportation revenues sour

Rather than simply assume a 

growth rate, which is consiste

detailed specific steps necess

transportation revenue sourc

recommendations from two n

by Congress through SAFETEA
262

ID Name Affiliation Comment Re

sales tax measures by 54% in 1980, 50.4% in 1990, and 67.8% in

2008. This suggests an increased willingness, not reluctance, to

support transportation investments by LA County voters. In San

Bernardino, Riverside and Orange sales tax extensions were

easily approved: Riverside voters approved Measure A in 2002

with 69% of the vote; San Bernardino County approved

Measure I in 2004 with 80% of the vote; and Orange County

approved a sales tax extension in 2006 with almost 70% of the

vote. In each case the original sales taxes had been originally

approved with narrow majorities.The point is that, with the exception of Ventura County, voters

throughout the SCAG region have consistently voted to approve

new or extended sales tax measures for transportation

improvements by substantial and increasing majorities in excess

of 2/3. If a county or the region needs more funds for

transportation investments, local voters seem a more promising

opportunity of first resort than a contentious State Legislature

or the Congress.We urge SCAG to work to challenge its member transportation

commissions to go to voters in the near future for local and

regional funding solutions instead of “punting” this problem of a

regional funding shortfall to the federal government. In other

words, let’s make the funding of regional planning more

achievable, and thus more real.

future cannot be known with 

therefore made reasonable a

through SCAG’s Technical Adv

Committees and documented 

transparency. As we gain mo

options, we will update the fi

amendments and/or subsequ

At a minimum, an RTP is prep

years.

100‐04 Beth Steckler Move LA b. Recommendation: Develop regional revenue sources to fund

regional projects.There are a number of transportation systems that are vital to

the welfare of the Southern California region as a whole, rather

than specific counties. This includes the 450‐plus‐mile regional

commuter rail system operated by Metrolink and the regional

goods movement system. Region‐wide investments in each of

these systems could yield enormous economic, environmental,

and equity benefits. We urge SCAG and its Regional Council to

consider taking a truly regional approach to an investment

strategy for each of these regional systems by including in the

RTP projected additional revenue from a region wide revenue

source.We recommend a broad‐based uniform regional tax or fee

increase, such as a 1/8 – 1/4 cent increase in sales tax or

equivalent parcel tax, that can raise between $15‐ $30 billion

Comment noted.
263

ID Name Affiliation Comment Re

over the 25 year life of the plan to invest specifically in regional

transportation needs such as meeting the needs of our goods

movement infrastructure, modernizing and electrifying the

regional commuter rail system, providing expanded BRT and bus

service as well as first‐mile‐last‐mile bike‐pedestrian

infrastructure that would connect to that regional commuter

system.We would pledge to work with you to build support for such a

funding measure.

100‐05 Beth Steckler Move LA c. Recommendation: Develop strategies to provide adequate

funding to modernize freight transportation projects.

The goods movement industry is a vital component to the

Southern California economy but is also a major reason for our

poor air quality and various health impacts affecting the region.

Developing and investing in both the zero and near‐zero

emission goods movement technology and the operational

efficacy of the goods movement infrastructure would

significantly benefit the region and the many communities of

concern that are directly affected by emissions and congestion

from transportation and rail activity. Estimates of the regional

investment needed could be up to $25 billion over the life of the

plan.Ensuring that funding mechanisms are in place to expedite the

implementation of the zero and near‐zero emission freight and

truck strategies as well as the infrastructure needed for

operational efficacy should be a central component of the

regional strategy.

For these reasons, we recommend that SCAG include the

following strategies: Develop a clear assessment of funding

options available, including various models of public‐private

partnerships that could make zero‐emission and near‐zero

emission freight technology options possible and ensure an

efficient goods movement system in the region. Recommend

pursuing legislation seeking a $30 per twenty‐foot container fee

for moving either into or out of the ports. This strategy could

generate as much as $441 million in revenue from loaded

containers in its first full year of implementation, when applied

equally to imports and exports and more in subsequent years as

cargo activity grows at our ports. Such a program could

generate over $10 billion over the life of the plan.1 Previous

Comment noted.
264

ID Name Affiliation Comment Re

legislative efforts have created a broad coalition to support this

measure. Such legislation has been approved twice by both

houses of the state legislature only to be vetoed by the previous

governor. As previously stated, we recommend a broad‐based

uniform regional tax or fee increase, such as a 1/8 – 1/4 cent

increase in sales tax or equivalent parcel tax that could raise

between $15‐ $30 billion over the 25 year life of the plan to

invest specifically in regional transportation needs such as

goods movement infrastructure needs, as well as modernizing

and electrifying the regional commuter rail system and related

infrastructure. Prioritize spending on projects that deliver

maximum health benefits for residents of the region. Include

public health as an overarching priority and goal in the $2.1

billion annual freight program included in the Environment and

Public Works Committee.

100‐06 Beth Steckler Move LA d. Support national efforts to create a strategic plan for the

freight system. Encourage SCAG to include language that

clarifies the current federal funding restraints and alter the RTP

to reflect that these revenues are assumed but not assured and

are contingent upon passage of the MAP‐21 program on page

95 and 100. As a revenue source the inclusion of this funding is

still in doubt as the current iteration of the House American

Energy and Infrastructure Jobs Act does not include a national

freight program or any dedicated freight funding. The

establishment of this program is contingent upon a freight

program making its way into the final federal transportation

reauthorization and that legislation passing through both

Chambers. Actively support the passage of a federal freight

program that would deliver these revenues and clearly establish

improving public health on the freight network and adjacent

communities as an overarching priority and goal of the federal

freight program. Support the inclusion of Senator Lautenberg’s

Freight Act of 2011 in the final federal transportation

reauthorization with the competitive grant program and the

goals and objectives as written.

Comment noted. SCAG, in co

partners, continues to activel

freight program. We also reco

known with certainty and we 

assumptions, which were vet

Advisory Committee and Poli

the Draft RTP to ensure trans

into future funding options, w

accordingly through amendm

as appropriate. At a minimum

every four years.

100‐07 Beth Steckler Move LA Champion increased Compass Blueprint funding to help local

governments update their general plans to implement the SCS.

While the RTP/SCS shows a significant shift in household growth

toward HQTAs, this will in most cases require changes in

General Plans and community plans — and ensuring that this

Comment noted. Through the 

SCAG has worked and provide

separate jurisdictions includin

profits, and transportation ag

applications will focus on loca
265

ID Name Affiliation Comment Re

will happen is likely to require incentives and other resources.

SCAG’s Compass Blueprint program was successful in helping

many communities move in the direction of smart growth and

urban infill years before SB 375. With additional funding, the

Compass Blueprint Demonstration Project Program could fund

the SCS implementation and ensure that growth happens in an

equitable way with minimal displacement, in addition to

updating plans. SCAG should also work with the other MPOs to

advocate for a statewide “infill first” package of incentives to

promote development near transit. SCAG should also consider

working with the CTCs to find sources of funding for land use

planning in HQTAs.

strategies, and will prioritize 

Transit Areas (HQTA). In addit

funding agencies have begun 

principles into their discretion

continue to pursue dedicated 

worthy voluntary program.

100‐08 Beth Steckler Move LA Expand proposed funding for transit, Metrolink, bus rapid

transit, bicycling, and pedestrian travel into the RTP constrained

plan.We need increased investment for bus and rail transit, bicycle

and pedestrian systems. This is especially true in the Inland

Empire where over‐dependence on a spreading highway

infrastructure and dispersed land use pattern has made

residents in these counties very vulnerable to just the kind of

economic calamity witnessed in the 2008 – 2012 Great

Recession.In addition, residents of agricultural areas, especially in the

eastern Coachella Valley, the North Shore of the Salton Sea and

similar communities, remain disproportionately underserved by

transit, which makes it very difficult for residents without a car

to access health care, groceries, or good jobs. Improvements to

bus headways, especially in these areas, could create new

HQTAs.Building transit infrastructure is one of the best ways to create

good, “green” jobs that enhance the health and wealth of the

region and its residents. Construction work can provide a career

path to middle‐income jobs through apprenticeship programs

that provide young workers with formal training. Agencies that

adopt project labor agreements and requirements ensuring that

jobs will go to local workers — and/or those who live in areas

with high unemployment — help make the local economy more

robust because workers’ earnings will be spent at local

businesses, creating additional jobs and local tax revenues.

Comment noted. Project #71

represent $3.0 billion in addit

service over the life of the pla

availability referred to in the 

do not reflect the 2035 plan.

100‐09 Beth Steckler Move LA Move enhanced Metrolink investments into the Constrained Comment noted. Commuter a
266

ID Name Affiliation Comment Re

Plan.The Metrolink commuter rail system is a regional gem that

could become a major source of VMT reduction, congestion

relief and economic development. It links many communities in

every county in the region.

We recommend moving into the Final Plan (the Constrained

Plan) the upgrading of the Metrolink commuter rail system

region‐wide to make a planned transition to an all‐electric

system capable of providing zero‐emission high‐speed service

(up to 110 mph) and enabling expanded express service in

select corridors with double tracking, grade separations and

other modifications needed. Such an upgrade may cost the

region as much as $8 to $10 billion, but would be well worth the

investment in terms of congestion relief, emission reductions

and economic opportunity created. This RTP Constrained Plan

enhancement could be funded by new resources, such as the

regional sales tax proposed above.

Specifically, we want to highlight opportunities for enhanced

investments on several key lines that we believe will create

exceptional regional connectivity. The Antelope Valley Line,

which is the focus of current planning efforts to dramatically

reduce the time it takes to travel over 76 miles from Lancaster

to Union Station by more than fifty percent ‐ from nearly two‐

hours to about one‐hour. The San Bernardino Line’s success

with limited express service from downtown San Bernardino to

Union Station indicate express service on a regular basis is

possible, especially if a direct link into Ontario Airport is created.

The Ventura County Line and the Orange County Line present

the possibility of a continuous, high speed, electric express

system from Ventura to Union Station to Orange County to San

Diego. LA Union Station Run‐Through Tracks project would

significantly enhance regional trip potential of all Metrolink

corridors serving Union Station by improving efficiency and

throughput capacity. We recommend additional corridor

infrastructure enhancements and improvements in Appendix A.

Each of these Metrolink corridors and projects, if funded and

enhanced, will create opportunities for new BRT and enhanced

bus service, as well as smart growth infill with first‐mile‐last‐

mile bicycle and pedestrian infrastructure in multiple

communities and will create enhanced access to the jobs

investments total $51.8 billio

investments total $55.0 billio

figures commuter and passen

transit ridership. The commu

laid out in the 2012 RTP/SCS 

development strategies in the 

corridors, that will be refined 

Improvement Plan and the An

Improvement Strategic Plan s

#7001210 includes early actio

improvements along these co

improvements outlined in thi

Station Run Through Tracks, m

Memorandum of Understand

process evolves. The electrific

will be a discussion that occu

RTP/SCS. These discussions w

passenger carriers, freight ca

Speed Rail Authority. The 201

prefigure these discussions, n

analysis process as to how all 

operate in shared use corrido
267

ID Name Affiliation Comment Re

corridors throughout the region.

100‐10 Beth Steckler Move LA Expand Bus Rapid Transit and provide more frequent bus

service on high‐performing routes linked to Metrolink to give

more people alternatives to driving alone.

Well over 80 percent of transit ridership in the region now uses

bus service. While our rail transit system is expanding

dramatically, we should expect that heavy reliance on bus

service is likely to continue as far out as 2035.

However, while there is a lot of growth projected for the Inland

Empire, much of it will not be near existing or planned bus or

rail service. For example, in Riverside County, about 40% of

residents live near bus lines with some service (15‐30 minute

headways) but presently only 10 percent of the population is

served by high‐quality transit (with 15‐minute headways). By

expanding the Bus Rapid Transit (BRT) system in the Inland

Empire, especially where proposed lines would connect with the

potentially enhanced Metrolink lines and by bringing up service

on select higher performing lines to 15‐ minute headways we

could increase high‐quality transit at a much lower cost.

Our recommendations in Appendix A are limited to

improvements to investment in Bus Rapid Transit infrastructure

(BRT) and enhanced bus service with connections to the

Metrolink Regional Rail network or regional airports. Each of

these Metrolink corridors and projects, if enhanced, will create

opportunities for new smart growth infill and TOD investment in

multiple communities. These corridors could be served as well

as by first‐mile‐last‐mile bicycle and pedestrian infrastructure

opportunities, and will help create enhanced access to jobs

throughout the region.See Appendix A below.

Comment noted. Project #71

represent $3.0 billion in addit

service over the life of the pla

availability referred to in the 

do not reflect the 2035 plan.

100‐11 Beth Steckler Move LA c. Increase funding for active transportation to at least $12

billion for bicycling and pedestrian improvements. SCAG has

received an outpouring of support for increased investment in

bicycle and pedestrian infrastructure and projects at workshops

and hearings across the region, as well from members of SCAG’s

Regional Council. As was often repeated at the hearings,

according to the 2009 National Household Travel Survey of

California, 14 percent of all trips in the region are pedestrian

while 6 percent are on bikes, and 25 percent of all roadway

injuries and fatalities affect pedestrians and bicyclists, yet only 1

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate
268

ID Name Affiliation Comment Re

percent of the regional investment is identified as going to non‐

motorized modes. A poll of Southern California voters

sponsored by Move LA, NRDC and the American Lung

Association late last year found that voters would make bicycle

and pedestrian investments a much higher priority.

While we applaud the SCAG staff for recommending that

funding for active transportation be increased from $1.8 billion

to $6 billion, we believe funding should be at least $12 billion.

We believe investments should prioritize first‐mile/last‐mile

connections to transit stations, which will help support the

increased investment in the transit system. Investments should

also be prioritized for areas of disproportionate high injury and

fatality rates and in areas with lower car ownership rates.

Safe Routes to School strategies and investments to improve

the safety of students as they walk and bike to school should

also be promoted because statewide cuts in school

transportation budgets make getting to and from school more

difficult for K‐12 kids — especially in rural areas where there are

no sidewalks or safe bike routes.

We recommend SCAG work with the CTCs to identify funding

sources that are flexible and that could be used to prioritize

accelerated transit, bike, pedestrian and other traffic‐reducing

projects. It is our judgment that one appropriate source of

funding for this program could be the regional sales (or parcel)

tax we have suggested earlier.

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

100‐12 Beth Steckler Move LA d. Encourage CTCs and local jurisdictions to adopt “complete

streets” policies. We believe that SCAG should encourage CTCs

and local jurisdictions each to adopt a complete streets policy

so that bike and pedestrian improvements can be made

routinely and more economically when streets are improved or

built. For example, counties in the SCAG region, especially

outside of LA County, often include funding for arterial capacity

enhancements for streets which largely run between and

through community centers. These stretches of boulevards

seem very good opportunities for implementation of “Complete

Streets” programs. We recommend that SCAG identify such

opportunities and call them out for special programming

efforts.

Comment noted. SCAG is com

jurisdictions in the developm

maintenance of local active tr

the adoption of Complete Str

100‐13 Beth Steckler Move LA e. Work with CTCs to develop a methodology for quantifying the

unmet need for bicycle and pedestrian investments to improve

Comment noted. SCAG is com

jurisdictions in the developm
269

ID Name Affiliation Comment Re

safety and increase active transportation. SCAG should work

with the CTCs to develop a methodology for quantifying the

unmet needs, particularly safety needs, for cyclists and walkers.

Because concerns about safety may discourage people from

walking and biking entirely, surveys may be required, especially

in rural areas, to accurately assess the needs of residents. We

recommend that SCAG work with the CTCs to develop active

transportation budgets and to identify existing and potential

local and regional funding sources. One idea, for example,

would be to create guidance that would be used to allocate

funding in each CTC’s Call for Projects.

maintenance of local active tr

work with the CTCs and local 

methodology to quantify the 

users.

100‐14 Beth Steckler Move LA f. Work with CTCs to ensure full participation of all counties in

the funding and implementation of regionally significant transit

and goods movements systems that achieve regional objectives

like cleaner air, reduced greenhouse gases, expanded access to

high quality transit, and mode shift away from driving alone.

SCAG should encourage county transportation commissions to

place a higher priority on investment in transit services and

active transportation projects and seek to ensure a fair share

investment in these projects among counties either by

identifying new revenues locally, shifting funds out of other

programmed projects, or participating in the creation of

regional revenue sources, and encouraging infill development

strategies that keep our momentum toward a higher regional

sustainability strong.

Comment noted. The distribu

transportation investments in 

tax measure commitments ap

transportation commission ad

plans, limitations associated w

other previous commitments

additional investments in tran

will consider your request in d

100‐15 Beth Steckler Move LA 3. Create a tighter link between transit and land use throughout

the region.The draft SCS takes into account changes underway in the

regional real estate market including the shift in new housing

development away from the construction of single family

homes on large lots and toward the development of multifamily

housing ‐‐ apartments, townhomes and condominiums ‐‐ in

more urban environments with easier access to jobs, service

and transit systems. The fact that half of all new homes and new

jobs will be located near transit under the plan will be a boon to

the region’s efficiency, economy and sustainability.

The demographic and real estate trends, more transit

opportunities and healthier, active lifestyles, portend a new,

and better, version of the American Dream in Southern

California. By focusing development in transit areas and

Comment noted.
270

ID Name Affiliation Comment Re

downtowns, the draft SCS plan would consume 408 square

miles less “greenfield” land than in the 2035 Baseline, which

assumes current land use trends.

100‐16 Beth Steckler Move LA a. SCAG should identify to local jurisdictions adjustments in land

use policy that would ensure each county is contributing its fair

share to meeting regional goals of cleaner air, reduced

greenhouse gas emissions, expanded access to high quality

transit, and mode shift away from driving alone.

Although the region as a whole will achieve reductions in

vehicle miles traveled sufficient to meet the targets for reducing

greenhouse gas emissions, the reductions are not evenly

distributed across the region. These outcomes are the result of

both past decisions and future actions reflected in this draft SCS

and RTP. The maps in the RTP/SCS suggest that in some areas,

especially Riverside County, significant growth is projected in

areas with little or no transit investment.

Comment noted. SCAG curren

for monitoring implementatio

scale. Those include periodic 

local profiles, Performance M

Program, periodic household 

update. SCAG will consider fu

program for the RTP/SCS in co

SCAG promotes not only tran

transit‐ready developments, 

the region.

100‐17 Beth Steckler Move LA b. Limit High Quality Transit Areas, especially along freeways in

low‐density areas, to within a 1/2 mile of the stop with frequent

services, as opposed to including the entire corridor. It is

unclear how SCAG defines high‐quality transit areas. Under SB

375, a HQTA is a place that has bus service with headways of 15

minutes or less during commute hours. Several freeway

corridors are designated as HQTAs presumably because they

have express bus service. But, there is not currently frequent

bus service along the I‐10 east of I‐215, I‐15 north of I‐10, I‐15

south of the 61, and the 33 (Ventura County) which are all

designated as HQTAs. Only the area within 1⁄2 mile of the stop

should be regarded as an HQTA.

Comment noted. “California P

“high quality transit corridor” 

service with service intervals 

peak commute hours, or, as p

Code Section 21064.3, a “maj

an existing rail transit station

bus or rail transit service, or t

major bus routes with a frequ

minutes or less during the mo

periods. SCAG has a statutory 

definitions. Transit services in 

have been identified in a serie

express bus service with head

during the peak commute ho

challenge the statutory defin

100‐18 Beth Steckler Move LA Include a snapshot of the current jobs‐housing fit and develop a

methodology for projecting the jobs‐housing fit as a result of

transportation investments and land use changes for the 2016

RTP/SCS.The current mismatch between the location of jobs and housing

is at the root of our transportation problems. SCAG should set a

baseline for a jobs‐housing fit by taking a “snap shot” of 4‐to‐5‐

mile buffer zones around major job centers, and then

comparing the wages provided by those jobs to cost of housing

Comment noted. After Plan a

with our stakeholders to iden

analyzing and monitoring key 
271

ID Name Affiliation Comment Re

within the buffer zone to see if there is a good fit. UC‐Davis and

the Sacramento Council of Governments have developed a

relatively simple methodology to do a jobs‐housing fit, and are

now developing a tool to project the jobs‐housing fit into the

future. Continuing to monitor the jobs/housing fit over

successive RTP/SCSs will be an important tool for transportation

planning in rural, urban and suburban areas.

100‐19 Beth Steckler Move LA Strengthen Conservation Planning Policy

We commend SCAG for including an advanced mitigation

strategy for land conservation. This strategy is an important

step forward. We recommend the following changes to

strengthen the Conservation Planning Policy section:

§ change “critical habitat” to important natural lands because of

its limitation to the federal designation and its relationship to

endangered and threatened species;

§ create an inclusive process for agencies, conservancies, and

non‐profits to help map and prioritize priority conservation

lands;§ include all unprotected undeveloped lands in the inventory of

potential mitigation location sites instead of limiting

opportunities to just Natural Communities Conservation Plan

and Habitat Conservation Plan areas;

§ expand the conservation activities to include existing and/or

future programs instead of simply already‐established

programs; and

§ Advocate for the advanced mitigation policy to result in the

environment ending up better than it started as opposed to no

gain (a net environmental benefit) from the standpoint of

natural resource lands after construction activities.

Comment noted. The propose

pursue a strategic planning p

resources. The intent is to inc

based on input from a wide v

has been clarified. It is SCAG’

determine the best conservat

appropriate public input and 

permitting agencies.

100‐20 Beth Steckler Move LA 4. Take greater measures to reduce greenhouse gases and other

emissions from freight.

We are deeply concerned that the projected increase in freight

volumes and traffic will undermine the gains of the RTP in other

areas. In particular, CO2 emissions from trucks would increase

at least 30% by 2023 and at least 60% by 2035. Even more

dramatically, CO2 emissions from rail would increase at least

50% by 2023 and at least 123% by 2035. To mitigate goods

movement related emissions, we recommend that SCAG take

the necessary steps to:

a. Ensure the ports augment the Clean Air Action Plan by

Comment noted. SCAG recog

major source of emissions tha

pollution problems that can h

such, SCAG’s recent goods mo

focused on integrating enviro

the 2012 RTP Goods Moveme

that goods movement is a ma

emissions that contribute to g

efforts to facilitate clean good

of near‐zero and zero emissio

contribute to GHG reduction 
272

ID Name Affiliation Comment Re

creating GHG reduction plans.

b. Devise a set of strategies that account for the differences

among local freight service and that of port origin/destination.

Similarly, the sector of medium duty trucks may be targeted for

technology improvements, given that it is the sector’s 2nd

largest emitter of NOx.

c. SCAG should identify and promote a sequence of projects

that maximizes on‐dock rail and that reduces constraints on the

expansion of on‐dock capacity in advance of projects that

expand off‐dock capacity. Without appropriate sequencing,

efficiencies could be lost.

d. Clean up existing freight corridors, not just the proposed new

projects.

While we welcome zero emission technology by the year 2035,

more short term gains should be implemented. SCAG should

further analyze what can be done until a majority of truck traffic

is zero or near zero emissions and consider using currently

available technology while working to demonstrate future

technology applications (such as maglev technology).

movement environmental str

of a wide range of technology 

available and/or under develo

consider the application of th

various goods movement ma

domestic trade, local, etc.). F

in the text of the RTP regardin

including demonstration proj

100‐21 Beth Steckler Move LA Improve public health monitoring and benefits, especially in

environmental justice communities.

We applaud SCAG for adopting a number of performance

“outcomes” — in particular, those measuring public health and

affordability — that will be monitored during RTP/SCS plan

implementation. We believe that these additional performance

metrics should be reported to the Regional Council as a way to

help encourage implementation of the RTP/SCS. While we

understand that SCAG has no authority over local land use or

county transportation planning and funding, we do believe that

it’s critical that SCAG find ways to incentivize RTP/SCS

implementation.

Comment noted. The perform

2012‐2035 RTP/SCS has been 

participation and input from 

as collaboration with other la

example, to facilitate the dial

performance measures for th

Performance Measures Subco

2011. The Subcommittee me

from various stakeholders an

the Plans and Programs Tech

further discussions prior to fo

Committees.As a result of the input proce

performance measures have 

including new categories such 

performance measures are al

on their intended uses: one fo

other for on‐going monitoring

will continue investigating ad

updates.

100‐22 Beth Steckler Move LA Evaluate the impact by geography of RTP/SCS investments on Comment noted. In previous 
273

ID Name Affiliation Comment Re

environmental justice communities by increasing monitoring

over successive RTP/SCSs.

The disparate impacts of transportation investments and land

use planning — especially noise and pollution — on lower‐

income communities is lost in the county‐wide or region‐wide

averaging that SCAG uses. It would also be informative if SCAG

monitored a number of geographic areas where environmental

justice populations are overrepresented. The Metropolitan

Transportation Commission in the Bay Area, for example, does

“snapshot” analyses of 44 geographic communities to focus on

key transportation‐related indicators such as transit service

frequency, walkability, access to essential destinations by a 30‐

minute transit trip, housing and transportation affordability,

bike and pedestrian collisions, diesel PM2.5 emissions, etc. For

example, the EJ appendix reports that air quality will be worse

for 23‐29% of the population with no indication of where they

live, making it difficult to design and evaluate the effectiveness

of mitigation measures.

SCAG is planning to track characteristics in 125 transit stations.

We recommend instead that SCAG analyze 125 places where

environmental justice populations are overrepresented. The

analysis could be used to monitor progress over successive

RTP/SCSs, and goals could be set and strategies identified to

reduce disparate impacts. Where there are disparities, SCAG

should propose mitigations and work with the CTCs to improve

conditions.Because the EJ analysis also suggests that low‐income people

are being displaced from station areas, we also recommend that

rail and possibly BRT stations be monitored for the impacts of

gentrification — by checking income levels, housing costs,

transit usage and car ownership, etc. SCAG could also develop a

toolbox of policies, implementation measures and funding

sources that could be used to help low‐income people continue

to live near stations.

(RTP) as well as for this Plan, 

concerns are identified, prese

Environmental Justice Appen

and suggestion into considera

and establish a region wide m

selected environmental justic

concern.While the EJ analysis in the D

with emissions increases, this 

improvements in vehicle tech

corridors. These corridors in 

and near‐zero emission vehic

improvements had been acco

would show no hot spots asso

emissions and exposure analy

is abundantly conservative an

scenario outcomes. Even in t

after accounting for vehicle te

no reliable way to conclude h

communities. Neither the av

distribution of households an

level of geography to show w

100‐23 Beth Steckler Move LA Improve the discussion around performance outcomes and

alternatives analyses.One of the best ways that SCAG can do this is to help make the

outcomes of land use planning and transportation investment

choices clearer to Regional Council members and the general

public — through reporting on performance outcomes. While

Comment noted.
274

ID Name Affiliation Comment Re

the Alternatives 1, 2, 3 & 4 presented at the summer workshops

illustrated the impacts of particular policy choices, the

Alternatives A, B, C & D were different in ways that were hard to

understand. We recommend that in the next RTP/SCS, SCAG

should give stakeholders more time and more information to

evaluate the different scenarios. We also recommend that SCAG

set targets for performance measures and outcomes, and to

evaluate the scenarios against these targets early and

continuously in the planning process.

100‐24 Beth Steckler Move LA Develop new tools for measuring health & equity impacts in

future RTP/SCSs.

We also believe that SCAG should develop new tools for

measuring health and equity impacts in future RTP/SCSs. In

particular: SCAG should enhance efforts to measure the daily

amounts of walking and biking related to work and non‐work

trips. SCAG should also measure chronic disease rate changes

based on transportation decisions and resulting physical activity

(based on the work of Neil Maizlish of the California

Department of Public Health’s work with the MTC in the Bay

Area and ongoing work with MPOs across the state). SCAG will

monitor premature mortality due to PM2.5, which is important

since the region contributes 53 percent of premature deaths in

the state of California due to PM2.5. We recommend SCAG

report improvements every two years, and develop a more

precise goal in collaboration with the LA County Department of

Public Health and the American Lung Association in California.

SCAG should monitor asthma incidence and exacerbations due

to NOx (an emission that is being measured) in collaboration

with the California Department of Public Health, the South

Coast Air Quality Management District, academic institutions,

and others who are focusing on communities most impacted by

air pollution, as well as communities located near high volume

roadways.

Comment noted. Comments 

current planning and research 

Sustainability Tool (ST) by ref

environment, and through co

following areas (1) health out

bike accidents and injuries, (3

Ozone) and air quality (disper

& gas), (5) water usage, (6) w

loads ‐ TMDL), (7) Vehicle Mil

accessibility, (8) various envir

pollutant information availab

Protection Agency’s Toxics Re

information is obtained, staff 

modeling analysis to link the 

determinants (road, freeway, 

buildings, design, fast food an

open space, walk/bike ways) 

listed above. SCAG staff has o

Angeles County Department o

and electricity consumption d

for certain localities. We antic

collaborations and technical e

various policy areas with the 

recommended approaches in 

the use of the tool.

101‐01 Beth Steckler Move LA I want to talk about three things that are really important that

can use some serious study and hopefully revision before the

final plan is presented to the Regional Council. • High Quality

Transit Area – these are areas that are defined in State law as

being places where during commute hours we have bus service

with at least four every hour or fifteen minute headways.

Comment noted. Daily train s

the Strategic Plan of the RTP, 

Coachella Valley from the Inla

Plan.
275

ID Name Affiliation Comment Re

Looking at the general maps in the Appendix, I see areas where I

can’t find bus service. They tend to be the areas that extend

along a high quality transit area that goes along the 10 Freeway

out to Palm Springs and I think a lot of us would like to get to

Palm Springs on transit and it’s really hard to do. Amtrak only

runs three days a week and it’s usually not on time. Let’s say if

the Amtrak service were to increase, since it only stops three

places between L.A. and Palm Springs, we should be looking at

the half mile radius around those stations rather than taking in

the entire corridor because for those people just because a train

goes by them it does not mean that they have access to high

quality transit. Increasing the bus service in a lot of areas would

be a way to create a high quality transit area. We need to have

a lot of them because the assertion is that fifty percent of our

new homes, our growing population, and our growing jobs will

be in these high quality transit areas.

101‐02 Beth Steckler Move LA • Jobs Housing Fit – SCAG has done a lot of work in this and it’s

not an easy field, particularly with the demise of the CRA but I

would propose that the jobs housing mismatch that we have in

this region is one of major underlying causes of our air pollution

and our traffic congestion. SCAG has described various things

but has put no programs in. The local cities and counties need

help solving this problem. A lot of it is about affordability.

Getting on handle on where the mismatch is and what we can

start doing to correct it is important. At UC Davis they have a

very simple methodology that can be done with this RTP, which

is to look at our job centers and take a 4‐5 mile buffer around

them. Check our currently, not projecting, what are the wages

and how much does the housing cost. We will see for example

in the Westside that the housing is really expensive. We want to

work with SCAG to figure out how this concept of jobs housing

fit really becomes something that we’re working to solve just

like we are working to solve the traffic problems and the air

quality problems.

Comment noted. During impl

continue to work with our sta

metrics for analyzing and mo

outcomes.

101‐03 Beth Steckler Move LA • Environmental Justice Analysis – This is greatly improved over

the last RTP, one of the things that could improve it further is in

the EJ analysis is a proposal that SCAG will monitor what is going

on at 125 transit station to see if we are really pushing poor

people out and things like that are going on. That sort of idea of

looking at a place, because most of the EJ analysis deals with

Comment noted. SCAG is con

based development/growth a

and safety indicators for futu
276

ID Name Affiliation Comment Re

population so we talk about all of the people who don’t have

cars, or don’t have high school educations, or don’t speak

English, or who are Seniors. To talk about those people as a

group across a region gives us one picture but to talk about

what’s happening in Wilmington along the 710 and whether the

RTP makes that better or worse is a completely different

picture. That’s part of the picture we need to understand, we

know that we have lower income populations living in the

places with the dirtiest air and the worst traffic. Coming down

to a kind of place based analysis within the EJ would really

strengthen it. SCAG is starting to get there with the 125 train

stations but it would really be strengthened if we also did it with

twenty three and twenty eight percent of the population is

going to have worse situations around some of the air pollution,

around some of the particulate matter and the carbon dioxide.

102‐01 James Camp NAIOP The funding for the RTP is also of great concern. Federal law

does require that the plans be fiscally constrained such that any

funding is available or reasonable expected to become

available. Yet, the draft RTP claims to be an approximate $524

billion program, but has a shortfall of $219 billion in revenues;

nearly half. There is a reference to about $127 billion of the

shortfall being reliant on major State and/or Federal actions,

which seem awfully speculative. NAIOP has a major concern

over the numerous references in the documents to pushing

local jurisdictions to adopt new fees or taxes. The

commercial/industrial development industry is already heavily

burdened with fees from many, many regulatory agencies and

jurisdictions. We often hear that some new fee is not that big,

or is for a great cause. Yet, the net effect is a mountain of "little

fees". Sort of a death by a thousand fees. To make up billions

and billions of revenue shortfall would necessitate extensive

new fees and taxes. This would clearly be a huge hindrance, if

not not paralyze, any type of economic recovery in the regions.

NAIOP did not see any type of analysis in the documents that

would lead one to believe such fee and tax increases are

reasonably possible, especially in light of Proposition 22, nor an

analysis of the economic impacts. Such analyses are needed

before any of the documents are finalized.

Comment noted. The project

based user fee and adjustmen

taxes when combined with th

and federal sources are less t

in state and federal transport

percent annually. Rather than 

the historical growth rate, wh

requirements, we detailed sp

state and federal transportat

with recommendations from 

established by Congress throu

economic impacts of the RTP 

Job Creation Analysis of 2012 

plan for the RTP does not req

jurisdictions adopt any new fe

102‐02 James Camp NAIOP [PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P
277

ID Name Affiliation Comment Re

103‐01 Adriano

Martinez

NaturalResourcesDefenseCouncil

On behalf of the Natural Resources Defense Council and the

Coalition for Clean Air, we write regarding the need for a near‐

term clean freight projects in the Regional Transportation Plan

(“RTP”). Specifically, we are concerned that there is not an

emphasis in the RTP on near term projects that will help the

region achieve its technology goals of creating a zero or near

zero emission freight movement system.

Comment noted. Further cla

text of the RTP as appropriate

103‐02 Adriano

Martinez

NaturalResourcesDefenseCouncil

Accordingly, we respectfully ask that the RTP be amended to

include short term projects in the constrained plan that will help

advance cleaner technologies in the short‐term.

Comment noted. Further clar

text of the RTP as appropriate

103‐03 Adriano

Martinez

NaturalResourcesDefenseCouncil

In the 2006 Clean Air Action Plan (“CAAP”), adopted

unanimously by both Boards of Harbor Commissioners for the

Ports of Los Angeles and Long Beach, the ports committed to

develop and implement a zero emissions container movement

system. In pertinent part, the Port boards declared that — This

component of the program is focused on finding the next

generation of transport solutions for goods movement. The

ultimate goal is a 21st century electric powered system that will

move cargo from our docks to the destinations within 200 miles

that today are moved by truck. It may take 20 years to complete

such a system but it will always be 20 years away unless in the

next five years we build and test a demonstration prototype and

perfect a detailed plan for widespread construction.

Comment noted. Cooment no

103‐04 Adriano

Martinez

NaturalResourcesDefenseCouncil

Here we are six years later, and we are no closer to actual

implementation of a zero emissions system.

Comment noted.

103‐05 Adriano

Martinez

NaturalResourcesDefenseCouncil

While there are a lot of discussions about these technologies,

there is an imperative need for SCAG to be leaders on this issue.

In that vein, SCAG needs to provide more support for this

concept in the near‐term.

Comment noted. Further clar

text of the RTP as appropriate

103‐06 Adriano

Martinez

NaturalResourcesDefenseCouncil

The RTP should be amended to include a project or projects that

will help spur technology. A catenary system along the Terminal

Island Freeway serving to connect the Port of Long Beach to the

Union Pacific Intermodal Container Transfer Facility (“ICTF”)

merits inclusion in the constrained portions in the plan.

Comment noted. Further clar

text of the RTP as appropriate

103‐07 Adriano

Martinez

NaturalResources

In the same vein, the RTP could also include other similar

projects, including a catenary system along Alameda Street in

Comment noted.
278

ID Name Affiliation Comment Re

DefenseCouncil

the harbor area.

103‐08 Adriano

Martinez

NaturalResourcesDefenseCouncil

At least one of these projects must be pushed forward in the

near‐term (e.g. next two years).

Comment noted.

103‐09 Adriano

Martinez

NaturalResourcesDefenseCouncil

The cost of such a system is estimated to be between 5 and 6

million dollars per mile on the high end.

Comment noted.

103‐10 Adriano

Martinez

NaturalResourcesDefenseCouncil

Furthermore, dollars should be allocated to procure trucks that

can use this system. Accordingly, we recommend an initial

allocation of 35 million for the entire project with the creation

of a plan to increase the percentage of trucks that use this

facility.

Comment noted.

103‐11 Adriano

Martinez

NaturalResourcesDefenseCouncil

Funding for this project could come from some combination of

the ports, agencies responsible for clean air locally and

statewide, and private industry.

Comment noted.

103‐12 Adriano

Martinez

NaturalResourcesDefenseCouncil

The key is to develop and implement the catenary system in the

short term to help progress in actually achieving zero emissions

goals.

Comment noted.

103‐13 Adriano

Martinez

NaturalResourcesDefenseCouncil

Finally, the catenary system should be incorporated as an

enforceable measure in the State Implementation Plan.

Comment noted.

103‐14 Adriano

Martinez

NaturalResourcesDefenseCouncil

This type of strategy provides an ideal Transportation Control

Measure. See 42 U.S.C. § 7408(f)(v), (vi); see also 42 U.S.C. §

7511A(e)(4).

Comment noted.

103‐15 Adriano

Martinez

NaturalResourcesDefenseCouncil

We would be delighted to collaborate with staff in determining

how these projects should be included in both the constrained

plan and the State Implementation Plan as an enforceable

measure to push progress towards a true zero emissions

system.

Comment noted.

104‐01 Amanda Eaken Natural

ResourcesDefense

I. Commit to the Creation of a Sustainable Transportation

Network While SCAG has received much praise for the land use

assumptions in its Sustainable Communities Strategy, it is

Comment noted. The 2012 RT

nexus between land use, tran

Much of the transit and active 
279

ID Name Affiliation Comment Re

Council unclear whether the transportation system has been adjusted

to support this land use pattern. While we recognize that SCAG

must use input from its six County Transportation Commissions

(CTCs) as the starting point for SB 375 scenario planning, we had

hoped that the evaluation process would not end there. The

problem, in our view, with the limited approach SCAG has

adopted is the inconsistency between the varied land use

projected across several scenarios and a transportation system

that has been kept relatively constant. Such an approach

ignores the evidence that land use patterns and transportation

systems are frequently mutually reinforcing. The walkable

compact development patterns SCAG calls for are less likely to

materialize without adjustments to its transportation network,

particularly in the Inland Empire. Similarly, compact land use

patterns need to be serviced with real transportation choices if

they are to be viable. We seek a commitment from SCAG,

through its next SCS process in four years, to evaluate scenarios

which consider what environmental achievements may be

possible with a transportation system that is more varied across

those scenarios.

in the plan will improve this n

SOV travel, and reducing VMT

104‐02 Amanda Eaken Natural

ResourcesDefenseCouncil

In particular, we find the emphasis on arterial widenings to be

of concern. SCAG’s EIR claims that it will spend $22 billion on

“local arterial improvements”. A review of the SCAG project list

indicates that by improve, the clear intent is to widen, or as

some engineers describe it, to “rationalize” the system.

Throughout the RTP project list, the verb widen is one of the

most commonly found. And yet, the empirical literature on

induced demand and induced growth makes clear that widening

roads does not solve traffic congestion, and, as a recent poll

demonstrates, the voters agreeii.iii The futility of attempting to

remedy congestion through arterial widening alone is perhaps

best elucidated in Riverside County, where, despite an

investment of more than six billion in arterial improvements,

the County’s residents can expect no marked improvement in

hours of delay. Instead, the County projects an increase in hours

of delay. While some of these arterial widenings may be

represented in sales tax measures, County Transportation

Commissions have significant latitude with respect to the

phasing and prioritization of investments in their regions.

Comment noted. It is importa

RTP/SCS investments, Riversi

experience a greater than fou

current conditions. The benef

RTP/SCS investments, includi

be discounted. Also, it is true 

authority over the phasing an

the RTP/SCS reflects the prior

commissions to SCAG.

104‐03 Amanda Eaken Natural Before continuing to our specific recommendations, we would Comment noted. We appreci
280

ID Name Affiliation Comment Re

ResourcesDefenseCouncil

like to note the absence of certain data which would have been

valuable in further scenario analysis. The transit and active

transport appendices of the plan contain a wealth of data,

categorized by county, concerning the current availability of

transit and active transportation elements. What is lacking,

however, are projections of how the current plan improves (or

does not, as the case may be) access to transit and active

transportation facilities for the residents of the various SCAG

counties by 2035. We have submitted a request for the data to

SCAG staff. We note that SCAG staff has been both helpful and

responsive, but, as we were informed by staff, the data could

not be made available in time for analysis in this comment

letter. Our recommendations for improving the transportation

network are as follows: 1. Accelerate funding for Metrolink to

provide badly needed regional commuting options The

Metrolink commuter rail system, which links numerous

communities in all SCAG area counties, is already a critical

component of SCAG’s transportation system, and, with

improvements, could become a major source of VMT reduction,

congestion relief and economic development. The Draft Plan

includes a Strategic Plan section with projects deemed

important by the region, but for which funding does not

currently exist. We strongly recommend moving the upgrading

of the Metrolink commuter rail system into the Constrained

Plan. The upgrade project would provide double tracking, grade

separations and other modifications where needed to enable

expanded express service, while making a planned transition to

an all‐electric system capable of providing zero‐emission high‐

speed service (up to 110 mph) in select corridors. Such an

upgrade could provide significant returns in the form of

congestion relief, emission reductions, and economic

opportunity created, as well as create enhanced opportunities

for transit‐oriented development.

requested data would have re

could not have been perform

public comment period. Rega

Metrolink, improvements to t

in the Constrained Plan, with 

in the Strategic Plan should a

available.

104‐04 Amanda Eaken Natural

ResourcesDefenseCouncil

2. Explore bus and bus rapid transit expansions to provide high

quality, cost‐effective transit to a majority of residents Eighty

percent of transit ridership in the region takes the form of bus

travel. Considering the long lead times involved with capital

expansion projects, expanded bus service may present the most

immediate and cost‐effective strategy to provide alternatives to

driving for millions of SCAG residents. And yet in Riverside

Comment noted. The Constra

increase in bus service freque

services in the region, includi
281

ID Name Affiliation Comment Re

County, projected to house another 1.1 million residents over

the life of the RTP (second only to Los Angeles County in growth

projections), only 10% of the population is currently served by

high quality bus service (less than 15 minute headways).

Currently 40% of residents have access to 15‐30 minute

headway service. SCAG should identify potential service

frequency upgrades which could provide a significantly higher

proportion of the population access to high quality transit

service. SCAG should identify strategic investments to increase

ridership in light of the new revenues which may be available

through the AB 32 cap and trade revenue. In fact, we would like

to urge SCAG’s Regional Council to adopt a policy commitment

that any new revenues received through the cap and trade

program be prioritized for efficient transit operations. The

public transportation literature indicates that for every 1

percent increase in transit service frequency, ridership increases

up to 0.5 percent and a similar increase in vehicle miles or

vehicle hours of service can increase ridership up to a range of

0.6 to 1% (Evans, 2004)iv. The highest‐performing lines could be

candidates for upgrade to Bus Rapid Transit, which could, in

turn, serve to anchor development along now low‐density

transportation corridors. SCAG and its CTCs should examine the

highest‐performing lines, and potentially recommend them for

upgrade to fixed guideway systems in this RTP.

104‐05 Amanda Eaken Natural

ResourcesDefenseCouncil

3. Commit funds for bicycling and walking commensurate to the

share of trips these modes accommodate SCAG has increased

bicycle and pedestrian funding from $1.8 billion to $6 billion in

this plan. While this is more than a 200% increase, for which

staff should be commended, it still accounts for just over 1% of

the plan’s total funds. This is hardly commensurate with the

20% of total trips taken on foot or by bike. The recent poll of

SCAG region voters conducted by NRDC, Move LA and ALAC

found that, by strong contrast, voters believe 14% of RTP funds

should go to making walking and biking safer. SCAG should

continue to examine the balance of funds which constitute the

$524 billion regional transportation plan, and investigate

whether there are ways to free up additional funding for these

most sustainable forms of transportation. For example, SCAG

proposes to spend $22 billion widening arterials in the six

county region. If some of these funds were instead directed to

Comment noted. The 2012‐2

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour
282

ID Name Affiliation Comment Re

ensuring that these roads are “complete streets” – safe for

walking and bicycling, the region would be taking real steps

towards encouraging sustainable transportation. SCAG should

encourage CTCs and local jurisdictions to adopt complete

streets policies so that bicycle and pedestrian improvements

can be made routinely and more economically when streets are

improved or built. Widening arterials will neither encourage

other modes nor solve traffic congestion. We believe

committing $6 billion to bicycle infrastructure and $6 billion to

pedestrian safety improvements is actually a very reasonable

request, and would still represent just 2.3% of total plan

revenues for these modes.

104‐06 Amanda Eaken Natural

ResourcesDefenseCouncil

4. Commit to collaborating with County Transportation

Commissions to Prioritize Projects which help to reduce VMT

and GHG Emissions While SCAG does not make final decisions

about transportation projects – its CTCs do—SCAG does play an

important role analyzing the social and environmental impacts

of alternative investment decisions. In its upcoming TIP process,

as well as the next SCS/RTP, we recommend that SCAG adopt a

process similar to the Bay Area Metropolitan Transportation

Commission’s to evaluate whether individual projects help to

achieve regional goalsv. In partnership with its County

Transportation Commissions, SCAG should engage in a project

performance analysis to determine whether its proposed

investments help the region achieve its intended outcomes of

improved air quality and health, location efficiency, improved

mobility for its residents and reduced household transportation

costs. Such an analysis assists decision makers in determining

which projects are consistent with SCS goals. The recently

conducted poll of Southern California voters found that voters

think building new roads and widening existing roads are by far

the least effective strategies to reduce congestion and improve

air quality. Instead, voters would rather see the region focus on

smarter land use and prioritize investments in transit, bicycle,

and pedestrian infrastructure. It is well known that SCAG is

facing a significant funding shortfall for this RTP and makes

some fairly ambitious assumptions about the availability of new

revenues. Perhaps a project performance assessment process

could help to encourage SCAG’s CTCs to adjust project priorities

to contribute to overall SCS goals1.

Comment noted. SCAG will co

transportation commissions a

refine performance measures 

possible, conduct project‐leve

appropriate and necessary.
283

ID Name Affiliation Comment Re

104‐07 Amanda Eaken Natural

ResourcesDefenseCouncil

II. The RTP Must Include More Detail on Making Clean Freight

Movement a Reality in the SCAG Region As the RTP highlights,

the movement of freight creates significant economic

productivity in the SCAG region, but these financial benefits

come at immense costs to the health and welfare of residents

throughout the region, including the primarily low income

communities of color nearest our freight hubs. Accordingly, any

work to expand the freight movement system must

concurrently push the cleanest technologies. In addition,

resources must be allocated to cleaning up the already

unacceptable high levels of pollution from the existing

infrastructure. There is consensus amongst all regulatory air

quality agencies that in order for the SCAG region to meet

federal and state clean air standards on time, it must shift the

freight movement system from a diesel‐dominated industry to anear zero or zero emissions systems. To turn the rhetoric of

moving to a cleaner freight system into a reality the RTP must

be modified to include more detail. In order to achieve the long‐

term, speculative projects of electric freight corridors on the I‐

710 and I‐60, we need short‐term projects. The notion was

eloquently put in the 2006 Clean Air Action Plan (“CAAP”),

adopted unanimously by both Boards of Harbor Commissioners

for the Ports of Los Angeles and Long Beach, in which the

commitment was made to the develop and implement a zero

emissions container movement system. In pertinent part it

reads: This component of the program is focused on finding the

next generation of transport solutions for goods movement. The

ultimate goal is a 21st century electric powered system that will

move cargo from our docks to the destinations within 200 miles

that today are moved by truck. It may (sic) take 20 years to

complete such a system, but it will always be 20 years away

unless in the next five years we build and test a demonstration

prototype and perfect a detailed plan for widespread

construction.vi This prototype project will serve as the path

towards actual achievement of the projects along the I‐710 and

I‐60. Other forward looking projects should also be included in

the RTP. A catenary system along the Terminal Island Freeway

serving to connect the Port of Long Beach to the Union Pacific

Intermodal Container Transfer Facility (“ICTF”) merits inclusion.

In the same vein, the RTP should also include a catenary system

Comment noted. SCAG has in

RTP/SCS as appropriate. Furth

included about near‐term dem
284

ID Name Affiliation Comment Re

along Alameda Street.

104‐08 Amanda Eaken Natural

ResourcesDefenseCouncil

These projects must be pushed forward in the near‐term (e.g.

next two years). Finally, the catenary system should be

incorporated as an enforceable measure in the State

Implementation Plan. This type of strategy provides an ideal

Transportation Control Measure. See 42 U.S.C. § 7408(f)(v), (vi);

see also 42 U.S.C. § 7511A(e)(4). We would be delighted to

collaborate with staff in determining how these projects should

be included in both the constrained plan and the State

Implementation Plan as enforceable measures to push progress

towards a true zero emissions system. 1 Given the recent

Association of Irritated Residents vs. Environmental Protection

Agency case, the region needs to adopt enforceable

Transportation Control Measures (TCMs). The measures

identified in this section and others are prime candidates for

inclusion in a list of TCMs.

Comment noted.

104‐09 Amanda Eaken Natural

ResourcesDefenseCouncil

III. Ensure Projects Meet a Robust Definition of SCS Consistency

in order to Qualify for SB 375 California Environmental Quality

Act Streamlining SCAG’s EIR sets too low a bar for compliance

with the SCS in order to achieve SB375’s contemplated CEQA.

Specifically, the EIR states that: “In other words, the SCS was

not developed with the intent that each project to be located

within any given TAZ must exactly equal the density and relative

use designations that are indicated by the SCS Development

Type in order for the project to be found consistent with the

SCS’s use designation, density, building intensity and applicable

policies. Instead, any given project, having satisfied all of the

statutory requirements of either a residential/mixed‐use project

or TPP as described above, may be deemed by the lead agency

to be consistent with the SCS so long as the project does not

prevent achieving the estimated average use designations,

densities and building intensities indicated by the Development

Type within the TAZ, assuming that the TAZ will be built‐out

under reasonable local planning and zoning assumptions.” We

are particularly concerned that the standard established by this

EIR‐‐specifically the meager requirement that a project merely

not prevent the achievement of a designated density for a

certain development type‐‐leaves it open to easy manipulation.

It would seem to be quite easy for an individual project, of

substantially lower density than that which is envisioned in the

Comment noted. The final RT

that lead agencies (including 

discretion and will be solely r

consistency of any future pro

provide a lead agency at the t

data and documentation to h

request.
285

ID Name Affiliation Comment Re

SCS, to justify its consistency with the SCS simply on the grounds

that higher density projects are imagined in the future. We

strongly recommend that SCAG adopt a more stringent

standard for consistency with the SCS in order to achieve the SB

375 CEQA benefits. At a minimum, we suggest the following

language as an alternate standard: so long as the project

promotes achieving the estimated average use designations,

densities and building intensities indicated by the Development

Type within the TAZ, assuming that the TAZ will be built‐out

under reasonable local planning and zoning assumptions.

104‐10 Amanda Eaken Natural

ResourcesDefenseCouncil

IV. Commit to increased Compass Blueprint funding to ensure

Local Governments have adequate resources to implement the

Sustainable Communities Strategy Working in close partnership

with its local jurisdictions, SCAG has identified a future growth

pattern which manages to save 400 square miles of open space

from development. This is a highly impressive accomplishment,

and it will take the sustained partnership of SCAG’s local

governments to follow through on the promise of this plan. To

recognize their critical role as essential partners in

implementation, SCAG should commit—in this plan—to an

increased funding level for the Compass Blueprint program.

SCAG may want to consider future revenues from the AB 32 cap

and trade program as a potential funding source for this

investment. Funds should be prioritized to local governments

who plan and zone for growth consistent with the SCS.

Comment noted. Through the 

SCAG has worked with and pr

to 94 separate jurisdictions in

profits, and transportation ag

applications will focus on loca

strategies, and will prioritize 

Transit Areas (HQTA). In addit

funding agencies have begun 

principles into their discretion

continue to pursue dedicated 

streams.

104‐11 Amanda Eaken Natural

ResourcesDefenseCouncil

Conformity We have reviewed SCAG’s conformity

demonstration for the 2012 RTP, and have identified the

conformity finding for PM 2.5 in the 2014 milestone year as

potentially problematic. According to the report, the PM 2.5

budget for that year is 35 tons, while estimated emissions are

calculated at 34.5 tons a difference of just one half ton.

(Transportation Conformity Report at p. 20.) This means that

the integrity of the conformity finding will be fatally

compromised by even small errors in future estimates of

emissions. There is an even chance that this half‐ton difference

is illusory. According to ARB’s June 20, 2011 revisions to the PM

2.5 transportation conformity budget, included with this letter,

the 35 ton 2014 PM 2.5 budget is rounded up to the nearest

ton.vii (See Table C‐3 at p. C‐10.) Because estimated emissions

for that year are 34.5 tons, there is a 50% chance that the

Comment noted. As required 

Board and stated in the Trans

16), the RTP emissions values 

same rounding convention us

any fraction rounded up to th

Transportation Conformity Re

transportation conformity, th

greater than the correspondi
286

ID Name Affiliation Comment Re

rounding error exceeds the difference between the 2014

budget and estimated emissions. Use of a “rounding up to the

nearest ton” method of establishing the emissions budgets,

when the difference between emissions and the budget is half a

ton, means that the conformity finding is random; there is a

50% chance that emissions exceed the budget. This is logically

indefensible and manifestly arbitrary and capricious. We believe

that the aforementioned improvements to the regional

transportation system work toward amelioration of this

problem. We also urge staff to commit to modeling alternative

transit scenarios in the next SCS/RTP process in order to fully

ascertain the potential environmental benefits.

104‐12 Amanda Eaken Natural

ResourcesDefenseCouncil

VI. Conclusion SCAG staff has taken significant strides with this

SCS to set the region on a more direct path to sustainability. In

particular, the land use pattern shows a substantial deviation

from years past in its attempt to provide opportunities for

Southern California residents to live in walkable communities

with affordable, convenient transportation options. We feel

more work is necessary to adjust the priorities in the

transportation system to ensure it is worthy of the ambitious

changes to the land use pattern SCAG envisions. We have been

honored to work so closely with your excellent staff through the

process of creating this plan, and we look forward to the critical

implementation phase in the years to come.

Comment noted.

105‐01 Bill Sherman NO 710 Action

Committee

Our group is a grassroots organization with members in

northeast area of Los Angeles and surrounding communities,

cities, neighborhood councils, and groups that have taken

official positions against the SR‐710 extension that represent

over 500 thousand people. At this time, we suggest and request

that SCAG remove from the RTP all line items associated with

expansion and extension of the SR‐710 freeway. It is

unreasonable to consider the 22 billion dollars from tolls, the

Fast Forward American Funding, and the PP Funding Method as

real possibility. The probabilities of these being available is very

precarious, this funding is more of a hope than a plan. We are

aware that there are significant differences between the traffic

modeling of SCAG and Metro. These differences need to be

resolved before the SCAG RTP can really be considered as a

valid study. I mentioned specifically the Light Truck Study, which

was performed in 2008, which concerned the truck traffic with

Comment noted. SCAG’s 2012 

constraint requirements set f

regulations and guidance, inc

strategies for ensuring availab

identified. See 23 CFR 450.32

in part, that the RTP includes 

demonstrating that projects i

using committed, available, o

sources. See 23 CFR 450.104. 

be funded by both core (Mea

available revenues. SCAG doc

sources identified for the SR‐

available. As such, strategies 

implementation steps for ens

new revenues are discussed i

Appendix. The SCAG regional 
287

ID Name Affiliation Comment Re

the proposed 2035 traffic analysis of the 710 tunnel. The Metro

RFP outlines a study area of 150 square miles to resolve the Gap

Closure issues and does not specifically speak of a mode, route,

or extension of the SR‐710. Your RTP is in conflict with the

EIR/EIS and undermines the entire on‐going process of both

SCAG and Metro. As a physician, I cannot leave without

commenting on health issue. Excellent studies from USC and

other well respected health institutions repeatedly have

identified the health risks of freeway and tunnels, these cannot

be mitigated. While jobs for LA workers are desirable, the

desertion of decreased air pollution and improved traffic

mobility is unproven. President Obama spoke specifically on this

issue in the State of the Union Address of last month, jobs do

not outweigh health. I was disappointed in the RTP in that it so

twentieth century. In a country that sent a man to the Moon,

can’t we find more innovative solutions to these same old

problems?

most current information and 

descriptions, growth forecast

a regional analysis and projec

CEQA/NEPA, corridor studies

different. SCAG recognizes th

analysis is underway. Upon th

selection of a preferred altern

with Metro to amend the RTP 

project description and assoc

106‐01 Multiple

Signers

No 710 Action

Committee

We urge SCAG policymakers to remove from the RTP all line

items associated with expanding and extending the 710

freeway, and remove from the RTP all items associated with

expanding and increasing existing infrastructure and technology

for goods movement in the region.

Comment noted.

106‐02 Multiple

Signers

No 710 Action

Committee

In addition, the No 710 Action Committee notes that SCAG must

move the proposed SR‐710 Extension Toll Tunnels from the

Constrained Plan to the Strategic Unfunded Plan in the 2012

RTP because there are no committed, available, or reasonably

available funds as required by federal law to include them in the

Constrained Plan.

Comment noted. SCAG’s 2012 

constraint requirements set f

regulations and guidance, inc

strategies for ensuring availab

identified. See 23 CFR 450.32

in part, that the RTP includes 

demonstrating that projects i

using committed, available, o

sources. See 23 CFR 450.104. 

be funded by both core (Mea

available revenues. SCAG doc

sources identified for the SR‐

available. As such, strategies 

implementation steps for ens

new revenues are discussed i

Appendix.

106‐03 Multiple

Signers

No 710 Action

Committee

We oppose SCAG RTP items associated with proposed SR‐710

Toll Tunnels because they will increase pollution, truck traffic,

Comment noted. The 2012 RT

multi‐modal plan that incorpo
288

ID Name Affiliation Comment Re

congestion, accidents, health impacts and environmental risks

in our communities and throughout the region. We oppose

related plan items which have the goals of increasing

conventional roadway and rail yard capacity for the same

reasons. The Programmatic Draft Environmental Report for the

Plan is inadequate, as is stated in an addendum to this letter.

These approaches are outdated, inefficient, and harmful to the

region. Better, zero‐emission proposals for goods movement

are available now – we should not wait another 20 years.

movement, and active transp

overall improved system perf

for a regional zero‐emission g

106‐04 Multiple

Signers

No 710 Action

Committee

Goods movement proposals in the Draft Plan are inconsistent

with regional, state, and federal air quality and congestion

targets stated in the plan. The plan states that to attain federal

ozone standards, the region will need broad deployment of zero

and near‐zero emission transportation technologies in the 2023

to 2035 timeframe (p.74). It also acknowledges that

conventional goods movement practices contribute to excess

ozone and poor air quality (p. 68), yet allocates billions of

dollars to expanding existing systems, with no requirement that

new technology be implemented.

Comment noted. Emissions fr

a significant concern for the S

proposed goods movement s

action plan focused on the de

technologies. Please refer to 

Environmental Strategy sectio

Appendix for further clarificat

not have the authority to ma

106‐05 Multiple

Signers

No 710 Action

Committee

The plan says that “truck‐only freight corridors are effective as

they add capacity in congested corridors, improve truck

operations and safety..and provide a platform for the

introduction and adoption of zero‐emission technologies.”

However, the plan does not require zero‐emission technology

(which truck operators will be reluctant to invest in because of

the added expense), assumes and accommodates more trucks

on the road en route to proposed freight corridors, and

allocates billions to construction of these corridors instead of

electrified rail freight movement projects which would eliminate

many trucks from inner‐city traffic altogether.

Comment noted. Emissions fr

a significant concern for the S

lane system identified in the 

facility used by zero‐emission 

support efforts by regional pa

movement emissions and imp

San Pedro Bay Ports Clean Air 

move all goods by rail, wheth

as existing modal segments g

For example, goods moving t

(e.g., Chicago, Dallas) may be 

Bay Ports to their final destin

from the Ports to local wareh

local stores, or across the inte

not be able to utilize rail as a 

increased travel time, first‐m

factors. The goods movemen

effectively rely on a single mo

106‐06 Multiple

Signers

No 710 Action

Committee

The plan acknowledges environmental justice legislation at the

federal and state level in detail and pledges SCAG’s compliance

with the spirit of these laws. It proposes to address freight

Comment noted. Your comm

however, maintains that SCIG 

initiative. We recognize that g
289

ID Name Affiliation Comment Re

movement and rail emissions‐related impacts, but it avoids

mention of significant and sustained community opposition to

the BNSF SCIG, which is on the Project List. The No 710 Action

Committee opposes the SCIG in solidarity with the Coalition for

a Safe Environment and other community groups that have

repeatedly presented their comments and concerns related to

environmental justice. These communities experience far higher

than average freight truck traffic and host undesirable

intermodal freight facilities. The resulting higher than average

health, quality of life, life expectancy and safety problems are

well documented. However, the existence of their concerns and

specific objections to the SCIG are completely ignored and not

mentioned in this Draft Plan or its appendix on Environmental

Justice. The No 710 Action Committee repeats that SCIG and

related Draft Plan components are part of an overall framework

which favors conventional goods movement activities that

cause significant pollution and negative impacts in neighboring

communities and throughout the region.

of emissions that contributes 

As such, SCAG’s recent goods 

have focused on integrating e

identified in the 2012 RTP Go

emphasize the need to deplo

and zero emissions) and inclu

with key regional stakeholder

106‐07 Multiple

Signers

No 710 Action

Committee

Job creation and retention goals in this Draft Plan represent

“mission creep” and tilt towards requiring more trucks, more

freeways, more traditional rail infrastructure, and more

conventional port transfer and loading. We oppose this

direction because it is part of a conceptual framework that

includes the proposed SR‐710 Toll Tunnels and the associated

negative impacts mentioned above: pollution, truck traffic,

congestion, accidents, health and environmental risks. The Port

Working Group, a community coalition, has noted that the SCIG

plan claims to add 400 permanent jobs, but existing businesses

at the proposed site provide more than 1,200 permanent jobs,

resulting in an overall reduction. Further, many of the

construction jobs are not permanent, and not guaranteed to be

awarded locally.

Comment noted. Considerab

that significant volumes of go

system by 2035. These goods 

significant economic benefits 

continues to work closely wit

mechanisms to support the c

activity while addressing the 

including air quality, environm

106‐08 Multiple

Signers

No 710 Action

Committee

The No 710 Action Committee urges regional mobilization

focusing on multi‐modal transit and goods movement projects

using electrified rail and zero emission technology. These will

also create jobs, but the approach is forward‐looking in terms of

job and skills training and future infrastructure needs. In

addition, more efficient, lower‐cost goods movement

technology will allow the Southern California region to attract

jobs and new investment, competing effectively with other

Comment noted. Emissions fr

a significant concern for the S

lane system identified in the 

facility used by zero‐emission 

all goods by rail, whether elec

existing modal segments gen

example, goods moving to dis

Chicago, Dallas) may be able 
290

ID Name Affiliation Comment Re

international and eastern seaboard ports’ expansion and

modernization.

Ports to their final destination

the Ports to local warehouses

stores, or across the internat

be able to utilize rail as a resu

increased travel time, first‐m

factors. The goods movemen

effectively rely on a single mo

106‐09 Multiple

Signers

No 710 Action

Committee

The plan refers to zero emission electrified rail technology as a

long‐term goal in sections of the report covering goods

movement, congestion, air quality, transportation investments,

and truck transport. It proposes a long‐term, bureaucratic

study. It does not acknowledge that specific patents, plans and

technologies are currently being proposed and discussed by

several parties. The Draft Plan indirectly and incorrectly implies

that such technology cannot be implemented on an accelerated

timetable. This is a matter of political will and private

investment, not feasibility. The No 710 Action Committee

objects to the Plan’s time‐delay in funding and implementing

zero emission strategies, because the near‐term alternatives

proposed in the Draft Plan include extension and expansion of

freeways (such as the 710) and traditional rail yards and goods

movement infrastructure which will result in added pollution,

truck traffic, congestion, accidents, health and environmental

risks in the region.

Comment noted. SCAG’s rece

an assessment of electrified r

suggest that additional evalua

address operational, reliabilit

other factors. SCAG has work

stakeholders and will continu

options for rail.

106‐10 Multiple

Signers

No 710 Action

Committee

We question the revenue projections in the Draft RTP. The

profitability of regional toll ways hasn’t been demonstrated, and

the exact uses of the proposed SR‐710 Toll Tunnels haven’t

been determined (car only, truck only, both?) yet the SCAG RTP

assumes a combined $22.3 billion in revenues for the tunnels

and other toll ways.

Comment noted. The RTP ass

toll facilities are restricted to 

debt service associated with c

and maintenance of those sa

any other facility, project or p

106‐11 Multiple

Signers

No 710 Action

Committee

On the expense side, funding should be reallocated. The billions

of dollars for freeway expansion, near‐term dedicated truck

lanes, the East‐West Corridor, and conventional rail yard / truck

loading should be spent on accelerated implementation of zero

emission electrified rail freight movement and other multi‐

modal and active transportation projects.

Comment noted. The distribu

transportation investments in 

tax measure commitments ap

transportation commission ad

plans, limitations associated w

other previous commitments

106‐12 Multiple

Signers

No 710 Action

Committee

The plan gives lip service to a modernized, zero emission freight

movement system from ports to electrified rail, but allocates no

funding for this important step that will dramatically reduce

truck traffic and congestion, improve air quality and

Comment noted. Further clar

demonstration initiatives hav

RTP.
291

ID Name Affiliation Comment Re

health/environmental impacts, and position this region as an

efficient, low‐cost, high‐tech goods movement magnet.

106‐13 Multiple

Signers

No 710 Action

Committee

The plan also admits that increased population, and a growing

aging population, will need alternative forms of transportation

as roads become more crowded in the region. More funding

should be directed proportionally to active transportation:

walking, biking, transit, and multi‐modal planning. The No 710

Action Committee proposes that the SCAG RTP allocate a share

of funding proportional to the anticipated users of and

established needs for active transportation to foster livable,

sustainable neighborhoods throughout the region and meet

AB32 and SB375 greenhouse gas emission goals.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

106‐14 Multiple

Signers

No 710 Action

Committee

SCAG RTP modeling is seriously out of date. Most of the SCAG

region is classified as a non‐attainment area for some criteria

pollutants and an extreme non‐attainment area for Ozone.

SCAQMD, as the regional air regulator, has 36 air quality sensors

across Southern California (Map 3.2‐1) but they don't monitor

pollution next to busy freeways. While the sensors may give a

big picture view in accordance with federal law, "without the

(freeway) monitors, there's a "glaring hole" in air pollution

planning that ignores the health of more than a million people

who live within 1000 feet of freeways in the AQMD's region,

according to Adrian Martinez, an attorney for the Natural

Resources Defense Council."1 Baseline data compiled from

freeway monitors would allow us to stop the current modeling

impulse to "average" pollution throughout the region, to look at

health risks more accurately in nearby populations, and not

claim unfounded benefits from basically shifting the pollution

elsewhere without eliminating it. Current traffic modeling

appears to be out of date and inadequate, as witnessed by the

delay of release of the preliminary DEIR on the lower I‐710 due

to inaccurate truck numbers. Without considering induced

demand, the true costs of building, and maintenance and

operations of highways the model doesn't build adequate and

accurate evidence for decision making. It leaves open to

unsupported speculation that more freeways or tunnels will

Comment noted. Air quality m

the local air districts. SCAG w

air quality monitoring to SCAQ

Model is a complex analytical 

our counterpart metropolitan 

Sacramento, and the San Fran

current state‐of‐the‐practice demand modeling. The SCAG 

undergone a series of expert 

a Peer Panel Review involving 

expert practitioners from aro

Panel concluded that the SCA

exceeds the state‐of the‐prac
292

ID Name Affiliation Comment Re

lessen congestion and improve air quality. There is no

uncongested freeway in LA and car and truck volumes are

projected to increase as the inborn population increases. The

volume of traffic and their attendant pollutants will inevitable

increase and move us towards a progressively unhealthy place

to live.

106‐15 Multiple

Signers

No 710 Action

Committee

Since the ARB identified diesel emissions as toxic air

contaminants that are carcinogenic (TACs) in August, 1998 and

14 years (3 RTPs) have passed, it would seem unlikely that the

above conjecture will come true any time soon, especially with

America's oil dependency. Mobile Sources Contribute to Serious

Health Impacts. Mobile sources such as trucks, locomotives and

automobiles create the vast majority of air pollution in the

South Coast Air Basin. One type of pollutant, fine particulates, is

estimated to cause 6,200 premature deaths in the Basin every

year. The average reduction in life span for such persons is

estimated by the California Air Resources Board and the U.S.

Environmental Protection Agency to be 14 years. (California Air

Resources Board, 2008 (mean estimate) 2 Health Risks Near

Transportation Facilities. The AQMD Multiple Air Toxics

Exposure Study (MATES III) shows that diesel particulate matter

is the overwhelming contributor to regional cancer risks from

air pollution which average 1,200 in a million. This is hundreds

of times higher than risk levels allowed for stationary sources

under AQMD rules (between 1 and 25 in a million). The highest

risks from air pollution are found near highways and other

transportation facilities such as the I‐71 0, because of heavy

reliance on diesel‐powered mobile sources. Persons in highly

polluted portions of the basin, and persons near transportation

facilities anywhere, also suffer greater risks of reduced lung

function and many other serious health effects. (SCAG Mates III

analysis, 2008) 3

Comment noted. Please note

source for the Mates III analy

analysis.

106‐16 Multiple

Signers

No 710 Action

Committee

The above is of particular concern to the No 710 Action

Committee because of the overwhelming emphasis on goods

movement and single occupancy vehicles in the RTP. The lower

I‐710 is listed on the projects list and proposes 4 truck lanes

from the Ports of LA‐Long Beach to the rail yards and 10 general

lanes from the Ports to SR‐60. While the upper I‐710 is listed as

a study (EIR/EIS) at a cost of$87,454 million, (2‐27) the projects

do not stand alone without consideration of the impact of the

Comment noted. While we un

used by trucks moving throug

by market segmentation and 

words, not every truck using t

SR‐710 given their destination 

recent port gate survey cond

majority of trucks utilizing the 

proximity to the Ports—with 
293

ID Name Affiliation Comment Re

other, basically a conduit for port truck traffic into residential

areas.

dock or off‐dock facilities in t

destination farther out are ge

of the east‐west corridors (SR

the majority of trucks moving 

and do not have an origin at t

localized impacts of trucks utbe determined through the E

for the project. Additionally, t

residential areas are determi

municipalities. SCAG will cont

regional partners and stakeho

regional significance.

