INPUT

COMMUNITY

SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

PUBLIC 

PARTICIPATION AND

CONSULTATION

ADOPTED I APRIL 2016

SUB APPENDIX PART 1 OF 5

Comments and Responses
ADOPTED I APRIL 2016

SUB APPENDIX PART 1 OF 5

COMMUNITY INPUT I PUBLIC PARTICIPATION AND CONSULTATION

COMMENTS AND RESPONSES
PUBLIC PARTICIPATION AND CONSULTATION INDEX

SUB APPENDIX PART 1 OF 5

Comments and Responses - ALPHABETICALLY

Affiliation Submittal ID Page #

Albert Perdon and Associates 16166; 16167; 16182; 16211; 16212; 16213; 16233 7

Alliance for a Healthy Orange County 16317; 16318 13

Alliance for a Regional Solution to Airport Congestion 16284; 16289;16291 21

Banning Ranch Conservancy 16241 27

Bel Air Skycrest Property Owner's Association 16173 27

Bolsa Chica Land Trust 16247 28

Building Industry Association of Southern California 16364 30

California Construction and Industrial Materials Association 16294 32

California Cultural Resources Preservation Alliance 16302 32

California Department of Transportation 16147; 16307; 16308; 16313; 16319; 16323;16370 34

California High Speed Rail Authority 16328 47

California Native Plant Society – Orange County Chapter 16231 49

California State Legislature 16287 52

Center for Demographic Research 16189; 16190; 16191; 16193; 16194;16237 52

City of Alhambra 16146 68

City of Anaheim 16248 68

City of Calimesa 16044 68

City of Claremont 16340 69

City of Diamond Bar 16345 69

City of Eastvale 16304 70

City of El Segundo 16305 71

City of Glendale 16341 73

City of Irvine* 16306; 16366; 16367 74

City of Irwindale 16171 77

City of La Cañada Flintridge 16333 77

City of La Habra 16049 77

City of Laguna Niguel 16335 78

City of Lake Forest 16309 78

City of Los Angeles 16262 78

City of Los Angeles – Department of City Planning 16155 79

1
PUBLIC PARTICIPATION AND CONSULTATION

SUB APPENDIX PART 1 OF 5

Comments and Responses - ALPHABETICALLY

INDEX

Affiliation Submittal ID Page #

City of Los Angeles – Department of Transportation 16178; 16192; 16215 85

City of Mission Viejo 16275 87

City of Montclair 16332 87

City of Monterey Park 16136 88

City of Moreno Valley 16060; 16061 88

City of Rancho Mirage 16174 89

City of Riverside 16069; 16246 90

City of San Clemente* 16311 90

City of San Gabriel 16342 92

City of Santa Clarita 16334 92

City of Santa Paula 16197 94

City of South Pasadena 16214; 16221 94

City of Tustin* 16310 104

Climate Plan 16327 105

Cyrus Planning 16208 106

Eastern Coachella Valley Coalition 16325 107

Encino Neighborhood Council 16052; 16076; 16176 111

Endangered Habitats League 16250 112

Environmental Coalition Support for Natural and Farmland Policies 16255 113

Five Point Communities 16315 115

Friends of Harbors Beaches and Parks 16330; 16331 116

Gateway Cities Council of Governments 16266 122

Golden State Gateway Coalition 16165 123

Grants To You 16024 123

Highgrove Municipal Advisory Council 16175; 16338 125

Hills for Everyone 16170 126

Imperial County Transportation Commission 16188; 16351 128

Inland Action 16140; 16352 128

Inland Empire Biking Alliance 16138; 16157; 16239; 16329 129

John Wayne Airport 16219 136

La Habra 2025 16163 137

Laguna Canyon Foundation 16280 138

2
PUBLIC PARTICIPATION AND CONSULTATION

SUB APPENDIX PART 1 OF 5

Comments and Responses - ALPHABETICALLY

INDEX

Affiliation Submittal ID Page #

Laguna Greenbelt, Inc. 16281 139

Latham and Watkins LLP 16316; 16336 140

Leadership Counsel for Justice and Accountability 16354 140

Letterly Environmental and Land Planning Management 16272 142

Local Agency Formation Commission for San Bernardino County 16282 142

Los Angeles Area Chamber of Commerce 16273 142

Los Angeles County Business Federation 16286 152

Los Angeles County – Department of Public Health 16264; 16292 143

Los Angeles County – Department of Regional Planning 16254 145

Los Angeles County – Metropolitan Transportation Authority 16183; 16184; 16185 145

Los Angeles World Airports 16372 153

Los Cerritos Wetlands Trust 16293 153

March Joint Powers Authority 16210 154

Metro Gold Line Foothill Extension Construction Authority 16337 155

Move LA 16349 156

National Trust for Historic Preservation 16298 156

Naturalist For You 16278 158

No 710 Action Committee 16301 160

Ontario Chamber of Commerce 16355 161

Orange County Bicycle Coalition 16022 162

Orange County Business Council 16297 162

Orange County Council of Governments* 16296 164

Orange County Health Care Agency* 16251 167

Orange County League of Conservation Voters 16169 168

Orange County Public Works* 16299 169

Orange County Transportation Authority 16059 172

Port of Hueneme 16180 174

Port of Los Angeles 16164 175

PTS Staffing Solutions 16067 176

Public Health Alliance of Southern California 16230 177

Puente Chino Hills Task Force Sierra Club 16168 182

3
PUBLIC PARTICIPATION AND CONSULTATION

SUB APPENDIX PART 1 OF 5

Comments and Responses - ALPHABETICALLY

INDEX

Affiliation Submittal ID Page #

Redlands Tea Party Patriots 16055 182

Riverside County Transportation Commission 16244; 16245 183

Rural Canyons Conservation Fund 16236 188

Saddleback Canyons Conservancy 16227 189

Safe Routes to School National Partnership 16321; 16322; 16356; 16359 191

San Bernardino Associated Governments 16181 199

San Gabriel Valley Council of Governments 16232 204

Sea and Sage Audubon Society 16225 206

Sequoyah School 16268 207

Sherman Oaks Homeowners Association 16160; 16161 207

Skirball Cultural Center 16172 208

South Bay Cities Council of Governments 16343 208

Southern California Gas Company 16295 210

Southern California Leadership Council 16290 216

SR 60 Coalition 16288 216

Transportation Corridor Agencies 16187 217

United States Environmental Protection Agency 16285; 16371 218

Ventura County 350 HUB 16274 220

Ventura County Air Pollution Control District 16257 228

Ventura County Planning Division 16235 220

Ventura County Public Works 16369 229

Ventura Hillsides Conservancy 16344 230

Western Riverside Council of Governments 16324 232

XpressWest 16320 233

5-Cities Alliance 16339 236

*To review responses to comments provided within the RTP/SCS matrix provided within this letter, please view responses to the 

Center of Demographic Research’s comments (the first letter that was received containing the RTP/SCS matrix).

4
PUBLIC PARTICIPATION AND CONSULTATION

SUB APPENDIX PART 1 OF 5

Comments and Responses - ALPHABETICALLY

INDEX

No Affiliation/Individuals Submittal ID Page #

Margarita Assael 16056 238

Enrique Ayala 16050 238

Fabricio Bautista 16209 238

Keshav Boddula 16141 239

Lana Butler 16125 239

Michael Cahn 16021 240

Tressy Capps 16303; 16350; 16353; 16361 240

Bruce Culp 16252; 16260 245

Sally Dhahbi 16062 245

Joyce Dillard 16312 246

Hank Fung 16020; 16238; 16348 247

Victor Gar 16126 250

John Paul Garcia 16360 250

Om Garg 16346 251

Jeffrey Giba 16347 251

Whitley Gilbert 16053 251

Terry Goller 16224 252

Ezequiel Gutierrez 16314 253

Eileen Harris 16216 254

Patricia Bell Hearst 16228 254

Richard Helgeson 16326 254

Robin Hvidston 16222 255

Anna Jaiswal 16128 257

Thomas Jatich 16127 257

Mark Jolles 16199; 16200; 16201; 16202; 16203;

16204; 16205; 16207; 16263

258

Dolly Leland 16363 267

Robert Newman 16300 267

Pat Nig 16198 268

Kirsty Norman 16139 268

Eva OKeefe 16158 269

Bill Oliver 16051 269

5
PUBLIC PARTICIPATION AND CONSULTATION

SUB APPENDIX PART 1 OF 5

Comments and Responses - ALPHABETICALLY

INDEX

No Affiliation/Individuals Submittal ID Page #

Betty Robinson 16253 270

Vivian Romero 16362 271

Irene Sandler 16226 273

Melody Segura 16054 273

Kristi Snyder 16057 274

Cari Swan 16269 275

Ann Tarkington 16365 275

Carol Teutsch 16162 276

Vicki Tripoli 16195 277

Janet West 16229 277

Anonymous 16357 277

Anonymous 16358 279

6
2016 RTP/SCS Comments and Responses

holdID Comment Response 

Submitted by Albert Perdon and Associates Submittal 16166 Related Documents

16166.01 The following input is provided in response to the invitation to submit comments on the 

Draft 2040 RTP/SCS. On March 14, 2014 a Brief was submitted to 

Ms. Deena C. Fawcett, Clerk/Administrator, Office of the Clerk, 

Court of Appeal, Third Appellate District State of California, 914 Capitol Mall 

Sacramento, CA 95814‐4814    

Re: California High‐Speed Rail Authority et al. v. The Superior Court of Sacramento, County, 

C075668 

Sacramento County Nos. 34201100113919CUMCGDS, 342011300140689CUMCGDS. A copy 

of this Brief was filed with Stephanie Fong Zook, Office of the State Attorney General. This 

Brief outlined a strategy for addressing the economic and environmental issues regarding 

the California High Speed Train Project. It presents an alternative land use and 

transportation alternative aimed at meeting the law established with voter passage of the 

2008 Proposition 1A High Speed Train bond measure. The Brief presents a transportation 

and land development strategy for meeting air quality attainment goals. The focus of this 

strategy is to accommodate a significant increase in population while achieving a net 

reduction in air emissions and auto traffic. It achieves this result by eliminating the need for 

many millions of people to own and operate an automobile for commuting and other 

purposes. It focuses growth into very high-density "sky cities" integrated with high-speed 

train service and other local transit services. As the Brief reveals, this result can be 

accomplished using conventional value capture strategies employed in numerous locations 

throughout California. It is expected that SCAG will identify this growth strategy in the draft 

and final SRTP/SCS EIR/EIS as a viable alternative for adoption by the SCAG Regional Council.

Comment noted. One of the 2016 RTP/SCS land use strategies is to focus new growth 

around transit. Land use policy around transit stations and amenities fall under the 

authority of the local governing jurisdiction. The SCS and SB 375 do not require a 

jurisdiction’s land use policies and regulations, including its general plan, be consistent 

with the SCS. While the SCS is intended to provide a regional policy foundation that local 

governments may build upon if they so choose, it is clear that local jurisdictions maintain 

local land use authority.

7
holdID Comment Response 

Submitted by Albert Perdon and Associates Submittal 16167 Related Documents Link

16167.01 The following input is provided in response to the invitation to submit comments on the 

Draft 2040 RTP/SCS. On March 14, 2014 a Brief was submitted to Ms. Deena C. Fawcett, 

Clerk/Administrator, Office of the Clerk, Court of Appeal, Third Appellate District State of 

California, 914 Capitol Mall, Sacramento, CA 95814‐4814, Re: California High‐Speed Rail 

Authority et al. v. The Superior Court of Sacramento, County, C075668 Sacramento County 

Nos. 34201100113919CUMCGDS, 342011300140689CUMCGDS. A copy of this Brief was 

filed with Stephanie Fong Zook, Office of the State Attorney General. This Brief outlined a 

strategy for addressing the economic and environmental issues regarding the California 

High Speed Train Project. A Power Point Presentation was prepared that describes the 

central points contained within the Brief. As in the Brief, the Power Point Presentation 

presents an alternative land use and transportation alternative aimed at meeting the law 

established with voter passage of the 2008 Proposition 1A High Speed Train bond measure. 

The presentation presents a transportation and land development strategy for meeting air 

quality attainment goals. The focus of this strategy is to accommodate a significant increase 

in population while achieving a net reduction in air emissions and auto traffic. It achieves 

this result by eliminating the need for many millions of people to own and operate an 

automobile for commuting and other purposes. It focuses growth into very high-density 

"sky cities" integrated with high-speed train service and other local transit services. As the 

presentation reveals, this result can be accomplished using conventional value capture 

strategies employed in numerous locations throughout California. It is expected that SCAG 

will include this presentation in the public hearing record for the draft and final SRTP/SCS 

EIR/EIS for adoption by the SCAG Regional Council as a viable alternative for adoption.

Comment noted. One of the 2016 RTP/SCS land use strategies is to focus new growth 

around transit. Land use policy around transit stations and amenities fall under the 

authority of the local governing jurisdiction. The SCS and SB 375 do not require a 

jurisdiction’s land use policies and regulations, including its general plan, be consistent 

with the SCS. While the SCS is intended to provide a regional policy foundation that local 

governments may build upon if they so choose, it is clear that local jurisdictions maintain 

local land use authority.