106‐17 Multiple

Signers

No 710 Action

Committee

The 1‐710 North project is also described as an Slane toll facility

in a tunnel (2‐13). While new schools cannot be built within 500

feet of a major highway or freeway, the reverse is not

regulated. A freeway or tunnel can be built within that distance,

which would result in at least 3 7 schools that are within 1000

feet of the extension and the 210 from South Pasadena and

Pasadena to Sylmar being subjected to toxins from an additional

30,000 vehicles and 2,500 more trucks daily. 4

Comment noted. Project‐spe

schools or other sensitive rec

addressed in the project‐leve

Report/Environmental Impac

106‐18 Multiple

Signers

No 710 Action

Committee

Tunnels concentrate pollution up to 1000 times. An Australian

school district will not allow their school busses to traverse a 2

mile tunnel that is considerably shorter than that planned for

the I‐710 extension. 5

Comment noted. Project‐spe

tunnels on pollution levels wo

project‐level Environmental I

Impact Statement.

106‐19 Multiple

Signers

No 710 Action

Committee

Health Risk Assessments (HRA) and Health Impact Assessments

(IDA) The RTP must consider formal Health Risk Assessment and

Health Impact Assessments for all of the 1‐710 corridor

communities and Hot Spot analysis for sensitive receptor

community sites such as schools, daycare centers, hospitals,

convalescent centers, senior centers, parks and recreation

centers, athletic fields and residential areas. Health

professionals must be included in the analyses. No 710 Action

Committee is attaching for your reference: • Scoping

comments, • 13 page Bibliography of Health/Pollution Impacts

links, • Chart of Selected Health and Economic Impacts of

Freight in Global Trade Impacts: Addressing the Health, Social

and Environmental Consequences ... • National Transportation

Objectives and Targets • Coalition for Clean Air‐ Top 10 facts

Californians should know about air pollution and health •

Coalition for Clean Air ‐ Pollutants and Health Effects • Coalition

Comment noted. The formal 

Health Impact Assessments c

project‐level analysis for a sp

analysis may affect local decis

Should such local decisions re

description in the RTP/SCS, SC

implementation agency (e.g., 

commission) to amend the RT
294

ID Name Affiliation Comment Re

for Clean Air ‐ Transportation Facts

106‐20 Multiple

Signers

No 710 Action

Committee

Port of Los Angeles, Port of Long Beach The Ports of Long Beach

and Los Angeles are the single largest source of air pollution in

the South Coast Air Basin. The AQMD stated in its February 17,

2009letter regarding 1‐710 Project Alternatives that "In sum,

this region needs every possible emission reduction from goods

movement and other mobile sources. This must include zero‐

emission technologies wherever possible." The agency

continued by mentioning electrified rail, maglev, the Alameda

Corridor Electrification, electric trucks, fixed‐guideway systems,

and zero emission technologies that have been available for

decades with photos of electrified freight transport systems in

England, France, Russia, Italy, etc. In concluding, the agency

stated ''we wish to caution against any unnecessary "phasing"

of the evaluation of zero‐emission alternatives which could

result in other portions of the 1‐710 project (i.e. lane expansion)

proceeding to project level analysis, possible approval and

construction, prior to full evaluation and potential decision

regarding the zero‐emission alternative." 6 The 12/6/2010"Development of a California Geospatial Intermodal Freight

Transport Model with Cargo Flow Analysis" commissioned by

CARB and CEP A states in its conclusion section "First, the Case

Study quantifies port‐related intermodal goods movement

through the state of California and beyond. Second, the

idealized use of least CO2 routing constraints illustrates how

emissions savings can be achieved through modal shifts. In

terms of savings in emissions, it is estimated that a total of 60%

reduction in C02 emissions is achievable by a modal switch from

road to rail." 7 We need no more long‐term goals or

bureaucratic studies as stated in the plan. The technology is

available now, the studies have been done, commercial projects

and lower polluting alternatives have been suggested in the 1‐

710 DEIR, the benefits are region wide.

Comment noted. SCAG will co

to evaluate and consider tech

106‐21 Multiple

Signers

No 710 Action

Committee

Goods movement versus people movement, by way of forms of

mass transit. For Los Angeles to become truly a world‐class city

more mass transit by way of light rail, busses, subways or

streetcar connections must be planned and implemented. Los

Angeles has been the laboratory for Detroit for the last 100

years and has only been catching up with other major U.S. cities

for the last 20 years. The Move L.A. " survey completed by

Comment noted. The distribu

transportation investments in 

sales tax measure commitme

transportation commission adplans, limitations associated w

other previous commitments
295

ID Name Affiliation Comment Re

Fairbank, Maslin, Maullin, Metz and Associates, shows that

voters in the six county region served by the Southern California

Association of Governments (SCAG) overwhelmingly support

expanding and investing in transit over investing in highways.

Even when voters backed highway spending, there was more

support for a "Fix It First" approach than funneling more money

into mammoth road expansion projects. Voters prioritized

expanding public transportation as the most effective means of

reducing traffic congestion and air pollution, said Denny Zane,

executive director of Move L.A."8 The 1‐710 North EIR Scoping

letters ran overwhelmingly against expansion of the

freeway/tunnel. Preferences are for mass transit projects that

would relieve congestion, clear the air, make commutes more

agreeable and efficient and put more people into one vehicle

rather than single occupancy vehicles. The RTP is "front loaded"

with highway projects and "back loaded" with transit. To meet

our State mandates, it would make sense to move the transit

projects up in the timeline and build them sooner than later.

106‐22 Multiple

Signers

No 710 Action

Committee

Health in all public policies. Health and health equity issues do

not appear prominently enough in your overall planning. Please

reference www.sgc.ca.gov/workgroups/hiap.html. Community

engagement is not demanding you build more and they are the

ultimate stakeholders and the ones who bear the costs and

health burdens.

Comment noted. The RTP/SC

that transportation and the b

health. In addition to the pub

Environmental Justice analysi

RTP/SCS will provide widespr

both public health and enviro

better place‐making will allow 

bicycling more regularly in th

development of urban parks t

for recreation and exercise. F

rates and valuations produce

Association, the RTP/SCS resu

total health incidences, and s

total costs.

106‐23 Multiple

Signers

No 710 Action

Committee

Funding an Undefined Project We are distressed to see the

enormous dollars that might go to a new infrastructure project

such as the 1‐710 north tunnels (11.8 billion, 2007 SCAG figure).

No project is actually defined yet. The EIRIEIS process is just

underway and is considering multiple routes, not just one. In

fact, the Technical Advisory Committee has only had 2 meetings

and is dealing first with a purpose and need evaluation. Our

scarce transportation dollars could be much better used in

Comment noted. SCAG recog

environmental analysis is und

that effort and selection of a 

SCAG will work with Metro to 

update the project descriptio

analysis.
296

ID Name Affiliation Comment Re

transit projects to make a healthier and sustainable region. This

should not be in the constrained list of projects but rather

removed to the strategic list. The cost estimates are way below

the building costs and there are many specialized issues in

concentrating pollution in tunnels. The toll revenues may not

come to pass, as many municipalities have found. It is not

revenue you can reliably build into the current plan. Due to no

foreseeable funding in sight to complete an undefined project,

the RTP must reflect reality and move the potential project from

the constrained to the strategic unfunded list. We need to move

to congestion pricing, reduced parking availability, higher

parking costs and other incentive taxes to move us away from

choosing individual mobility options.

106‐24 Multiple

Signers

No 710 Action

Committee

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

106‐25 Multiple

Signers

No 710 Action

Committee

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

107‐01 Will Kempton Orange County

(multipleagencies)

Induced growth discussions incorrectly imply a lack of

coordination between land‐use and transportation planning

agencies and are contrary to the balanced plans provided

through the LRTP and OC SCS collaboration process. Please state

that land‐use plans and transportation projects identified in the

OC SCS and LRTP are balanced and, if necessary, clarify under

what circumstances “induced growth” may occur.

Comment noted. The referen

removed in the Final RTP/SCS

107‐02 Will Kempton Orange County

(multipleagencies)

New revenue sources and innovative financing strategies used

to demonstrate financial constraint can have significant impacts

on businesses and the economy that must be clearly

understood before advancing. In fact, the RTP vision statement

recognizes the linkages between economy and the regional

transportation system. Specifically, details on how any new user

fees would be further defined, evaluated, and advanced must

be evaluated through a full economic analysis prior to final

adoption of the RTP. In addition, this analysis should

demonstrate, by county, the need for new revenues, how the

new revenues are proposed to be invested, and how a county‐

level return to source mechanism can be ensured.

Comment noted. The Transpo

detailed explanation on all re

An analysis of the economic i

the Economic and Job Creatio

RTP/SCS. We recognize that r

consideration for any new rev

107‐03 Will Kempton Orange County

(multipleagencies)

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P
297

ID Name Affiliation Comment Re

108‐01 Kate Klimow Orange County

BusinessCouncil

There are repeated references throughout the RTP/SCS that

transportation projects “induce growth” which incorrectly

implies a lack of coordination between land‐use and

transportation planning agencies and that there was insufficient

effort in the planning process to accommodate for anticipated,

organic, population growth. The RTP/SCS and the PEIR should

differentiate between balanced, planned growth identified by

local jurisdictions, and growth that is inconsistent with what is

already being planned for at the local level.

Comment noted. SCAG addre

2012‐2035 RTP/SCS PEIR revi

Joint Regional Council and Po

PEIR on February 21, 2012. Fo

the Final PEIR Addendum Sec

on the Draft RTP PEIR, Letter 

The reference to induced gro

RTP/SCS.

108‐02 Kate Klimow Orange County

BusinessCouncil

SCAG should identify in the plan the economic contribution of

the goods movement sector to the regional and state economy

and elevate the importance of the east‐west corridor as critical

to the future of California’s position in the global economy.

Comment noted. The econom

movement is articulated in th

108‐03 Kate Klimow Orange County

BusinessCouncil

The RTP should explicitly state how any new user fees would be

further defined, evaluated (both for economic and feasibility

impacts), and advanced. In particular, the analysis should

demonstrate the need for new revenues and how the new

revenues are proposed to be invested, while also protecting

existing transportation plans as identified by local

transportation entities. Voter‐approved projects funded by local

sales tax measures must be protected.

Comment noted. The Transpo

a detailed explanation on all r

the transportation expenditu

Transportation Finance Appe

plan for all new revenue sour

recognize the importanceof p

plans adopted by county tran

SCAG region and the voter‐ap

plans through local option sa

to work collaboratively to ens

108‐04 Kate Klimow Orange County

BusinessCouncil

With the elimination of redevelopment agencies, the ability of

local jurisdictions to meet the densification of urban centers in

the near term is highly problematic and ignores issues related to

aging or inadequate infrastructure capacity and high

development costs for higher density projects. It also threatens

the availability of sufficient housing options necessary to meet

the needs of a dynamic workforce. Recommendations regarding

land‐use should take into account the region’s unique

communities, market forces, and take a flexible not proscriptive

approach to protect regional diversity.

Comment noted. The elimina

jurisdictions' ability to finance 

intended to support the polic

continue to identify funding r

pursuing such policies.

108‐05 Kate Klimow Orange County

BusinessCouncil

Finally, since passage of SB 375, the State of California has de‐

funded transit, transportation and redevelopment support for

local government. This continues years of state diversion of

revenues from gasoline, sales, income and other taxes needed

for local government programs. Local government cannot

achieve these mandated changes without increased, not

decreased, state support. SCAG should explicitly state the

Comment noted. We agree, a

regional targets was conditio

aimed primarily at restoring p

transportation. We also inclu

adjustments to state and fede

specific steps necessary to sta

transportation revenue sourc
298

ID Name Affiliation Comment Re

imperative for state support for planning, transit, transportation

and redevelopment or other necessary funding to pre‐SB 375

levels in order to achieve mandated goals.

adequate resources to meet s

108‐06 Kate Klimow Orange County

BusinessCouncil

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

109‐01 Dave Simpson Orange County

Council ofGovernments

SCAG's adoption of the growth forecast numbers should be at

the county level, consistent with past RTPs, and not at a smaller

level of geography such as city, census tract, or traffic analysis

level.

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use deallocation being adopted at th

that the SCS be based on a ju

distribution.

109‐02 Dave Simpson Orange County

Council ofGovernments

All documents, tables, maps, narrative, modeling runs, PEIR

Alternatives (including Alternative C/3/Envision 2) referencing

the Orange County growth forecasts should be updated with

the Orange County Projections‐2010 Modified Growth

Projections, as adopted by the OCCOG Board of Directors and

consistent with the subregional delegation MOU between

OCCOG, OCTA and SCAG.

Comment noted. SCAG has in

Modified dataset into the SCA

for the 2012 RTP/SCS and upd

tables, maps, narrative, mode

Alternate Creferencing the O

109‐03 Dave Simpson Orange County

Council ofGovernments

The RTP/SCS identifies strategies to reduce greenhouse gas

(GHG) emissions from cars and light duty trucks. Because

counties, jurisdictions and agencies have different needs and

feasibility of implementation, we believe these strategies should

be clearly identified as a menu of options that can be used to

achieve the goal of reduced GHG emissions. However, the

document can be construed to suggest that each of the

strategies listed in the table on pages 150‐153 are necessary to

successfully implement the SCS, many of which are beyond

SCAG's purview or control. It is requested that the language be

clear that it is permissive. (1) Revise language on page 149: "The

following tables list specific implementation strategies that local

governments, SCAG, and other stakeholders may use or

consider while preparing specific projects which that help to

successfully implement the SCS." (2) Please provide SCAG

analysis supporting the strategies in the Draft RTP/SCS Chapter

4. (3) Please describe what municipal obligations are anticipated

as a result of adopting these strategies as a list to be

accomplished rather than a menu of options.

Comment noted. The subregi

GCCOG and OCCOG are incor

RTP/SCS in their entirety, and 

endorsed by the regional plan 

region. Regional strategies in

as financing strategies, apply 

RTP/SCS has been updated to 

109‐04 Dave Simpson Orange County There are strategies in the OC SCS that are not included in the Comment noted. The subregi
299

ID Name Affiliation Comment Re

Council ofGovernments

regional SCS. Similarly, there are some strategies in the regional

SCS that are not consistent with the strategies in the OC SCS.

This creates confusion and clarification is needed. SCAG has

incorporated the OC SCS in its entirety into the regional SCS as

an appendix to the regional SCS, but it is unclear what the

standing is of the OC SCS. The OC SCS contains a set of

strategies that were agreed upon by local governments,

agencies and other stakeholders within Orange County and was

accepted by SCAG and should represent the SCS that is

applicable to the Orange County region. Please revise the text in

the last paragraph on page 106 to state: "These subregional SCS

documents are incorporated into the regional SCS and

represent the SCS for each of these subregions."

GCCOG and OCCOG are incor

RTP/SCS in their entirety, and 

endorsed by the regional plan 

region. Regional strategies in

as financing strategies, apply 

RTP/SCS has been updated to 

109‐05 Dave Simpson Orange County

Council ofGovernments

1) RTP General. All chapter headings should include the Chapter

number on each page for ease of reference.

Comment noted. Chapter num

requested.

109‐06 Dave Simpson Orange County

Council ofGovernments

2) RTP p. 1, left col – “The 2012 RTP/SCS includes a strong

commitment to reduce emissions from transportation sources

to comply with SB 375, improve public health, and meet the

National Ambient Air Quality Standards as set forth by the

federal Clean Air Act.”

Comment noted.

109‐07 Dave Simpson Orange County

Council ofGovernments

3) RTP p. 4, right col ‐ “This region needs a long‐term,

sustainable funding plan that ensures the region receives its fair

share of funding, supports an efficient and effective

transportation system that grows the economy, provides

mobility choices, and improves our quality of life.”

Comment noted. We agree t

receives its fair share of trans

109‐08 Dave Simpson Orange County

Council ofGovernments

4) RTP p. 7, Table 2 and p. 95, Table 3.3 ‐ Is additional $0.15 gas

tax the sum total of both state and federal taxes or $0.15 each?

Comment noted. The additio

excise gas taxes.

109‐09 Dave Simpson Orange County

Council ofGovernments

5) RTP p. 40, left col ‐ “Strategic investments, put forth by the

private sector, that would remove barriers associated with

telecommuting are expected...”

Comment noted. The referen

follows: "Strategic investmen

that would remove barriers a

expected to increase the num

telecommuters to 5 percent i

109‐10 Dave Simpson Orange County

Council ofGovernments

6) RTP p. 42, Table 2.2 ‐ 241 toll road completion year is 2030 Comment noted. Table 2.2 w

completion year of 2030.

109‐11 Dave Simpson Orange County

Council of

7) RTP p. 50, left col – “scrip”, Please define in text and add to

glossary.

Comment noted. This term ha
300

ID Name Affiliation Comment Re

Governments

109‐12 Dave Simpson Orange County

Council ofGovernments

8) RTP p. 54, right col ‐ “Despite our concerted effort to reduce

traffic congestion through years of infrastructure investment,

the region’s system demands continue to exceed available

capacity during peak periods.”

Comment noted. We agree th

is an appropriate addition to 

109‐13 Dave Simpson Orange County

Council ofGovernments

9) RTP p. 70, 78 ‐SCAG seems to rely on CEQA to achieve the

"maximum feasible" reductions in emissions from

transportation. However, this is not consistent with the intent

of SB 375’s goal of achieving specific thresholds of 8% by 2020

and 13% by 2035 through a sustainable communities strategy

plan. Please provide clarification to this section indicating if the

air quality and greenhouse gas CEQA mitigation measures

obligate regional agencies and project developers to undertake

more strategies, programs and mandates beyond those

included in the OC SCS. 10) RTP p. 78, right col ‐ On road

emissions (from passenger vehicles and heavy duty trucks)

constitute 93 percent of the transportation sector total.

Emissions from passenger vehicles, which are the subject of SB

375 and this RTP/SCS, constitute ___% of the transportation

sector’s greenhouse gas emissions total.” 11) RTP p. 80, left col ‐ 

Statements are made, such as, "the RTP has the ability to affect

the distribution of that growth" (in population in the region).

These statements could be interpreted to be contrary to SCAG's

obligation under the Memorandum of Understanding with

OCCOG to respect the strategies and local land use policies in

the OC SCS. Please clarify how it is in SCAG's ability to affect

local change when the OC SCS is consistent with acceptance of

local land use plans and planned population and employment

distribution? Recommended text change: “Transportation

projects including new and expanded infrastructure are

necessary to improve travel time and can enhance quality of life

for those traveling throughout the region. However, these

projects also have the potential to attract more of the regional

population growth in certain areas of the region. This means

that although SCAG does not anticipate that the RTP would

affect the total growth in population in the region, the RTP has

the ability to affect the distribution of that growth.

Transportation projects in the RTP also have the potential to

divide established communities, primarily through acquisition of

rights‐of‐way.”

Comment noted. Edits regard

emissions from the transport

RTP/SCS. In regard to the mit

intend to dictate mitigation to 

addressed these concerns wit

revision approach, as present

and Policy Committee Works

2012. The reference to induce

the Final RTP/SCS.
301

ID Name Affiliation Comment Re

109‐14 Dave Simpson Orange County

Council ofGovernments

RTP p. 82, right col ‐ Text indicates that the RTP and projects in

the RTP/SCS as “inducing” growth. It is noted that use of the

term “induced growth” has a negative connotation and implies

growth above and beyond what would occur naturally.

However, it is stated in the RTP that the population, housing,

and employment growth totals are fixed and only the

distributions may change based on the plan. This means there

will not be “new” growth and that the RTP and SCS may simply

influence and shift the growth anticipated for the region. This

moving of growth is the result of changes in distribution that are

due to changes in land use or densities. Because of this, it is

requested that references to “induced growth” be reworded to

reflect the shifting of growth in the region. Recommended text

change: “Cumulative impacts from the projected growth include

increased impervious surfaces;...”

Comment noted. The referen

removed in the Final RTP/SCS

109‐15 Dave Simpson Orange County

Council ofGovernments

12) RTP Ch. 3 ‐ SCAG’s Financial Plan includes a significant

portion of “New Revenue Sources and Innovative Financing

Strategies” that are not currently in place or available. While

some of the proposed revenues are within the control of SCAG

or MPOs and County Transportation Commissions, the majority

of the revenues (in terms of dollars) require either state or

federal action to implement. Please explain what the

implications are if these new revenue sources and innovative

financing strategies do not become available? 13) RTP p. 95,

Table 3.3 – Delete “Mileage‐based user fees would be

implemented to replace gas tax and augment—estimated at

about $0.05 (2011$) per mile and indexed to maintain

purchasing power starting 2025.” Suggested language is from

page 31 of Growth Forecast Appendix: “Current gasoline tax,

estimated at about $0.05 (2011$) per mile will increase through

2025, then in 2026 it would be replaced with a mileage‐based

user fee indexed to maintain purchasing power.”

Comment noted. The determ

with fiscal constraint, as part 

requirements, are made at th

amendment. We recognize th

with certainty and therefore 

which were vetted through S

Committee and Policy Comm

the RTP. As we gain more ins

we will update the financial p

amendments and/or subsequ

At a minimum, an RTP is prep

years. The Growth Forecast A

accurately reflect the mileage

109‐16 Dave Simpson Orange County

Council ofGovernments

14) RTP p. 105, right col ‐ “While the region was once known

worldwide as the “capital of sprawl,” the region today is

projecting growth on only a small fraction of the raw land

available in the region.” 16) p. 106 ‐ SCAG indicates that the OC

SCS has been incorporated into the regional SCS. OCCOG was

one of two subregions that undertook the arduous task and

obligation of preparing an SCS. Please add clarifying text that

these subregional SCSs, including the OC SCS, represent the

Comment noted. The final RT

and addsss comment.
302

ID Name Affiliation Comment Re

Sustainable Communities Strategies applicable to those

subregions. 17) p. 110, right col ‐ “Municipal water and sewer

systems, for example, ensure clean water. At the same time, as

areas become more urbanized and the percentage of

impervious surface is increased, the hydrologic regime is

dramatically altered. Drainage conveyances that once were

natural and riparian are required to be engineered as hardened

flood control channels to provide adequate protection of

private property and public infrastructure from the increased

frequency, duration, peak flow, and overall volume of

stormwater runoff. With this armoring of once natural channels,

water quality benefits from biofiltration are lost along with

opportunities for infiltration and evapotranspiration, which can

lead to hydromodifcation downstream in sections which are not

yet engineered and hardened. Many strategies...” 18) p. 112,

117 ‐ The SCS documents the development of four scenarios to

explore basic aspects of future growth. These scenarios were

used in public outreach and the SCS and the associated

Appendix states that “Using the public dialogue and feedback

from the analysis of the SCS Scenarios, SCAG developed the

2012 RTP/SCS Plan alternatives.” (Similar references are also

include at RTP/SCS p. 117, and SCS Background Documentation

p. 71). The RTP/SCS and Appendix then describes a process that

led to the Plan alternatives. Neither the RTP/SCS, Appendix or

PEIR expressly state or illustrate the fundamental land use and

socioeconomic foundation for the SCS. In order to confirm

consistency with the OC SCS, it is requested that SCAG include

appropriate tables, graphics and maps that provide the detail

that confirm this consistency.

109‐17 Dave Simpson Orange County

Council ofGovernments

19) p. 113, 122 ‐ The regional SCS states that the

scenarios/alternatives were developed using the Local

Sustainability Planning Tool (LSPT). The LSPT is a sketch planning

tool that flattens geographical areas to a 5‐acre grid cell. The OC

SCS land use data was provided at much greater level of detail

in that specific parcel data and detail were provided by each

jurisdiction. A cursory review of some LSPT data reveals

inconsistencies regarding interpretation of Orange County land

uses. It is acknowledged that the regional SCS states, "Land use

inputs for OCCOG SCS were unchanged". Yet use of the LSPT

and SCAG Development and Community Types presented in the

Comment noted. The subregi

GCCOG and OCCOG are incor

in their entirety, and as such, 

the regional plan for impleme

strategies included in the RTP

apply region‐wide. The final R

Documentation Appendix wa

language and addressreflect t
303

ID Name Affiliation Comment Re

SCS leave open the question as to whether the OC SCS was

altered, as noted above. Please provide confirmation that theunderlying OC SCS land use data was used without significant

alteration and LSPT flattening and interpretation in the

development of the regional SCS Plan and alternatives. 20) p.

127, right col – “Gentrification”, add to glossary 21) p. 128, left

col ‐ “Thus, this adjustment allowed the land use pattern to

conform more closely to local general plans, while reducing the

amount of vehicle miles traveled.” Whose/What are “local

expectations?” 22) p. 149, right col ‐ Revise language to clarify

that SCAG intends policies, strategies, and measures are a menu

of options. “The following tables list specific implementation

strategies that local governments, SCAG, and other stakeholders

may use or consider while preparing specific projects which

would help to successfully implement the SCS.” 23) p. 150‐152 ‐

The OC SCS was accepted by SCAG and represents the set of

strategies and the growth distribution that outlines the best

approach for how the requirements of SB 375 would be met

within the subregion. Specifically, the OC SCS included 15

specific Sustainability Strategies, reflecting a menu of 222

practices and actions that OC agencies have agreed to pursue

(or continue to pursue) to achieve GHG reductions that support

SB 375. Why doesn’t the regional SCS specifically acknowledge

these 15 strategies yet include other strategies and

performance measures not included in the OC SCS (e.g.,

Locational Efficiency)? 24) p. 166, right col – “Greenfield”, add

to glossary

109‐18 Dave Simpson Orange County

Council ofGovernments

25) p. 194, right col ‐ “In addition to these targeted outreach

efforts, all regular and special meetings of the RTP task forces,

the Transportation Committee (TC), the CEHD, the EEC, and the

SCAG Regional Council are publicly noticed and ...”

Comment noted. Referenced 

SCAG committees that are pu

109‐19 Dave Simpson Orange County

Council ofGovernments

26) p. 201 ‐ Please clarify whether the text stating “Long‐term

emission reduction for rail, with a goal of zero‐emissions rail

system” is intended to reflect a zero‐emissions freight rail

system, or whether this goal also applies to passenger rail.

Comment noted. This text ref

movement. However, any pla

emissions freight rail system 

passenger rail system in the c

109‐20 Dave Simpson Orange County

Council ofGovernments

27) p. 202‐203, Table 7.1 ‐ Unfunded operational

improvements, of which several are listed on page 203, Table

7.1, include transit station improvements in Irvine, Fullerton,

and Santa Ana, bus rapid transit (BRT) in Orange County, and

high speed rail (HSR) Phase II. Please confirm that these are

Comment noted. The operati

with the Orange County SCS.
304

ID Name Affiliation Comment Re

consistent with the OC SCS.

109‐21 Dave Simpson Orange County

Council ofGovernments

28) p. 207 ‐ Strategic Finance. Please explain what will happen if

reasonably foreseeable revenue sources of approximately $200

million do not become available?

Comment noted. The determ

with fiscal constraint as part o

requirments, are made at the 

amendment. We recognize th

with certainty and therefore 

which were vetted through S

Committee and Policy Comm

the RTP. As we gain more ins

we will update the financial p

amendments and/or subsequ

At a minimum, an RTP is prep

years.

109‐22 Dave Simpson Orange County

Council ofGovernments

29) p. 205 – “Active transportation”, add to glossary Comment noted. This term ha

109‐23 Dave Simpson Orange County

Council ofGovernments

Growth Forecast Appendix, p. 23, Table 13 ‐ In December 2011,

Orange County provided SCAG with the revised growth forecast

dataset, OCP‐2010 Modified, per the OC SCS MOU (official

OCCOG Board action 1/26/2012). Please incorporate revised

Orange County numbers (i.e. OCP‐2010 Modified) into all

reports, tables, exhibits, alternatives, maps, and modeling runs

for final RTP.

Comment noted. SCAG has in

Modified dataset into the fina

2012 RTP/SCS and updated a

narrative, modeling runs, and 

referencing the Orange Coun

109‐24 Dave Simpson Orange County

Council ofGovernments

Finance Appendix ‐ What are the implications if revenues other

than core revenues do not become available? Please describe

any implications to the ability of the region to meet SB 375 GHG

emission reduction targets or the federally required air quality

conformity?

Comment noted. The majorit

available revenues (excluding 

to be available until the latter 

determination of the RTP’s co

part of meeting air quality co

at the time of plan adoption o

the future cannot be known w

reasonable assumptions, whi

Technical Advisory Committe

well documented in the RTP. 

funding options, we will upda

through amendments and/or 

appropriate. At a minimum, a

every four years.

109‐25 Dave Simpson Orange County

Council ofGovernments

PM Appendix p. 1 ‐ The document states, “The performance

measures are used to evaluate how well the RTP/SCS addresses

the adopted goals and performance outcomes.” Is there any

Comment noted. The Perform

been revised to state that the 

are not required for use at th
305

ID Name Affiliation Comment Re

formal role for the performance measures? ARB will evaluate

for SB 375 compliance not based on these measures but based

on ARB process. Please include language clarifying that this is a

requirement to demonstrate compliance with federal

requirements and not for the obligations under SB 375. PM

Appendix p. 1, end of first paragraph ‐ Add statement:

“Performance measures and expected outcomes will be used to

monitor the RTP/SCS at the regional level; these measures and

outcomes are not proposed for use at the subregional or

project‐specific level.” PM Appendix p. 1, col 2 ‐ The document

states, “The Regional Council will formally adopt the goals and

outcomes as part of the final 2012 RTP/SCS.” Does this bring any

formal obligation to meet goals? Goals are general, flexible, and

aspirational rather than specific, as on p.1.

level.

109‐26 Dave Simpson Orange County

Council ofGovernments

[PM Appendix] p. 13, Table 8 ‐ The RTP/SCS claims an extra 2%

CO2e emissions reduction in 2035 from the NHTS post‐

processing analysis. While the RTP/SCS meets the ARB SB375

goal without the extra 2%, we would like to note that the extra

2% could be important if the attorney general raises concerns

about backsliding. Consequently, the reliability of the extra 2%

reduction should be checked. Questions on the NHTS model are

below. It would be useful to know the answers to better judge

the quality, although we do note that the report does look like it

meets the standards or best practice. p. 9 ‐ NHTS Model

Documentation Report. Are the auto and bus accessibility

variables included in the regression models for 30‐mile rings? In

“Number of trips” model – is number of cars, included as an

independent variable, the actual or predicted value? The same

question applies to other models. p. 23, Table 10 ‐ NHTS Model

Documentation Report. Were the elasticities for the SCAG NHTS

study calculated at sample means, or for each observation and

then averaged for the sample? p. 24, Test 3 ‐ NHTS Model

Documentation Report. (Compare Trip‐Based and NHTS Model):

The final test was to compare the results of the Trip‐Based

Model and the NHTS Model for the same scenarios. Please

describe the scenarios tested.

Comment noted. Response to 

1) Are the auto and bus acces

regression models for 30‐mile 

use concept of 30‐mile ring, i

accessibility indicators, with t

are calculated: auto accessibi

variable in the VMT model, an

the mode choice model. Zone

accessibility calculation reflec

transportation network, whic

based modeling analysis.2) In “Number of trips” mode

an independent variable, the 

Response: To estimate mode

household vehicles is from NH

model to estimate the numbe

vehicles is estimated from the 

(predicted).3) Were the elasticities for th

sample means, or for each ob

the sample? Response: It is ca

the result averaged.

4) The final test was to compa

Model and the NHTS Model f

describe the scenarios tested

for the RTP/SCS.
306

ID Name Affiliation Comment Re

109‐27 Dave Simpson Orange County

Council ofGovernments

[SCS Background Appendix] p. 53, right col ‐ Housing Options

and Mix: Define Larger‐lot single family in text. p. 71‐74, 80‐83 ‐ 

Alternatives naming: A, B, C. Names of Alternatives differ than

those listed in the PEIR on pages ES‐3 and 1‐4. Please be

consistent with naming protocol for alternatives between

two/all documents. p. 71, right col ‐ “Plan Alternative (B)... The

alternative maintains city‐level forecast control totals for both

households and jobs, however, within city boundaries shifts are

made to focus a much larger share of future growth in a more

compact way around HQTAs, except in Gateway and Orange

County COG subregions per their SCS delegation agreements.

Future housing market demand is expected to shift significantly

to small lot single‐family, townhomes and multi‐family

housing.” [“housing” misspelled] p. 71, right col ‐ Plan

Alternative (B). Define small lot single family in text. p. 71, right

col ‐ Plan Alternative (C). “As a result very suburban

communities may experience no new housing or employment

growth, while some urban areas with very good access to

regional transit may experience significant increases in housing

or employment growth.” p. 72, left col ‐ “While each alternative

is distinctive, a number of parameters remained constant across

each alternative: the regional RTP/SCS forecast total for

population, households and jobs;...” “Detailed forecast: the

detailed distribution of population, households, and jobs across

the region...” p. 72, Table D1 ‐ Alternatives A & B: “Controlled to

TAZ‐based RTP/SCS Forecast for 2020; Controlled to city‐level

RTP/SCS Forecast for 2020‐2035, except in Gateway and Orange

County COG subregions per their SCS delegation agreements.”

Add statement to table notes: Gateway and Orange County COG

subregions’ local input data will not be changed per their SCS

delegation agreements. p. 74, Table D2 – Alternatives A & B:

Add statement: Gateway and Orange County COG subregions’

local input data will not be changed per their SCS delegation

agreements. p. 75, right col ‐ “Development Types. The

alternatives are built on, and provides data at, the level of the

TAZ, which includes housing units and employment.” Please

clarify if TAZ is Tier 1, Tier 2, or both.

Comment noted. The final SC

Subregional Sustainable Com

have been updated to add cla

comment, as appropriate.

109‐28 Dave Simpson Orange County

Council ofGovernments

[SCS Background Appendix] p. 79, right col ‐ “Subregional SCSs

submitted by the Gateway Cities Council of Governments

(GCCOG) and the Orange County Council of Governments

Comment noted. The SCS Bac

was updated as part of the fin

language and address comme
307

ID Name Affiliation Comment Re

(OCCOG) will be unchanged and integrated into the alternatives

(with possible revisions for Alternative C only).” p. 79 ‐ The

section includes the following language: “Subregional SCSs

submitted by the Gateway Cities Council of Governments

(GCCOG) and the Orange County Council of Governments

(OCCOG) will be respected and integrated into the alternatives

(with possible revisions for Alternative C only).” Please clearly

indicate what the “possible revisions” are and what process

would be used to coordinate with Orange County should

changes to the socioeconomic data contained in the OC SCS be

proposed? p. 80 ‐ Alternative A. Add statement: “Gateway and

Orange County COG subregions’ local input data will not be

changed per their SCS delegation agreements.” p. 81 ‐ 

Alternative B. It is not clear whether Alternative B is the SCS

land use plan. If it is, statements in the appendix lead one to

believe the OC SCS foundation has been altered. For example,

adjustments made to land uses to locate proximate to High

Quality Transportation Areas (HQTA) and intensification of

residential and employment development in HQTA that diverge

from local General Plans as well as implementation of a vehicle

user fee are not part of the OC SCS. Is Alternative B the SCS land

use plan? Add statement: “Gateway and Orange County COG

subregions’ local input data will not be changed per their SCS

delegation agreements.” p. 115, left col ‐ Transit Zoning Code

Santa Ana 2011. Is this a duplicate of the 2010 Santa Ana

project?

109‐29 Dave Simpson Orange County

Council ofGovernments

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

110‐01 Mike

Harmanos

Orange CountyRenewableEnergy Society

We are a local chapter of the American Solar Energy Society.

The Association of Governments had an Energy Working Group

in 2006 and knowing that this process was going to take place,

the plans of that group were put on temporary hold. The draft

plan that was released in December mentions renewable energy

one time on Page 82 of the report. I’m hoping that the energy

working group can get reactivated, built back up again, and get

the thoughts and ideas of grassroots organizations and elected

officials working together. The organization that I represent has

approximately 45 members in Orange County. We have people

in the industry, people who are scientists, we have individuals

Comment noted. We look for

County Renewable Energy So
308

ID Name Affiliation Comment Re

who are just concerned about renewable energy and are

advocating its effective and intelligent use going into the next

20 years. I wanted to thank you for your hard work and also

offer my organization’s help in addressing some of the

renewable energy infrastructure requirements that you will face

going into 2035 and how renewable energy can be used, not in

competition with an oil‐based energy system, but as a back‐up

system, just as any decent business or organization would build

contingency plans for back‐up and concerns.

111‐01 Greg Nord Orange County

TransportationAuthority

The draft RTP suggests that $127.2 billion of the approximately

$219.5 billion regional shortfall can be addressed through

actions at either the state or federal level with a $0.15 gas tax

increase between 2017 and 2024. After that, the draft RTP

assumes that the state or federal government would either

replace the gas tax with an indexed mileage‐based user fee of

$0.05 per mile, beginning in 2025, or further increase fuel taxes

to generate revenues equivalent to the mileage‐based user fee.

OCTA cannot support an increase in fees, including the

introduction of a mileage‐based user fee, until a comprehensive

economic impact study is completed and presented to the OCTA

Board of Directors (Board) for discussion. In addition, when

considering support for any kind of a new user‐based fee

program, an emphasis must be placed on the need for a return‐

to‐source criteria that guarantees funds generated within

Orange County are reinvested in Orange County. Finally, there

should also be a process for recognizing and rewarding areas

that keep the transportation system in a state of good repair.

Comment noted. The project

based user fee and adjustme

taxes when combined with th

and federal sources are less t

in state and federal transport

percent annually. Rather than 

the historical growth rate, wh

requirements, we detailed sp

state and federal transportat

with recommendations from 

established by Congress throu

economic impacts of the RTP 

Job Creation Analysis of the 2

that return‐to‐source and rew

substantial strides to obtainin

items for any new revenue so

111‐02 Greg Nord Orange County

TransportationAuthority

The draft RTP identifies Phase I of the California High‐Speed Rail

Authority (CHSRA) Project as a potential solution for improving

interregional and intercity ground transportation. As described

in the RTP, the project is planned to connect San Francisco with

Los Angeles and Anaheim. This also assumes improvements to

increase speeds along the Los Angeles‐San Diego‐San Louis

Obispo (LOSSAN) corridor and the Metrolink Antelope Valley

Line. This project description is consistent with the draft CHSRA

Business Plan, which OCTA has reviewed and provided

comments on (attached). OCTA would like SCAG to take these

comments into consideration as the RTP is refined for adoption

in April. In summary, these comments focused on the following:

OCTA supports the phased delivery approach, which includes

Comment noted. The 2012 RT

in the region's existing rail se

included in the Constrained a

regularly providing high‐spee

through the Transportation C
309

ID Name Affiliation Comment Re

early investment in the existing LOSSAN and Metrolink

infrastructure; Rather than initially investing in the central

segment, OCTA believes it is more prudent to begin

implementation at the “bookends” of the system; Extending the

implementation of Phase I by 13 years may jeopardize existing

funding due to timely use criteria; The updated schedule should

account for potential contingencies, and the associated

potential cost increases should be addressed through

contingency planning; The project’s dependency on public funds

could place CHSRA in direct competition for funding with

existing transit service providers and local transportation

agencies; It is questionable whether the funding plan truly

complies with the requirements set out in Proposition 1A,

specifically Section 2704.08(c)(2), items A through K; The

operating assumption of “up to nine trains per hour” will likely

result in an unnecessary level of service, and the projected

operating surplus of $1 billion per year is too optimistic; The

$171 billion alternative investment in airports and roadways

does not account for the airport and roadway investments that

will be required both with and without the high‐speed rail

project. In addition, OCTA recommends that SCAG provide

regular updates to the Transportation Committee and Regional

Council regarding the CHSRA business plan, financial status,

implementation progress, and any changes in assumptions by

the CHSRA; particularly with respect to the status of the

memorandum of understanding that better defines CHSRA’s

commitments to near‐term speed improvements for the

LOSSAN and Metrolink services.

111‐03 Greg Nord Orange County

TransportationAuthority

The draft RTP includes the implementation of a regional high‐

occupancy toll (HOT) lane network. This network appears to

utilize existing and planned high‐occupancy vehicle lanes to

generate new revenues by selling excess capacity to single‐

occupancy drivers. The proposed regional HOT lane network

assumes that Orange County would include HOT lanes on

Interstate 5 (I‐5) between the San Diego County border and the

southern end of State Route 73 (SR‐73); along I‐405 between

the northern end of SR‐73 and the Los Angeles County border;

and along State Route 91 (SR‐91) extending the Express Lanes

west to the Los Angeles County border. On December 12, 2011,

the OCTA Board approved the Express Lane Planning and

Comment noted. The OCTA E

Implementation Principles wi

assumptions for the applicab

lane network. The proposed r

product of the Express Travel 

plays an active role. In additio

OCTA Board has directed staf

Travel Choices Phase II study 

local match for the study, wh

implementation issues. We a

implementing agency for the 

continue to work in a collabo
310

ID Name Affiliation Comment Re

Implementation Principles (attached). OCTA requests that these

principles be incorporated into the assumptions for segments of

the regional HOT lane network that are within Orange County.

Furthemore, the proposed HOT lane improvements to I‐5, and

SR‐91 should be subject to further study to evaluate right‐of‐

way impacts, community issues, and overall feasibility, prior to

inclusion in the constrained plan.

111‐04 Greg Nord Orange County

TransportationAuthority

Due to continuing growth at the ports of Long Beach and Los

Angeles, and increasing congestion on freeways throughout the

SCAG region, the draft RTP highlights the need for a zero

emission East‐West Freight Corridor. The corridor would aid the

movement of goods between the ports and warehousing

facilities located inland. This reflects the findings from the

Comprehensive Regional Goods Movement Plan and

Implementation Strategy. Several other corridors were

examined, including the SR‐91, through Orange County and

Interstate 10. After considerable study, the State Route 60

corridor was selected for further study based on its proximity to

current and future markets, feasibility and right‐of‐way

constraints, future truck volumes, and potential for reducing

truck‐involved accidents. The SR‐91 was not selected primarily

due to right‐of‐way constraints throughout the corridor, andlack of good access to warehousing locations. OCTA supports

the East‐West Corridor as it appears in the Draft 2012 RTP.

OCTA believes that the findings from the Comprehensive

Regional Goods Movement Plan and Implementation Strategy

are accurate, and OCTA encourages SCAG to build on the

progress of the East‐West Corridor based on these findings.

Comment noted.

111‐05 Greg Nord Orange County

TransportationAuthority

SCAG proposes a number of other investments within the draft

RTP that affect Orange County, and go beyond the Long‐Range

Transportation Plan (LRTP). OCTA recognizes that it is within

SCAG’s purview to plan for regional strategies that enhance

transportation, such as the ones discussed below. It should be

noted that OCTA is committed to delivering the projects within

the LRTP. OCTA will only consider additional investments after

revenues are identified to account for these commitments. The

regional strategies identified by SCAG do not have clear funding

mechanisms, and it must be made clear that their inclusion in

the RTP does not constitute a commitment to fund and/or

implement the improvements. Examples of regional strategies

Comment noted.
311

ID Name Affiliation Comment Re

include the congestion management projects identified by the

California Department of Transportation. In Orange County,

these corridors include State Route 57, State Route 22,

Interstate 605, SR‐91, and I‐405. The improvements consist of

relatively low‐cost operational improvements such as ramp

metering, auxilary lanes, and other ramp and interchange

enhancements. These are in addition to what was already

submitted to SCAG by the county transportation commissions

(CTCs) such as OCTA, and rely on funding sources beyond those

identified in the LRTP. The draft RTP also proposes additional

transit enhancements throughout the region. The key transit

investments that go beyond what the CTCs have committed

include expanding local bus service, additional bus rapid transit,

and new express bus service. These improvements are not

specified in the draft RTP, but the additional cost to the region

for these services is estimated at about $2.6 billion. These

additional costs are covered by SCAG’s assumed transportation

funding levels, which are beyond the available and committed

resources identified in the LRTP. An additional emphasis is also

placed on walking and bicycling, which is referred to as “active

transportation.” The draft RTP proposes to increase the regional

investment in active transportation by about $4.5 billion. When

the committed investments submitted by the CTCs are

accounted for, the total active transportation investment is

approximately $6 billion for the SCAG region. Again, this

additional investment is over and above resources identified in

the LRTP, and the improvements are addressed only at the

regional level.

111‐06 Greg Nord Orange County

TransportationAuthority

Throughout the draft RTP and PEIR, there are references to

transportation projects inducing growth and influencing land‐

use development and demand. One such instance is on page 80

of the draft RTP, which states the following: “Transportation

projects including new and expanded infrastructure are

necessary to improve travel time and can enhance quality of life

for those traveling throughout the region. However, these

projects also have the potential to induce population growth in

certain areas of the region. Although SCAG does not anticipate

that the RTP would affect the total growth in population in the

region, the RTP has the ability to affect the distribution of that

growth.” These types of statements are misleading for a

Comment noted. The referen

removed in the Final RTP/SCS
312

ID Name Affiliation Comment Re

number of reasons. For example, the excerpt quoted above

states that the “RTP has the ability to affect the distribution of

growth.” This can be understood to imply that SCAG has the

ability to influence growth through the development of the RTP.

OCTA trusts that this is not SCAG’s intent. OCTA recommends

that such references be clarified, as land use decisions are

within the purview of local agencies. Moreover, and more

importantly, statements such as the above excerpt imply a lack

of coordination between land‐use and transportation agencies,

especially in the light of the recent efforts to develop the

Sustainable Communities Strategies at the subregional and

regional levels. There should be an emphasis in the RTP on the

fact that land‐use and transportation agencies are coordinating

better now than ever before. OCTA recommends that SCAG

clarify the negative implication of the statements regarding

induced growth, and highlight the elevated level of coordination

occurring today.

111‐07 Greg Nord Orange County

TransportationAuthority

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

112‐01 Greg Nord Orange County

TransportationAuthority

OCTA would like to request modifications to the project list that

have been submitted to SCAG staff through the standard RTP

long‐range project list modification and FTIP database update

processes. Major project modifications include: ORA55241

ORA020115 2A0705 2H01143 2M0730 2H0703 2H0706 2T01135

2120010 2TR0701 2L206 2TR1001 Major project additions

include: ORA030605 Additional comments have also been

submitted via email regarding the following projects: 2M0733

(extend the limits to SR‐91) 550 (only model the HOV ramp in

the Strategic Plan) Furthermore, the comments submitted on

the Orange County fact sheet, which was used for SCAG's RTP

workshops/outreach, should also be reflected in the Final RTP

and PEIR. Finally, please modify the project desription for

HSRT0701 to read as follows: ENVIRONMENTAL CLEARANCE

AND ADVANCED CONCEPTUAL DESIGN OF THE CALIFORNIA

HIGH SPEED RAIL AUTHORITY, HIGH SPEED RAIL PROJECT FROM

SAN FRANCISCO TO LOS ANGELES AND ANAHEIM.

Comment noted. We have ad

to the project list as submitte

commissions through the sta

modification and FTIP databa

113‐01 Carolyn

Mamaradlo

Orange CountyTransportationAuthority

With regard to Page 6 of the Draft RTP Active Transportation

chapter: Please note that the latest OCTA bikeways plan is the

2009 Commuter Bikeways Strategic Plan. This plan is expected

Comment noted. The title of 

corrected and the added desc

Bikeways program has been a
313

ID Name Affiliation Comment Re

to be updated for 2014. On Jan. 23, 2012, the OCTA Board of

Directors directed staff to move forward with the Orange

County Bikeways program, a coordinated effort between local

agencies and OCTA entailing (1) strategic corridor planning, (2)

the development of detailed implementation plans, and (3)

construction of high‐priority projects. The goal of this program

is to take advantage of grant funding opportunities by

developing shelf‐ready projects along regional bikeway

corridors.

114‐01 Michael

Kodama

OrangelineDevelopment

Authority

On January 11, 2012, the Orangeline Development Authority

Board of Directors voted to communicate to you its support for

including the OLDA Northern Corridor in the Constrained

Projects List for the 2012 Regional Transportation Plan. This

addition provides connectivity ncessary for the success of the

OLDA Southern Corridor (West Santa Ana branch), which is in

the constrained list. The OLDA Northern Corridor coincides with

much of the list of improvements being studied by Metro as the

Antelope Valley Line Infrastructure Improvement Strategic Plan

and the currently planned alignment of the California High

Speed Rail project. The likelihood that funds would be available

for these set of Improvements are enhanced by the

Memorandum of Understanding being negotiated for use of the

Proposition 1A (High Speed Rail) funds.

Comment noted.

114‐02 Michael

Kodama

OrangelineDevelopment

Authority

Recent events and planning efforts have focused attention on

the OLDA Northern Corridor from Downtown Los Angeles to

Santa Clarita. Based upon these efforts, OLDA would like to

suggest that the OLDA Northern Corridor be included in the

constrained plan (Antelope Valley Line). Specific planning efforts

in the corridor include; Bob Hope Airport ‐ The Burbank

Glendale Pasadena Airport Authority and OLDA are conducting a

$5.4 million Ground Access Study. The grant provides planning

and construction funds for improvements on the Antelope

Valley Line and has become a catalyst for OLDA Northern

Corridor improvements. The study focuses on multimodal

transportation improvements linking to the regional system,

including the feasibility of a new North Station on the Antelope

Valley Line at Hollywood Way and San Fernando Road. The

study has led to additional planning efforts that can lead to

significant improvements linking Santa Clarita to Downtown Los

Angeles. Further, the Airport is going to break ground on a

Comment noted. For a projec

the constrained RTP, the proj

have reasonably available fun

construction and right of way 

concurrence of the relevant c

commission/s. As discussed w

Authority, the Northern Corri

inclusion in to the future RTP 

conditions are satisfactorily m

section of the Passenger Rail 

developments brought up in 
314

ID Name Affiliation Comment Re

Regional Intermodal Transportation Center. More details are in

the SCAG RTP appendix entitled "Aviation and Airport Ground

Access."

114‐03 Michael

Kodama

OrangelineDevelopment

Authority

Antelope Valley Line Infrastructure Improvement Strategic Plan

‐ Metro is conducting a study to upgrade the Antelope Valley

Line. The 75 mile corridor runs at‐grade from Los Angeles Union

Station to Lancaster and includes plans for several capital

improvements. The Antelope Valley Line Study is providing the

plan to create a shared corridor involving not only current

Metrolink service but also part of the High Speed Train system.

Results of this study should be available in March 2012 and are

expected to include recommendations that meet many of the

OLDA goals and objectives.

Comment noted. The RTP dis

Study and includes capital im

Constrained Plan.

114‐04 Michael

Kodama

OrangelineDevelopment

Authority

Memorandum of Understanding ‐ In January, 2012, a MOU has

been developed between the California High Speed Rail

Authority, SCAG, Metro, SCRRA and many other local

transportation agencies. The MOU addresses advance

investment of up to $1 billion in Southern California as part of

the CHSRA's commitment to a "Blended Approach" to the

construction of the high speed train system in California. As you

are aware, this MOU is a significant document that allows for

this work to now be included in the Constrained portion of the

Draft RTP. This can lead to the planning and funding necessary

to include OLDA's Northern Corridor in the Constrained portion

of the RTP. Again, on behalf of the OLDA Board, we would like

you to work with us on how we can include the OLDA Northern

Corridor in the Constrained Project list for the 2012 RTP.

Comment noted.

115‐01 Paul Little Pasadena

Chamber ofCommerce

While we appreciate that a regional approach to traffic

management, transportation and goods movement we also

want to be sure that plans and implementations are truly

regional and economics and impacts to local economies are

given due consideration.

Comment noted. SCAG engag

economic experts and they h

provides a significant econom

economy. Please see Econom

part of the Final RTP/SCS for 

115‐02 Paul Little Pasadena

Chamber ofCommerce

For example, we would be very concerned about user‐based fee

proposals to fund transportation projects. For us, we could not

support any program or plan that would put the Pasadena area

at a competitive disadvantage economically. Traffic,

transportation, goods movement and customers need to be

able to access Pasadena as easily, simply and cost‐effectively as

our neighbors in the region.

Comment noted. We agree th

critically consider associated 

would result in the SCAG regi

an economic disadvantage. T

in the RTP financial plan assu

implementation.

115‐03 Paul Little Pasadena Plans for programs that will charge drivers a fee to get to Comment noted. We agree. T
315

ID Name Affiliation Comment Re

Chamber ofCommerce

Pasadena should be implemented region‐wide, not piecemeal,

and certainly not in the San Gabriel Valley first. If, for example,

congestion pricing schemes or toll roads are proposed, we

would want those implemented region‐wide, not in a way that

puts our area at a disadvantage economically as increased costs

to travel to, through or past Pasadena that do not exist in other

places, put Pasadena at a competitive disadvantage compared

to those places in the area that would not see those same

programs implemented and those additional costs imposed.

any fee imposed exclusively t

to San Gabriel Valley resident

SCAG region and its member 

disadvantage are critical cons

development of all funding p

115‐04 Paul Little Pasadena

Chamber ofCommerce

Likewise, and program or plan to assess fees to mitigate

development impacts need to be approved by the local

government and funds generated need to be used by those

local governments to reduce impacts in their area and existing

local fees should exempt businesses within those jurisdictions

from any additional costs.

Comment noted. The financia

revenues nor assume the imp

impacts fees for the City of Pa

Finance Appendix provides a 

sources and summarized the 

included in the RTP.

115‐05 Paul Little Pasadena

Chamber ofCommerce

We are also concerned that an agency with little understanding

of the Pasadena economy, our local business community or

community needs is proscribing programs, mitigation and

measures that may be inappropriate or unworkable in our local

jurisdictions. It is certainly prudent for SCAG, through the RTP,

to set goals for everything from pollutants in the air to the time

it should take to travel between cities in the region, but SCAG

should not be determining what programs will achieve those

goals, not what local costs will be able to achieve them.

Comment noted. The RTP/SC

programs, mitigation or othe

Pasadena. Local agencies reta

implement any of the program

RTP/SCS.

115‐06 Paul Little Pasadena

Chamber ofCommerce

We also appreciate the linking of land use policies with

transportation planning, however we do not see how many

local jurisdictions could achieve the goals, especially given the

elimination of redevelopment agencies by the State of

California. Quite simply, there is no mechanism for localities to

support development of any kind, especially not more dense

development in our downtowns that would like require

consolidation of properties. How is that to be accomplished

when there is no mechanism to capitalize such endeavors?

Comment noted. The elimina

jurisdictions' ability to finance 

intended to support the polic

continue to identify funding r

pursuing such policies.

115‐07 Paul Little Pasadena

Chamber ofCommerce

In fact, we are very concerned that the funding mechanisms

identified to finance projects will be very short of anticipated

levels, and that some of these mechanisms may never be

available as they are not currently implemented in California.

Comment noted. SCAG is wor

governments for SCS implem

funding for SCAG’s Local Sust

Program (e.g., Compass Bluep

Growth Council grants.

We recognize that the elimin

jurisdictions' ability to finance 
316

ID Name Affiliation Comment Re

intended to support the polic

continue to identify funding r

pursuing such policies.

115‐08 Paul Little Pasadena

Chamber ofCommerce

We are also concerned that, while it is important to move

goods, vehicles and persons easily through the region, we

should be very mindful of impacts to local streets and local

economies. Putting in a freeway does no good if the resulting

overflow traffic stifles local streets and strangles local business

districts.

Comment noted.

115‐09 Paul Little Pasadena

Chamber ofCommerce

Finally, the Pasadena Chamber of Commerce cannot stress

enough the importance of our local economies. Transportation

planning, like every other government endeavor, needs to fully,

accurately and appropriately take impacts to the local, regional

and state economy into consideration. The best transportation

plan imaginable is worthless if it stifles job and economic

growth and puts our region, and its cities at a competitive

disadvantage.

Comment noted. SCAG engag

economic experts and they h

RTP provides a significant eco

economy. Please see Econom

Appendix for more informatio

116‐01 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

Dear President O’Connor and Southern California Association of

Governments Regional Council Members: The undersigned

appreciate the dedication and efforts of the staff at Southern

California Association of Governments (SCAG) in completing the

Draft 2012 Regional Transportation Plan/Sustainable

Communities Strategy (2012 RTP/SCS). We are encouraged by

the recommendations in the plan that moves the region

towards an improved transportation system while improving

public health and air quality. The 2012 RTP/SCS includes many

smart growth strategies that will increase mobility, public health

and environmental health standards. As advocates for

improving public health and equity, we are encouraged to see

SCAG’s recommendations to: ∙ Increase investment in active

transportation strategies. ∙ Acknowledge that a regional zero

emission freight system is needed in the region. ∙ Discuss

gentrification issues as part of Environmental Justice. ∙ Monitor

premature mortality due to PM2.5. Though SCAG has shown

commitment to improving the region’s mobility, economy and

sustainability by including public health analysis in

transportation planning policies, more can still be done to

improve air quality, increase equity and improve our goods

movement system. The SCAG region faces immense public

health and environmental challenges, and the RTP/SCS must be

Comment noted. The RTP goo

that investments in transport

transportation programs contregion’s air quality goals. Effo

San Pedro Bay Ports have inv

trucks over the last several ye

are underway to establish a r

emission freight system. The 

recommendation to continue 

quality management agencie

our goal of a zero and/or nea

and analysis included in the E

does not account for Plan imp

particularly for truck only cor

are exclusively for zero and/o

Furthermore, the Program En

accompanying the RTP/SCS in

would reduce impacts associa

feet of freeways and high‐tra

significant. Analysis included 

account for emissions improv

implementation of these miti

emissions and exposure analy
317

ID Name Affiliation Comment Re

enhanced to address these issues. The SCAG region continues to

have the worst air quality in the nation and contains “14 non‐

attainment and maintenance areas in four air basins”.

Additionally, SCAG recognizes that 25% to 27% of the

population “within the freeway adjacent areas are projected to

see increases in their emission exposures to CO and PM”.

According to Figure 46 in the Environmental Justice Appendix,

close to 60% of the population residing within 500 feet from the

buffer area are Hispanic and in Quintile 1 (The Lowest Income

Household). The issues of air pollution are even more acute in

the SCAG region given the rampant prevalence of diesel

equipment used in the freight industry. Residents in close

proximity to highways, particularly those with high levels of

diesel trucks, will experience increased rates of cardiovascular

and respiratory disease, premature mortality, increased lung

cancer incidence, decreased life expectancy, reproductive

health problems, and increased asthma symptoms

abundantly conservative and 

outcomes. If these emission

accounted for, we believe the 

areas with worsened emissio

the Plan. Moreover, the curr

and on the distribution of hou

imprecise such that the overl

populations will tend to overs

Nevertheless, given on‐going 

on health impacts, SCAG enco

cognizant of any potential he

delivery. Consistent with the 

implemented as part of the p

in disseminating information 

to reduce risk at the project l

SCAG has shown a commitme

region through its Environme

trends observed in data from 

American Community Survey 

oriented developments (TOD

continue to evaluate and mo

framework presented in the E

economy is recovering.

116‐02 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

. As advocates for improving public health and equity, we are

encouraged to see SCAG’s recommendations to: ∙ Acknowledge

that a regional zero emission freight system is needed in the

region. ∙  

Comment noted. Emissions fr

a significant concern for the S

lane system identified in the 

facility used by zero‐emission 

Environmental Action Plan th

zero emission technologies in 

federal requirements.

116‐03 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

As advocates for improving public health and equity, we are

encouraged to see SCAG’s recommendations to: Discuss

gentrification issues as part of Environmental Justice.

Comment noted. While the E

some locations with emission

account for plan improvemen

particularly for truck only cor

are exclusively for zero and n

these emission improvement

believe the analysis would sh

the plan. As such, the emissio

the Draft EJ Appendix is abun

demonstrating worst‐case sce
318

ID Name Affiliation Comment Re

event that hot spots remain a

technology improvements, th

hot spots would overlay with 

available data on emissions n

and population is at a precise 

show where they would inter

evolving information on healt

project sponsors to be cogniz

project design and delivery. C

identified in the proposed fin

disseminating information an

reduce risk at the project leve

in analyzing gentrification in t

Environmental Justice (EJ) An

from the 2000 Census and 20

Survey (ACS) in areas with tra

are inconclusive. SCAG will co

the information based on the 

analysis in the future as the e

SCAG will also include potent

gentrification and displaceme

116‐04 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

As advocates for improving public health and equity, we are

encouraged to see SCAG’s recommendations to: ∙ Monitor

premature mortality due to PM2.5. Though SCAG has shown

commitment to improving the region’s mobility, economy and

sustainability by including public health analysis in

transportation planning policies, more can still be done to

improve air quality, increase equity and improve our goods

movement system. The SCAG region faces immense public

health and environmental challenges, and the RTP/SCS must be

enhanced to address these issues. The SCAG region continues to

have the worst air quality in the nation and contains “14 non‐

attainment and maintenance areas in four air basins”.

Additionally, SCAG recognizes that 25% to 27% of the

population “within the freeway adjacent areas are projected to

see increases in their emission exposures to CO and PM”.

According to Figure 46 in the Environmental Justice Appendix,

close to 60% of the population residing within 500 feet from the

buffer area are Hispanic and in Quintile 1 (The Lowest Income

Household). The issues of air pollution are even more acute in

Comment noted. The RTP goo

that investments in transport

transportation programs contregion’s air quality goals. Effo

San Pedro Bay Ports have inv

trucks over the last several ye

are underway to establish a r

emission freight system. The 

recommendation to continue 

quality management agencie

our goal of a zero or near‐zer
319

ID Name Affiliation Comment Re

the SCAG region given the rampant prevalence of diesel

equipment used in the freight industry. Residents in close

proximity to highways, particularly those with high levels of

diesel trucks, will experience increased rates of cardiovascular

and respiratory disease, premature mortality, increased lung

cancer incidence, decreased life expectancy, reproductive

health problems, and increased asthma symptoms.

116‐05 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

While we recognize that the goods movement sector is an

economic driving force in the region, we cannot sit by idly and

allow the immense damage to the health of our most

vulnerable communities persist. Given these challenges, we

recommend several improvements that must be made to

improve the RTP/SCS.

Comment noted.

116‐06 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

The RTP/SCS Must Do More To Promote Public Health

Protections, Active Transportation and Equity. The RTP/SCS is

the blueprint for years to come. As such, it must be designed to

promote public health through choosing better transportation

alternatives and making sure we spread the benefits of these

investments to all residents in the region, regardless of race,

income, or other social status. Moreover, we must make sure

we minimize exposure to environmental harms.

Comment noted. It should be 

in the report that while some 

emissions increases, this anal

improvements in vehicle tech

corridors. These corridors in 

and near‐zero emission vehic

improvements had been acco

would show no hot spots asso

emissions and exposure analy

abundantly conservative and 

scenario outcomes. Even in t

after accounting for vehicle te

no reliable way to conclude h

communities. Neither the av

distribution of households an

level of geography to show w

intersect. Nevertheless, give

information on health impact

sponsors to be cognizant of a

design and delivery. Consiste

proposed final PEIR, SCAG wi

information and identifying e

the project level. As to existin

future growth along the Free

be noted that currently the le

facilities is substantially highe
320

ID Name Affiliation Comment Re

and in 2035 these areas still w

region as a whole. SCAG is ve

interests between near roadw

from TODs as a result of activ

SCAG encourages researches 

feasible mitigation measures

However, regionwide air qua

comparing to either today’s c

the plan. While regional emis

now and 2035, the rate of de

volume roads is even greater

increase in population in thes

is higher for these individuals 

area. As such, subsequent pr

should be cognizant of on‐go

the plan as a whole shows be

decreased levels of risk in are

116‐07 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

II. The RTP/SCS Must Invest and Include Healthy and Equitable

Policies. Implementing this recommendation requires

addressing the following critical public health issues: A. Mitigate

PM and CO exposure in high quality transit areas. The 2012

RTP/SCS will redirect 51% of new housing near High Quality

Transit Areas (HQTA) providing an opportunity for healthy

communities. Redirecting the growth of new housing closer to

busy roads and freeways could violate the California Air

Resources Board’s recommended 500 feet freeway buffer, and

potentially increase CO and PM exposure and noise impacts.

SCAG has acknowledged that 25% to 27% households living

within freeway adjacent areas will see increases in their

emission exposure to CO and PM. In addition to monitoring

these areas for PM and CO, we recommend that SCAG also

project and map out the areas that may be impacted as a result

of the redirected growth up to the year 2035. We also

recommend for SCAG to include current mitigation strategies in

the EJ Toolkit and work with the local communities, health

advocates and stakeholders to continue developing policies that

will be included as part of the mitigation strategies for HQTA.

Comment noted. Data and an

Environmental Justice Appen

improvements in vehicle tech

corridors. These corridors in 

and/or near‐zero emission ve

Environmental Impact Report 

includes mitigation measures 

associated with health risk wi

traffic volume roadways to le

included in the Appendix also 

improvements through the im

measures. As such, emissions 

this Appendix is abundantly c

worst‐case scenario outcome

improvements had been acco

would show little or no areas 

spots”) associated with the P

available data on emissions a

households and population is 

with emissions and EJ popula

potential impacts. Neverthel

evolving information on healt

project sponsors to be cogniz
321

ID Name Affiliation Comment Re

project design and delivery. C

identified and to be impleme

PEIR, SCAG will assist in disse

identifying effective strategie

level. SCAG has shown a com

in the region through its Envi

trends observed in data from 

American Community Survey 

oriented developments (TOD

continue to evaluate and mo

framework presented in the E

economy is recovering. SCAG 

resources related to gentrific

EJ Appendix.

116‐08 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

B. Mitigate highway noise areas in communities of concern.

Highway noise areas are also disproportionate to environmental

justice communities with 22% of the affected population

residing within roadway noise areas and 14% of the households

below the poverty line. Noise impacts have been associated

with hearing impairment, hypertension and ischemic heart

disease annoyance and sleep disturbance. Further noise impact

mitigation studies should be utilized in future 2012 RTP/SCS

plans.

Comment noted. The Environ

includes recommended mitig

environmental justice commu

research is needed to better 

particularly in communities o

working with the Center for C

Environmental Justice to iden

be appropriate for future RTP

116‐09 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

C. Monitor and develop tools to avoid gentrification and

displacement in TODs. SCAG’s current analysis of 125 HQTA

around rail stations found that the demographics of HQTA/TOC

are changing. Poverty rates are declining in these areas when

compared to the rest of the region. These results show that

displacement and gentrification may be occurring in these

areas. As such, gentrification should be acknowledged and

policies need to be put in place to avoid this from happening. In

addition to tracking the 125 rail stations, SCAG should: 1. Track

commute time by race and income in Communities of Concern

(COCs) and compare it to the region. 2. Set a baseline for jobs‐

housing fit by taking a “snap shot” of 4‐to‐5‐mile buffer zone

around major job centers, and compare the wages provided by

those jobs to cost of housing within the buffer zone to see if

there is a good jobs‐housing fit. Continuing to monitor the

jobs/housing fit over successive RTP/SCSs will be an important

tool for transportation planning in rural, urban and suburban

Comment noted. SCAG has sh

gentrification in the region th

(EJ) Analysis. The trends obse

and 2005‐09 American Comm

transit oriented development

will continue to evaluate and 

the framework presented in t

economy is recovering.
322

ID Name Affiliation Comment Re

areas. 3. Use the Compass Blueprint Program to advance a

policy toolkit that highlights and recommends anti‐displacement

and anti‐gentrification policy options in TOD areas, as an eligible

subject for a Compass Blueprint grant proposal.

116‐10 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

III. The RTP/SCS Must Ensure That the Region has a Complete

Network of Transportation Strategies that Connect Travelers to

a Wider Range of Transportation Options. This entails

implementation of the following recommendations: A. Increase

investment in active transportation. In order to achieve true

walkable and healthy communities we recommend for SCAG to

increase its investments in Active Transportation strategies

beyond the $6 billion currently recommended.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

116‐11 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

B. Increase investment in public transportation. Prioritize

investment in bus rapid transit and taking existing infrastructure

to include bus‐only lanes instead of expanding highway toaccommodate for additional capacity.

Comment noted. The 2012 RT

transit capital, $51.8 billion fo

operations funding. 46.9% of 

transit or rail.

116‐12 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

C. Access, mobility and safety. In order to better connect the

region that depends on non‐motorized modes of

transportation, first‐mile/last‐mile strategies should also include

close‐the‐gap strategies that integrate active modes of

transportation to allow for accessibility to employment and

services. To better do this, SCAG should identify geographic

areas with high concentrations of communities of concern and

track their transportation access, cost, mobility, rent, and

gentrification and displacement patterns (using the seven

indicators to track early signs of displacement or gentrification).

The data can be used in future RTP/SCS and determine where

close‐the‐gap strategies would best serve the region and

address any adverse impacts that transportation projects can

cause to communities of concern. SCAG should also use the

data to determine what communities are underserved by

Comment noted.
323

ID Name Affiliation Comment Re

transportation projects and connect those underserved

communities to high opportunity areas.

116‐13 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

IV. SCAG Must Support Federal Policies That Benefit Active

Transportation. Given the current state of the federal

transportation bill and efforts to strip dedicated funding from

MAP‐21 in the Senate and the House American Energy and

Infrastructure Jobs Act in the House, we are concerned that

expected federal revenues for bicycle and pedestrian

enhancements may not materialize.

Comment noted.

116‐14 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

To this end we request that SCAG fully support an amendment

offered by Senator Lautenberg in the EPW Committee to ensure

that total funds available in the “additional activities” reserve

fund in MAP‐21 for Recreational Trails, Safe Routes to School,

and bicycle and pedestrian investments are equal to those

currently in SAFETEA‐LU. Additionally, this amendment would

ensure that regions within states are able to have direct and

first access to these funds so that cities throughout the SCAG

region are able to directly apply for and receive funding for

important bicycle and pedestrian projects. As the Senate bill

progresses to the floor there will be opportunities for Senator

Boxer to incorporate these provisions into the final bill and it is

important for SCAG to make clear it supports them.

Comment noted.

116‐15 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

V. The Freight Strategies in the RTP/SCS Must Be Improved. We

remain deeply concerned about the freight elements of the

RTP/SCS. While the plan acknowledges the need to move to

zero emissions technologies, it provides little substance on how

it will actually happen.

Comment noted.

116‐16 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

The RTP must be more rigorous. To support this, we suggest the

following improvements to the freight elements of the plan. A.

The RTP/SCS must actually require creation of a zero‐emission

truck and freight goods movement for the region. Several issues

must be addressed in the 2012 RTP/SCS before it is adopted

with regard to how freight is moved through the year 2035.

Goods movement strategies must ensure that the South Coast

Air Basin meet federal air quality standards set forth in the

Clean Air Act.

Comment noted. SCAG does 

such policies. However, the re

identified in the 2012 RTP is e

zero‐emission/near‐zero‐emi

opportunity to incentivize the 

technologies for regional freig

support efforts by regional pa

goods movement emissions a

116‐17 Patty Ochoa Physicians for

Social

Currently, the plan provides little detail on this issue, including

how black box reductions will be achieved from the substantial

Comment noted.
324

ID Name Affiliation Comment Re

Responsibility,and OtherOrganizations(collaborativeletter)

portion of emissions from freight.

116‐18 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

While we agree with the many experts who “question the long‐

term viability of continued reliance on fossil fuels,” the RTP/SCS

lacks details on how best to actually achieve this goal

Comment noted.

116‐19 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

The “uncertainty of a petroleum‐based future” needs to be at

the forefront of the 2012 RTP/SCS where any expansion plans

that increase a petroleum‐based roadway system and raise

Vehicle Miles Travel (VMT) must be curtailed.

Comment noted.

116‐20 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

The RTP/SCS needs to do more than just put words on paper

about the need for this system. Future projects must be

required to incorporate these technologies or they should not

be built.

Comment noted. SCAG does 

such policies. However, the re

identified in the 2012 RTP is e

zero‐emission trucks. This sys

incentivize the adoption of cl

for regional freight movemen

efforts by regional partners a

movement emissions and imp

116‐21 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

Financing these cleaner technologies is an important

consideration for SCAG. Ensuring that funding mechanisms are

in place to expedite the implementation of the zero and near‐

zero emission freight and truck strategies should be a central

component of the strategy. For these reasons, we recommend

that SCAG consider including the following funding strategies: 1.

Develop a clear assessment of various financing options

including various models of public‐private partnerships that

could make zero‐emission technology options possible.

Recommend a $30 per twenty‐foot container fee for moving

either into or out of the ports. This strategy could generate as

much as $441 million in revenue from loaded containers in its

first full year of implementation, when applied equally to

Comment noted. SCAG will w

and stakeholders to identify p

appropriate.
325

ID Name Affiliation Comment Re

imports and exports

116‐22 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

Use currently available clean truck technology and incentivize it

through funding and or by way of preferential access lanes at

terminals

Comment noted.

116‐23 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

Reinstitute the diesel truck fee to incentivize clean, alternative

fuel trucks.

Comment noted.

116‐24 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

B. The RTP/SCS must implement near‐term solutions to reduce

greenhouse gas emissions from freight. We are deeply

concerned that the projected increase in freight volumes and

traffic will undermine the gains of the 2012 RTP/SCS in other

areas. In particular, CO2 emissions from trucks would increase

at least 30% by 2023 and at least 60% by 2035.

Comment noted. The 2012 RT

establishes a plan to advance 

Many of these technologies w

116‐25 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

Even more dramatically, CO2 emissions from rail would increase

at least 50% by 2023 and at least 123% by 2035.

Comment noted. The 2012 RT

establishes a plan to advance 

Many of these technologies w

116‐26 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

Given that “This RTP Goods Movement Environmental Strategy

was developed to address community concerns, federal

attainment requirements, and climate change issues,” it is

problematic that near‐term solutions are not more fully

articulated.

Comment noted. The 2012 RT

decision points to move the r

emissions freight transportat

has been provided about nea

116‐27 Patty Ochoa Physicians for

SocialResponsibility,

Near‐term strategies to clean up goods movement must be fully

integrated into the 2012 RTP/SCS.

Comment noted. Further clar

near‐term solutions as appro
326

ID Name Affiliation Comment Re

and OtherOrganizations(collaborativeletter)

116‐28 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

We would like to work with you before the final version of the

2012 RTP/SCS to resolve this deficiency.

Comment noted. SCAG has p

input to the 2012 RTP. This in

SCAG RTP website, policy and 

eighteen public workshops he

eighteen additional workshop

following the release of the D

were held in every county in t

various interests such as resid

representatives of public age

and environmental, housing a

see the SCAG 2012 RTP Public 

http://www.scagrtp.net/cont

continue to work with partne

adoption of the 2012 RTP.

116‐29 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

Indeed as stated “For trucks, an aggressive program to bring

more currently available, clean fuel trucks and hybrid trucks into

service represents the best near‐term strategy.” Yet no such

program is identified for either trucks or rail.

Comment noted.

116‐30 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

The ports of Los Angeles and Long Beach have left a gaping hole

in clean air planning by not establishing targets and reduction

plans for greenhouse gases (GHGs).

Comment noted.

116‐31 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

SCAG and the 2012 RTP/SCS should demand that the Clean Air

Action Plan be augmented with GHG reduction plans. Both ports

have in the past promised to have such plans but neither has

released one.

Comment noted.

116‐32 Patty Ochoa Physicians for Such plans should complement and accelerate SCAG’s vision for Comment noted.
327

ID Name Affiliation Comment Re

SocialResponsibility,and OtherOrganizations(collaborativeletter)

increased efficiencies and the deployment of cleaner

technologies.

116‐33 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

While we commend the steps to evaluate and seek funding for

longer‐term zero and near‐zero emissions technologies, the

severity of the pollution and congestion from freight activities

merits additional attention in the near‐term.

Comment noted. The 2012 RT

decision points to move the r

emissions/near‐zero‐emission

Further clarification has been 

technologies as appropriate.

116‐34 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

And while the 2012 RTP/SCS rightly considers heavy‐duty trucks

and rail emissions, it would be worth devising a set of strategies

that account for the differences among local freight service and

that of port origin/destination.

Comment noted. SCAG concu

how the operational requirem

different markets would impa

116‐35 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

Similarly, the sector of medium duty trucks may be targeted for

technology improvements, given that it is the sector’s 2nd

largest emitter of NOx

Comment noted.

116‐36 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

In the section On‐Dock/Near‐Dock Rail Capacity Enhancements,

the 2012 RTP/SCS appropriately expresses preference for on‐

dock rail “By allowing more on‐dock rail, truck traffic between

the San Pedro Bay Ports and distant rail yards can be reduced.

Use of on‐dock rail eliminates truck vehicle miles of travel (VMT)

and associated emissions”

Comment noted.

116‐37 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborative

SCAG should demand a sequencing of projects that maximizes

on‐dock rail and that reduces constraints on the expansion of

on‐dock capacity in advance of projects that expand off‐dock

capacity. Without appropriate sequencing, efficiencies could be

lost.

Comment noted. SCAG works 

including the San Pedro Bay P

implementation of regionally

However, SCAG does not dete

implementation of projects a
328

ID Name Affiliation Comment Re

letter)

116‐38 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

VI. The RTP/SCS Must Remove the East‐West Corridor Route

Project. Recommending to build an east‐west corridor without

analyzing the health, housing and demographic impacts of the

project on the neighboring communities can have severe

environmental, health and justice implications for the region

and particularly for local communities of concern (COC).

Comment noted. The regionathe 2012 RTP is envisioned to 

emission/near‐zero‐emission

and demographic impacts fro

alignment identified as part o

in more detail through an Env

SCAG also continues to suppo

stakeholders to address good

impacts on communities.

116‐39 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

Additionally, if the east‐west corridor project goes forward, an

increase in truck traffic per day (from 58,000‐78,000) could

increase noise pollution and air pollution

Comment noted. The regiona

the 2012 RTP is envisioned to 

emission/near‐zero‐emission

air quality impacts from the E

alignment identified as part o

in more detail through an Env

116‐40 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

The Goods Movement Environmental Strategy and Action Plan

schedules full operational deployment of zero and near zero‐

emissions for trucks in 2018.

Comment noted. For clarifica

Environmental Strategy ident

zero emission trucks beginnin

2035.

116‐41 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

This plan prematurely predicts that the infrastructure, market

and technology will be available for use without taking into

consideration funding shortfalls and without putting in place

earlier interventions.In the meantime, east‐west corridor

adjacent communities will be adversely impacted by

displacement, or over‐burden suffering from adverse health and

quality of life impacts associated with the construction of the

project and the trucks that will eventually utilize the route.

Comment noted. The East‐W

to serve as a platform for the 

emissions/near‐zero‐emission

specific technology has yet to 

zero‐emission/near‐zero‐emi

SCAG will work closely with it

stakeholders to identify appro

the East‐West Freight Corrido

Corridor offers the possibility 

quality impacts to those com

volume corridors.

116‐42 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations

SCAG must go beyond investing in research and guarantee that

all lanes classified as zero‐emission truck‐only lanes only be

used by zero‐emission trucks.

Comment noted. The regiona

the 2012 RTP is envisioned to 

emission/near‐zero‐emission

opportunity to incentivize the 

emission/near‐zero‐emission
329

ID Name Affiliation Comment Re

(collaborativeletter)

movement. SCAG continues t

partners and stakeholders to 

emissions and impacts and en

emission/near‐zero‐emission

116‐43 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

Before considering adding this project [East West Corridor] to

the RTP/SCS, SCAG must address the following: 1. Provide

health and community demographic data on impact on the

east‐west corridor project. Specifically data that shows potential

neighborhoods which may be displaced, noise and air quality

impacts on surrounding communities, race, class, socio‐

economic status of the communities that will be impacted and

how many of them are COCs.

Comment noted. The East‐W

to be a facility used by zero‐e

trucks and anticipated to red

for adjacent communities. Th

alternatives would be analyze

Environmental Impact Report 

impacts would also be analyz

116‐44 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

2. Develop an analysis of the local roadway systems that trucks

will utilize once they have reached their destination.

Comment noted. Specific rou

influenced by numerous varia

volumes, seasonality, land‐us

etc.). Models are used to dete

used by trucks including freew

of the specific impacts upon l

in more detail through an Env

116‐45 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

3. Develop an analysis of the total number of on‐ramps and off‐

ramps planned for the east‐west corridor, an approximation of

where they will be (i.e. which streets will be used for entering

and exiting the east‐west corridor), and the configuration/style

of each on‐ramp and off‐ramp.

Comment noted. Specific ingr

West Freight Corridor would 

through an Environmental Im

116‐46 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

4. Define the performance measures that would outline how

success would be measured for the proposed east‐west

corridor, including anticipated truck traffic counts.

Comment noted. Specific me

were utilized for preliminary 

alignments. Further work wo

defining specific performance 

West Freight Corridor under f

116‐47 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

5. Set outreach and communication guidelines that allow for

greater public participation from the general public and

pertinent partners and timely feedback to questions asked.

Comment noted. SCAG will co

regional partners and stakeho

Corridor. An Environmental Im

require significant outreach a

and the public.
330

ID Name Affiliation Comment Re

116‐48 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

6. Include an outreach and engagement plan that includes

impacted COCs, stakeholders and health advocates, as part of

the Goods Movement and Environmental Strategy Action Plan.

Comment noted. SCAG will co

regional partners and stakeho

Corridor. An Environmental Im

require significant outreach a

and the public.

116‐49 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

VII. SCAG Must Support National Efforts to Create a Strategic

Plan for the Freight System. Given the limitations with funding

our goods movement and particularly the zero emissions and

near zero emissions freight strategy, we encourage SCAG to

include language that clarifies the current federal funding

constraints and alter the 2012 RTP/SCS to reflect that these

revenues are assumed but not assured and are contingent upon

passage of the MAP‐21 program on page 95 and 100.

Comment noted.

116‐50 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

As a revenue source the inclusion of this funding is still in doubt

as the current iteration of the House American Energy and

Infrastructure Jobs Act does not include a national freight

program or any dedicated freight funding and the establishment

of this program is contingent upon a freight program making its

way into the final federal transportation reauthorization and

that legislation passing through both Senate and House.

Comment noted.

116‐51 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

SCAG should actively support the passage of a federal freight

program that would deliver these revenues and clearly establish

improving public health on the freight network and adjacent

communities as an overarching priority and goal of the federal

freight program, and support the inclusion of Senator

Lautenberg’s Freight Act of 2011 in the final federal

transportation reauthorization with the competitive grant

program and the goals and objectives as written.

Comment noted. SCAG, in co

partners, continues to activel

freight program.

116‐52 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

We support the addition of this language as offered by Senator

Lautenberg and the inclusion of Senator Lautenberg’s FREIGHT

Act of 2011(Focusing Resources, Economic Investment, and

Guidance to Help Transportation) in the Commerce Committee

bill S. 1950 the Commercial Motor Vehicle Safety Enhancement

Act of 2011 which would create a national strategic plan for the

freight system, a competitive grant program, and establish clear

goals and objectives including reducing emissions, improving

safety and efficiency, enhancing economic competitiveness, use

of innovative technologies, and improving the state of repair of

Comment noted. SCAG, in coo

partners, continues to activel

freight program.
331

ID Name Affiliation Comment Re

existing infrastructure.

116‐53 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

VIII. The RTP/SCS Must Focus Attention on Cleaning Up Existing

Freight Corridors, Not Just the Proposed New Projects. While

we welcome zero emission technology by the year 2035, more

short term gains must be implemented.

Comment noted. As part of th

supports a number of regiona

intended to address the move

Southern California. These pr

through analysis and collabor

stakeholders and can be foun

Additionally, following the ad

release the final version of th

Movement Plan and Impleme

effort to identify a fully‐integ

system.

116‐54 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

SCAG should incorporate what can be done until a majority of

truck traffic is zero or near zero emissions and consider using

currently available technology while working to demonstrate

future technology applications (such as maglev technology).

Comment noted. Emissions fr

a concern for the SCAG region

efforts by regional partners a

movement emissions and imp

initiatives as the San Pedro Ba

116‐55 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

Additionally, SCAG member governments must include a zero

emission corridor from the ports to the ICTF or along Alameda

Street and strengthen specific requirements in new projects

beyond “bare minimum” standards used in current projects.

Comment noted. Further clar

text of the RTP.

116‐56 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

IX. The RTP/SCS Must Include Public Health as an Overarching

Goal of the Goods Movement Element. More and more

research is associating air pollution with asthma prevalence,

poor lung function and a series of other health impacts. The

California Air Resources Board states that the “prevalence of

asthma in the U.S. has increased by more than 75% since 1980”.

Furthermore results from the USC Children’s Health Study, a ten

year study, show that children in Southern California’s more

polluted communities “suffer reduced growth of lung function,

asthma exacerbations, more school absences, and new onset

asthma”.

Comment noted. The RTP/SC

various demographic groups. 

Environmental Justice analysi

mapped exposure to ozone, c

emissions, cancer risks, and r

assess the impact of emission

throughout the region, emiss

to the Environmental Justice 

Program Environmental Impa

a Health Risk Assessment in A

Environmental Justice Appen

health impacts on children 5 

recognition of this important 
332

ID Name Affiliation Comment Re

116‐57 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

The public health evidence is growing. Our built environment

plays a direct impact to our health and the transportation sector

must take into consideration the public health implications to

the region, and not just the region’s economic growth.

Comment noted.

116‐58 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

SCAG must: 1. Include public health as an overarching goal in

the Goods Movement Element and include performance

standards to measure improvements.

Comment noted. Public healt

Environmental Strategy and i

performance measure section 

116‐59 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

2. Include public health as an overarching and priority and goal

in the $2.1 billion annual freight program included in the

Environment and Public Works Committee.

Comment noted.

116‐60 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

3. Prioritize spending on projects that deliver maximum health

benefits for residents of the region, especially in low income

communities of color overburdened by air pollution and higher

rates of uninsured residents.

Comment noted.

116‐61 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

X. Public Participation Failures Must Be Remedied. Outreach

and education to the public, especially on the onset on this

process, was not sufficient to ensure that an adequate

representation of members from impacted communities

participate and give meaningful input.

Comment noted. SCAG has pr

input to the 2012 RTP. This in

SCAG RTP website, policy and 

eighteen public workshops he

eighteen additional workshop

following the release of the D

were held in every county in t

various interests such as resid

representatives of public age

and environmental, housing a

see the SCAG 2012 RTP Public 

http://www.scagrtp.net/cont
333

ID Name Affiliation Comment Re

continue to work with partne

adoption of the 2012 RTP.

116‐62 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

There were not enough public meetings or an adequate

outreach strategy to ensure that there was more community

involvement in this important process.

Comment noted. SCAG has p

input to the 2012 RTP. This in

SCAG RTP website, policy and 

eighteen public workshops he

eighteen additional workshop

following the release of the D

were held in every county in t

various interests such as resid

representatives of public age

and environmental, housing a

see the SCAG 2012 RTP Public 

http://www.scagrtp.net/cont

continue to work with partne

public outreach efforts follow

116‐63 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

Furthermore, a Goods Movement Steering Committee was

established under SCAG to provide guidance and

recommendations to SCAG’s 2012 RTP/SCS; however, no formal

process was established to receive formal recommendations

from this group on the 2012 RTP/SCS.

Comment noted. SCAG has pr

input to the 2012 RTP. This in

SCAG RTP website, policy and 

eighteen public workshops he

eighteen additional workshop

following the release of the D

were held in every county in t

various interests such as resid

representatives of public age

and environmental, housing a

see the SCAG 2012 RTP Public 

http://www.scagrtp.net/cont

continue to work with partne

public outreach following the 

116‐64 Patty Ochoa Physicians for

SocialResponsibility,and OtherOrganizations(collaborativeletter)

We commend SCAG for completing the first Sustainable

Community Strategy for the region and look forward to working

with SCAG to ensure that it truly is a successful SCS by

prioritizing health and equity.

Comment noted.

117‐01 Eric Shen Port of Long

Beach

On behalf of the Port of Long Beach, thank you for the

opportunity to review and comment on the draft 2012‐2035

Regional Transportation Plan/Sustainable Communities Strategy

Comment noted.The statistic 
334

ID Name Affiliation Comment Re

(RTP/SCS), including the Goods Movement Report contained

within the RTP/SCS and the draft Program Environmental

Impact Report. In general, we find these reports are well‐

written and accurate with respect to maritime activities. We

would like to offer one minor correction. Maritime Ports The

statistic for the Ports of Long Beach and Los Angeles in the

second paragraph, second sentence of the PEIR on page 3.12‐15

is incorrect. The ports of Long Beach and Los Angeles combined

are the world's sixth‐busiest port complex in 2011 (15.8 million

total TEU), after Singapore (23.2 million TEU), Hong Kong (22.4

million), Shanghai (18.1 million) and Shenzhen, China (16.2

million). As noted in the PEIR, 34% of the jobs in the region

depend on the goods movement industry. However, our region,

with a combined population over 18 million residents, is bearing

the brunt of traffic congestion, safety and air quality impacts.

The Port of Long Beach is committed to developing programs

that will support the anticipated growth in trade activities with

minimum impact on the region’s environment. The Port cannot

do it alone – and we stand ready to work with you in

implementing programs envisioned in the Regional

Transportation Plan/Sustainable Communities Strategy.

118‐01 Eric Shen Port of Long

Beach

California Coastal Trail: Please revise the map shown as Exhibit

19 to reflect the Coastal Trail route connecting San Pedro and

Long Beach via Terminal Island. This is consistent with recent

plans to include a Class 1 Bike Path as part of the Gerald

Desmond Bridge Replacement Project, including Coastal

Commission’s condition of approval on the Harbor Development

Permit for the project. The Class 1 Bike Path is also consistent

with both the cities of Los Angeles and Long Beach Bicycle

Master Plans.

Comment noted. Exhibit 19: C

is being proposed by the Calif

proposing the CCT go over th

(Replacement) and the Gerald 

based on the California Coast

endorsement of the Gerald D

Active Transportation Append

reflect that proposal.

119‐01 Eric Johnson Puente‐Chino

Hills Task

Force of the

Sierra Club

Thank you for the opportunity to comment on the Southern

California Association of Governments (SCAG) 2012 Regional

Transportation Plan (RTP) and Sustainable Community Strategy

(SCS). The Puente‐Chino Hills Task Force of the Sierra Club is

based in Brea but our members come from the four counties

that touch the Puente‐Chino Hills. We offer hikes, sponsor

educational events and provide input on projects that threaten

the biological and recreational integrity of this important region.

We are writing to provide comments on the Draft 2012 RTP/SCS

and the Draft Program Environmental Impact Report (PEIR). We

Comment noted. The propose

pursue a strategic planning p

resources. The intent is to inc

based on input from a wide v

has been clarified.
335

ID Name Affiliation Comment Re

are so pleased to see an advanced mitigation component in the

Draft 2012 RTP/SCS. This is a remarkable first step to creating a

program that thoughtfully mitigates impacts to our natural

environment from transportation projects. As you know,

Orange County and San Diego have similar programs that have

met great success. By incorporating this strategy into your

policy document, the many benefits of this large‐scale

conservation approach will be realized. Thank you for your

leadership. Under the Endangered Species Act, the United

States Fish and Wildlife Service have defined critical habitat as

areas that support endangered or threatened species that are

essential to the species’ conservation. The description in the

Conservation Planning Policy section (page 76 of the Draft 2012

RTP/SCS) states “large‐scale acquisition and management of

critical habitat to mitigate impacts related to future

transportation projects” [emphasis added]. We believe there

are other habitat areas in the SCAG region worth considering for

acquisition and management and therefore SCAG should not

limit the mitigation opportunities to only critical habitat. We

suggest expanding the language to incorporate all “important

habitat lands.”

119‐02 Eric Johnson Puente‐Chino

Hills Task

Force of the

Sierra Club

On page 79 of the Draft 2012 RTP/SCS we were encouraged to

see SCAG recognize the benefits of reducing transportation

impacts to sensitive lands and encouraging smart land use

decisions. We believe landscape level advanced mitigation will

become a statewide planning policy. Planning future

transportation projects with a comprehensive mitigation

program ensures our open space infrastructure can continue to

function and maintain viable habitats, linkages, and species

populations in perpetuity. Unfortunately, we noticed the lack of

inclusion of wildlife linkages in this section. Orange County’s

transportation measure language included wildlife linkages and

we recommend SCAG include linkages as well.

Comment noted. The mitigat

Resources and Open Space in

of habitat linkages, preservat

crossings to minimize the imp

wildlife species and habitat fr

119‐03 Eric Johnson Puente‐Chino

Hills Task

Force of the

Sierra Club

We appreciate SCAG’s effort to create a strategic planning

process that would document important conservation lands in

the region. We believe there is an important opportunity with

this concept to also create a Southern California Greenprint. By

completing a Greenprint a comprehensive view of our open

space land attributes would be documented. Such attributes

include: recreation priorities, agricultural lands, scenic values,

Comment noted. The propose

pursue a strategic planning p

resources. The intent is to inc

input from a wide variety of s

possible option for the mitiga

discussed with a wide variety 
336

ID Name Affiliation Comment Re

historic preservation, and more. A Greenprint would give a

more complete picture of both opportunities and challenges,

while at the same time respecting property rights.

120‐01 Carol Banner Realtors

Committee on

Air Quality

Comments on the Draft RTP/SCS. The RCAQ finds that the Draft

Plan does not discuss or quantify the impact of the Plan on the

affordability and availability of housing in the region. This

information is of the utmost importance to the public and to

elected officials in order to understand the consequences of

increased infill development, density, open space preservation

and other proposals in the Draft Plan that will change the size,

type, cost and distribution of housing in the region. The impact

that these strategies will have on housing affordability, and

home ownership rates must be explained. At present, the Draft

Plan discusses the changing population composition and a shift

to multifamily housing in only the most general terms. The

Scenario Outcomes on page 116 look at energy costs and water

cost‐ but fail to examine housing costs. The Economic Impact

Technical Report is silent on the housing cost and affordability

impacts of the proposed major shifts in the housing supply.

Recommended Revision: We request that the final Plan include

a discussion in the SCS chapter that both qualitatively and

quantitatively summarizes the proposed plan's impact on

housing cost and affordability.

Comment noted. The Environ

analysis of key indicators and 

development areas that conc

gentrification using 2000 Cen

Community Survey data. The 

will continue to monitor thes

jurisdictions in California mus

plan housing elements. The h

through a sites and zoning an

accommodate projected hou

groups as determined by the 

Assessment (RHNA). The draf

developed using the same int

2012 RTP/SCS. To ensure that 

for all types of housing, partic

RHNA Plan applies a social eq

disproportional distribution o

jurisdictions groups in order t

affordable housing.

120‐02 Carol Banner Realtors

Committee on

Air Quality

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

121‐01 Jeffrey Dinkin Regent

Properties

The SCS does not appear to account for projects already in

process. Regent has several projects with pending applications

that represent a substantial investment of resources to design,

plan, and communicate with responsible agencies. While the

SCS itself states that it was created with input from local

jurisdictions, we are concerned that the growth projections

contained in the SCS and Land Use Pattern Maps do not in fact

reflect the land use decisions made by local jurisdictions. more

specifically, while the draft RTP/SCS indicates that it shifted

projected densities from less developed areas to the urbanized

core, nowhere does the SCS clearly state that those shifts in

density take into account development projects that are either

already approved or that are reasonably foreseeable projects

which local jurisdictions have already spent considerable

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as

trends occurring in many tran

the SCS is intended to provide 

local governments may build 

generally includes the quantit

each city and county in the re

jurisdictions maintain local la
337

ID Name Affiliation Comment Re

resources processing.

121‐02 Jeffrey Dinkin Regent

Properties

Underlying TAZ data must be released to allow meaningful

public comment. Moreover, the SCS's treatment of approved

projects is impossible to determine from the information that

SCAG has made available to the public. The 2035 Land Use

Pattern Maps, which are intended to depict projected density

and land use, are at such a large scale, with such slight color

gradations, that they cannot be interpreted in any meaningful

way. The SCS itself does not seem to contemplate that these

maps will be important to future transportation and land use

decisions. Instead, the SCS focuses on the projected density

contained in the data that underlies the maps‐‐data that SCAG

has not released to the public. The SCS states that the land use

projections contained in the SCS are based on the distribution of

growth forecast data to TAZs (RTP/SCS, p 122). According to the

SCS, the TAZ data contains forecasted housing, population and

employment data, which the SCS used to create "Community

Types" and more refined "development types" that contain

average use designations, densities and building intensities. The

SCS states that a development type, including an average

residential density, has been assigned to each TAZ for purposes

of creating the SCS (Draft RTP/SCS p 123). However, it cannot be

determined whether this assignment was made in a manner

that takes existing conditions (including approved and

reasonably foreseeable projects) as a baseline for these

projections, nor can it be determined how the forecasting was

done or how it was distributed across the TAZ. Despite the

critical role of the TAZ data in developing the SCS, we are not

aware that SCAG has made this data available for public review

and comment in any meaningful way. We were able to obtain

partial [TAZ] data showing housing densities only, from other

agencies involved in the SCS process. These data do not contain

employment or population forecasts, and do not contain any

community type or development type designations which,

according to the SCS, have been assigned to each TAZ. It is not

possible for the public to provide meaningful comment on the

SCS without access to the underlying data on which density and

land use projections are based. In the absence of the underlying

data and modeling supporting the proposed plan, we are

substantially impaired in our ability to provide meaningful

Comment noted. The TAZ‐lev

the purpose of modeling perf

local jurisdictions, maintain th

determine consistency of any 

TAZ‐level dataset was provide

comment period.
338

ID Name Affiliation Comment Re

public comment on the technical and legal adequacy of the

plan. In particular, we cannot assess whether the underlying

data adequately reflects all developments as approved. Under

the federal (5 U.S.C. S500 et. seq) and California Administrative

procedures Acts (Gov. Code SS11340 et. seq., including S

11346.2(b)(6)), the opportunity for public comment must

include disclosure of the data and technical studies in time to

provide meaningful public comment. See e.g. Solite Corp v. EPA

952 F.2d 473, 484 (D.C. Cir. 1991( (per Curiam). While we are

not confident that the data is either accurate or complete, we

have reviewed what data we were able to obtain. Based on our

review, we conclude that the forecasted housing densities do

need to be corrected, as the numbers clearly do not reflect

either existing entitlements or pending, reasonably foreseeable

projects.

121‐03 Jeffrey Dinkin Regent

Properties

Implications of Consistency with underlying TAZ data. The

importance of TAZ data is not limited to understanding how the

SCS was created. In addition to being the basis for creation of

the SCS land use projections, according to the SCS, the TAZ data

is to be relied on in future determinations as to whether a

project is consistent with the SCS...Despite these explicit

statements that the existing TAZ data will be critically important

to future decisions affecting projects, SCAG has not provided

the public the opportunity to review and comment on the TAZ

data in any meaningful way. Significantly, a project's consistency

with the SCS ‐‐ which is to be determined at the TAZ level

according to the SCS ‐‐ affects not only the availability of CEQA

streamlining incentives, but can have adverse consequences for

the availability of federal funds for transit improvements that

would serve the project. Transit improvement projects relying

on federal funds must be consistent with an approved RTP, and

with the adoption of SB 375, that includes consistency with the

SCS portion of the RTP as well. Thus, if the draft RTP/SCS has

shifted density away from approved or pending projects, those

projects stand to lose critical transit improvements. The loss of

transit improvements could impair project feasibility, or create

new unmitigated impacts if traffic mitigations become

unfunded, which could result in an unlawful taking of private

vested property rights for those projects that have already been

approved by local jurisdictions. In many cases, approved

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.
339

ID Name Affiliation Comment Re

projects also involve executed development agreements, which

means that violation of contractual rights could also result,

causing difficult situations for developers and local jurisdictions.

We are concerned that a project’s inconsistency with the

growth projections contained in the SCS may have broader

implications as well. Local jurisdictions will be under

considerable pressure to conform their general plans to the

density, intensity, and land uses contained in the SCS, or risk

losing transportation funding throughout their jurisdictions.

While all the implications of a project’s inconsistency with the

SCS have yet to be determined, we are concerned that by

shifting density away from locally approved and pending

projects, the SCS is creating land use policy in violation of SB

375's mandate that the SCS must not supersede the land use

authority of cities and counties.

121‐04 Jeffrey Dinkin Regent

Properties

RTP/SCS consistency should be determined at the jurisdictional

level. The TAZ maps are a modeling tool for engaging in a

regional planning and evaluation process. The feasibility of

achieving the precise results in any particular TAZ area has not

been evaluated or confirmed by any city council or board of

supervisors, and as explained above it appears that the TAZ data

and maps for 2035 do deviate from general plans and vested

entitlements that have been approved by those elected

officials. While we understand elected bodies or senior

administrative staffs of local jurisdictions may have approved

local input for the overall population and household numbers

within their respective jurisdictions, we believe they have not

approved the TAZ data or maps. Accordingly, requiring

consistency determinations concerning use designations,

density, and building intensity at such a small scale of each TAZ

would be inappropriate and overly prescriptive...There is no

legislative mandate that SCAG identify the location of land uses,

densities, and building intensities within the region more

precisely down to a TAZ level. Instead, SCAG should

appropriately identify these characteristics at a level consistent

with the need for reasonable flexibility and local control. At

lowest, the level of comparison should be at the jurisdictional

level ‐ particularly given that there are nearly 200 jurisdictions

within the SCAG region. Accordingly, we urge SCAG to identify

such characteristics at no finer a scale than at the lesser of the

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.
340

ID Name Affiliation Comment Re

(i) jurisdiction , and the (ii) sub‐region (i.e., where

unincorporated county land is divided into sub‐regions). Despite

SB 375’s mandate that the SCS not regulate land use, the draft

RTP/SCS “shifts” households “from the periphery into the

urbanized core” stating that much of this shift “will occur

naturally in the marketplace,” and that this “shift” was done

“per consultation with the local jurisdictions.” (Draft RTP/SCS p.

128). However, this shift does not “occur naturally,” nor

through a “consultation” process between agency staff that

excludes the public. Instead, such a shift can only occur, if at all,

as part of a separate and lengthy discretionary development

application process involving requests to local land use

jurisdictions to amend their general plans, specific plans, area

plans, and zoning. In short, there is no “shift” to high‐density

housing in some local jurisdictions, and away from housing

density already approved by other jurisdictions, unless and until

the local land use jurisdictions adopt the requested

discretionary approvals.

122‐01 Sandy Cajas Regional

HispanicChamber ofCommerce

For the past three years, business and industry representatives

from throughout Southern California have participated in the

Southern California Association of Government’s extensive

process used to develop the region’s Draft 2012 Regional

Transportation Plan (RTP), which includes an inaugural

Sustainable Communities Strategy (SCS). Our interest in this

process has been particularly keen given both the significant

economic challenges currently facing our region’s economy and

the fact that the inaugural SCS could – if not considered from

many viewpoints – have unforeseen negative consequences. In

light of our ongoing participation and understanding, we

appreciate the tremendous effort that SCAG’s staff and leaders

have put into the process that led to the Draft 2012 RTP/SCS &

PEIR. The development of this RTP/SCS followed an inclusive

approach with SCAG holding hundreds of meetings with SCAG’s

public and private stakeholders. We also appreciate the

extensive economic analysis that SCAG has performed on the

Draft RTP/SCS in order to provide all stakeholders and SCAG’s

Regional Councilmembers with an understanding of the

financial impacts of the plan. As representatives of Southern

California’s broader business community, we recognize the

crucial roles that transportation and infrastructure have in

Comment noted.
341

ID Name Affiliation Comment Re

maintaining our region’s economy and quality of life.

Accordingly, through this letter, we join together to provide

SCAG with general comments regarding remaining significant

concerns about the contents of both (i) the Draft 2012 RTP/SCS,

and (ii) the Draft Program Environmental Impact Report (PEIR).

122‐02 Sandy Cajas Regional

HispanicChamber ofCommerce

From the beginning, representatives of businesses and

industries have agreed upon the qualities of a good RTP/SCS.

Those qualities can be summarized as follows. The RTP/SCS

should: Foster economic growth and job creation in a balanced

and accountable manner and in recognition of foreseeable

regional population growth;

Comment noted. Please see R

Chapter 1, Vision.

122‐03 Sandy Cajas Regional

HispanicChamber ofCommerce

Utilize all revenue sources very efficiently, and utilize new

revenue sources only if they are economically sound and

equitable

Comment noted. The Transpo

additional detail and explanat

included in the RTP. We cons

principles as a foundation for 

revenues that are reasonably 

financial strategies:

• Establish a user‐based syste

of transportation, provides fi

transportation funds, and ens

costs and benefits.

• Promote national and state 

source guarantees while main

regions that continue to com

• Leverage locally available fu

tools (e.g., tax credits and exp

capital and accelerate project 

• Promote funding strategies 

commitment to the nation’s g

recognizing the pivotal role th

and international trade. The i

return of $2.90 for every doll

122‐04 Sandy Cajas Regional

HispanicChamber ofCommerce

Honor the prerogatives that local governments – as the level of

government with the greatest understanding of and sensitivity

to community interests and context – should continue to enjoy

concerning land use and community development

Comment noted. SCAG's SCS 

local jurisdictions and SB 375 

jurisdiction's land use policies 

with the SCS. While the SCS is 

strategy that local governmen

and generally includes the qu

each city and county in the re

jurisdictions maintain local la
342

ID Name Affiliation Comment Re

122‐05 Sandy Cajas Regional

HispanicChamber ofCommerce

Comply with the California Environmental Quality Act (CEQA)

and federal environmental laws and regulations (e.g., federal

Clean Air Act conformity); and Allow for expeditious review and

approval of projects that are consistent with a sound and

reasonably accommodating RTP/SCS.

Comment noted. The RTP/SC

business, investment, and em

This plan does so by proposin

in the next 25 years. This con

infrastructure jobs program i

will put thousands of Souther

much needed jobs, not only i

cross‐section of industry clust

period, the plan will generate 

region. This represents the di

building and maintaining proj

induced benefits of the invest

122‐06 Sandy Cajas Regional

HispanicChamber ofCommerce

Allow for expeditious review and approval of projects that are

consistent with a sound and reasonably accommodating

RTP/SCS.

Comment noted. The RTP/SC

business, investment, and em

This plan does so by proposin

in the next 25 years. This con

infrastructure jobs program in 

will put thousands of Souther

much needed jobs, not only i

cross‐section of industry clust

SCAG and consultant team id

spending approximately $21 

2012 RTP/SCS for capital proj

maintenance expenditures. T

associated with the RTP spen

number. In addition SCAG est

2012 RTP/SCS projects and st

additional 354,000 jobs (on a

productivity benefits from tra

associated impact on regiona

122‐07 Sandy Cajas Regional

HispanicChamber ofCommerce

Despite our overall appreciation for the work put in by SCAG’s

staff, there are important aspects of the Draft 2012 RTP/SCS

and Draft PEIR which, we believe, require much more

consideration and correction or clarification before SCAG

approves the 2012 RTP/SCS and the Final PEIR. Corrections – or

at least substantial clarifications – are needed in order to bring

the Final 2012 RTP/SCS and PEIR back into line with the

principles set forth above. Stated here in the most general

terms, SCAG’s staff and ultimately its Regional Council should

address the following concerns and correct the final 2012

Comment noted. The TAZ‐lev

the purpose of modeling perf

land use assumptions for the 

jurisdictional level.
343

ID Name Affiliation Comment Re

RTP/SCS and the accompanying PEIR. 4) The RTP/SCS is

undergirded by analysis which shows the dispersion of

populations and employment shown and categorized at the

level of sub‐jurisdictional “transportation analysis zones” (TAZs).

The TAZ level of detail is, we believe, too small and precise a

level at which to prescribe the spatial dispersion of

development and redevelopment, particularly in light of the

regional nature of the RTP/SCS. Page 148 of the SCS should

therefore be clarified to indicate that questions of consistency

with the RTP/SCS should be substantively measured and

determined at a jurisdictional or sub‐regional level, not at a TAZ

level.

122‐08 Sandy Cajas Regional

HispanicChamber ofCommerce

5) The RTP/SCS should aim to reflect and accommodate both

the short‐term future of the SCAG region and its long‐ term

future. For example, the RTP should better anticipate the need

for and reasonable likelihood of a gradual transition in the

region’s overall vehicle fleet (e.g., gradually towards alternative

fuels) and the ongoing need for enhancements to vehicular

mobility even as more mass transit comes to fruition.

Comment noted. The 2012 RT

document that accounts for v

both near‐term and long‐term 

going need for enhanced mob

122‐09 Sandy Cajas Regional

HispanicChamber ofCommerce

6) More detail, clarity and explanation are needed concerning

the new revenue sources that are outlined within the plan

document. New revenues account for $219.5 billion out of the

total $524.7 billion needed for the transportation plan, yet

there is very little detail explaining these significant new fees

and impositions (see page 95 & 96 of the Draft RTP/SCS). To

fully and fairly evaluate these proposals, the business

community and all stakeholders need the benefit of additional

detail and explanation. In particular, we need clarity and

assurance regarding the following: a. The new revenue concepts

assumed within the RTP/SCS must be fair, equitable and

economically sound, meaning that an appropriate nexus exists

to assure that new revenues are drawn fairly and proportionally

from those who benefit from the related transportation

infrastructure or improvement. b. The new revenue sources

within the RTP must be effectively allocated, meaning the plan

should clearly articulate how resources will be efficiently and

responsibly allocated so that there is the best possible return on

investment for the expenditure of these new transportation

funds. SCAG needs to show that it will be a responsible,

accountable and innovative steward of the new revenues that it

Comment noted. The Transpo

additional detail and explanat

included in the RTP. We cons

principles as a foundation for 

revenues that are reasonably 

financial strategies: • Establis

reflects the true cost of trans

protection for transportation 

distribution of costs and bene

programs that include return

maintaining flexibility to rewa

commit substantial local reso

funding with innovative finan

expansion of TIFIA) to attract 

project delivery. • Promote fu

federal commitment to the n

recognizing the pivotal role th

and international trade. The i

return of $2.90 for every doll
344

ID Name Affiliation Comment Re

is proposing.

122‐10 Sandy Cajas Regional

HispanicChamber ofCommerce

7) New revenues from fees on businesses operating in the SCAG

region – and particularly the “Freight Fee/National Freight

Program” listed on page 96 of the Draft RTP – need to be

developed and implemented at the federal level, not the local

and regional level. Unless such fees are imposed on a national

scale, the region’s competiveness will be compromised.

Comment noted. The RTP doe

of local, regional, or statewid

SCAG region or its member e

disadvantage were critical co

development of all funding p

122‐11 Sandy Cajas Regional

HispanicChamber ofCommerce

8) In the RTP, SCAG should identify and highlight the significant

economic contributions of the goods movement sector to the

regional and state economy. Specifically, the RTP should

acknowledge that, as business stakeholders work with

regulatory agencies to further reduce emissions in the SCAG

region, any technology introduced must not compromise the

safety, velocity, cargo throughput, economic competitiveness,

or reliability of the goods movement system. It would be helpful

for SCAG to state clearly in the RTP that, to date, stakeholders

have not reached consensus on technologies, timing, funding,

or emissions impacts of the various options that SCAG examined

in the RTP. For example, SCAG discusses long‐term steps

towards a "Zero Emissions Container Movement System"

(ZECMS). If SCAG chooses to pursue such a fundamental shift in

new technology, it would need to work with all goods

movement stakeholders to clearly establish whether and, if so,

when and where within the transportation infrastructure a

ZECMS option could be demonstrated and evaluated without

negatively effecting the velocity and throughput of the system.

Comment noted. SCAG recog

the goods movement sector t

We concur that any technolo

compromise the safety, veloc

competitiveness, and reliabili

SCAG will continue to work w

stakeholders in further evalua

122‐12 Sandy Cajas Regional

HispanicChamber ofCommerce

9) With the recent elimination of redevelopment agencies, the

ability of local jurisdictions to meet the densification of urban

centers in the near term is challenged, given the costs related to

aging or inadequate infrastructure capacity and high

development costs for higher density projects. The elimination

of redevelopment agencies also threatens the availability of

sufficient housing options necessary to meet the needs of a

dynamic workforce. In fact, since the passage of SB 375, the

State of California has stripped local governments of funds that

were previously available for transit, transportation and

redevelopment. This follows many years in which the state

diverted revenues from gasoline, sales, income and other taxes

needed for local government programs. Local governments

cannot help to fulfill the 2012 RTP/SCS without increased, not

Comment noted.
345

ID Name Affiliation Comment Re

decreased, state support. SCAG should emphasize the need for

the state to restore support for planning, transit, transportation

and redevelopment or other necessary funding to pre‐SB 375

levels in order to speed the attainment of mandated goals.

While we find many very positive aspects in the plan, especially

related to principles and direction, these significant issues need

to be addressed. The short list of general concerns set forth

above is not meant to be exhaustive. Many of the organizations

that subscribe to the above‐stated comments will be

commenting more robustly in separate writings. We join here,

however, to express our unity in finding the Draft 2012 RTP/SCS

and PEIR to be in need of significant clarification and correction.

We are also jointly committed to completing this process and,

over the remaining weeks, working closely with SCAG to

develop and adopt a smart, flexible, accountable, and

economically sound RTP/SCS.

123‐01 Tony Largo Reservation

TransportationAuthority

The Reservation Transportation Authority (RTA) is a consortium

of Southern California Tribes, providing transportation services

to tribes located in Santa Barbara, San Bernardino, Riverside

and San Diego Counties. Our charge is to contract for funds to

plan, design and construct new roads on reservations but also

to act as a transportation advocate on behalf of the RTA

Member Tribes. 1‐States receive Federal Highway funding that

is intended to include Tribal projects. But as tribes attempt to

participate and gain funding for tribal road improvement

projects, the tribal projects receive little or no consideration for

funding. While tribes are specifically included by law they are

excluded by practice. The State funding process must be

weighted in such a manner that would allow tribal

transportation projects access and consideration to develop

transportation infrastructure projects. With the understanding

that tribes have not been able to historically participate and do

not have the ability to staff a tribal program, in comparison to

local governments. Tribal Governments enjoy a special and

unique distinction as governments different than a local

government and not subservient to a state agency. 2‐With few

exceptions Reservation Lands are not located within

metropolitan areas. However Reservations, even though located

in rural areas can produce generate high volumes of traffic

depending on the types of development that the Reservations

Comment noted. We agree th

stakeholders such as tribes ne

and advance the best, most a

provide needed funding for R

Council and Policy Committee

tribal governments within SCA

tribes in our future planning e
346

ID Name Affiliation Comment Re

are involved in. Studies need to reflect reservation development

and show the impacts related to Compass Blueprint strategies.

3‐Understanding that tribal transportation facilities are old and

may have been constructed with scarce dollars, without

consideration to the need for sidewalks and gutters and

drainage and lighting. If these improvements are a

consideration for “Sustainability” then it should be a given that

tribes should are in need. When many of the tribal

improvements were made and every dollar was needed to

complete a new road, nobody would ever dare to include any

amenities other than pavement. Historically tribes would

receive funding to build a road and then because of limited

funding would not receive road construction funds again.

123‐02 Tony Largo Reservation

TransportationAuthority

4‐ Local traffic counts and Caltrans traffic counts do not present

tribal traffic data, especially accident data for reservations.

While Tribal Reservations are in rural areas there are often high

traffic counts, from visitors/tourist. Jurisdiction for reservation

traffic counts is the domain of the BIA and correlation of the

data needs to be reflected accordingly as well as tribal data that

is captured to support development activities.

Comment noted. For the RTP

at the screen‐line level, at a r

local projects or planning stud

local lead agency. SCAG will c

local agencies and tribal repre

ways to improve its traffic da

123‐03 Tony Largo Reservation

TransportationAuthority

5‐VMT if carried out would impact rural reservations

disproportionately just based upon the additional miles of travel

required for rural reservation residents. This seems unfair in

comparison to the fuel tax per mile currently in place, which is

also unfair since tribe do not receive a return share of the tax

like local and county governments do.

Comment noted. The propose

existing state and federal gas 

the amount of transportation 

based user fee would charge 

existing gas excise taxes charg

consumed. The amount of ga

product of the total number o

implementation of the mileag

any drivers to increase the nu

provide additional revenue to 

improvements that could allo

travel options throughout the 

efforts underway throughout 

implementation plan for the 

Transportation Finance Appe

implementation plan will be s

disproportionate impacts to u

123‐04 Tony Largo Reservation

TransportationAuthority

6‐How can tribal transit systems be efficiently operated or even

provided and integrated with other transit systems when the

tribal lands are so rural?

Comment noted. SCAG looks 

tribes within SCAG to investig

tribal transit networks into ot
347

ID Name Affiliation Comment Re

123‐05 Tony Largo Reservation

TransportationAuthority

7 – What tribes currently sit on SCAG’s Regional Council and

policy committees? The RTA wants to be supportive of the

comments that may have been submitted by other tribes and

we do not want to contradict the needs submitted by other

tribal representatives.

Comment noted. Mark Calac, 

Luiseño Indians, serves on SC

Executive/ Administrative Co

Councilman, Chemehuevi Ind

Transportation Committee. C

Morongo Band of Mission Ind

Community, Economic and H

John Palinkas, Board Membe

Indians, and Jim Cohen, Depu

Band of Luiseño Indians, serv

Environment Committee.

123‐06 Tony Largo Reservation

TransportationAuthority

8 – How can the tribes and SCAG better collaborate with each

other in developing and applying for transportation grants that

benefit tribal areas? There appears to be hesitation at the State

level, perhaps because they are inexperienced in dealing with

grant applications from tribal groups. Thank You, Tony Largo,

RTA

Comment noted. While SCAG 

the county transportation com

for collaboration on funding f

use planning assistance, pleas

staff. SCAG also employs Reg

county in the SCAG region tha

contact for SCAG.

124‐01 Mochael Osur Riverside

CountyDepartment of

Public Health

Improve assessment of health benefits through new modeling

approaches. Utilize the new California Department of Public

Health I‐THIM screening tool to analyze the potential chronic

disease reductions that can be achieved in the SCAG region

based on increased transportation‐related activity such as

walking and biking. This model was used in the San Francisco

Bay Area region to determine reductions in heart and

respiratory disease, breast cancer and other health effects

linked to active transportation scenarios. We urge SCAG to

incorporate this tool in regional planning and decision making

for transportation investments.

Comment noted.

124‐02 Mochael Osur Riverside

CountyDepartment of

Public Health

In addition to monitoring premature mortality, SCAG should

also assess reductions in asthma incidence and exacerbations

due to traffic related pollution (NOX) and other targets through

collaboration with local health departments, the South Coast Air

Quality Management District, academic researchers and

community based organizations. Improvements to the targets

should be monitored and reported to the public every two

years.

Comment noted. SCAG is curr

our Sustainability Tool (ST) by 

tract based land use and built 

to confidential health survey 

Angeles County, Department 

completing this work for the 

round of Regional Transporta

Communities Strategy (SCS) i

124‐03 Mochael Osur Riverside

CountyDepartment of

Focus on investments on completing transit systems and

building out transit infrastructure, rather than highway

expansion, including the following: Doubling Metrolink ridership

Comment noted. The RTP inc

transit service in the Inland E

rail service, new BRT and exp
348

ID Name Affiliation Comment Re

Public Health by 2020 and double it again by 2035; Expanding Bus Rapid

Transit and regional bus service; Enhancing TOD planning and

1st‐mile‐last‐mile investments near Metrolink stations; Doubling

the bicycle network to 24,000 miles and improving pedestrian

environment. Increase transit and transit oriented planning in

Inland Empire. Because so much of the planned growth in the

Inland Empire is relatively low density and remote from transit,

SCAG should work closely with Inland Empire governments to

accelerate expansion and frequency of transit and rail to the

area and focus more growth around transit corridors.

frequencies of local fixed‐rou

124‐04 Mochael Osur Riverside

CountyDepartment of

Public Health

Front load active transportation funding. SCAG should commit

to a higher amount of transportation funding for bike and

pedestrian infrastructure, especially in the early years of the 25‐

year RTP process. SCAG should work with local transportation

agencies to prioritize bicycle and pedestrian projects and ensure

the majority of funds are spent prior to 2020.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

SCAG cannot unilaterally chan

that are already in place. Sign

active transportation propose

predicated on additional reve

require future actions at the s

Therefore, the plan realistica

not be available in the near te

expected to be available is 20

124‐05 Mochael Osur Riverside

CountyDepartment of

Public Health

Increase investments in zero emission freight transportation in

order to reduce diesel emissions and exposures in communities

near freight corridors and rail yards. Ensure that funding

mechanisms are in place to expedite the implementation of the

zero and near‐zero emission freight and truck strategies and

infrastructure. Prioritize spending on projects that deliver

maximum health benefits for residents of the region, especially

those living along the freight corridor.

Comment noted. Emissions fr

a significant concern for the S

lane system identified in the 

facility used by zero‐emission 

opportunity to incentivize the 

technologies for regional freig

continues to support efforts b

stakeholders to address good
349

ID Name Affiliation Comment Re

impacts on communities such 

Air Action Plan. SCAG also sup

freight projects listed in the 2

closely with regional impleme

completion. Further, the 2012 

Action Plan that will lead to t

technologies in the timefram

requirements.

124‐06 Mochael Osur Riverside

CountyDepartment of

Public Health

Evaluate the number and type of new developments that could

be located in close proximity to freeways and traffic roadways in

the SCAG region under the new RTP. Work with the air district,

health departments and universities to develop and implement

best practice policies for developments located near heavy

traffic areas to reduce exposures to air pollution.

Comment noted. SCAG prepa

the emissions exposure in are

high volume roads. It should 

emissions near these facilities 

whole. In 2035, these areas s

the region as a whole. Howev

overall decrease between now 

near freeways and high volum

RTP/SCS does result in an inc

locations, and as such health 

than if they were not in the b

project level analysis and mit

going health concerns. Howe

benefits for emissions exposu

areas near freeways.

124‐07 Mochael Osur Riverside

CountyDepartment of

Public Health

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

125‐01 Carolyn Luna Riverside

CountyPlanningDepartment

(Part 1 of 2) One of the biggest changes in the RTP/SCS 2012 is

its emphasis on higher density residential development and its

concentration within the High Quality Transit Areas (HQTA) to

accommodate the changing demand in types of housing. To a

certain extent, this is true on a regional level; however, the

trend is not necessarily mutual when each area is separated out

of the SCAG region. Inland counties still see the demand for

single family housing, and when the economy rebounds, the

County of Riverside still plans on managing the growth of the

single family housing market through its General Plan. SCAG

should address the fact that growth is still occurring in the

Inland counties as evidenced by the recent census. Table 4, 8,

10, and 11 of the RTP Growth Forecast shows the past, current

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as

trends occurring in many tran

on the agreed‐upon forecaste

household and employment a

Riverside County, SCAG shifte

while maintaining jurisdiction 

the Plan Alternative.
350

ID Name Affiliation Comment Re

and forecasted trends for each county in the region. Example:

Riverside County’s share of regional population in 1990 was 8%,

in 2000 it grew to be 9.4%, and then 12.1% in 2010. Even with

SCAG assumptions shown in Table 8 of the Growth Forecast, the

share of the population for Riverside County grows to 15% by

2035 equaling that of Orange County. In contrast, the share of

population in Los Angeles County diminishes to 51% from 54%

and employment to 51% from 57% by 2035. Riverside County

would like to compare the projection numbers of 2020 and

2035 with SCAG’s growth forecasts. Riverside County population

projections of 2010 is 2,153,189 and 2035 is 3,396,287. Using

the example above, an inferred conclusion can be made that

SCAG’s HQTA designations for 2035 (Exhibit 4.13 to 4.19) do not

accurately reflect the population and employment trends

shown in Table 8. It appears that HQTAs were designated based

on existing Transit or Transportation corridors without

considering the actual existing and proposed population centers

of each jurisdiction in Riverside County. When HQTAs are

compared together amongst all six counties, as in Exhibit 4.13,

the share of HQTAs clearly do not show the 15% population

share that Riverside County represents in 2035. Also, questions

can be raised as to why Riverside County HQTAs do not connect

to any of the surrounding counties such as San Diego County.

125‐02 Carolyn Luna Riverside

CountyPlanningDepartment

(Part 2 of 2) In addition, when city boundaries are overlaid on

top of Exhibit 4.18 (see handout 1), the unincorporated section

of the County contains only one corridor with an HQTA on I‐15

in Temescal Canyon. Currently, the unincorporated County has

355,718 people (excluding Jurupa Valley and Eastvale) and

expects a population growth of 704,253 people by 2035, almost

doubling the current number. Considering the County forecast

and the historical growth trend of Riverside County, SCAG’s

placements of HQTAs become more questionable. How was

SCAG able to redistribute 51 percent of the new residential

growth in the unincorporated Riverside County? From Riverside

County’s perspective, the placements of the HQTAs are

perceived to just be relocation of growth rather than managing

growth. Riverside County would benefit greatly if the details of

the land use and projection data analysis were shared with the

local jurisdictions. Currently, based on the plan and the PEIR,

the land use analysis and local inputs on the data incorporations

Comment noted. HQTAs are g

radius of an existing or plann

quality transit corridor with a 

minutes or less during the mo

commute period. Developme

areas may be considered for 

meet certain criteria set forth 

by legislation; however, we h

land use strategies to be cons

areas that may eventually be

growth in HQTAs, SCAG distri

transportation analysis zones 

25% or greater of their land w

the sum of the selected TAZs’ 
351

ID Name Affiliation Comment Re

are not clearly outlined. Example: PEIR 2.25 states, “The SCS

focuses the majority of new housing and job growth in High

Quality Transit Areas (HQTA) and other opportunity areas in

existing main streets, downtowns, and commercial corridors,

resulting in an improved jobs‐housing balance and more

opportunity for TOD.” Again, looking at the HQTAs on a macro

level, the jobs‐housing balance goal may have been achieved

based on the provided locations of the HQTAs, but if the HQTAs

are separated out by counties, jobs‐housing balance cannot be

achieved in the Inland Empire region. As stated, “The 2012‐2035

RTP/SCS assumes that 51 percent of new housing developed

between 2008 and 2035 will be within HQTAs, along with 53

percent of new employment growth (compared with 39 and 48

percent, respectively in 2008).” (PEIR p.2‐31). As indicated

above, if most of the growth is still projected to occur in the

Inland Empire region, achieving the goal of locating 51 percent

of the new growths in the limited HQTAs in the Inland Empire is

not feasible. Creating more urban centers within suburban

counties achieve far greater jobs‐housing balance than having

the employment concentration heavily depend on Orange and

Los Angeles Counties.

125‐03 Carolyn Luna Riverside

CountyPlanningDepartment

Both of the SCAG documents have stated that the outreach

efforts have allowed the organization to collect land use data

from the local jurisdictions in developing the SCS, especially in

Orange County and Los Angeles County (Gateway Cities COG).

Riverside County also appreciates many opportunities and

discussions on various levels of data sharing with SCAG. In the

past, Riverside County has provided SCAG with General Plan

Land Use data, Demographics/Socioeconomic data, and Growth

Projections data with maps and comment letters on a TAZ level

basis. All of these great efforts cannot be recognized if SCAG

does not detail how they have incorporated the local

jurisdiction inputs into the RTP/SCS and PEIR. Some projection

data from SCAG was shared, but the discrepancies between

SCAG and Riverside County data was not explained. (see

attachment) Example: SCAG RTP/SCS and PEIR state, “SCAG

shall encourage cities and counties in the region to provide

SCAG with electronic versions of their most recent general plan

(and associated environmental document) and any updates as

they are produced” (MM‐LU1), and “...Lead and responsible

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as

trends occurring in many tran

the SCS is intended to provide 

local governments may build 

generally includes the quantit

each city and county in the re

jurisdictions maintain local la

maps have been developed fo

performance. Lead agencies, 

maintain their own discretion 

of any future project with the 

assumptions for the RTP/SCS 

jurisdictionalgeographic scale

specific mitigation measures 

PEIR Addendum Section 4.0, 
352

ID Name Affiliation Comment Re

agencies can and should then make any necessary adjustments

to the applicable General Plan. Any such identified adjustment

shall be communicated to SCAG” (MM‐PS11 and PS56). “As a

result of this comprehensive and integrated approach, the

transportation projects and strategies included in the 2012‐

2035 RTP/SCS are generally consistent with the county and

regional level general plan data available to SCAG.” (PEIR 3.8‐

13) SCAG should work with local jurisdictions to explain how the

data provided by various agencies were used in the RTP/SCS,

and SCAG also should ask local jurisdictions for interpretation of

the provided land use data.

Draft RTP PEIR, Letter Numbe

125‐04 Carolyn Luna Riverside

CountyPlanningDepartment

Growth forecasts at the jurisdictional level were approved by

the Riverside County Board of Supervisors, the CVAG and

WRCOG Executive Committees and were transmitted to SCAG in

2010. Subsequent to these policy level actions, County staff

provided SCAG staff detailed growth forecast at the TAZ level.

WRCOG did approve revised forecasts for the jurisdictions

within its subregion and RTP/SCS 2012 ‐ Comment Letter

02/14/2012 SCAG staff did adjust the forecasts for the Cities of

Hemet, Menifee, and San Jacinto. The growth distribution of

households and employment utilized in the RTP/SCS are not

consistent with the TAZ level data provided to SCAG staff. It is

therefore recommended that the growth forecasts are not

approved at the TAZ level. It is further recommended that no

findings of consistency and conformity, recommendations on

the placement of infrastructure, or recommended funding be

based on the TAZ level forecast used in the RTP/SCS plan. From

the perspective of local jurisdiction, it is alarming and

disconcerting to find that the data provided to SCAG can be

modified without adequate methodologies or explanations.

Comment noted. SCAG has in

growth forecasts at the jurisd

Riverside County into the SCA

for the 2012 RTP/SCS. SCAG’s 

growth forecasts at the jurisd

2012 RTP/SCS.

125‐05 Carolyn Luna Riverside

CountyPlanningDepartment

“One of the most critical elements of the RTP/SCS is the

financial plan. The RTP is required to be financially constrained,

meaning that project costs must be matched with “reasonably

available” revenues.” Riverside County agrees with other COG

comments on the Financial Plans of the RTP/SCS. There are

some innovative funding mechanisms identified in the plan

(Table 3.3 and 3.4.4), however, once again, the feasibility of the

revenue identified in the RTP is questionable. In fact, it is very

unlikely that much of the new supplemental revenues identified

in the plan will materialize. There are no other alternatives

Comment noted. Federal regu

financial constraint requirem

information for demonstratin

implemented using committe

available revenue sources, wi

federally supported transport

operated and maintained. Th

mileage‐based user fee and a

gas excises taxes when comb

forecast for state and federal 
353

ID Name Affiliation Comment Re

identified in the plan that would replace or augment the loss in

revenue if the new funding measures fail. Implementation

measures on the funding items should be more clearly outlined

and planned for the local jurisdictions. Examples: 15c per gallon

in addition to 18c per gallon current California State gas tax is

almost doubling the tax rate. A mileage‐based user fees are also

identified in the plan that estimates about 5c per mile starting

2025 replacing current gas tax. In addition, the plan identifies E‐

Commerce Tax, Highway Tolls, and Special Districts.

than the historical average in

transportation revenues sour

Rather than simply assume a 

growth rate, which is consiste

detailed specific steps necess

transportation revenue sourc

recommendations from two n

by Congress through SAFETEA

future cannot be known with 

reasonable assumptions, whi

Technical Advisory Committe

documented in the RTP to en

more insight into the future a

assumptions, we will update 

through amendments and/or 

appropriate. At a minimum, a

every four years. The Transpo

additional detail and explanat

included in the RTP.

125‐06 Carolyn Luna Riverside

CountyPlanningDepartment

RTP p.54: Complete Streets Discussion: “Encourage local

jurisdictions to adopt and implement the proposed SCAG

Regional Bikeway Network.” Riverside County continuously

implements and updates its own trails network to create

connectivity and accessibility. We would like to find out how

SCAG’s Exhibit 2.5 Regional Bicycle Network was developed

before relying on the map provided in the regional plan. Such

process should be a “bottom‐up” process and not a “top‐down”

approach.

Comment noted. The SCAG R

Riverside County was develop

originally developed by the W

Governments (WRCOG) and t

Governments (CVAG) for thei

local plans included therein a

and the CVAG Parkway 1e11. 

within Riverside County illust

in order to promote bicycle c

counties and to develop a reg

that development of specific 

for those facilities lies at the l

County of Riverside’s particip

development of the Regional 

125‐07 Carolyn Luna Riverside

CountyPlanningDepartment

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

126‐01 Anne Mayer Riverside

CountyTransportation

Chapter 2, Transportation Investments Page 41, Congestion

Management System ‐ The 2012 RTP SCS address federal

requirements for the Congestion Management System.

Comment noted. Federal CM

23CFR450.320 requires that a

to alternative strategies to Si
354

ID Name Affiliation Comment Re

Commission Specifically, the RTP SCS component contains Transportation

Demand Management strategies, which is a required element

for County Congestion Management Program to meet federal

CMS guidance. The individual county CMPs, Caltrans CSMPs,

and the SCS give the entire picture of the region's TDM efforts.

Therefore, RCTC requests the following be removed: "First,

SCAG will incorporate a requirement in the FTIP guidelines that

calls for submittal of documentation by the sponsoring agencies

associated with significant roadway capacity projects (greater

than $50 million) to ensure documentation of all the

alternatives considered in defining the project as well as

identifying appropriate mitigation that would be implemented

in conjunction with the project." This requirement should also

be removed from the FTIP guidelines since a comprehensive

view of the region's TDM projects and program is clearly

highlighted in county CMPs, Caltrans CSMPs, and the RTP SCS.

conjunction with regionally si

projects included in the RTP a

was specifically issued a corre

MPO certification to address 

documentation of such consid

making process in identifying 

believe this requirement wou

sponsoring agencies other th

documentations such as the p

that are generated as part of 

making work.

126‐02 Anne Mayer Riverside

CountyTransportationCommission

Page 43, Completing our System ‐ Table 2.2 Major Highway

Completion Projects includes one to two projects per county

emphasizing "critical gaps in the network that hinder access to

certain parts of the region." The project identified in Riverside

Coutny is "CETAP Intercounty Corridor A." RCTC requests that

this project be removed from the list and be replaced with the

SR‐79 realignment (RTP ID# RIV62024), and the I‐215 widening

project from Scott to Nuevo (RTP ID# RIV070309).

Comment noted. The referen

RTP as requested by the com

Intercounty Corridor A with t

widening from Scott to Nuevo

126‐03 Anne Mayer Riverside

CountyTransportationCommission

Page 44, Completing Our System ‐ Table 2.3 identifies Major

HOV Projects for each county. The I‐215 Bi‐county project is

listed under San Bernardino County from Spruce Street to

Orange Show Road. This project is also in Riverside County.

RCTC requests that SCAG clarify that the project is in San

Bernardino, from Orange Show Road to the Riverside‐San

Bernardino County line, and in Riverside County from the

Riverside‐San Bernardino County line to Spruce Street. Table 2.3

does not include the SR‐91 HOV lane project (RTP ID# 010212).

RCTC requests that SCAG add this project to the table as it is a

major highway project that will begin construction this year

and, together with the I‐215 Bi‐county project, will provide a

continuous HOV system from Orange County to San Bernardino

County along the SR‐91/I‐215 corridor.

Comment noted. The SR‐91 H

RIV010212) is currently listed 

91 from Adams to SR‐60/215

correctly depict the Riverside 

215 Bi‐County project.

126‐04 Anne Mayer Riverside

County

Page 46, Strategically Expanding Our System ‐ Exhibit 2.1 Major

Highway Project ‐ This map highlights highway improvement

Comment noted. The referen

include the Mid County Parkw
355

ID Name Affiliation Comment Re

TransportationCommission

projects to be implemented by 2035. RCTC requests that the

Mid County Parkway (RTP ID# RIV031218) and SR‐79

realignment (RTP ID# 62024) be added to the map.

126‐05 Anne Mayer Riverside

CountyTransportationCommission

Page 76‐79, Environmental Mitigation ‐ This section discusses

Conservation Planning, Biological Resources and Open Space,

Locations for Mitigation, etc. RCTC requests that SCAG include

Riverside County's Multiple Species Habitat Conservation Plan

efforts in Western County and Coachella Valley in this section as

an example of what counties are doing to mitigate

environmental impacts.

Comment noted. The MSHCP 

excellent example and has be

Environmental Mitigation dis

126‐06 Anne Mayer Riverside

CountyTransportationCommission

Chapter 4, Sustainable Communities Strategy Page 128,

Resources Areas and Farmland ‐ This section talks about areas

to be protected from development including parklands, open

space, natural resource areas, and farmland. It says that "SCAG

is also developing a natural lands acquisition and open space

conservation strategy to encourage large‐scale acquisition and

management of critical habitat to mitigate impacts..." RCTC also

requests that SCAG mention Riverside County's MSHCP

accomplishments in section.

Comment noted. The MSHCP 

excellent example and has be

Environmental Mitigation dis

126‐07 Anne Mayer Riverside

CountyTransportationCommission

Page 151, Table 4.4 Transportation Network Actions and

Strategies ‐ Another action/strategy listed is "Cooperate with

stakeholders, particularly county transportation commissions

and Caltrans, to prioritize funding sources for preservation and

maintenance of the existing transportation network." RCTC

agrees that there is insufficient funding for System Preservation.

Each county transportation commission established projects

and programs with various ways to fund and implement them.

Funding is limited and it would be more beneficial to work with

stakeholders in identifying a new funding source or increased

funding levels instead of competing with very limited existing

fund sources. RCTC suggests that SCAG revise the wording to "...

to identify new funding sources and/or increased funding levels

for preservation and maintenance..." This recommended

change should also be reflected in Chapter 2, Page 39, under

System Preservation.

Comment noted. The request

RTP/SCS.

126‐08 Anne Mayer Riverside

CountyTransportationCommission

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

127‐01 Andrea Riverside Page 238 Agency RCTC RTP ID 3CR0702: Revise project Comment noted. We have ad
356

ID Name Affiliation Comment Re

Zureick County

TransportationCommission

description to remove PVL station at Hemet Airport and replace

with station near new SR‐79 alignment and Stetson Rd.

to the project list as submitte

commissions through the sta

modification and FTIP databa

127‐02 Andrea

Zureick

RiversideCountyTransportationCommission

Page 239 Agency RTA RTP ID 3TC04TR6: Change the project

description to “Construct new Hemet Transit Center (with

approximately 4 bus bays) in the vicinity of State St and

Devonshire Ave near the future courthouse location. Change

the project location from Menifee to Hemet. Change the

completion year from 2027 to 2015, and update the total

project cost from $5,926 to $1,442.

Comment noted. We have ad

to the project list as submitte

commissions through the sta

modification and FTIP databa

127‐03 Andrea

Zureick

RiversideCountyTransportationCommission

Page 240 Agency RCTC RTP ID 3C01MA03: Change project

description to “CETAP – Riverside County to Orange County –

Construct new intercounty transportation Corridor A – 2 toll

each dir on new facility parallel to SR‐91, from from SR‐ 241 to I‐

15, with IC at SR‐241, SR‐71, I‐15”. Network year remains 2035.

Update total project cost to $2,720,000. Move balance of

project description “CETAP – Corridor B – 2 toll each dir on new

facility from I‐ 15/Mid‐County Pkwy to SR‐241/SR‐133” to

Strategic Projects Section.

Comment noted. We have ad

to the project list as submitte

commissions through the sta

modification and FTIP databa

127‐04 Andrea

Zureick

RiversideCountyTransportationCommission

Page 266 Agency Coachella RTP ID 3A07094: This is currently

programmed as FTIP ID RIV071246. Network year should remain

2018 (previously requested to change to 2020). Update total

project cost from $4,853 to $22,290.

Comment noted. We have ad

to the project list as submitte

commissions through the sta

modification and FTIP databa

127‐05 Andrea

Zureick

RiversideCountyTransportationCommission

New Project, RTA: Regional transit center for mass transit

service in central western Riverside County along I‐215 corridor.

Network year is 2030 and the total project cost is $10M.

Comment noted. We have ad

to the project list as submitte

commissions through the sta

modification and FTIP databa

127‐06 Andrea

Zureick

RiversideCountyTransportationCommission

We would like to request modifications to the project list that

we have submitted to SCAG staff through the standard RTP

long‐range project list modification and FTIP database update

processes: Major project modifications have been submitted for

the following RTP projects: 3A07262 3A07205 3A07207

3A07024 3A07040 3A07069 3A07088 3120008 3A01CV047A

3A01CV047B 3A01CV049 3A01CV048 3A07074 3A07031 3ITS08

3A01CV123 3A01CV111 3A07018A 3A01CV104 3A01CV105

3A01CV103 3120010 3A01CV060 3A01CV059A 3A01CV061

3A01CV063 3A04A25 3A07266 3A04WT165 3A01CV067

3A01CV068 3A07001 3120014 3A01CV071 3A07101 3A07292

3A01CV076 3A01CV075 3A01WT210 3A04WT187 3A01WT045

3A04WT046 3A01WT218 3A04A22 3A04WT198 3A01CV085

Comment noted. We have ad

to the project list as submitte

commissions through the 201
357

ID Name Affiliation Comment Re

3A01CV086 3A07097 3A07244 3A07079 3120012 3A04WT078

3M01CV01 3M0715 3M0702 3M01CV03 3M0716 3M0708

3M0722 3TL504 3TR04C 3TR04A, 3TR04B 3ITS09 3TL1507

3TL1607 3TL1107 3TC04TR1 3TC04TR10 3TC04TR6 3TC04TR8

3TC0702 3A01CV098 3120007 3A01CV002 3A04CV113

3A01CV004 3A01CV014 3A07094 3A07164 3A07165 3A01CV017

3A07011 3A01CV018 3A01CV016 3A01CV023 3A04CV027

3A07078 3A07137 3A07029 3120004

127‐07 Andrea

Zureick

RiversideCountyTransportationCommission

Major project additions have been submitted for the following

RTP projects: 3120015 RIV111201 3120016 RIV111131

3A04WT198B 3120017 3120018 3120019 3120020 3120021

3120022 3120023 3120024 3120025 3120026 3120027

3120028 3120029 3120030 3120031 3120032 3120033

3120034 3120035 RIV071250B RIV050531 RIV071241

Comment noted. We have ad

to the project list as submitte

commissions through the 201

127‐08 Andrea

Zureick

RiversideCountyTransportationCommission

Major project deletions have been submitted for the following

RTP projects: 3A07109 (project complete) 3A04WT070

3A01WT036 (project complete) 3A01WT035 (project complete)

3A07076 3M01WT021 3TK04MA13 (programmed as RIV120201

in 2011 FTIP A24) 3M04WT009 (programmed as RIV091012 in

2011 FTIP A24)

Comment noted. We have ad

to the project list as submitte

commissions through the 201

127‐09 Andrea

Zureick

RiversideCountyTransportationCommission

Major project changes were submitted as part of 2011 FTIP A24:

RIV071247 RIV031209 RIV071253 RIV071267 RIV050532

RIV071250 RIV090902 (3M0803) RIV520109 RIV091007

(removed from A24) RIV090622 RIV071252 (3A07020)

RIV071254 (3A07022) RIV62034 RIV120201 (3TK04MA13)

RIV62029 RIV091008 (3A07131) RIV060111 RIV100107

(3M10WT03) RIV091012 (3M04WT009) RIV100104 (3M0725)

RIV060114 RIV110825 RIV031218 RIV080917 (3A07155)

RIV080918 (3A07156) RIV031209 RIV050535 RIV120202

(replaced with RIV090902)

Comment noted. We have ad

to the project list as submitte

commissions through the 201

127‐10 Andrea

Zureick

RiversideCountyTransportationCommission

Page 83 Agency Lake Elsinore RTP ID RIV091007: This project is

not reflected in the Financially‐ Constrained RTP Projects list –

please confirm project is modeled.