8
holdID Comment Response 

Submitted by Albert Perdon and Associates Submittal 16182 Related Documents Link

16182.01 The following input is provided in response to the invitation to submit comments on the 

Draft 2040 Regional Transportation Plan/Sustainable Community Strategy (the Plan) and on 

the 2016PEIR. People are frustrated. Traffic continues to increase, making it more difficult 

to get around. Housing is less affordable today than in the past, especially for people in 

middle and lower income brackets. Neighborhoods are being overrun by increased density 

that destroys the character of the communities people have lived in for years. Billions of 

tax-payer dollars have gone into expanding freeways and building transit lines, yet 

congestion is getting worse. Hundreds of billions more have been spent in private dollars to 

maintain a car-dependent transportation system that cannot possibly keep up with a 

growing demand. On January 1, 2016, the Los Angeles Times reports in “Carmageddon 

West” that, “Another traffic nightmare is shaping up near downtown L.A. A 55-hour street 

closure in the heart of downtown Los Angeles this weekend is sure to bring some major 

headaches for drivers.” Carmageddon West is a major headache for millions of daily 

commuters throughout Southern California – including on weekends. Multiple 

transportation plans aimed at securing increased tax support with promises of improved 

traffic flow have failed to deliver on the promises. There is an opportunity to reverse past 

and current trends by adopting a more effective transportation plan and an improved 

community development strategy – a strategy that increases wealth and prosperity for 

people throughout the region. The opportunity lies in the inherent power of local citizens 

and their local city leaders to take charge of their own destiny by reducing reliance on 

established federal, state and regional authorities. This strategy is described in the 

accompany presentation prepared for the cities of Bellflower and Paramount, California. It 

offers a formula for achieving greater prosperity that can be applied to other cities as well. 

A major benefit of this strategy is a dramatic reduction in air emissions. It is expected that 

SCAG will include this presentation in the public hearing record for the draft and final 

SRTP/SCS PEIR/PEIS to be adopted by the SCAG Regional Council, and deem it to be a viable 

alternative for consideration.

Comment noted. One of the 2016 RTP/SCS land use strategies is to focus new growth 

around transit. Land use policy around transit stations and amenities fall under the 

authority of the local governing jurisdiction. The SCS and SB 375 do not require a 

jurisdiction’s land use policies and regulations, including its general plan, be consistent 

with the SCS. While the SCS is intended to provide a regional policy foundation that local 

governments may build upon if they so choose, it is clear that local jurisdictions maintain 

local land use authority.

9
holdID Comment Response 

Submitted by Albert Perdon and Associates Submittal 16211 Related Documents Link

16211.01 The following input is provided in response to the invitation to submit comments on the 

Draft 2016-2040 Regional Transportation Plan (RTP)/Sustainable Communities Strategy 

(SCS) and 2016 PEIR. The attached Power Point Presentation describes a transit and city 

development alternative that will have significant benefit in resolving growth, 

transportation and land development issues. SCAG needs to consider and incorporate the 

strategies presented in this presentation in preparing the final RTP and PEIR documents. 

The recommendation goes well beyond the approach that SCAG has presented in its prior 

and current plans. The region will not attain achievable air quality mandates unless a large 

majority of growth is accommodated in a manner that eliminates the need for travel by an 

automobile. As described in this presentation, such an approach is viable and costeffective. The presentation centers on an integrated plan for very high-density housing and 

high-speed transportation along the segment of the California High Speed Train corridor 

from Ontario to the U.S.-Mexico border at Chula Vista and Tijuana. Development of this 

corridor improvement resolves a major deficiency with the State’s current plan for the 

California High-Speed Train project. The State has not developed a viable funding plan for 

this corridor segment, let alone for the northerly segments to the San Francisco Bay Area or 

Sacramento. The presentation was prepared following extensive analysis during the period 

2010 to 2013. The study results are based on the data available at that time. Events 

occurring since then have not changed the nature or strength of the recommendations 

contained in this presentation. It is expected that SCAG will include this presentation in the 

public hearing record for the draft and final RTP/SCS and PEIR/PEIS to be adopted by the 

SCAG Regional Council, and deem it to be a viable alternative for consideration.

Comment noted. One of the 2016 RTP/SCS land use strategies is to focus new growth 

around transit. Land use policy around transit stations and amenities fall under the 

authority of the local governing jurisdiction. The SCS and SB 375 do not require a 

jurisdiction’s land use policies and regulations, including its general plan, be consistent 

with the SCS. While the SCS is intended to provide a regional policy foundation that local 

governments may build upon if they so choose, it is clear that local jurisdictions maintain 

local land use authority. The California High-Speed Rail Authority is the lead agency 

responsible for planning, designing, funding, implementing and operating the California 

High-Speed Train (CA HST). The 2016 RTP/SCS includes Phase One of the CA HST in the 

financially constrained plan however Phase Two, which is Los Angeles to San Diego in the 

SCAG region, is financially unconstrained and is in the 2016 RTP/SCS strategic plan.

10
holdID Comment Response 

Submitted by Albert Perdon and Associates Submittal 16212 Related Documents Link

16212.01 The following input, in the form of the attached Power Point Presentation, is provided in 

response to the invitation to submit comments on the Draft 2016-2040 Regional 

Transportation Plan (RTP)/Sustainable Communities Strategy (SCS) and 2016 PEIR. The 

SCAG Regional Council is urged to consider this presentation entitled “Sliced Peaches” as it 

finalizes the development and approval of the 2016-2040 RTP and 2016 PEIR/PEIS.

Comment noted. SCAG respects the local jurisdictions' land use authority, and maintains 

that all land use authority remains with the local jurisdictions. Land use strategies in the 

RTP/SCS are based on the five (5) guiding principles approved by the Regional Council on 

November 5, 2015. These guiding principles were utilized for the Policy Growth Forecast 

(PGF). The PGF envisions future regional growth that is coordinated with the 

transportation system improvements of the approved in the previous 2012 RTP/SCS, as 

well as anticipated new transportation projects planned by the region’s CTCs and transit 

providers. It also incorporates best practices for increasing transportation choices, 

reducing our dependence on personal automobiles, allowing future growth in walkable, 

mixed-use communities and in HQTAs, and further improving air quality. The guiding 

principles below served as the basis for developing the PGF: • Principle #1: The Draft PGF 

for the 2016 RTP/SCS shall be adopted by the Regional Council at the jurisdictional level, 

thus directly reflecting the population, household and employment growth projections 

derived from the local input and previously reviewed and approved by SCAG’s local 

jurisdictions. The PGF maintains these projected jurisdictional growth totals, meaning 

future growth is not reallocated from one local jurisdiction to another. • Principle #2: The 

Draft PGF at the Transportation Analysis Zone (TAZ) level is controlled to be within the 

density ranges of local general plans or input received from local jurisdictions in this most 

recent round of review. • Principle #3: For the purpose of determining consistency for 

CEQA, lead agencies such as local jurisdictions have the sole discretion in determining a 

local project's consistency with the 2016 RTP/SCS. • Principle #4: TAZ level data or any 

data at a geography smaller than the jurisdictional level is included in the Draft PGF only to 

conduct the required modeling analysis and is therefore, only advisory and non-binding 

because SCAG’s sub-jurisdictional forecasts are not to be adopted as part of the 2016 

RTP/SCS. After SCAG’s adoption of the PGF at the jurisdictional level, the TAZ level data 

may be used by jurisdictions in local planning as it deems appropriate and there is no 

obligation by a jurisdiction to change its land use policies, General Plan, or regulations to 

be consistent with the RTP/SCS. SCAG staff plans to monitor the use of this data after the 

adoption of the RTP/SCS to encourage appropriate use. • Principle #5: SCAG staff 

continues to communicate with other agencies who use SCAG sub-jurisdictional level data 

to ensure that the “advisory & non-binding” nature of the dataset is appropriately 

maintained. SCAG established the PGF based on the guiding principles in order to provide 

maximum flexibility for the local jurisdictions. It is the direction of the Regional Council to 

maintain local land use authority, and providing supportive local policies goes beyond 

SCAG’s authority. The six Land Use Strategies the PGF is based on are meant to provide a 

foundation for local jurisdictions to implement the vision of the RTP/SCS. The 2016 

RTP/SCS reaffirms the 2008 Advisory Land Use Policies that were incorporated into the 

2012 RTP/SCS. These foundational policies, which have guided the development of this 

Plan’s strategies for land use, are: • Identify regional strategic areas for infill and 

investment; • Structure the plan on a three-tiered system of centers development; • 

Develop “Complete Communities”; • Develop nodes on a corridor; • Plan for additional 

housing and jobs near transit; • Plan for changing demand in types of housing; • Continue 

to protect stable, existing single-family areas; • Ensure adequate access to open space and 

preservation of habitat; and • Incorporate local input and feedback on future growth.

11
holdID Comment Response 

Submitted by Albert Perdon and Associates Submittal 16213 Related Documents Link

16213.01 The following input is provided in response to the invitation to submit comments on the 

Draft 2016-2040 Regional Transportation Plan (RTP)/Sustainable Communities Strategy 

(SCS) and 2016 PEIR. The attached Power Point Presentation describes a transit and city 

development alternative that will have significant benefit in resolving growth, 

transportation and land development issues. SCAG needs to consider and incorporate the 

strategies presented in this presentation in preparing the final RTP and PEIR documents. 

The recommendation goes well beyond the approach that SCAG has presented in its prior 

and current plans. The region will not attain achievable air quality mandates unless a large 

majority of growth is accommodated in a manner that eliminates the need for travel by an 

automobile. As described in this presentation, such an approach is viable and costeffective. The presentation centers on an integrated plan for very high-density housing and 

high-speed transportation along the segment of the California High Speed Train corridor 

from Ontario to the U.S.-Mexico border at Chula Vista and Tijuana. Development of this 

corridor improvement resolves a major deficiency with the State’s current plan for the 

California High-Speed Train project. The State has not developed a viable funding plan for 

this corridor segment, let alone for the northerly segments to the San Francisco Bay Area or 

Sacramento. The presentation was prepared following extensive analysis during the period 

2010 to 2013. The study results are based on the data available at that time. Events 

occurring since then have not changed the nature or strength of the recommendations 

contained in this presentation. It is expected that SCAG will include this presentation in the 

public hearing record for the draft and final RTP/SCS and PEIR/PEIS to be adopted by the 

SCAG Regional Council, and deem it to be a viable alternative for consideration.

Comment noted. One of the 2016 RTP/SCS land use strategies is to focus new growth 

around transit. Land use policy around transit stations and amenities fall under the 

authority of the local governing jurisdiction. The SCS and SB 375 do not require a 

jurisdiction’s land use policies and regulations, including its general plan, be consistent 

with the SCS. While the SCS is intended to provide a regional policy foundation that local 

governments may build upon if they so choose, it is clear that local jurisdictions maintain 

local land use authority. The California High-Speed Rail Authority is the lead agency 

responsible for planning, designing, funding, implementing and operating the California 

High-Speed Train (CA HST). The 2016 RTP/SCS includes Phase One of the CA HST in the 

financially constrained plan however Phase Two, which is Los Angeles to San Diego in the 

SCAG region, is financially unconstrained and is in the 2016 RTP/SCS strategic plan.

12
holdID Comment Response 

Submitted by Albert Perdon and Associates Submittal 16233 Related Documents Link

16233.01 The following input is provided in response to the invitation to submit comments on the 

Draft 2016-2040 Regional Transportation Plan (RTP)/Sustainable Communities Strategy 

(SCS) and 2016 PEIR. The attached Power Point Presentation describes a transit and city 

development alternative that will have significant benefit in resolving growth, 

transportation and land development issues. SCAG needs to consider and incorporate the 

strategies presented in this presentation in preparing the final RTP and PEIR documents. 

The recommendation goes well beyond the approach that SCAG has presented in its prior 

and current plans. The region will not attain achievable air quality mandates unless a large 

majority of growth is accommodated in a manner that eliminates the need for travel by an 

automobile. As described in this presentation, such an approach is viable and costeffective. The presentation centers on an integrated plan for very high-density housing and 

high-speed transportation along the segment of the California High Speed Train corridor 

from Ontario to the U.S.-Mexico border at Chula Vista and Tijuana. Development of this 

corridor improvement resolves a major deficiency with the State’s current plan for the 

California High-Speed Train project. The State has not developed a viable funding plan for 

this corridor segment, let alone for the northerly segments to the San Francisco Bay Area or 

Sacramento. The presentation was prepared following extensive analysis during the period 

2010 to 2013. The study results are based on the data available at that time. Events 

occurring since then have not changed the nature or strength of the recommendations 

contained in this presentation. It is expected that SCAG will include this presentation in the 

public hearing record for the draft and final RTP/SCS and PEIR/PEIS to be adopted by the 

SCAG Regional Council, and deem it to be a viable alternative for consideration.

Comment noted. One of the 2016 RTP/SCS land use strategies is to focus new growth 

around transit. Land use policy around transit stations and amenities fall under the 

authority of the local governing jurisdiction. The SCS and SB 375 do not require a 

jurisdiction’s land use policies and regulations, including its general plan, be consistent 

with the SCS. While the SCS is intended to provide a regional policy foundation that local 

governments may build upon if they so choose, it is clear that local jurisdictions maintain 

local land use authority. The California High-Speed Rail Authority is the lead agency 

responsible for planning, designing, funding, implementing and operating the California 

High-Speed Train (CA HST). The 2016 RTP/SCS includes Phase One of the CA HST in its 

financially constrained plan. Phase Two, which is from Los Angeles Union Station to San 

Diego, is not funded and is contained in the strategic unconstrained plan for informational 

purposes only.

Submitted by Alliance for a Healthy Orange County Submittal 16317 Related Documents Link

16317.01 1) Safety of active transportation users. Because SCAG’s short trips strategies—which AHOC 

completely supports—focus on the large (33%) proportion of all trips made, safety of active 

transportation users needs to be more prominently discussed, especially within the context 

of Orange County’s high speed arterials and the Caltrans’ new separated bikeways 

standards (DIB 89, released 2015-12-30). Since SCAG states on page 90 that regional 

arterials comprise 80% of the total road network and carry most traffic overall, addressing 

safety of pedestrians on bicyclists on those roads is operationally essential to the entire 

system. Additionally, since transportation to and from school comprises 1/4 to 1/3 of all 

average daily trips, we can’t emphasize enough the operational and equitable significance 

of prioritizing safe routes to school for our children.