Comment noted. FTIP ID RIV0

Financially‐Constrained Proje

off RTP ID 3A04WT047, which 

RIV091007 can be found in th

127‐11 Andrea

Zureick

RiversideCountyTransportationCommission

Page 90 Agency Palm Springs RTP ID RIV090402: This project is

not reflected in the Financially‐ Constrained RTP Projects list –

please confirm project is modeled.

Comment noted. RIV090402 

Constrained Project List beca

REG0704, which is in the Proj

be found in the Model List.

127‐12 Andrea Riverside Page 243 Agency Riverside County/Indo: Programmed as FTIP ID Comment noted.
358

ID Name Affiliation Comment Re

Zureick County

TransportationCommission

47520 (I‐10/Jefferson IC).

127‐13 Andrea

Zureick

RiversideCountyTransportationCommission

Page 250 Agency Moreno Valley RTP ID 3M0712: Programmed

as FTIP ID RIV080902.

Comment noted.

127‐14 Andrea

Zureick

RiversideCountyTransportationCommission

Page 251 Agency Moreno Valley RTP ID 3M0801: Programmed

as FTIP ID RIV080904.

Comment noted.

127‐15 Andrea

Zureick

RiversideCountyTransportationCommission

Page 252 Agency Coachella RTP ID 3M0717: Programmed as

FTIP ID RIV071274.

Comment noted.

127‐16 Andrea

Zureick

RiversideCountyTransportationCommission

Page 255 Agency RCTC RTP ID 3M0738: Programmed as FTIP ID

RIV110122.

Comment noted.

127‐17 Andrea

Zureick

RiversideCountyTransportationCommission

Page 272 Agency Moreno Valley RTP ID 3A10WT01:

Programmed as FTIP ID RIV091004.

Comment noted.

127‐18 Andrea

Zureick

RiversideCountyTransportationCommission

Page 272 Agency Riverside County RTP ID 3A04WT137A:

Programmed as FTIP ID RIV090903. Verify that project is

modeled.

Comment noted. This project 

127‐19 Andrea

Zureick

RiversideCountyTransportationCommission

Page 280 Agency Moreno Valley RTP ID 3A01WT053:

Programmed as FTIP ID RIV080908.

Comment noted.

127‐20 Andrea

Zureick

RiversideCountyTransportationCommission

Page 286 Agency Moreno Valley RTP ID 3A04WT056F:

Programmed as FTIP ID RIV080915.

Comment noted.

127‐21 Andrea

Zureick

RiversideCountyTransportationCommission

Page 287 Agency Moreno Valley RTP ID 3A0805: Programmed as

FTIP ID RIV080917.

Comment noted.
359

ID Name Affiliation Comment Re

127‐22 Andrea

Zureick

RiversideCountyTransportationCommission

Page 291/2 Agency Rancho Mirage RTP ID 3A07116/3A07128:

Programmed as FTIP ID RIV091010.

Comment noted.

128‐01 Andrea

Zureick

RiversideCountyTransportationCommission

Please see attached comment on the Riverside County project

list.

Comment noted.

129‐01 Larry Rubio Riverside

Transit Agency

Chapter 2, Pages 49 and 50, under Transit Policies, RTA supports

the need for increases in state and federal funding for

sustaining the operation of transit services and infrastructure

including future BRT and express bus service projects as

included in the Draft RTP/SCS. In addition, as our region's

population continues to age, increased operational funding

support to provide paratransit services will be a continued need

moving forward.

Comment noted.

129‐02 Larry Rubio Riverside

Transit Agency

Transportation Investments, Chapter 2, Pages 50 and 51, under

Passenger and High‐Speed Rail, the RTA requests that short

term commuter rail service improvements be made in Riverside

County. At this time of record ridership growth on RTA's

services, these near term improvements would promote further

bus and rail integration resulting in region‐wide reductions in

congestion due to reduced automobile traffic.

Comment noted. The Riversid

Commission is working to inc

Metrolink lines.

129‐03 Larry Rubio Riverside

Transit Agency

Transportation Investments, Chapter 2, Page 41, under

Transportation Systems Management, t he RTA suggests that

more emphasis be placed on developing a wider variety of

capital funding sources to support and maintain Transit AVL and

ATIS. In this time of social media applications, this is highly

important in attracting and retaining revenue to support the

transit system.

Comment noted. The 2012 RT

investment in real‐time passe

discussed in the Transit Appe

129‐04 Larry Rubio Riverside

Transit Agency

With school districts continuing to lose state transportation

funding, the RTA will be expected to provide additional services

to schools throughout western Riverside County without the

provision of additional operating funds. The RTA desires to work

closely with SCAG and other regional agencies to develop

funding solutions to accommodate this growing trend.

Comment noted. The RTP sup

for transit services. SCAG will 

funding solutions and work w

to help fill these potential gap

129‐05 Larry Rubio Riverside

Transit Agency

Ensure modeled RTA transit projects included in the Draft

RTP/SCS are accurately depicted based on system‐wide high

ridership results in 2011, continued reductions in unimployment

Comment noted.
360

ID Name Affiliation Comment Re

within westenr Riverside County and forecasted gas price

changes.

130‐01 Pauline Chow Safe Routes to

SchoolNationalPartnership

Increase the overall percentage of RTP funds dedicated to active

transportation from 1.3 percent of the 2012 RTP to 5‐8 percent

of the total 2012 plan. The request for 5‐8 percent reflects the

region’s current mode split, collision trends, community interest

and support, as well as current bicycle and pedestrian planning

and implementation requirements, based on projections by the

Los Angeles County Department of Public Health (LAC DPH)

Methodology (released 12/2011). The LAC DPH determined in a

rigorous study that the unmet regional funding need for a

walkable and bikeable SCAG Region was close to $40 billion.

This represents roughly 8 percent of the total RTP budget, which

is significantly larger than SCAG’s proposed $6B to address

regional needs.As local governments contribute resources to the construction

of active transportation projects, all other funding sources for

active transportation, such as the amount of RTP local (county

sales taxes and other local revenues included in the 2012 RTP),

state, and federal programing dollars, should be increased to

aid these efforts. Additional state and federal funding will help

cities do more with their local dollars, especially since often

local funding is tied into federal funds.

As it stands in the draft 2012 RTP, eighty percent of the SCAG

funds dedicated to active transportation investments in the

2012 RTP are not programmed until after 2026. Between 2016‐

2025, the funding for active transportation will be only one‐half

of the current annual 2012 budget. We encourage SCAG to

prioritize active transportation funding and distribute these

funds evenly over the 25 year period, which will bring the

benefits of active transportation to fruition sooner for all

communities.While we encourage SCAG to increase funds to support Active

Transportation, we recognize the constraints and importance of

working with County Transportation Commissions (CTC’s) to

fast‐track active transportation funding. We request the 2012

RTP include development of an Active Transportation Finance

Strategic Plan by 2014 that identifies how each CTC is spending

funds and the opportunities available for increasing funding for

active transportation in each county during the next ten years.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour
361

ID Name Affiliation Comment Re

This plan ideally is developed by convening a Regional Active

Transportation Early Action Transportation Program in which

SCAG brings together each County Transportation Commission

(CTC), elected officials and other stakeholders to discuss and

prioritize what each County is doing regarding active

transportation and funding areas which may be leveraged for

the needed funding, for walking and bicycling and first mile/last

mile projects, in the earlier stages of the 2012 RTP. We request

that this Early Action Program have be adopted and include a

2014 implementation plan.

We have seen tremendous ‐ and still growing ‐ support and

action from throughout the six‐county region calling for policy

makers to support and build walkable and bikeable

neighborhoods. We encourage SCAG leaders to respond by

supporting the impressive efforts underway throughout the

region to create healthy and active communities for all.

130‐02 Pauline Chow Safe Routes to

SchoolNationalPartnership

Allocate Funding for Bicycle and Pedestrian Planning and Usage

Counts: Improving the walking and biking environments in our

region cannot be done without adequate planning at the local

level. Unfortunately, many SCAG cities do not have bicycle or

pedestrian master plans and project lists; in Los Angeles County,

for example, only approximately 11 of 88 cities have bicycle

master plans and only 4 cities have pedestrian plans. This lack of

planning is a grievous impediment to improving infrastructure

for cyclists and pedestrians. In addition, we must increase

documentation of bicycle and pedestrian travel usage and

demand by regularly assessing numbers of people walking and

biking. Without such figures, it is difficult to forecast mode

share and usage or measure the positive benefits of

investments in these modes.

● IdenƟfy funding sources in order to set aside at least $19M in

the 2012 RTP to support SCAG cities in developing bicycle and

pedestrian master plans, safe routes to school plans and

required, but overdue ADA transition plans. It is estimated that

approximately $200,000 per city is required to develop these

plans (95 cities at $200,000). Establish a goal of 50 percent of

SCAG cities having completed at least one plan by 2016 in order

to prepare for the 2016 RTP.

● Create and fund a regional bicycle and pedestrian count

program at SCAG establishing yearly usage counts at key

Comment noted.
362

ID Name Affiliation Comment Re

locations in cities throughout the SCAG region. Use the data

collected to establish trends, set performance goals, evaluate

fund requests for facility improvements, prioritize

improvements, and show the impacts of recent improvements.

Set aside funds in SCAG’s 2012/2013 OWP to create program

and maintain this program in future years. (See links: Nashville

Metropolitan Planning Organization’s program, Technical

Memorandum on Regional Pedestrian and Bicycle Count

Procedures)

130‐03 Pauline Chow Safe Routes to

SchoolNationalPartnership

Adopt a Regional Complete Streets Plan by 2014: This plan will

incorporate input from local jurisdictions to prioritize complete

streets projects in programing efforts and dedicate a portion of

system preservation and maintenance funding for improving

the road conditions of all users.

Comment noted. Goal 3: Incr

in the SCAG Region, Objective 

Streets Policy includes two po

jurisdictions to prioritize and 

comply with ADA requiremen

jurisdictions to develop and im

Policies.

130‐04 Pauline Chow Safe Routes to

SchoolNationalPartnership

Adopt a Safe Routes to School Regional Strategic Plan by 2014:

Such a plan would be similar to the plan currently being

adopted by SANDAG. In our region 14 percent of all morning

congestion is caused by private car drop off at schools (Traffic

Injury Prevention, August 2011). It is critical that transportation

agencies look at the needs of the entire network when planning

resource investments. SANDAG’s Regional Safe Routes to School

Strategic Plan works to establish a critical needs assessment for

their Region on how students and their families currently go to

and from school, creates data standards and guidelines,

considers school siting and closures as possible land use

strategies, bridges the gap between transportation planning

agencies and school districts, and works to provide much

needed technical assistance to local jurisdictions ‐ with skill sets

such as how to obligate federal Safe Routes to School funds in a

timely manner.

Comment noted. Goal 3: Incr

in the SCAG Region, Objective 

School Policy includes three p

children; including those with 

school; 2) Make bicycling and 

more appealing transportatio

healthy and active lifestyle fro

the planning, development, a

activities that will improve sa

consumption, and air pollutio

miles) of primary and middle 

130‐05 Pauline Chow Safe Routes to

SchoolNationalPartnership

School Siting and Joint Use Policies as land use elements of the

SCS: School siting can often determine whether or not it is

possible for children to walk and bicycle to school.

When schools are placed on the outskirts of urban areas it

becomes necessary for children to be driven to school. As noted

above, 14 percent of all morning congestion is caused by private

car drop off at schools (Traffic Injury Prevention, August 2011).

Therefore schools should be located within residential

Comment noted. The Final 20

address comment. See Table 

Strategies.
363

ID Name Affiliation Comment Re

neighborhoods whenever possible and equitable to reduce

congestion and increase opportunities for bicycling and walking.

Joint Use Policies allow school facilities such as playgrounds and

recreational facilities to be used by the community when

schools are not in session. This can open up recreational

activities in neighborhoods that lack parks and open spaces.

When schools are located within neighborhoods, community

members can access these locations without the use of a

private automobile which can lead to further reductions in

congestion.

130‐06 Pauline Chow Safe Routes to

SchoolNationalPartnership

Set measurable safety and health goals for all users: Goals are

set for the reduction of green house gases in the draft 2012

RTP/SCS. Active transportation plays a pivotal role in the

reduction of these green house gasses. Similar measurable goals

should be set for reducing crash rates for active transportation

and for reducing the health impacts of obesity. These could

include a report on the number of children walking and bicycling

to school across the entire region as well as a report detailing

access to parks, open spaces and quality active transportation

networks.

Comment noted. The Safety A

various goals and strategies d

transportation fatalities in the 

designed to increase active tr

of life are expected to increas

benefit.

130‐07 Pauline Chow Safe Routes to

SchoolNationalPartnership

Monitoring detailed population data and metrics in

environmental justice communities: The analysis conducted by

SCAG in the Environmental Justice Supplementary Report (“EJ

Supp. Report”) provides detail on existing inequities in all

modes of transit, housing, employment, environmental impacts,

and health risks. The historical analysis in the Environmental

Justice Supplementary Report confirms the challenges faced by

the environmental justice population, as defined by SCAG:

○ longer commute Ɵmes and distances than average,

○ vulnerability to gentrificaƟon and displacement from high

quality transit areas (HQTA) or transit oriented communities

(TOC),○ higher proporƟonal use of non‐automobile travel, such as bus,

rail, walk, and bicycle, and growth patterns concentrated within

geographies of poor quality transit, lower housing costs, and

fewer employment opportunities.

Concerns arise in the inconsistencies of the environmental

justice analysis. SCAG’s analysis of travel time and travel

distance savings shows “fairly similar and close” rates for all

ethnic groups, including non‐white Hispanics. Yet, the increase

Comment noted. (1) SCAG ha

analyzing gentrification in the 

Justice (EJ) Analysis. Trends o

Census and 2005‐09 America

with transit oriented develop

SCAG will continue to evaluat

based on the framework pres

future as the economy is reco

monitor and track place‐base

associated environmental and 

Environmental Justice studies

Transportation Plans (RTP) as 

emissions and noise concerns 

mapped in the Environmenta

the comment and suggestion 

existing efforts and establish 

to focus on selected environm

communities of concern. (3) S

enhancing our Sustainability T

Census tract based land use a
364

ID Name Affiliation Comment Re

of transportation and infrastructure projects in HQTA/TOC will

increase gentrification and displacement of environmental

justice populations. The forecasted benefits for environmental

justice populations are likely negated or overridden by

predicted geographical shifts.

In order for SCAG to properly mitigate disparities in

transportation, housing, and land use impacts in low‐income

and minority communities, it must monitor population changes

by more detailed population segments (i.e. neighborhoods,

census tract) because root factors of inequities play out at these

population segments. It is difficult to illustrate short‐term

impacts and long‐term benefits on the environmental justice

population without such details. For example, the continued

poor job housing fit and balance in the SCAG region leave lower‐

income populations with no public or active transportation

options in their daily commute. Metrics need to demonstrate

immediate changes to transportation usage from ticket pricing,

placement of rapid bus transit stops in high concentrations of

lower‐income and elderly groups, and safety programs for

walking and bicycling. (see link: Health Equity and Prevention

Primer, Prevention Institute)

Additionally, SCAG should provide the tools and policies for

local jurisdictions to develop strategies to reduce commute

distances and relieve sedentary lifestyles for lower income and

communities of color. Healthy, sustainable, and accessible

place‐making is crucial to the environmental justice population

because geography and socioeconomic structure are influential

predictors of obesity in the United States. Environmental justice

populations must be ensured the opportunity to go to school,

live, work, and play in all neighborhoods through land use

strategies, incentives for businesses and developers,

infrastructure and non‐infrastructure programming, such as

Complete Streets, first/last mile to transit, density bonus,

parking reductions, safe and secure bicycle parking and street

crossings, and affordable and work force housing in HQTA/TOC.

(see link: Why Place & Race Matters, Policy Link)

SCAG does not adequately link RTP/SCS active transportation

funding to its environmental justice obligations. The lack of

active transportation funding

disproportionally affects immigrant, lower‐income, and minority

correlate to confidential heal

from the Los Angeles County, 

SCAG anticipates completing 

prior to the next round of Reg

Sustainable Communities Stra

enhance our efforts in tabula

residents in the region and to 

understanding the linkages b

community health, SCAG’s cu

is to enhance the Sustainabili

by refining the tool's base dat

through collecting informatio

outcomes, (2) safety ‐ pedest

(3) emissions (PM, CO, CO2, N

(dispersion), (4) energy usage 

usage, (6) water quality (tota

Vehicle Miles Traveled (VMT) 

environmental indicators (suc

available from the US Environ

Release Inventory (TRI)). Onc

can conduct a correlation and 

environment and determinan

hospitals, etc., buildings, desi

access, park, open space, wal

environmental outcomes liste

obtained health data from Lo

Public Health, parcel level gas 

and water consumption data 

there will be many collaborat

stakeholders in various policy 

consensus on recommended 

practices for the use of the to
365

ID Name Affiliation Comment Re

populations because these neighborhoods have greater barriers

to physical activity and transit access, higher numbers of busy

regional arterial, poor pedestrian and bicycle infrastructure,

unsafe neighborhoods, and lack of safe storage for bicycles and

safe crossings. Thus, these neighborhoods would benefit from

an increase in funding allocations (in order for SCAG to meet its

Title VI obligations) and from a detailed strategic plan. (see

links: Do All Children Have Places to Be Active, Active Living

Research; Low Income Resource Guide, Safe Routes to School

National Partnership)

131‐01 Rye Baerg Safe Routes to

SchoolNationalPartnership

When we get to the 2016 RTP, in four years, I want to see us

have strong, solid, ground work for active transportation. I want

SCAG to do some really strong regional planning. I want Staff to

work with the CTC’s to make sure that we know the numbers

that are out there, we have the strong funding sources available

so than when we get to this process again in 2016 we are

adequately prepared for that.

Comment noted.

132‐01 Pauline Chow Safe Routes to

SchoolNationalPartnership

Per 2009 National Household Travel Survey, 21 percent of all

trips in the SCAG region are currently being done via walking

and bicycling.

Comment noted.

132‐02 Pauline Chow Safe Routes to

SchoolNationalPartnership

And tragically, per SCAG 2012 Draft RTP, 25 percent of all

roadway fatalities in the SCAG region are pedestrians and

bicyclist.

Comment noted.

132‐03 Pauline Chow Safe Routes to

SchoolNationalPartnership

The RTP/SCS provides 1.3% of its funding to active

transportation. 80% of the 1.3% funding ‐ 6 billion dollar ‐ is not

funded until after 2025. Communities will not see the benefits

of walking and bicycling to school, work, and play for at least 13

years.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

SCAG cannot unilaterally chan
366

ID Name Affiliation Comment Re

that are already in place. Sign

active transportation propose

predicated on additional reve

require future actions at the s

Therefore, the plan realistica

not be available in the near te

expected to be available is 20

132‐04 Pauline Chow Safe Routes to

SchoolNationalPartnership

I am a resident of Upland, San Bernardino County, CA and enjoy

using the Pacific Electric Trail and Bike lanes, where they exist.

However, safety for pedestrians and bicyclists in my city is a

huge problem. The last couple of mile to my destination from

the Pacific Electric Trial is where I feel unsafe and a target for

injury....or even death. This region has great resources and with

a little more effort, it can develop the infrastructure for

adequate active transportation. Regards, Pauline Chow, Esq.

Southern California Regional Policy Manager Safe Routes to

School National Partnership

Comment noted.

133‐01 Larry McCallon San

BernardinoAssociatedGovernments

The RTP/SCS growth forecasts should be adopted at the County‐

level, not at the city or TAZ level. SANBAG needs the ability to

adapt the forecasts to development trends and new

information that will inevitably come to light at the small‐area

level over the next 4‐year RTP/SCS cycle. This is consistent with

SCAG's approvals in the past.

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use de

allocation being adopted at th

that the SCS be based on a ju

distribution.

133‐02 Larry McCallon San

BernardinoAssociatedGovernments

The growth distribution at the TAZ level needs to be adjusted to

be consistent with the distribution of growth for households

and employment being submitted by SANBAG in parallel with

the comment letter. The growth distribution is based on the

distribution of households and employment previously

submitted by SANBAG, together with adjustments for the Plan

Alternative of the RTP/SCS. No change is being suggested in the

city‐level distribution of growth.

Comment noted. The comme

incorporated into the final da

submitted by SANBAG.

133‐03 Larry McCallon San

BernardinoAssociatedGovernments

Please confirm that the East‐West Freight Corridor (dedicated

truck lanes) will continue from SR‐60 northerly on the I‐15 and

terminate just to the north of I‐10, with appropriate connector

ramps to and from I‐10 east of I‐15. This is stated in the text of

the draft RTP/SCS, but some of the maps and the transportation

model networks are not yet consistent with this.

Comment noted. The propose

Freight Corridor included in t

facility would continue from S

terminate just to the north of 

networks will reflect consiste

133‐04 Larry McCallon San

Bernardino

We would like to request modifications to the project list, as

submitted to SCAG staff through the standard RTP long‐range

Comment noted. SCAG has ad

to the RTP Project List as subm
367

ID Name Affiliation Comment Re

AssociatedGovernments

project list modification and FTIP database update processes.

These changes have been previously communicated to SCAG

staff subsequent to the release of the Draft RTP and are being

confirmed below [refer to letter for details].

commissions, including SANB

long‐range project list modifi

processes.

133‐05 Larry McCallon San

BernardinoAssociatedGovernments

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

134‐01 Robert Scott San Fernando

Valley CouncilofGovernments

SCAG is to be congratulated on the production of this

unprecedented draft document that does laudable job of

combining a Regional Transportation Plan and the inaugural

"Sustainable Communities Strategy." The San Fernando Valley

Council of Governments represents the San Fernando and Santa

Clarita valleys, a metropolitan region of over two million—more

populous than 15 states, and one of the largest unified regions

in the United States. Until now, we have not always had the

opportunity to fully participate in SCAG planning activities as a

region. We welcome this opportunity. Because of the shortness

of time, we will be unable to submit a full and substantive reply

by the end of the public comment period on February 14, 2012.

We note that SCAG’s regional transportation modeling area

covers the Counties of Imperial, Los Angeles, Orange, Riverside,

San Bernardino, and Ventura. This modeling area is divided into

11,267 Transportation Analysis Zones (TAZs). Unfortunately, the

TAZ maps were only made available on January 26th of this

year. There has been very little time for meaningful analysis.

Comment noted.

134‐02 Robert Scott San Fernando

Valley CouncilofGovernments

The City of Los Angeles and other respondents have noted that

the plans tend to be inconsistent with existing Community Plans

and General Plans. This could result in confusion, cost and

needless litigation. We would like to reserve the opportunity to

comment further as the process continues to unfold.

Substantive points have been raised by several credible groups.

Given the significance of the RTP/SCS, we must approach this

task with care, and the issues raised by SCLC, OCBC and the City

of Los Angeles, inter alia, certainly bear further, and more

detailed discussion.

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as

trends occurring in many tran

the SCS is intended to provide 

local governments may build 

generally includes the quantit

each city and county in the re

local land use authority.

134‐03 Robert Scott San Fernando

Valley Councilof

Further consideration is needed on "Policies and Principles of a

Sound RTP/SCS" as stated: 1. Provides Positive Economic

Impacts ... A Plan that is pro economic growth and job creation

Comment noted. The Econom

Appendix to the final RTP/SCS 

more comprehensive assessm
368

ID Name Affiliation Comment Re

Governments the 2012 RTP/SCS.

134‐04 Robert Scott San Fernando

Valley CouncilofGovernments

2. Provides Local Control ... A Plan that honors local control and

flexibility over land use and transportation

Comment noted. This RTP/SC

flexibility over land use and tr

region.

134‐05 Robert Scott San Fernando

Valley CouncilofGovernments

3. Assures New Revenue Sources are Fair, Equitable and

Economically Sound

Comment noted. The Transpo

additional detail and explanat

included in the RTP. We cons

principles as a foundation for 

revenues that are reasonably 

financial strategies: • Establis

reflects the true cost of trans

protection for transportation 

distribution of costs and bene

programs that include return

maintaining flexibility to rewa

commit substantial local reso

funding with innovative finan

expansion of TIFIA) to attract 

project delivery. • Promote fu

federal commitment to the n

recognizing the pivotal role th

and international trade. The i

return of $2.90 for every doll

134‐06 Robert Scott San Fernando

Valley CouncilofGovernments

4. Is Balanced and Accountable Comment noted. The Transpo

additional detail and explanat

included in the RTP. We cons

principles as a foundation for 

revenues that are reasonably 

financial strategies: • Establis

reflects the true cost of trans

protection for transportation 

distribution of costs and bene

programs that include return

maintaining flexibility to rewa

commit substantial local reso

funding with innovative finan

expansion of TIFIA) to attract 

project delivery. • Promote fu

federal commitment to the n
369

ID Name Affiliation Comment Re

recognizing the pivotal role th

and international trade. The i

return of $2.90 for every doll

134‐07 Robert Scott San Fernando

Valley CouncilofGovernments

As a matter of process, it is recommended as follows: • Extend

the public comment period to allow a more full and fair

discussion of the issues.

Comment noted. We apologiz

not be extended primarily du

by deadlines for SCAG to mee

conformity requirements.

134‐08 Robert Scott San Fernando

Valley CouncilofGovernments

• Create an Issue Matrix of all recommendations to allow easier

reference, for discussion and resolution. • Share the Issue

Matrix, including pros and cons with all subregions, COGs,

stakeholders and the Regional Council.

Comment noted. SCAG has ut

Responses matrix as part of t

purpose of discussing and res

134‐09 Robert Scott San Fernando

Valley CouncilofGovernments

• Highlight controversial issues for detailed discussion and

consensus building.

Comment noted.

134‐10 Robert Scott San Fernando

Valley CouncilofGovernments

• Seek strategies that emphasize empowerment and incentives

rather than compliance and regulation.

Comment noted.

134‐11 Robert Scott San Fernando

Valley CouncilofGovernments

• Set forth overarching disclaimers [local jurisdictions'

reservation of rights] to clarify what the RTP/SCS is not. Focus

on the legal implications of the RTP/SCS and PEIR.

Comment noted. The 2012 RT

jurisdiction's land use policies 

consistent with the RTP or SC

provide a regional policy foun

may build upon if they so cho

quantitative growth projectio

the region , local jurisdictions 

134‐12 Robert Scott San Fernando

Valley CouncilofGovernments

• Reconcile reduction in greenhouse gases (GHG) with loss of

gas tax revenues.

Comment noted. The Transpo

additional detail and explanat

included in the RTP, including 

gasoline. As is noted in the Pl

purchasing power due to cha

of hybrid and electric vehicles

excise rates. Improved vehicl

reduced greenhouse gas emis

134‐13 Robert Scott San Fernando

Valley CouncilofGovernments

• Provide outreach and public information that contains

standardized references, metrics and common denominators—

materials that can be readily understood by local leaders,

constituents and the consuming public.

Comment noted. SCAG will co

its outreach activities to ensu

local leaders and the public i

understandable.

134‐14 Robert Scott San Fernando • Emphasize the economic realities of existing transportation Comment noted. The RTP/SC
370

ID Name Affiliation Comment Re

Valley CouncilofGovernments

systems, and explain the need for, and alternatives for future

improvements.

of our existing transportation 

sustainable funding source an

from federal and state source

system. The strategies of this 

understood reality with user systems and the assumption 

funding source will need to b

maintain and improve our ex

systems.

134‐15 Robert Scott San Fernando

Valley CouncilofGovernments

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

135‐01 Carolyn

Casavan

San FernandoValley GreenTeam

It is apparent that a great deal of time and effort have gone into

the preparation of the Draft 2012‐2035 RTP/SCS and the

interactive version provided on the website provides an

excellent format for the community to access and comment on

the plan. That being said, this is the first time that we are seeing

all of this work pulled together and we believe that the public

needs more time to effectively comment on the plan. We

strongly recommend extending the comment period by 30‐60

days. The following are our initial comments regarding the Draft

2012‐2035 RTP/SCS. A more thorough analysis and response will

be prepared if the comment period is extended.

Comment noted. The 55‐day 

period for the Draft 2012‐203

and Sustainable Communities 

14, 2012, and this process co

state requirements. During th

engaged in extensive outreac

the regional stakeholders, inc

transportation commissions, 

representatives from the priv

development of the draft RTP

that the comment period cou

to schedule constraints dictat

federal transportation confor

135‐02 Carolyn

Casavan

San FernandoValley GreenTeam

Increase investment in and give higher priority to mass transit

projects, especially local projects that improve the accessibility,

frequency, and convenience of public transportation for getting

around within and between local cities. As can be seen from the

Orange and Red Lines, people will use public transportation that

meets these standards. We need more projects that reach more

locations. We need to increase the capacity of existing projects,

such as the Orange Line, to meet growing demand. And we

need to improve access to other projects such as the Red Line.

Comment noted. The RTP inc

and operating funding.

135‐03 Carolyn

Casavan

San FernandoValley GreenTeam

Focus funding for highways and streets on maintenance rather

than expansion. It is better to reach our goals through

reductions in vehicle miles traveled (VMT) than through

expansion of vehicle access. We don’t even have enough money

to maintain our existing streets and highways. Why would we

Comment noted. The RTP/SC

highway preservation than in 

for highway operations and m

$20.9 billion for local streets 
371

ID Name Affiliation Comment Re

add more lane miles to these conditions? Let’s focus on

improving what we have before building more.

135‐04 Carolyn

Casavan

San FernandoValley GreenTeam

Integrate transit stops and bicycle racks/storage with local

communities. Consider multi‐use parking facilities that

accommodate complementary parking needs, such as transit

and high density residential. Enhance linkages between transit

stops and nearby commercial districts. Considered preferred

parking at rail stations for carpool and/or vanpool.

Comment noted. The 2012 RT

investment in Active Transpo

mile projects.

135‐05 Carolyn

Casavan

San FernandoValley GreenTeam

Develop tourism and entertainment oriented transit. Provide

rail service between cities and tourism destinations with

weekend schedules that enable day and weekend trips (i.e.,

early morning and evening service). Configure bus routes and

transit schedules on weekends to connect restaurant and

entertainment districts in the City of Los Angeles and enhance

these linkages with shuttle and pedicab services between transit

stops and entertainment districts, such as between the North

Hollywood transit station and the nearby North Hollywood

commercial district.

Comment noted. The RTP inc

increase in existing ones that 

and entertainment destinatio

135‐06 Carolyn

Casavan

San FernandoValley GreenTeam

Change the mileage based fee for vehicles to a GHG based fee

collected as part of the vehicle registration process. Paying this

fee as part of registration rather than as fuel taxes, raises

individual awareness of vehicle related GHG emissions and the

fee can be tiered to further incentivize fuel efficiency and

reduced VMT. The fee can be based on vehicle miles traveled

times the miles per gallon rating of the vehicle to determine

GHG emissions. For many automobiles the actual gas usage is

already available in their navigation systems. For others, vehicle

mileage can be reported annually and trued up at time of sale.

Comment noted. SCAG will co

part of our subsequent work 

issues for the mileage‐based 

135‐07 Carolyn

Casavan

San FernandoValley GreenTeam

Increase funding for Active Transportation, First Mile/Last Mile,

and Transportation Systems Management.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu
372

ID Name Affiliation Comment Re

will continue to evaluating fu

and pursue new funding sour

135‐08 Carolyn

Casavan

San FernandoValley GreenTeam

Determine the cost effectiveness of high‐speed rail relative to

GHG reduction, congestion reduction and number of passengers

served and compare to the cost‐effectiveness of other transit

projects. Set a standard for cost‐effectiveness and design

projects to meet this standard or withhold funding.

Comment noted. The Californ

Plan contains a cost/benefit a

135‐09 Carolyn

Casavan

San FernandoValley GreenTeam

Set a goal to reduce vehicle miles traveled within the region

rather than facilitating driving.

Comment noted. A reduction 

135‐10 Carolyn

Casavan

San FernandoValley GreenTeam

Plan for the retention and expansion of manufacturing

capabilities in the region. Local manufacturing is a critical

component of sustainability. It is essential to providing good

paying jobs for skilled workers and supports the regional

economy by retaining capital in the community and contributing

to a more stable tax base, it reduces GHG emissions resulting

from transportation related to importing goods from overseas,

it showcases the resources and skills of the region, and it

stimulates innovation by providing an outlet for new ideas. The

purchase of regional materials/labor is good for the economy

and good for the environment. Encourage this type of

development by enhancing rail transit to and from local

manufacturing centers, protecting industrial areas from

encroachment of incompatible land uses and developing

strategies to facilitate the growth of sustainable local

manufacturing.

Comment noted. SCAG has co

with business leaders through

RTP/SCS. For example, the Gl

with representatives from pri

California Leadership Council

Council and Inland Empire Ec

Economic and Job Creation St

Regional Council in June 2011

is on retaining and creating m

the policies and investment la

in the 2012 RTP/SCS will facil

jobs and serve manufacturing 

136‐01 Angel Carrillo San Gabriel

Valley CouncilofGovernments

As its Governing Board meeting on February 16th, the San

Gabriel Valley Council of Governments (SGVCOG) Governing

Board adopted a position of "support" for the above mentioned

alternative for the SCAG Draft 2012 Regional Transportation

Plan (RTP)/Sustainable Communities Strategy (SCS). The draft

RTP/SCS includes four alternatives. The San Gabriel Valley

Council of Governments supports Alternative B as this

Alternative best addresses future transportation needs and

anticipated changes associated with future growth.

Comment noted.

137‐01 Cynthia Kurtz San Gabriel

ValleyEconomicPartnership

The Partnership supports the Gold Line Foothill Extension the

Montclair as a part of the RTP constrained plan. The Partnership

supports the completion of the Alameda Corridor East in the

constrained plan. America Fast Forward (30/10 initiative)

addresses the need for improving the Los Angeles County

Comment noted. Regarding t

carpool lanes on I‐10 from SR

please note that projects #LA

included in the RTP and when 

continuous carpool lanes from 
373

ID Name Affiliation Comment Re

transportation infrastructure quickly. Specifically, projects that

the Partnership continues to support that are included in the

30/10 initiative are the Goldline Eastside Extension SR 60

alignment as well as the Goldline Foothill Extension, and the

Regional Connector. We support leveraging the voter approved

Measure R funds to complete the above projects in an

expedited manner. The Partnership supports SCAG evaluating

the impact of using funds earmarked for High Speed Rail to

improve the current regional Metrolink service. Highway 71 in

Pomona is a bottle neck point in the San Gabriel Valley. The

Partnership supports SCAG in their plan to change the highway

from an expressway to a full freeway between I‐10 and SR‐60

with the addition of 1 mixed flow lane and 1 HOV lane in each

direction as part of the constrained plan. The Partnership

recommends the RTP include carpool lanes on the I‐10 Freeway

from Route 57 to downtown Los Angeles.

137‐02 Cynthia Kurtz San Gabriel

ValleyEconomicPartnership

• Adding express bus service as a part of the proposed High

Occupancy Toll Lanes network is imperative if the project is to

be successful. Additionally, we ask SCAG to evaluate the Metro

Express Lanes Project before committing to a regional High

Occupancy Toll network.

Comment noted. We agree th

network could prove much m

of express bus service. We lik

the Metro Express Lane demo

critical input on subsequent d

Express/HOT lane network.

137‐03 Cynthia Kurtz San Gabriel

ValleyEconomicPartnership

• Addressing increased east west truck traffic in the San Gabriel

is important. However, the East West Freight Corridor proposed

in the RPT has not had sufficient public input. Many of our

member cities are opposed to the project as they understand it

today. We ask that SCAG take the time necessary to consult

with the community before moving forward.

Comment noted. SCAG has pr

for input to the 2012 RTP/SCS

limited to, the SCAG RTP/SCS 

meetings, a series of eighteen 

Summer 2011, and eighteen a

hearings held following the re

workshops were held in every 

input from various interests s

representatives of public age

and environmental, housing a

see the SCAG RTP Public Part

http://www.scagrtp.net/cont

continue to work with partne

adoption of the 2012 RTP/SCS

information on the 2012 RTP/

Corridor to the San Gabriel Va

Transportation Committee an

membership, on several occa
374

ID Name Affiliation Comment Re

Council of Governments have 

SCAG staff recommendations 

conducted considerable outre

Valley adjacent to the propos

SCAG intends to continue to w

including cities of the San Gab

West Freight Corridor.

137‐04 Cynthia Kurtz San Gabriel

ValleyEconomicPartnership

The Partnership recognizes that declining gas tax will impact the

maintenance of our highway system unless alternative revenue

sources are available. We support studying evaluating other

revenue options including one based on vehicle miles traveled

to replace gas tax. However, we are aware that other agencies

are evaluating new transportation fees as well such as the

traffic mitigation fee proposed by METRO. During these difficult

economic times, any new tax or fee could result in additional

job loss. Economic impacts need to be considered before asking

voters for any additional transportation funding.

Comment noted. We agree th

before the mileage‐based use

which is basis for assumption 

after 2025. The projected rev

fee and adjustments to state 

combined with the core reve

sources generate less revenu

increase in state and federal t

five percent annually. Rather 

of the historical growth rate, 

requirements, we detailed sp

state and federal transportat

with recommendations from 

established by Congress throu

efforts underway throughout 

implementation plan for the 

Transportation Finance Appe

implementation plan will be s

disproportionate impacts to u

assume any revenues associa

fee feasibility study currently 

of a proposed restructuring o

Program.

138‐01 Kim Floyd San Gorgonio

Sierra Club

We are pleased to see an advanced mitigation component in

the Draft 2012 RTP/SCS. This is an excellent first step to creating

a program that thoughtfully mitigates impacts to our natural

environment from transportation projects. As you know,

Orange County and San Diego have similar programs that have

met great success. By incorporating this strategy into your

policy document, the many benefits of this large‐scale

conservation approach will be realized. Thank you for your

leadership.

Comment noted.

138‐02 Kim Floyd San Gorgonio Under the Endangered Species Act, the United States Fish and Comment noted. The propose
375

ID Name Affiliation Comment Re

Sierra Club Wildlife Service have defined critical habitat as areas that

support endangered or threatened species that are essential to

the species’ conservation. The description in the Conservation

Planning Policy section (page 76 of the Draft 2012 RTP/SCS)

states “large‐scale acquisition and management of critical

habitat to mitigate impacts related to future transportation

projects” [emphasis added]. We believe there are other habitat

areas in the SCAG region worth considering for acquisition and

management and therefore SCAG should not limit the

mitigation opportunities to only critical habitat. We suggest

expanding the language to incorporate all “important habitat

lands.”

pursue a strategic planning p

resources among a wide varie

include all applicable protecte

clarified.

138‐03 Kim Floyd San Gorgonio

Sierra Club

On page 78 of the Draft 2012 RTP/SCS, the document mentions

the 2008 Regional Comprehensive Plan that inventoried

protected and unprotected areas in relationship to wildlife

linkages, linkage designation areas, park and recreation areas.

We were pleased that SCAG completed this Plan showing what

areas are protected and critical to maintaining functioning

habitat reserves. We agree that the planning efforts SCAG

undertakes in the future should involve updating the maps, but

recommend expanding the language in this section to include all

forms of protected lands. By limiting the acquisition and

management opportunities of conservation lands to just Natural

Communities Conservation Plan (NCCP) or Habitat Conservation

Plan (HCP) areas, decisions about priority conservation areas

will be misinformed. In fact, it no longer demonstrates a

comprehensive plan because of the limited scope (of pre‐

established mitigation sites, which are likely unrelated to

transportation projects). Protected areas (e.g., National Forests,

State Parks, Regional Parks, etc.) not in an NCCP/HCP are

excluded from the big picture, yet they have extensive benefits

to the entire open space system and often times link important

habitat areas throughout the region. Consequently, we

recommend having this updated map and mitigation site

locations expanded to include more than just NCCP/HCP areas

and instead include all levels of protected lands (federal, state,

regional, and local).

Comment noted. The propose

pursue a strategic planning p

resources. The intent is to inc

not just NCCP/HCP areas, bas

stakeholders. Language has b

138‐04 Kim Floyd San Gorgonio

Sierra Club

On page 79 of the Draft 2012 RTP/SCS, we were encouraged to

see SCAG recognize the benefits of reducing transportation

impacts to sensitive lands and encouraging smart land use

Comment noted. The mitigat

Resources and Open Space in

of habitat linkages, preservat
376

ID Name Affiliation Comment Re

decisions. We believe landscape level advanced mitigation will

become a statewide planning policy. Planning future

transportation projects with a comprehensive mitigation

program ensures our open space infrastructure can continue to

function and maintain viable habitats, linkages, and species

populations in perpetuity. Unfortunately, we noticed the lack of

inclusion of wildlife linkages in this section. Orange County’s

transportation measure language included wildlife linkages and

we recommend SCAG include linkages as well. We appreciate

SCAG’s effort to create a strategic planning process that would

document important conservation lands in the region. We

believe there is an important opportunity with this concept to

also create a Southern California Greenprint. By completing a

Greenprint a comprehensive view of our open space land

attributes would be documented. Such attributes include:

recreation priorities, agricultural lands, scenic values, historic

preservation, and more. A Greenprint would give a more

complete picture of both opportunities and challenges, while at

the same time respecting property rights.

crossings to minimize the imp

wildlife species and habitat fr

possible option for the mitiga

discussed with a wide variety 

139‐01 Jerry Paresa San Manuel

Band ofMissionIndians

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

140‐01 Elizabeth

Cheadle

Santa MonicaMountainsConservancy

Avoidance of Growth in Resource Areas The RTP/SCS generally

steers growth toward more compact forms in already urbanized

areas, making efficient use of existing infrastructure and

reducing impacts to resource lands. The policy decisions

contained within the SCS are projected to save 408 square miles

of nonurban land over the life of the plan. If realized, these

gains are certainly an achievement, although there is no

projection of where this growth will not occur and what

mechanisms will preserve the land in perpetuity. The lack of

specificity makes it difficult for the Conservancy to evaluate the

impacts of the proposed plan. While the projections are

intended to be a meta‐analysis of regional economic trends

rather than a location‐specific analysis of growth patterns, SCAG

is clearly making assumptions about where development on

resource lands is and is not appropriate. This process is not

transparent. For example, the Regional Housing Needs

Assessment (RHNA) assigns population targets for different

Comment noted. The mitigat

Resources and Open Space in

of habitat linkages, preservat

crossings to minimize the imp

wildlife species and habitat fr

regional plan based on exten

input. SCAG’s SCS is based up

jurisdictions, along with volun

transit oriented development

discretionary resources to au

which provides grants to mun

achieve sustainable commun

require that a jurisdiction’s la

including its general plan, be 

agencies, including local juris

discretion in how to determin

with the SCS. The growth and 
377

ID Name Affiliation Comment Re

subareas of the region, which are then used to justify additional

development whether or not it is consistent with stated goals to

encourage compact development within existing urban areas.

Newhall Ranch has used the RHNA targets as the basis for its

massive expansion into open space areas west of Santa Clarita,

resulting in unmitigable habitat and connectivity loss. At least

Newhall Ranch is contiguous with the existing Santa Clarita

urban area. SCAG appears to endorse the proposed Centennial

development at Tejon Ranch by projecting housing demand in

the area‐‐no doubt a self‐fulfilling prophecy‐‐despite flagrantinconsistency with SCS objectives. These decisions serve as the

basis for urbanization of resource lands, yet are not made in

consultation with resource agencies. With the understanding

that land use authority belongs to local jurisdictions, a truly

comprehensive regional plan would transparently set growth

parameters in concert with resource conservation goals to

eliminate these apparent contradictions. Projecting growth in

resource areas sets in motion policies that induce that growth;

therefore great care must be taken to ensure such growth

meets regional objectives.

RTP/SCS are proposed to be a

140‐02 Elizabeth

Cheadle

Santa MonicaMountainsConservancy

Wildlife Crossings of Transportation Facilities The Conservancy

appreciates SCAG's recognition of the impact that linear

transportation facilities have on natural areas and the need for

well‐designed wildlife crossings to partially mitigate these

effects. Wildlife crossings serve two distinct purposes: reducing

mortality and preserving genetic connectivity. Roads are the

leading direct source of human‐caused mortality for most

species in Southern California and the entire country. They can

become a population sink if a significant fraction of a local

species is killed, affecting broader population distribution across

the landscape. Additionally, for highly mobile predators,

individuals crossing roads are frequently dispersing from their

home range in search of new territory and mates, a vital

population dynamic that is devastating if interrupted. National

Park Service research has documented significant genetic

differences among carnivore populations on either side of the

101 Freeway in the Santa Monica Mountains. Wildlife crossings

need to be discussed in the context of habitat connectivity,

which is the broader ecological goal for conservation areas.

Wildlife crossings are but one critical tool to ensure that

Comment noted. The mitigat

Resources and Open Space in

of habitat linkages, preservat

crossings to minimize the imp

wildlife species and habitat fr

conservation strategy, SCAG, 

stakeholders, may pursue add

which could be incorporated 

forward to working with the S

Conservancy on future planni
378

ID Name Affiliation Comment Re

indicator species are able to safely move about their

environment. The Conservancy has partnered extensively with

the National Parks Service, U.S. Geological Survey, and UCLA to

research movement corridors in Southern California, with an

emphasis on our core jurisdiction in the Santa Monica

Mountains, Simi Hills, Santa Susana Mountains, San Gabriel

Mountains, and Verdugo Mountains. While much has been

learned about movement patterns in these areas and the way in

which key transportation facilities create genetic barriers to

connectivity, the measures that might mitigate these impacts

have not been thoroughly researched. Wildlife corridor design is

a field in its infancy with few scientifically verified best practices

for crossing dimensions and landscape features. Given that this

research is needed to properly mitigate transportation impacts,

SCAG should invest in connectivity research with a program

specifically designed to establish measures that can be

incorporated into the 2016 RTP revision. Such a program would

aggregate existing research, propose new study areas, and

develop design best practices specifically tailored to the

Southern California eco‐region.

140‐03 Elizabeth

Cheadle

Santa MonicaMountainsConservancy

Environmental Mitigation Program SCAG has identified the need

for a regional Natural Lands Acquisition and Open Space

Conservation Strategy to protect remaining resource lands and

mitigate for impacts from transportation improvements. The

Conservancy looks forward to working with SCAG on the

development of such a strategy. In addition to mitigation

banking, transfer of development rights, and payment of in‐lieu

fees, the Conservancy recognizes conservation easements as a

powerful preservation tool for habitat areas. Conservation

easements should be listed in the plan alongside the other

preservation mechanisms. The Conservancy has supported the

establishment of transfer of development rights (TDR) programs

in multiple updated general plans as a potentially useful market‐

based preservation mechanism that supports regional density

goals. SCAG should take a leadership role in setting guidelines

and best practices for these new county and municipal

programs as well as explore the creation of a regionally unified

TDR program.

Comment noted. The propose

pursue a strategic planning p

resources. The intent is to inc

based on input from a wide v

Conservation easements and 

for the mitigation program th

stakeholders, including memb

140‐04 Elizabeth

Cheadle

Santa MonicaMountains

River Parkways and Active Transportation As mentioned

previously, the Conservancy is interested in urban river projects

Comment noted. The 2012‐20

approximately $6.7 billion tow
379

ID Name Affiliation Comment Re

Conservancy for their multiple recreational, environmental, and

transportation benefits. The RTP/SCS should fully fund build‐out

of these active transportation corridors throughout the region.

When well designed, these facilities serve as "bicycle freeways"

connecting various parts of the region with uninterrupted travel

for nonmotorized users. For this reason, the Los Angeles River

trail featured prominently in the "Carmageddon" race between

Jet Blue and a group of elite bicyclists from Burbank to Long

Beach. Separated from traffic, such facilities are also inviting for

bicyclists of all ages and abilities, which is necessary to attract

substantial mode share away from automobiles. The draft Los

Angeles County Bicycle Master Plan, among others, calls for

build‐out of the river trail system and includes preliminary cost

estimates. The RTP/SCS calls for $6 billion over the next two

decades for active transportation investments, which seems low

when compared to the identified need in local bike and

pedestrian plans. Given the central role active transportation

plays in meeting regional planning objectives, funding levels

should be set based on full build‐out of local bicycle and

pedestrian plans, with an appropriate amount projected for

those jurisdictions that have not yet completed such plans. The

currently proposed funding level does not appear to be rooted

in such a need‐based assessment. It is not adequate to simply

compare the proposed expenditures with past levels

independent of a needs assessment. In addition to the total

funding level, the proposed timing of active transportation

investment is inadequate. Only 20 percent of the proposed

expenditures would occur during the first 15 years of the 25‐

year planning period, leaving the vast majority of expenditures

for the highly speculative future and of little use to current

residents. Transit and transportation demand management aresimilarly back‐loaded with only highway‐related investmentsreceiving funding priority in the near term. These nonhighway

investments are the ones most likely to generate greenhouse

gas emissions savings, among other benefits, and the earlier

they are made the longer the benefits can accumulate. The

proposed expenditure plan runs directly counter to the stated

emphasis of the SCS.

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

SCAG cannot unilaterally chan

that are already in place. Sign

active transportation propose

predicated on additional reve

require future actions at the s

Therefore, the plan realistica

not be available in the near te

expected to be available is 20

140‐05 Elizabeth

Cheadle

Santa MonicaMountains

Active transportation projects, including the river parkways, are

suffering for lack of funding. The most visionary plans, such as

Comment noted.
380

ID Name Affiliation Comment Re

Conservancy the City's Los Angeles River Revitalization Master Plan, require

extensive funding to come to fruition and provide their multiple

benefits. Planning is well underway, but capital dollars are in

short supply for these projects. Furthermore, achieving

greenhouse gas reduction and air quality goals requires early

mode shift to maximize cumulative benefits over the life of the

plan. The Conservancy suggests that the plan's funding priorities

be reversed to immediately fund active transportation

investments at a sufficient level to achieve build‐out of the

region's bicycle and pedestrian networks in the near and

medium term. Such a change would make the RTP more

consistent with the land use and mode share objectives outlined

by the SCS, the intent of SB 375.

140‐06 Elizabeth

Cheadle

Santa MonicaMountainsConservancy

Environmental Justice and Public Health Like SCAG, the

Conservancy takes its commitment to environmental justice

seriously as a State agency. The Conservancy is therefore

delighted to see equal access to parks, one of its core missions,

considered as a performance measure for environmental

justice. The SCAG model does not currently include programs

intended to ameliorate these access issues, such as the

Mountains Recreation and Conservation Authority's (MRCA)

Transit to Trails program. Given the inherent remoteness of

open space parkland, it is likely infeasible to run regular transit

service to most parks. The highly successful Transit to Trails fills

this gap, but is perpetually underfunded in comparison to the

access demand. Funding for such programs from SCAG

transportation funds would be appropriate mitigation for

impacts to environmental justice populations. Part of embracing

environmental justice as a core mission includes looking

holistically at issues that affect the community. Poor air quality

is not the only impact from a transportation system that is

overly reliant on cars. Obesity and related illnesses are a direct

result from community design that does not allow for safe

opportunities to walk and bike for everyday transportation. The

RTP/SCS should therefore include obesity‐related health

outcomes as a performance measure for the regional

transportation system. The currently unequal health outcomes

will require targeted investments in disadvantaged communities

to create active transportation networks that provide access to

services, jobs, schools, and parks. River parkways directly

Comment noted. SCAG is con

data and technical approache

patterns of the region’s 18 m

local knowledge on the healt

environment, SCAG is current

Sustainability Tool (ST) by ref

environment, and through co

following areas (1) health out

bike accidents and injuries, (3

Ozone) and air quality (disper

& gas), (5) water usage, (6) w

loads ‐ TMDL), (7) Vehicle Mil

accessibility, (8) various envir

pollutant information availab

Protection Agency’s Toxics Re

information is obtained, staff 

modeling analysis to link the 

determinants (road, freeway, 

buildings, design, fast food an

open space, walk/bike ways) 

listed above. So far, SCAG sta

Los Angeles County Departme

gas and electricity consumpti

data for certain localities. We 

collaborations and technical e

various policy areas with the 

recommended approaches in 
381

ID Name Affiliation Comment Re

address this need by providing bikeways through many of the

poorest communities in the region.

the use of the tool. As noted 

performance measures that h

stakeholders for monitoring u

outcomes. However, these m

for data collection or further 

potential uses for monitoring

RTP/SCS updates if additiona

Additional funding for Transit 

greater detail in preparation f

the Region’s County Transpor

forward to working with the S

Conservancy on these import

140‐07 Elizabeth

Cheadle

Santa MonicaMountainsConservancy

Additionally, the safety performance measure appears to

discount the health benefits of active transportation while

overstating risks. SCAG methodology rewards shifts to "safer"

modes, but uses datasets that penalize pedestrians and

bicyclists for being hit by cars. This methodology would

discourage investments that increase active transportation

when it is precisely these investments that address the safety

issues faced by those bicycling and walking on public streets.

The methodology further does not include the well‐

documented "safety in numbers" phenomenon that decreases

risk for active modes the more people utilize them. Likewise, it

does not consider improved public health outcomes that have

been calculated to more than offset risk. The poor safety

performance of walking and bicycling modes is justification for

increasing investment in active transportation, particularly

separated facilities for bicyclists.

Comment noted. The Active T

research performed by Dr. Je

University) indicates that incr

(bicycle lanes and bicycle pat

greater bicycle usage. In addi

has doubled along with the n

fatalities have not grown, and 

total. While the anecdotal ev

bicycling also provides an inc

the causes for that safety incr

Active Transportation Safety 

complete streets policies at t

for all modes – as fundament

plans. SCAG is proposing to in

the region from approximate

SCAG is also proposing to incr

transportation from $1.8 billi

Performance Measures Appe

bicyclist and pedestrian fatali

The Performance Measures A

to "Protect the environment 

improving air quality and enc

(non‐motorized transportatio

There are performance meas

stakeholders for monitoring u

require additional efforts for 

to determine their potential u

included in future RTP/SCS up
382

ID Name Affiliation Comment Re

research are completed.

140‐08 Elizabeth

Cheadle

Santa MonicaMountainsConservancy

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

141‐01 Wally Siembab Siembab

Corporation

Despite its relative low capital cost and high cost‐effectiveness,

telecommuting remains in 2012 a marginal strategy for reducing

GHG emissions and congestion.

The 2012 RTP could lay out the path by which telecommuting

could reach its potential, particularly in an RTP with such a

gigantic revenue shortfall. But it doesn’t.

Table 4.5 of the SCS lists only one specific telecommuting

action/strategy, and it will do nothing to change the marginal

role of telecommuting over the next 4 years. “Encourage the

development of telecommuting programs by employers through

review and revision of policies that may discourage alternative

work options.”

The discussion of Telecommuting/Work‐at‐Home in the TDM

Appendix is equally unhelpful, focusing on barriers to

telecommuting and mentioning a few policies to overcome

those barriers, none innovative nor likely to make a difference.

One of the basic problems with telecommuting in the 2012 RTP

(and previous RTPs) is that the strategy is treated as a member

of the TDM family of policies.

However, among all the TDM options, only telecommuting

mimics land use. Telecommuting, like other network

applications associated with “distributed organizations” (such as

tele‐medicine, e‐retail, distance education, etc), can affect thelocation of destinations. For example, portions of auto‐oriented

employment centers can be strategically re‐located into walking

neighborhoods. In other words, telecommuting can impact the

spatial distribution of functionality. It is really a way of

implementing “location efficiency.”

Beyond that conceptual revision, there are a number of

strategic options that should be added to the 2012 RTP.

Goal should be for every employee except for those involving

physical materials‐handling or other hands‐on activity (like truck

driving) to expect some to be offered some telecommuting

option; with every employer expected to authorize an

alternative work site within 4 miles of every eligible employee’s

home. This is consistent with existing travel patterns to other

Comment noted. According t

the percentage of workers te

significantly over the past 10 

agency is restricted to policy 

jurisdictions to remove barrie

telecommuniting.
383

ID Name Affiliation Comment Re

destinations; is compatible with short‐range electric vehicles;

and will reinforce the “neighborhood oriented development”

(NOD) strategy.

141‐02 Wally Siembab Siembab

Corporation

Four initiatives are required to reach that goal. 1. Regional

Telework Facilitator

Public agencies trying to encourage the telework strategy tend

to do so through corporate demonstration programs. The

AQMD recently funded such a program which is in process

today. Demonstration programs have been repeatedly found to

produce short term but not long term results. When the funding

goes away, the active teleworkers begin to decline back to pre‐

demonstration levels.

Establishing the institutional infrastructure that will support

telework in the long run is the most effective step that could be

taken. Similar to the old “Commuter‐Computer” for ride

sharing, this regional organization would market the telework

option (in all of its varieties – home based, satellite, shared

work center, network access center, etc.) to employers. Other

tasks include maintaining best practices, offering first line

technical assistance, and making referrals to implementation

consultants.A five year public commitment would be best, giving the

organization the opportunity to develop a business plan in order

to continue operating with a minimal public subsidy. Technology

firms with products used in telework are good candidates to

serve as private partners.

Comment noted.

141‐03 Wally Siembab Siembab

Corporation

2. Opinion Leaders

Elected officials, public sector executives plus leading private

CEOs committing their own organizations to an aggressive

telework program is also essential. The organizations and their

commitments should have a high profile. The practice should

also include the full range of distributed applications such as

distance education, telemedicine, e‐retail, etc. The Regional

Telework Facilitator should organize and maintain this public‐

private leadership council.

Comment noted.

141‐04 Wally Siembab Siembab

Corporation

3. Telework Facilities Exchange

The Telework Facilities Exchange (TFX) was a work‐station

sharing program for government employees that I designed and

implement in the mid‐1990s, sponsored by the League of

California Cities and funded by the SCAQMD. Government

Comment noted. Innovative s

Facilities Exchange are occurr

at its satellite offices. In addit

rental (including receptionists

machines) are being advertise
384

ID Name Affiliation Comment Re

employees (city, county, state, federal) were matched to a

vacant work station in another government building near their

residence. It was, at the time, the largest multi‐jurisdictional

telework program in the nation. The planning and advocacy

function of the project was the prototype Regional Telework

Facilitator.

based businesses that need o

costs of bandwidth decreasin

becoming more cost effective 

Occasional telecommuters ar

using free wi‐fi capabilities.

141‐05 Wally Siembab Siembab

Corporation

4. Network Access Centers

Network Access Centers (NAC) are a new type of public facility

that will contribute to transportation access, economic

development, and education. A NAC is a multi‐function, multi‐

user facility that provides technical assistance, fast network

connections, information technology, work stations, meeting

space, and special programs that include distance education

classes, tele‐medicine consultations and so forth. A NAC is

essentially a programmable building whose functionality can be

changed hour by hour, day by day to satisfy community need

for travel.

NACs should be added to transit stops (especially multi‐mobility

hubs), public schools, public libraries, neighborhood centers,

and downtown districts.

The Blue Line TeleVillage in Compton, funded by Metro in the

late 1990s, established proof of concept in LA County. Yet it was

not replicated.

Comment noted. Office space 

being advertised for short an

based workers and out‐of‐are

operations and to meet client

can consider the feasibility of 

research on first/mile solutio

142‐01 Mike Bullock Sierra Club I have saved the file provided by Mark. I contains some very

valuable ideas. Great work! As a retired systems engineer, I

view our top‐level requirement to be climate stabilization. The

file "SDSC_to SANDAG_Re_CARB" shows that we need a 35.1%

reduction in per‐capita driving, by 2035, with respect to 2005. It

is also shown that this is a 15% drop in net driving. So why add

lanes? But how can we get such a decrease? Many of your

strategies are important. However, the most important would

be to unbundle the cost of driving and parking. Regarding

parking, I have attached my peer‐reviewed and published

report, "Manuscript19c". For roads, I have attached

"2011NevadaRoadUseDraft".

Comment noted. In the Trans

Appendix, SCAG encourages a

parking and parking pricing st

142‐02 Mike Bullock Sierra Club From the parking report's Section "A GLIMPSE INTO A POSSIBLE

FUTURE ": Jason is driving to work for the first time in several

years. He has decided to save money by carrying home a new 3‐

D, big‐screen computer, which he plans to purchase at a store

near his office after work. He wanted to avoid paying delivery

Comment noted. The 2012 RT

improve and expand real‐tim

for transit services.
385

ID Name Affiliation Comment Re

charges. Things have been changing around his office

development since they unbundled the cost of parking at the

near‐by train station. Many people who caught the early trains

and lived close to the station stopped driving and parking in the

best parking spaces; demand for housing close to the station

went up; and wealthy riders, who insisted on driving, did so,

confidant that they could always find parking as close to the

platform as their schedules required, due to congestion pricing.

Who would have guessed how much those people were willing

to pay? It was shocking. Parking‐lot earnings, paid to round‐trip

train riders, meant that the net cost to ride the train went

significantly down. Ridership and neighborhood vitality both

went significantly up. All Jason knew was that the price to park

at his office had been going up yearly because of increased land

values. His parking‐lot earnings from his office had been

increasing almost every month, due to the ripple effect of train

riders parking off‐site at cheaper parking. Some of them were

using his office parking. As he pulls out of his driveway, he tells

his GPS navigation unit his work hours (it already knew his office

location), the location of the store where he plans to buy the

computer, and his estimated arrival and departure times at the

store. He tells the GPS unit he wants to park once, park no more

than 1 block from the store, walk no more than 1 mile total, and

pay no more than an average of $2 per hour to park. He is not

surprised to hear the GPS tell him that his request is impossible.

He tells the GPS he will pay an average of $3 per hour and

learns that the GPS has located parking. It guides him into a

church parking lot. He hopes the church will use his money

wisely. The GPS tells him the location of a bus stop he could use

to get to work and the bus‟s next arrival time at the stop. With

automatic passenger identification and billing, the bus has

become easy to use, except that it is often crowded. Jason gets

out of the car and walks to work, with no action required

regarding the parking.

142‐03 Mike Bullock Sierra Club Three weeks later, when Jason gets his monthly statement for

his charges and income for automotive road use, transit use,

parking charges, and parking earnings, he finds that the day‟s

parking did indeed cost about $30 for the 10 total hours that he

parked. He notes that the parking‐lot earnings for his office

parking averaged about $10 per day that month. He then

Comment noted.
386

ID Name Affiliation Comment Re

notices the parking lot earnings from the store, where he spent

about $1000 dollars. He sees that the parking‐lot earnings

percent for the store that month was 1.7%, giving him about

$17. So for the day, Jason only spent a net of about $3 on

parking. Then he realized that he should have had the computer

delivered after all. If he would have bicycled that day, as he

usually did, he would have still gotten the $27 earnings from the

two parking facilities and he would have paid nothing for

parking. So the choice to drive cost him $30. He remembers that

the delivery would have only been $25 dollars. Oh well. He

enjoyed his before‐work and after‐work walks.

143‐01 Ellen Perkins South Bay

Cities Council

ofGovernments

The SBCCOG lacks the resources to comprehensively review and

comment on the RTP and PEIR. We have reviewed the

comments being submitted by the Orange County and Gateway

Cities Councils of Governments and are in general support

them.

Comment noted.

143‐02 Ellen Perkins South Bay

Cities Council

ofGovernments

In particular, we want to reinforce the following: • Gateway

COG’s question regarding the Financial Plan ‐ Table 3.4.1 which

presents Core and Reasonably Available local sources of

revenue and includes development mitigation fees for Orange

and Riverside Counties. Does the revenue estimate include any

assumption of funds from the potential adoption of a

development fee in Los Angeles County?

Comment noted. The RTP Fin

revenues associated with the 

feasibility study currently bei

proposed restructuring of its 

143‐03 Ellen Perkins South Bay

Cities Council

ofGovernments

• OCCOG’s request that SCAG adopt growth forecast numbers

at the county level rather than lower geographical levels such as

city or census tract.

Comment noted. Based on st

(Government Code Section 65

(3)) the Regional Housing Nee

with the RTP/SCS land use deallocation being adopted at th

that the SCS be based on a ju

distribution.

143‐04 Ellen Perkins South Bay

Cities Council

ofGovernments

Our focus was on the SCS portion of the RTP. Our comments

address strategies included in Tables 4.3 and 4.4 and we request

the following changes: Add the following new options: Update

local zoning codes, General Plans and other regulatory policies

and pursue opportunities to develop appropriately scaled mixed

office‐retail commercial centers within walking distance of

residential neighborhoods Responsible parties: Local

jurisdictions

Comment noted. The 2012‐20

address comment, as approp

143‐05 Ellen Perkins South Bay

Cities Council

Land Use Actions and Strategies, Table 4.3 Update local zoning

codes, General Plan and other regulatory policies to accelerate

Comment noted. The 2012‐20

address comment, as approp
387

ID Name Affiliation Comment Re

ofGovernments

adoption of land use strategies that will over time convert auto

oriented intersections of major arterials into mixed office‐retail

commercial centers. Responsible parties: Local jurisdictions

143‐06 Ellen Perkins South Bay

Cities Council

ofGovernments

Land Use Actions and Strategies, Table 4.3 Expand Compass

Blueprint priorities to support member cities and sub‐regional

COGs adopting neighborhood oriented development as a land

use strategy and range‐limited electric vehicles as a mobility

strategy. Responsible parties: Local jurisdictions, COGs, SCAG

Comment noted. The 2012‐20

address comment, as approp

143‐07 Ellen Perkins South Bay

Cities Council

ofGovernments

Land Use Actions and Strategies, Table 4.3 Amend the following

existing options (as indicated in italics[quotes]): Update local

zoning codes, General Plans, and other regulatory policies to

accelerate adoption of land use strategies included in the

RTP/SCS Alternative, "or that have been formally adopted by

any sub‐regional COG that is consistent with regional goals."

Responsible parties: Local jurisdictions

Comment noted. The 2012‐20

address comment, as approp

143‐08 Ellen Perkins South Bay

Cities Council

ofGovernments

Land Use Actions and Strategies, Table 4.3 Amend the following

existing options (as indicated in italics[quotes]): Pursue joint

development opportunities to encourage the development of

housing and mixed‐use projects around existing and planned

rail stations, along high‐frequency bus corridors, in transit

oriented development "and in neighborhood oriented

development." Responsible parties: Local jurisdictions, CTCs

Comment noted. The 2012‐20

address comment, as approp

143‐09 Ellen Perkins South Bay

Cities Council

ofGovernments

Land Use Actions and Strategies, Table 4.3 Amend the following

existing options (as indicated in italics[quotes]): Support

projects, programs, policies and regulations to protect resource

areas, such as natural habitats and farmland from future

development; and "support project, programs, policies, and

regulations that lead to development of “complete

communities” on greenfields." (A diversity of housing choices

and educational opportunities; jobs for a variety of skills and

education; recreation and culture; a full‐range of shopping,

entertainment and services; all within a relatively short

distance) Responsible parties: Local jurisdictions, SCAG

Comment noted. The 2012‐20

address comment, as approp

143‐10 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4 Add

the following new options: Promote the use of range‐limited

battery electric vehicles through land use policies that bring

origins and destinations closer together such as the

neighborhood oriented development strategy; and through

transportation infrastructure such as complete streets

(designed to accommodate slow speed electric vehicles) and

Comment noted. The 2012‐20

address comment, as approp
388

ID Name Affiliation Comment Re

EVSE deployment in homes and in public parking lots.

Responsible parties: Local jurisdictions, COGs, SCAG, and CTCs

143‐11 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4 Add

the following new options: Encourage the development of new,

short haul, cost‐effective transit services such as DASH and

demand responsive (DRT) in order to both serve and encourage

development of compact neighborhood centers. Responsible

parties: CTCs and municipal transit operators

Comment noted. The 2012‐20

address comment, as approp

143‐12 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4 Add

the following new options: Ensure every sub‐region has multiple

access points to the regional high speed transit network with at

least one of them being a candidate for development into a

multi‐mobility hub (MMH). Responsible parties: CTCs and local

jurisdictions

Comment noted. The 2012‐20

address comment, as approp

143‐13 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4 Add

the following new options: Lobby the state to provide funding

for complete streets planning and implementation in support of

reaching SB 375 goals. Responsible parties: SCAG, State

Comment noted. The 2012‐20

address comment, as approp

143‐14 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4

Amend the following existing options (as indicated in italics

[quotes]): Explore and implement innovative strategies and

projects that enhance mobility and air quality, including those

that increase the walkability of communities, accessibility to

transit via non‐auto modes "and ZEV modes, and accessibility

via ZEV modes." Responsible parties: Local jurisdictions, COGs,

SCAG, and CTCs

Comment noted. The 2012‐20

address comment, as approp

143‐15 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4

Amend the following existing options (as indicated in italics

[quotes]) Collaborate with local jurisdictions to plan and

develop residential and employment development around

current and planned transit stations "and neighborhood

commercial centers." Responsible parties: Local jurisdictions,

SCAG

Comment noted. The 2012‐20

address comment, as approp

143‐16 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4

Amend the following existing options (as indicated in italics

[quotes]) Collaborate with local jurisdictions to provide a

network of local community circulators that serve new TOD,

HQTAs, "and neighborhood commercial centers" providing an

incentive for residents and employees to make trips on transit

Comment noted. The 2012‐20

address comment, as approp
389

ID Name Affiliation Comment Re

"and/or stay in the local communities." Responsible parties:

Local jurisdictions, SCAG, and CTCs

143‐17 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4

Amend the following existing options (as indicated in italics

[quotes]) Develop first mile/last mile strategies on a local level

to provide an incentive for making trips by transit, bicycling,

walking "or driving neighborhood electric vehicles or other ZEV

options." Responsible parties: Local jurisdictions, COGs, SCAG,

and CTCs

Comment noted. Table 4.4 ha

recommendation.

143‐18 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4

Amend the following existing options (as indicated in italics

[quotes]) Encourage the development of a Complete Streets

policy, "explicitly accommodating slow speed and other ZEVs."

Responsible parties: Local jurisdictions, COGs, SCAG, and CTCs

Comment noted. The 2012‐20

address comment, as approp

143‐19 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4

Amend the following existing options (as indicated in italics

[quotes]) Develop infrastructure plans and educational

programs to promote active transportation "and ZEV " options.

Responsible parties: Local jurisdictions, COGs, SCAG, and CTCs

Comment noted. Table 4.4 of 

updated to include a specific 

143‐20 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4

Amend the following existing options (as indicated in italics

[quotes]) Emphasize active transportation projects "and slow

speed ZEV modes" as part of complying with the Complete

Streets Act Responsible parties: Local jurisdictions, COGs, SCAG,

and CTCs

Comment noted. Table 4.4 ha

comment, as appropriate.

143‐21 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4

Amend the following existing options (as indicated in italics

[quotes]) Collaborate with local jurisdictions "and sub‐regional

COGs" to develop regional policies regarding TSM Responsibleparties: Local jurisdictions, COGs, SCAG,

Comment noted. Revised Tab

State and Federal Governmen

examine potential innovative 

143‐22 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4

Amend the following existing options (as indicated in italics

[quotes]) Collaborate with local jurisdictions "and sub‐regional

COGs" to update the ITS inventory. Responsible parties: Local

jurisdictions, COGs, SCAG

Comment noted. Table 4.6 ha

recommendation.

143‐23 Ellen Perkins South Bay

Cities Council

ofGovernments

Transportation Network Actions and Strategies, Table 4.4

Amend the following existing options (as indicated in italics

[quotes]) Collaborate with the State and Federal Government

"and sub‐regional COGs" to examine potential innovative TDM

Comment noted. Revised Tab

State and Federal Governmen

examine potential innovative 
390

ID Name Affiliation Comment Re

strategies Responsible parties: SCAG, State and COGs

143‐24 Ellen Perkins South Bay

Cities Council

ofGovernments

In addition, the 2012 RTP should include a preliminary cost

estimate for implementing the Regional PEV Readiness Plan and

the sub‐regional strategies to develop infrastructure and

supportive land uses mentioned in Table 4.7. The completed

PEV Readiness Plan will provide such an estimate however that

will occur after RTP adoption so that an estimate as place holder

should be added in this plan.

Comment noted. SCAG receiv

Infrastructure Planning, with 

SBCCOG. The total of the gran

new area of study for SCAG a

unknown at this time. As the 

progresses over the next 24 m

will have a better estimate of 

143‐25 Ellen Perkins South Bay

Cities Council

ofGovernments

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

144‐01 Elaine Chang South Coast

Air Quality

Management

District

AQMD staff appreciates that the lead agency has worked with

our staff and the CARB staff to develop an aggressive plan

containing transportation policies that promote zero emission

technologies. AQMD staff looks forward to our joint efforts with

SCAG staff on future demonstration and deployment of these

important technologies, including a zero emission on‐road

demonstration project within the next one to three years.

Further information in the Final EIR and RTP about the following

strategies would be helpful to provide clarity in how these

aspects of the plan impact air quality. 1) Although zero emission

technologies are described in the Draft RTP, it is not clear to

what extent the emission reductions from these projects have

been included in the constrained plna (e.g., RTP Table 2.11). The

Final RTP/SCS and PEIR should include specific details about

how much of the emission reduction benefits of the I‐710

corridor project, East‐West freight corridor project, and zero

emission deployment from the ports to near dock rail yards are

included in the 2035 emission calculations. 2) SCAG should work

with local transportation agencies, the ports, and other private

and public stakeholders to identify funding in the constrained

plan for zero‐emission technology demonstrations (or initial

deployments) in the port to near dock rail yard corridor. These

should involve multiple technologies, including technologies

with potential for regional application, and should involve major

truck manufacturers. Such demonstrations can and should be

initiated by no later than 2013 and should include testing and

evaluation of wayside power (e.g., catenary trucks), battery

electric trucks, and fuel cell trucks. AQMD will partner in

Comment noted. Although ze

described in the Draft RTP, SC

reductions from these projec

will provide further clarificati

demonstration initiatives for 

looks forward to our joint effo

demonstration and deployme
391

ID Name Affiliation Comment Re

supporting this measure (e.g., funding, seeking funding

partners, and developing other support). 3) The Draft RTP/SCS

includes several key port‐related projects such as the SCIG and

ICTF that are considered critical to the regional goods

movement system and will have serious air quality implications

for the basin and substantial impact on the heavy duty truck

distribution in the region. Specifically, the Draft RTP/SCS

indicates these projects are needed to address an overall

growth volume at the San Pedro Bay Ports of up to 43 million

containers by 2035 ‐ more than tripling current levels. In

addition, this significant growth in heavy duty truck traffic calls

for the need to develop zero and near‐zero emission goods

movement technologies.

144‐02 Elaine Chang South Coast

Air Quality

Management

District

One of the primary goals of the SCS is to decrease per‐capita

greenhouse gas emissions from passenger vehicles and light

duty trucks. These greenhouse gas reductions will have the co‐

benefit of reducing emissions of criteria pollutants. Because the

SCS is an integral part of the RTP and therefore the AQMP,

timely implementation of the SCS goals is relied upon to meet

air quality standards. As a result, the AQMD staff requests that

the plan be revised to include a periodic tracking and reporting

element for the SCS that would occur more frequently than the

regular RTP cycle. Specifically, staff requests that the tracking

process not be limited to policy review of the SCS, but also

include identification of revenue sources (see funding

comments) and other metrics deemed appropriate by SCAG.

These reported metrics should be made available to the public

to ensure that our basin remains on track to meet AQMP goals.

Comment noted. As done in t

amended once or twice withi

addition, the FTIP is develope

amendment and FTIP, a comp

conformity analysis including 

financial constraint test are p

RTP and FTIP are consistent w

SIPs/AQMPs.In anticipation of additional n

implementation of the 2012‐

further enhance its regional m

post‐RTP adoption activities. 

from member jurisdictions an

in developing an enhanced m

144‐03 Elaine Chang South Coast

Air Quality

Management

District

As required by federal regulation, SCAG has included a financial

plan to demonstrate how the RTP can be implemented. The

plan includes financial resources that are "reasonably expected

to be available" to carry out the plan. However, about $219.5

billion out of a total of $524.7 billion in costs of the RTP are

expected to be funded by "new" sources of funds that are not

currently available ("core" funds). This means that over 40% of

the total cost of the plan is dependent on future new funding.

Federal regulation provides that in the case of new funding

sources, "strategies for ensuring their availability shall be

included." A review of the "new" funding sources indicates that

most would require further action by the state legislature,

Comment noted. However, SC

of reasonably available sourc

federal and state requiremen

meets the financial constraint 

“sufficient financial informati

projects” in the plan “can be 

available, or reasonably availa

reasonable assurance that th

transportation system is bein

maintained.” The determinat

fiscal constraint, as part of me

requirements, are made at th
392

ID Name Affiliation Comment Re

Congress, and/or a vote of the people. Moreover, federal

regulations require the financial plan to "address the specific

financial strategies required to ensure the implementation of

TCMs in the applicable SIP." We are concerned that these

strategies are not sufficiently identified and assured of

implementation. State law also requires the RTP to include a

financial element, which must summarize "the cost of plan

implementation constrained by a realistic projection of available

revenues." The financial element may recommend the

development of specified new sources of revenue. However, in

describing the requirement for "financial constraint," the

treatise California Transportation Law (Solano Press, 2000;

March, Jeremy) provides at page 139 that the plan should:

"Explain the consequences of living with existing revenues only,

including what parts of the plan would not be achievable

(without new revenues). Indicate alternative policy directions if

proposed revenues are not realized, and the time frame when

the change in policy direction should be undertaken if proposed

revenues are not forthcoming." The RTP does not currently

present sufficient information to demonstrate why the "new"

funding sources must actually become available. Moreover, it

does not identify which measures or projects are to be funded

by "core" revenues (those already available or committed) and

which are to be funded by "new" sources. In order for the public

and policymakers to have a clear understanding of why the

"new" funding sources must become available, and thus to

implement the needed steps for this to occur, the RTP should

clearly identify the consequences if the plan were forced to

depend only on "core" funding.

amendment. The Transportat

additional detail and explanat

included in the RTP. The majo

reasonable available revenue

not assumed to be available u

recognize that the future can

therefore make reasonable a

through SCAG’s Technical Adv

Committees and are well doc

more insight into future fund

financial plan accordingly thro

subsequent Plan updates as a

is prepared and adopted ever

144‐04 Elaine Chang South Coast

Air Quality

Management

District

AQMD staff initially requested that SCAG prepare an analysis in

the Final RTP/SCS of what transportation control measures

would be needed to offset growth in emissions due to growth in

VMT, if the decision in AIR v. EPA were to become final [632

F.3d 584 (9th Cir. 2011)]. The conformity section of the Draft

RTP acknowledged in a footnote that the RTP would not be

sufficient, but did not explain what would be required. On

January 27, 2012, the Ninth Circuit Court of Appeals denied

EPA's petition for rehearing in that case. As a result, AQMD staff

is now requesting a scenario analysis that includes the

incremental emission impact in the SCAB due to VMT growth.

Comment noted. SCAG will co

and SCAQMD to understand t

Ninth Circuit Court Ruling in t

Residents et al. v. EPA case (N

related to the Transportation 

non‐attainment area containe

amend the plan (if required) o

analysis and published applic
393

ID Name Affiliation Comment Re

This scenario analysis would use the difference between 2035

VMT and the VMT from years 1997, 2008, and 2012, and

applicable vehicle emission rates in 2035. The Draft EIR

compares today's emissions with future emissions, and

compares emissions with the project compared to emissions

without the project. We request that SCAG analyze the

emissions impact of growth in VMT. For illustration purposes,

staff reiterates its request that the RTP also include an analysis

of what additional Transportation Control Measures it would

take to comply with this decision.

144‐05 Elaine Chang South Coast

Air Quality

Management

District

In order to provide certainty and transparency to the public, the

details regarding the planning assumptions in the RTP/SCS (such

as housing density, distribution of employment, etc.) should be

made publicly available upon approval of the Final RTP/SCS.

Because the RTP/SCS will be used to determine whether future

projects can utilize new CEQA streamlining procedures,

stakeholders need to have a readily available data source that

describes what planning assumptions are included in the SCS.

This final SCS planning scenario at the local level should be

published and available to the public, and any future

changes/amendments should also be made available for review

so that all stakeholders can evaluate the consistency of future

projects with the SCS.

Comment noted. The TAZ‐lev

regarding the planning assum

upon request.

144‐06 Elaine Chang South Coast

Air Quality

Management

District

The AQMD staff appreciates SCAG's participation at the

February 1, 2012 study session on the economic impact of the

Draft RTP/SCS. At that meeting SCAG acknowledged and

clarified the limitations of the Draft RTP/SCS economic analysis

released in December of 2011 and presented the results from

additional analyses. Based on our understanding of the

economic analysis from that meeting, we request that SCAG

provide further clarification on its methods in assessing RTP

employment impacts. This information is crucial because the

AQMP heavily relies upon employment figures generated by the

RTP for emission projections. For example, the Draft RTP

assumes that employment will be the same with and without

the plan (Table 3.10‐10 of the Draft EIR). Any additional analysis

conducted after the draft document on job impacts should be

released prior to approving the Final RTP and should provide

more detailed description on the analysis assumptions and

proper interpretation of the results. Also, the AQMD staff

Comment noted. The analysis 

consultant team identified 17

approximately $21 billion per 

RTP/SCS for capital projects a

expenditures. The 174,500 is 

the RTP spending but it is not 

SCAG estimated that impleme

and strategies could support 

(on average for 2010‐2035) a

from travel time and cost sav

regional economic competitiv

incorporated in the 2.2 millio

the regional growth forecast 

assumes that enabling policie

training, AQMP, RTP, etc., are 

support the economic compe

underlie the jobs forecast. SC
394

ID Name Affiliation Comment Re

recommends inclusion of the financing component of operation

and maintenance expenditures in the job impact assessment of

the RTP/SCS.

the no project alternative on 

note is that the no project alt

that nothing in the RTP is imp

already in place and not subje

are likely to occur. The first is 

all the RTP projects, it will be 

residents and public agencies 

replaced by job impacts from 

money. The second set of imp

the productivity benefits from 

time and cost savings and com

the no project alternative. As 

to show that the no project a

level of regional job, populati

compared to the proposed RT

as additional economic analy

SCAG staff welcomes further 

staff to ensure that we are al

and job impacts from 2012 RT

the forthcoming 2012 AQMP

144‐07 Elaine Chang South Coast

Air Quality

Management

District

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

145‐01 Lisa Payne Southern

CaliforniaAssociation of

Non‐Profit

Housing

The RTP is leaving out one very important component for a

sustainable region. What’s driving the congestion on the

highways is people being unable to afford to live close to where

they work. Homes within reach of workers in transit were raised

at many of the community hearings that SCAG had in the

different counties. There is nothing in the RTP that address this

mismatch between what people make and what housing costs. I

urge SCAG to do a rigorous study of a jobs‐housing fit

throughout the region. National studies have shown that what

most often happens around rail transit stops is that the cost of

housing around the stops goes up, car ownership around the

stop goes up, and transit ridership rises more slowly than

expected or even declines more rapidly than in the surrounding

metro area. In one study there was a recommendation that

what transit systems need in order to have ridership is not

transit oriented development but neighbors that will use the

Comment noted. After Plan a

with our stakeholders to iden

analyzing and monitoring key 
395

ID Name Affiliation Comment Re

transit system, the SCANPH thinks we need both. The RTP really

focuses only on the form of the transit oriented development

and not on who is living inside them and whether they are really

going to be using the transit system. The SCANPH feels strongly

that the success of a push for sustainable growth depends on

having a jobs‐housing fit. City of Los Angeles as an example,

obviously where most of the transit rail stops are going to be,

nearly one‐half of our workers in LA make under twenty‐five

thousand a year at their jobs. Fifty percent make under fifty

thousand per year. The average income of households currently

living around the rail transit stops is about thirty thousand per

year. What is being planned in terms of transit oriented

development around transit in LA however, are apartments for

single people and couples that make over eighty thousand a

year. If we don’t watch out the cost homes around transit will

be expensive and most of the workers will be driven out to the

suburbs, to the periphery, and will be shut out from living

around the transit stops. We need an on‐going and rigorous

study to see what we are getting around the transit stops. We

know that providing affordable homes for workers and transit

riders requires resources. Often a first step for getting resources

is to lay out where we are in terms of meeting the need for

affordable homes to match the jobs we have. SCANPH and

other housing organizations throughout the State are already

advocating for more resources and land use policies to g

146‐01 Multiple

Signers

SouthernCaliforniaBusinessCommunity

Turning to the substance of the RTP/SCS as a policy matter, we

have the following additional general comments: 4) The

RTP/SCS is undergirded by analysis which shows the dispersion

of populations and employment shown and categorized at the

level of sub‐jurisdictional “transportation analysis zones” (TAZs).

The TAZ level of detail is, we believe, too small and precise a

level at which to prescribe the spatial dispersion of

development and redevelopment, particularly in light of the

regional nature of the RTP/SCS. Page 148 of the SCS should

therefore be clarified to indicate that questions of consistency

with the RTP/SCS should be substantively measured and

determined at a jurisdictional or sub‐regional level, not at a TAZ

level.

Comment noted. The TAZ‐lev

the purpose of modeling perf

local jurisdictions, maintain th

determine consistency of any 

growth and land use assumpt

are proposed to be adopted a

146‐02 Multiple

Signers

SouthernCalifornia

5) The RTP/SCS should aim to reflect and accommodate both

the short‐term future of the SCAG region and its long term

Comment noted. The RTP/SC

document that accounts for v
396

ID Name Affiliation Comment Re

BusinessCommunity

future. For example, the RTP should better anticipate the need

for and reasonable likelihood of a gradual transition in the

region’s overall vehicle fleet (e.g., gradually towards alternative

fuels) and the ongoing need for enhancements to vehicular

mobility even as more mass transit comes to fruition.

both near‐term and long‐term 

going need for enhanced mob

146‐03 Multiple

Signers

SouthernCaliforniaBusinessCommunity

6) More detail, clarity and explanation are needed concerning

the new revenue sources that are outlined within the plan

document. New revenues account for $219.5 billion out of the

total $524.7 billion needed for the transportation plan, yet

there is very little detail explaining these significant new fees

and impositions (see page 95 & 96 of the Draft RTP/SCS). To

fully and fairly evaluate these proposals, the business

community and all stakeholders need the benefit of additional

detail and explanation. In particular, we need clarity and

assurance regarding the following: a. The new revenue concepts

assumed within the RTP/SCS must be fair, equitable and

economically sound, meaning that an appropriate nexus exists

to assure that new revenues are drawn fairly and proportionally

from those who benefit from the related transportation

infrastructure or improvement. b. The new revenue sources

within the RTP must be effectively allocated, meaning the plan

should clearly articulate how resources will be efficiently and

responsibly allocated so that there is the best possible return on

investment for the expenditure of these new transportation

funds. SCAG needs to show that it will be a responsible,

accountable and innovative steward of the new revenues that it

is proposing.

Comment noted. The Transpo

additional detail and explanat

included in the RTP. We cons

principles as a foundation for 

revenues that are reasonably 

financial strategies: • Establis

reflects the true cost of trans

protection for transportation 

distribution of costs and bene

programs that include return

maintaining flexibility to rewa

commit substantial local reso

funding with innovative finan

expansion of TIFIA) to attract 

project delivery. • Promote fu

federal commitment to the n

recognizing the pivotal role th

and international trade. The i

return of $2.90 for every doll

146‐04 Multiple

Signers

SouthernCaliforniaBusinessCommunity

7) New revenues from fees on businesses operating in the SCAG

region ‐ and particularly the "Freight Fee/National Freight

Program" listed on page 96 of the Draft RTP ‐ need to be

developed and implemented at the federal level, not the local

and regional level. Unless such fees are imposed on a national

scale, the region's competitiveness will be compromised.

Comment noted. The RTP doe

of local, regional, or statewid

SCAG region or its member e

disadvantage were critical co

development of all funding p

146‐05 Multiple

Signers

SouthernCaliforniaBusinessCommunity

8) In the RTP, SCAG should identify and highlight the significant

economic contributions of the goods movement sector to the

regional and state economy. Specifically, the RTP should

acknowledge that, as business stakeholders work with

regulatory agencies to further reduce emissions in the SCAG

region, any technology introduced must not compromise the

safety, velocity, cargo throughput, economic competitiveness,

Comment noted. SCAG recog

the goods movement sector t

SCAG concurs that any techno

compromise the safety, veloc

competitiveness, and reliabili

SCAG will continue to work w

stakeholders in further evalua
397

ID Name Affiliation Comment Re

or reliability of the goods movement system. It would be helpful

for SCAG to state clearly in the RTP that, to date, stakeholders

have not reached consensus on technologies, timing, funding,

or emissions impacts of the various options that SCAG examined

in the RTP. For example, SCAG discusses long‐term steps

towards a "Zero Emissions Container Movement System"

(ZECMS). If SCAG chooses to pursue such a fundamental shift in

new technology, it would need to work with all goods

movement stakeholders to clearly establish whether and, if so,

when and where within the transportation infrastructure a

ZECMS option could be demonstrated and evaluated without

negatively effecting the velocity and throughput of the system.

146‐06 Multiple

Signers

SouthernCaliforniaBusinessCommunity

9) With the recent elimination of redevelopment agencies, the

ability of local jurisdictions to meet the densification of urban

centers in the near term is challenged, given the costs related to

aging or inadequate infrastructure capacity and high

development costs for higher density projects. The elimination

of redevelopment agencies also threatens the availability of

sufficient housing options necessary to meet the needs of a

dynamic workforce. In fact, since the passage of SB 375, the

State of California has stripped local governments of funds that

were previously available for transit, transportation and

redevelopment. This follows many years in which the state

diverted revenues from gasoline, sales, income and other taxes

needed for local government programs. Local governments

cannot help to fulfill the 2012 RTP/SCS without increased, not

decreased, state support. SCAG should emphasize the need for

the state to restore support for planning, transit, transportation

and redevelopment or other necessary funding to pre‐SB 375

levels in order to speed the attainment of mandated goals.

While we find many very positive aspects in the plan, especially

related to principles and direction, these significant issues need

to be addressed. The short list of general concerns set forth

above is not meant to be exhaustive. Many of the organizations

that subscribe to the above‐stated comments will be

commenting more robustly in separate writings. We join here,

however, to express our unity in finding the Draft 2012 RTP/SCS

and PEIR to be in need of significant clarification and correction.

We are also jointly committed to completing this process and,

over the remaining weeks, working closely with SCAG to

Comment noted. The elimina

jurisdictions' ability to finance 

intended to support the polic

continue to identify funding r

pursuing such policies.
398

ID Name Affiliation Comment Re

develop and adopt a smart, flexible, accountable, and

economically sound RTP/SCS.

146‐07 Multiple

Signers

SouthernCaliforniaBusinessCommunity

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

147‐01 Larry Russell Southern

CaliforniaContractorsAssociation

According to the Construction Industry Research Board,

Burbank, total construction in California has dropped 57%

between 2005‐2009. Construction employment has a direct

correlation with total construction activity. According to the

California Employment Department, construction employment

over that same period dropped from 933,700 people in 2006 to

559,800 IN 2010. That represent a 40% drop in construction

employment over a five‐year period. The construction industry

has been hit very hard by this recession. The RTP calls for 525

billion dollar investment which will significantly boost

construction activity in Southern California. The SCCA supports

this plan however we echo the concerns voices earlier, we

would like to see more clarity on the 219.5 billion dollars in new

revenue sources outlined in the RTP. According to the American

Road and Transportation Builders Association in Washington,

DC, Greenfield Infrastructure Projects can now take up to

nineteen years to complete from concept to construction due to

NEPA and CEQA processes. SCCA is also concerned about the

number of mitigation measures contained in the PEIR. We

encourage SCAG to further examine the economic impacts of

these mandates on our local governments and contractors and

the potential for project delays and for future litigation. SCCA

supports a balanced approach in providing multi‐modal

transportation alternative in Southern California. We encourage

SCAG to ensure a truly balanced approach that balances transit,

highway, freight rail, and bridge and roadway improvements

with smart land use strategies and encourage walking, biking,

and other transportation options.

Comment noted. The Transpo

detailed explanation on all re

transportation expenditures i

148‐01 Larry Russell Southern

CaliforniaContractorsAssociation,Inc.

SCCA appreciates SCAG’s goals of optimizing system

performance (including preservation and maintenance),

investing in completing transportation system gaps and

strategic investments to expand the system as the population

grows. Protecting our existing transportation infrastructure and

making strategic investments to expand infrastructure will be

Comment noted.
399

ID Name Affiliation Comment Re

key to safely moving people and goods for decades to come.

SCCA supports a balanced approach to providing multi‐modal

transportation alternatives to southern California. We

encourage SCAG to ensure a truly balanced approach that

balances transit, highway, freight rail, bridge and roadway

improvements with smart land use strategies that encourage

walking, biking and other transportation options.

148‐02 Larry Russell Southern

CaliforniaContractorsAssociation,Inc.

The RTP calls for $524.7B in infrastructure investment which will

significantly boost construction activity in southern California.

The SCCA supports this plan. However, we echo the concerns

voiced at the February 2 Public Input Hearing by the Southern

California Leadership Council and we would like to see more

clarity on the $219.5B in new revenue sources outlined in the

plan.

Comment noted.TheTranspor

additional detail and explanat

included in the RTP.

148‐03 Larry Russell Southern

CaliforniaContractorsAssociation,Inc.

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

149‐01 Alexander

Pugh

SouthernCaliforniaEdison

Growth in the use of electric vehicles: Assumptions about the

number of battery and hybrid plug‐in electric vehicles (PEV) in

Southern California between now and 2035 may be higher than

accounted for within the RTP/SCS and PEIR.

Comment noted. The RTP/SC

most recent data available. W

engaged in a multi‐year plann

Study as well as developing d

RTP/SCS is an evolving docum

years. At that time, SCAG will 

including new PEV assumptio

to work with SCE on the Regio

149‐02 Alexander

Pugh

SouthernCaliforniaEdison

Currently SCE is planning for three scenarios for PEV growth

within its service territory by 2020: low‐175,000; medium‐

450,000; and high‐1,000,000. In January the California Air

Resources Board passed the Advanced Clean Car Initiative

calling for more than one million PEVs in California by 2025.

Additionally planners and researchers in Southern California,

including SCAG and the UCLA Luskin Center are conducting

research to guide the build out of publicly accessible charging

stations region‐wide. This too may further support the growth

of the PEV market.

Comment noted. SCAG looks 

SCE on the Regional PEV Infra

149‐03 Alexander

Pugh

SouthernCaliforniaEdison

In regards to charging infrastructure, great strides have been

made in southern California to update the older 1990s paddle

chargers to the new J1772 standard.

Comment noted.
400

ID Name Affiliation Comment Re

149‐04 Alexander

Pugh

SouthernCaliforniaEdison

Moreover, there are a number of charging station installers and

equipment manufacturers in southern California, which means

both a direct positive environmental and economic impact

comes from electric vehicle growth.

Comment noted.

149‐05 Alexander

Pugh

SouthernCaliforniaEdison

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

150‐01 Robert Cruz Southern

California Gas

Company

Southern California Gas Company (SoCalGas) respectfully

submits these comments regarding the Southern California

Association of Governments’ (SCAG) 2012‐2035 Draft Regional

Transportation Plan/Sustainable Communities Strategy

(RTP/SCS). SoCalGas, a regulated utility of Sempra Energy has

been delivering clean, safe and reliable natural gas to its

customers for more than 140 years. It is the nation's largest

natural gas distribution utility, providing service to 20.9 million

consumers connected through nearly 5.8 million gas meters in

more than 500 communities. SoCalGas’s service territory

encompasses approximately 20,000 square miles throughout

Central and Southern California, from Visalia to the Mexican

border. These comments address those portions of the RTP/SCS

related to use of natural gas fuel in SCAG’s region. Our

overarching concern and comment is that the RTP/SCS is not

balanced in terms of options presented for alternative vehicle

fuels. There is an obvious and inexplicable predisposition

towards electric and zero‐emission vehicles (ZEVs) without

apparent backup documentation regarding the cost‐

effectiveness and feasibility of such an “all” electric strategy.

We respectfully request that SCAG produce a more balanced

and pragmatic RTP/SCS that truly considers both the short‐term

and long‐term future of the region, by incorporating options for

cost‐effective, practical, and immediately available, alternative‐

fuel motor vehicles such as natural gas‐fueled vehicles (NGVs).

Comment noted.

150‐02 Robert Cruz Southern

California Gas

Company

Having a broad array of clean‐fuel options makes sense for your

member agencies given the diversity of your six counties and

191 cities. Many of your members have already made significant

commitments to NGVs powered by clean, compressed natural

gas (CNG), in terms of infrastructure, training and vehicle

purchases. For example, as recently as last year, the LA County

Metropolitan Transportation Authority retired its last diesel bus

and now operates 2221 CNG‐powered buses serving the

Comment noted. SCAG welco

working with Southern Califo

incorporating reasonable alte

updates.
401

ID Name Affiliation Comment Re

communities comprising the County of Los Angeles. This

important decision was made within the context of financially

constrained budgets, especially given the order of magnitude

higher cost for purchasing, operating and maintaining electric

and fuel‐cell transit buses. Furthermore, since affordable near‐

zero vehicle technology is developing faster than fuel‐cell and

electric vehicle technology, it is imperative that more‐effective,

readily available, alternative‐fuel options are included in the

RTP/SCS as possibilities for all of your member agencies.

SoCalGas would like to share data with SCAG staff on cost‐

effective, readily available near‐zero vehicle technologies, such

as NGVs. In the spirit of assisting SCAG in developing the most

comprehensive and legally defensible RTP/SCS, the discussion

below provides support for why SCAG should incorporate

options for cost‐effective, practical, and immediately available

alternative‐fuel motor vehicles such as NGVs, in its RTP/SCS.

150‐03 Robert Cruz Southern

California Gas

Company

In addition, the RTP/SCS’s current limitation of alternative‐fuel

vehicles to just fuel‐cell and electric vehicles belies a narrow

focus solely on tailpipe emissions. While it is true that ZEVs have

zero tailpipe emissions compared to near‐zero or low‐emission

vehicles (LEVs) such as NGVs, it would not be accurate to say

that ZEVs generate zero emissions overall compared to low‐

emission vehicles. For example, electric vehicles receive their

power from generating facilities that also generate combustion

emissions. Emissions are also generated by the processes used

to manufacture the special batteries needed for such vehicles.

These emissions cannot be ignored nor discounted, particularly

with respect to attainment of the National Ambient Air Quality

Standard for ozone, or contributing to any new “or existing

violation of any standard in any area.” Furthermore, there is

efficiency loss using electrical power rather than directly using

natural gas to power vehicles. Indeed, in the course of

producing useful electric energy in the U.S., “we waste or

discard about 70 percent of the initial raw energy found in coal

or most other fuel sources.” It is more energy efficient,

therefore, less wasteful and less polluting to directly use natural

gas to power vehicles rather than generating electricity

transmitted long distances over power lines and then used to

power an electric vehicle. Therefore, energy efficiency should

be taken into account to fulfill the SB 375 requirement for “a

Comment noted. While the R

vehicle fleet assumptions in A

sought to further the implem

number of planning efforts, in

AB 118 funding. As discussed 

the RTP, the planning for a ze

of near‐term alternative fuels 

long‐term vision. For example

currently engaged with three 

encourage the use natural ga

Drayage‐ Natural Gas Truck R

replacement of old, heavy‐du

trucks powered by clean natu

with the deployment of appro

The Liquefied Natural Gas (LN

makes the final connection be

LNG fuel infrastructure in Sou

stations being developed in U

fueling corridor along one of 

goods movement truck route

Salt Lake City, Utah. And final

CNG Truck Replacement Proje

deploy 262 natural gas trucks 

stations. There are currently o
402

ID Name Affiliation Comment Re

balanced” and “pragmatic,” RTP/SCS. fueling stations in developme

shown a commitment to expa

alternative fuels. SCAG looks 

Company on these and future 

150‐04 Robert Cruz Southern

California Gas

Company

2. AB 32 (Núñez 2006) ‐ Global Warming Solutions Act The

RTP/SCS needs to broaden its scope beyond electric vehicles

and incorporate the use of alternative‐fuel motor vehicles such

as NGVs in order to be fully consistent with the policy objectives

of AB 32, which is an overall reduction of California’s

greenhouse gases (GHG) emissions. As discussed above, energy

is wasted when natural gas is used to generate electricity for

electric vehicles, compared to natural gas used directly to

power NGVs. In addition to this, using natural gas to generate

electricity for electric vehicles creates more GHG emissions

compared to natural gas used directly to power NGVs. This

point is illustrated in a recent study which found that if you

compared an electric‐resistance water heater to a natural‐gas

water heater on a full fuel‐cycle basis, the natural‐gas water

heater emits over 50 percent less CO2 equivalent emissions

annually. Furthermore, the RTP/SCS also needs to be consistent

with the goals of AB 32’s low‐carbon fuel standard (LCFS). The

LCFS is designed to ensure the use of low‐carbon transportation

fuels in order to achieve the lower GHG levels intended by AB

32. This is achieved through the development of a carbon‐

intensity index which is measure of a transportation fuel’s GHG

emissions generated through its life cycle, i.e., GHG emissions

generated from obtaining the fuel’s raw materials,

manufacturing the fuel, transporting the fuel from the producer

to the ultimate consumer, and using the fuel. Electricity as a

transportation fuel has a carbon‐intensity index, as well as CNG,

hydrogen, gasoline, and other transportation fuels. If the

RTP/SCS solely focuses on fuel‐cell and electric vehicles, and

excludes other alternate‐fuel vehicles, such as NGVs that have

lower carbon‐intensity index values, it would be inconsistent

with the broader GHG reduction goals of AB 32, which is the law

that forms the very foundation for SB 375 and the SCS

requirement.

Comment noted. The SCAG C

engaged with three projects t

use natural gas as an alternat

Truck Replacement Project in

heavy‐duty diesel drayage tru

clean natural gas engines, cor

of approximately 180 natural 

Gas (LNG) ‐ Corridor Expansio

connection between the exist

infrastructure in Southern Ca

being developed in Utah, pro

corridor along one of the nat

movement truck routes betw

Lake City, Utah. And finally, th

CNG Truck Replacement Proje

deploy 262 natural gas trucks 

stations. There are currently o

fueling stations in developme

shown a commitment to expa

alternative fuels. We look for

California Gas Company on fu

neutral towards zero or near‐

supports any and all such tec

150‐05 Robert Cruz Southern

California Gas

Company

3. AB 118(Núñez 2007), amended by AB 109 (Núñez 2008) ‐ 

Alternative and Renewable Fuel and Vehicle Technology

Program Assembly Bill 118 created and authorized the California

Comment noted. While the R

vehicle fleet assumptions in A

sought to further the implem
403

ID Name Affiliation Comment Re

Energy Commission (CEC) to “develop and deploy innovative

technologies that transform California’s fuel and vehicle types

to help attain the state’s climate change policies.” With an

annual budget of $100 million, the CEC must accomplish this

goal by, among other things, funding projects that provide for

“a measurable transition from the nearly exclusive use of

petroleum fuels to a diverse portfolio of alternative fuels”

(emphasis added). Over the last three years, the CEC has

allocated AB 118 funding to a variety of projects including, but

not limited to, installing electric vehicle‐charging stations,

installing CNG dispensing facilities, deploying the use of heavy‐

duty natural‐gas vehicles and promoting biofuels such as

biomethane. For 2012‐13, CEC is planning to spend $2.5 million

on new CNG refueling facilities, $12 million for NGV incentives

and $20 million towards the production of biomethane. In order

not to undermine the gains made by AB 118 and devalue the

substantial investments made by the CEC in CNG refueling

infrastructure, NGVs, and biomethane, SCAG should incorporate

a diversity of alternative‐fuel motor vehicles into the RTP/SCS,

including NGVs. It would be a sad waste of public funds and

resources if the RTP/SCS did not become more diverse and

better align its goals with those of AB 118.

number of planning efforts, in

AB 118 funding. As discussed 

the RTP, the planning for a ze

includes the use of near‐term 

as bridge to the long‐term vis

Cities Coalition is currently en

support and encourage the u

fuel. The Drayage‐ Natural Ga

involves the replacement of o

trucks with new trucks power

corresponding with the deplo

natural gas trucks. The Liquef

Expansion Project makes the 

existing public access LNG fue

California and the LNG fuel st

providing a 700‐mile LNG fue

nation’s most heavily traveled 

between Southern California 

finally, the SANBAG/ Ryder H

Project is funded with $19.2 m

trucks and construct two fuel

over 130 vehicles deployed, w

development. Through Clean 

commitment to expand the u

SCAG looks forward to workin

and future planning efforts.

150‐06 Robert Cruz Southern

California Gas

Company

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

150‐07 Robert Cruz Southern

California GasCompany

1. SB 375 (Steinberg, 2008) ‐ Addressing Greenhouse Gas

Emissions from the Transportation Sector via Regional

Transportation Plans The RTP/SCS needs to incorporate the use

of other alternative‐fuel vehicles, such as NGVs in order to fully

meet all of SB 375’s requirements. This is because SB 375

requires plans such as the RTP/SCS to be “balanced” and

“pragmatic,” and to consider “both the short‐term and long‐

term future.” Consequently, the RTP/SCS should incorporate

cost‐effective, practical, and immediately accessible alternative‐

fuel motor vehicles such as NGVs. The planning and

infrastructure necessary for deploying electric and fuel‐cell

Comment noted.
404

ID Name Affiliation Comment Re

vehicles is an extremely resource‐intensive and long‐term

process. Indeed, if the RTP/SCS were to mandate solely electric

and fuel‐cell vehicles, then SCAG would be making the same

mistakes that CARB made when it implemented its Zero

Emission Bus (Z‐Bus) program ten years ago. CARB adopted the

Z‐Bus program in 2000 as part of its Transit Fleet Rule which

basically requires transit‐bus fleets (with over 200 buses) to

have by 2010, 15% of their new bus purchases be Z‐Buses, such

as battery‐electric or fuel‐cell buses, or electric trolleys. Over

the last ten years, however, a number of demonstration

projects conducted by a number of large transit agencies

showed that these Z‐Buses were very expensive, performed

poorly, were unreliable, and its key components (batteries, fuel‐

cells) were extremely expensive to replace with a very short life

span, e.g., a fuel‐cell has a life span of 5,000 hours and costs

over $1 million to replace. In September 2010, Foothill Transit

took delivery of three battery‐electric powered Z‐Buses, costing

$1 million each. Each bus had a 30‐mile range requiring a 10‐

minute recharge period. Worse, the recharging periods for

these electric buses would occur during peak‐electric periods

when electricity is at highest cost and potentially overloading

already strained California power grids. As a result, CARB is in

the process of revising the Z‐Bus rule to allow for greater

flexibility and to give the bus‐transit agencies more time.

Therefore, in order for the RTP/SCS to succeed in meeting the

requirements of SB 375, it must take note of what CARB learned

from its Z‐Bus program and broaden its scope beyond just fuel‐

cell and electric vehicles, to include other alternative‐fuel

vehicles such as NGVs.

151‐01 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

On behalf of the Southern California Leadership Council (SCLC),

we would like to acknowledge the Southern California

Association of Governments (SCAG) and both its staff and

leadership who have worked diligently to prepare the Draft

2012 Regional Transportation Plan (RTP), Sustainable

Communities Strategy (SCS) Program Environmental Impact

Report (PEIR), and associated documents. This first of its kind

effort, as called for under SB 375, has taken over three years

and involved an unprecedented level of collaboration between

SCAG and its public and private sector stakeholders from

throughout the region. The degree of outreach and engagement

Comment noted. Please see r
405

ID Name Affiliation Comment Re

is exceptional and SCAG should be applauded for its efforts. As

you know, the Southern California Leadership Council is a non‐

partisan, non‐profit, business‐led public policy partnership. The

Leadership Council exerts strong leadership on issues of

regional significance, providing a common voice on major public

policies critical to economic vitality, job growth and quality of

life in Southern California. The Leadership Council unites

business and community leaders from throughout the seven‐

county region into one effective leadership organization whose

membership includes three former California governors and two

dozen presidents and CEO’s of top Southern California

companies. SCLC appreciates its strong working relationship

with SCAG and its ability to provide business and industry input

into SCAG policies and initiatives. In particular, SCLC has been an

active participant in the over three year long process of crafting

and developing the RTP/SCS. Based on this extensive

involvement, SCLC offers the following general comments and

recommendations on the draft plan and requests that this letter

be included in public record as our collective comments on the

Draft RTP/SCS, PEIR and associated documents.

151‐02 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

SCLC’s Position – SCLC supports a 2012 RTP/SCS that recognizes

the critical importance of transportation and infrastructure to

economic vitality, job creation and the quality of life for all

Southern Californians. We also support an RTP/SCS that honors

market forces, local control and flexibility as it works to secure

an integrated approach to land use, transportation, housing and

environmental planning in order to achieve GHG emission

reductions under the SCS. In evaluating SCAG’s Draft 2012

RTP/SCS to determine if it is such a plan, from early on SCLC has

applied a consistent set of policies and principles related to

good planning, to assure that the RTP/SCS is a smart, feasible,

flexible, accountable plan that is CEQA compliant, economically

sound and preserves existing employment and enhances job

creation. The following is the specific set of key policies and

principles that SCLC and others in the business community have

applied in evaluating the plan; and we believe that they

represent the qualities of a good and sound RTP/SCS.

Comment noted.

151‐03 Richard

Lambros

SouthernCaliforniaLeadership

Provides Positive Economic Impacts ... A Plan that is Pro

Economic Growth and Job Creation – The RTP/SCS must

undergo a true economic cost/benefit analysis so that economic

Comment noted. Economic a

updated to provide a more co

benefits and impacts of the 2
406

ID Name Affiliation Comment Re

Council impacts are understood and known by both SCAG Regional

Council members and stakeholders well before making a final

decision on the RTP/SCS.

151‐04 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

Provides Local Control: o Any new transportation revenues or

fees collected must be under the control of the local

transportation agency/authority. o Cities, counties and local

transportation agencies must maintain appropriate control and

flexibility in managing decisions and resources related to land

use, transportation and community development.

Comment noted. We agree th

consideration for any new rev

assume nor would it result an

transportation revenues that 

transportation agency/autho

powers to SCAG.

151‐05 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

Assures New Revenue Sources are Fair, Equitable and

Economically Sound – New transportation revenue concepts

within the RTP/SCS must undergo cost/benefit and other

appropriate analysis to assure that they are economically

sound. They must also be fair and equitable, meaning that an

appropriate nexus exists to assure that new revenues are drawn

fairly and proportionally from those who benefit from the

related transportation infrastructure or improvement.

Comment noted. The Transpo

additional detail and explanat

included in the RTP. We cons

principles as a foundation for 

revenues that are reasonably 

financial strategies: • Establis

reflects the true cost of trans

protection for transportation 

distribution of costs and bene

programs that include return

maintaining flexibility to rewa

commit substantial local reso

funding with innovative finan

expansion of TIFIA) to attract 

project delivery. • Promote fu

federal commitment to the n

recognizing the pivotal role th

and international trade. The i

return of $2.90 for every doll

151‐06 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

Is Balanced and Accountable – The plan’s call for new revenue is

balanced with performance measures, reforms and guarantees

that assure the RTP/SCS is effective, efficient and responsible to

the citizens and taxpayers of Southern California.

Comment noted. The 2012 RT

modal plan that incorporates 

transportation strategies to a

performance.

151‐07 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

Is CEQA Compliant and Defensible – The RTP/SCS is processed

correctly from an environmental impact perspective and built to

withstand a CEQA Challenge.

Comment noted.

151‐08 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

Provides for CEQA Streamlining and Protects Against CEQA

Abuse – The plan is crafted so as to capture and make feasible

all available CEQA benefits, especially streamlining, while also

anticipating and limiting opportunities for CEQA abuse.

Comment noted.
407

ID Name Affiliation Comment Re

151‐09 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

SCLC’s Comments and Recommendations – In measuring the

draft plan against these key policies and principles, we find

many very positive aspects of the RTP/SCS – especially those

related to the plan’s core principles, approach and direction.

Likewise, we find a number of other aspects of the Draft 2012

RTP/SCS in need of much more consideration, correction and

clarification before SCAG finalizes and approves the plan. Most

notable among our concerns is the Draft PEIR, which we believe

is in need of significant amendment in order to be more in‐line

with the same core principles, approach and direction reflected

in the Draft RTP/SCS. Outlined below, in very general terms, are

SCLC’s comments and recommendations related to specific

aspects of the Draft RTP/SCS and PEIR that we believe need to

be addressed and corrected in the final plan documents.

Comment noted. See the Fina

Responses to Comments on t

81.

151‐10 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

2. Transportation Analysis Zones (TAZs) –The Draft RTP/SCS

suggests (on page 148 of the draft SCS particularly) that future

policy conformity determinations should be made by comparing

projects with some undisclosed data set related to the

projected dispersion of populations and employment, shown

and categorized at the level of sub‐jurisdictional “transportation

analysis zones.” The TAZ level of detail is, we believe, too small

and precise a level at which to prescribe policy outcomes

concerning the spatial dispersion of development and

redevelopment, particularly in light of the regional nature of the

RTP/SCS. The SCS should, therefore, be clarified to indicate that

questions of consistency with the RTP/SCS should be

substantively measured and determined at a jurisdictional or

subregional level, not at a TAZ level.

Comment noted. The TAZ‐lev

the purpose of modeling perf

local jurisdictions, maintain th

determine consistency of any 

growth assumptions for the R

adopted at the jurisdiction lev

151‐11 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

3. New Revenue Sources – The Draft RTP/SCS needs to provide

more detail, clarity and explanation concerning the new

revenue sources that are outlined within the plan document.

New revenues account for $219.5 billion out of the total $524.7

billion needed for the transportation plan, yet there is very little

detail explaining these significant new fees and impositions (see

page 95 & 96 of the Draft RTP/SCS). To evaluate these proposals

fully and fairly, the business community and all stakeholders

need the benefit of additional detail and explanation. In

particular, we need clarity and assurance regarding the

following: a. The new revenue concepts assumed within the

RTP/SCS must be fair, equitable and economically sound,

Comment noted. The Transpo

additional detail and explanat

included in the RTP. We cons

principles as a foundation for 

revenues that are reasonably 

financial strategies: • Establis

reflects the true cost of trans

protection for transportation 

distribution of costs and bene

programs that include return

maintaining flexibility to rewa

commit substantial local reso
408

ID Name Affiliation Comment Re

meaning that an appropriate nexus exists to assure that new

revenues are drawn fairly and proportionally from those who

benefit from the related transportation infrastructure or

improvement. b. The new revenue sources within the RTP/SCS

must be effectively allocated, meaning the plan should clearly

articulate how resources will be efficiently and responsibly

allocated so that there is the best possible return on investment

for the expenditure of these new transportation funds. SCAG

needs to show that it will be a responsible, accountable and

innovative steward of the new revenues that it is proposing.

funding with innovative finan

expansion of TIFIA) to attract 

project delivery. • Promote fu

federal commitment to the n

recognizing the pivotal role th

and international trade. The i

return of $2.90 for every doll

151‐12 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

4. Federal Level Fee Imposition – New revenues from fees on

businesses operating in the SCAG region – and particularly the

“Freight Fee/National Freight Program” listed on page 96 of the

Draft RTP/SCS – need to be developed and implemented at the

federal level, not the local and regional level. Unless such fees

are imposed on a national scale, the region’s competiveness will

be compromised.

Comment noted. The RTP/SC

implementation of local, regio

Ensuring that the SCAG regio

an economic disadvantage w

the development of all fundin

151‐13 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

5. Goods Movement – In the RTP/SCS, SCAG should identify and

highlight the significant economic contributions of the goods

movement sector to the regional and state economy.

Specifically, the RTP should acknowledge that, as business

stakeholders work with regulatory agencies to further reduce

emissions in the SCAG region, any technology introduced must

not compromise the safety, velocity, cargo throughput,

economic competitiveness, or reliability of the goods movement

system.

Comment noted. SCAG recog

the goods movement sector t

SCAG concurs that any techno

compromise the safety, veloc

competitiveness, and reliabili

SCAG will continue to work w

stakeholders in further evalua

151‐14 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

6. Economic Analysis of the Draft RTP/SCS – Throughout the

process of developing the RTP/SCS and especially in the last few

months leading up to the release of the Draft Plan, SCLC

regularly called for a valid economic analysis of the plan – one

which would provide a true cost benefit analysis. It should be

noted that SCLC was not the only one concerned about the

plan’s potential economic impact. In fact, this past summer,

when SCAG conducted a series of 18 RTP/SCS Public Outreach

Workshops, a majority of participants indicated that the

economy was the most important priority for the region –

finishing ahead of transportation and the environment. As a

result of this and the clear linkage between the RTP/SCS and the

economy, SCAG deployed a team of outside economists to do a

complete economic impact analysis of the Draft RTP/SCS. SCLC

Comment noted. The Econom

Appendix has been updated a

provide a more comprehensiv

impacts of the 2012‐2035 RTP
409

ID Name Affiliation Comment Re

applauds SCAG’s commitment to providing thorough economic

analysis, including an evaluation of the plans impact on jobs and

job creation. With the work of the economists now mostly

complete, their impact analysis of the plan has produced some

extremely positive data, showing the costs of the plan to be far

exceeded by the benefits the RTP/SCS will provide in the way of

job creation and economic growth in our region. SCLC strongly

encourages SCAG to widely communicate this economic data

and to be sure and include all appropriate new economic data

sets and analysis in the final RTP/SCS.

151‐15 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

7. Phase II Economic Recovery Strategy – SCLC agrees with

SCAG’s GLUE Council, that if SCAG utilizes the work done last

year to develop and adopt SCAG’s first ever regional Economic

Recovery Strategy and couples this with the outstanding

economic analysis conducted by SCAG in support of the

RTP/SCS, SCAG is well positioned to develop a Phase II Economic

Recovery Strategy as a companion measure for adoption in

conjunction with (or shortly thereafter) the final RTP/SCS. The

Phase II Economic Strategy would be a way for SCAG, its GLUE

Council, local government the business community and other

stakeholders to come together and support critically necessary

regulatory reforms and strategies to help reinvigorate the

region’s economy and support the full implementation of the

RTP/SCS. The Phase II Strategy would also give SCAG and GLUE a

vehicle for establishing a true Regional Economic Plan to go

along with SCAG’s other regional plans such as the RTP, the SCS

and RHNA.

Comment noted.

151‐16 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

Conclusion – While SCLC finds a number of very positive aspects

in the plan, especially related to principles and direction, there

is still work to be done, significant issues to be addressed, and

details to be developed. With this in mind, SCLC is committed to

completing this process and working closely with SCAG. Just as

it has done over the multi‐year process that has lead up to the

Draft RTP/SCS and PEIR, SCLC will remain very active and

engaged on this issue throughout the remainder of the process

as we work together to finalize and approve a 2012 RTP/SCS

and PEIR for our region that is business friendly, economically

viable, promotes job creation and enhances the quality of life

for all Southern Californians.

Comment noted. SCAG looks 

partnership with SCLC.

151‐17 Richard Southern [PEIR comment(s)] See the Final PEIR Addendum 
410

ID Name Affiliation Comment Re

Lambros California

LeadershipCouncil

Comments on the Draft RTP P

152‐01 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

As the SCLC evaluates the RTP there are six core principles that

we believe should be present in a good RTP/SCS: • Needs to

revive positive economic impacts. SCAG has done some

economic analysis and the SCLS would ask that Staff complete

the analysis as soon as possible and make it widely available

both to stakeholders and to Regional Council members so

everyone can have the full benefit of the economic impacts.

However at this point the analysis we are seeing looks very

positive. • Needs to provide local control • Assure that new

revenue sources are fair, equitable and economically sound •

Needs to be balanced and accountable • CEQA compliant and

defensible, especially given some recent lawsuits against the

SANDAG RTP • Needs to provide CEQA streamlining and protect

against CEQA abuse

Comment noted. The Transpo

additional detail and explanat

included in the RTP. We cons

principles as a foundation for 

revenues that are reasonably 

financial strategies: • Establis

reflects the true cost of trans

protection for transportation 

distribution of costs and bene

programs that include return

maintaining flexibility to rewa

commit substantial local reso

funding with innovative finan

expansion of TIFIA) to attract 

project delivery. • Promote fu

federal commitment to the n

recognizing the pivotal role th

and international trade. The i

return of $2.90 for every doll

152‐02 Richard

Lambros

SouthernCaliforniaLeadershipCouncil

I call upon SCAG to look closely at the local impute, make sure

that local impute actually matches up with approvals on the

ground. As SCLC looked at the mapping, we noticed a lot of

scenarios where local approved plans for development are not

reflected in the mapping. That will create a significant problem

further on.

Comment noted. SCAG’s SCS 

local jurisdictions and SB 375 

jurisdiction’s land use policies 

general plan, be consistent w

altered small area land use as

trends occurring in many tran

153‐01 Karen Sakoda Southern

CaliforniaRegional RailAuthority

RTP Page 5 ‐ We understand that Metrolink's list of constrained

projects is included in the $3.9 billion Transportation

Investment cost for commuter rail, along with other commuter

rail projects submitted by the County Transportation Agencies.

Comment noted.

153‐02 Karen Sakoda Southern

CaliforniaRegional RailAuthority

RTP Page 21 ‐ In addition to the four routes mentioned that

share portions with the LOSSAN corridor, the Antelope Valley

Line shares a segment between Los Angeles Union Station and

Burbank Junction. We also recommend removing the reference

to the Dodger trains, and replacing the team name with a more

general reference to trains for sporting events, and other

special events.

Comment noted. The Final RT

153‐03 Karen Sakoda Southern RTP Page 51 ‐ Recommend modifying wording that states Comment noted. The Final RT
411

ID Name Affiliation Comment Re

CaliforniaRegional RailAuthority

existing rail service will eventually meet 110 mph. Speeds will

vary considerably depending on track configuration and

geography, and 110 mph may be attained where safely possible.

153‐04 Karen Sakoda Southern

CaliforniaRegional RailAuthority

Page RTP 53 ‐ Improvements to the LOSSAN Corridor section

contains a sentence "... AVL travel time between Palmdale and

LAUS can be shortened by 33% simply by skipping less used

station stops." Recommend revising AVL express train wording

to state, "travel time could be shortened by 25% by skipping

selected station stops..."

Comment noted. The Final RT

153‐05 Karen Sakoda Southern

CaliforniaRegional RailAuthority

RTP Page 73 ‐ Goods Movement Rial Strategy ‐ We support

expansion of the rail system to accommodate anticipated

increases to freight and passenger rail services. Funding

capacity expansion, safety improvements and grade separation

projects will be crucial to meeting regional goals.

Comment noted.

153‐06 Karen Sakoda Southern

CaliforniaRegional RailAuthority

RTP Page 84 ‐ For new projects that result from implementation

of the RTP, noise mitigation measures should be addressed

through associated project environmental reviews.

Comment noted. Language h

that the mitigation measures 

implementing agencies when 

153‐07 Karen Sakoda Southern

CaliforniaRegional RailAuthority

RTP Page 184 ‐ Environmental Justice Mitigation Toolbox ‐ Rail

Related Impact mitigations pose some challenges. We cannot

support the recommendation that rail operators improve the

acoustical insulation of dwelling units where setbacks and

sound barriers do not sufficiently reduce noise. Also,

recommending speed limits and limits on the hours of operation

to mitigate noise inhibits Metrolink's ability to operate and

expand.

Comment noted. The referen

the final version of the Enviro

Toolbox have been deleted.

153‐08 Karen Sakoda Southern

CaliforniaRegional RailAuthority

RTP Page 197 ‐ Greater Vision for our Commuter Rail System ‐ 

Tex states that Metrolink operates 164 trips on weekdays.

Currently, Metrolink operates 163 trips per weekday. Also, the

document states, "With the investments proposed within the

Constrained Plan, we except to achieve more than double the

ridership by 2035." Recommend adding investments proposed

in the Strategic Plan which are also necessary to achieve the

stated ridership growth.

Comment noted. The Final RT

153‐09 Karen Sakoda Southern

CaliforniaRegional RailAuthority

Passenger Rail, Page 5 ‐ Text states that Metrolink operates 164

trips on weekdays. Currently, Metrolink operates 163 trips per

weekday.

Comment noted. The Final RT

153‐10 Karen Sakoda Southern Passenger Rail, Page 10 ‐ Recommend clarifying which Comment noted. The Final RT
412

ID Name Affiliation Comment Re

CaliforniaRegional RailAuthority

"Authority" is being discussed. It is sometimes not clear

whether the Authority is the HSR Authority, or SCRRA.

153‐11 Karen Sakoda Southern

CaliforniaRegional RailAuthority

Passenger Rail, Page 20 ‐ Recommend adding wording to

include investments in the Constrained Plan and the Strategic

Plan to achieve a doubling of ridership by 2035.

Comment noted. The Final RT

154‐01 Stephen

Rogers

Stephen WRogers P.E.Consulting

Thank you and SCAG for this opportunity to provide written

public comments pertaining to the subject Draft PEIR document

for the 2012‐2035 Regional Transportation Plan/ Sustainable

Communities Strategy (RTP/ SCS) document, dated December

2011. The following additional mitigation measures and

sustainable community strategies are proposed for SCAG’s

consideration and inclusion in the Final Program Environmental

Impact Report (PEIR), as appropriate: 1. The Friendly

Communities program is being developed as a private public

partnership, to focus on the needs and quality of life issues

unique to residents of unincorporated area communities, and

other communities of special interest. This program could be

replicated statewide/ nationwide.

Comment noted. See the Fina

Responses to Comments on t

88.

154‐02 Stephen

Rogers

Stephen WRogers P.E.Consulting

2. A Countywide Vehicle Asset Management Plant Program

(VAMPP) should be considered for strategic location along

major routes within the regional highway network, to improve

the implementation of standardized maintenance programs for

governmental, transit and private fleet asset services

management. This program could be replicated

statewide/nationwide.

Comment noted.

154‐03 Stephen

Rogers

Stephen WRogers P.E.Consulting

3. Technological advances in vehicle, truck and heavy

equipment lubrication, translating into significant emissions

reductions and extended oil service drain intervals, can be

realized by the use of Synthetic Lubricants and fleet conversion

to bypass filtration. In a recent study, reported December

2011,Amsoil Synthetic Lubricants Increased Fuel Economy 6.54

% in diesel trucking applications

Comment noted.

154‐04 Stephen

Rogers

Stephen WRogers P.E.Consulting

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

155‐01 Stephen

Rogers

Stephen WRogers P.E.

The comments I would like to express and share with regard to

quality of life issues through a more efficient transportation

Comment noted.
413

ID Name Affiliation Comment Re

Consulting system and a more sustainable system overall. Housing plays a

big role in transportation. Lately, there hasn’t been an influx

into Southern California as there has been in the past and so

these growth forecasts need to be examined and I know there is

some work ongoing in that area. Since it has such a great impact

on the needs for transportation systems whether it be the

highways, airports, rail, any of that – we need to make sure we

have reasonable numbers, reasonable forecasts, and I see this

leading to the big picture which is the quality of life for

Southern California.

155‐02 Stephen

Rogers

Stephen WRogers P.E.Consulting

We are all financially strapped right now, and the last thing we

look for is to pay more to be able to drive on a freeway. I think it

is certainly something that should be examined to show that

SANBAG, SCAG, and other agencies are spending our tax money,

gas tax money and federal money in an appropriate way. Then I

think we would be willing to go along with this Plan. But right

now, I think it is a big reach for anybody to say we are willing to

start paying to drive on freeways.

Comment noted. Our current 

continues to be maintained b

and federal gas taxes, local sa

sources. The RTP would not im

general purpose freeway lane

156‐01 Stephen

Rogers

Stephen WRogers P.E.Consulting

Thank you and SCAG for this opportunity to provide written

public comments pertaining to the subject Draft PEIR document

for the 2012‐2035 Regional Transportation Plan/ Sustainable

Communities Strategy (RTP/ SCS) document, dated December

2011, and Federal Transportation Improvement Program (FTIP)

Proposed Amendment # ‘s 11‐24, ‐20: The following highway

projects in the City of Redlands area of San Bernardino County,

have been mistakenly left out of the identified FTIP projects lists

and associated RTP/SCS documents: 1. Redlands Boulevard/

Colton Ave./ Alabama St./ RR‐X’s (SanBAG) Intersection(s)

reconstruction 2. San Bernardino Avenue/ I‐210 Freeway

Interchange Upgrade (impacting proposed Redlands Crossing

(Super WalMart) development (see comment letter pertaining

to Redlands Crossing Draft Environmental Impact Report,

attached.) 3. Alabama Street/ I‐10 Freeway Interchange

Upgrade

1) This project is programmed 

included on the posted Projec

programmed this project in th

SR210/between Highland and 

details of the IC at this locatio

project is included in the RTP 

under RTP ID# 4M01025. How

programmed this project in th

157‐01 Steve Bennett Supervisor,

First District,County ofVentura

Dear Sirs & Madams: While the RTP generally does a sound job

of planning for the future transportation needs of our region, I

must take exception to the proposed allocation of a mere 1.3%

of transportation funding for so called “active transportation.” I

would encourage that a minimum of 5‐8% of funding be

devoted to pedestrian and bicycle facilities. First, SB 375

Comment noted. While achie

greenhouse gas emissions can 

through automobile trip redu

automobile trip reduction. In

transportation may result in r

turn could reduce greenhous
414

ID Name Affiliation Comment Re

mandates that that the RTP address trip reduction. With only

1.3% of funding devoted to active transportation, this mandate

is not being adequately satisfied. Second, public safety demands

a greater allocation for active transportation. With 25% of

traffic fatalities involving bicyclists or pedestrians, clearly far

more must be done to protect the public. Lastly, the

convergence of global warming, increasing fuel costs, declining

personal incomes, and the obesity epidemic all point towards an

overwhelming need to greatly expand the non‐motorized

transportation infrastructure in our region. Expanding the SCAG

region’s bicycle and pedestrian network must be accomplished

at the same time as other transportation facility improvements,

and proceed in concert with the growth of our region in a

planned and coordinated manner . For these reasons, I

encourage revision of the RTP to identify major nonmotorized

transportation needs, corridors, and linkages, and to allocate a

minimum of 5‐8% of transportation funding to active

transportation. Cordially, Steve Bennett Supervisor, First District

County of Ventura

input requesting additional fu

the 2012 RTP increased fundi

$1.8 billion in the 2008 RTP to 

Much of this increase in fund

to the state and federal gas e

historical purchasing power a

portions of those revenue sou

funding active transportation 

158‐01 Will Wright The American

Institute ofArchitects

On behalf of the Los Angeles chapter of the American Institute

of Architects (AIA|LA), I am writing to express our thoughts on

the draft 2012 – 2035 Regional Transportation Plan/ Sustainable

Communities Strategy (RTP). With great respect for the process

to draft such a comprehensive plan, we commend you on the

progress made so far. As AIA|LA supports smart growth policies

that facilitate infill development projects and concentrate our

investments in areas that sustain the vibrancy of the urban core,

we encourage you to adopt Alternative 3 (Envision 2

Alternative) of the draft plan. This option will foster smart

growth land use and housing patterns to achieve superior

environmental results in air quality, aesthetics, open space and

farmland preservation, water conservation, greenhouse gas

emissions reductions, mobility, and land use.

Comment noted.

158‐02 Will Wright The American

Institute ofArchitects

Transit projects and active transportation investments should

take precedent over highway expansion projects. Infill

development and transit‐first policies are natural allies of each

other. Accelerating transit infrastructure and associated joint‐

use, mixed‐income development also helps our region achieve

its social, economic and cultural development goals.

Comment noted. The 2012 RT

transit capital projects, $51.8 

projects, $6.7 billion to active 

transit operations and mainte

158‐03 Will Wright The American AIA|LA is concerned that the current draft plan provides for a Comment noted. The Draft RT
415

ID Name Affiliation Comment Re

Institute ofArchitects

disproportionate share of funds towards highway capacity

improvement that will facilitate greenfield development. The

consequence of additional freeway lanes will be more VMT and

more sprawl, with the associated air quality and infrastructure

maintenance requirements. Environmentally and economically,

facilitating more compact urban development and design

conserves our natural resources and our tax dollars. In short,

adopting the Envision 2 Alternative Plan will help S.C.A.G.

emphasize its leadership role to shape emerging land‐use and

transportation plans. Moving forward we invite the S.C.A.G.

Board of Directors and staff to work with AIA|LA to shape an

environmentally healthy and economically compelling vision for

the future of Southern California.

funding towards traditional h

including arterials, high occup

lanes, and interchange impro

capacity expansion (excluding 

accounts for 20.4 percent of t

alternative plan recommende

constrained.

159‐01 Will Wright The American

Institute ofArchitects

The AIA strongly encourage SCAG to reprioritize the funding

allocations away from highways and into transit.

Comment noted.

159‐02 Will Wright The American

Institute ofArchitects

We encourage you to recommend a 10% allocation to active

transportation something that will make the region not only

more economically competitive but will also make it a healthier

place.

Comment noted.

159‐03 Will Wright The American

Institute ofArchitects

With regards to the process, is this RTP an accumulation of all

the plans that are currently already out there or is there truly

some vision behind it? If we look at ourselves in the year 2040,

will we be in a place that we really want to be in or are just in a

place that we are going towards right now and not really taking

the measures to sort of shift course. With regards to the vision,

there is an opportunity for SCAG to engage the architecture

community a little more in depth and bring forward some of the

livability and lifestyle issues that are at present being reduced to

the conversation about traffic. This is not about traffic, this is

about human conditions, this about lifestyle, this is about the

type of place we want to live in, be in, and to experience as a

human. Some of the questions I have been receiving from the

people I represent in my role on AIA is questioning what is the

urban design intelligence that is currently inherent in the RTP?

Is there urban design intelligence, is there any concern with

what it is actually like to be standing on your own two feet

around some of these major investments that we are making? I

think there is a true opportunity perhaps to learn a little bit

through this process when we revisit a new plan for the future

Comment noted. After Plan a

with our stakeholders to iden

analyzing and monitoring key 
416

ID Name Affiliation Comment Re

of the Southern California region to really start to think about

what is the future like and how do we come back and change

our implementation strategies so that we get to where we want

to be as opposed to simply following the path to where we think

we need to be based on the funding priorities that we have

already set.

160‐01 Penny

Newman

The Center for

CommunityAction and

EnvironmentalJustice

The technologies mentioned must be required for future

projects and incorporate these technologies or they should not

be built.

Comment noted. SCAG will co

partners and stakeholders an

advance appropriate strategi

negative impacts of freight m

the SCAG region.

160‐02 Penny

Newman

The Center for

CommunityAction and

EnvironmentalJustice

The Center for Community Action and Environmental Justice

appreciates the efforts of the Southern California Association of

Governments (SCAG) in completing the Draft 2012 Regional

Transportation Plan/Sustainable Communities Strategy (2012

RTP/SCS). We are encouraged by the concerted efforts put forth

in the draft towards improving the transportation system which

also includes some measures to address Public Health and Air

Quality in our region. We have joined with other concerned

organizations to outline comments on the plan and incorporate

those comments with ours, however we do have some specific

concerns which we feel will directly impact our communities in

the City of Jurupa Valley (formerly known as unincorporated

Mira Loma community in Riverside County) and the City of San

Bernardino Westside communities.

Comment noted.

160‐03 Penny

Newman

The Center for

CommunityAction and

EnvironmentalJustice

The communities in the Jurupa area have for many years seen

an influx of warehousing slowly encroaching into our

neighborhoods. Many of these projects are at the fence line of

homes and schools. Residents in close proximity to highways,

and busy streets with high levels of diesel truck traffic, will

experience increased incidents of asthma, cancer risks,

cardiovascular and respiratory disease, premature mortality,

decreased life expectancy, reproductive health problems.

Comment noted. The RTP/SC

various demographic groups. 

Environmental Justice analysi

mapped exposure to ozone, c

emissions, cancer risks, and r

assess the impact of emission

throughout the region, emiss

to the Environmental Justice 

RTP/SCS exposes the SCAG re

to the no plan alternative and 

addition, the Program Enviro

RTP/SCS included a Health Ris

160‐04 Penny

Newman

The Center for

Community

Components of the Regional Goods Movement System SCAG

has addressed the fact that the Inland Valley is already home to

Comment noted. As noted in 

evaluates impacts on various 
417

ID Name Affiliation Comment Re

Action and

EnvironmentalJustice

(2008) about 837 million square feet of warehousing space with

another 185 million square feet in developable land. An

estimated 15 percent of the occupied warehouse space served

port‐related uses while the remaining 85 percent supported

domestic shippers. National and regional distribution facilities

tend to be located in the Inland Valley and concentrated in the

Jurupa Valley/Fontana area. The impacts to the surrounding

communities from the diesel spewing trucks drawn to these

warehouses create severe health outcomes and disruption of

the quality of life for local families. SCAG must address these

impacts in a significant manner as to minimize to the furthest

extent possible the environmental and health risks posed from

exposure to diesel exhaust.

Title VI and Environmental Ju

RTP/SCS, SCAG has mapped 

of particulate matter emissio

hazard risks. In order to asses

various demographic groups 

information was summarized 

communities. Additional anal

Final Environmental Justice (E

health and emissions impacts 

years of age. Included in this 

and respiratory risk for areas 

children, along with projected 

on young children for those w

region’s freeways and highly 

Program Environmental Impa

a Health Risk Assessment in A

160‐05 Penny

Newman

The Center for

CommunityAction and

EnvironmentalJustice

The implementation of specific truck routes to keep truck traffic

away from communities of concern as project specific strategies

tend not to address specific impacts to these communities.

Comment noted. SCAG will co

partners and stakeholders an

advance appropriate strategie

negative impacts of freight m

the SCAG region.

160‐06 Penny

Newman

The Center for

CommunityAction and

EnvironmentalJustice

Other measures such as establishment of green zone/buffer

area between diesel sources and residents of at least 1000 feet

are necessary to be protective of residents in close proximity.

Comment noted. The Environ

is not an exhaustive list of me

potential measures that could 

sponsors where appropriate a

do include a recommendation 

barriers between noise sourc

160‐07 Penny

Newman

The Center for

CommunityAction and

EnvironmentalJustice

Additional mitigation measures of trees and foliage that help to

trap many of the ultra fine particles to lessen the impacts to

communities of concern, sound walls to lessen the noise

pollution from residential areas that are too close to freeways

and heavily traveled thoroughfares.

Comment noted. The noise m

Justice Mitigation Toolbox pr

recommendation to construc

noise sources and noise‐sens

this suggested measure, inclu

and foliage, is at the discretio

160‐08 Penny

Newman

The Center for

CommunityAction and

EnvironmentalJustice

Regional Clean Freight Corridor System The truck corridor that

SCAG has proposed will heavily impact the inland valley

communities as SCAG has indicated the increase of truck traffic

to our area will grow from 58,000 to 70,000 trucks per day

although these trucks would be removed from general purpose

lanes when they get to Interstate 15 and State highway 60. That

Comment noted. Emissions fr

a significant concern for the S

lane system identified in the 

facility used by zero‐emission 

opportunity to incentivize the 

technologies for regional freig
418

ID Name Affiliation Comment Re

traffic will then be dumped into our communities at a rate that

will create an even greater health crisis for our communities.

The disregard for the impacts of the plan upon the Inland Valley

communities south of the 15/60 interchange must be

addressed. The residents can’t wait until 2035 for a solution to

this huge impact. Goods movement strategies must ensure that

the South Coast air basin meet federal air quality standards set

forth in the Clean Air Act.

work with and support effort

stakeholders to address good

impacts on communities.

160‐09 Penny

Newman

The Center for

CommunityAction and

EnvironmentalJustice

The RTP/SCS must remove the East‐West Corridor Route

Project.

Comment noted.

160‐10 Penny

Newman

The Center for

CommunityAction and

EnvironmentalJustice

Recommending building an east‐west corridor without analyzing

the health, housing and demographic impacts of the project on

the neighboring communities can have severe environmental,

health and justice implications for the entire region, and

particularly for local communities of concern as previously

stated.

Comment noted. The regionathe 2012 RTP is envisioned to 

trucks. Specific housing, healt

the East‐West Freight Corrido

the 2012 RTP would be analy

project level Environmental Im

160‐11 Penny

Newman

The Center for

CommunityAction and

EnvironmentalJustice

Communities like the City of San Bernardino Westside are an

example of one of the worst impacted by the BNSF Intermodal

Rail yard which after a health risk assessment conducted in

2008 found that residents living in close proximity faced an

increased cancer risk from diesel emissions as much as 15 times

higher than the Union Pacific Railyard UP in Colton and 3 times

higher than any other railyard in the region. To these residents

the point of maximum impact is 3,300 people in a million are at

greatest risk.

Comment noted. SCAG recog

communities are more acute

emissions than others. As a re

and support efforts by region

address goods movement em

communities.

160‐12 Penny

Newman

The Center for

CommunityAction and

EnvironmentalJustice

The RTP/SCS must focus attention on cleaning up existing

freight corridors. Rail companies should not expand until rail

yards like San Bernardino’s BNSF Facility implement zero

emissions technology. These communities with the highest

health risk cannot wait until 2030 for solutions. As freight

transport increases, SCAG must encourage the incorporation of

evolving technologies to specific high risk areas first and not just

for proposed new projects.

Comment noted. SCAG recog

communities are more acute

emissions than others. The Ea

example of goods movement 

harmful emissions through th

SCAG continues to encourage 

partners and stakeholders to 

emissions and impacts on com

160‐13 Penny

Newman

The Center for

CommunityAction and

Environmental

SCAG should use the highest polluting facilities for testing and

evaluation, as well as for the use of advanced technology

locomotive demonstrations.