Comment noted. SCAG understands the importance of safety in which one of the notable 

goals of the 2016 RTP/SCS is to ensure travel safety and reliability for all people and goods 

in the region. Chapter 5 of the RTP/SCS includes several strategies as a means towards 

improving safety and security for all people and goods throughout the region. In addition, 

as part of the highways and arterials strategies, SCAG continues to support complete 

streets and opportunities where feasible and practical.

16317.02 2) More funding is needed for safe walking and biking facilities, especially on high speed 

Orange County arterial roadways.

Comment noted. The 2016 RTP/SCS is a fiscally constrained multi-modal transportation 

plan. While funding for active transportation is doubled from the previous RTP/SCS, SCAG 

recognizes more needs to be done. The Plan Implementation section of the Active 

Transportation Appendix includes strategies designed to develop additional funding 

solutions to help meet active transportation needs beyond what is in the 2016 RTP/SCS..

13
holdID Comment Response 

Submitted by Alliance for a Healthy Orange County Submittal 16317 Related Documents Link

16317.03 a. CalTrans’ new separated bikeway design criteria (DIB 89) states a concrete barrier should 

be used on roadways with speed limits greater than 35 mph. Yet the cost of Class 1 

segregated facilities is approximately $1M/mile to build, so the number of such projects 

that can be built for the $10B planned for active transportation construction is not 

sufficient from a public safety or transportation capacity perspective.

Comment noted. The 2016 RTP/SCS is a fiscally constrained multi-modal transportation 

plan. While funding for active transportation is doubled from the previous RTP/SCS, SCAG 

recognizes more needs to be done. The Plan Implementation section of the Active 

Transportation Appendix includes strategies designed to develop additional funding 

solutions to help meet active transportation needs beyond what is in the 2016 RTP/SCS.

16317.04 b. If we are to reduce the vehicle load on the entire network, we need to prioritize funding 

for more efficient, non-motorized modes of travel over short distances. The a.t. funding 

proposed by SCAG is in sufficient to accomplish the needed reduction in vehicle load.

Comment noted. The 2016 RTP/SCS is a fiscally constrained multi-modal transportation 

plan. While funding for active transportation is doubled from the previous RTP/SCS, SCAG 

recognizes that more needs to be done. The Plan Implementation section of the Active 

Transportation Appendix includes strategies designed to develop additional funding 

solutions to help meet active transportation needs beyond what is in the 2016 RTP/SCS.

16317.05 3) We should not represent active transportation expenditures without including discussion 

of balancing those investments with long term cost savings in health care, facility 

maintenance, and congestion relief and prevention.

Comment noted. SCAG is working to better develop data and tools that will help identify 

the benefits of active transportation.

16317.06 b. The 2016 RTP/SCS does not compare the cost of building safe walking and biking 

infrastructure to the cost of caring for people afflicted with preventable chronic diseases. 

With the fraction of national GDP spent on healthcare being 18% and projected to grow to 

34% by 2040, these types of comparisons must be prominently discussed at all levels of 

government.

Comment noted. SCAG is currently in the process of monetizing the health benefits of 

active transportation. The analysis will be incorporated into future presentations for 

discussion with policy makers.

16317.07 a. Costs of active transportation investment are recoupable, whereas long-term healthcare 

costs are increasingly unsustainable.

Comment noted.

16317.08 c. Data discussion in the Public Health appendix must be included in the main document to 

provide decision makers with real cost comparisons. For example, the appendix, page 8, 

cites the Milken Institute projections that $117B of the $431B in 2023 health care costs 

statewide could be avoided through prevention; physical inactivity and obesity are 

estimated to have cost $41.2B in 2006 statewide.

Comment noted. Health care costs are mentioned in the main document briefly on page 

55. Additional information has been included in the main document of the final Plan. 

However, the main document is intended to summarize findings from the appendices. The 

reader should refer to the appendices for more details.

16317.09 d. Comparing the latter to the extremely small funding allocated to active transportation 

construction, $10B over the life of the 2016 RTP/SCS, the investment in safe walking and 

biking infrastructure, along with access to convenient public transit, is an entirely 

recoupable cost. In fact, for $41.2B we could build 41,200 miles of protected, Class 1 

pedestrian and bicycle paths, the type of facility most people want to use. We need to 

present those kinds of comparisons so all decision makers will be empowered to make 

informed choices on our behalf.

Comment noted.

16317.10 e. Based on OCTA’s Outlook 2035 projections, time for physical activity will diminish over 

the next 20 years, as the average motorist commute will increase by 166%, making a 30 

minute commute become 80 minutes each way. Roundtrip, Orange County residents will 

spend 2 hours, 40 minutes of every day in their cars driving to and from work. Under those 

conditions, the likelihood of a wholesome diet and exercise are not good, particularly not 

for families with children. We are concerned the consumption of fast and unhealthful food 

will become the norm simply because the transportation system doesn’t allow time for 

better choices.

Comment noted. The Draft 2016 RTP/SCS projects that commute times to work will 

decrease for all modes regionwide compared to baseline. This will be made possible in 

part through land use changes and transit and active transportation investments that 

encourage shorter trips, which can be accomplished by active modes such as walking and 

bicycling.

14
holdID Comment Response 

Submitted by Alliance for a Healthy Orange County Submittal 16317 Related Documents Link

16317.11 The “Highways and Arterials” section (beginning on page 95) overemphasizes management 

of the vehicular system and its bottlenecks while ignoring the operational and equitable 

necessity of safe pedestrian and bicycle travel. The vehicular-centric discussion of highways 

and arterials is inconsistent with its first paragraph stating “costly expansions to address 

congestion are no longer financially feasible.”

Comment noted. The six-county SCAG region is a vast and diverse region, geographically as 

well as demographically. Accordingly, the 2016 RTP/SCS recognizes that 'one size fits all' 

approach will not work for our region. So, the plan is multi-modal and aims to address 

transportation needs of all segments of our society across our expansive region by 

expanding and enhancing travel choices. The plan creates opportunities to engage in 

healthy and active lifestyle through significant increase in investment in Active 

Transportation modes. At the same time, the plan also recognizes that over 90 percent of 

the trips will continue to rely on our roadways, particularly in places like Riverside and San 

Bernardino counties. So, strategic improvements to our roadways to improve safety and 

congestion must be a part of any sensible long term plan. Furthermore, it should be noted 

that many of these roadway improvement projects are part of the commitment made by 

the counties to their residents in passing the local option sales tax measures that fund 

many of these projects.

16317.12 a. “SCAG continues to advocate for a comprehensive solution based on a system 

management approach . . . ” It’s not comprehensive if it’s not equitably multimodal. (see 

page 95)

Comment noted. The six-County SCAG region is a vast and diverse region, geographically 

as well as demographically. Accordingly, the 2016 RTP/SCS recognizes that 'one size fits all' 

approach will not work for our region. So, the plan is multi-modal and aims to address 

transportation needs of all segments of our society across our expansive region by 

expanding and enhancing travel choices. The plan creates opportunities to engage in 

healthy and active lifestyle through significant increase in investment in Active 

Transportation modes. At the same time, the plan also recognizes that over 90 percent of 

the trips will continue to rely on our roadways, particularly in places like Orange County. 

So, strategic improvements to our roadways to improve safety and congestion must be a 

part of any sensible long term plan. Furthermore, it should be noted that many of these 

roadway improvement projects are part of the commitment made by the counties to their 

residents in passing the local option sales tax measures that fund many of these projects.

16317.13 b. The highways and local arterials framework and guiding principals state “[s]upport 

complete streets opportunities where feasible and practical.” i. That bullet point is dead 

last (see page 99) and follows a 3-page list of 58 freeway projects, 1/3 of which are in 

Orange County.

Comment noted.

16317.14 ii. The 2016 RTP/SCS repeatedly mentions the financial INfeasibility of continuing the status 

quo but requires feasibility and practicality for the non-motorized infrastructure that could 

significantly reduce vehicular congestion for short trips. Considering SCAG asserts 38% of all 

trips are ≤ 3 miles and 78% of those are made by driving full sized cars, we would like to see 

more equitable representation of active transportation in the RTP. Again, the RTP/SCS’s 

lack of comparison between investment and future cost savings to the public and private 

sectors does not accurately represent the value of active transportation.

Comment noted. SCAG's 2016 RTP/SCS Active Transportation Appendix includes strategies 

to increase the percentage of walkers and bicyclists, particularly for short trips. In addition, 

SCAG is working to better develop data and tools that will help identify long-term benefits 

of investing in active transportation.

16317.15 iii. If anything, active transportation modes should be described as improving feasibility and 

practicality for short trips. Please remove all feasibility and practicality requirements from 

discussion of walking, biking, and complete streets.

Comment noted. However, feasibility and practicality are necessary considerations when 

designing for complete streets.

15
holdID Comment Response 

Submitted by Alliance for a Healthy Orange County Submittal 16317 Related Documents Link

16317.16 c. The planned monetary investment in TDM/TSM is 50% greater than active transportation 

projects’ construction. We hope SCAG revisits that relationship and the message it sends.

Comment noted. Please note that the total for active transportation capital projects 

represents the total for capital projects that are exclusively active transportation. Many of 

the capital projects in other categories (e.g., arterials, Transportation Demand 

Management and Transportation System Management) include active transportation 

components that are not reflected in the total for active transportation capital projects.

16317.17 d. Chapter 9, “Looking Ahead,” pp 173-74, the RTP/SCS says, “ . . . active transportation will 

serve regional mobility, ensuring people can quickly, easily and safely transfer from one 

mode of transportation to the next . . . a critical role in helping the region to realize its 

vision . . . active transportation networks contribute to the attractiveness and economic 

vitality . . . an important role in reducing congestion and increasing mobility.” i. That kind of 

language should not just be in the last chapter, it should be repeated throughout the 2016 

SCAG RTP/SCS, especially the sections on congestion management and highways and 

arterials.

Comment noted. While not explicitly stated as in Chapter 9 (Looking Ahead), Chapter 5 

(The Road to Greater Mobility and & Sustainable Growth) lists in greater detail how active 

transportation strategies will help achieve mobility in the region. The Active 

Transportation Appendix further delineates how Active Transportation can benefit the 

region.

16317.18 5) Congestion management section omits important Federal and State congestion 

management law regarding walking and biking, safety, and the role pedestrians and 

bicyclists play in reducing congestion. Rather than citing FHWA code regarding a systematic 

approach (page 79), referring to Federal and State law, particularly paragraphs on walking 

and biking, multimodality, and safety, would acknowledge the high-level recognition of the 

importance of active transportation to everyone, not just non-motorized travelers. We 

suggest including the following: a. 49 USC 5303(a)(1) Policy: It is in the national interest to 

encourage and promote the safe and efficient management, operation, and development 

of surface transportation systems that will serve the mobility needs of people and freight . . 

. b. 49 USC 5303(h)(1): The metropolitan planning process for a metropolitan planning area 

under this section shall provide for consideration of projects and strategies that will--(B) 

increase the safety of the transportation system for motorized and non-motorized users; c. 

Calif code § 65089 (b)(2): The [congestion management] program shall contain . . . A 

performance element that includes . . . measures to evaluate current and future 

multimodal system performance for the movement of people and goods. d. Calif code § 

65089 (b)(3): The [congestion management] program shall contain . . . [a] travel demand 

element that promotes alternative transportation methods including . . . transit, bicycles . . .

Comment noted. SCAG implements an integrated approach in its federally-required 

Congestion Management Process (CMP) in order to improve and optimize the 

transportation system in its region. FHWA's CMP Guidebook outlines eight actions that are 

core requirements of the CMP which SCAG implements, including developing multi-modal 

performance measures and identifying, implementing and assessing strategies that include 

transportation demand management, transportation systems management, active 

transportation investments, land use strategies and multi-modal capital and operating 

improvements. The 2016 RTP/SCS includes significant emphasis and investments in all of 

these transportation elements.

16317.19 6) Congestion management expenditures focus on vehicular-centric approaches that are 

inconsistent with the 2016 RTP/SCS goals and guiding policies, particularly those promising 

a “Health in All Policies” approach. We question the sustainability and efficacy of SCAG’s 

congestion management approach within the context of the RTP/SCS goals and policies. 

From the perspective of community health and operational efficiency, it would be more 

effective to focus on (and fund) pedestrian and bicyclist safety and quality of experience as 

obviating the need for trendy or high-tech, high-cost, vehicular traffic management tools.

Comment noted. The 2016 RTP/SCS includes a wide variety of transportation strategies 

and investments, recognizing that improvements to all transportation modes are 

necessary in order to reduce congestion and improve the transportation system in the 

SCAG region. These include transportation demand management, transportation systems 

management, active transportation investments, land use strategies and multi-modal 

capital and operating improvements. SCAG is also conducting a community outreach and 

advertising campaign, called Go Human, which seeks to reduce traffic collisions in 

Southern California and encourage people to walk and bike more. The goal is to create 

safer and healthier cities through education, advocacy, information sharing, and events 

that help residents re-envision their neighborhoods.

16
holdID Comment Response 

Submitted by Alliance for a Healthy Orange County Submittal 16317 Related Documents Link

16317.20 a. The Congestion Management Appendix includes 4 pages of “CMP Toolbox and 

Strategies.” Nowhere in those pages, 19-22, is active transportation mentioned. Every tool 

elaborates exclusively on vehicle traffic management techniques, with two small 

paragraphs mentioning transit passenger counting and electronic fare systems. 