Comment noted. Emissions fr

a significant concern for the r

with and support efforts by re

to address goods movement 
419

ID Name Affiliation Comment Re

Justice

160‐14 Penny

Newman

The Center for

CommunityAction and

EnvironmentalJustice

The public health evidence is insurmountable to deny. Our built

environment plays a direct impact to our health and the

transportation sector must take into consideration the public

health implications to the region, as well as those communities

of concern and not just the region’s economic growth.

Comment noted. The RTP/SC

that transportation and the b

health. In addition to the pub

Environmental Justice analysi

RTP/SCS will provide widespr

both public health and enviro

better placemaking will allow 

bicycling more regularly in th

development of urban parks t

for recreation and exercise. F

rates and valuations produce

Association, the RTP/SCS resu

total health incidences, and s

total costs.

161‐01 Cesar

Covarrubias

The KennedyCommission

The RTP/SCS identified High‐Quality Transit Areas (HQTA) in the

region as opportunity planning areas for the majority of future

housing and employment growth. It is projected that by the

year 2035, 51 percent of new homes and 53 percent of new

employment growth will be developed in HQTA. While the

HQTA encourages higher density and compact development

near and around job centers and transit amenities, this type of

development does not necessarily facilitate the development of

affordable homes throughout the SCAG region. While there are

several jurisdictions that have initiated urban infill or transit‐

oriented developments, many of these housing developments

have been planned or developed to provide housing

opportunities affordable to higher income households. These

developments lack mixed‐income housing opportunities that

would be available to many working families, especially lower

income families, who want to live and work in the City. While

future growth in HQTA reflects the emerging demographic

trends and is the recommended major land use scenario, the

RTP/SCS acknowledges that there are potential impacts of

displacement of lower income households and gentrification

resulting from new transit oriented developments that attract

affluent residents in the neighborhood. The Commission

recommends that SCAG closely analyze, monitor and mitigate

any potential impacts or environmental justice inequalities

stemming from future development.

Comment noted. SCAG has sh

gentrification in the region th

(EJ) Analysis. The trends obse

and 2005‐09 American Comm

transit oriented development

will continue to evaluate and 

the framework presented in t

economy is recovering.
420

ID Name Affiliation Comment Re

161‐02 Cesar

Covarrubias

The KennedyCommission

On the June 30, 2011 SCAG Environmental Workshop,

participants commented on the need for a performance

measure such as a jobs‐housing fit analysis in the RTP/SCS. This

analysis would evaluate the types of jobs being created in the

community to the housing types and affordability levels of

homes being developed. The RTP/SCS has instead provided a

performance measure on jobs‐housing imbalance or jobs‐

housing mismatch that analyzes the socio‐economic profiles of

long distance commuters. This is a small step towards the right

direction but the Commission recommends there needs to be

more research and thorough analysis, specifically on the jobs‐

housing fit, to provide a better understanding of how we can

strengthen the link between jobs and housing development for

all economic segments of the community.

Comment noted. Please see t

analysis for the inter‐county c

Justice Appendix (pgs. 59‐61)

Longitudinal Employer‐House

SACOG/UC Davis to conduct t

LEHD data to SCAG TAZ geogr

analysis between the ratio of 

(employable residents) and th

time; (2) define both distance 

modes to investigate relation

job pay/worker earning matc

time and mode usage; (3) con

conclusion for inter‐county co

The initial result from the item 

above showed that there is n

ratio and commuting distance

the entire analysis by summe

and policy implications with a

parties.

161‐03 Cesar

Covarrubias

The KennedyCommission

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

162‐01 Bart Reed The Transit

Coalition

Identify the Measure R Van Nuys and Sepulveda Pass transit

projects as corridors rather than designating them as 'busways,'

which could improperly preempt and prejudice the

environmental clearance process. Note that neither Measure R

nor Metro have chosen the mode for either corridor;

“Rapidways” describe rapid transit corridors regardless of

mode.

Comment noted. Text in the R

the comment.

162‐02 Bart Reed The Transit

Coalition

Converting existing High Occupancy Vehicle (HOV) carpool lanes

to High Occupancy Toll (HOT) must allow carpools to have

access to these lanes free of charge and without mandatory

transponders. Otherwise, the intent of the RTP/SCS will be

undermined and its outcome will underperform the potential of

these lanes due to a reduction in both the number of carpools

and the average number of passengers per vehicle.

Comment noted. On the exist

County, carpoolers have free 

periods/directions. Metro ha

for its forthcoming demonstr

Phase 2 of SCAG's Express Tra

study will directly address im

proposed regional HOT lane n

could be integrated.

162‐03 Bart Reed The Transit

Coalition

Converting loading and unloading activities at the ports to direct

ship to rail (excluding any intermediate truck sorting steps) will

enable greater capacity at lower cost and environmental

impact. Creation of a freight pipeline from the Ports to the

Comment noted. Local, regio

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten
421

ID Name Affiliation Comment Re

Inland Empire with an underground alternative to the 60 Truck

Freightway should be an alternative. In addition to a regional

gas tax for transportation, SCAG should implement a diesel fuel

tax that accounts for both the wear and tear on roadways as

well as pollution. Receipts from both taxes should be kept

together in a regional transportation matching fund.

resulting from freight movem

efforts have included the con

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing marke

issues, operational feasibility, 

stakeholders (such as the San 

among others. SCAG will cont

stakeholders and transportat

potential solutions to regiona

163‐01 Numan Parada Transit

Coalition

In looking at the RTP, it seems like a good step in the right

direction in getting everyone in the same boat and how to

proceed with our issues of adding people and jobs. The way I

see it, we need to add houses. We need to have jobs, but we

have this balancing act of doing it without consuming anymore

resources than what we already have. I agree with mixed use

development that is focused on resources that we already have

– infrastructure that we already have. So we hope this Plan

proceeds.

Comment noted.

163‐02 Numan Parada Transit

Coalition

We are looking towards the very real possibility that we will

have $5.00 a gallon gas by this summer and it’s going to be

increasing more in the foreseeable future. If this continues, it

will consume more of a family’s income. Because of that, short‐

haul flights, which consume the most fuel, may be scuttled in

the future. Even if there were more flights, we obviously are

going to be constrained by the airports. So we need a much

better transportation system and inter‐city system much like

the high‐speed rail program. So I want to remind everyone that

we must be focused and we must keep our vision to address

these issues. This document is a good first step.

Comment noted. The Californ

in the Constrained Plan and P

the RTP.

164‐01 Valarie McFall Transportation

CorridorAgencies

Page 23, Vision, Transportation Demand Management

Transportation pricing is not identified as part of the RTP/SCS

“vision” either as a transportation demand management

method or as a financing tool, even though it is clearly a

component of the transportation plan and financial plan for

Comment noted. Pricing is dis

strategies such as the Express

Financial Plan. The Orange C

entirety into the SCAG RTP/SC
422

ID Name Affiliation Comment Re

implementation. The Orange County SCS includes a description

of the current and planned priced transportation network that

should be adapted to address the entire region. Recommended

Clarification: Add information from the Orange County SCS

(pages 126 and 127 of the Subregional Sustainable Community

Strategies Technical Appendix) that describes the existing and

planned inter‐operable priced transportation network in the

region, including toll roads, express lanes and high occupancy

toll (HOT) lanes. The text can be expanded to address HOT

lanes, toll2 facilities, express lanes and tolled truck lanes in the

region as a whole, and should include the following points:

Tolled centerline miles in the region will increase from 61 in

2008, to 408 in 2035, including toll roads, express lanes, HOT

lanes, and tolled truck lanes. Priced lanes provide flexibility and

options as part of the congestion relief toolbox of measures

designed to help meet sustainability and emission reduction

goals related to SB 375 and other state and federal mandates.

“Priced facilities are an especially important tool for providing

intra‐county, inter‐ county and interregional capacity.” “The

existing priced transportation network serves the locations

where major employment and housing growth are projected to

occur.” “Toll roads and express lanes charge users a fee for

travel, but typically offer less congested traffic lanes than

nearby freeways and roadways. Reduced congestion provides

improved and more efficient mobility with fewer air pollutants

and greenhouse gas (GHG) emissions caused by congestion.”

“The toll road system is designed to interrelate with transit

service. The toll roads can accommodate Bus Rapid Transit and

express bus service, and toll road medians are sized and

reserved to provide the flexibility for future transit, if

appropriate.” Priced facilities such as the Orange County toll

roads are privately funded. This insures that these facilities can

relieve congestion and associated air pollution and GHG

emissions without further stressing limited state, federal and

local transportation funding resources.

164‐02 Valarie McFall Transportation

CorridorAgencies

Page 42, Major Highway Completion Projects, Table 2.2 SR‐241

(ORA052) is identified in Table 2.2 as a major highway

completion project. However, the completion year is listed as

2020‐2030. Although widening will occur in the 2020 to 2030

timeframe, the official project description identifies the

Comment noted. Table 2.2 ha

completion year of 2030. Disc

measures is included in the T

Appendix.
423

ID Name Affiliation Comment Re

completion date as 2030. Recommended Clarification: In Table

2.2, we request that the completion date for SR 241 be clarified

as 2030, consistent with the project description for ORA052. In

the interest of establishing that some major highway projects in

Table 2.2 provide emissions reduction benefits without

burdening limited federal, state and local funding resources, we

request the following clarifying footnote: SR 241 is a privately

funded Transportation Control Measure.

164‐03 Valarie McFall Transportation

CorridorAgencies

Page 56, Express/HOT Lane Network This appears to be the only

“priced transportation” discussion in the transportation

investments chapter. It does not identify how many miles of

priced lanes exist now, or how much that network will be

expanded in the plan. Toll roads are included in the priced

transportation network, along with express lanes, and HOT

lanes, but are not included in the discussion. However, TCA’s

Toll Roads are depicted in Exhibit 2.6, Regional HOT Lane

Network. The terminology should be clarified. Recommended

Clarification: Re‐title this section, “Express Lanes, HOT Lanes

and Toll Roads: The Priced Transportation Network.” Table 2.6

should be retitled “Express Lanes, HOT Lanes and Toll Roads”

The text should provide brief definitions of each type of facility

that makes up the priced transportation network, as Express

Lanes, Toll Roads and HOT Lanes each operate differently. The

discussion should include that express lanes, HOT lanes and toll

roads generate user fees that pay for construction and

operation of their facilities. The text should discuss that all

priced facilities in the SCAG region insure inter‐operability by

using a common technology, FasTrak, to collect user fees. The

text should discuss that all priced facilities in the SCAG region

insure inter‐interoperability by using a common technology,

FasTrak, to collect user fees. The text should establish the

congestion reducing goal of priced transportation, and the

associated criteria pollutants and GHG emissions benefits of

providing free flow capacity that avoids emissions generated by

idling. In addition, user fees provide an economic incentive for

cost‐sharing that promotes ride‐sharing, which is beneficial to

reduced criteria pollutants and GHG emissions reductions.

Comment noted. The page re

the proposed Express/HOT La

to be a general discussion of 

roads are provided in the refe

background layer representin

including mixed‐flow and HOV 

164‐04 Valarie McFall Transportation

CorridorAgencies

Page 76, Conservation Planning Policy The description of this

policy requires clarification to express the intent of SCAG’s

Energy and Environment Policy Committee and the coalition of

Comment noted. A reference 

Program will be included in th

policy was as part of the final 
424

ID Name Affiliation Comment Re

more than 20 public, non‐profit and private sector interests,

including TCA that urged SCAG to include it. Recommended

Clarification: Add a paragraph that explains why the

conservation program benefits GHG emissions and other criteria

pollutants reductions. Specifically, in addition to meeting Safe,

Accountable, Flexible, Efficient Transportation Equity Act: A

legacy for Users (SAFETEA‐LU) requirements, the open space

lands conservation program would use natural land acquisition

to sequester (store) carbon, avoid GHG emissions, and reduce

vehicle miles traveled (VMT). This proposed program allows for

early implementation and mitigation opportunities. Jurisdictions

would have the option to invest early in this open space

strategy which offers immediate GHG emissions avoidance

benefits, while simultaneously proceeding with the longer term

and planning intensive projects to build transportation centers

near existing residential areas, or employment centers near

transit stations, etc. Suggested steps to develop a regional

conservation planning policy should be expanded to include the

following key points supported by SCAG’s Energy and

Environment Committee and the coalition that recommended

this program: Build upon existing open space land acquisition

and open space programs in the region, tailoring programs to

each individual county in the region. These include, but are not

limited to, OCTA’s Measure M Mitigation Program, and TCA’s

open space mitigation program, which has protected 2,200

acres in perpetuity to date. Pursue open space conservation in a

voluntary manner, working with willing private sector

landowners.

identified in the comment. Th

conservation policy are curre

final RTP/SCS. SCAG looks fo

Transportation Corridor Agen

164‐05 Valarie McFall Transportation

CorridorAgencies

Page 78, Greenhouse Gases The draft document states that

“The transportation sector, primarily, cars and trucks that move

goods and people, is the largest contributor [to greenhouse gas

(GHG) emissions] with 36.5 percent of the State’s total GHG

emissions in 2008. On road emissions (from passenger vehicles

and heavy duty trucks) constitute 93 percent of the

transportation sector total.” This statement covers only part of

the transportation system’s GHG emissions role. The text must

recognize projects that reduce transportation network GHG

emissions by relieving congestion and insuring free‐flow

conditions. Because GHG emissions from vehicles increase in

stop‐and‐go traffic, congestion relief projects that eliminate

Comment noted. Edits are ref

Safety section of the Final RT
425

ID Name Affiliation Comment Re

bottlenecks and maintain free‐flow conditions actually reduce

transportation network GHG emissions, much as Transportation

Control Measures are transportation projects that reduce

criteria pollutants. Further, the SB 375 Regional Targets

Advisory Committee (RTAC) recommends tracking the

performance of such strategies “to smooth extreme congestion

to more carbon‐friendly speeds” in its final report to the

California Air Resources Board. Recommended Clarification:

Insert the following statements on page 78: Congestion relief

projects reduce transportation network GHG emissions, which

otherwise result from idling. Consistent with the SB 375 RTAC’s

recommendation in its final report to the California Air

Resources Board, the RTP/SCS includes projects and strategies

designed “to smooth extreme congestion to more carbon‐

friendly speeds.” A subset of projects included in the Draft

RTP/SCS reduce GHG emissions by providing relief of existing

and projected congestion. These include toll roads, express

lanes, HOT lanes, high occupancy vehicle (HOV) lanes, and

dedicated truck toll lanes. Congestion pricing is a powerful

transportation demand management tool incorporated in the

Draft RTP/SCS for reducing GHG emissions. SCAG has launched a

two‐year study of congestion pricing strategies that can provide

needed transportation facilities while reducing the region’s GHG

emissions associated with vehicle trips. Orange County’s toll

road network is a prime example of priced congestion relief

projects. The toll roads have variable pricing incentives that

spread out vehicle use to limit peak‐hour congestion that leads

to increased GHG emissions. Other examples of projects that

reduce GHG emissions on the regional transportation network

include express lanes,

164‐06 Valarie McFall Transportation

CorridorAgencies

Page 79, Air Quality Transportation Control Measures (TCMs)

are mentioned as mitigation measures, but are not defined or

illustrated. The importance of TCMs needs to be clarified and

expanded to clearly communicate their air quality role in the

RTP. Recommended Clarification: • Provide a brief description

of projects that qualify as TCMs. • Explain the role of TCMs in

reducing emissions. • Provide a reference to the list of TCMs

contained in the Conformity Technical Report.

Comment noted. Appropriate 

RTP/SCS.

164‐07 Valarie McFall Transportation

Corridor

Page 86, Financial Plan, Introduction The draft document states

that “We have successfully implemented toll systems in the past

Comment noted. We agree th

can provide for financial inno
426

ID Name Affiliation Comment Re

Agencies with the Transportation Corridor Agencies’ network of toll roads

and the SR‐91 Express Lanes in Orange County. This kind of

innovation in transportation continues as neighboring counties

within our region consider a broader network of toll systems.”

However, the statement needs to clarify the financial planning

importance of privately funded toll facilities. Recommended

Clarification: Priced transportation facilities also provide the

opportunity for financial innovation. The Orange County toll

roads (SR 73, SR 133, SR 241, and SR 261) are privately funded.

They provide congestion relief and associated air pollution and

GHG emissions reduction without further stressing limited

federal, state, and local transportation funding.

facilitate private financing to 

other user fees/pledged sour

164‐08 Valarie McFall Transportation

CorridorAgencies

Page 92, Core Revenues, Regional Revenues Table 3.6, Regional

Revenues, identified federal, state and local sources of

transportation funding for the plan. Nowhere in the document

is the private sector funding contribution assumed for the plan

described, although toll road widenings, expansions, and new

tolled facilities that are privately funded are included in the plan

and in the total cost of the plan. Accurately describing the

extent of private funding is an important public disclosure, and

an important element of the financial plan that relieves the

burden on limited federal, state and local transportation

funding. Recommended Clarification: • Clarify in the text the

percentage of total funding contributed by private sources. This

sum should include the privately funded Orange County toll

roads (SR 73, SR 133, SR 241, and SR 261). • A companion pie‐

chart, similar to Table 3.6, showing the split between public and

private funding would also clarify this point.

Comment noted. Private fund

the private equity participatio

available revenue sources. W

important innovative financin

associated debt must be paid 

of return on investment to fa

to take on investment risks. T

funding (and not just financin

overall revenue sources.

164‐09 Valarie McFall Transportation

CorridorAgencies

Page 103, Table 3.5 2012 RTP Revenues (in Nominal Dollars,

Billions) Until such time that the TCA Board reviews, considers,

and/or approves a VMT‐based user fee; TCA is not in a position

to support an increase in fees as proposed in the draft Plan.

Furthermore, the draft does not clarify how the cost of a

proposed new VMT fee, increased gas tax fee, tolls and user

fees would layer over each other. It appears that they would

accumulate for individual drivers, with a potentially significant

economic impact on drivers and households. Drivers paying to

use toll roads, express lanes and HOT lanes would be paying

twice for the same mileage.

Comment noted. The Transpo

detailed explanations on all r

RTP. This report also clearly s

fee and adjustments to state 

would not layer over each oth

of the mileage‐based user fee 

It is also assumed to replace t

excise tax. We acknowledge t

before the mileage‐based use

which is basis for assumption 

2025. The inclusion of the mi

recommendations from two n
427

ID Name Affiliation Comment Re

by Congress through SAFETEA

transportation revenue sourc

throughout the country, we w

for the mileage‐based user fe

Appendix. Included in the imp

evaluate and address any disp

The proposed mileage‐based 

federal gas excise taxes, is dir

transportation resource used

would charge drivers for each 

excise taxes charge drivers fo

amount of gallons of gas cons

total number of miles travele

existing TCA facilities pay tolls 

91 Express Lanes (if they use 

taxes (which funds TCA facilit

and they pay the Measure M 

Orange County). The introduc

does not introduce a layer of 

Express Travel Choices Phase 

specifically address coordinat

express/HOT lanes and toll fa

region.

164‐10 Valarie McFall Transportation

CorridorAgencies

Page 145, Exhibit 4.17, Land Use Pattern Orange County (2035)

The southerly portion of SR 241 (ORA052), from Oso Parkway to

the San Diego County border, has been inadvertently left off

this map. Recommended Clarification: • Please show the SR 241

alignment on Exhibit 4.17 consistent with the project modeling

list and other transportation network maps in the Draft

RTP/SCS.

Comment noted. SCAG will u

164‐11 Valarie McFall Transportation

CorridorAgencies

Page 161, Performance Outcomes This text should clearly state

that performance measures and outcomes are not intended to

apply to individual areas or projects, but rather to the region as

a whole. Recommended Clarification: We recommend that the

following clarification be inserted: Performance measures and

expected outcomes will be used to monitor the RTP/SCS at the

regional level; these measures and outcomes are not proposed

for use at the subregional or project‐specific level.

Comment noted. The RTP/SC

assessed at the regional level

to Table 5.1 stating that these 

use at the subregional or proj

164‐12 Valarie McFall Transportation

Corridor

Page 207, Strategic Plan SCAG assumes $100 billion will be

available from a future VMT fee starting in 2025, but funding for

Comment noted. We agree th

before the mileage‐based use
428

ID Name Affiliation Comment Re

Agencies mileage‐based user fee demonstration projects and

implementation strategies are not included in the constrained

RTP/SCS; they are listed in the unfunded Strategic Plan. The TCA

Board has made no decision on the use of VMT fees and until

such time is unable to support its use in the proposed in the

draft Plan.

That is why we did not assum

to 2025. The inclusion of the 

recommendations from two n

by Congress through SAFETEA

transportation revenue sourc

throughout the country, we w

for the mileage‐based user fe

Appendix. Included in the imp

evaluate and address any disp

The mileage‐based user fee dimplementation strategies, in

illustrative projects that could 

become available.

164‐13 Valarie McFall Transportation

CorridorAgencies

Highways and Arterials Technical Report Page 15, Express/ High

Occupancy Toll (HOT) Lane Network. As with the comment on

page 57 of the main RTP/SCS document, the technical report

should clearly include toll facilities in the description of projects

included in this category. Orange County toll roads are not

categorized as express or HOT lanes, but collect tolls as a means

of insuring low‐emission free‐flow capacity and funding the

construction and operation of the facility. Toll roads integrate

with express lane and HOT lane facilities via the common

FasTrak technology that allows inter‐operability and

convenience for drivers. Retitle this section, “Express Lanes,

HOT Lanes and Toll Roads: The Priced Transportation

Network.” • Table 2.6 should be retitled “Express Lanes, HOT

Lanes and Toll Roads” • The text should provide brief definitions

of each type of facility that makes up the priced transportation

network, as express lanes, toll roads and HOT lanes each

operate differently. Recommended Clarification: The text

should discuss that all priced facilities in the SCAG region ensure

inter‐operability by using a common technology, FasTrak, to

collect user fees. • The discussion should include that express

lanes, HOT lanes and toll roads generate user fees that pay for

construction and operation of their facilities. • The text should

establish the congestion reducing goal of priced transportation,

and the associated criteria pollutants and GHG emissions

benefits of providing free flow capacity that avoids emissions

generated by idling. In addition, user fees provide an economic

incentive for cost‐sharing that promotes ridesharing which is

Comment noted. This section 

proposed Express/HOT Lane 

a general discussion of priced 

are provided in Exhibit 6 as p

representing major planned h

flow and HOV projects.
429

ID Name Affiliation Comment Re

beneficial to reduced criteria and GHG emissions reductions.

164‐14 Valarie McFall Transportation

CorridorAgencies

SCS Background Documentation Pages 36 and 37, Land Use

Pattern Maps for 2020 and 2035. Both of these maps are

inconsistent with transportation network maps in the document

and do not include SR 241 (ORA052), specifically called out in

the RTP as a TCM and priced transportation project in southern

Orange County. Recommended Clarification: Please show the SR

241 alignment on the Land Use Pattern Maps for 2020 and 2035

consistent with the project modeling list and other

transportation network maps in the Draft RTP/SCS. Page 54,

Pricing and Vehicle Policy Assumptions. This discussion only

refers to a 2‐cent per mile VMT fee; the Plan proposes a 5‐cent

per mile fee. This inconsistency should be eliminated.

Recommended Clarification: • Amend the reference to a 2‐cent

VMT fee to a 5‐cent per mile VMT fee starting in 2025,

consistent with the RTP/SCS main document. Add the following

sentence: • Toll roads, express lanes and HOT lanes charge

varying tolls per mile for use of their facilities. Tolls are project‐

specific and typically vary by time of day and day of the week.

Tolls collected for existing toll roads in Orange County are

dedicated to operational expenses and retiring the bonds issued

for construction.

Comment noted. The existing

used for reference in the Land 

Page 54, this section of the re

assumptions used in a sketch 

inform public workshops. It is 

discussion of priced transport

164‐15 Valarie McFall Transportation

CorridorAgencies

Transportation Conformity Technical Report Page 14, Toll

Roads: The discussion of toll road assumptions specifically

mentions express lanes and HOT lanes, but not tolled facilities

such as existing toll roads SR 73, SR 241, SR 133 and SR 261 in

Orange County. Recommended clarification: SR 241 should be

added to Table 6 as a tolled facility and the effect of the toll

charges on it should be incorporated into the highway

assignment procedure. Table 6 should be retitled appropriately

to include "Express Lane, HOT Lane and Toll Road Networks."

This change should also be made in the main RTP/SCS

document.

Comment noted. All toll road

2012 RTP/SCS highway netwo

TCA toll charges on those toll 

highway assignment Procedu

reflect the TCA toll roads are 

network. The intention of Ta

network new to the 2012 RTP

164‐16 Valarie McFall Transportation

CorridorAgencies

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

164‐17 Valarie McFall Transportation

CorridorAgencies

Transportation Conformity Technical Report General This report

addresses the need for the transportation system to enhance

emergency preparedness, and transportation security and

preparedness. Projects that enhance the region’s security are

Comment noted. Most transp

RTP/SCS will help improve tra

the region directly or indirect

redundancy provided by proj
430

ID Name Affiliation Comment Re

not identified. Recommended Clarification: Provide illustrations

of transportation projects needed in the RTP/SCS to improve

transportation security. For example, the southerly extension of

SR 241 provides an alternative route connecting the SCAG and

San Diego Association of Governments coastal regions, which

have very high current and projected travel volumes. This route

will ease future projected congestion to ensure critical capacity

for access and evacuation in times of environmental or other

emergencies, such as earthquakes, wildfires, traffic accidents,

and potential nuclear threats at the San Onofre plant. The need

for an alternative route was recently illustrated by the lack of

evacuation capacity from the 2007 North San Diego County

wildfires.

addressing mass evacuation d

region. In addition, SCAG has 

both before a major emergen

1. Provide a policy forum to h

and education on security po

2. Assist in the planning and p

infrastructure repairs3. Leverage projects and plan

Intelligent Transportation Sys

enhance or provide benefit to 

and those responsible for pla

emergencies.a. Integrate security into the 

b. Become a central repositor

can be used for planning, trai

law enforcement personnel a

SCAG works with local, state 

planning for disaster respons

collaborated with local jurisd

the Federal Emergency Mana

development of the Southern 

Earthquake Response Plan. T

Earthquake Response Plan (O

state/federal response to a ca

California. SCAG has also assi

regional impacts of transport

interchange collapse.SCAG regularly updates the re

incorporate security, most re

While SCAG has a role in plan

infrastructure, and the repair 

after a disaster, County Office

Federal Emergency Managem

immediate and sustained disa

identification of safe access/e

nature of the emergency.

164‐18 Valarie McFall Transportation

CorridorAgencies

Performance Measures Technical Report Page 2, discussion of

types of performance measures. As with the comment on page

160 of the main RTP/SCS document, the text must make clear

that the performance indicators are intended to be applied to

Comment noted. The Perform

revised to state that the RTP/

not required for use at the su
431

ID Name Affiliation Comment Re

the RTP/SCS at the regional level and are not proposed for

project‐specific application. Recommended Clarification: We

recommend that the following clarification be inserted: •

Performance measures and expected outcomes will be used to

monitor the RTP/SCS at the regional level; these measures and

outcomes are not proposed for use at the subregional or

project‐specific level.

165‐01 John Longville Trustee, San

BernardinoCommunityCollege District

As a past president of SCAG (1992‐1993) who has been active in

California transportation policy for more than 35 years, I am

encouraged to see our MPO proposing to address the declining

investments our State has been making in needed construction

and maintenance. Decades ago California wisely spent tax

dollars to build and repair the vital transportation infrastructure

on which our entire economy depends. We must resume that

level of investment so that our children will be able to compete

effectively in the 21st century world economy.

Comment noted.

166‐01 John Longville Trustee, San

BernardinoCommunityCollege District

As a past president of SCAG (1992‐1993) who has been active in

California transportation policy for more than 35 years, I hope

that we will retain the ability in this RTP/SCS to adopt new

technological solutions to our goods movement problems, as

well as the currently proposed truck corridor strategy. Private

sector investors are developing an alternative highly

mechanized freight‐moving system that has won the support of

the Sierra Club for its environmental benefits and that offers

some remarkable energy and time advantages as well. SCAG’s

final language in the RTP should be written broadly enough to

avoid needlessly placing obstacles in the way of such

technological progress in goods movement abilities.

Comment noted. Thank you f

regional, and state partners, 

from both the public and priv

together over many years to 

solutions to the challenges re

Southern California. These ef

consideration of numerous co

date have indicated that a reg

clean trucks (i.e., near‐zero a

promising solution to regiona

SCAG anticipates further anal

including evaluation of a wide 

application to such a system. 

evaluation would be made ab

segmentation, first‐mile/last‐

collaboration with regional st

Bay Ports), and costs among o

dialogue with stakeholders an

identify potential solutions to 

167‐01 John Longville Trustee, San

BernardinoCommunityCollege District

Our generation has benefited greatly from the transportation

investments that earlier Californians made many decades ago.

We have been less foresighted in recent years, declining to pay

for much of the infrastructure maintenance, expansions and

improvements that those who follow us will need. “Reasonably

Comment noted.
432

ID Name Affiliation Comment Re

available revenues” should not be discounted to accommodate

those who have reaped the rewards of earlier public

expenditures but now do not want to pay forward a fair share

for the needs of our children and grandchildren.

168‐01 John Longville Trustee, San

BernardinoCommunityCollege District

More than 20 years ago I was one of the founders of the

Southern California Regional Rail Association, which created

Metrolink. Unfortunately, many people are still unable to use

Metrolink, either because of inadequate train frequency or

because the system has too many unserved areas.

Improvements to that existing system will make it useful for a

larger proportion of our population, greatly increasing the

overall efficiency of the region's total transportation system.

Comment noted. The Draft RT

expansion of the commuter r

for speed improvements asso

Speed Rail project.

169‐01 Frank Colcord Unitarian

Universalist

LegislativeMinistry

The UULM will be submitting detailed comments in writing that

will emphasize things like active transportation. I am here today

mainly to voice general support for the Draft RTP/SCS. My

demonization’s principals emphasize inherit worth and dignity

of the individual while recognizing human kinds interconnected

dependence on our environment. The RTP reflects those values

by helping ensure access to transportation and housing for all

those in our community in way that emphasizes environmental

sustainability. The RTP fill a real need which is to ride a tangible

vision for what our community can look like in this time of

climate change.

Comment noted.

170‐01 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

We are pleased that the draft RTP and SCS have a number of

positive elements expanding clean transportation, encouraging

more sustainable land uses, and reducing greenhouse gas

emissions: ‐ The planning process took account of the

relationship between transportation, land use, sustainability,

environmental justice and economic development. ‐ The draft

plan calls for significant investments in transit construction,

operations and maintenance, ‐The draft plan increases

investments in active transportation compared to previous

RTPs. ‐ The draft plan anticipates that vehicle miles traveled will

increase less than population growth ‐ The sustainablecommunities strategy quantifies how different forms of growth

will have very different impacts on sprawl, energy and water

use and other sustainability indicators. ‐ The draft plan

anticipates adoption of zero emission technologies towards the

end of the plan time frame. ‐ The draft plan supports high speed

rail. ‐ The draft plan anticipates a reduction in greenhouse gas

Comment noted.
433

ID Name Affiliation Comment Re

emissions from transportation in line with the goals of SB 375. ‐ 

The single largest anticipated funding source in the draft plan is

implementation of a fee on driving or an increase in the gas tax,

either of which would discourage driving. ‐ Much of the new

highway space proposed in the draft plan is toll roads, HOV

lanes, or HOT lanes (open to HOB or Tolls) and therefore may

lead to less new, induced driving than the provision of free,

multiuse lanes. We however, believe that the plans can do more

and need to do more to expand alternatives to driving; price car

and truck traffic to reflect their negative externalities; reduce

the amount of space given to cars, trucks and parking; create

good places rather than sprawl; and clean up the goods

movement industry.

170‐02 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

Rapidly create a more balanced transportation system. The

SCAG region has 21,638 center‐line miles of road, 4315 miles of

bikeways of varied quality (almost zero if it protected lanes on

streets), and 470 miles of passenger trains (only 80 miles of

which is light rail/subway, the rest metrolink). Opportunities

and infrastructure to walk, bike, and take transit should be

rapidly expanded so residents have choices how far to get

around. 1. Significantly increase investments in active

transportation from the $6 billion budgeted. The Los Angeles

County Department of Public Health calculates that $40 billion is

needed to fix sidewalks, implement jurisdictions' bike plans; and

invest in last mile infrastructure near transit stations. ‐ Streets

are our most important public spaces so we should reconfigure

them to be vibrant, safe, healthy places rather than spaces

designed to move as many cars as possible without regards for

impacts on adjacent activities. Active transportation funding

should convert existing arterials and local streets to be world

class living and complete streets. SCAG should encourage

jurisdictions to follow the street design standards contained in

the Model Design Manual for Living Streets. ‐ Most cities in the

SCAG area have not developed bike or pedestrian plans so part

of this funding should go towards assisting these cities in

developing plans early in the implementation years. ‐ Most

people will not ride bicycle in traffic (or separated from traffic

by a painted line). In the developed world, every nation with

high rates of cycling has separated bike facilities while every

nation with low cycling rates lacks this infrastructure. Let's start

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour
434

ID Name Affiliation Comment Re

creating a network of protected bike lanes/cycletracks in all

urbanized areas of Southern California, like the Dutch did

beginning in the mid 1970's. Budget at least $1 billion for the

construction of 1000‐2000 miles of protected bike lines to

increase rates of cycling among non traditional cyclists

constructed in Long Beach.

170‐03 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

2. Expand and accelerate transit investments so all planned

transit projects in the RTP are constructed by 2022. Existing and

new transit services should be funded so as to be affordable

with frequent service. Rapid buses should serve all major streets

in urban areas so that buses become the default motorized

transportation choice.

Comment noted. SCAG suppo

and other transit projects wit

as soon as funding becomes 

170‐04 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

Pay for additional active transportation and transit investments

by defunding harmful highway projects and by identifying local

revenue sources that tax harmful transportation. Moving people

by cars and materials by trucks and diesel trains and separating

where we live from where we work and shop produces fatal

collisions, cancer and heart disease, obesity and diabetes, and

climate change with a disparate impact on residents of low

income neighborhoods bisected by highways and living near

ports, warehouses, railyards and intermodal facilitie. SCAG

should projects that increase harmful transportation and tax

driving and freight transport to pay for clean transportation. 1.

Chancel highway expansion projects to pay for more active

transportation and transit. Among the dozen most expensive

road expansion projects in the RTP are: east west freight

corridor ($15.2 billion), Riverside to Orange County CETAP ($13

billion), high desert corridor ($6.9 billion), 710 corridor

expansion ($6.1 billion), 710 gap closure ($5.6 billion), 5 north

capacity enhancements ($5.3 billion), 241 expansion ($2.7

billion), mid county parkway ($2.3 billion), 15 widening ($1.7

billion), 405 widening in Orange County ($1.7 billion), 5

widening ($1.6 billion), and 79 expansion ($1.4 billion). Building

these highways projects will expand driving (and, if built in areas

with predominately rural or suburban land uses, also expand

sprawl). Cancelling them can allow the $63.5 billion budgeted

for these projects to be spent on active transportation and

transit.

Comment noted. The distribu

transportation investments in 

tax measure commitments ap

transportation commission adplans, limitations associated w

other previous commitments

170‐05 Mark

Vallianatos

Urban and

Environmental

2. Support local revenue sources that price driving, parking, and

freight transport to reflect the externalities of motorized

Comment noted. As noted, th

of revenue sources tied to tra
435

ID Name Affiliation Comment Re

Policy InstituteOccidentalCollege

transportation. There are a variety of methods for increasing

the price of driving, some of which are contemplated in the

RTP's financial plan.Higher gas taxes, carbon taxes, charges

based on miles driven, appropriately and dynamically priced

parking, and congestion charges aimed at commuters entering

central city areas are all useful policies.

principles SCAG considered a

regionally appropriate revenu

developing the RTP financial s

based system that better refl

transportation, provides firew

funds, and ensures an equita

benefits.

170‐06 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

C. Reduce rather than increase the space granted to cars and

trucks in order to reduce driving. Roads and parking currently

take up too much of our land, which encourages car‐based

transportation and all the problems that accompany it. Driving

increases when roads are constructed, lengthened or widened.

1. Do not add any lane miles of highways or major arterials. The

SCAG region currently (base year 2008) has 21,638 miles of road

and 55,890 lane miles of roads. the draft RTP anticipates adding

948 centerline miles/ 7419 lanes miles which would be a 4.4%

11.1% increase. As Duranton and Turner have shown, "For

interstate highways in the densest metropolitan areas we find

that vkt increase in exact proportion to highways, confining the

'fundamental law of highway congestion' suggested by Downs

(1962, 1992). This relationship also approximately holds for

other important roads in dense areas and for interstate

highways in less dense part of metropolitan areas." Converting

mixed flow lanes to toll, HOV or HOT lanes or converting HOV

lanes to toll or HOT lanes would still be acceptable.

Comment noted.

170‐07 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

2. Set a target to reduce vehicle miles traveled from the

baseline year of 2008. Vehicle Miles traveled in the baseline

year 2008 was 445,844 daily, approximately half of freeways,

half of arterial roads. SCAG calculates that this number will rise

to 546,806 daily by 2035 without any changes to roads (a 22.6%

increase). Under their plan, VMT will still rise, to 516,990 (16%

increase). They also anticipate that VMT for trucks will grow

even faster, expanding from 30,201 to 53,431 under their 2035

plan (a 76.9% increase). Instead of planning for this increase, set

a target for a reduction in VMT.

Comment noted. SCAG may c

future RTPs.

170‐08 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

3. Plan for highway removal or modification. Learning from

cities removing highways, agencies and municipalities should

plan to remove, cover or alter and reclassify as arterials

highways that divide communities, negatively impact valuable

natural resources such as rivers and coasts, or channel excessive

Comment noted. Plans for hig

should also consider circulatio

and the regional system.
436

ID Name Affiliation Comment Re

valuable traffic into neighborhoods. Freeway stubs such as the

710 N above the 10 or the 2 as it approaches Silverlake are ripe

for removal or conversion and the 101 through downtown Los

Angeles has been the subject of advocacy for capping for a park.

170‐09 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

D. Pursue stronger sustainable communities strategies to create

good places rather than sprawl. People are drawn to diversity in

the built environment, so municipalities should increase

interesting, mixed‐use neighborhoods by focusing growth near

transit and altering zoning rules that restrict mixed use

development to a small fraction of cities' land area. 1. Adopt

alternative 3 (the envision 2 alternative) smart growth land use

and housing patterns) rather than the planned project. This

alternative version of the plan relies on smart growth land use

and housing patterns to achieve superior environmental results

in air quality, aesthetics, open space and farmland preservation,

water conservation, greenhouse gas emissions reductions,

mobility, and land use.

Comment noted. For more in

see the Final PEIR Addendum 

Comments on the Draft RTP P

170‐10 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

Fund local jurisdictions to allow them to update their general

plans and zoning codes to reflect sustainable community and

smart growth principals.

Comment noted. Through the 

SCAG has worked with and pr

to 94 separate jurisdictions in

profits, and transportation ag

applications will focus on loca

strategies, and will prioritize 

Transit Areas (HQTA). In addit

funding agencies have begun 

principles into their discretion

continue to pursue dedicated 

important program.

170‐11 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

Encourage sensitive densification of existing single family zoned

areas by encouraging municipalities to allow cottage housing,

duplexes, accessory dwellings, and small lot subdivisions in R‐1

zones.

Comment noted. Chapter 4 o

multiple actions and strategie

development of housing. The

the unique housing needs of 

region.

170‐12 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

4. Encourage all jurisdictions to eliminate mandatory parking

minimums for existing and new buildings.

Comment noted. In the Trans

Appendix, SCAG encourages c

parking requirements in zonin

170‐13 Mark

Vallianatos

Urban and

Environmental

E. Clean up goods movement industry before planning to

expand it. Do not invest in goods movement roads and rail

Comment noted. Goods mov

economic driver for the SCAG 
437

ID Name Affiliation Comment Re

Policy InstituteOccidentalCollege

expansion in the hopes that zero emission technologies will

emerge decades later. Invest more in zero emission trucks and

locomotives now as a recondition before expanding freight

infrastructure. Otherwise impacted communities will continue

to suffer disproportionately from pollution from good

movement. 1. Require widespread adoption of zero emission

trucks and rail in the region as a precondition for funding any

expansion of goods movement infrastructure.

revenues for Southern Califor

Forecasts indicate that the am

the region are expected to in

horizon. SCAG works closely w

stakeholders to identify appro

challenges that may include e

used for goods movement ac

goods movement activities ar

SCAG region. The regional tru

2012 RTP is envisioned to be 

trucks. This system also offer

adoption of clean, zero‐emiss

freight movement. The 2012 

economic benefits of freight m

myriad impacts of freight. The 

approached as separate conc

and support the efforts of, re

to address goods movement 

communities.

170‐14 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

Recommend a $30 per twenty‐foot container fee for moving

either into or out of the ports to help pay for mitigation of

existing environmental impacts and to help pay for research

into zero emission alternatives. This strategy could generate as

much as $441 million in revenue from loaded containers in its

first full year of implementation, when applied equally to

imports and exports.

Comment noted. SCAG will w

and stakeholders to identify p

appropriate.

170‐15 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

3. Require maximum development of on dock rail before

funding any off dock projects.

Comment noted. SCAG works 

including the San Pedro Bay P

implementation of regionally

However, SCAG does not dete

implementation of projects a

170‐16 Mark

Vallianatos

Urban and

EnvironmentalPolicy InstituteOccidentalCollege

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

171‐01 Stuart

Waldman

Valley IndustryandCommerceAssociation

On behalf of the Valley Industry and Commerce Association

(VICA), thank you for your commitment to the transportation

needs of Southern California. While we appreciate the inclusion

of a handful of major San Fernando Valley‐centered projects in

Comment noted. The distribu

transportation investments in 

tax measure commitments ap

transportation commission ad
438

ID Name Affiliation Comment Re

the Regional Transportation Plan (RTP), we are disappointed by

the insufficient appropriations for these projects and the lack of

investment overall in the San Fernando Valley.

plans, and other previous com

171‐02 Stuart

Waldman

Valley IndustryandCommerceAssociation

Specifically, no funding is directed to renovations of I‐101

between downtown Los Angeles and the city of Calabasas or

improvements to I‐405 north of the I‐101 interchange.

Comment noted. The distribu

transportation investments in 

tax measure commitments ap

transportation commission ad

plans, limitations associated w

other previous commitments

171‐03 Stuart

Waldman

Valley IndustryandCommerceAssociation

Furthermore, I‐134, I‐170, and the major arterials of the Valley

receive minimal investment.

Comment noted. The distribu

transportation investments in 

tax measure commitments ap

transportation commission ad

plans, limitations associated w

other previous commitments

171‐04 Stuart

Waldman

Valley IndustryandCommerceAssociation

Despite $40 billion in financing secured for Measure R projects

in the greater San Fernando Valley, the only Valley projects in

the Federal Transportation Improvement Plan (FTIP) are the

renovation of the Interstate‐101 off‐ramp at Van Nuys

Boulevard; the freeway connector at the I‐101 and I‐405

interchange; the I‐405 Corridor Mass Transit project through the

Sepulveda Pass; the studies of the Van Nuys corridor and

Burbank‐Glendale‐Pasadena Airport intermodal ground access;

and expansion of transit centers at Pierce and Mission Colleges.

These projects are of vital regional significance to the Valley, but

they are only the tip of the iceberg.

Comment noted. The distribu

transportation investments in 

tax measure commitments ap

transportation commission ad

plans, limitations associated w

other previous commitments

171‐05 Stuart

Waldman

Valley IndustryandCommerceAssociation

Key sections of the I‐101 freeway need to be renovated to

relieve bottlenecks and increase roadway safety between the

Valley and downtown Los Angeles. These sections include the I‐

101 interchanges with the I‐170 and I‐134, which connect

commuters and clients with the north, east and west San

Fernando Valley. The roadway degradation along this I‐101

corridor requires immediate attention and should be included in

the RTP.

Comment noted. The RTP inc

for highway system preservat

171‐06 Stuart

Waldman

Valley IndustryandCommerceAssociation

The north and west Valley also depend heavily on I‐405. Comment noted.

171‐07 Stuart Valley Industry To reduce traffic and enable quicker, more efficient Comment noted. The RTP inc
439

ID Name Affiliation Comment Re

Waldman and

CommerceAssociation

transportation between the Valley and West Los Angeles, mass

transit solutions are necessary.

capital investments.

171‐08 Stuart

Waldman

Valley IndustryandCommerceAssociation

The I‐405 Mass Transit project through the Sepulveda Pass is

the first step.

Comment noted. This is a Me

RTP.

171‐09 Stuart

Waldman

Valley IndustryandCommerceAssociation

A planning process and full financing must be put into place

without delay.

Comment noted.

171‐10 Stuart

Waldman

Valley IndustryandCommerceAssociation

While renovation of I‐101 and I‐405 are pressing, their effective

use will not be possible without proper maintenance of the

transportation system that serves these freeways

Comment noted. The RTP inc

for highway system preservat

171‐11 Stuart

Waldman

Valley IndustryandCommerceAssociation

While the Financially‐Constrained RTP Projects and Strategic

Plan lists contain a few projects along major Valley arterials, this

system requires immediate restoration and improvement. Van

Nuys Boulevard, Sepulveda Boulevard, Riverside Boulevard,

Ventura Boulevard, Mulholland Drive, Laurel Canyon Boulevard,

Victory Boulevard, Sherman Way, Burbank Boulevard, Reseda

Boulevard, Topanga Canyon Boulevard, De Soto Avenue,

Vineland Boulevard, Hollywood Way, Canoga Avenue, Vanowen

Street, Nordhoff Street and Lankershim Boulevard are just a few

of the several roadways critical for employees and clients to

access the Valley using I‐101 and I‐405.

Comment noted. The RTP inc

for local streets and roads sys

171‐12 Stuart

Waldman

Valley IndustryandCommerceAssociation

The City of Los Angeles recently submitted a list of additional

“Local Highway” projects, the majority of which target major

Valley arterials. We ask that you review this list and include

several—if not all—of the identified projects in the Strategic

Plan.

Comment noted.

171‐13 Stuart

Waldman

Valley IndustryandCommerceAssociation

The sections of I‐170, I‐134 and I‐5 freeways connecting the east

San Fernando Valley cities of Burbank and Glendale to the rest

of Los Angeles County also receive only minor attention in the

RTP.

Comment noted.

171‐14 Stuart

Waldman

Valley IndustryandCommerceAssociation

Roadway repair and mass transit options along these routes are

necessary for Bob Hope Airport access and mobility into and

within these east Valley cities. We ask that you increase

investment in the Burbank‐Glendale‐Pasadena Airport

Comment noted. Some of the

included in the Strategic Plan

Bob Hope Airport, City of Los 

explore opportunities to cons
440

ID Name Affiliation Comment Re

intermodal ground access study and add renovations of the East

Valley arterials to the Strategic Plan.

updates.

171‐15 Stuart

Waldman

Valley IndustryandCommerceAssociation

Thank you for considering our recommendations. We look

forward to full funding of the San Fernando Valley projects on

the Federal Transportation Investment Plan and Financially‐

Constrained RTP Projects lists, as well as expansion of the

Strategic Plan to include critical Valley projects.

Comment noted.

172‐01 Rachel Morris VCCool +

Ventura

Bicycle Union

You will find our 1,241 signatures for increased funding for

Active Transportation in the 2012 SCAG RTP in the shared

Dropbox folder as noted in my e‐mail. To see VCCool’s online

petition and video please visit: www.active‐transit.org.

Comment noted.

173‐01 Ben Cacatian Ventura

County Air

PollutionControlDistrict

Pg. 26 The 2007 ozone AQMP was approved by VCAPCD and

ARB and submitted to US EPA as the Ventura County portion of

the SIP in 2008. EPA has not formally approved the 2007 SIP

submittal, thus, the 1994/1995 approved SIP is the applicable

SIP for conformity. The 2007 submitted SIP does not include

TCM G – Employee Commute Options (ECO) that was part of the

1994/1995 approved SIP. TCM G was repealed in 1998 as result

of the federal removal of the ECO mandate and State law that

prohibited non‐mandated federal ECO rules. Pg. 27 You have

listed the “Land Use Strategy Transit Strategies” as one TCM.

These two strategies are separate TCMs and should be shown

separately on the list.

Comment noted. Appropriate 

the Final RTP.

173‐02 Ben Cacatian Ventura

County Air

PollutionControlDistrict

PROJECT LIST APPENDIX The project list should include the

name of the lead agency/jurisdiction to cross reference the

projects with other sections of the RTP/RTIP and locate the

project descriptions from the agencies/jurisdictions. The listed

project costs for Ventura County appear to be extremely large

and appear to need updates. The following Ventura County

projects, as listed by their respective description and

completion date, appear to be TCMs and should be listed

Transportation Conformity Report appendix: VEN055410,

VEN055413, VEN031203, 5TC0701, VEN990310, VEN990319,

VEN053403, VEN051401, VEN031229, VEN040502, 5TPL04,

VEN056403, VEN990341, 5N011, 5A0742, 7120009, 7120008.

Comment noted. SCAG attem

information for all RTP projec

for all projects. In response to 

VEN055413, VEN031203, VEN

VEN031229 have been correc

VEN990319 has been correct

not a reportable TCM; 5TPL04

7120009, and 7120008 are no

not included in the Transport

Appropriate revisions will be 

regarding VEN040502, VEN05

174‐01 Rachel Morris Ventura

CountyClimate Care

OptionsOrganized

5‐8% of 2012 RTP /SCS total investment of should go to active

transportation. Petition with 1241 signatures.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th
441

ID Name Affiliation Comment Re

Locally Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

175‐01 Patty Senecal Western

StatesPetroleum

Association

The RTP/SCS should consider a range of possible growth factors

for the goods movement sector (e.g., high, low). This “bounding

exercise” would help decision makers and the public better

understand how sensitive economic and environmental factors

are to goods movement sector growth. Also, given that we are

informed that ship emissions are temporally variable, the

“bounding exercise” should also inform the AQMP emissions

inventory and consequent air quality modeling. It is especially

important that SCAG validate the emissions baseline (e.g., the

2009‐2011 actual emissions) so that the growth projections are

based on “real” emissions rather than theoretical or modeled

emissions from past exercises. This is made even more

important because the initial “in‐year” emissions are the basis

for building future‐year emission projections.

Comment noted. SCAG did us

for the base year to validate t

growth in the future. As such 

of both base year and project

175‐02 Patty Senecal Western

StatesPetroleum

Association

SCAG should publish the technical assumptions used in the draft

RTP/SCS concerning assumed rates of deployment for: (a) zero

emission transport for container drayage; (b) zero and near

zero‐emission trucks for regional transport; (c) electrified rail

technologies; and (d) zero or near zero emission rail technology.

The timing for these assumptions is critical to the AQMP

attainment demonstration. In addition, the RTP should provide

information on daily, monthly, or seasonal activity associated

with these actions. Again, as stated previously, this information

is critical to input into the emissions inventory and the air

quality modeling.

Comment noted.

175‐03 Patty Senecal Western

StatesPetroleum

Association

The RTP/SCS needs to fully consider the electricity sector

infrastructure needs, implementation challenges and emissions

impacts that would result from the policy recommendations

contained in the draft plan. These emission impacts will be

significant in scale and may impact the feasibility of RTP/SCS

measures, particularly the schedules. These data are essential to

Comment noted. The Program 

includes an analysis of electri

and Utilities chapter. SCAG c

SCAQMD in the development 

have the necessary data.
442

ID Name Affiliation Comment Re

proper development of the AQMP and the air quality modeling

used by the SCAQMD.

176‐01 Glenn Parker Wildlife

CorridorConservationAuthority

We are pleased to see the inclusion of an advanced mitigation

component. We have suggestions for modification of the

Conservation Policy: (1) Ensuring State conservancies and joint

powers authorities with a conservation focus are included in the

mapping & prioritization of conservation lands. Specifically, we

recommend including WCCA, Puente Hills Habitat Preservation

Authority, San Gabriel & Lower Los Angeles Rivers and

Mountains Conservancy, Mountains Recreation and

Conservation Authority, and Santa Monica Mountains

Conservancy among the entities upon whose expertise can be

tapped; (2) Extending the inventory of protected lands to

include all protected lands‐Federal, State, regional and local

natural lands‐instead of narrowly limiting the inventory to

simply Natural Communities Conservation Plan and Habitat

Conservation Plan areas; (3) Ensuring existing wildlife corridors

and habitat linkages and highway/roadway undercrossings are

protected and enhanced during the evaluation of habitat lands

and during construction of roadway projects; (4) Advocating

that the advanced mitigation policy result in a net

environmental benefit for the natural resource lands after

construction activities are completed. Also, large‐scale

acquisition and management of lands must not be limited to

"critical habitat," (p. 76, 128) as this can be confused with the

legal term used by US Fish & Wildlife Service for some federally

endangered and threatened species. To clarify, this should be

replaced by text reflecting the intent, i.e., the best available

natural lands with valuable environmental resources deserving

of conservation/preservation. WCCA looks forward to working

with SCAG on the development of the Natural Lands Acquisition

and Open Space Conservation Strategy. This will protect

remaining resource lands and mitigate for impacts from

transportation improvements. WCCA recognizes conservationeasements as a powerful preservation tool for habitat areas.

Conservation easements, and fee title transfers to open space

park agencies, should be listed in the plan alongside other

preservation mechanisms. SCAG should take a leadership role in

setting guidelines and best practices for these new county and

municipal programs as well as explore the creation of a

Comment noted. The propose

pursue a strategic planning p

resources. The intent is to inc

stakeholders, including the gr

regarding “critical habitat” w

habitat lands.”
443

ID Name Affiliation Comment Re

regionally unified transfer of development rights (TDR) program.

This method should not only be limited to agricultural lands but

also include other opens space lands.

176‐02 Glenn Parker Wildlife

CorridorConservationAuthority

The policy decisions in the SCS are projected to save 408 sq.

miles of nonurban land over the life of the plan. There is no

projection of where this growth will not occur and what

mechanisms will preserve the land in perpetuity. The lack of

specificity makes it difficult for WCCA to evaluate the impacts of

the proposed plan. SCAG is clearly making assumptions about

where development on resource lands is and is not appropriate.

This process is not transparent. For example, the large

undeveloped privately‐owned property known as the Aera

property in the middle of the Puente chino Hills wildlife corridor

has been identified on Exhibit 4.1 as population growth of

2,001‐3,500 persons per sq. mile. In fact, much of this property

has been identified as a proposed Significant Ecological Area in

LA County's most recent draft General Plan. Ironically, this

particular development proposal's population, employment and

housing growth areas contradict the goals of SB375 and its

requirement for reduced VMT. The location of development is

nowhere near public transit, does not include a major

employment center but instead focuses on large single family

residential units, requires dependency on the automobile, and

will increase VMTs, not reduce them. With the understanding

that land use authority belongs to local jurisdictions, a truly

comprehensive regional plan would transparently set growth

parameters in concert with resource conservation goals to

eliminate these apparent contradictions. Projecting growth in

resource areas sets in motion policies that induce that growth;

therefore great care must be taken to ensure such growth

meets regional objectives.

Comment noted. It is the inte

significant ecological areas. S

land use policy as a foundatio

development pattern: ensure 

preservation despite competi

by growth, housing and empl

development patterns.The RT

are to be protected from dev

Government Code Section 65

conservation strategy will pu

for identifying open space res

plans. The intent is to include 

based on input from a wide v

The Exhibits 4.1, 4.2 and 4.3 w

size, but the high resolution G

available upon request. The r

developed for the purpose of 

figures allocated to the area w

received from projects submi

governmental Review (IGR). S

jurisdictions going forward on 

ensure that the identified Are

represented.

176‐03 Glenn Parker Wildlife

CorridorConservationAuthority

WCCA appreciates SCAG's recognition of the impact that linear

transportation facilities have on natural areas and the need for

well‐designed wildlife crossings to partially mitigate these

effects. Wildlife crossings need to be discussed in the context of

habitat connectivity, which is the broader ecological goal for

conservation areas. Wildlife corridor design is a field in its

infancy with few scientifically verified best practices for crossing

dimensions and landscape features. Given that this research is

needed to properly mitigate transportation impacts, SCAG

Comment noted. The mitigat

Resources and Open Space in

of habitat linkages, preservat

crossings to minimize the imp

wildlife species and habitat fr

wildlife crossings and habitat 

develop the proposed conser

forward to working with the W

Authority on future planning 
444

ID Name Affiliation Comment Re

should invest in connectivity research with a program

specifically designed to establish measures that can be

incorporated into the 2016 RTP revision. Such a program would

aggregate existing research, propose new study areas, and

develop design best practices specifically tailored to the

Southern California eco‐region.

176‐04 Glenn Parker Wildlife

CorridorConservationAuthority

WCCA is interested in urban river projects for their multiple

recreational, environmental, and transportation benefits. The

RTP/SCS should fully fund build‐out of these active

transportation corridors throughout the region. When well

designed, these facilities serve as "bicycle freeways" connecting

various parts of the region with uninterrupted travel for non‐

motorized users. The RTP/SCS calls for $6 billion over the next

two decades for active transportation investments, which

seems low when compared to the identified need in local bike

and pedestrian plans. Given the central role active

transportation plays in meeting regional planning objectives,

funding levels should be set based on full build‐out of local

bicycle and pedestrian plans, with an appropriate amount

projected for those jurisdictions that have not yet completed

such plans. The currently proposed funding level does not

appear to be rooted in such a need‐based assessment. It is not

adequate to simply compare the proposed expenditures with

past levels independent of a needs assessment. In addition to

the total funding level, the proposed timing of active

transportation investment is inadequate. Only 20% of the

proposed expenditures would occur during the first 15 years of

the 25‐year planning period, leaving the vast majority of

expenditures for the highly speculative future and of little use to

current residents. Transit and transportation demand

management are similarly back‐loaded with only highway‐related investments receiving funding priority in the near term.

These non‐highway investments are the ones most likely to

generate greenhouse gas emissions savings, among other

benefits, and the earlier they are made the longer the benefits

can accumulate. The proposed expenditure plan runs directly

counter to the stated emphasis of the SCS. WCCA suggests that

the plan's funding priorities be reversed to immediately fund

active transportation investments at a sufficient level to achieve

build‐out of the region's bicycle and pedestrian networks in the

Comment noted. SCAG has de

Bikeway Network to close reg

network. Implementation of t

locally proposed bikeway pro

bikeways from 42.6% to 63.7%

allocates approximately $6.7 Transportation investments. 

we have received and based o

finance plan, staff is pleased t

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu
445

ID Name Affiliation Comment Re

near and medium term. Such a change would make the RTP

more consistent with the land use and mode share objectives

outlined by the SCS, the intent of SB375.

176‐05 Glenn Parker Wildlife

CorridorConservationAuthority

WCCA encourages SCAG to evaluate the feasibility and to

develop a greenway corridor that can be used for active

transportation (e.g., bicycle trail) along San Jose Creek,

connecting to the San Gabriel River (by Whittier Narrows) and

further west. This San Jose Creek bikeway is an east‐west route

that parallels the SR‐60 freeway. It is an important commuter

route, where a viable bikeway could relieve some freeway

traffic. Maintaining and enhancing an open creek channel for

wildlife use (e.g., birds) and recreational use (bicycles) would be

a valuable amenity in this area. It would be beneficial to

investigate and implement other bicycle routes in the area,

including a connection between the LARIO trail along the Rio

Hondo from its end at Peck Road Water Conservation Park to

the San Gabriel River. Another valuable connection would be

between the Whittier Greenway Trail to the San Gabriel River at

its west end and from its east end to Coyote Creek. These trails

are pieces in the larger planned bikeway trail network

throughout the region.

Comment noted. SCAG will w

consider the incorporation of 

transportation along the spec

update of the SCAG Regional 

176‐06 Glenn Parker Wildlife

CorridorConservationAuthority

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

177‐01 Steve Twining WRAC I am very happy to see that there is some funding for the initial

phase of the Fast Train. We need to compete with Europe,

Japan, and China.

Comment noted.

177‐02 Steve Twining WRAC I have concern over the RTP’s population projections and

understand that you can adjust them every four years.

Comment noted. The RTP, inc

projections are updated ever

planning requirements.

177‐03 Steve Twining WRAC HOV Lane construction can be very disruptive to communities.

Those of us on the Westside are literally almost dying in the

traffic between Westwood and Brentwood. As for the Ports,

your projections about containers, I am sure you are well aware

about the Panama Canal being widened so larger ships can go

through. As a result, perhaps the region will have a less of

increase in usage at the two Ports in Long Beach and Los

Angeles.

Comment noted. Mitigation o

addressed in the project‐leve

implementing agencies.
446

ID Name Affiliation Comment Re

177‐04 Steve Twining WRAC As for the Ports, your projections about containers, I am sure

you are well aware about the Panama Canal being widened so

larger ships can go through. As a result, perhaps the region will

have a less of increase in usage at the two Ports in Long Beach

and Los Angeles.

Comment noted. The expansi

the potential for diversion of 

Pedro Bay Ports. This diversio

regional goods movement sys

However, the potential level 

this time. SCAG continues to 

stakeholders to address the c

as a result of the project.

177‐05 Steve Twining WRAC Over the years the inner city transportation planning has been

very weak. Recently the situation has improved somewhat. We

are concerned about some of our streets which are not going to

have over passes. The Expo Line is designed to reduce traffic but

on some of our street traffic will be slowed because of the delay

in getting over the Expo Line.

Comment noted.

177‐06 Steve Twining WRAC The jobs housing issue is a major issue for the Westside of Los

Angeles. Some of our neighboring cities have expanded their job

locations at the expense of housing. Our communities suffer

from all the traffic that goes to work in adjacent cities in both

directions. In many of the areas of the city, in the hills

particularly, we are concerned that senior citizens can not being

riding bicycles downhill to connect to the east west

transportation.

Comment noted. SCAG's Activ

Transportation Safety Append

safety policy recommendatio

safety of bicyclists. Additiona

to expand travel options for 

system by promoting a balan

approach.

177‐07 Steve Twining WRAC The other issues that concerns me is the lack of availability to go

on rapid transit directly into the airport.

Comment noted. The Airport 

Aviation Technical Appendice

contains an extensive analysi

issues and opportunities at ai

proposes a number of new tr

projects.

178‐01 A.K. Bahl Camarillo

resident

There must be a vote of the whole population of Camarillo –

NOT 84 people shoving it down our throats!! Everyone at our

meeting was AGAINST this planning. If you got 1 million

negative comments and 10 positive you still wouldn’t stop it,

would you?!!!!

Comment noted. The Regiona

every four years to comply w

proposed policies and strateg

2035 Regional Transportation 

Strategy were developed by s

throughout the region, input 

the last two years, and input 

Council, which is comprised o

Members and County Superv

the SCAG region. These electe

members of SCAG’s Regional 

and they have discussed the p
447

ID Name Affiliation Comment Re

regular and special meetings 

adoption at their April 4, 201

179‐01 David Reid Colton

Resident

San Bernardino RTP Public Hearing ‐ 1/18/2012 David Reid ‐ 

Colton Please finish Santa Ana [River?] Bike Trail

Comment noted.

180‐01 Susan Lien

Longville

ConcernedCitizen

As a former SCAG Regional Council Member that served during

the time I was a member of the San Bernardino City Council

from 1998‐2006, I had the opportunity to work closely with

previous Regional Transportation Plan (RTP) implementation

efforts. I continue to remain engaged as a private citizen in

issues of importance to Southern California. Thank you for the

opportunity to submit my public comment by email. In the last

RTP, there was a concept similar to the current GRID (Green Rail

Intelligent Development) to which there was no progress during

implementation. I am writing to express my desire that this

Southern California alternative to Goods Movement be once

again included in the current RTP. The GRID alternative, which

proposes the installation of 15‐ft. water‐tight pipelines housed

in an unmanned electrified rail guide way, has a number of

advantages for traversing goods from the Ports of Los Angeles

and Long Beach to the inland regions of California. First,

installation of an underground pipeline would employ

installation that is identical to the installation of water pipelines

that use only a “cut and cover” technique which

environmentally presents much less adverse impacts.

Furthermore, this project holds the potential of creating many

jobs in Southern California during the manufacturing and

construction of the system because materials proposed in GRID

are already manufactured locally. Finally, I believe that including

an alternative Goods Movement concept that would be

powered by electricity, rather than diesel, is good public policy.

As a resident of San Bernardino, the concept of moving Port

freight through an underground pipeline that would ultimately

emerge at an Inland Port holds the promise of someday

reducing the truck traffic that is affecting so many of Southern

California’s Disadvantaged Communities where rail and existing

roadways traverse and gravely impact the respiratory health of

our children and seniors who have been shown to be

disproportionately affected by goods movement. For those

reasons, I urge SCAG to include the GRID alternative in the

current RTP providing the opportunity to further examine a

Comment noted. Thank you f

regional, and state partners, 

from both the public and priv

together over many years to 

solutions to the challenges re

Southern California. These ef

consideration of numerous co

date have indicated that a reg

clean trucks (i.e., near‐zero a

promising solution to regiona

SCAG anticipates further anal

including evaluation of a wide 

application to such a system. 

evaluation would be made ab

segmentation, first‐mile/last‐

collaboration with regional st

Bay Ports), and costs among o

dialogue with stakeholders an

identify potential solutions to 
448

ID Name Affiliation Comment Re

concept without any significant impact to air quality as is found

in existing rail shipments or container movement by diesel‐

powered semi trucks. Sincerely, Susan Lien Lon I look forward to

hearing the Regional Council has included GRID as an alternative

Goods Movement Alternative. Susan Lien Longville, 1833

Kenwood Ave. 92404

181‐01 Kevin Orange County

businessowner

We don’t have money. We are being told that Washington is

mandating this and that and they are insane. Sacramento is

mandating this and that and they are insane. We don’t have the

money. Our money is not worth the money it’s printed on. We

have to be fiscally conservative and responsible. We can’t afford

this, as pretty as it may look.

Comment noted.

182‐01 Alice Eaton Thousand

Oaks resident

I am opposed to incurring any debt on any transportation plan

in this current economic climate. I feel that any plan that

envisions rezoning for government to control our community’s

growth in this central plan is a violation of the 14th

Amendment.

Comment noted.

182‐02 Ernest

Wurschum

ThousandOaks resident

There should be a public meeting during the evening so that

working people can attend.

Comment noted. While SCAG 

the public to learn about and 

plans, services and initiatives

public hearings in various loca

various times, SCAG realizes t

be convenient for everyone. S

public meetings in the evenin

assessment of outreach activ

182‐03 Michelle

Gregory

ThousandOaks resident

This is ICLEI, Agenda 21. This is NOT what people want. Ten

states have passed resolutions exposing Agenda 21, ICLEI and

the fraudulent “green agenda”.

Comment noted. The greenh

targets that SCAG is required 

RTP/SCS is a state law require

183‐01 A Ball We don't need more gov't interference in our cities and local

plans. We don't want to live in the super density skyscraper

cities that have been imposed in Korea and that you are trying

to shove down our throats. If the gov't won't live there, we

shouldn't have to either!!!!!

Comment noted.

183‐02 A Ball Air quality is much improved in the last ten years. We don't

need gov't interference in imposing more cripling gov't

legislation and mandates already inhibiting any US growth. Let

free enterprise work to improve our transportation. It is always

preferrable to any gov't rules!

Comment noted.

184‐01 A Ball I oppose the Regional Transportation plan! When are you going Comment noted.
449

ID Name Affiliation Comment Re

to publish the content of the letters directed against and for this

plan? We need to have a vote from the public. We don't need

increased rail and bike lanes. They are too underutilized now.

We don't need more traffic lanes....just fix the ones that are

there. If the border laws were enforced we wouldn't have so

many people (illegal) reaching our state.

185‐01 A Ball I oppose the regional transportation plan. This is supposed to be

a 'free' country where we have a right to decide our future.

Your plan takes this away from our decision and puts it in the

hands of 84 people. I can't believe you, as an American, can go

along with this intrusion into our lives.

Comment noted. SCAG’s Regi

Members are voter‐elected M

County Supervisors from juris

region. The cities and countie

official to represent them at S

Committees.

186‐01 Anna Rahtz My comments regarding the draft RTP/SCS encompass two

main concerns. 1. Why are highway capital project funds being

front loaded (i.e., more or the same amount of money is being

spent on them in the short term as in the long term) while funds

for transit and active transportation are being back loaded

(more is being spent on them in the long term after the year

2020)? 2. The text in the draft document does not seem to

match up with the list of projects that are actually being funded.

Much of the text in the RTP/SCS document is dedicated to

explaining the need to preserve the existing system because it

will cost more to reconstruct it later than to preserve it now.

This is true ...so then why is a higher percentage of funding for

arterial and mixed flow capital projects being spent before 2020

than for highway operations and maintenance (Table 3.6)? I

counted at least 82 road widening projects just in San

Bernardino County in the FTIP (which will be funded in a five

year period). I would like to see more justification in the text

explaining the benefits and need for these road widening

projects, but when I look in the text in the draft document

explaining project approach, I don’t see much at all about

highway capacity expansion. It seems to be bundled in with

project categories such as “Mixed Flow and Interchange

Improvements” and “System Completion and Expansion” that

are not giving a true description of what these projects are

really accomplishing. It appears to me that these capacity

expansion projects are being sold as measures to relieve

congestion and reduce travel times, recovering productive time

for travelers. On the contrary, it has been widely proven that

Comment noted. The distribu

transportation investments in 

sales tax measure commitme

transportation commission ad

plans, limitations associated w

other previous commitments
450

ID Name Affiliation Comment Re

highway capacity improvement projects provide only temporarycongestion relief, if any at all, and that they in fact induce

additional trips that result in even heavier congestion in the

long term (References: Mark Hansen and Yuanlin Huang, “Road

Supply and Traffic in Californian Urban Areas,” Transportation

Research A, Volume 31, No 3, 1997, pp. 205‐218... Mark Hansen,

“Do New Highways Generate Traffic?” Access, No. 7, Fall 1995,

pages 20, 22 ... W. Wayt Gibbs, “Transportation’s Perennial

Problems,” Scientific American, October 1997.)

187‐01 C P Thank you for your work putting together this plan, and for

accepting and considering comments. Here are my responses to

reading the plan: 1) I would like to see more investment in and

commitment to providing alternative forms of transportation.

Comment noted.

187‐02 C P a) If the low investment in “active transportation” infrastructure

is a result of the analysis conducted to identify the “optimal mix

of strategies and projects that yields the highest return on

investment,” is it possible that some of the costs have been

externalized from the analysis? What about the cost benefits of

improved environmental and human health from active

transportation? Has this been undervalued in the analysis?.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

187‐03 C P b) Currently, I rely solely on single‐occupancy vehicle

transportation. The reason I don’t use alternative forms of

transportation is because it costs significantly more time and

money to do so. I would like to see our alternative

transportation infrastructure grow to the point of dominating

our mobility system. Only then will it become convenient to use.

Comment noted.

187‐04 C P c) Current bicycle infrastructure is severely lacking; we need

much more investment in it. Even doubling it would not be

nearly enough. Thank you.

Comment noted.

187‐05 C P The maps indicating Rail Transit System Growth from 1990 to

2035 show a significant slowdown of rail development in the

2012‐2035 RTP. The routes and extensions identified are

excellent, but we should invest more in the system. The map

Comment noted. The 2012‐20

billion to transit capital proje

capital projects, and $139.3 in 

maintenance funding. 46.9% 
451

ID Name Affiliation Comment Re

would be more useful in showing this if it included both time

periods on the same map. Currently, I rely solely on single‐

occupancy vehicle transportation. The reason I don’t use

alternative forms of transportation is because it costs

significantly more time and money to do so. I would like to see

our alternative transportation infrastructure grow to the point

of dominating our mobility system. Only then will it become

convenient to use. Thank you.

public transit or passenger ra

187‐06 C P Thank you for your work putting together this plan, and for

accepting and considering comments. Here are my responses to

reading the plan: I would like to see a more thorough analysis

and presentation of the land use pattern. a) There is no map

that shows the before and after regional development from

now to 2035; there is no way to see how much sprawl will

occur. b) I can’t tell from the SCS chapter whether there will

really be any significant change in sprawling development

habits. Currently, it gives the impression there won’t. I don’t see

that this SCS has “set forth a future land use pattern to meet

GHG emission reduction targets." Thank you.

Comment noted. Appendix: S

the 2012‐2035 RTP/SCS conta

land use development patter

2020 and 2035. These maps s

to meet SCAG's GHG emission 

187‐07 C P Thank you for your work putting together this plan, and for

accepting and considering comments. Here are my responses to

reading the plan: Although the RTP meets the CARB GHG

reduction targets, it will still result in an overall increase in GHGs

(2005 pop of 17M at one unit of per capita GHG emissions vs.

2035 pop of 22M at .84 (1‐16%) unit of per capita GHG

emissions equals 18.48 units of per capita GHG emissions, an

8% increase!). The real goal is to counteract climate change and

the only way to do that is to reduce our total GHG emissions. In

my opinion, we should be investing as much as possible in those

forms of transportation that reduce GHGs. I'm talking 90% of all

our investments. And I say that as a single‐occupancy driver

who relies solely on auto infrastructure (for lack of better

options). I know this plan is only required to comply with SCAG's

targets, but because of the importance and power of addressing

environmental problems at the regional level, I wish this

regional plan would be more ambitious. Thank you.

Comment noted.

188‐01 Carol Teutsch Thank you for the comprehensive SCAG RTP currently in draft

format. I have viewed your video and attended one of your

public meetings. Many of the comments offered in the public

forum reflected interest in the active transportation elements

Comment noted.
452

ID Name Affiliation Comment Re

and delayed funding for implementing these concepts which I

am sure you took note of and which reflect my own priorities.

Having individual mobility on freeways as a key objective is not

sustainable and we should shift away from that as a priority.

188‐02 Carol Teutsch I am a physician deeply interested in the environment and in

the impact of our environment (built and natural) on our health.

TRANSPORTATION IS HEALTH. I am delighted with the Health in

All Policies document put in place for the state by our former

governor, but feel its careful recommendations are not being

given adequate prioritization in your thinking.

www.sgc.ca.gov/workgroups/hiap.html

Comment noted.

188‐03 Carol Teutsch I am new to southern California, having moved here from the

east coast. The area is captivating and we need to protect it—

not pave over more of it and not continue to building polluting

solutions.

Comment noted.

188‐04 Carol Teutsch I would like to see to health risk and health impact assessments

as part of your standard operating plan development. The

externalities of health and environmental impact must be

known because they affect long costs and benefits, which is

your responsibility in these long term plans. A very nice and

recent example of integrating public health objectives in

transportation planning can be seen in an independent research

report from the Victoria Transport Policy Institute

(www.vtpi.org) (http://www.vtpi.org/health.pdf accessed

March 27, 2011).

Comment noted. The Program 

the RTP/SCS included a Healt

188‐05 Carol Teutsch I know that cargo movement is an essential part of your plan.

Investing now in better options that are zero emission is key to

the region’s long term success. We could implement the

“greenest” port in the world, helping our region, our citizens’

health and demonstrating leadership for the world. There is

concern about whether trucking is an appropriate choice for

cargo transport and inappropriately subsidized by not

accounting fully for externalities. The new GAO Report GAO‐11‐

134 showed that “ on average, additional freight service

provided by trucks generated significantly more costs that are

not passed on to consumers of that service than the same

amount of freight service provided by either rail or water.” This

report puts an additional burden on SCAG to consider

alternatives such as rail and appropriately include consideration

of all externalities. (Full report at

Comment noted. Emissions fr

a significant concern for the S

lane system identified in the 

facility used by zero (or near 

continues to support efforts b

goods movement emissions a

as the San Pedro Bay Ports Cl

feasible to move all goods by 

conventional rail, as existing m

different markets. For examp

outside the region (e.g., Chica

from the San Pedro Bay Ports 

However, goods moving from 

regional manufacturers to loc

international border with Me
453

ID Name Affiliation Comment Re

http://www.gao.gov/new.items/d11134.pdf as a result of cost, lack of acc

first‐mile/last‐mile issues, or 

movement system is complex 

single mode of transportation

188‐06 Carol Teutsch The tunnel proposal is of special concern to me since I live in

Northeast LA. We will be bringing a corridor of damaging health

effects up this way instead of solving the problem in the south

710 region. We see increasing proof of adverse health effects of

ultrafine particles and no means to remove them in tunnel

exhausting. We also need to see a robust model of costs of

running tunnel ventilation which is very expensive. I have many

additional references on tunnels and how they concentrate

pollutants if you need them. The large ventilation shafts in

residential areas are visually and from a health perspective

undesirable. We also attract trucks to our roads which are not

held to the same pollution standards‐‐‐from Mexico and in

construction. I would like you to directly address these issues in

your RTP.

Comment noted. Issues regar

of ventilation shafts are not a

analysis of the RTP/SCS and w

project‐level engineering and 

developed by implementing a

must comply with CEQA and 

188‐07 Carol Teutsch We are all concerned about jobs. The link provided is by a highly

respected transportation expert and deals with questions of

jobshttp://www.uctc.net/access/38/access38_transportation_growt

h.shtml.

Comment noted.

188‐08 Carol Teutsch You have a difficult job, but it is clear that you can never build

your way out of the terminal congestion we have on our

freeways. There is no uncongested freeway in the area. The

models that are often used do not consider adequately induced

demands and changing patterns and many secondary variables.

We need to provide alternatives and shift incentives to reduce

demand on the freeways for individual and truck mobility so our

current freeways can function efficiently most of the time. We

need to coordinate smart land use with transportation. There

are a lot of creative thinkers and voices. Let’s work together to

come up with the best solutions!

Comment noted. The RTP/SC

multi‐modal set of transporta

address the region's transpor

every four years to regularly r

conditions.

189‐01 Catherine

Paquette‐

Richardson

I am taking this opportunity to write to you to comment on the

2012‐2035 Draft Regional Transportation Plan/Sustainable

Communities Strategy (RTP/SCS). I am from the southern area

of Orange County, California. In general, where the RTP is

planning on expanding the freeway network system and local

roads, I am in agreement. Expanding the use of transit (bus,

Comment noted. All major tra

extensive period of study and 

lead agency. These include an 

Environmental Impact Report

and preliminary engineering d

need for additional transport
454

ID Name Affiliation Comment Re

commuter rail) should only be done where studies show there is

a greater need, which would minimize having to use precious

tax dollars to subsidize this transit. Bicycle paths are great, but

they should not be seen as an alternative to general

transportation but rather mainly as recreation.

189‐02 Catherine

Paquette‐

Richardson

High‐speed rail should be postponed until California is once

again a booming state and unemployment is maintained or

lower than 5.5%. Record number of businesses and people are

leaving California, which is one reason why there will be a tax

revenue shortfall in the billions of dollars. In fact State

Controller John sent a letter to the California legislatorsannouncing that the State will run out of cash on March 8, 2012.

He stated that the legislature will need to allow the State

Treasurer to delay $2.4 billion in payments to universities,

counties and Medi‐Cal, and will need to borrow another $3.3

billion from Wall Street bankers.

Comment noted.

189‐03 Catherine

Paquette‐

Richardson

I understand that we are spending $700,000 daily just on the

California High Speed Rail Authority staff and consultants. This is

not the best use of taxpayer dollars at this time. The cost of

high‐speed rail continues to be underestimated time and again.

Ridership is suspect and with each year, more and more

taxpayer’s monies will have to be used to support high‐speed

rail. Its reduction on GHG will in no way match these exorbitant

costs.

Comment noted. The annual 

High Speed Rail Authority (Au

legislature in conjunction wit

control over those funding m

with the Authority to refine t

189‐04 Catherine

Paquette‐

Richardson

When your report states that the region wastes over 3 million

hours each year sitting in traffic, mass transit would waste

perhaps comparable hours, if not more, having to get to the

transit stations, then wait for a bus or rail, and again need to get

to our final destinations. Besides, transit travel in southern

California is not conducive to our lifestyle. It is certainly not

friendly to families. Our preferred life style in southern

California is single‐family homes separated from industry and

business zones. Clumping people in high‐density living just to

reduce the use of vehicles is forcing people to change their

preferred lifestyle and not giving them a choice. Freeways

around these high‐density areas will eventually impede traffic

flow from city to city.

Comment noted.

189‐05 Catherine

Paquette‐

Richardson

The only thing unsustainable to this preferred lifestyle is the

limit and restrictions arbitrarily placed on our resources by

government to appease the radical environmental groups and

Comment noted. State laws r

achievement of the greenhou

as part of the 2012‐2035 RTP/
455

ID Name Affiliation Comment Re

individuals. There is also disagreement as to whether GHG

cause global warming which our government has refused to

question.

189‐06 Catherine

Paquette‐

Richardson

What is most important in California right now is to stay within

a balance budget, to cut or postpone spending and to relax

regulations so we become more business friendly. Our tax

revenues would then grow. Unfortunately, if there are no funds

to pay for all of the RTP, then its plan needs to be postponed

indefinitely. I am not be in favor of increasing taxes, fees or

penalties in any form to try to obtain funds to pay for the RTP. I

will be voting against all tax increases or bonds.

Comment noted.

190‐01 Cathy

Richardson

I’m against this basically because when you do the research,

there is reasoning, there’s eminent domain, things that are

going to happen that we aren’t even imagining. So I want to

know if this is something that is going to be clearly laid out that

voters can understand and vote on, or is it just going to

happen? Do we have any say and things can be redistricted and

eminent domain can come in and take out whole communities?

Is it just because this one Proposition has passed, all these other

things are added to it without people being able to protest?

Comment noted. SCAG is man

develop a “Sustainable Comm

does not require local jurisdic

the use of eminent domain. W

provide a regional policy foun

may build upon if they so cho

quantitative growth projectio

the region, local jurisdictions 

191‐01 Cristi Ritchey We do not want anything else to be "fixed" nor "sustainable?

The majority of valid scientists agree that Global Warming is

utter nonsense. We do not want any of our tax dollars going to

it.

Comment noted.

192‐01 Cyrus Hojjaty Greetings SCAG, Cyrus Hojjaty here and I arrived at your

meeting and voiced my concern over the 2035 General Plan and

SB 375. Despite the fact that it is true that some people enjoy

living in mixed‐use buildings, take mass transit, and walk to their

daily needs, this plan not only does not meet the desires

effectively of those individuals, but does not meet the demands

of others. Many of these plans are costly, unnecessary, and

invade peoples lifestyles whether they choose to change or not.

It seems understandable that many of the policies that SCAG is

trying to implement are trying to reverse the policies that were

created by the coded car‐dependent cities since the 1930s. It is

true that many of these urban policies have understandable

concerns, however at least the most important benefit is that

many people are able to get single‐family homes and some free‐

flowing traffic. We must preserve these benefits instead. What

is so depressing that even though SCAG criticizes the car‐

Comment noted.
456

ID Name Affiliation Comment Re

dependent lifestyle we currently have, it was heavy intervention

that created the system in the first place! As a matter of fact,

many of these areas involving strip malls, collector roads,

housing subdivisions, etc... were heavily manipulated by codes,

regulations, and subsidies. So basically the association does not

want to admit that the system was caused by heavy

intervention and yet they act like as the “saviors” to this

problem to bring even more intervention. Sadly, many do not

understand because of the different “buzzwords” and looks of

the project. Give me a break! We are not mice! We are humans!

We are not supposed to be treated in lab experiments whether

it is a car‐dependent landscape or a high‐density packed

environment!

192‐02 Cyrus Hojjaty What is deceptive and problematic, is that events are used to

manipulate the decisions of the citizens. People are wrongfully

being concerned over resource‐depletion and man‐made

climate change. These concepts have heavily been debunked by

many scientists and yet the temperatures have even rising in

other planets as well! Do we really have to trample down on

people over a belief that is heavily flawed? This does not sound

like improving the lives of the many to me! Besides, we so much

land available left in Southern California. With so much vast

miles vacant land, why can’t alternative town complex get built

instead that COMPETES with what we have instead of

monopolizing? I mean even if the 2035 was a wonderful

approach, there is no need for monopolies. Urban planning is

not a natural monopoly. In fact, during the meeting I display an

alternative plan that does instead compete. SCAG should

probably learn from a 19 year old, who has not even been to

school to study urban planning!

Comment noted.

192‐03 Cyrus Hojjaty Many of your projects in SCAG listed for Orange County are

quite concerning yet some necessary. For land‐use, let the

developers and the marketplace decide if the mixed‐use designs

are necessary. Allow flexible zoning codes to let people decide

whether it will be strip malls, attached homes, office strips, or

mixed‐use. Of course you do in some areas want to restrict

development like industry, toxic waste dumps, etc... For

goodness sake, do not add any regulations, codes, get huge

subsidies, and threat public and private property. My

suggestions for the highway improvements and upgrades are

Comment noted. SB 375 legis

jurisdiction’s land use policies 

with the SCS. While the SCS is 

policy strategy that local gove

choose, and generally include

projections from each city an

forward, local jurisdictions m
457

ID Name Affiliation Comment Re

letting construction occur when the REAL unemployment rate

(Not CPI junk) for Orange County dips below 8.5%. I defiantly

opposed to unnecessary projects like the high speed rails, road

tolling, smart streets, rapid connectors, and the high‐frequency

Metrolink (unless if the ridership is high.)

193‐01 Cyrus Hojjaty If you go back, we did mixed use a hundred years ago, but we

didn’t have these General Plans. We didn’t have all these bogus

regulations and laws. It was really the market that did this and

then in the 1930s or 1940s, you guys made it illegal to do these

things. You said it’s all about car dependency and housing

subdivisions and strip malls. So you talk about how things are so

drivable, but yet it’s the codes and regulations that the special

interest groups have lobbied that cause the problems we have

today. So why should we have you guys act like the saviors and

make things even worse. There’s a high chance that I’m going to

live here in Orange County. There are a lot of desirable factors

here and so it’s amazing how the problems were created by the

planners and the codes and regulations. That’s why we have

strip malls because they were created to benefit the “Big Box”

corporations. And now you want to do eminent domain and add

a lot of laws and get people out of their cars. We have a right to

meet our own needs. If you guys want transit and you want

mixed use, or if you want large lot homes and free flowing

traffic, then pack your bags – go out into vast empty land and

build your dream city there.

Comment noted. SCAG is man

develop a “Sustainable Comm

RTP.This process does not req

nor does it involve the use of 

intended to provide a regiona

governments may build upon 

includes the quantitative grow

county in the region going for

local land use authority.

194‐01 Dan Crain The Regional Transportation Plan would hold that much more

strength if it included the GreenRail/Intelligent Design (G.R.I.D.)

element. This G.R.I.D. proposal would reduce diesel truck

emissions and truck traffic ‐ plus the undergrounding of freight

movement would make for safer highways. The G.R.I.D.

proposal, using an underground automated freight conveyance

system, would also include underground automobile

transportation corridors that would have NO impact on the

above ground environment, a feature which the Sierra Club fully

endorses. In addition, thousands of good jobs to assist our

southern and inland California economies would be created in

committing the design from paper to reality, building additional

port infrastructure in the ports of Los Angeles and Long Beach,

digging the tunnels and manufacturing the light rail systems for

the effective conveyance of freight. Frankly, this is an absolutely

Comment noted. Local, regio

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten

resulting from freight movem

efforts have included the con

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing marke

issues, operational feasibility, 
458

ID Name Affiliation Comment Re

BRILLIANT proposal that would enhance the quality of life for

millions of residents who call southern and inland California

their home. As a former Yucaipa Mayor and Councilmember

from 1992 ‐ 2000 (and SANBAG representative), an Inland

California community where truck traffic is exceedingly

prevalent on the 10 freeway, I heartily endorse this proposal. I

ask that the SCAG Board of Directors include the Green

Rail/Intelligent Design Proposal in all your deliberations for the

Regional Transportation Plan's EIR. Thank you for giving every

serious consideration to these comments.

stakeholders (such as the San 

among others. SCAG will cont

stakeholders and transportat

solutions to regional freight c

195‐01 Danny Morgan We need to come up with a underground rail system to move

containers from the ports to the inland valleys.

Comment noted. Local, regio

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten

resulting from freight movem

efforts have included the con

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing markeissues, operational feasibility, 

stakeholders (such as the San 

among others. SCAG will cont

stakeholders and transportat

potential solutions to regiona

196‐01 Darryl Parker We support the building of the Highgrove Metrolink Station.

Thank You The Parkers

Comment noted. Station‐stop 

a local issue, and is the respo

within each county.

197‐01 Deirdre

Hennings

I strongly support Senate Bill 375. Comment noted.

198‐01 Denise Savoie I believe revenue projections are unrealistic and program costs

unsustainable. Expenditure projections astronomically surpass

what voters, like myself, supported when the HSR measure was

approved.

Comment noted.

198‐02 Denise Savoie HSR needs to be taken back to the voters. Cost estimates are

inexcusable...especially in an economic climate with revenues

Comment noted.
459

ID Name Affiliation Comment Re

decreasing and with cuts to vital social service programs and

education looming...the CHSR Authority needs to be held

accountable for bringing voters the project they approved!

199‐01 Dennis Baxter As a former San Bernardino City Council member, I am anxious

to see greater transit service availability for low income

residents of our region. Those of us who are easily able to

slightly increase our funding of these necessary investments

must step forward and approve such expenditures as others did

before us.

Comment noted.

200‐01 Elise Kalfayan SCAG’s draft 2012 RTP and its EIR are both flawed, do not meet

AB32 and SB 375 goals, and will not move this region toward

better mobility, an improved economy, or sustainability. The

plan advocates expanding and extending urban highways,

building a dedicated truck route for freight movement, and

creating more conventional goods movement platforms such as

the BNSF SCIG project. According to the EIR, these have

“significant and unavoidable impacts.” The plan’s slate of

projects will worsen air quality, increase congestion and safety

risks on roadways, pose threats to public health, and degrade

the environment overall and specifically of those communities

adjacent to such infrastructure.

Comment noted. As discussed 

RTP/SCS is estimated to redu

reliability, improve air quality

emissions.

200‐02 Elise Kalfayan [PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

201‐01 Erin Cornwell I was bit surprised and disappointed that 2012 Regional

Transportation Plan concluded that the best solution for the

Goods Movement Strategy was more lanes of truck traffic. The

vision of SCAG is simply to build truck‐only corridors, actually

freeways, that may “improve truck operations and safety....and

provide a platform for the introduction and adoption of zero‐

emission technologies.” If SCAG really had a vision to

accomplish these things, then a better goal would be to remove

the trucks from the system entirely. Why not consider an

underground system that would limit land surface

development? The Green Rail Intelligent Development (GRID)

system may just be the perfect solution. This system would

move cargo containers through a series of underground

“subways” directly from the port to the distribution city. This

system would be zero‐emission on day one, not after some

costly regulations kick‐in. The trucks would still be removed

from roads, which would be safer and cost taxpayers less in

Comment noted. Local, regio

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten

resulting from freight movem

efforts have included the con

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing markeissues, operational feasibility, 

stakeholders (such as the San 

among others. SCAG will cont
460

ID Name Affiliation Comment Re

highway maintenance. It would also reduce additional “eye‐

sore” freeways, reduces noise pollution and free land surfaces

for other more economical developments. I believe that it

would behoove SCAG to consider this as a solution.

stakeholders and transportat

potential solutions to regiona

202‐01 Ezequiel

Gutierrez

Public Participation The work of SCAG is challenging and must

address extensive policies, programs and laws on local, state

and federal levels. One requirement that was noticeably absent

throughout the Draft RTP/SCS process was compliance with the

requirements of the Environmental Justice Order of the U.S.

Department of Transportation (DOT). The order can be found in

62 Federal Register at 18380. The public participation required

in the DOT Order is much more extensive than what was

afforded in SCAG public participation efforts, as described in the

Draft RTP/SCS and experienced by the undersigned. The Order

required a marked elevation of public participation by

communities of concern as stated “during the planning and

development” of the Draft RTP/SCS rather than providing for a

passive audience to occasional presentations by SCAG staff with

limited time given for contemporaneous comment. The non‐

compliant efforts were not without adverse consequence in

providing for environmental justice; a great deal more work

remains to be done, as more fully set forth in comments by

Climate Plan and its partner coalition. It is feared that without

addressing those concerns, the environmental impacts on the

SCAG region will be significant and wide spread. A draft RTP/SCS

that is responsive to all residents of the region would address

the needs of the entire economic spectrum of the region, not

for political acceptance but as the best policy for dealing with

growth, regional management and environmental impacts.

Comment noted. From comm

SCAG staff identified environm

further follow‐up. As such, SC

workshops and convened foc

justice analysis in an attempt 

public to participate meaning

June 24, 2010, SCAG held a w

process and familiarize the pa

justice analysis process. On Ju

up workshop to discuss the p

stakeholders and seek furthe

from the first workshop, SCAG 

modeling process. A majority 

Justice organizations were re

part of the workshops, SCAG 

the environmental justice com

was strongly encouraged and 

individual meetings and prese

groups, at their convenience. 

noticed and advertised to nea

to the special environmental 

workshop for Resource Agenc

RTP/SCS, where environment

Furthermore, environmental 

involved throughout the plan

goods movement efforts. We 

work with environmental just

202‐02 Ezequiel

Gutierrez

Environmental Impacts If the economy of the region is well

served by this planning, and significant growth is encouraged,

transportation demands by the entire economic spectrum of

the region will be greatly increased. The demands on the

currently overloaded transportation system of the region which

we have all experienced will itself be greatly increased into an

unresolvable gridlock. Persons from communities reflecting the

entire economic spectrum of the region commute daily and

without adequately providing for them, as discussed by the

Comment noted. SCAG has sh

environmental justice analyse

RTP/SCS evaluates region‐wid

groups. New to the Title VI an

for the 2012 RTP/SCS, SCAG 

concentration of particulate m

respiratory hazard risks. In or

emissions on various demogr

region, emissions information 
461

ID Name Affiliation Comment Re

coalition, transportation disaster in the not too distant future is

certain. Without incorporation of responsive planning, through

those efforts described in the coalition comments and through

full compliance with the DOT Order, the Draft RTP/SCS and its

related Draft PEIR are fundamentally not certifiable. Request is

respectfully made that SCAG charge its staff with pursuing

responsive planning, as recommended, so that all communities

of the SCAG region and so that the region itself may benefit

from these dedicated efforts.

Environmental Justice commu

Environmental Impact Report 

Risk Assessment in Appendix 

SCAG complies with all releva

regard to environmental justi

Orders on environmental just

with stakeholders to address 

in the transportation planning 

203‐01 Ezequiel

Gutierrez

I have noted that through the years a lot of the planning is done

in parallel fashion, there is not too much correspondence

between the various planning agencies. This has not improved

through the years and that is an area in which more progress

needs to be made. SB 375, which this document addresses, falls

short of what SB 375 is requiring. SB 375 is not really requiring

another plan but a strategy as the name explicitly says. The

strategy is to implement AB 32 and along that line, because it is

an implementation strategy and what is really called for by the

State Legislation, there needs to be more efforts toward making

sure that those goals are going to be met. For example, a lot

more monitoring and evaluation of performance goals should

be make and should be set forth from this point. In the area of

affordable housing, that is really dealt with more on an

implementation level as opposed to grand plans. Without

providing some kind of guidance to the jurisdictions maybe

some model ordnances, some model programs, some suggested

funding for affordable housing programs, I think the mission of

SCAG as set forth has increased by SB 375 would fall a bit short.

The document is well prepared but we need implementation in

mind as it moves forward. Along that line, the corner stone of

SB 375 legislation was transit oriented development and I feel

the document fell short in that department. Because of the link

between land use and transportation a lot more should be done

by this document. Maybe it does not have to be rewritten now,

but as time goes on more effort needs to be put in providing

some kind of model, some kind of paradigms for jurisdictions to

take a look at so they can accomplish what SB 375 and this

document is trying to accomplish.

Comment noted. SCAG curren

for monitoring implementatio

scale. Those include periodic 

local profiles, Performance M

Program, periodic household 

update. SCAG will consider fu

program for the RTP/SCS in co

203‐02 Ezequiel

Gutierrez

There is a new book that came out by Ron Altoon, LA Architect,

called “Urban Transformation, Transit Oriented Development,

Comment noted.
462

ID Name Affiliation Comment Re

and the Sustainable City”. The book cites about a half dozen

different transit orient forms. For example the TOD that

everyone is familiar with but also Transit Adjacent Development

(TAD). I think SCAG could be a tremendous service to its

jurisdictions if it provides that sort of thing. It should be

integrated into this document so that when member

jurisdictions look at the document they have some guidance

from SCAG on the different possibilities, the different types of

these transit area projects that they could take a look at and

perhaps engage in some correspondence with SCAG Staff so

that is accomplished. AB 32 and SB 375 is calling for more than

just a plan and I think that by providing guidance, models,

paradigms of transit oriented stations, a lot could be done to

move the goals of this legislation forward.

204‐01 Gerardo

Hinojosa

I have reviewed most of the content of the environmental

impact report and wish to state my comments. Removing big rig

traffic from our already congested freeways near the harbor

and 710 corridor is a fantastic plan. I dread traveling on the 710

freeway knowing the big rigs will hinder the efficient flow of

traffic. I feel unsafe every time I travel through the corridor on

my way to do business in Long Beach. The action of vehicle

drivers darting in and out of traffic lanes in order to avoid the

big rigs creates unsafe conditions. The plan should go further. I

believe big rig traffic should be kept on the outskirts of highly

populated areas. Why not have an underground subway type

system which will move freight containers on rails to various big

rig collection/distribution points throughout southern

California. Freight is unloaded from the ships, placed on transit

units, which are then sent through the underground rail system.

The underground rail system can be powered by electricity to

minimize the fume accumulation within the tunnel system.

Freight to be consumed is moved away from the port, freight

for export would move back towards the port. The new

collection points can be near existing rail yards for freight to be

distributed across the country. Some of the freight has shelf life

issues, so the shorter in transit time the fresher the product will

arrive at its intended destination. An underground system

would provide jobs for tradesmen. I do not have to go any

further with this. Californians need jobs.

Comment noted. Increased sa

the 2012 RTP, especially with 

separation of trucks and pass

opportunity to reduce accide

Local, regional, and state part

stakeholders from both the p

worked closely together over 

implement potential solution

freight movement in Souther

included the consideration of 

analysis to date have indicate

used by clean trucks (i.e., nea

promising solution to regiona

SCAG anticipates further anal

including evaluation of a wide 

application to such a system. 

evaluation would be made ab

segmentation, first‐mile/last‐

collaboration with regional st

Bay Ports), and costs among o

dialogue with stakeholders an

identify potential solutions to 

205‐01 Gerry Lease Dear Mr. Lieb (and Committee members who may be involved Comment noted. Local, regio
463

ID Name Affiliation Comment Re

in this undertaking): I have thoroughly read and am opposed to

your Comprehensive Regional Goods Movement Plan. I do not

believe the truck‐only lanes you are recommending to be a

effective way of handling this issue. Have you given

consideration to moving freight underground? It would be much

cleaner, and would save our roads, to say nothing of how it

would help traffic bottlenecks. Car pool lanes have not proven

to be an effective solution for Southern California's freeway

traffic problem. Suggesting truck only lanes as a better way to

address traffic issues on Southern California highways is not

forward thinking in this century and would not do the trick. If

you feel strongly that it would, then incorporating electric

power should be required in order to eliminate the pollution

from the trucks. However, you still have the issue of the wear

and tear on the roads! I truly believe an underground freight

movement system would be the most effective and GREEN. I

have recently seen a presentation to build a goods‐movement

pipeline system underground to and from the port, that would

allow for automated fright delivery and be cost‐effective. That

route could include the corridor you describe in your

transportation plan. For Southern California, this makes all the

sense in the world to me. We are saturated with cars, trucks,

motorhomes and countless other vehicles on our freeways in

Southern California. I believe you can come up with a much

more viable goods‐movement solution than the one you

currently propose. UNDERGROUND gets my vote. Kind regards,

Gerry Lease

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten

resulting from freight movem

efforts have included the con

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing markeissues, operational feasibility, 

stakeholders (such as the San 

among others. SCAG will cont

stakeholders and transportat

solutions to regional freight c

emissions from freight activit

2012 RTP advances strategies 

emission technologies to truc

advanced technology options 

206‐01 Ghassan

Roumani

The Plan as indicated by the SCS City maps, will denigrate the

quality of life for the residents of San Marino. My comments

regarding the 2012‐2035 RTP are limited to where I live, Oak

Knoll Avenue in San Marino, and the adjacent area. While

reviewing the Resources> SCS Map Tool from the SCAG web

site, I was shocked to discover that Oak Knoll Avenue in San

Marino has been designated a High Quality Transit Corridor.

Oak Knoll Avenue is a 72 feet narrow, two lane street fronted

exclusively by single family homes where children live and play.

The homes, built between 1920 and 1950, and the set back is

close to the street. The posted speed limit is 30 mph, the posted

weight limit is three tons, and truck traffic is prohibited. The City

of San Marino General Plan classifies Oak Knoll Avenue as a

Comment noted. Under SB 37

must meet in order to be des

Area (HQTA) or High Quality T

Public Resources Code Sectio

must be offered with certain 

periods. Although your street 

mean there will be transit ser

be available on adjacent stree

the criteria for HQTAs and ma

your street is a viable transit 
464

ID Name Affiliation Comment Re

residential collector street. The street carries an unusually high

volume of cut‐through traffic, exceeding the capacity of a two

lane residential street. How then, was Oak Knoll Avenue

designated a HQTC? As Stephanie Johnson mentioned in her

email directed to you dated February 11, 2012 regarding Los

Robles the same applies to Oak Knoll Avenue in San Marino.

Oak Knoll Avenue does not meet the definition of HQTC.

Regional traffic should not be directed toward Oak Knoll

Avenue, exacerbating the existing cut‐through traffic and its

resulting negative impacts upon the residents.

207‐01 Glenn Bailey Looking at the numbers, I do not see the real game changing

commitment. You are talking about State Legislation, Climate

Change, etc. when you are putting in 6 billion dollars, which

sounds like a lot of money for active transportation, but that is

both bicycling and pedestrian and yet your total overall

investment is 525 billion, that is just a little over one percent. If

you look at the mode share for cycling and pedestrian, it is

already above that now. If you goal is to make it even more, you

should at least put in ten percent of the money for bicycle and

pedestrian efforts. This could include some of the issues such as

sidewalk repair but there are many other things that we should

be looking at. One of the things that I thought SCAG was

supposed to function as which was an overall umbrella

organization coordinating the various public agencies, cities,

and counties throughout the region, I think you have some work

to do. For example, the City of Los Angeles has a bicycle plan

that was adopted March last year and the County of Los Angeles

has a bicycle plan that is going to the Board of Supervisors later

this month. And yet, in the Counties plan they have designated

various flood control rights‐of‐way for part of the network

throughout the San Fernando Valley. They are saying it is part of

their network and yet they did not have one of their public

hearings in the San Fernando Valley, saying because it is part of

the incorporated City of Los Angeles, not part of the

unincorporated County of Los Angeles. How can they truly get

public feedback and integration of plans if they do not have a

meeting represents 1.4 million people.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

207‐02 Glenn Bailey Another example is Topanga Canyon Boulevards, which

happens to be a state highway at the westerly edge of Los

Angeles County, and yet is the only link between the City of Los

Comment noted.
465

ID Name Affiliation Comment Re

Angeles, County of Los Angeles, and Simi Valley and Ventura

County for cyclist to be able to get there. Although Topanga

Canyon Boulevard was in the 1997 and the current 2010 RTP for

bicycle lanes on Topanga Canyon Boulevard, when Caltrans

approached the City of Los Angeles saying we are going repave

and redesign Topanga Canyon Boulevard so we can implement

your Plan, the City said no. Now it is a six lane highway up to

Parthenia Street with more to come up to the 118 without any

public notice. The connectivity between City of LA and LA

County and Simi Valley and Ventura County, has not improved

for the last forty years. You cannot ride on the 118 freeway it is

a highway that was built in the early 1900’s, curvy and narrow.

So, this is a lack of coordination, a lack of commitment that I

hope that part of this plan will change.

207‐03 Glenn Bailey The Orange Line Bus Rapid transit facility, I understand that

there is a grant that SCAG was part of that with regards to doing

sustainability within a half mile of each of the stations along the

Orange Line, this is a half‐mile radius. It is inadequate to be

looking at the real potential for getting folks to and from transit

and sustainable, which is what this grant is about, by not going

out four‐five plus miles. This needs to be quantified and very

specific in all of the documents. See how the younger

generation is getting around in Hollywood. There are sometimes

in the day, at some intersections, that the bicycles outnumber

the vehicles. If you really want to get ahead of the curve and

accommodate the younger generation, do it in this Plan.

Comment noted. The RTP is s

in Active Transportation facili

208‐01 Greg Adams Page 5: Kudos on your recognition of the problems associated

with “first mile/last mile” logistics. In and of itself this aspect of

a travel decision can be so expensive and burdensome that a

well‐meaning commuter must choose to drive the entire route

despite public transportation availability along most of the

route. I suggest you expand on this aspect of the plan. More

bike racks on buses may not cut it; local shuttles by cities and

park and ride pool vehicles to transportation hubs might help.

Comment noted.

208‐02 Greg Adams Page 7: I may have missed it but “Nominal dollars” in Table 2

(and in many other locations of the document) should be

defined early in the report.

Comment noted. Nominal do

dollars and is defined in the P

208‐03 Greg Adams Page 12: Increasingly today one hears very inflated claims about

job creation resulting from a particular project which are largely

unsubstantiated. Perhaps there should be a down‐to‐earth ,

Comment noted.
466

ID Name Affiliation Comment Re

simplified discussion of what is to unfold jobwise, not relying on

REMI algorithms but a common sense explanation of why

150,000‐180,000 jobs per year will be created ( and presumably

sustained)as a result of the RTP implementation. Please avoid

what has occurred in the world of green technology, for

example. If one were to total all the job creation claims from all

the alternatives seeking funding, there would be no

unemployment in the United States. The role of lower

education levels on the created jobs in the region needs more

explanation.

208‐04 Greg Adams Page 24: More explanation is needed as to the long term trend

of declining commute trip carpool rates. It seems

counterintuitive especially lately given rising gasoline prices.

Does this corroborate with rideshare data reported to the

SCAQMD?

Comment noted. The long ter

American Community Survey

impacted by the recession an

fluctuations in gasoline prices 

requires carpool reporting as 

commute reduction program 

single site. Participation in th

on‐site emission reduction st

208‐05 Greg Adams Page 25 and 28: Improved fuel efficiency, alternative‐fuel

vehicle penetration, lack of inflation adjustors‐all have

contributed to gas tax shortfalls. Passenger vehicles becoming

increasingly cleaner have diminished the benefits of reduced

vehicle use and congestion management strategies thereby

making conformity determinations more difficult. Both of these

areas may be worthy of pursuing changes to the federal Clean

Air Act or at least the regulations implementing the provisions

of the Clean Air Act. This, added to the statement on Page 29

that emissions forecasted from just three sources‐ships, trains

and aircraft (“federal sources”) that alone would lead to ozone

levels near the federal standard, might be additional

ammunition and support for selective changes to the CAA.

Comment noted. SCAG works 

and other air districts in the S

and related issues associated 

208‐06 Greg Adams Page 40‐ Transportation Demand Management: First mile/last

mile strategies need more discussion per my remarks on Page 5

above.

Comment noted. The Transpo

Appendix describes first mile/

detail.

208‐07 Greg Adams Page 41‐Congestion Management System: Non‐recurring

congestion accounts for almost 50 percent of all congestion on

our roadway system. One suggestion is for SCAG to strike an

agreement with CalTrans prohibiting road repair contracts from

proceeding during daylight hours where the work of repair can

cause enormous traffic jams. This past Sunday, on the I‐10

Comment noted. SCAG's Cong

describes strategies for reduc
467

ID Name Affiliation Comment Re

freeway heading west into Banning, traffic was delayed 3 full

hours, backing up all the way to Whitewater, for very minor

road repairs that caused two of the four lanes to be cordoned

off. Highway Patrol did not appear until an hour and a half into

the action which suggests there might be better coordination of

their activities from a congestion management standpoint.

208‐08 Greg Adams Page 43‐Corridor System Management Plans: Enhanced incident

management must include the above recommendation. The

California Highway Patrol (CHP) and CalTrans need to better

coordinate. In the case of accidents, the CHP needs to develop

expedited procedures and physical screening techniques to

minimize the impacts of rubbernecking and the slowdowns that

result.

Comment noted. The Conges

describes the use of Transpor

coordinating the response to 

of non‐recurring congestion.

208‐09 Greg Adams Pages 51 and 53‐Passenger and High‐Speed Rail: The SCAG

planning region will not be connected to the HSR network until

2033, 23 years into this plan. The HSR Authority’s 2009 Business

Plan posits that passengers will travel between Los Angeles and

San Francisco in less than three hours, for about 80% of

comparable airfare. Given that first mile/last mile

considerations also exist, why would one choose such a means

of travel? Do I presume correctly that the 80% airfare figure is

the one‐way plane fare in the 2033 timeframe? Given the

astronomical cost of the project, might not those resources be

better employed on more local and cheaper alternatives such as

in‐city rapid rail?

Comment noted. The commu

and intercity passenger rail p

2012 RTP/SCS were selected 

Subcommittee of the Transpo

forwarded to the Transportat

Council for inclusion as fiscall

2012 RTP/SCS. The selected p

by the jointly by SCAG’s Policy 

Council. The financial and pro

the California High Speed Rai

Plan are not considered in the 

the business plan is a resourc

the presence of new project d

plan, such as the blended app

208‐10 Greg Adams Page 71‐Regional Clean Freight Corridor System: While truck‐

only lanes handling 58,000‐70,000 trucks per day would be a

challenge of the highest degree to implement, non‐freeway

alignments handling the same traffic flow would be an even

greater hurdle, even with 100% ZEVs.

Comment noted.

208‐11 Greg Adams Page 86‐The economic Outlook: The inability of existing excise

taxes to keep pace with increasing transportation needs and the

detrimental effects of increasing fuel economy on traditional

revenue sources needs to be the primary focus of a SCAG

lobbying effort in Congress at least to escalate the excise tax at

the CPI rate.

Comment noted.

208‐12 Greg Adams Page 105‐ The plan’s goal to seek to change the region from

being known worldwide as the “capital of sprawl” results in a

Comment noted. The elimina

jurisdictions' ability to finance 
468

ID Name Affiliation Comment Re

“densification” of the existing inner cities, to my way of

thinking. Associated with that densification are costly

infrastructure changes. Has a cost analysis of this consequence

been performed? It is very difficult, as you are well aware, to

plan for such effects of densification given the countering

aspects of the recent RDA court decision and the re‐distribution

of funds to the cities that will result.

intended to support the polic

continue to identify funding r

pursuing such policies.

The RTP/SCS did not provide 

infrastructure costs from den

costs and investments. Nonet

were also provided to regiona

Sanitation District where imp

raised here will be assessed.

208‐13 Greg Adams Page 123‐Changing Demographics and Housing Market Demand

The impacts of the recent RDA decision should be addressed in

this chapter, even if the results are somewhat speculative. SB

375 combines transportation and housing planning by

integrating the Regional Housing Needs Assessment (RHNA)

process with the RTP/SCS. How will this nexus be impacted by

the RDA decision? Would the example communities that areillustrated on pages 126 and 138, for example, been

constructed in the first place without RDA assistance?

Comment noted. The elimina

jurisdictions' ability to finance 

intended to support the polic

continue to identify funding r

pursuing such policies. The Fi

updated, as appropriate.

RHNA will not be affected by 

208‐14 Greg Adams Page 173‐ Table 5.3‐ Total Employment Impact Please provide

an explanation as to how goods movement, logistics and

distribution will be impacted by an expanded Panama Canal and

a shift of some traffic to the Gulf Coast ports of the United

States.

Comment noted. The expans

the potential for diversion of 

Pedro Bay Ports. This diversio

regional goods movement sys

However, the potential level 

this time. SCAG continues to 

stakeholders to reduce freigh

reliability of goods movemen

regarding cargo diversion as a 

increase global competitivene

209‐01 Hank Fung Land use: Part of historic resources is also recognizing the land

use impacts of denser development on historic residential and

commercial districts. The SCAG region has several commercial

and residential neighborhoods which are on the National

Register of Historic Places. Many of these districts are near

transit‐friendly areas which are slated for denser development

under the RTP. In the development approval process, local

jurisdictions should recognize those impacts and mitigate

appropriately. SCAG correctly notes that revitalizing traditional

downtowns has the greatest potential for accommodating

growth in all communities in Southern California, but it should

be done in a sensitive manner. As a result of increased land

Comment noted. The actions 

Chapter 4 of the 2012‐2035 R

components of livable streets

SCAG's land use and transpor

bicycling and pedestrian infra

neighborhoods, and transit ac

provide a regional strategy th

if they so choose, and genera

growth projections from each 

going forward, local jurisdicti

authority.
469

ID Name Affiliation Comment Re

prices and expansion in average space per person (i.e. families

in which children used to share bedrooms now each having

their own room), exurban and 2000’s suburban developments

are often more dense (less green space, more units per acre)

than suburban developments in the 1950’s, 1960’s, and 1970’s.

This is a naturally occurring trend, but the problem is that these

types of development are now placed in areas with poor transit

service, thus increasing traffic demand. Conversely street design

of the 1950’s and beyond, focusing traffic on arterials (i.e. the

half mile square street grid in Northern and Central Orange

County) discourages pedestrian and bicycle usage. Through

livable streets policies, SCAG should encourage design that is

more neighborhood friendly and helps to spread out traffic

instead of concentrating it in a few areas.

209‐02 Hank Fung Transit quality: The definition of “high quality transit area” is

extremely broad. Areas around park and ride lots in the suburbs

with four buses an hour, two or three hours a day and no other

service qualify. For example, Foothill Transit operates frequent

commuter express service to traditional suburban areas, but

only during peak hours. This policy could lead to the

development of dense Planned Unit Development and

condominium tracts, but with no appropriate transit service

outside of bus service to a downtown area, where most

residents do not work. SCAG should refine the definition, or

create a new criterion, to reflect true quality service. Such a

service would allow individuals to make most day‐to‐day trips,

not just peak hour trips to work, via means other than individual

passenger vehicles. “High quality transit” includes midday and

weekend service, evening service for service workers to get

home and for residents to enjoy a dinner and a movie, and

should provide connections to multiple destinations instead of

just a CBD. Otherwise any development near a park and ride lot

could qualify as a HQTA and be exempt under SB 375, despite

the number of trips generated therein. Although SCAG has no

power to do so, it should encourage transit agencies to relax

efficiency criteria to encourage provision of off‐peak service.

Often evening and weekend service is cut because it is not as

cost effective as peak service, yet reduction of these services

results in people purchasing cars and dropping off of transit use

altogether. While no one is suggesting operation of empty

Comment noted. “High Qualit

defined by Senate Bill 375, th

Climate Protection Act of 200

preparation of a Sustainable C

2012 RTP/SCS. California Pub

defines a “high quality transit 

route bus service with service 

minutes during peak commut

Resources Code Section 2106

containing an existing rail tra

by either a bus or rail transit s

or more major bus routes wit

15 minutes or less during the 

periods. SCAG has a statutory 

definitions.The elimination of RDAs may 

finance various local plans an

policies in the 2012 RTP/SCS. 

funding resources for local go

The RTP/SCS did not provide 

infrastructure costs from den

costs and investments. Nonet

were also provided to regiona

Sanitation District where imp

raised here will be assessed.
470

ID Name Affiliation Comment Re

buses, we should not penalize agencies for operating lifeline

night and weekend service either. Improving span of service, as

described in Page 49, should be more of a key. Also

consideration needs to be given to fare policy. The San Diego

Association of Governments (SANDAG) recently obtained fare

setting policy for its jurisdiction, because it recognizes the

connection between appropriate transit fares and its regional

planning goals. All fare changes must go through the SANDAG

board. Although SCAG may not wish to usurp the roles of the

local transit operators like SANDAG did, it should recognize that

appropriately set fares can increase transit ridership while still

being fair to the taxpayer.

209‐03 Hank Fung One way to do this is through implementation of a regional

smart card. Although in need of improvement, the LA County

MTA’s TAP program has significant potential and could serve as

a basis for a region‐wide fare card, similar to ones in

Washington DC, Seattle, and the San Francisco Bay Area.

Business rules should be revised so transfers with a smart card

are automatically provided. Such a card could eliminate the

need to remember multiple fares or to carry multiple passes for

inter‐county travelers. The SCAG region should not make the

same mistake as 511, in where San Bernardino and Riverside

Counties have a different 511 system from Los Angeles and

Orange Counties.

Comment noted. Implementa

identified as FTIP ID LA0G203

Additional fare media integra

addressed by individual trans

inclusion in future Regional T

submittal lists of relevant Cou

209‐04 Hank Fung Road Pricing: In the past, a vehicle mileage tax (VMT) has been

very controversial. It also discourages adoption of more fuel

efficient vehicles, although arguably as fuel prices go up that

incentive is provided anyway. A consideration could be made to

freeze the existing gas tax at the current level, while imposing a

VMT – but the VMT would have to go into real projects instead

of just in a “black hole” general fund. The existing gas tax is not

enough for operations and maintenance of existing highway

facilities. Therefore, all new capacity should be tolled or

otherwise have a funding source for maintenance that is

corridor‐specific.

Comment noted.The mileage

RTP would be enacted by Con

would be dedicated to transp

state or federal general fund 

resources are needed for ope

ensure a state of good repair

209‐05 Hank Fung Strategic Plan: Unfunded capital improvements: Caltrans has

declared that SR‐39 through the San Gabriel Mountains from

the Azusa city limits to SR‐2 is excess and has asked the County

of Los Angeles or the United States Forest Service to take over

the roadway. Recently the San Gabriel Valley COG indicated that

Comment noted. The RTP/SC

in part on Los Angeles County 

Plan Strategic Plan. We have 

that there is no double‐count

project lists.
471

ID Name Affiliation Comment Re

the extension of SR‐39 through the San Gabriel Mountains to

connect to SR‐2 should be reconsidered. Although there would

need to be significant mitigation for the Bighorn Sheep, this

extension could provide significant benefit in improving access

to recreation and for emergency response and evacuation.

More importantly, the costs and benefits of this project have

never been debated in a public forum with decision makers. The

SR‐39 extension from Crystal Lake to SR‐2 should be added in

the Strategic Plan for possible future funding eligibility. While

reviewing the Strategic Plan project list, it appears that some of

the projects in that list were already funded or are no longer

being considered. For example, the SR‐126/Commerce Center

Drive grade separation project is funded. Parts of the Colima

Road project have already been implemented or have been

funded through the MTA Call for Projects, or are included in the

FTIP or RTP plan. The Fullerton Road under UPRR is part of the

ACE Phase II program. SCAG should work to verify that this list is

current prior to RTP adoption and is not double counting

projects.

210‐01 Hank Fung With regard to freight movement strategies, in the past SCAG

has considered making the truck only lanes “green lanes” for

clean fuel and low emission trucks. This should be considered in

any studies. Also, electrification of freight rail, while currently

not funded in the short term, is a strategic long term

improvement that should be strongly considered for

implementation. This has the potential of eliminating a

significant amount of emissions from diesel locomotives.

Implementation of “inland ports” with freight rail connections

to truck facilities in the Antelope Valley and the Inland Empire

have a potential of bringing jobs into these economically hard

hit areas.

Comment noted. Research an

that a regional truck‐lane syst

near‐zero and zero‐emission) 

regional freight concerns. Thi

Nevertheless, SCAG anticipat

concepts including evaluation 

options for application to suc

is not part of the constrained 

RTP, SCAG will work with regi

applicability for the region. Th

construct an electrified rail sy

of both railroads (Union Pacif

Fe Railway). Recent studies b

Ports indicate that a number 

inland ports. The long term d

facilities is unknown and dep

such as market development, 

210‐02 Hank Fung [PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

211‐01 Harvey Liss I have an extremely important issue that affects air quality

probably more than any other, and I don’t know how to have it

Comment noted. The RTP/SC

through 2035 towards Transp
472

ID Name Affiliation Comment Re

considered. Only today, I became aware of the RTP review

process and the meeting on Tuesday at the SCAG main office, at

noon, from an email from Supervisor Pat Bates, and a deadline

for public comment seems to have passed without my being

aware of it. The issue concerns synchronization of traffic signals.

There are hundreds of millions of dollars that have been spent

and that will be spent, in theory, to synchronize traffic signals

from Measure M funds (the Project P arterial synchronization

projects). After a year of effort working with the City of Irvine,

and doing other research on the matter, I made a horrible

discovery, and that is that when a city (like Irvine) claims that it

is synchronizing signals with Project P funds distributed by

OCTA, they can end up only being synchronized for 5 hours/day;

that is, only during the AM and PM rush hours, rather than all

day. I interviewed city traffic engineers from two other Orange

County cities and got very varying times of synchronization for

their respective cities. OCTA, itself, on its website states: “The

synchronization system is usually activated during morning and

evening peak traffic hours...” Hence, when a city claims it is

using Project P funds to synchronize signals, it could be mostly

misleading, and I can explain why synchronization is often done

in such a limited fashion. By contrast, the city of Austin, TX,

synchronizes its signals from 6am to 11pm, and that only since

2005, because they have an activist city traffic engineer (with

whom I’ve chatted) that truly wanted to do things right! This is

the way it should be done. Here, again, I can explain what he

had to overcome to make this happen. Synchronizing traffic

signals the way it’s done in Austin would probably have a bigger

reduction of air pollution than any other policy change in

Southern California. How can I get this issue turned into a

mandate of the RTP? How do I begin? Who can I talk to?

strategies, including traffic sig

synchronization programs are 

and local jurisdictions.

211‐02 Harvey Liss I’m certainly willing to come to LA on Tuesday to speak during

the public comments period if I had some assurance that I

would have an opportunity to speak; however, from reading the

rules (total time of public comment limited to 20 minutes), it

appears that I would likely have no opportunity to speak. And I

have no idea what time I can show up to fill out a public

comment card to assure that I would be in line early enough to

get to speak, or if everyone is given an opportunity to speak,

that I would have more than 15 seconds. This is a link to an OC

Comment noted. The RTP/SC

through 2035 towards Transp

strategies, including traffic sig
473

ID Name Affiliation Comment Re

Register article about the work I recently completed with the

City of Irvine: http://www.ocregister.com/news/city‐327277‐

liss‐traffic.html Is it too late to do anything about this? Do we all

suffer another 4 years of incredible air pollution and wasted

hundreds of millions of dollars, unnecessarily? Please help.

212‐01 Irene

Rauschenberger

Re: The vision for the 2012 RTP/SCS ‐ As a native Oxnard

resident and layperson, I wish respond to the Ventura County

Star 2/12/12 commentary on the transportation plan.

(Columnist, Hasan Ikhrata) I’m particularly interested in the

principle of mobility, it's impact on sustainability. As I see it,

there is a great need for more bike routes and pedestrian

spaces in the City of Oxnard where I live, albeit the need is

important in all cities, and full filling this need would be a

positive impact on our clean air and open spaces. In short, a

designated class I/II bike route connecting Ojai, Ventura, Oxnard

and Malibu would demonstrate mobility and sustainability

profoundly! Ojai already has a class I bike route adjacent to

HWY 33, Ventura has good bike paths on the beach that could

be connected to Oxnard’s scenic Harbor Blvd. to Wooley Rd. run

east adjacent or in place of the RR track (that is idle) then west

adjacent to Ventura Rd. there are huge drains that could be

covered into bike paths, continue east on Channel Islands to “J”

street west (another huge drain project currently under review)

to connect to Hueneme Road, then head east towards Ormand

Wetlands, and the PCH HWY to Malibu! Connections that would

be the pride of Ventura County and a much needed mobile

infrastructure. Respectfully... Resident of Oxnard

Comment noted.

213‐01 Jaemi Jackson In the Active Trans page 25, Tables 6 & 8 are exactly the same. Comment noted. The tables h214‐01 James Fujita I want to see the TAP card added to Metrolink. The TAP card has

the potential to be for Southern California what SUICA is for

Central Japan — one single, simple to use electronic and online

fare payment system for an entire region. There is no reason —

except for bureaucratic bickering — why the same card can't be

used in Los Angeles, Orange County and other areas.

Comment noted. Implementa

identified as FTIP ID LA0G203

Additional fare media integra

addressed by individual trans

future Regional Transportatio

the relevant county transport

215‐01 Jason Herring I am strongly opposed to solving regional transport planning

through more freeway expansion. The current RTP focuses too

much on legacy transportation modes and not enough towards

forward‐looking solutions to our congestion problems. Living in

the Port area I am very interested in proposed direct‐to‐rail

technologies such as the GRID SuperDock, which would create a

Comment noted. Local, regio

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten

resulting from freight movem

efforts have included the con
474

ID Name Affiliation Comment Re

freight tunnel from the port to inland warehousing and

intermodal areas. Please consider this more forward looking

concept in your planning.

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing marke

issues, operational feasibility, 

stakeholders (such as the San 

among others. SCAG will cont

stakeholders and transportat

solutions to regional freight c

216‐01 Jennifer

Anderson

Nice Delphi comment form. I am aware of what you criminals

are trying to do and you can forget it. There will be no agenda

21 in Southern California, no tax increases, no wildlands. I am a

homeowner and I vote, and I am telling all of my neighbors and

handing out information. Furthermore, I intend to see to it that

those engaged in this subversive land grab are tried for treason

against the United States. If you think you can get away with

surreptitiously introducing the UN Agenda, you have got

another thing coming. I will find out the names of the people

responsible for this and publicize them as widely as possible. No

passing the buck, each and every one of you.

Comment noted.

217‐01 Jenny Wilder In order to get into the 21st century and deal with the ever

increasing population and transportation problems, it is

necessary to provide some real transit alternatives to one

person per car. This means that a more proportionate share of

the available funds must be spent on transit needs and not on

creating new freeways/roads. Please don't fall into the trap of

spending transit funds on items that are NOT public transit. I

live in Apple Valley and there are currently NO alternatives!

There is a great need for metro link to San Bernardino, Rancho

Cucamonga and Palmdale. The fact that the Cajun Pass is "too

steep" is ridiculous and the High Desert Corridor as an

alternative for people and goods between San Bernardino or

even Los Angeles via Palmdale is incomprehensible. There are

already a number of freight trains going up and down the Cajun

Pass, but only one passenger train. We need regular transport

service to connect to the metro system in the Inland Empire‐ 

Comment noted. Transit serv

the 2012 RTP/SCS as RTP ID#7

Service.
475

ID Name Affiliation Comment Re

especially if the government envisions even more growth in the

High Desert.

217‐02 Jenny Wilder There is a great need for HOV lanes on the I‐15 from Victorville

to San Bernardino and Rancho Cucamonga, to the I‐215 and I‐

210. Roads such as Bear Valley Road and Hwy 18 through the

community must get a makeover. First, provide a free shuttle to

get up and down the roads. Must be regular and frequent

(every 30 minutes ‐ stores can help fund this). Next: work on

makiing the entry and exit of the main road limited by providing

access to shopping from parallel streets behind the current

shopping centers.

Comment noted. The RTP/SC

Victorville to the Riverside Co

street improvements to Bear 

jurisdictions are responsible f

environmental review, and im

217‐03 Jenny Wilder Do not allow changes of zoning along the main roads such as

Bear Valley Road that will increase traffic before making

accommodation for that traffic or alternatives (e.g., a super

Walmart outside Spring Valley Lake).

Comment noted. Local land u

amendments, remains with lo

217‐04 Jenny Wilder Look at providing more walking and bicycling alternatives for

short trips or to enhance transit options. A walking/bicycling

path all along the Mojave River is a must. Provide bridges

dedicated to walking/bicycling over the Mojave River and

railway ‐ especially to access the Community College.

Meanwhile, reduce the speed over the current bridges to

provide better safety for pedestrians and bicycles.

Comment noted. One of the p

Transportation Component o

increase bikeways in the regio

over 10,000 miles.

217‐05 Jenny Wilder Avoid sprawl developments (especially those which require a

zone change) and encourage "in fill" developments that

promote walking and bicycling.

Comment noted. Local land u

amendments, remains with lo

RTP/SCS focuses future housi

Quality Transit Areas (HQTA), 

more compact, mixed‐use de

opportunities for walking and 

shorter auto trips.

217‐06 Jenny Wilder Decrease the speed limit and provide traffic calming devices

along Apple Valley Road near the 55+ community and in other

areas with elderly residents. Provide bicycle/neighbor

electric/handicap scooter facilities in and around these

communities.

Comment noted. As stated in 

of 2008 (AB 1358) requires cit

the concept of Complete Stre

ensure that transportation pl

our roadway system. SCAG su

implementation of Complete 

SCAG will work with the local 

Complete Streets strategies w

providing information and res

activities.
476

ID Name Affiliation Comment Re

217‐07 Jenny Wilder The weather is great in the High Desert for walking and

bicycling. Thank you for the opportunity to comment.

Comment noted.

218‐01 Joe Portera We need to invest in safer crosswalks and bikelanes, especially

crosswalks by schools.

Comment noted. The Active T

Goal 3: Increase Active Trans

Region by Adopting a Safe Ro

219‐01 John Bednarski I have been a resident of the San Gabriel valley for nearly 30

years, most recently living in Altadena for more than 20 years. I

want to take this opportunity to voice my support for SCAG's

plans to close the 710 Gap. Closure of this transportation gap

will speed commuting for those of us that use that surface route

on a regular basis, improve safety for those communities that

presently are subjected to surface traffic up and down

Freemont and Pasadena Avenues, and lessen air pollution as

there will be fewer idling cars stuck in traffic jams as they slowly

move through Alhambra, South Pasadena and Pasadena. While

there has been noisy criticism of the 710 Gap closure from

selected communities in the area, I do not believe that these

communities necessarily speak for the thousands of private

citizens like myself that support the Gap closure. I also suggest

that SCAG look at aggressively moving up the schedule for the

Gap closure. Right now, the program is scheduled to be

completed in 2030. I firmly believe that schedule can be

advance at least 5 years earlier, and a 2025 completion of the

Gap closure is viable. How can this be done? I understand that a

3 year environmental assessment process is underway. During

this time, conceptual design should be started on a variety of

options, including the most obvious/logical option, the tunnel

beneath South Pasadena and Alhambra. As soon as a Record of

Decision is issued on the program, preliminary design should

commence and efforts should start on gaining enabling

legislation to perform the program under a Design Build

approach (similar in fashion to what is currently being

accomplished in Seattle, WA with the Alaska Viaduct tunnel).

These activities represent about a 2 year effort. Next with the

DB approach in hand, final design can start as soon as the DB

firm is selected, and work can begin on procuring the tunnel

boring machine. Allowing a 6 year time frame for the DB

construction would then put the project on line approximately

11 years from today(roughly 2023), then add 2 years of

contingency time in the planning window, and this gives a 13

Comment noted.
477

ID Name Affiliation Comment Re

year timeframe from start to finish (2012+13=2025). This should

be easily accomplishable. Tunnel boring machine technology is

robust and relatively standard for the size of machines that will

be needed for this double‐decked bore. Mining 2 miles per year

should be easily accomplishable. I support your efforts to close

this transportation gap.

220‐01 John Bednarski Please make sure to include a fast and convenient light rail link

to LAX in your plans. The present light rail system is completely

lacking in its ability to service LAX. I could never understand why

a major city like Los Angeles could fail so badly in NOT being

able to bring light rail transportation right into LAX. I would

suggest that every major city in the USA has some form of direct

rail transport right to their respective major airport. Yet in Los

Angeles, this capability is sorely lacking. Those of you that make

such transit plans for the region need to solve this obvious

shortcoming and hopefully your solution provides a

methodology for smooth and efficient travel‐by‐rail to LAX from

numerous locations, like downtown Los Angeles. Thank you for

this opportunity to comment.

Comment noted. This corrido

1TR0101, the Metro Rail Gree

221‐01 John Bonilla Mr. Jacob Lieb, I found my way to the Regional Transportation

Plan while looking for emission reduction information. The

South Coast Air Quality Management District Technology

Symposium had information for import goods container

movement emission reduction; the Green Rail Intelligent

Development Project which made quite an impression upon me.

While looking further into this plan I found information about

the fully electrified rail running underground most of the time in

massive pipelines which further impressed me and with the

Angeles Chapter of the Sierra Club support of that project, it

added to my opinion that this plan is very much worth

considering. While looking into available information for that

plan I found my way to the Regional Transportation Plan but

was very surprised that the Regional Goods Movement System

had information for the Potential East West Freight Corridor but

did not include the possibility of considering the Green Rail

Intelligent Development project or to place the East West

Freight Corridor underground. I hope my comment to include

the Green Rail Intelligent Development Project as a possibility in

the final Transportation Plan as an alternate to the above

ground Corridor is given additional consideration. I’m highly

Comment noted. Local, regio

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten

resulting from freight movem

efforts have included the con

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing marke

issues, operational feasibility, 

stakeholders (such as the San 

among others. SCAG will cont

stakeholders and transportat

potential solutions to regiona

advances strategies for apply

technologies to truck lanes an
478

ID Name Affiliation Comment Re

impressed by the underground plan and feel that though the

main concern is pollution in our air a strong secondary concern

should be the visual, auditory and traffic impacts that could be

avoided by having underground transportation rails. It’s also my

belief that while any plan would take a long time to complete,

implementation of an underground system would help limit

traffic impact during construction and avoid using land space

that could in the future be used for other improvements. Thank

you, John Bonilla

technology options for rail.

222‐01 John Longville I am amazed at how much testimony has been submitted, from

one person after another, urging us to devote more resources

to something other than just single occupancy vehicles. It is very

clear from the testimony that is being presented that the

people are in front of us. This is indicated as well by the polling

that has been done. Move LA recently brought in a survey that

indicated the amount to which the public would like to see us

doing more for transit, bicycles, and pedestrian facilities. I hope

that as the final stages of this process wrap up that SCAG will be

able to accommodate some of these wishes in the shifts that

will take place.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

222‐02 John Longville Thus far, there are a lot of wonderful things coming through this

process but I am not confident that we have enough realism in

addressing the financial needs for what needs to be done. Once

again our people are in front of us. Most of our counties have

adopted sales tax measures for transportation and they pass

overwhelmingly. I want to thank SCAG for the time and effort

the agency has put into the document.

Comment noted.

223‐01 Jon Portera These signatures represent just some of the children in the

Oxnard Elementary School District; actually, they are from just

one school. They were gathered by these same children during

their recess time. For me they have a significance beyond the

number 100 plus because the children responded from their

heart for the fifth grader who was killed two years ago at a

crosswalk near the school.

Tragically, it would have been such a simple matter to have

allocated more funds to have had a crossing guard on duty at an

earlier time or to have had an illuminated and sounding

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate
479

ID Name Affiliation Comment Re

crosswalk by their school. To now try to pay tribute to this

young girl's passing by creating safer crosswalks and bike lanes,

at or near school crossings, would be the most fitting act to

remember her by, an act to prevent further tragedies like this

from ocurring.

jurisdictions will be spending 

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

224‐01 Joyce Dillard The CIRCULATION ELEMENTS of the regional cities GENERAL

PLANS should be addressed as they expand to a overview of the

regional needs and has a direct relationship to land use. This will

also address the Military needs and national defense issues

which are underplayed for the region. Per the Governor’s Office

of Planning and Research “Update to the General Plan

Guidelines‐Complete Streets and the Circulation

Element:: ...circulation element shall contain objectives, policies,

principles, plan proposals, and/or standards for planning the

infrastructure to support the circulation of people, goods,

energy, water, sewage, storm drainage, and communications.

Extreme weather conditions, atmospheric rivers, fires, floods

are a concern of the Department of Water Resources and

planning for the 200‐year floodplain is reflected in AB 162 Wolk

Government Code Section 65300‐65303.4. Elements include: •

Land Use • Conservation • Safety • Housing

Comment noted.

224‐02 Joyce Dillard Also consideration should be given to HUD Coastal High Hazard

Areas and the incorporation of Protection Wetlands into

Floodplain Management in a 500‐year floodplain. Southern

California has the worse extreme weather in the country. The

CS San Bernardino Alluvial Task Force is rolling out an online/cell

phone mapping tool in the near future. This should be

employed. Remember, water vapor is a greenhouse gas.

Comment noted. The Program 

includes an analysis of floodp

Chapter. For additional resp

the 2012‐2035 RTP/SCS, Chap

the Draft PEIR.

224‐03 Joyce Dillard The Goods Movement, in the Port of Los Angeles, is not so

much about the port docks as the movement of goods to

market (Harbor Commission meeting February 2, 2012). That

connectivity is a key factor to the area receiving goods instead

of the Panama Canal and should be taken more seriously.

Comment noted. The SCAG re

gateway for containerized go

of reasons including, but not 

container port complex, a larg

system of regional roadways, 

system, an abundance of war

and geography. The infrastru

considerable advantage for tr

country. SCAG has explored p

through its studies on port an

to evaluate the impacts of the 

the SCAG region and the need 
480

ID Name Affiliation Comment Re

competitiveness.

224‐04 Joyce Dillard Aging pipelines infrastructure should be addressed at all levels

included public utilities such as Southern California Gas. There

may be black holes in jurisdiction making Public Health and

Safety an issue not addressed. CTPG California Transmission

Planning Group’s efforts in transmission delivery should be

addressed as part of Circulation.

Comment noted. The RTP/SC

utilities.

224‐05 Joyce Dillard ATBCB Pedestrian Facilities in the Public Right‐of‐Way issues will

play a role in expenditures and compliance throughout the

region as it effects productivity.

Comment noted.

224‐06 Joyce Dillard You are completely missing the expected aging population.

Critical Actions aka hospitals etc. should be analyzed with the

aging population. The LAUSD population and other school

districts are important to incorporate for a projection of the

future work force. Families, not density, is true growth.

Comment noted. SCAG uses t

projection models to develop 

school enrollment, and house

224‐07 Joyce Dillard Air Quality solutions should be addressed as test sites are

lacking to distinguish areas of non‐compliance. Though trains

may be a solution, diesel emissions and the particulates are not.

Though density appears to be a solution, digital signs and ozone

creating projects are not. We need to take seriously the extent

of non‐compliance for Particulate Matter and NOX,

grandfathered land use and realistic solutions. Mapping is

important to see where issues can be addressed and where they

cannot.

Comment noted. The RTP/SC

visualization techniques to fa

technical analyses.

224‐08 Joyce Dillard Metropolitan Water District has a business plan and those plans

should be addressed seriously as they manage water. That

business model is not about variance. Use of Rainwater

Harvesting, not a Title 22 Water, may be a larger problem if the

State Department of Public Health and the Federal EPA do not

address their responsibilities. Outbreak of disease, whether

aviary or human, would cause extreme problems in dense areas

and with public transportation.

Comment noted. The Program 

the RTP/SCS includes a chaptadditional response, please se

RTP/SCS, Chapter 4, Response

224‐09 Joyce Dillard Debt services and fees should be addressed as baseline needs

for Capital Improvements. Job growth is insufficient. Just what

industries will relocate here. Who guarantees that a Transit

Oriented District is available as a vehicles traveled reduction, if

there is no real plan and no real attraction. Your allocations are

as follows: Transit 10.41% Passenger and High‐Speed Rail

10.81% Active Transportation 1.26% Transportation Demand

Comment noted.
481

ID Name Affiliation Comment Re

Management (TDM) 0.84% Transportation Systems

Management (TSM) (includes Intelligent Transportation Systems

(ITS)) 1.42% Highways 15.15% Arterials 4.63% Goods Movement

(includes Grade Separations) 10.04% Aviation and Airport

Ground Access‐Included in modal investments Operations and

Maintenance 45.44% With Operations and Maintenance

funding included the following percentages of your allocation

are: Transit 39.60% Highways 27.03% Arterials 9.01% This is

distribution is not realistic to the existing system and does no

guarantee the growth that is needed for increased economy

and for jobs. Sustainable Communities Strategy should be a

complete overall picture.

225‐01 Joyce Dillard For the LA County region and the City of Los Angeles, in

particular, undergrounding of Utilities has not been included in

the Community Plans, nor has it been addressed in a City of Los

Angeles Circulation Element, as no such element, as required by

law, has been prepared.

Comment noted. The RTP/SC

225‐02 Joyce Dillard Project LAF3148 has not been discussed in the community

especially in light of the Public Health and Safety issues: North

Main St Grade Separation. Construct a new grade separation

over UPRR and Metrolink & LA River while preserving the

historic Main St Bridge. This is #10 in LA County on the PUC

grade separation list. Project site is located approximately 1

mile northeast of downtown Los Angeles, located on Main

Street over the Los Angeles River between Wilhart and Lamar.

North Main St. Grade Separation: Construct a new grade

separation over UPRR and Metrolink & LA River while

preserving the existing historic N. Main St. Bridge. Bike lanes will

be added at the shoulders of the bridge. Other work

components include realigning Albion Street and modifying the

intersections of North Main and Mesnager Street at the west

end.

Comment noted. This project 

project in the 2011 Federal Tr

Program (FTIP) adoption cycle 

30‐day public review and hea

received for this project.

225‐03 Joyce Dillard Project LAD0169 has not been discussed in the community:

BROADWAY IMPROVEMENTS FROM MAIN ST TO GRIFFITH ST.

Construction of missing curb & gutter and reconstruction of

Existing Pavement and undergrounding the overhead power

lines. In this low‐mod income area, please anticipate the loss of

business and reach out to the public.

Comment noted. This project 

back in the 2004 Regional Tra

Program (RTIP) and carried ov

RTIP/FTIP (2006, 2008, and 20

the 30‐day public review and 

cycles.

226‐01 Judy

Bergstresser

The SCAG PEIR / RTP is flawed in the same way as the SANDAG

RTP / EIR – they are inadequate under CEQA law. The joining

Comment noted. SCAG’s PEIR 

environmental impacts and o
482

ID Name Affiliation Comment Re

motion filed by the Attorney General of the State of California in

the lawsuit against the San Diego Association of Governments

(SANDAG) Regional Transportation Plan states that the

Environmental Impact Report (EIR) prepared for the plan does

not adequately analyze or prevent air pollution and climate

concerns, and prioritizes expanding freeways while delaying

public transit projects. The SCAG is similarly flawed and will not

stand up to CEQA challenge.

measures for consideration a

226‐02 Judy

Bergstresser

I oppose all items in the draft RTP that recommend the

expansion or extension of highways, for the following reasons:

The fundamental law of highway congestion (Anthony Downs,

1962, 2004, 1992; and confirmed most recently by Gilles

Duranton and Matthew Turner of the University of Toronto )

states that the travel speed of an expanded highway reverts to

its previous level before the capacity expansion and that the

extension of interstate highways is met with a proportional

increase in traffic in the U.S. SCAG’s assumption that highway

expansion reduces congestion and improves pollution levels is

grossly inaccurate. The traffic modeling fails to fully account for

generated and induced traffic. And therefore exaggerates the

benefits of expansion and the does not reflect the severity of

future congestion problems. The draft RTP anticipates adding

948 centerline miles and 7419 lanes miles which would be a

4.4% and 11.1% increase respectively. The SCAG RTP will

increase pollution, truck traffic, congestion, accidents, health

impacts and environmental risks throughout the Southern

California region.