Consequently, the 2016 RTP/SCS multimodal integration and its potential for mutually 

complementary capacity across all modes of travel appears to be lacking. We would like to 

have seen more attention given to the multimodal foundation of Federal and State 

congestion management laws.

The 2016 RTP/SCS includes a wide variety of transportation strategies and investments, 

recognizing that improvements to all transportation modes are necessary in order to 

reduce congestion and improve the transportation system in the SCAG region. These 

include transportation demand management, transportation systems management, active 

transportation investments, land use strategies and multi-modal capital and operating 

improvements. Active Transportation strategies are discussed throughout the RTP/SCS and 

in a separate technical appendix. The Congestion Management appendix discusses 

transportation demand management strategies in comprehensive and significant detail on 

pages 24 through 28, and Active Transportation, First/Last Mile strategies on pages 28 

through 30. Table 6 on pages 33 to 43 also discuss these strategies in significant detail.

Submitted by Alliance for a Healthy Orange County Submittal 16318 Related Documents Link

16318.01 b. Evidence of overly vehicular-centric planning are found in the Public Health appendix, 

page 14, where it states the 2016 RTP/SCS will create a 19% increase in access to jobs by 

car but access to jobs reached by transit will only increase by 3%.

Comment noted. The six-county SCAG region is a vast and diverse region, geographically as 

well as demographically. Accordingly, the 2016 RTP/SCS recognizes that 'one size fits all' 

approach will not work for our region. Thus, the Plan is multi-modal and aims to address 

transportation needs of all segments of our society across our expansive region by 

expanding and enhancing travel choices. The plan creates opportunities to engage in 

healthy and active lifestyle through significant increase in investment in Active 

Transportation modes.

16318.02 c. The Congestion Management Appendix, pages 19-20, itemizes $9.2B in TSM 

improvements without addressing their sustainability or effective duration. Rather than 

spending billions on ramp metering, enhanced incident management, bottleneck removal, 

signal synchronization, and data collection, would it not be more cost effective to reallocate 

those funds on mass transit projects following the same path as the freeways and 

highways, complemented by rapid buses and safe pedestrian and bicycle facilities for the 

first and last miles?

TSM strategies have been demonstrated to improve safety, reduce congestion, and 

improve travel times, and result in much higher benefit-to-cost ratios than traditional 

capacity improvements. See, for example, http://www.itsbenefits.its.dot.gov/. Further, the 

2016 RTP/SCS includes a wide variety of transportation strategies and investments, 

recognizing that improvements to all transportation modes are necessary in order to 

reduce congestion and improve the transportation system in the SCAG region. These 

include transportation demand management, transportation systems management, active 

transportation investments, land use strategies and multi-modal capital and operating 

improvements.

16318.03 d. TDM and TSM strategies emphasize vehicle traffic flow optimization technologies that 

cost more than the RTP/SCS’s planned active transportation infrastructure projects. For 

example, the combined funding plans for the optimization strategies are 50% greater than 

the total active transportation construction (physical projects) plans, $16 billion vs. $10 

billion, respectively.

TSM strategies have been demonstrated to improve safety, reduce congestion, and 

improve travel times, and result in much higher benefit-to-cost ratios than traditional 

capacity improvements. See, for example, http://www.itsbenefits.its.dot.gov/. Further, the 

2016 RTP/SCS includes a wide variety of transportation strategies and investments, 

recognizing that improvements to all transportation modes are necessary in order to 

reduce congestion and improve the transportation system in the SCAG region. These 

include transportation demand management, transportation systems management, active 

transportation investments, land use strategies and multi-modal capital and operating 

improvements.

17
holdID Comment Response 

Submitted by Alliance for a Healthy Orange County Submittal 16318 Related Documents Link

16318.04 e. The TDM discussion on page 80, does not identify safe routes to school as one of its 3 

main focus areas. It should. That omission ignores the accepted 25-30% ADT rate for 

academic trips and their potential to reduce vehicular congestion if children had safer 

routes to walk and bike to school. Instead, the RTP/SCS mentions (see page 93) safe routes 

to school as a “comprehensive TDM strategy” under “Education/Encouragement 

Strategies.” That placement and description diminishes the importance of safe routes to 

school from both a transportation and equity perspective. Education/Encouragement is a 

complement to, not a substitute for, infrastructure safety as the RTP implies.

Comment noted. The Congestion Management appendix details Safe Routes to School 

Programs as a TDM strategy in Table 6 on page 38. In addition, a new bullet has been 

inserted on page 80 in the TDM section in the second set of bullets to read: "Investments 

in Safe Routes to School programs and infrastructure." 

16318.05 f. The introduction to “Highways and Arterials” is more representative of what our future 

priorities should be. The RTP states, “. . . costly expansions to address congestion are no 

longer financially feasible . . . improvements beyond TSM and TDM strategies need to be 

considered.” We couldn’t agree more. Please repeat that statement in the TSM/TDM 

section on page 80.

Comment noted. The TSM/TDM discussion on page 80 is specific to those types of 

investments which help maximize the performance of the existing and planned 

transportation system. Strategies in addition to TSM/TDM are addressed elsewhere in the 

RTP/SCS document.

16318.06 7) We are concerned with expressions of hesitancy to fully embrace the Health in All 

Policies approach to transportation. The Public Health Appendix offers hope for a new 

approach to transportation by recognizing the neighborhood and built environment 

category of the social determinants of health. We commend SCAG for incorporating such 

visionary language. However, the Public Health Appendix makes its commitment 

conditional upon feasibility and supportive literature. For example: a. The first guiding 

principal says, “[t]o reflect and provide information on the ways in which the investments 

and strategies [of the RTP/SCS] provide an opportunity to improve public health . . . , as 

feasible. We ask that the phrase, “as feasible,” be removed. (See Public Health Appendix p. 

11).

Comment noted. As discussed in the Public Health Appendix, public health is a new topic 

of consideration with in the 2016 RTP/SCS. SCAG is still exploring opportunities for data 

collection, analysis and reporting with regional and local partners. The full extent of the 

possibilities for these partnerships is yet unknown and needs to be further explored. These 

principles were recommended for inclusion in the Public Health Appendix at the October 

8, 2015 Energy and Environment Committee.

16318.07 b. The description of the public health analysis framework says (Ibid), “[a]nalysis of the 

public health impacts will be targeted to focus areas where there is literature to support 

the relationship between public health and the built environment.” Yet on page 8 of the 

Public Health Appendix, the RTP/SCS states, “[b]uilding off of a large body of research, 

SCAG has examined the connection between the built environment, physical inactivity, and 

obesity. SCAG has found that there is significant association between neighborhood land 

use/built environment characteristics and levels of obesity.” The two sentences are plainly 

contradictory; there should be no hesitancy in applying evidence from bountiful sources of 

peer reviewed literature to implementation of the 2016 RTP/SCS. We ask that the 

phrase,”literature to support,” be removed, especially since that condition is not placed 

upon parts of the 2016 RTP/SCS we’ve identified as being overly vehicular-centric.

Comment noted. Public health is a new focus area for the Plan. The Public Health Appendix 

is designed to serve as a reference for other agencies across the region and liturature was 

surveyed to ensure that the focus areas were supported by current research. These 

guiding principles were approved by the Energy and Environment Committee to guide the 

development of the Appendix on October 8, 2015.

16318.08 8) Benefits of Uber/Lyft-type transportation are not linked to SOV trip or congestion 

reduction. Uber/Lyft service is a substitute for car ownership and is most often used by 

individuals, not groups, adding vehicles to the roadway without obligating users to share 

the service with another rider. When used in that fashion, Uber/Lyft becomes just another 

SOV, albeit with a chauffeur. Therefore, we ask SCAG to remove Uber/Lyft from the TDM 

discussion.

Comment noted. Uber/Lyft-type car sharing transportation services can encourage and 

result in a reduction in car ownership and SOV vehicle miles travelled. Car sharing can 

increase the effective catchment areas to transit and rail stations from less than 1/4-mile, 

the standard for walking access, to distances considerably greater. The 2016 RTP/SCS 

includes car sharing as an integral and effective first/last mile strategy.

18
holdID Comment Response 

Submitted by Alliance for a Healthy Orange County Submittal 16318 Related Documents Link

16318.09 9) There is no mention of pursuing use of the vacant Pacific Electric Right of Way/West 

Santa Ana Branch Corridor as either a rail or active transportation corridor, or both.

The West Santa Ana Branch Corridor (RTP ID 1TR1011) and the Orange County/Santa Ana 

and Garden Grove Streetcar (RTP ID 2TR1001) are both located along portions of the 

Pacific Electric Right of Way/West Santa Ana Branch Corridor.

16318.10 10) Rail transit network planning in Orange County is sorely lacking. We applaud and 

enthusiastically support the central Orange County streetcar plans. But looking at the map 

in exhibit 5.2 illustrates the meager investment in and consideration of rail travel in Orange 

County: just two, very small orange lines for the street cars. Compared to exhibit 5.4’s 

representation of major highway projects in Orange County, the graphics state what the 

words do not: vehicles will still receive priority in coming decades. It would be wonderful to 

see exhibit 5.2 illustrate “possible future rail alternatives” parallel to or even elevated 

above major Orange County arterials. For example, rail linkage from the heart of the county 

to the ocean, as once existed between Santa Ana and Newport Beach, would recognize the 

need for efficient mountains to the sea connections. Since central Santa Ana is the county 

seat, linking coastal communities to that area would be a welcome alternative to SR-55.

The Strategic Plan identifies projects that the region might pursue in the future if and 

when additional funding becomes available. A discussion of the role of the Strategic Plan, 

and an identification of Strategic Plan projects, can be found on pages 170-172 of the 2016 

RTP/SCS.

16318.11 11) Railcar speed: we applaud the honest discussion of slow (37 mph avg) rail travel but we 

need to set higher goals than marginal improvements to 19th century rail technology. 

Nationally, we “aspire” to the federal definition of “high speed rail” being 110 mph 

minimum. California needs to distinguish itself from that standard by aspiring to at least 

match Japan’s Shinkansen trains, which have been operating at a max speed of 150-200 

mph since 1964.

Comment noted. The 2016 RTP/SCS includes investments in capital and operating 

improvements to Metrolink and the Amtrak Pacific Surfliner in the SCAG region to increase 

speed and service, including bringing some of their operating segments up to the federal 

high-speed rail definition of 110 mph. In addition, implementation of the California HighSpeed Train (CA HST) in our region is included in the financially-constrained plan. The CA 

HST is legally mandated to operate at speeds of up to 220 mph.

16318.12 12) Regional Bikeway Network Map: Exhibit 5.3 depicts regional bikeways only within the 

SCAG region, which makes our region appear disconnected from others, particularly 

SANDAG. The established, world famous Pacific Coast Bike Route linking Canada to Mexico 

is just one example of an interstate facility that should be represented. Please amend the 

map to show the extensions of the bikeways to other MPO regions.

Comment noted. While SCAG is unable to amend the Regional Bikeway Network Map as 

requested in the final 2016 RTP/SCS, SCAG will collect active transportation geodata from 

other regions and incorporate into maps in future RTP/SCSs.

16318.13 13) What are the standards for implementing bike share systems? Safety of the 

transportation infrastructure surrounding the bike share stations is not mentioned as a 

criterion. We believe safety analysis should be required because the success of bike sharing 

depends on potential users’ perception of safety.

While there are no established standards for bike share at the present time, station siting 

guidelines/criteria for bike share systems are developed by the local 

implementation/operating entities which include safety. Current entities developing bike 

share include Los Angeles County Metropolitan Transportation Authority, City of Long 

Beach, and City of Santa Monica.

16318.14 14) Mitigation measures include encouragement of bike lanes but bike lanes don’t enhance 

bicycling. The California Highway Design Manual, 2015 edition (& prior ones) state, 

“Generally, pavement markings alone will not measurably enhance bicycling.” (See § 

1002.1(3)). A mitigation measure that doesn’t enhance something for the intended user 

doesn’t compensate the public for the impact of a project. We recommend you replace 

“bike lanes” with “Class IV/separated bikeways designed using best practices from the 

bicyclist’s point of view.” Ibid

Comment noted: The 2016 RTP/SCS includes both Separated Bikeways and Class 2 bike 

lanes, with SCAG's regional greenway network comprised of Class 1 bicycle/Multi-use 

paths and Class 4 separated bikeways. It may be premature to replace bike lanes with 

separated bikeways as a mitigation measure. The California Highway Design Manual 2015 

edition, references pavement markings alone as not enhancing bicycling [for bike lanes]. 

Other improvements, including improvements to the surface, augmented sweeping 

programs, special signals, etc,. may improve the situation for bicyclists [along with the 

pavement markings].

19
holdID Comment Response 

Submitted by Alliance for a Healthy Orange County Submittal 16318 Related Documents Link

16318.15 15) The 2016 RTP/SCS vehicular-centric congestion management priorities are plainly 

inconsistent with its Public Health Appendix explanation of the nexus of poverty, access to 

goods & services, and transportation safety as being regional “major public health drivers.” 

a. The Public Health Appendix, page 3, states, “[a]ccess to daily needs and activities, such as 

schools, healthy food options, jobs, parks and open space and primary care is central to 

maintaining and improving public health.” AHOC concurs and suggests that statement be 

central to SCAG’s congestion management by reducing demand with increased investment 

in safe active transportation infrastructure, rather than the described vehicular flow 

optimization technology.

Comment noted. Access to daily needs and activities will continue to be accomplished by 

all modes of transportation. While the Plan will make more places accessible using transit 

and active transportation, the majority of trips in the SCAG region will continue to be 

made by automobiles. The Plan lays out strategies for improving congestion through 

TSM/TDM measures and increasing the number of short trips which will make essential 

destinations accessible to users of all modes of transportation.