Comment noted. Increase in t

condition is primarily due to e

people over the plan period. 

basis will decrease over this p

implemented. While the Plan 

highway improvements, incluproject, there is no evidence 

contribute to the total VMT in

The 2012 RTP identifies a mu

incorporates transit, highway

strategies as well as demand 

pricing strategies to achieve o

performance and reduction in 

375.

226‐03 Judy

Bergstresser

I oppose the 710 gap closure project as it is undefined and is not

eligible to be on the Constrained Plan. The proposed SR‐710

Extension Toll Tunnels, at $5.6 BILLION already underfunded by

at least 50%, must be moved from the Constrained Plan to the

Strategic Unfunded Plan in the 2012 RTP because there are no

committed, available, or reasonably available funds as required

by federal law for inclusion in the Constrained Plan. There is

enormous internal inconsistency with the SCAG’s six possible

construction zones yet all actual estimates based only the

previously defined Meridian Route alignment.

Comment noted. SCAG’s 2012 

constraint requirements set f

regulations and guidance, inc

strategies for ensuring availab

identified. See 23 CFR 450.32

in part, that the RTP includes 

demonstrating that projects i

using committed, available, o

sources. See 23 CFR 450.104. 

be funded by both core (Mea

available revenues. SCAG doc

sources identified for the SR‐

available. As such, strategies 
483

ID Name Affiliation Comment Re

implementation steps for ens

new revenues are discussed i

Appendix.

226‐04 Judy

Bergstresser

I oppose plan items in the draft RTP that recommend increased

conventional roadway and rail yard capacity for goods

movement. The RTP should instead include existing zero‐

emission goods movement alternatives. Goods movement must

be accomplished via electrified freight rail not trucks. Goods

movement proposals in the draft RTP are inconsistent with

regional, state, and federal air quality and congestion targets

stated in the plan. The plan states that to attain federal ozone

standards, the region will need broad deployment of zero and

near‐zero emission transportation technologies in the 2023 to

2035 timeframe (p.74). It also acknowledges that conventional

goods movement practices contribute to excess ozone and poor

air quality (p. 68) and negative impacts in neighboring

communities and throughout the region. However, the plan

allocates billions of dollars to expanding conventional goods

movement, saying “truck‐only freight corridors are effective as

they add capacity in congested corridors, improve truck

operations and safety.and provide a platform for the

introduction and adoption of zero‐emission technologies.” Yet

the plan does not require zero‐emission technology.

Comment noted. Emissions fr

a significant concern for the S

lane system identified in the 

facility used by zero emission 

Environmental Action Plan th

zero emission technologies in 

federal requirements. It is no

whether electrified or conven

segments generally serve diff

moving to distant areas outsi

may be able to use rail from t

final destination. However, go

local warehouses, regional m

across the international bord

utilize rail as a result of cost, 

travel time, first‐mile/last‐mi

The goods movement system 

rely on a single mode of trans

226‐05 Judy

Bergstresser

[PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

227‐01 Karen Doris

Wright

SCAG needs to INCREASE the percentage of funding spent on

Bus Transit and Bicycle pathways, lanes, stripped areas that are

WIDE enough to take us into the future 200 years and provide

for adequate ways to get to work, school, home, events, public

meetings with appropriate secure parking for bicycles near

Metrolink, Bus, and other points. Currently a significant portion

of the population in SCAG areas use public transportation, but

the dollar amount to support necessary transit is insufficient.

Say for example that 30 percent of the SCAG population relies

soley on public transit such as BUSES or bicycles or walking. Yet

less that 6 percent of the funding is spent for the transit of

these people. Furthermore their basic transportation need is

NOT MET, For example just within the City of Riverside, which is

the County Seat for the County of Riverside, citizens in one area

of the City, La Sierra and perhaps Arlanza, HAVE NO BUS ACCESS

Comment noted. The Draft RT

transit and active transportat

of the total RTP expenditures

additional funding, the region 

funding may be reasonably av

2012‐2035 RTP/SCS provides 

for all modes of transportatio

fiscal constraint requirement
484

ID Name Affiliation Comment Re

to RTA buses for about 12 a day from approximately 6:30 pm to

6:30 am. And for other areas of Riverside there is NO ACCESS TO

BUS TRANSIT from approximately 10:30 pm to 6:30 am. This

means that thousands of citizens are DENIED ESSENTIAL BASIC

TRANSPORTATION needed to get them to jobs such as jobs in

the medical field which are 24 hour jobs, to hospital and urgent

care during those hours, cannot go out for a late dinner or

show, cannot attend events in different venues in the Riverside

area and cannot attend many public meetings or attend

educational opportunities at schools, colleges, or universities

due to the limitations on bus service. On the other hand on the

ROADS/ARTERIALS/ FREEWAYS in the SCAG area those who own

cars are able to get around 24 hours a day, seven days a week.

SCAG is working to IMPROVE their driving experience by adding

to roads, lanes, etc. But what is WRONG WITH THIS PICTURE.

What is WRONG is that SCAG has DISENGAGED a SIGNIFICANT

PORTION OF THE POPULATION in the SCAG area from

opportunities to work, get educated, participate in the

democratic process and to attend the many events put on

across the SCAG counties BY DENYING THE FUNDING NEEDED

TO SUPPLY BASIC NEEDED BUS SERVICE. The lack of SCAG focus

and funding for this area impacts negatively on our air quality

by forcing citizens into their cars. For example I live right by

Magnolia in Riverside and could take the bus to the

International Film Festival, to events downtown etc but have

learned there are NO BUSES going home.

227‐02 Karen Doris

Wright

Therefore I recommend that SCAG STUDY the funding

distribution, and study the population within our area and

determine who MUST use buses and who could use buses, and

then based on that resulting percentage which I believe would

exceed 30 percent of the SCAG population, allocate that

amount of ALL FUNDS FOR ALL TRANSIT/ROADS/METROLINK

etc. and apply that percentage to improve BUS SERVICE, BUS

ROUTES, Late NIGHT and early AM SERVICE, BUS EQUIPMENT

and an advertising program to encourage everyone to ride the

bus from billionaires (and they DO RIDE THE BUS) on down and

also education them how to ride the bus, with improves

REGIONAL BUS signage, linking lines etc. Much less that 6

percent of SCAGs monies go to BUS SERVICE and it is

UNCONCIONABLE that you ignore and underfund the bus

Comment noted.
485

ID Name Affiliation Comment Re

service in favor of those with the means to buy a car. Educated,

Many people all over the World ride buses in urban areas and to

get back and forth from suburban areas. That includes

Cambridge and London England, Paris France, New York NY,

New Jersey, Toronto, San Francisco and the broader San

Francisco Bay areas and the approx nine Counties. I personally

have lived or traveled in all those locations and use the bus

when in those locations to get around. Annually I visit SF in the

month of November and when I get there I park my car and

travel around the SF Bay area to my destinations using the bus.

Should say that San Francisco and Davis CA also have extensive

bicycle ridership and I too have riden bicycles to get around in

SF and have noticed that from the 1970s to now a dramatic and

extensive difference in bicycle ridership with extensive use of

dedicated lanes and shared lanes and more all over San

Francisco. This too could come to pass if ONLY SCAG would but

some time and money into IMPROVING BOTH THE BUS SERVICE

ACROSS THE SCAG AREA BY DRAMATICALLY INCREASING THE

FUNDING from much less than 6 percent to a more reasonable

amount, say 20 percent of the TOTAL FUNDING FOR ALL KINDS

OF TRANSIT/BUSES/TRAINS/BICYCLES. and also doubling or

tripling the amount allocated for bicycle lanes/stripped areas,

parking etc. These Comments APPLY ALSO TO MANY OTHER

TOPICS/CATEGORIES and their chapters and subsections,

including the TRANSIT TOPIC. It applies to the Highways and

Arterials, Highspeed Rail etc. as funding for those areas will

need to be REDUCED until such time as SCAG provides NEEDED

BASIC BUS SERVICE including late evening and early am across

the SCAG area

228‐01 Karen Wright • There needs to be an increased percentage of the funding

used for bicycles and for bus service.

Comment noted. The 2012‐20

approximately $6.7 billion tow

investments. In response to t

received and based on final re

staff is pleased to note that th

Transportation has actually b

the Draft RTP/SCS that was re

comment. This represents an 

the commitments made in th

not account for the estimate

jurisdictions will be spending 
486

ID Name Affiliation Comment Re

plan period based on their cu

will continue to evaluating fu

and pursue new funding sour

228‐02 Karen Wright • There should be bicycle lanes at the over and underpasses in

Riverside along the 91 where you’re adding an HOV or carpool

lane. This should be across the SCAG region.

Comment noted.

228‐03 Karen Wright • There needs to be lockable units for bikes through the region. Comment noted.228‐04 Karen Wright • There needs to be steps to get citizens out of cars. The city

and county governments and federal agencies need to take

away their free parking. It’s a bad policy for cities, counties,

state and fed to provide free bus passes when those entities

also provide free parking spaces.

Comment noted.

228‐05 Karen Wright • Bus Transit ‐ SCAG needs to develop a public relation program

across all the counties to also encourage county and city

employees and other business leaders to use buses.

Comment noted. The RTP pro

transit funding and projects t

to use transit.

228‐06 Karen Wright • There needs to be funding for late night bus service. This

needs to be provided so people can attend their city council and

educational meetings.

Comment noted. The RTP sup

services.

228‐07 Karen Wright • Do not place high density housing only in downtown areas. Comment noted. The SCAG re

diverse, thus a variety of deve

The future land use developm

promotes a variety of housing 

228‐08 Karen Wright • Air Quality ‐ High density housing should not be put along

freeways or extremely busy intersections

Comment noted. There is sub

on health risks related to air p

infrastructure included in bot

Appendix and in the Program 

Staff has provided further ana

Appendix, as part of the final 

comments on this issue.

228‐09 Karen Wright • Safety at overpasses and underpasses Comment noted. The Transpo

goals and strategies related t

and fatalities.

229‐01 Karyl

Partenheimer

I am writing in response to the proposed Regional

Transportation Plan for a truck‐only East‐West Corridor from

San Pedro Bay Ports to downtown Los Angeles and on to San

Bernardino County. While this plan could potentially alleviate

some of the traffic along the I‐710, I‐60, and I‐15 freeways, I feel

it falls short of its potential. This plan does not address the

opportunity to improve the environmental deterioration caused

Comment noted. The East‐W

as a zero (or near zero)‐emiss

the opportunity to reduce ha

particulate matter. Local, reg

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten
487

ID Name Affiliation Comment Re

by diesel truck emissions such as reducing fine particulate

matter, improving air quality, and reduced noise pollution. I

understand the Sierra Club has endorsed a plan for a proposed

GRID Project Super Dock in which an underground tunnel is

used to facilitate a drone train delivery system of containers

emanating from the Ports of Los Angeles and Long Beach. This

underground system would not only reduce the truck traffic

along the local interstate highways, as proposed by the current

RTP SCAG plan, but would also provide an unseen, unheard, and

zero‐emissions right‐of‐way alternative to the congested,

environmental degradation system we currently endure. This

new concept would greatly decrease air, noise, and traffic

pollution as well as provide additional land space for future

development. I strongly encourage further consideration of this

alternate plan before we commit ourselves to an unnecessarily

limited concept.

resulting from freight movem

efforts have included the con

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing markeissues, operational feasibility, 

stakeholders (such as the San 

among others. SCAG will cont

stakeholders and transportat

potential solutions to regiona

230‐01 Kathleen

Danica

If a transportation plan is approved by SCAG, what will happen

to private property of those whose land may be “in the way” of

the determined plan?

Comment noted.

231‐01 Kathy

Huffmire

I am against this "sustainable community" against the re‐zoning

eminate [sic] domain etc.

Comment noted. SCAG is man

develop a "Sustainable Comm

RTP. This process does not re

nor does it involve the use of 

232‐01 Lars

Clutterham

In the City of Downey General Plan of 2005, the City speaks

about creating a bicycle infrastructure. In the City of Downey

Downtown Specific Plan of 2010‐11 the City talks about creating

a bicycle infrastructure, it acknowledges that it does not have a

master plan but hopes to move forward to that. SCAG awarded

the City of Downey a Compass Blueprint Award for their

Downtown Specific Plan. Yet in Downey’s contribution to their

sub‐regional SCS, the Gateway Cities Councils of Government’s

SCS projecting out to 2035, they had no bicycle infrastructure

planning. In addition, City Council of Downey within the last two

weeks has confirmed an EIR and then authorized the

development of a 1.5 million square foot shopping center,

which as it stands, can only be accessed by single occupancy

vehicles. I do not fault the City of Downey or its

Councilmembers. They are looking for revenue and they have

seventy seven acres they are trying to develop, but I feel a sense

of great urgency and would like to encourage SCAG to envision

Comment noted.
488

ID Name Affiliation Comment Re

a great deal more active and zero emission transportation. My

sense of urgency has a couple of elements. It took the

Netherlands forty years to change their transportation culture

and I do not think we have that much time in Southern

California.

233‐01 Matt Korner I strongly urge the Southern California Association of

Governments and its members to support, in the Regional

Transportation Plan, the strategy that the City of San

Bernardino adopted in 2009 to re‐establish itself as the core of

the Inland Empire and to reposition the municipality to compete

in the category of first‐tier cities, including Los Angeles and San

Diego. Doing so will more fully support SCAG's Transect‐based

planning and will enable the M.P.O. to attain the most

ambitious S.B. 375 targets. Improving livability and reducing

pollution there will enable the Inland Empire to attract a greater

diversity of incomes and skill sets and will, in so doing, help fix

the regional jobs‐housing imbalance whereby the coastal

counties experience a lack of affordable housing and the inland

areas a lack of high‐paying jobs.

Comment noted. The 2012 RT

projects that aim to turn the 

multimodal transportation hu

233‐02 Matt Korner With the proper support, San Bernardino can emerge as a

gateway city housing a million or two more residents since the

municipality has the powerful combination of existing land‐use

intensity, extensive infrastructure, and copious amounts of

vacant and underutilized land. San Bernardino is also located a

sufficient distance from Los Angeles. Ontario has the land but

lacks the infrastructure; Riverside has the infrastructure but

lacks the land. As one of the two nexuses of the former Pacific

Electric Railway, the centuries‐old San Bernardino is the natural

metropolis in the Inland Empire region and would have retained

parity with Los Angeles and San Diego had investments in

freeways and airports over the last sixty years not directed

growth to the coast.

Comment noted.

233‐03 Matt Korner I strongly urge SCAG to reconsider the expansion of the 210

freeway that is planned between the 215 and the 10. The

below‐grade portion of this expressway, in fact, may be an

excellent candidate for a highway‐to‐boulevard conversion that

conforms to S.B. 375, that supports the CalTrans‐funded T.O.D.

Overlay District at the Marshall Boulevard sbX station, and that

serves as a potential "Compass Blueprint" demonstration

project. The community deserves an analysis of the available

Comment noted. The 210 fre

identified by the San Bernard

(SANBAG) as a project for inc

the RTP/SCS must comply wit

requirements, including the c

conclusion of CEQA/NEPA for 

SANBAG on updating the RTP 

changes in the project descrip
489

ID Name Affiliation Comment Re

alternatives, especially since freeway widenings do not yield

sustainable relief from traffic congestion. San Bernardino is

doing its part to reduce V.M.T. through mixed‐use planning and

through the creation of fixed‐guideway transportation systems;

the city should be spared further sprawl‐inducing and tax‐base‐

undermining mistakes, and the residents should not see their

health further compromised and their properties further

degraded.

233‐04 Matt Korner I strongly urge SCAG to support the I‐215 alignment for

California High‐Speed Rail and for the optional station location

in San Bernardino. This configuration is especially important for

air‐rail integration with both SBD and March Inland Port and for

possible interstate service to Phoenix and/or Las Vegas.

Comment noted.

233‐05 Matt Korner I strongly urge SCAG to revise its allocations for regional

aviation demand to more closely match those in the 2008 R.T.P.

since San Bernardino International Airport was built, in part,

with these allocations in mind and since requiring better ground

access and air‐rail integration will depend on the 2012 R.T.P.

Disney's Magical Express at Walt Disney World should be used

as a model for seamless integration between Metrolink and

SBD, so that, for example, air passengers can check luggage at

L.A. Union Station and can directly board planes at the inland

airport from some sort of transfer available at the Metrolink

station.

Comment noted. The 2035 ai

the Draft 2012 RTP/SCS are b

scenario that was generated 

Constrained Scenario. It is a m

the one that was adopted for 

for the 2012 RTP since it mor

passenger activity trends in th

growth over the last decade. 

for San Bernardino Internatio

passengers (MAP), is much m

developed by the most recen

2023) than SCAG’s much high

MAP in 2035). Disney’s Magic

between a large internationa

and a large international tour

its potential future applicatio

limited.

233‐06 Matt Korner I strongly urge SCAG to incorporate the following concepts into

the R.T.P.: • Development‐oriented transit, transit‐oriented

development (with unbundled and restricted parking), and

clean‐energy car sharing are all mutually‐supportive, and the

three elements should be planned together. Every transit

station, especially where connecting transportation is deficient,

should have car sharing available. • Convert existing cars owned

by private individuals to share cars. • Convert existing cars in

governmental and other institutional fleets to share cars. •

Since "last mile" travel is more complicated than "first mile" and

Comment noted. The Transpo

Appendix lists various strateg

of Single Occupancy Vehicles

Management Appendix summ

make the existing transportat

includes a TDM/TSM Toolbox 

performance measurement c
490

ID Name Affiliation Comment Re

since residential uses tend to be more sprawling, concentrate

more employment, leisure, and retail uses around transit

stations and limit parking. • Enlarge catchment areas around

transit stations through traffic calming and bicycle/N.E.V.

lanes. • Allow N.E.V.'s to share bikeways throughout the region.

233‐07 Matt Korner I strongly urge SCAG to incorporate the following concepts into

the R.T.P.: • Mandate butanol to be used in existing gasoline

engines. • Mandate bio‐Diesel to be used in existing Diesel

engines. • Develop and mandate algal fuels to be used in jet

engines, especially at SBD. • Promote conversion of existing

Diesel engines to natural gas, etc. • Promote conversion of

existing gasoline engines to electricity, etc. • Promote

conversion of existing gasoline engines to flex‐fuel capability

and mandate provision of alternative fuels subsidized by

gasoline and Diesel taxes.

Comment noted. The RTP/SC

vehicle technology. However

Movement section of the RTP

future includes the use of nea

technologies as bridge to the 

SCAG Clean Cities Coalition is 

activities for three projects th

natural gas as an alternative f

Truck Replacement Project in

heavy‐duty diesel drayage tru

clean natural gas engines, cor

of approximately 180 natural 

Gas (LNG) ‐ Corridor Expansio

connection between the exist

infrastructure in Southern Ca

being developed in Utah, pro

corridor along one of the nat

movement truck routes betw

Lake City, Utah. And finally, th

CNG Truck Replacement Proje

deploy 262 natural gas trucks 

stations. There are currently 

fueling stations in developme

shown a commitment to expa

alternative fuels.

In addition, SCAG is currently 

to prepare Southern Californi

In Electric Vehicles (PEV), whi

address AB 32 and SB 375, an

Southern California. SCAG rec

perspective is necessary to ad

In order to better understand 

in the region, SCAG has coord

utilities, subregional councils 

jurisdictions and other key re
491

ID Name Affiliation Comment Re

included PEV related actions 

that would support and expa

In June 2011, SCAG, in conjun

applied for two PEV planning 

applications. The first grant, a

Energy (DOE) has as its prima

Regional PEV Readiness Plan 

Coast Air Quality Managemen

statewide application in partn

Quality Management District, 

Collaborative, and Clean Citie

awarded $1 million to PEV Re

$300,000 going to SCAG.

The second successful grant a

California Energy Commission 

collaborative effort between 

with SCE, the Western Rivers

(WRCOG), and South Bay Citie

(SBCCOG). This grant has bee

purpose of the project is to d

subregional plans in collabora

These subregional plans will s

subregions as they begin to d

Plans.SCAG will continue to work w

new planning effort and will p

additional stakeholders as the 

233‐08 Matt Korner • Add non‐highway bi‐county connectors between San

Bernardino and Riverside similar to the Gold Line between Los

Angeles and Pasadena and develop the land accordingly;

expand Metrolink between the two cities and add stations.

Comment noted.

233‐09 Matt Korner • Promote the Inland Empire as offering value in the form of a

higher quality of life versus a lower cost of living, especially

when that lifestyle is coming in a highly‐desirable urban package

with more square footage, features, and amenities than those

found in the coastal counties.

Comment noted.

233‐10 Matt Korner • Increase the numbers of freeway‐running express buses that

connect to multimodal terminals in city centers and ensure

reliability through concurrent use of congestion pricing/tolls.

Comment noted.

233‐11 Matt Korner • Pay particular attention to improving the guest experience at Comment noted.
492

ID Name Affiliation Comment Re

transit stations since the waits are often cited as the most

onerous parts of public transportation.

233‐12 Matt Korner • Increase the internal demand for Inland Empire airports by

expanding the tourism industry in the region.

Comment noted.

233‐13 Matt Korner • Expedite high‐speed rail development, especially on the L.A.‐

to‐San Diego segment where the need is gr

Comment noted.

234‐01 May Baki We have heard of a proposed "Regional Transportation Plan"

that is being developed by SCAG to create a system of truck‐

only lanes extending form the San Pedro Bay Ports to

downtown Los Angeles via the I‐710, connecting the east‐west

segment, and finally reaching the I‐15 in San Bernardino County.

We also heard of another project called the "GRID" designed to

upgrade the port to a first class and efficient ships handling and

cargo unloading center and also connects the Port to its

distribution centers using an underground railroad system that

has no second worldwide. The RTP project is projected to create

an all trucks lane, but would still be unsafe due to its traffic, and

environmentally unfriendly due to the concentrated number of

trucks that will be running all day and night on its lanes. In

contrary, the GRID project will change the container handling

system in such a way that not only would put the entire freight

infrastructure underground, but also provide zero‐emission,

zero noise pollution, zero light pollution, and free the land

surface for other useful development. As residents of Southern

California and Greater Los Angeles, we commend you for the

improvements that your team is considering to improve our

port and economy, and we respectfully ask you to consider the

GRID project instead of the RTP.

Comment noted. Local, regio

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten

resulting from freight movem

efforts have included the con

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing marke

issues, operational feasibility, 

stakeholders (such as the San 

among others. SCAG will cont

stakeholders and transportat

potential solutions to regiona

reducing emissions from freig

region. The 2012 RTP advance

and zero‐emission technologi

evaluate advanced technolog

235‐01 Michael Greer We do NOT want any plan dictated by ICLEI or Agenda 21. We

haven't asked for "sustainable communities" or trains or bike

paths. We want our roads and freeways fixed and no money

diverted to "sustainable" ANYTHING. There is NO Global

Warming and NO reason to limit our energy.

Comment noted.

236‐01 Miriam Strysik 710 Tunnel ‐ NO ‐ Increases truck traffic for port movement

using outdated technology. FREIGHT IS THE WAY TO GO. In

terms of savings in emissions, it is estimated that a total of

~60% reduction in CO2 emissions is achievable by a modal

switch from road to rail. See Case Study "Development of a

California Geospatial Intermodal Freight Transport Model with

Comment noted. SCAG recog

goods movement emissions c

that there are limited opport

strategies to facilitate signific

distinct modal market segme

such, our research focus to da
493

ID Name Affiliation Comment Re

Cargo Flow Analysis" ‐

http://www.arb.ca.gov/research/apr/past/07‐314.pdf

near‐zero and zero‐emission 

trucks serving the region.

237‐01 Paul Coambs Without delving into the exact specifics of the plan, the

executive summary adequately demonstrates that SCAG plan is

responding to federal and state requirements regarding

emissions impacting “air quality.” As such, the SCAG plan falls

right into line with the precepts of the U.N. Agenda 21 program.

In short, the SCAG plan intends to begin a transition to force the

population into high density urban cities and transportation

corridors. With a goal of zero or near zero emissions, the

eventual end‐plan will not just diminish the use of automobiles

for personal use, it will eliminate, for all practical purposes, the

use of the internal combustion engine. SCAG is using a smoke

screen approach to sell its programs. In addition to the emission

requirements, SCAG attempts to justify forcing people to use

“active transportation” for safety and health reasons. Yet, SCAG

fails to propose adequate funding for bicycle safety. The state of

health of individuals concerning obesity, etc, is alarming but it is

not the business of a transportation system. Claiming that high

density housing is a healthy plan is dishonest. Bicycling and

walking is healthy, not living in the environment prescribed by

the plan. The SCAG plans require the implementation of

alternative energy systems, which are neither technologically

nor fiscally available. The SCAG plan is not what we need with

the current runaway government spending. The SCAG plan is a

classic liberal boondoggle that requires a huge redistribution of

wealth. SCAG is a natural extension of the federal and state buy‐

in to the U.N. agenda to extort money from the western world

and in the process to hamstring the capitalistic engine that

modernized much of the world. The ignorance of the western

politic to join with the U.N. in this socialist movement and at the

same time turn a blind eye to India, China and the third world

nations is astounding. Dump the SCAG plan and tell both the

feds and California to eliminate the unrealistic environmental

requirements.

Comment noted.

238‐01 Peter Orona Today there is no 710 Surface Freeway Route, Valley Blvd.‐

Alhambra Connector Road, or 710 Tunnel; consequently, the

risk emanating from such concepts are zero. To all Federal,

State, County, and Local governments who profess

accountability when maintaining modern commercial

Comment noted. Issues regar

location of tunnel portals are 

level analysis of the RTP/SCS 

part of project‐level engineer

are developed by implementi
494

ID Name Affiliation Comment Re

productivity, it is your duty to find a balance between an

individual’s right to exist, and urbanization. Anything short of

this is a travesty to the democratic process, and an abatement

of our humanity. As elected officials, it is your responsibility in

making sure that our communities are not abused. Our

communities are holding you accountable. As honorable civil

servants of our communities, we respectfully request the

following items be addressed rigorously, competently, and

judiciously. 1. What would it take to construct the southern

portal between the 60 Frwy (Pomona), and the 10 Frwy (San

Bernardino)? Can Freeway Interchanges be configured? If yes,

then would it be possible for the southern portal to begin just

before the 10 Frwy. Can a tunnel be constructed to go

underneath the San Bernardino Frwy?

238‐02 Peter Orona 5. How will the Valley Blvd.‐Alhambra Ave. Connector Road

(part of the Low‐Multi‐ Build Alternatives) benefit El Sereno?

Compare and contrast the efficiency and effectiveness between

the Valley Blvd.‐Alhambra Ave. Connector Road, a 710 Surface

Freeway Route, and the 710 Tunnel. Provide all information on

any and all environmental studies, or reports that have been

done and completed near, and around the proposed 710

Tunnel. Indicate what efforts have been made to provide this

information to the community of El Sereno. Provide any tangent

plans that are being considered in conjunction to the 710

Tunnel in order to mitigate LA County traffic problems. For

example, will a commuter train station be constructed in El

Sereno between Alhambra Ave., and Valley Blvd.?

Comment noted. Issues and q

performed as part of the Env

Report/Environmental Impac

lead agency, in this case, Calt

238‐03 Peter Orona 12. Can Caltrans buy/build two tunnel boring machines? Having

the boring machines simultaneously working at both ends could

cut tunnel construction time in half. Why can't the boring

machines be designed, and built by Americans within the United

States?

Comment noted. Issues and q

performed as part of the Envi

Report/Environmental Impac

lead agency, in this case, Calt

238‐04 Peter Orona 13. After tunnel construction and cost, how many years will it

take to break even? When will Los Angeles County start making

its profits?

Comment noted. Issues and q

performed as part of the Env

Report/Environmental Impac

lead agency, in this case, Calt

238‐05 Peter Orona 18. How much will a toll road system cost to implement, and

maintain?

Comment noted. The cost of 

into the financial analysis and 

delivery options, including P3

Current analysis assumes tha
495

ID Name Affiliation Comment Re

facilities pay for the construct

associated with construction) 

maintenance of those same f

electronic toll collection syste

to attract private capital and 

maintaining the facility, reduc

of revenue and risks.

238‐06 Peter Orona 19. Are current modes of production changing to prevent the

harmful effects of pollution? Provide information that the

Market Place will create alternative‐affordable modes of

transportation, and fuels by the time the 710 Tunnel is

completed? For example, when will Fuel Cell Vehicles (FCV’s) be

readily available on a mass transit scale?

Comment noted. The Californ

developed and approved Adv

gasoline‐ and diesel‐fueled ca

More information can be fou

http://www.arb.ca.gov/mspr

238‐07 Peter Orona 20. Will the 710 Tunnel engineers learn from all the errors that

previous tunnel mishaps demonstrate? For example, people

living around tunnel portals in Australia are suffering, and dying.

The Big Dig in Boston is a fiasco. Will an independent panel of

environmental experts review the 710 Tunnel EIR? Will a

contact telephone number for all agencies, and government

officials be provided to voice concerns and complaints during

construction?

Comment noted. Issues and q

performed as part of the Env

Report/Environmental Impac

construction activities should 

this case, Caltrans.

238‐08 Peter Orona 21. Logistically, would it be possible to evenly spread the

amount of freight tonnage along the Pacific Rim harbors (San

Diego, Long Beach, San Pedro, San Francisco, and Seattle). What

would it take to ensure that a more efficient and effective On

Time Delivery System be implemented? Would an upgraded of

our national railway system help prevent unnecessary truck

traffic through the counties of LA/Riverside/Ventura/ San

Bernardino/San Luis Obispo, etc.? For example, can the

coordination of freight goods that make their way towards the

Midwest, or Northwest be dropped off at any of the northern

bays rather than being distributed from the ports of Los Angeles

or Long Beach?

Comment noted. In 2010, the 

handled cargo valued at appr

resulted in major regional eco

jobs, business revenues, and 

SCAG region serves as an imp

be maintained. While it migh

serviced at other west coast p

significant advantages that at

Pacific Rim to the region inclu

water ports and port equipm

large ships, an extensive high

the nation, two Class I railroa

region, an abundance of ware

a considerable amount of tra

internal market. An efficient a

critical to the goods moveme

feasible to move all goods by 

generally serve different mar

to distant areas outside the r
496

ID Name Affiliation Comment Re

able to use rail from the San P

destination. Goods moving fr

regional manufacturers to loc

international border with Me

as a result of cost, lack of acc

first‐mile/last‐mile issues, or 

movement system is complex 

single mode of transportation

238‐09 Peter Orona 22. Are the 710 Tunnel scrubber towers, and emergency exits

going to be equidistant from each other? Indicate tower and

exit locations. Can tower and exit locations be situated where

there are no existing domiciles? If a scrubber tower is warranted

in a residential neighborhood, can a four‐block radius of green

space circumscribe the scrubber tower?

Comment noted. Issues regar

location of tunnels are not ad

analysis of the RTP/SCS and w

of project‐level engineering a

developed by implementing a

238‐10 Peter Orona 23. How many people concerned about the 710 Tunnel have

read ADVICE & PLANNING by Martin H. Krieger?

Comment noted.

238‐11 Peter Orona [PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

239‐01 Phillip Brown Rather than overly focused, commuter driven centralizing of

trips via expensive rail more planning and building should be

made to provide for increased population density and job

creation to reduce travel and commuting with shorter trips;

think “Centers Concept” in sub‐regional aggregations. In that

manner extensive low cost medium capacity transportation and

land use in patterns and corridors will provide a much more

Southern California like growth and compatibility with what

exists. The specific overall comment to be made is that SCAG

needs to include the Flow Boulevard concept in its planning

vision formation, criteria and plan recommendations for the

Regional Transportation Plan. It may be better said that SCAG

being the lead agency should see that County agencies like the

Los Angeles County Metropolitan Transportation Authority be

directed to enlarge its forms of transportation improvement to

include well crafted land use and transportation improvement

forms such as the Flow Boulevard technique.

Comment noted. SCAG will co

partners in considering innov

transportation challenges.

240‐01 Randy

Strapazon

I am a resident of La Canada Flintridge and will be impacted by

the closure of the 710 gap connecting to the 210 freeway. There

is a reason that the debate about the benefits of closing that

gap has been ongoing for more than thirty years. It is not a good

idea! We need people looking to the future, not to the past, for

Comment noted. SCAG recog

environmental analysis is und

that effort and selection of a 

SCAG will work with Metro to 

update the project descriptio
497

ID Name Affiliation Comment Re

traffic and congestion relief solutions. Building a tunnel will only

increase the number of vehicles passing through this section. If

your agency is concerned with environmental impact and the

reduction of greenhouse gasses, increasing the number of

vehicles on the road is shortsighted. Please look to more long

range and reasonable solutions, not the ones "your fathers"

might have chosen. Thank you, Randy Strapazon

analysis.

241‐01 Richard

Risemberg

Having read multiple synopses of SCAG's Regional

Transportation Plan, I am stunned to discover that the RTP

suffers from both a lack of, and an excess of, imagination. The

lack of imagination is exemplified by the plan's reliance (despite

a few bones thrown to transit and non‐motorized

transportation) on still more lane‐miles for still more cars and

trucks. This is a paradigm that has consistently failed us for over

half a century, since traffic engineers first figured out that

building ever more roads induces ever more traffic and creates

ever denser congestion. The excess of imagination is

exemplified in the evident belief that simply enacting practices

that have failed again and again for two generations will

somehow magically "work" this time.

Comment noted.

241‐02 Richard

Risemberg

Considering how best practices are evolving in other US regions

and worldwide, it is actually shocking that SCAG is not

dedicating its energies to nurturing the non‐fossil‐fueled and

non‐motorized transport modes that are becoming the new

paradigm worldwide.

Comment noted.

241‐03 Richard

Risemberg

Bicycling, walking, and both light and heavy rail passenger

transport have been proven not only to reduce congestion, but

also to improve public health and happiness and increase

economic activity, as people trade sitting in massive traffic jams,

or speeding down surface streets looking in vain for free

parking, into actually participating in the casual public

discourses of civic life‐‐which include being able to browse

commercial streets from the seat of a bicycle, or on foot after

descending from the tram, unfrustrated by the parking struggle.

Comment noted.

241‐04 Richard

Risemberg

And freight movement in our region is a nightmare, primarily

because it is so dependent on trucks, whose energy efficiency is

one‐quarter that of a diesel train, and whose spatial needs are

orders of magnitude higher than those of railroad operations.

This absurd obsession with truck freight results in thousands of

acres of precious land being taken off the market, and the tax

Comment noted. Local, regio

experts and stakeholders from 

sectors, have worked closely 

identify and implement poten

resulting from freight movem

efforts have included the con
498

ID Name Affiliation Comment Re

rolls, to support a dirty, cumbersome, and fundamentally

antiquated method of moving freight between ships and

railcars. Wasting thousands of acres of port property to stack

containers by onesies onto trucks, simply to haul them forty

miles and put them on the train they are destined for anyway,

is, frankly, ridiculous. I am familiar with the GRID project that

has been making waves lately, and its "Superdock" is a far

superior way of moving import and export goods bewteen ships

and trains. Furthermore, GRID's proposed underground electric

rail shuttle to the Downtown and Inland Empire railyards

promises not only to reduce the devastation diesel trucks and

even trains are wreaking on populations adjacent to the 701

corridor, but also to save the region millions from freeway and

street expansions that would become unnecessary! This is a

concept both visionary and practical, and represents the sort of

thinking we need from SCAG‐‐not habitual reiterations of

outmoded practices that will only drown us in concrete, smog,

and traffic chaos.

Research and analysis to date 

truck‐lane system used by cle

emission) offers a promising s

concerns. Nevertheless, SCAG 

alignment concepts including 

technology options for applic

technology options, evaluatio

adequately addressing markeissues, operational feasibility, 

stakeholders (such as the San 

among others. SCAG will cont

stakeholders and transportat

potential solutions to regiona

242‐01 Robert Rigdon I am concerned that the Farmers Field NFL stadium in

downtown Los Angeles will block cross‐town traffic in all

directions.

Comment noted. Projects suc

project‐level environmental i

California law, to identify imp

identify mitigation measures. 

currently under development

243‐01 Rodney

Spooner

Does the finance plan include bonds or loans, and are they

going to be voted on by taxpayers? How many would be

permanent versus temporary and how many would be

government versus private? I hope that the jobs industry are

American jobs and I hope that would be a requirement of this

whole project is that everything will be American.

Comment noted. The Transpo

detailed explanation on all re

The financial plan includes bo

sales tax measures and bonds 

facilities where the tolls colle

Steps for issuing the bonds ar

requirements of each measur

policies established by the iss

in the region are seeking or h

cost loans from the federal go

program. Since SCAG is not a

issue bonds nor seek loans fo

encourage the participation o

result in efficiencies and in tu

most of the direct jobs associ

construction or related to the 

transportation system, they a
499

ID Name Affiliation Comment Re

jobs.

244‐01 Rose Gonzales Riverside County Comment noted.245‐01 Stephanie

Johnson

Thank you for the opportunity to comment on the SCAG 2012‐

2035 Regional Transportation Plan/Sustainable Communities

Strategy. The Plan states as its goal “improving the quality of life

for our residents”. The 2012 RTP/SCS will transform the region,

serving as a blueprint for improving quality of life for our

residents by providing more choices for where they will live,

work, and play, and how they will move around. The 2012

RTP/SCS proposes investing over $500 billion over the next 25

years to improve the quality of life of the region’s residents by

enhancing our transportation system. While I agree that

improving the quality of life for the residents is an admirable

goal, the Plan as indicated by the SCS City maps, will denigrate

the quality of life for the residents of San Marino. My comments

regarding the 2012‐2035 RTP are limited to where I live, Los

Robles Avenue in San Marino, and the adjacent area.

Comment noted.

245‐02 Stephanie

Johnson

While reviewing the Resources > SCS Map Tool from the SCAG

web site, http://rtpscs.scag.ca.gov/Pages/SCS‐Maps‐Tool.aspx, I

was shocked to discover that Los Robles Avenue in San Marino

has been designated a High Quality Transit Corridor. The SCAG

RTP Plan indicates that: A HQTA (High Quality Transit Area) is

generally a walkable transit village, consistent with the adopted

SCS that has a minimum density of 20 dwelling units per acre

and is within a 1⁄2 mile of a well serviced transit stop, and

includes transit corridors with minimum 15 minutes or less

service frequency during peak commute hours. Los Robles

Avenue in San Marino is a 7/8 of a mile, two lane narrow street

fronted exclusively by single family homes where children live

and play. The homes, built between 1920 and 1950, and the set

back is close to the street. The posted speed limit is 30 mph. the

posted weight limit is three tons, and truck traffic is prohibited.

The City of San Marino General Plan, classifies Los Robles

Avenue as a residential collector street. The street carries an

unusually high volume of cut‐through traffic, exceeding the

capacity of a two lane residential street. There is no bus service.

How then, was Los Robles Avenue in San Marino designated a

HQTC? I posed this question to both the City of San Marino staff

and City Council. They were unaware of this designation in the

proposed RTP Plan. I also made inquiries of SCAG staff and was

Comment noted. Los Robles A

not designated a High Quality 

2012 RTP / SCS. There is no cu

transit service to establish an 

corridor. There appears to be 

available on the website refe

corrected.
500

ID Name Affiliation Comment Re

told that the Map for San Marino was incorrect with regard to

bus stops, because no bus route is planned for the street.

245‐03 Stephanie

Johnson

Below are copies of the SCAG SCS Maps for San Marino,

Alhambra, South Pasadena and Pasadena. It is not clear why

certain streets have been designated HQTC and others have

not. SCAG Map for San Marino – High Quality Transit Corridors

(HQTC) This map indicates that Los Robles is a HQTC with bus

stops. South Pasadena Note that although Fremont Avenue is

designated a HQTC in Alhambra, it is not in South Pasadena,

although the street merges into S. Pasadena Avenue that is the

freeway entrance to the 210 and 134 freeways in Pasadena.

Garfield Avenue has a METRO bus route that extends through

South Pasadena that stops at the Gold Line Mission Street

station. Alhambra Why is Garfield Avenue not designated a

HQTC? It is a major arterial in Alhambra and has a bus routes

that extends through South Pasadena that stops at the Gold

Line Mission Street station. Pasadena Note that both Los Robles

Avenue and Oak Knoll Avenue in Pasadena, south of California

Boulevard, are single family residential areas. Alhambra, South

Pasadena, San Marino, Pasadena Fremont marked in purple for

reference purposes. If regional planning is to be based upon the

SCS maps, then further information regarding how the HQTC

attribute was assigned to streets must be made public. Los

Robles Avenue in San Marino does not meet the definition of an

HQTC. Regional traffic should not be directed toward the street,

exacerbating the existing cut through traffic and its resulting

negative impacts upon the residents.

Comment noted. California P

21155 defines a “high quality 

having fixed route bus service 

than 15 minutes during peak 

California Public Resources Co

transit stop” is a site containi

ferry terminal served by eithe

the intersection of two or mo

frequency of service interval 

morning and afternoon comm

mandate to follow these defi

City of San Marino is not desi

within the context of the 201

planned bus or other transit s

that corridor. There appears t

available on the website refe

corrected. South of Common

within the City of Alhambra is 

route 258 and route 485, who

period headways meet the st

258 leaves Fremont Avenue a

service of route 485 is not suf

to trigger an HQTA designatio

which operates along Garfield 

has 40 minute peak commute 

meet the statutory definition 

Robles Avenue and Oak Knoll 

are single family residential a

246‐01 Stephen

Shapiro

I don't want money diverted from fixing our EXISTING

infrastructure to "sustainable" anything. There is NO Global

Warming and no reason to ration our energy.

Comment noted.

247‐01 Susan Sulsky I oppose all items in the draft RTP that recommend the

expansion or extension of highways, for the following reasons:

The fundamental law of highway congestion (Anthony Downs,

1962, 2004, 1992; and confirmed most recently by Gilles

Duranton and Matthew Turner of the University of Toronto )

states that the travel speed of an expanded highway reverts to

its previous level before the capacity expansion and that the

Comment noted. Increase in t

condition is primarily due to e

people over the plan period. 

basis will actually decrease ov

implemented. While the Plan 

highway improvements, inclu

project, there is no evidence 
501

ID Name Affiliation Comment Re

extension of interstate highways is met with a proportional

increase in traffic in the U.S. SCAG’s assumption that highway

expansion reduces congestion and improves pollution levels is

grossly inaccurate. The traffic modeling fails to fully account for

generated and induced traffic. And therefore exaggerates the

benefits of expansion and the does not reflect the severity of

future congestion problems. The draft RTP anticipates adding

948 centerline miles and 7419 lanes miles which would be a

4.4% and 11.1% increase respectively. The SCAG RTP will

increase pollution, truck traffic, congestion, accidents, health

impacts and environmental risks throughout the Southern

California region.

contribute to the total VMT in

The 2012 RTP identifies a mu

incorporates transit, highway

strategies as well as demand 

pricing strategies to achieve o

performance and reduction in 

375.

247‐02 Susan Sulsky I oppose the 710 gap closure project as it is un‐defined and is

not eligible to be on the Constrained Plan. The proposed SR‐710

Extension Toll Tunnels, at $5.6 BILLION already underfunded by

at least 50%, must be moved from the Constrained Plan to the

Strategic Unfunded Plan in the 2012 RTP because there are no

committed, available, or reasonably available funds as required

by federal law for inclusion in the Constrained Plan. There is

enormous internal inconsistency with the SCAG’s six possible

construction zones yet all actual estimates based only the

previously defined Meridian Route alignment.

Comment noted. SCAG’s 2012 

constraint requirements set f

regulations and guidance, inc

strategies for ensuring availab

identified. See 23 CFR 450.32

in part, that the RTP includes 

demonstrating that projects i

using committed, available, o

sources. See 23 CFR 450.104. 

be funded by both core (Mea

available revenues. SCAG doc

sources identified for the SR‐

available. As such, strategies 

implementation steps for ens

new revenues are discussed i

Appendix.

247‐03 Susan Sulsky I oppose plan items in the draft RTP that recommend increased

conventional roadway and rail yard capacity for goods

movement. The RTP should instead include existing zero‐

emission goods movement alternatives. Goods movement must

be accomplished via electrified freight rail not trucks. Goods

movement proposals in the draft RTP are inconsistent with

regional, state, and federal air quality and congestion targets

stated in the plan. The plan states that to attain federal ozone

standards, the region will need broad deployment of zero and

near‐zero emission transportation technologies in the 2023 to

2035 timeframe (p.74). It also acknowledges that conventional

goods movement practices contribute to excess ozone and poor

Comment noted. Emissions fr

a significant concern for the S

lane system identified in the 

facility used by zero emission 

Environmental Action Plan th

zero emission technologies in 

federal requirements. It is no

whether electrified or conven

segments generally serve diff

moving to distant areas outsi

may be able to use rail from t

final destination. However, go
502

ID Name Affiliation Comment Re

air quality (p. 68) and negative impacts in neighboring

communities and throughout the region. However, the plan

allocates billions of dollars to expanding conventional goods

movement, saying “truck‐only freight corridors are effective as

they add capacity in congested corridors, improve truck

operations and safety.and provide a platform for the

introduction and adoption of zero‐emission technologies.” Yet

the plan does not require zero‐emission technology.

local warehouses, regional m

across the international bord

utilize rail as a result of cost, 

travel time, first‐mile/last‐mi

The goods movement system 

rely on a single mode of trans

247‐04 Susan Sulsky [PEIR comment(s)] See the Final PEIR Addendum 

Comments on the Draft RTP P

248‐01 Theresa

Sherrin

I’m also a native Californian and also had a business in Orange

County. This is going to ruin the businesses. It’s not going to

help us. It’s going to cost us a lot of money. I just think that this

is the wrong way to go. The Government is trying to take

everything we have away from us and I think they are

interfering with what we should have and have more open

space. This is part of agenda 21. They are trying to take us over.

We need to wake up to that and I don’t think the people in this

community want it. I want to make sure that we don’t waste

money. If we are going to spend money on some kind of a

program, I just don’t want to waste money. Like we build a

transit system and it’s not conducive here in Orange County or

it doesn’t get used or it has to be subsidized so much by the

Government. I don’t want us to make that mistake because

Southern California is not like Northern California. We don’t live

that way. We don’t live where a transit system works. That’s our

lifestyle. Who has the right to dictate what our lifestyle should

be, but we can’t afford to waste anymore taxpayer money. So I

don’t care if funding comes from the Federal Government, or

where the funding comes from. We can’t afford to have

infrastructure that’s going to go blank. That’s going to sit there

and start to be urban decay.

Comment noted. The RTP/SC

collaborative bottom‐up proc

residents, stakeholders, local 

and county transportation co

249‐01 Anonymous In this very difficult economy, how will such a proposed plan be

funded? Will there be a tax increase to fund this project?

Comment noted. We recogni

and the nation continue to slo

Recession. However, the RTP 

stretches to 2035. There will 

economic cycles over the cou

economic conditions have va

years. The Transportation Fin

explanation on all revenue so
503

ID Name Affiliation Comment Re

including potential tax increa

cannot be known with certain

reasonable assumptions, whi

Technical Advisory Committe

well documented in the RTP. 

funding option, we will updat

through amendments and/or 

appropriate.

250‐01 Anonymous For those of us who believe that the US is in an economic crisis,

no increase in tax, be it excise of other, is acceptable.

Comment noted. We recogni

and the nation continue to slo

Recession. However, the RTP 

stretches to 2035. There will 

economic cycles over the cou

economic conditions have va

years. The Transportation Fin

explanation on all revenue so

including potential tax increa

cannot be known with certain

reasonable assumptions, whi

Technical Advisory Committe

well documented in the RTP. 

future funding options, we w

accordingly through amendm

updates as appropriate.

251‐01 Anonymous You’re planning for growth which SCAG was originally designed

to do, to plan for regional growth but you have actually planned

for shrinkage because the only way that this type of transit

system would work is to pack us into the cities because all of

what you’re talking about is for dense mixed‐use communities

as opposed to the way that we like to live; in our suburbs, in our

homes. I’d like to find out what changed you from a “planning

for what people want” to “planning for what government

officials think we need”.

Comment noted.

252‐01 Anonymous Let me make another comment because that’s not going to be

the truth because what is being imposed on us is sustainable

communities and one of them being proposed right here in

Camarillo is to take out part of our meal in our center of our city

as they did in Thousand Oaks with the Thousand Oaks Blvd.

specific plan. We are not LA County and everything that I saw in

that film was geared towards LA County and a lot of it was done

Comment noted.
504

ID Name Affiliation Comment Re

to emotionalize us into accepting this.

253‐01 Anonymous In the last 30 months, VCTC has received about $180 million

from the federal government. I think that they’re staff there is

about 15 people and of that $180 million, 27% was spent on

planning and I’m just wondering where all of that money is

going and why are you planning our future? Why isn’t it just

being dictated by the free market what our needs are and why

are they regulating and taxing the land here and ruining the

ranchers and farmers so that they have to sell their land or it’s

taken back by the city. On Thousand Oaks Blvd in a 3 mile long

span where they’re putting in a specific plan, 62 businesses

have gone bankrupt and the city has taken back the land.

Where are we getting all of the land to do all of these projects?

Comment noted.

254‐01 Anonymous What you’re proposing to do is to try and get people on trains.

The trains are empty. I’ve lived here since 1960 and since 1960

I’ve never seen a quarter‐filled train car. Not once. Secondly,

you’re trying to get people on bikes. Most people cannot ride

bikes but most have health reasons. Most of the people in this

community have doctor’s appointments because many are

elderly. How do you propose to get those people to their

doctors’ appointments regularly? It’s just not a reality because

this is not LA. You go to LA and do it but don’t take our

freedoms away and don’t crowd people into an area and take

our rights of driving or anything else away.

Comment noted.

255‐01 Anonymous You said that the RC will vote on April 4th. Is that the 6 Counties

or will only Ventura County vote independently?

Comment noted. The Regiona

members from all six countie

single body.

256‐01 Anonymous Will our elected officials from our County really make a

difference in their vote?

Comment noted. The elected 

and the other five counties w

represent the cities and coun

the Policy Committees provid

staff in the development of a

program is presented to the R

the Regional Council and Poli

include representatives from 

opportunities to provide thei

appropriate revisions.

257‐01 Anonymous Last question, at the end of this session today, how are you

going to determine what the outcome is? Is there a vote? How

are you going to report on the conclusion of this meeting?

Comment noted. All formal co

responded to and presented 

considered as part of the fina
505

ID Name Affiliation Comment Re

258‐01 Anonymous When I voted for my elected officials, I did not know that I was

giving them domain to make decisions over my future and the

future of my children and my grandchildren without me having

a vote. I’d like to know why none of this organizational planning

has come up for a vote of any of the constituents. It seems to

me like it’s already drawn up, people have made up their minds

and the 84 blessed ones are going to decide how the rest of us

are going to live. I don’t approve of that.

Comment noted. The RTP/SC

bottom‐up, multi‐year proces

interested parties from acros

RTP/SCS's most fundamental 

forecast and anticipated futu

were developed with input fr

projects include long‐range tr

county transportation commi

approved sales tax measures

hearings were also held as th

developed in order to solicit i

259‐01 Anonymous Do you know of any situation in the entire US where rail‐

passenger traffic has broken even if it would not have been

supported by the government?

Comment noted.

260‐01 Anonymous If the rails aren’t breaking even and the buses aren’t breaking

even, then what’s the model for all of the stuff that you have? Is

it Europe? They’re not breaking even either. That’s just obvious

to us what’s going on here and we have our eyes on you.

Comment noted.

261‐01 Anonymous I’d like to pass around these pictures that I took last summer in

Seoul, Korea and this is the way that you would like us to live.

I’d like for everyone to take a look at how their housing is. There

were 600 – 800 square feet for each apartment that was

covered with a quick train that went from the airport to

downtown Seoul. All of those people that got crammed into

those houses didn’t have a say either or they will not be there.

Comment noted.

262‐01 Anonymous Your interpretation of the construction of all of this is that all

limited to union construction or construction people like my son

who is non‐union. Are those jobs going to be open for them?

Comment noted. The RTP/SC

construction of projects inclu

263‐01 Anonymous If there are 84 officials from 197 jurisdictions represents less

than 50% representation amongst those jurisdictions and that

doesn’t seem sufficient to me. Secondly, you just mentioned

where the derivation of the statistics came from on population

increases which is all well and good except that the crucial part

that is missing is demographic changes over time which are

going to involve aging populations or that half the people will be

over 50 by 2035. That really should factor into the idea of

bicycling, etc.

Comment noted.

264‐01 Anonymous I’ve attended a couple of other meetings that were like this

through my educational entity that I’m affiliated with and I can

Comment noted. SCAG works 

major Metropolitan Planning 
506

ID Name Affiliation Comment Re

say that they cite these statistics and often they don’t tell you

where they came from and that’s my question. Where are the

statistics coming from pertaining to the carbon dioxide

emissions? One of the things that you told us is that people

have changed what they want in their lifestyles, young people

are getting married and having children no longer want to live in

the suburbs and no longer want to have their own single family

homes and they actually prefer to live in these denser

transportation hubs. The only study that I’ve ever been able to

get anyone to admit that they’ve derived this information from

was a Calbert Hoi Study. It is very important if you want to

project your plans with citizen involvement and be open and

fully transparent that these kinds of presentations should have

your derivation of your statistics that are much more detailed.

California Air Resources Boar

requirements of SB375 with r

emissions and target setting. 

CARB on their website: www.

265‐01 Anonymous I’ve noticed that this meeting is in the afternoon on a workday

and it’s the only one for this county and then you move on to

the next county. That’s really not enough time to hear from the

population that you’re serving. It’s very unfair and wrong.

Comment noted. While SCAG 

the public to learn about and 

plans, services and initiatives

public hearings in various loca

various times, SCAG realizes t

be convenient for everyone. S

public meetings in the evenin

assessment of outreach activ

266‐01 Anonymous It strikes me as wrong that your 84 representatives of the

population represent 18 million people. If that’s the way that it

goes then that should also be transparent so that we know

where these people stand, what they’re planning and that

they’re speaking for us. You may have the best intentions in the

world but we still live in a free country.

Comment noted. SCAG’s Regi

Members are elected Mayors

County Supervisors from juris

region. The cities and countie

represent them at SCAG’s Reg

Committees. SCAG’s Regiona

meetings are open to the pub

Regional Council meetings ar

SCAG’s website, www.scag.ca

viewing online. The names of 

Committee Members are pos

267‐01 Anonymous Can you please provide a list of the 84 people on the RC. Their

positions and maybe their contact information.

Comment noted. The roster o

be found on SCAG's website a

268‐01 Anonymous We keep hearing about all of the problems on the road and the

air quality and the truth is that the air quality is getting better

and we have more cars on the road. Secondly, I’d like to

reiterate on the handicap people and elderly people. This

wonderful congestion that you have is going to involve great

Comment noted. SCAG’s RTP/

needs of the elderly and disab

sidewalks in the region up to 

Safety Appendix has recomm

drivers (Challenge Area 9) to 
507

ID Name Affiliation Comment Re

difficulties for the freedom of our elderly people and their

inabilities to get into cars which equates to freedom.

their driving skills as well as p

help maintain mobility for sen

drive.

269‐01 Anonymous Never before have the crucial linkages between the economy

and transportation system and land use been as important as

now. That is an assertion and its telling me that a group of

people got together and decided what would be good for this

area of California and decided that they would implement this

without any risk to themselves because they have full taxpayer

backing and they are able to do through eminent domain

confiscate property if the people don’t agree to their plans.

Through these financial statements that have additional taxes

and a lovely thing called mileage user fees. My question is, how

are those calculated and how will they be? On your website

there is a significant source for funding and it ends up being

somewhere along the lines of $110 billion from innovative

financing and new revenue sources but for the first 2 time

periods there’s zero so out of 3 time periods it gets us to $110

billion dollars. Out of the 3 categories, the only one bigger is the

sales tax. Can you explain to me how those mileage based user

fees are calculated?

Comment noted. The Transpo

detailed explanation on all re

The potential implementation 

not assumed to start until 20

the existing state and federal 

mileage‐based user fee, like t

excise tax, is directly linked th

resource used. While the mile

drivers for each mile traveled

charge drivers for each gallon 

of gas consumed is a direct p

traveled.

270‐01 Anonymous What troubles me is that there are 84 people in this county who

are so involved that they don’t understand or accept the fact

that the green agenda is a complete fraud. That there’s no

global warming and that man isn’t creating it. It would be

insignificant and even Phil Jones in the IPCC admits that over

the last few years there has been insignificant increase in

temperature and yet you want to reduce CO2 emissions which

is what we breath. The only reason you’d like to control CO2 is

to control our lives.

Comment noted. The greenh

SCAG is required to meet via 

requirement as a result of Se

271‐01 Anonymous I heard the President of Mercedes Benz speak on the future of

the automobile and he said that the automatic self‐controlled

automobile is the thing of the future and that you can call up

your car and will pick you up and drive you to your dentist and

will return you to your home and is within 15 to 20 years out.

Google has an automobile that is driven 144,000 miles without

an accident and has been tested and is a perfectly practical

system. It’s the future of automobiles. Why do you go back to a

train which is a 19th century invention and try to force us into

ancient technology. Why don’t you have foresight and look into

Comment noted. The 2012‐20

that recognizes the importan

arterial system, and includes 

improve this system. Such a s

smarter vehicles as they are f

into the market.
508

ID Name Affiliation Comment Re

the future of the automobile and make our infrastructure that

we have now twice as productive.

272‐01 Anonymous Why do you want to include the trains before there’s a need?

Why not let the free market work? You show pictures of

Ventura highway from Ventura to Santa Barbara that are 4

years old. It no longer looks that way. Why are you seeking us?

Why should we pay for this if we don’t want them?

Comment noted.

273‐01 Anonymous When the 84 czars vote, is that good for the region? Now our

towns, cities and counties are going to become regions so will

we be ruled by regions?

Comment noted. SCAG’s Reg

Members are elected Mayors

County Supervisors from juris

region. The cities and countie

represent them at SCAG’s Reg

Committees.

274‐01 Anonymous All the money is there then? The gathering of our tax money is

there.

Comment noted.

275‐01 Anonymous With these trains that you’re talking about that are coming in

full, when they get to the station in Los Angeles, I’m assuming

that everyone works within a block away from where the

station is or do they and do they not have to take some other

form of car, taxi or bicycle?

Comment noted. A majority o

subway upon arrival to L.A. U

276‐01 Anonymous You are saying that the expansion of the train system costs so

many billions of dollars. Instead of spending that money on the

trains buy these people cars or give them taxi fare. Here’s a

comment on bicycle lanes. In Ventura County, very few people

use bikes for serious transportation and you can’t go to the

market so if people use this for pleasure and today I drove from

Carmen Drive to the library and there was a biker on the bike

lane and I didn’t think that he was riding very steadily. I went

around him and how often do we read in the newspaper about

a bicyclist who’s killed while riding on the road. Bike riding is

dangerous. I don’t see spending money on more bike lanes.

Also, the bike lane is not more than 2 feet wide and it’s not

enough.

Comment noted.

277‐01 Anonymous Why can’t you put bike lanes on the sidewalk? Truthfully, hardly

anyone uses sidewalks.

Comment noted. Many local j

on sidewalks due to safety co

278‐01 Anonymous There’s already that’s been tried and tested in England and it’s a

solar car and the gas companies bought it up because it ran on

sunshine. This happened in the late 70’s or early 80’s and it was

a wonderful machine and although the patent has been bought

Comment noted. We recogni

with certainty and therefore w

which were vetted through S

Committee and Policy Comm
509

ID Name Affiliation Comment Re

it is possible in the future that this can be produced and

available for us here. So a gasoline tax would no longer be

available to the government and that might really put a kink in

your plans. There are batteries that go for 100 miles without

recharging and much of this is being held back by vested

interests. We’re being nailed to the wall by a government

agenda that’s going to tax us and use a chunk of fictitious pie in

the sky in the future to grab our money today and push us into a

place that none of us want to live.

the RTP. As we gain more ins

we will update the financial p

amendments and/or subsequ

279‐01 Anonymous When Naresh was starting off with his presentation he was

talking about bond funding for some of this project. What

portion of the overall costs for all of this involves bond funding?

Comment noted. Debt service 

issued and anticipated to be i

horizon of the RTP accounts f

cost.

280‐01 Anonymous I think that overall planning is very important and this is a great

function that must be done. The problem that I see with this

whole thing is that you are embarking on a very expensive

proposition here. You have a shrinking tax base on a federal

basis half the people in the country don’t even pay taxes which

leaves the rest for the middle class to cover. Here in California, I

read last week that in 2008 and 2009 roughly one‐third of the

top two percent of tax payers are what’s at stake. I see our tax

base shrinking and the lady across the room who commented

on the aging population, I think that the tax base is shrinking

and what we’re going to end up is that you’ll find middle class

taxpayers will not be able to afford to live in the state and

they’re going to leave and the 4 million people that you’re

talking about growing in our region will be illegals. The rest of us

will be gone. You’ll have 6 million people come in as illegals and

the rest of us will be gone. At that point, when you dismiss us,

you don’t go into a major expansion program when you’re on

your knees and you’re about ready to choke. That’s the time

that you go back and get yourself healthy again. This economy is

on its knees in California and the economy nationally is on its

knees. I don’t think that the time to start this is now and then

we’ll all be for it.

Comment noted. We recogni

with certainty and therefore 

which were vetted through S

Committee and Policy Comm

the RTP. As we gain more ins

we will update the financial p

amendments and/or subsequ

281‐01 Anonymous I’d like to let you know that I have ridden on the Red Line and it

is very busy. The Orange Line is also very busy and I had to stand

in it which I didn’t mind at the time as I was going to downtown

LA and on a separate occasion I had to go into downtown LA in

my car and had to park at a parking structure and it cost me

Comment noted. The RTP is f

there is sufficient financial inf

projects in the plan can be im

available, or reasonably availa

reasonable assurance that th
510

ID Name Affiliation Comment Re

about $20 to park. The gentlemen who suggested that people

should abandon the rail and alternative modes of transportation

and everyone should have a car well when your population is

swelling and your land is not increasing with the population you

need to come up with a creative solution and everyone can’t be

driving in a car because there’s just no room. If you’ve ever

been on the 101 and 405 exchange then you know that it’s the

second most congested freeway interchange in the country and

possibly would rank high in the world. My question is that the

sustainable communities that started under the Obama

administration that partnered the targeted transportation, the

EPA and HUD. I read recently that because of the lack of funding

that communities were getting funding to improve their

sustainable aspects such as mobility that they are not going to

be doing this anymore until the economy can improve. How do

you think that this will affect the long‐term plan?

transportation system is bein

maintained. We also recogniz

with certainty and we therefo

which were vetted through S

Committee and Policy Comm

to ensure transparency. As w

and the reasonableness of ou

financial plan accordingly thro

subsequent Plan updates as a

is prepared and adopted ever

282‐01 Anonymous The lady in the back mentioned that she had difficulty in getting

to a location like downtown. To answer her question, back in

the 70’s there was something called carpooling. It can still be

done today. If you go on the freeway today, you can see that 90

percent of the vehicles have one person. I realize that if you’re

in business for yourself or a private contractor then you’re going

from one site to another you’re not going to ride with someone

else on the freeway but many people are going to the same

location and if they chose and still keep their freedom. For

those that are challenged financially or otherwise, you can still

carpool. Maybe the state or county should develop a

sophisticated carpool program for its substituents that maybe

would assist the freeway congestion problem that you’re

concerned about.

Comment noted. There is an 

Southern California, operated 

commissions in Los Angeles, O

and Ventura Counties. Visit w

283‐01 Anonymous Do you have a cost/benefit analysis? Was that done with this

plan and if so, how detailed or how specific is it and where’s the

money going?

Comment noted. A benefit‐co

RTP. The investments in the R

every dollar invested. Plan ex

the RTP and appendices and a

Financial Plan. You might also 

the economic impacts of the 

Economic and Job Creation A

284‐01 Anonymous Was there an inflation rate that was built into the projections

that you’re making going out to 2035?

Comment noted. SCAG used 2

constant dollar revenue forec

expenditure) dollars based on 
511

ID Name Affiliation Comment Re

measured by the Gross Dome

an approach consistent with t

of Management and Budget i

United States Government. T

annual inflation factor to esti

capital expenditures based on 

trends measured the by Caltr

index. The faster increase in c

contributes to a decline in pu

funding over the RTP plannin

285‐01 Anonymous What are we using for historical inflation rates? Comment noted. SCAG used 2

constant dollar revenue forec

expenditure) dollars based on 

measured by the Gross Dome

an approach consistent with t

of Management and Budget i

United States Government. T

annual inflation factor to esti

capital expenditures based on 

trends measured the by Caltr

index. The faster increase in c

contributes to a decline in pu

funding over the RTP plannin

286‐01 Anonymous Given all of the quantitative easing that we’ve had just in the

past year and a half and given that there’s going to be more

with what’s going on in Europe I don’t think that you’re inflation

rate will be 2%. I think that we’re probably looking at double

digit minimum that’s going to take these projections out.

Comment noted. We recogni

with certainty and therefore 

which were vetted through S

Committee and Policy Comm

the RTP. As we gain more ins

we will update the financial p

amendments and/or subsequ

At a minimum, an RTP is prep

years.

287‐01 Anonymous If every 4 years you’re making adjustments. Say inflation starts

increasing after 4 years at 3 and by the time that you get to 12

years it’s up 10 percent. We’re no longer looking at a $100M

project. We’re talking about a project that’s going to cost

$150M. Right now, 40% of every dollar that the feds spend is

being borrowed from China. That will increase the way that

things are going. Where are we going to get all of this money?

Comment noted. The Transpo

detailed explanation on all re

288‐01 Anonymous Why would we start on a project when we’re so unhealthy to Comment noted.
512

ID Name Affiliation Comment Re

begin with?

289‐01 Anonymous You said that the money is already there that is being used to do

these projects?

Comment noted. The Transpo

a detailed explanation on all r

RTP.

290‐01 Anonymous That’s not true because already they’re complaining that there’s

no money, no tax revenue, no money coming in to fix roads or

anything else. Secondly, I spoke about the elderly but what I

didn’t bring up is that getting the kids to school, sporting events,

going to church, if you have to count on all of this to get you

places it’s not going to happen.

Comment noted.

291‐01 Anonymous Ok, but what you want to do is tax these same people to use

their own car and to provide the rail and bus system to get

them to where they are.

Comment noted.

292‐01 Anonymous If people are counting on going on trains and buses if it comes

to that then who is going to be there to take these people when

their children, spouse or someone has an emergency. How are

they going to get back and forth?

Comment noted.

293‐01 Anonymous My understanding is that part of the SCAG process is taking

place because of federal grant money that has come down to

the states, to the cities. Is that correct?

Comment noted. SCAG is fun

Department of Transportatio

funds.

294‐01 Anonymous Where is the money for the planners and the presenters and

the developers of this RTP coming from?

Comment noted. SCAG is fun

Department of Transportatio

member agency dues.

295‐01 Anonymous So every time this plan is revisited, which is every 4 years, it’s an

increasing if nothing else in planning cost that involves a great

many people. Is that correct?

Comment noted. The RTP is a 

Therefore, these planning eff

the U.S. Department of Trans

and member agency dues. Ho

required per state law which 

absorbs these cost through o

planning over the years have 

296‐01 Anonymous I guess that what I’m getting at is that under the circumstances,

we know that our state is in debt and we know that we don’t

have the money to do it. We know that we don’t have the

money to revisit it every 4 years so why not find something

realistic based on the economy that we currently have and the

knowledge that it will take at least 10 years for the economy to

take an upturn so that there are some additional taxpayer funds

spent for revisiting these plans.

Comment noted. We recogni

and the nation continue to slo

Recession. However, the RTP 

stretches to 2035. There will 

economic cycles over the cou

economic conditions have va

years. We recognize that the 

certainty and therefore we m

which were vetted through S
513

ID Name Affiliation Comment Re

Committee and Policy Comm

the RTP. As we gain more ins

we will update the financial p

amendments and/or subsequ

297‐01 Anonymous Are those all green projects under the international codes? Comment noted. SB 375 does 

land use policies and regulati

design guidelines, need to be 

While the SCS is intended to p

foundation that local governm

choose and generally include

projections from each city an

jurisdictions maintain local la

298‐01 Anonymous It does have to do with SCAG because they have speakers, they

have joint projects and I have newspaper articles. SCAG is very

involved in that and it’s how you’re set up.

Comment noted.

299‐01 Anonymous Regarding the whole plan. The way that the pictures are

represented seems to indicate that there’s going to be a

complete change in terms of our housing development or

commercial development and it’s all kind of vertically

concentrated so that you can walk out and catch a train or go

wherever you’re going to go. That has to go hand in hand with

maintaining the roadways and all those other things that you

plan on doing. When I drive from San Diego to LA to here,

there’s a constant city after city.

Comment noted. The 2012 RT

transportation and land use s

large and diverse region. Ope

existing highway system is a c

300‐01 Anonymous Please name me a city that you are talking about that we can

look at.

Comment noted. Examples of 

Plan are occurring in a myriad 

of the SCAG region.

301‐01 Anonymous We all know that bike lanes and streets are very dangerous

because many cars and trucks can’t see the bikers and the

bikers don’t follow many rules of the law of the road like cars

do. Someone mentioned bike lanes and these sidewalks. This is

very dangerous to pedestrians because I almost got killed in

Amsterdam because bikes ride in both directions on the

sidewalk. Again, it comes down to the elderly who can’t hear

the bicycles and sometimes can’t see them if they’re coming

from behind so please take that into consideration.

Comment noted. The RTP inc

Appendix which contains poli

safety issues.

302‐01 Anonymous Revolving around the issue but I know that we’ve all heard of

Agenda 21 and right here is a book that says something about

environmental justice and if you go to the Agenda 21 page it has

Comment noted. Considerati

transportation planning proce

Rights Act of 1964 (Title VI). T
514

ID Name Affiliation Comment Re

the exact same wording that you have in your book as it does in

Agenda 21 which is an international agenda for development.

You are all taking it straight from the science and you’re putting

out this thing to our country. That’s not what this country was

built on and all of you that are doing this consciously know that

you’re eroding our freedoms and your own freedoms. If you

may not know this then you need to go onto the website.

transportation agencies to dis

and burdens of proposed pro

VI states that “No person in t

ground of race, color or natio

participation in, be denied th

discrimination under any prog

financial assistance.” As a gov

federal funding, SCAG is requ

justice analysis for its Regiona

303‐01 Anonymous We’re going to spend a billion dollars an acre to go through an

expensive area rather than a ten‐thousand an acre to go

through a poor area?

Comment noted.