16318.16 16) Reducing VMT per capita is not a meaningful way to improve public health outcomes if 

the absolute quantity of air pollutants in the SCAG region does not decrease. Using per 

capita analysis is misleading. From an air quality perspective, the RTP/SCS strategy should 

pursue a non-comparative target number for each air pollutant. Damage to any particular 

individual’s health is not diminished by exposing more people to dangerous levels of air 

pollution (see Public Health Appendix p 1).

Comment noted. SCAG is required under SB 375 to measure the reduction of VMT per 

capita to reach its greenhouse gas reduction targets. In addition to meeting those targets, 

the Plan will also improve other air quality outcomes across the region as detailed in the 

Air Quality Conformity Appendix and PEIR, Section 3.3 Air Quality.

16318.17 b. AHOC recommends that the 2016 RTP/SCS include in the main document, not just the 

appendix, a direct comparison of investment in safe active transportation facilities to 

healthcare savings. Featuring those discussions will better illuminate the financial feasibility 

of active transportation and the unsustainability of costs of chronic disease.

Comment noted. SCAG is currently performing research to monetize the benefits of active 

transportation through an Active Transportation Health and Economic Impact Study. 

However, this project is not expected to be completed in time to allow incorporation of 

the results into the Plan.

16318.18 17) The Public Health Appendix inadequately represents the lack of parks in central Orange 

County where rates of preventable, chronic disease are high. “Exhibit 1 2010 Access to 

Parks” is the only graphical representation comparing park space to population density and 

it does a poor job of illustrating a known issue: density, poverty, chronic disease, dangerous 

infrastructure, and lack of recreational opportunity are concentrated in areas with 

significant community health problems. We recommend including a chart that displays 

those variables numerically, with park space per capita, would better identify the problem 

and encourage efforts to address it.

Comment noted. The Environmental Justice Appendix includes a comprehensive analysis 

of park access for environmental justice communities. Please refer to page 74 of the 

document for SCAG's accessibility analysis to jobs, shopping, parks, and schools. Public 

health risks for areas in the SCAG region that have the highest concentration of low 

income and minority population is also included in the Appendix, starting on page 167.

16318.19 We also suggest the Public Health Appendix include data and maps from the California 

State Parks Dept Park Access Tool, which maps existing parks/open space, park space per 

capita, and disadvantaged communities by census tract. By focusing on central Orange 

County cities of Anaheim, Garden Grove, and Santa Ana, the Park Access Tool easily 

represents significant disparities in park acreage that correlates with Orange County Health 

Care Agency data on obesity.

Comment noted. The Environmental Justice Appendix includes a comprehensive analysis 

of park access for environmental justice communities. Please refer to page 74 of the 

document for SCAG's accessibility analysis to jobs, shopping, parks, and schools.

20
holdID Comment Response 

Submitted by Alliance for a Healthy Orange County Submittal 16318 Related Documents Link

16318.20 . Here is just one example of the obesity correlation: a. It is important to distinguish those 

communities from the countywide park access data revealing only 11% of 3 million OC 

residents live further than 1/2 mile from a park and 61% of residents countywide live where 

there is less than 3 acres of parks or open space per 1,000 residents. i. Central OC 

populations living more than 1/2 mile distance from a park are 17% (Santa Ana), 29% 

(Garden Grove), and 14% (Anaheim). ii. Populations in the same cities with less than 3 acres 

of parks/open space per 1,000 residents are: 83% (Santa Ana), 88% (Garden Grove), and 

70% (Anaheim). iii. Obesity rates for adults in those cities are 31.1% (Santa Ana), 24.2% 

(Garden Grove), and 27.8% (Anaheim). It is 18.2% countywide, according to OCHCA data 

from 2014.

Comment noted. The Environmental Justice Appendix includes a comprehensive analysis 

of park access for environmental justice communities. Please refer to page 74 of the 

document for SCAG's accessibility analysis to jobs, shopping, parks, and schools. The Public 

Health Impacts section of the Environmental Justice Appendix also provides a summary of 

existing conditions for areas of concern in the SCAG Region, which was done using 

Cal/EPA's CalEnviroScreen Tool.

Submitted by Alliance for a Regional Solution to Airport Congestion Submittal 16284 Related Documents Link

16284.01 ARSAC would like SCAG to re-establish Airport Regionalization as a permanent, standing 

sub-committee of the Transportation Committee. While SCAG cannot force airlines to serve 

underutilized, unconstrained airports that want more airline service, SCAG can help create 

critical mass for these airports by advocating for ground transportation improvements such 

as rail, bus and freeway connections. The formation of a Regionalization sub-committee will 

cement SCAG’s long-term commitment to effect regionalization of air service in Southern 

California. Regionalization Committee membership should be open to staff and other 

interested parties.

Comment noted. Formation of a subcommittee of the Transportation Committee can only 

be initiated either by the Transportation Committee or the Regional Council.

16284.02 ARSAC would like SCAG to remove from consideration any and all plans to create a 405 

interchange at Arbor Vitae. This interchange has been studied and rejected at least 3 times 

by the Federal Highway Administration (FHWA). It is a waste of taxpayer’s money to 

conduct any further study here. Without completing rebuilding 4 four miles of the 405 

freeway, it would be impossible to build an offramp from the 405 north freeway.

Comment noted. Most of the projects featured in the Plan's Project List Appendix were 

provided by the six County Transportation Commissions (CTCs), in this case Metro. 

Decisions to delete, replace or modify a project must come through the CTC.

16284.03 In the RTP Project List, Table 2, "Financially Constrained RTP Projects", there are a number 

projects related to the LAX Landside Access Modernization Plan (LAMP). These include 

projects 1160009to 116027. Considering that LAMP has issued an NOP and the Draft EIR is 

not expected until April 2016, why are these projects included?

Comment noted. Completion of EIR is not a pre-requisite for inclusion of a project in the 

RTP/SCS. In fact, most of the projects included in the RTP/SCS have not gone through the 

environmental review process.

16284.04 As a general comment, the US commercial airline industry has completed consolidation for 

the time being. Major factors that are missing and need to be included in this document 

include: 1. “Open Skies” agreements between the U.S. and most countries that have 

removed most barriers to international service at airports in Southern California. 2. New, 

fuel efficient long range aircraft such as the Boeing 787 Dreamliner and the Airbus A350 

XWB. The combination of Open Skies and the 787 has opened many new city pairs in 

California including: a. Norwegian Long Haul- LAX to Copenhagen, Denmark; Stockholm, 

Sweden; and Oslo, Norway; Oakland to Stockholm and Oslo b. All Nippon Airways- San Jose 

to Tokyo-Narita, Japan c. Japan Airlines- San Diego to Tokyo-Narita, Japan d. Hainan 

Airlines- LAX to Changsha, China and San Jose to Beijing, China e. British Airways- San Jose 

to London Heathrow 3. Possible effects of FAA redesign of Southern California’s airspace 4. 

Possible effects of implementation of Next Generation Air Traffic Control System 

“NextGen”.

Comment noted. The RTP is not intended as an exhaustive discussion of all aviation related 

issues in the region. Explicit discussion of each of the issues identified in the comment 

would not impact the aviation forecasts in the RTP.

21
holdID Comment Response 

Submitted by Alliance for a Regional Solution to Airport Congestion Submittal 16284 Related Documents Link

16284.05 Comments on Exhibit 1- Southern California Regional Aviation Assets (PDF page 4). Please 

use a different symbol for commercial airline capable airports that presently do not have 

commercial airline service. This would include Oxnard (OXR), Palmdale (PMD), 

Riverside/March Inland Port (RIV), San Bernardino (SBD) and Victorville/Southern California 

Logistics Airport (VCV).

Comment noted.

16284.06 Comments on Airport Profiles, page 5 (PDF page 7). LA/Ontario International Airport. The 

transfer of Ontario International Airport (ONT) from Los Angeles World Airports (LAWA) to 

the Ontario International Airport Authority (OIAA) should be noted here.

Comment noted. While an agreement has been reached between the City of Los Angeles 

and the Ontario International Airport Authority the legal transfer of the airport has not yet 

taken place. That said, the text has been updated to reflect the intended transfer.

16284.07 Comments on Airport Profiles, page 6 (PDF page 8). Long Beach Airport. JetBlue began 

operations from LGB in 2001. The City of Long Beach recently raised the number of daily 

commercial flights allowed from 41 to 50. This Appendix should reflect the updated 

number in the text and in capacity calculations.

Comment noted. The City's action, following a court judgment, occurred after the analyses 

for the RTP were complete. The impact of this action will be incorporated through future 

RTP/SCS update, as appropriate.

16284.08 Comments on Airport Profiles, page 7 (PDF page 9), Imperial County Airport. SeaPort 

Airlines discontinued all service in California on January 15, 2016.

Comment noted. SeaPort's action occurred after the release of the Draft 2016 RTP/SCS. 

The USDOT and Imperial County are in the process of identifying a new operator. Any 

impact due to this new development will be reflected in the future RTP/SCS update, as 

appropriate.

16284.09 Comments on Airport Profiles, no page number. Missing commercial airports. Although 

these airports do not have commercial passenger and/or cargo service at the present time, 

profiles should be included for these airports: Oxnard, Palmdale, Riverside/March Inland 

Port, San Bernardino and Victorville/Southern California Logistics Airport.

Comment noted. The intent of the airport profiles is to highlight trends in activity at 

commercial airports. Since none of the airports identified in the comment have 

commercial service, they are not included in this section. The RTP elsewhere describes 

these airports as having the ability to accommodate commercial service.

16284.10 Comments on Page 9 (PDF page 11): 1. Overlapping catchment areas. Please provide a map 

of the commercial airport catchment areas in Southern California (including Kern, San Diego 

and Santa Barbara Counties).

Comment noted. Staff believes, airport catchment areas do not have discreet boundaries 

that would allow mapping in a defensible manner.

16284.11 Comments on Page 9 (PDF page 11): 2. Inclusion of San Diego, Carlsbad and Santa Barbara 

airports. We agree with the inclusion of these airports into the SCAG aviation forecast. 

Additional areas that need to be added include Bakersfield, Mojave and Inyo Kern airports. 

Bakersfield has had limited air service and a private bus service from Bakersfield to LAX has 

been operational for decades. The model should also include Tijuana International Airport, 

especially since the new Cross Border Xpress bridge has opened. Fares from Tijuana for 

flights within Mexico and to Central and South America can be less expensive than from 

U.S. airports. Additionally, SCAG needs to break out the numbers for each of these airports 

listed above.

Comment noted. Certain additional airports in San Diego County and Santa Barbara have 

been included in the SCAG forecast due to their proximity to the SCAG region and the 

volume of demand to and from the SCAG regions are significant. The SCAG region 

surrounds San Diego County, and Santa Barbara is immediately adjacent to the SCAG 

region. Bakersfield, Mojave, and Inyo Kern airports are significantly smaller and farther 

from the SCAG region, which results in their having relatively insignificant interaction with 

the SCAG region in terms of air travel demand. While the new Cross Border Xpress bridge 

has opened, service from Tijuana has been available for many years. The impact on 

demand from the SCAG Region due to the Cross Border Xpress is unknown. SCAG does not 

see a lot of value in providing forecasts or detailed analysis of airports not within its 

jurisdiction.

16284.12 Comments on Page 10: 1. The model does not appear to include increased utilization of 

alternatives to commercial airlines such as charter (e.g. Clay Lacy, JetSuite), fractional 

ownership (e.g. NetJets, Citation Shares) and membership plans (e.g. Surf Air). Private air 

transportation providers gained popularity after 9/11 for passengers wanting to avoid the 

hassle of commercial airport security and the convenience of business aircraft travel. Some 

of these business aircraft service providers fly into and out of some of the same airports as 

commercial airlines- e.g. Burbank, Long Beach and Santa Ana/John Wayne.

Comment noted. The air taxi services described were included in the analysis of demand 

for commercial air travel versus general aviation services. Detailed general aviation 

forecasts were not updated in the current RTP/SCS. The 2012 RTP/SCS evaluated general 

aviation market in greater detail. SCAG will consider updating the general aviation forecast 

in the next RTP/SCS update.

22
holdID Comment Response 

Submitted by Alliance for a Regional Solution to Airport Congestion Submittal 16284 Related Documents Link

16284.13 Comments on Page 12: 1. Combination of Canada and Greenland. We are mystified at this 

combination. While geographically Canada and Greenland are nearby, they are 

economically and politically an ocean apart. Greenland is an autonomous territory of the 

Kingdom of Denmark. The only flights to and from Greenland are to Denmark, Germany 

and Iceland.

Comment noted. Staff agrees that direct flights to Greenland are generally limited to a few 

from European cities. However, the decision to classify Greenland in one region or another 

does not affect the results of the aviation demand forecasts.

16284.14 Comments on Page 14: 1. Mexico/Central America/Caribbean O&D Market. How did was 

the evaluation the Caribbean O&D market conducted? Was Cuba included? Considering 

there are very few non-stop flights from SCAG area airports to the Caribbean, did the 

model consider one-stop or transfer flights to the Caribbean? Connecting airports should 

include Miami, Fort Lauderdale, Atlanta, Houston and Dallas/Fort Worth.

Comment noted. All passenger statistics used were Origin and Destination traffic, which 

includes all passengers between two points without regard to routing and intermediate 

stops. Therefore, the absence of non-stop flights is immaterial to the data, as all 

passengers traveling between the SCAG region and Mexico/Central America and the 

Caribbean are captured. All traffic using services via connecting airports in the United 

States as well as outside the United States was included. Cuba was included.

16284.15 Comments on Page 15: 1. South America O&D Market. How did was the evaluation the 

South America O&D market conducted? Considering there are very few non-stop flights 

from SCAG area airports to South America, did the model consider one-stop or transfer 

flights to the South America? In addition to Mexico City, Mexico; San Jose, Costa Rica and 

Panama City, Panama, connecting airports should include Bogata, Columbia; Lima, Peru; 

Miami, Fort Lauderdale, Atlanta, Houston and Dallas/Fort Worth.

Comment noted. All passenger statistics used were Origin and Destination traffic, which 

includes all passengers between two points without regard to routing and intermediate 

stops. Therefore, the absence of non-stop flights is immaterial to the data, as all 

passengers between the SCAG region and South America are captured. All cities in the 

South American region were included. All traffic using services via connecting airports in 

the United States as well as outside the United States was included.

16284.16 Comments on Page 16: Trans-Atlantic O&D Market. How did was the evaluation the TransAtlantic O&D market conducted? While the number of non-stop flights from the SCAG area 

airports to Trans-Atlantic has increased with “Open Skies” bilateral aviation agreement and 

new fuel efficient long-range aircraft such as the Boeing 787 Dreamliner and Airbus A350 

XWB , did the model consider one-stop or transfer flights over the Atlantic? The chart 

below shows potential traffic flows. Choices for these routing may depend on schedules 

(one-stop from West Coast offers earlier arrival in Europe than non-stop) fares and seating 

availability (sometimes affect frequent flyer redemptions).

Comment noted. All passenger statistics used were Origin and Destination traffic, which 

includes all passengers between two points without regard to routing and intermediate 

stops. Therefore, the absence of non-stop flights is immaterial to the data, as all 

passengers between the SCAG region flying Trans-Atlantic are captured. New aircraft 

technology was considered, as was the ability to economically fly to new non-stop 

destinations. All traffic using services via connecting airports in the United States as well as 

outside the United States was included.

16284.17 Comments on Page 18: 1. Average growth forecast used. We agree with the 1.6 growth rate 

used for the air traffic model. Between the start of the “Jet Age” in October 1958 and up to 

9/11, historically, world air traffic doubled every 20 years. Half of the world’s air traffic is in 

the United States. Since 9/11, we have seen dramatic change in the airline industry through 

consolidation and “right sizing” of aircraft to routes. U.S. airlines are now primarily focused 

on profits instead of market share.

Comment noted.

16284.18 Comments on Page 18: 2. Air Traffic Allocation Model. Price (air fare cost) is a major factor 

that is missing from this model. Passengers who live close to Burbank, Ontario and John 

Wayne airports are sometimes faced with significant fare differences between their home 

airport and LAX. In some cases, the fare difference is so great that it is worthwhile for the 

passenger to drive and park his car at or near LAX and still have money leftover for which 

he may have spent on flying out of his local airport. If airfare prices were similar at each 

SCAG airport (“co-terminal” pricing), then the problem of leakage of some passengers to 

LAX, and the attendant ground traffic congestion, could be reduced.

Comment noted. "Relative air fare costs at the region's airports are reflected in the 

""passenger preference"" component of the model illustrated in Exhibit 3.

23
holdID Comment Response 

Submitted by Alliance for a Regional Solution to Airport Congestion Submittal 16284 Related Documents Link

16284.19 Comments on Page 19: 1. Airfield and Terminal Capacities. Please provide us with the data 

and calculations used each of the four airports listed here: Burbank, LAX, Long Beach and 

John Wayne. Data sought is airfield configuration used, number of gates and gate sizes, 

aircraft selection, aircraft engine assignment (critical for air quality evaluations), etc. We 

ask that the 2009 LAX Design Day Flight Schedule (DDFS) not be used here. The DDFS 

excluded the Airbus A330 and Boeing 717 aircraft from the 2009 and 2025 baselines and 

overestimated the Boeing 767 for 2025 which the airlines are now retiring in favoring of 

narrowbody aircraft such as the Airbus A321 and Boeing 737-900ER.

Comment noted. The Capacity Analysis Technical Memorandum has been posted on 

SCAG's web site. The 2009 LAX Design Day Flight Schedule was not used in the estimate of 

LAX capacity.

16284.20 Comments on Page 20: 1. Los Angeles International Airport. The current north airfield 

separation of 700 feet meets current FAA standards for parallel runway separation (FAA 

Advisory Circular 150/5300-13A, Section 316)

Comment noted. The RTP as written is correct. It is correct that the north airfield meets 

the minimum standard for parallel runway separation under VFR (visual flight rules) 

conditions. When conditions require instrument flight rules (IFR), FAA regulations require 

greater runway separation for parallel runway operations. The RTP states that the north 

airfield does not meet the FAA requirement for parallel runway operations under IFR 

conditions.

Submitted by Alliance for a Regional Solution to Airport Congestion Submittal 16289 Related Documents Link

16289.01 Comments on Page 20: 2. LAX capacity. Please provide the backup materials and 

calculations for the LAX capacity described in the second column. The Petitioners (ARSAC 

and cities of El Segundo, et al) are seeking to extend the 153 gate cap and 78.9 MAP limit at 

LAX through the year 2040.

Comment noted. The Capacity Analysis Technical Memorandum has been posted on 

SCAG's web site.

16289.02 Comments on Page 20: 3. Long Beach Airport. Please update the daily commercial flight 

limit from 41 to 50.

The City's action, following a court judgment, occurred after the analyses for the Draft 

RTP/SCS were complete. The impact of this action will be incorporated through the future 

update to the RTP/SCS, as appropriate.

16289.03 Comments on Page 21: 1. Table 2. For LAX, please add, “Stipulated Settlement Agreement 

of 153 gates and 78.9 MAP limit” to the Source of Constraint column.

Comment noted. The majority of the Stipulated Settlement Agreement expired on 

December 31, 2015. The passenger gate provision in Section IV will expire on December 

31, 2020. Therefore, they are not applicable to the analysis of the capacity of the airport in 

2040. Should the Settlement Agreement be changed or extended in the future, SCAG will 

consider reflecting the changes through future update to the RTP/SCS as appropriate.

16289.04 Comments on Page 21: 2. Forecast Air Passenger Allocation Scenarios. Please provide the 

data and calculations for the unconstrained and constrained scenarios.

The data for every regional scenario is derived from the same data as the overall regional 

demand. The calculations for each scenario are described in the Aviation and Ground 

Access Appendix. While we did not develop a true unconstrained scenario, we believe the 

Less Regionalization Scenario is similar to unconstrained scenario.

16289.05 1. Airport Ground Access. As with page 18 comments, the price factor is missing in this 

discussion.

Comment noted. The Airport Ground Access section is focused on the ability of passengers 

to access each airport. It is not intended to analyze the factors that go into a passenger's 

choice of airports. The statement that "Passengers’ choice of airports is based in part on 

the travel time to the airport and the convenience of access" is not intended to suggest 

that other factors are not important; indeed, it states that there are other factors that 

influence passengers' decisions."

24
holdID Comment Response 

Submitted by Alliance for a Regional Solution to Airport Congestion Submittal 16289 Related Documents Link

16289.06 2. We challenge the use of “ranges” in Table 3 for LAX, ONT, PMD and SBD. Courts have 

held that the purpose of Environmental Impact Reports are supposed to be informational 

documents for the public and for decision makers. The use of ranges appears to be 

disingenuous to the public, especially when SCAG staff confirmed that the higher MAP 

numbers will be used for the regional air quality model.

Comment noted. The RTP/SCS is a planning document, and the ranges reflect an 

appropriate amount of uncertainty given the information available at the time the 

document was prepared. As noted in the comment, the PEIR used the high end of the 

range for the analysis of potential impacts at each airport. Use of higher range of MAP in 

the Air Quality and environmental analysis is intended to analyze worst case scenario from 

impact standpoint.

16289.07 3. We should also point out that it is nonsensical that the overall 136.2 MAP 2040 forecast 

would be the same for all four of the scenarios shown on page 22, particularly between the 

adopted scenario that respects airport capacity constraints, and the unconstrained 

scenario. Past RADAM modeling done by SCAG realistically reduced overall demand served 

in constrained scenarios (i.e. puts unserved demand in a "latent demand" category) since 

not all passengers that cannot be served by a nearby constrained airport would be 

expected to drive to other airports, and some would simply chose not to fly. Unconstrained 

airport systems would always be expected to serve the highest levels of demand. SCAG's 

demand allocations apparently went through an artificial and arbitrary exercise to keep the 

demand totals the same for all four scenarios, such as by arbitrarily eliminating service at 

some airports in the unconstrained scenario.

Comment noted. The aviation forecast process employed in the 2016 RTP/SCS differed 

from that employed in recent previous RTPs. Rather than generate forecasts for each 

airport and sum them to calculate total regional demand, the 2016 RTP/SCS forecast began 

with an overall aviation demand forecast for the entire region. Several scenarios were 

examined as to how the regions's airports could accommodate this demand. All of the 

scenarios presented in the RTP/SCS assume that the region develops policies to develop its 

infrastructure to accommodate the entire demand. As suggested in the comment, it is 

possible that the region does not do so, and that potential aviation trips might be 

discouraged. However, such a scenario is not included in the RTP/SCS.

16289.08 Comments on Page 23: 1. Burbank Airport (BUR). Please add in wording concerning the 

California High Speed Authority’s plan to have a station at BUR.

Comment noted. Staff have added language to incorporate this comment.

16289.09 Comments on Page 24: 1. Burbank Airport (BUR). Please add in wording concerning the 

California High Speed Authority’s plan to have a station at BUR.

Comment noted. While an agreement has been reached between the City of Los Angeles 

and the Ontario International Airport Authority the legal transfer of the airport has not yet 

taken place. That said, the text has been updated to reflect the intended transfer.

16289.10 Comments on Page 25: 1. Los Angeles International Airport (LAX) FlyAway bus service. 

Please update this sentence to: LAWA operates LAX FlyAway, which provides non-stop bus 

service between each of the LAX terminals and seven locations: Van Nuys Airport, Union 

Station, Westwood, Hollywood, Santa Monica, Orange Line and Long Beach. Pursuant to 

the LAX Master Plan Mitigation and Monitoring Plan Air Quality Commitment 3 (MM-AQ3), 

LAX is supposed to have 8 additional sites operational (not including Van Nuys) by the end 

of 2015. This is a requirement before a building permit can be issued for the Intermodal 

Transportation Facility (ITF).

Comment noted. The Plan has been updated to reflect this comment.

16289.11 Comments on Page 25: 2. LAX bus service. Add in Bakersfield after Ventura County. Comment noted.

16289.12 Comments on Page 25: 3. Transportation Networking Companies (TNC’s). Add a sentence 

to end of the second to last paragraph, “In December 2015, LAX permitted TNC operators 

such as Lyft and Uber to pick-up and drop-off passengers at designated points on the 

Departures area on the upper level roadway.”

Comment noted. The text has been updated to reflect this comment.

16289.13 Comments on Page 26: 1. Recently Completed Ground Access Projects. After Hollywood, 

add in Orange Line and Long Beach.

Comment noted. The text has been updated to reflect this comment.

16289.14 Comments on Page 28: 1. Ontario International Airport. The transfer of Ontario 

International Airport (ONT) from Los Angeles World Airports (LAWA) to the Ontario 

International Airport Authority (OIAA) should be noted here.

Comment noted.

25
holdID Comment Response 

Submitted by Alliance for a Regional Solution to Airport Congestion Submittal 16289 Related Documents Link

16289.15 Comments on Page 28: 2. Please add in wording concerning the California High Speed 

Authority’s plan to have a station at ONT.

Comment noted. The text has been updated to reflect this comment.

16289.16 Comments on Page 30: 1. Palmdale Regional Airport (PMD). Please add in wording that the 

Palmdale Airport Authority has a lease with the US Air Force for use of Air Force Plant 42’s 

two 12,000 foot runways and a 60-acre leasehold with a passenger terminal for use as 

Palmdale Regional Airport. Also, Los Angeles World Airports (LAWA) owns 17,750 acres to 

the east and south of Plant 42 for a future airport. Some of the land is leased for farming, a 

golf course, the NASA Dryden facility and a factory that supplies railcars for Metro.

Comment noted. The text has been updated to reflect this comment.

16289.17 Comments on Page 33: 1. San Bernardino International Airport (SBD). Add in a sentence 

that SBD has a passenger terminal with X passenger gates and Federal Inspection Service 

(Immigration, Customs, etc.) facilities. Also add in a sentence that SBD has Maintenance, 

Repair and Overhaul (MRO) facilities and is home to San Bernardino’s Sheriffs Office air unit 

and US Forest Service air resources.

Comment noted. Language regarding the Federal Inspections Service has been added.

16289.18 Comments on Page 35: 1. Southern California Logistics Airport (VCV). In the last sentence, 

change Oxnard Airport to Southern California Logistics Airport.

Comment noted. The text has been updated to reflect this comment.

16289.19 Comments on Page 35: 2. Technical and Policy Committee Review. ARSAC commends SCAG 

for reaching out to commercial airport operators to solicit their input on future passenger 

growth at their respective airports. ARSAC remains concerned that the data and 

calculations used for projecting future LAX passenger growth have been hidden. ARSAC 

requests release of that data and calculations.

Comment noted. The Capacity Analysis Technical Memorandum has been posted on 

SCAG's web site which includes the more detailed analysis on LAX.

16289.20 Comments on page 154, Aviation Noise Impacts 1. In Table 83- 2016-2040 RTP/SCS Aviation 

Plan and Scenario, there are issues here with the baselines for John Wayne and LAX. Where 

did these numbers come from? SNA has a legal constraint of 12.5 MAP and should not be 

given a higher number. Where did the 100.7 MAP come from for LAX?

The “unconstrained scenario” as shown on Table 3, of the 2016 RTP/SCS Aviation Plan and 

Scenario Appendix, represents a scenario in which there are no RTP/SCS in place, and 

there are no legal restrictions. What it is meant to portray is a 2040 MAP forecast purely 

driven by market demands. As such, in a world where no Plan or legal restrictions exist, the 

most popular airports within the region would be Los Angeles (LAX) and John Wayne (SNA) 

airports. The purpose of the unconstrained scenario represents a conservative and worst 

case scenario which was used for informational purposes only.

Submitted by Alliance for a Regional Solution to Airport Congestion Submittal 16291 Related Documents Link

16291.01 Comments on page 154, Aviation Noise Impacts 2. Why are the other tables for airport 

forecasts not consistent throughout the RTP and PEIR?

Comment noted. Figure 3.17.4-1, Anticipated Future Passenger Demands at Major 

Southern California Airports, within the Draft 2016 RTP/SCS PEIR has been revised to be 

consistent with Table 3 of the 2016 RTP/SCS Aviation Plan and Scenario Appendix.

26
holdID Comment Response 

Submitted by Banning Ranch Conservancy Submittal 16241 Related Documents Link

16241.01 The 2012 RTP/SCS provided an important stepping stone for the 2016 Plan. In previous 

Plans, natural lands and farmlands were handled under the banner of “land use.” In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn’t be overlooked. We 

believe the opportunity before you isn’t to “plan for” the future of open space in the 

region—as that’s what you’ve been doing since the 2012 Plan. Instead, we believe SCAG 

can now start “implementing” a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. We and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16241.02 SCAG’s Support of Regional Wildlife Corridors The current federal transportation bill, FAST 

Act, supports understanding transportation impacts on natural resources. The previous bill, 

MAP-21, supported restoring and maintaining environmental functions (i.e., wildlife 

corridors) affected by the infrastructure projects in the RTP. SCAG has even supported 

efforts in Los Angeles County to create a wildlife corridor over the 101 Freeway. Many 

efforts are underway across the region to connect landscapes to one another. This is very 

important to the region and its biodiversity. Wildlife corridors allow species to migrate and 

forage and expand genetic diversity. These corridors also allow ecosystems to maintain 

ecological functions, act as sources for repopulation after natural disasters such as fire, 

flood or landslide, and improve the resiliency in the face of climate change impacts. The 

Plan would be stronger if it supported the enhancement of and/or protection of 

documented and regionally significant wildlife corridors, especially those that are impacted 

by infrastructure projects.

Comment noted. The RTP/SCS describes (in Chapter 5) next steps for further developing a 

habitat conservation strategy. Included in the steps is the recommendation to provide 

“incentives for jurisdictions to cooperate across county lines to protect and restore natural 

habitat corridors, especially where corridors cross county boundaries.” The Natural/Farm 

Lands Appendix further supports wildlife corridors in its recommended policies, with the 

specific recommendation to “Encourage and facilitate research, programs and policies to 

identify, protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Additionally, continue support for preserving wildlife corridors and 

wildlife crossings to minimize the impact of transportation projects on wildlife species and 

habitat fragmentation.”

Submitted by Bel Air Skycrest Property Owner's Association Submittal 16173 Related Documents Link

16173.01 I am writing on behalf of Bel Air Skycrest Property Owners' Association (BASPOA) regarding 

the proposed Sepulveda Tunnel Reversible Lane project. My community travels the 

Sepulveda Pass on a daily basis, and we strongly oppose this project, which pre-dates and 

has now been made obsolete by the I-405 Sepulveda Widening. To be honest, we were all 

quite shocked to see this antiquated proposal show up on the 2016 Draft RTP/SCS Project 

List, given that northbound traffic problems in the Pass have been resolved by the I-405 

Widening Project. We urge that the reversible lane proposal be dropped.

Comment noted. Since the completion of the improvements on I-405, additional 

improvement needs in this corridor, including Sepulveda Boulevard, are being further 

examined. SCAG will work with Metro and Caltrans to reflect the ultimate improvement 

configuration in this corridor in the future RTP/SCS amendments or updates as appropriate.

27
holdID Comment Response 

Submitted by Bel Air Skycrest Property Owner's Association Submittal 16173 Related Documents Link

16173.02 Bel Air Skycrest Property Owners' Association agrees with the Sherman Oaks Homeowners 

Association (SOHA) that the big problem involving the Sepulveda Corridor is not the tunnel 

itself but the lack of rapid transit between the Valley and LA proper, and that more 

energies must be directed, without delay, to finding a viable north-south rapid transit 

solution for the City of Los Angeles, one that will take Valley dwellers to LAX, jobs, and 

more, while relieving traffic on the 405 and Sepulveda.

SCAG works with the county transportation commissions to develop the transportation 

investment strategies in the RTP/SCS. The details for the Sepulveda Pass Transit Corridor 

(RTP ID 1160001), were submitted to SCAG by Metro staff in the Spring of 2015. The 

project details submitted include project termini, stations locations, project cost 

assumptions, and completion year assumptions. The 2039 completion year and $2.468 

billion cost estimate are consistent with Metro’s board adopted 2009 Long Range 

Transportation Plan (LRTP), as displayed in Figure N on page 30 of that plan. Should the 

project details change due to voter approval of a new sales tax measure and due to Metro 

updating its LRTP, then SCAG will work with Metro to update the RTP/SCS accordingly.

Submitted by Bolsa Chica Land Trust Submittal 16247 Related Documents Link

16247.01 The 2012 RTP/SCS provided an important stepping stone for the 2016 Plan. In previous 

Plans, natural lands and farmlands were handled under the banner of “land use.” In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn’t be overlooked. We 

believe the opportunity before you isn’t to “plan for” the future of open space in the 

region—as that’s what you’ve been doing since the 2012 Plan. Instead, we believe SCAG 

can now start “implementing” a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. We and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16247.02 We are pleased to see an Appendix devoted directly to natural and farmlands protection in 

the 2016 Plan. We are glad that the Plan contains specific strategies addressing natural land 

and farmlands issues. This is certainly a step in the right direction. The culmination of the 

work from the last RTP/SCS is clearly visible in this Draft Plan. SCAG has demonstrated that 

Metropolitan Planning Organizations can play a vital, thoughtful and science-based role in 

mitigating impacts to our natural environment from transportation, infrastructure and 

other development projects. By incorporating natural and farmlands protection strategies 

into your policy document, we believe the many benefits of this broad-based conservation 

approach will be realized sooner than expected. Thank you for your leadership.

Comment noted.

16247.03 Maps contained within the PEIR, RTP, SCS and Appendix should be internally consistent and 

they are not. For example, each map that shows “open space” or “protected lands” should 

be using the same base dataset but they do not. The 2012 Plan resulted in the creation of 

SCAG’s very own geographic information systems (GIS) dataset: the Natural Resource 

Inventory. It is more accurate than what is in the document now and it has been vetted by 

numerous organizations. That’s why it is surprising to see that so few of SCAG’s own GIS 

layers were actually used in the documents’ maps. We urge SCAG to honor its own work 

and that of its partner organizations by using this dataset as the basis for natural and 

farmland mapping. Let’s move forward with the same baseline information.

Comment noted. Each of the maps identified in the comment serve a distinct purpose and 

as such may reference a different data set to fully address its purpose. The various data 

sets each have their own set of constraints, not limited to richness of data and scale, which 

primarily explains the differences in mapping between PEIR and the RTP/SCS. Maps have 

been clarified to properly identify the purpose of the map and the specific data source.

28
holdID Comment Response 

Submitted by Bolsa Chica Land Trust Submittal 16247 Related Documents Link

16247.04 Our organization supports the idea that as new growth occurs it should focus on the 

existing infill areas. This is consistent with the finding in the SCAG surveys where 

respondents preferred to see existing urban areas built upon before greenfields are 

targeted for development, especially those at the Wildland-Urban Interface. When 

developments are built in infill areas, it likely relieves pressure from the fringe. However, 

the Plan fails to outline exactly how (or with what mechanism) these fringe lands (or any 

lands) will actually be protected. Just because the pressure is relieved doesn’t mean the 

land then automatically becomes protected. Numerous organizations, ours included, focus 

their work on preservation of important habitat lands. A lot of time, energy, political will, 

strategy and other efforts combine to create a successful conservation transaction that 

leads to permanently conserved lands. SCAG must identify the mechanism, process or plan 

on how the greenfield lands will be protected.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16247.05 SCAG focused many sections of the document on formal conservation plans, in the form of 

Natural Community Conservation Plans and Habitat Conservation Plans (NCCP/HCP), as the 

conservation method most identified by the agency. It is important to note that NCCP/HCP 

programs are only one conservation mechanism and they have limitations. For example, 

they are voluntary, property owner driven and generally only apply to larger land 

ownerships. Efforts underway by local, regional, state and federal agencies outside of these 

formal plans should not be discounted and must be included. Furthermore, many 

conservation organizations help facilitate, coordinate and find funding for land 

conservation transactions. We believe the conservation approach promoted by SCAG 

should include all of the ways land is protected, including those less regulated methods of 

conservation outside of NCCP/HCP programs.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation. Suggestions for strategies 

beyond HCPs and NCCPs will be encouraged and appreciated. Your group is encouraged to 

participate in the effort.

16247.06.1 The Plan outlines that the region anticipates an additional 3.8 million people by 2040 

providing increased pressure on our existing parkland. Studies document that many 

communities in the Southern California region already do not have enough parkland as 

outlined by the Quimby Act (three acres per 1,000 residents).

Comment noted.

16247.06.2 Throughout the document, the Plan promotes providing more access to these existing 

parks as infill projects are built, but nowhere does it state how additional parks will be 

created. The mechanism is missing. More importantly, these city parks are fundamentally 

different than habitat-focused parks. Usually city and regional parks include high intensity 

recreation oriented activities, like soccer and baseball fields, and are turfed. The types of 

land acquired as mitigation or through local conservation efforts typically are focused on 

preservation of natural habitat and less intensive uses (birding, hiking, etc.). In fact, many 

of these mitigation lands have limited or managed public access. Providing “more” access 

to either high or low intensity parks and/or habitat lands may have significant 

consequences for the land manager. The document needs to address the impacts to local 

parks with increased access from expanding populations. The document also needs to 

address how additional lands will be protected, i.e., what mechanism will be used?

Comment noted. The term "Natural Lands" is used intentionally to differentiate between 

potentially sensitive habitat areas and urban/suburban parks that provide open space and 

active recreation. Specifically, "Natural Lands" refers to biologically diverse areas and 

landscapes that may provide ecosystem services, such as grasslands, wetlands, deserts, 

forests, shrublands, riparian areas, and other types of habitat lands. Natural Lands is not 

intended to include agricultural croplands, grazing/rangeland, other working lands, or 

municipal parks serving primarily recreational purposes. In the coming years, SCAG will be 

working with local entities to assist in the cross-jurisdictional coordination of habitat 

conservation strategies. Your coalition is encouraged to participate in the effort.

29
holdID Comment Response 

Submitted by Bolsa Chica Land Trust Submittal 16247 Related Documents Link

16247.07 The current federal transportation bill, FAST Act, supports understanding transportation 

impacts on natural resources. The previous bill, MAP-21, supported restoring and 

maintaining environmental functions (i.e., wildlife corridors) affected by the infrastructure 

projects in the RTP. SCAG has even supported efforts in Los Angeles County to create a 

wildlife corridor over the 101 Freeway. Many efforts are underway across the region to 

connect landscapes to one another. This is very important to the region and its biodiversity. 

Wildlife corridors allow species to migrate and forage and expand genetic diversity. These 

corridors also allow ecosystems to maintain ecological functions, act as sources for 

repopulation after natural disasters such as fire, flood or landslide, and improve the 

resiliency in the face of climate change impacts. The Plan would be stronger if it supported 

the enhancement of and/or protection of documented and regionally significant wildlife 

corridors, especially those that are impacted by infrastructure projects.

Comment noted. The RTP/SCS describes (in Chapter 5) next steps for further developing a 

habitat conservation strategy. Included in the steps is the recommendation to provide 

“incentives for jurisdictions to cooperate across county lines to protect and restore natural 

habitat corridors, especially where corridors cross county boundaries.” The Natural/Farm 

Lands Appendix further supports wildlife corridors in its recommended policies, with the 

specific recommendation to “Encourage and facilitate research, programs and policies to 

identify, protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Additionally, continue support for preserving wildlife corridors and 

wildlife crossings to minimize the impact of transportation projects on wildlife species and 

habitat fragmentation.”

Submitted by Building Industry Association of Southern California, Link

Inc.

Submittal 16364 Related Documents

16364.01 BIASC supports SCAG's commitment to advance the adoption of the RTP/SCS Growth 

Forecast at the jurisdictional level as demonstrated in the Preferred Scenario. Additionally, 

BIASC is opposed to the Alternative #3 Plan as analyzed in the DEIR on the premise that this 

"intensified" plan would, by design, negatively impact the existing built landscape region 

wide, potentially forcing jurisdictions to adopt land use and planning policies in conflict 

with their respective communities needs and individual character, in order to stay 

consistent with the 2016 RTP/SCS intensified scenario. It is also noted that the intensified 

scenario may not include all technical corrections to the growth forecasts for all counties.

Comment noted.

16364.02 Additionally, BIASC has worked closely with SCAG staff to insure the inclusion of identified 

development agreements and entitlements region wide were included in the preferred 

scenario and reflected in the resulting Traffic Analysis Zone (TAZ) mapping. BIASC must 

note, however, that some jurisdictions like Orange County expended greater time and 

resources to reconciling existing entitlements with SCAG modeling outcomes than others, 

and therefore are likely to have a higher degree of over-all accuracy than other counties. 

BIASC requests that any entitlements which may have not been captured through the 

extensive vetting process by SCAG, be included in the future as they might be identified.

Comment noted. SCAG will convene a working group in the Spring/Summer 2016, made up 

of stakeholders and jurisdiction staff, that will work towards capturing any entitlements 

that were not included in the local input process.

16364.03 BIASC sees this current iteration of the RTP/SCS as measured and reflective of both the 

progress made to date by the 2012 Plan and the current economic, technological and 

funding constraints that exist presently and will affect the implementation of this current 

RTP/SCS updated plan. Funding opportunities and strategies will continue to be a 

significant challenge in implementing the 2016 RTP/SCS update, and adherence to sound 

economic impact analysis will be crucial to assuring the Plan contributes to the continuing 

California economic recovery.

Comment noted.

30
holdID Comment Response 

Submitted by Building Industry Association of Southern California, Link

Inc.

Submittal 16364 Related Documents

16364.04 We are pleased to support SCAG's Preferred Scenario as outlined and described in both the 

20162040 RTP/SCS and the Draft Program Environmental Impact Report (DPEIR). SCAG's 

five core principles contained in the RTP/SCS document are reasonable and respectful of 

local growth forecast input as provided by the various jurisdictions and subsequently 

corrected and updated. The Plan's reliance and focus on technology and innovation, rather 

than solely increased land use constraints and density maximization to reduce Vehicle 

Miles Travelled (VMT), reflects a thoughtful and prudent planning approach applied in the 

current Preferred Scenario. With the increasing rate at which fleet change and alternative 

fuels are entering the market, this RTP/SCS update iteration is well timed to take advantage 

of the advances since the 2012 Plan was adopted.

Comment noted.

16364.05 Funding (Long-term): (P.128) The RTP/SCS Summary of Revenue Sources is very heavily 

dependent on tax and fee increases, including new politically sensitive and untested user 

based programs like a proposed VMT tax which is programmed to produce $124 Billion in 

revenue closer to the planning horizon, via a four cent per mile fee. A second anticipated 

fee source is in County Development Impact Fees (DIF's) projected to provide upwards of 

$10 Billion. These are both a major "leaps of faith" on multiple fronts and can have a 

dampening impact on both the affordability of housing and the viability of some already 

depressed markets such as the Inland Empire. BIASC suggests that economic viability be 

highlighted again in this section to include language acknowledging the absolute need for 

balanced approaches to increasing taxes and fees, and the potential to negatively impact 

an already fragile California economy. It is important to underscore the vital nature of job 

creation and affordability to spurring consumer activity and the resulting tax revenue 

generation that is central to badly needed public sector investment. This is consistent with 

the RTP/SCS Goal #1, "Align the plan investments and policies with improving regional 

economic development and competitiveness."

The projected revenue from the mileage-based user fee is equivalent to what existing 

state and federal excise taxes would generate had they been indexed for inflation when 

last adjusted more than two decades ago. An analysis of the economic impacts of the Plan 

is provided in Chapter 7 and the Economic and Job Creation Analysis Appendix. 

Additionally, a comprehensive analysis of the California Road Charge Pilot Program will be 

available no later than June 30, 2018 in accordance with SB 1077. The 2016 RTP/SCS does 

not assume revenue from a mileage-based user fee prior to 2025. The Plan used the 

following guiding principles for identifying reasonably available revenues: establish a user 

fee based system that better reflects the true cost of transportation, provides firewall 

protection for new and existing transportation funds and ensures an equitable distribution 

of costs and benefits; promote national and state programs that include return-to-source 

guarantees, while maintaining flexibility to reward regions that continue to commit 

substantial local resources; leverage locally available funding with innovative financing 

tools (e.g., tax credits and expansion of the Transportation Infrastructure Finance and 

Innovation Act [TIFIA]) to attract private capital and accelerate project delivery; and 

promote funding strategies that strengthen the federal commitment to the nation’s goods 

movement system, recognizing the pivotal role that our region plays in domestic and 

international trade. The Plan includes $10.1 billion in Mitigation Fees generated from 

existing development impact fee programs projected to FY2039-40.

16364.06 Land Use Strategies: (P. ES-9) With regard to the guiding land use strategies, BIASC 

respectfully asks SCAG to consider the following additions concerning SCAG's basic litany: • 

Identify regional strategic areas for infill and investment, including policies that provide 

incentives and avoid conflicts of purpose or intent; • Structure the plan on a three-tiered 

system of centers development; • Develop "Complete Communities"; (Please define 

Complete Communities) • Develop nodes on a corridor; • Plan for additional housing and 

jobs near transit; • Plan for changing demand in types of housing and consumer 

preferences: • Ensure adequate access to open space and preservation of habitat, while 

avoiding conflicts between wildlife and communities as much as possible; and • 

Incorporate local input and feedback on future growth.

Comment noted. The guiding land use policies included in the 2016 RTP/SCS were 

originally developed for the 2008 RTP, and subsequently incorporated in the 2012 

RTP/SCS. The 2016 RTP/SCS continues to utilize these land use policies and the additional 

language proposed in this comment will not be considered for the 2016 RTP/SCS. We 

encourage the BIASC to be a part of the discussion and development of the guiding land 

use policies in the development of the 2020 RTP/SCS. Further clarity has been provided 

regarding "complete communities" consistent with these established policies.

31
holdID Comment Response 

Submitted by California Construction and Industrial Materials Link

Association

Submittal 16294 Related Documents

16294.01 CalCIMA is encouraged by SCAG’s proposed endeavor to coordinate with the Department 

of Conservation (DOC) and California Geological Survey (CGS) to maintain a data base of 

available mineral resources in the SCAG region including permitted and unpermitted 

aggregate resources, and the anticipated 50-year demand for aggregate and other mineral 

resources. As detailed in this section, SCAG plans to work with local agencies on strategies 

to address anticipated demand and avoid transport of materials long distances from 

locations outside the SCAG region, including identification of ways to encourage and 

increase recycling to reduce demand for aggregate. CalCIMA appreciates that industry will 

be included in the strategizing phase of this endeavor to provide perspective related to 

identification of ways to encourage and increase recycling of aggregate.

Comment noted. SCAG will continue to coordinate with the Department of Conservation 

(DOC) and California Geological Survey (CGS) to maintain a mineral resources data base for 

the SCAG region including permitted and unpermitted aggregate resources, and to work 

with agencies to create strategies in anticipation of the aggregate demand in the SCAG 

region.

Submitted by California Cultural Resources Preservation Alliance Submittal 16302 Related Documents Link

16302.01 The 2012 RTP/SCS provided an important stepping stone for the 2016 Plan. In previous 

Plans, natural lands and farmlands were handled under the banner of “land use.” In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn’t be overlooked. We 

believe the opportunity before you isn’t to “plan for” the future of open space in the 

region—as that’s what you’ve been doing since the 2012 Plan. Instead, we believe SCAG 

can now start “implementing” a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. We and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16302.02 We are pleased to see an Appendix devoted directly to natural and farmlands protection in 

the 2016 Plan. We are glad that the Plan contains specific strategies addressing natural land 

and farmlands issues. We would like to see more attention given to archaeological sites and 

other cultural properties. This is a step in the right direction, however we would like to see 

more attention given to the protection of archaeological sites and other cultural resources. 

The culmination of the work from the last RTP/SCS is clearly visible in this Draft Plan. SCAG 

has demonstrated that Metropolitan Planning Organizations can play a vital, thoughtful and 

science-based role in mitigating impacts to our natural environment from transportation, 

infrastructure and other development projects. By incorporating natural, cultural, and 

farmlands protection strategies into your policy document, we believe the many benefits of 

this broad-based conservation approach will be realized sooner than expected. Thank you 

for your leadership.

Comment noted.

32
holdID Comment Response 

Submitted by California Cultural Resources Preservation Alliance Submittal 16302 Related Documents Link

16302.03 Maps contained within the PEIR, RTP, SCS and Appendix should be internally consistent and 

they are not. For example, each map that shows “open space” or “protected lands” should 

be using the same base dataset but they do not. The 2012 Plan resulted in the creation of 

SCAG’s very own geographic information systems (GIS) dataset: the Natural Resource 

Inventory. It is more accurate than what is in the document now and it has been vetted by 

numerous organizations. That’s why it is surprising to see that so few of SCAG’s own GIS 

layers were actually used in the documents’ maps. We urge SCAG to honor its own work 

and that of its partner organizations by using this dataset as the basis for natural and 

farmland mapping. Let’s move forward with the same baseline information.

Comment noted. Each of the maps identified in the comment serve a distinct purpose and 

as such may reference a different data set to fully address its purpose. The various data 

sets each have their own set of constraints, not limited to richness of data and scale, which 

primarily explains the differences in mapping between PEIR and the RTP/SCS. Maps have 

been clarified to properly identify the purpose of the map and the specific data source.

16302.04 Our organization supports the idea that as new growth occurs it should focus on the 

existing infill areas. This is consistent with the finding in the SCAG surveys where 

respondents preferred to see existing urban areas built upon before greenfields are 

targeted for development, especially those at the Wildland-Urban Interface. When 

developments are built in infill areas, it likely relieves pressure from the fringe. However, 

the Plan fails to outline exactly how (or with what mechanism) these fringe lands (or any 

lands) will actually be protected. Just because the pressure is relieved doesn’t mean the 

land then automatically becomes protected. Numerous organizations, ours included, focus 

their work on preservation of important habitat lands. A lot of time, energy, political will, 

strategy and other efforts combine to create a successful conservation transaction that 

leads to permanently conserved lands. SCAG must identify the mechanism, process or plan 

on how the greenfield lands will be protected.

In the coming years, SCAG will be working with local entities to assist in the crossjurisdictional coordination of habitat conservation strategies. Your coalition is encouraged 

to participate in the effort.

16302.05 SCAG focused many sections of the document on formal conservation plans, in the form of 

Natural Community Conservation Plans and Habitat Conservation Plans (NCCP/HCP), as the 

conservation method most identified by the agency. It is important to note that NCCP/HCP 

programs are only one conservation mechanism and they have limitations. For example, 

they are voluntary, property owner driven and generally only apply to larger land 

ownerships. Efforts underway by local, regional, state and federal agencies outside of these 

formal plans should not be discounted and must be included. Furthermore, many 

conservation organizations help facilitate, coordinate and find funding for land 

conservation transactions. We believe the conservation approach promoted by SCAG 

should include all of the ways land is protected, including those less regulated methods of 

conservation outside of NCCP/HCP programs.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation. Suggestions for strategies 

beyond HCPs and NCCPs will be encouraged and appreciated. Your group is encouraged to 

participate in the effort.

33
holdID Comment Response 

Submitted by California Cultural Resources Preservation Alliance Submittal 16302 Related Documents Link

16302.06 The Plan outlines that the region anticipates an additional 3.8 million people by 2040 

providing increased pressure on our existing parkland. Studies document that many 

communities in the Southern California region already do not have enough parkland as 

outlined by the Quimby Act (three acres per 1,000 residents). Throughout the document, 

the Plan promotes providing more access to these existing parks as infill projects are built, 

but nowhere does it state how additional parks will be created. The mechanism is missing. 

More importantly, these city parks are fundamentally different than habitat-focused parks. 

Usually city and regional parks include high intensity recreation oriented activities, like 

soccer and baseball fields, and are turfed. The types of land acquired as mitigation or 

through local conservation efforts typically are focused on preservation of natural habitat 

and less intensive uses (birding, hiking, etc.). In fact, many of these mitigation lands have 

limited or managed public access. Providing “more” access to either high or low intensity 

parks and/or habitat lands may have significant consequences for the land manager. The 

document needs to address the impacts to local parks with increased access from 

expanding populations. The document also needs to address how additional lands will be 

protected, i.e., what mechanism will be used?

Park accessibility is an integral part of sustainable communities as it improves public 

health, air quality, and quality of life. Providing parks within infill areas has a different set 

of challenges that varies by jurisdiction. SCAG encourages jurisdictions to look at funding 

sources, such as the California Department of Housing and Community Development 

(HCD) Housing-related Parks program, to help build and maintain local parks. The Housingrelated Parks program awards money to build and maintain parks based on the number of 

affordable housing units a jurisdiction has built, which can help increase park accessibility 

in traditionally underserved areas. SCAG will continue to provide jurisdictions information 

regarding funding opportunities and encourage jurisdictions to provide parks as part of 

their long-range plans. The term "Natural Lands" is used intentionally to differentiate 

between potentially sensitive habitat areas and urban/suburban parks that provide open 

space and active recreation. Specifically, "Natural Lands" refers to biologically diverse 

areas and landscapes that may provide ecosystem services, such as grasslands, wetlands, 

deserts, forests, shrublands, riparian areas, and other types of habitat lands. Natural Lands 

is not intended to include agricultural croplands, grazing/rangeland, other working lands, 

or municipal parks serving primarily recreational purposes. In the coming years, SCAG will 

be working with local entities to assist in the cross-jurisdictional coordination of habitat 

conservation strategies. Your coalition is encouraged to participate in the effort.

16302.07 The current federal transportation bill, FAST Act, supports understanding transportation 

impacts on natural resources. The previous bill, MAP-21, supported restoring and 

maintaining environmental functions (i.e., wildlife corridors) affected by the infrastructure 

projects in the RTP. SCAG has even supported efforts in Los Angeles County to create a 

wildlife corridor over the 101 Freeway. Many efforts are underway across the region to 

connect landscapes to one another. This is very important to the region and its biodiversity. 

Wildlife corridors allow species to migrate and forage and expand genetic diversity. These 

corridors also allow ecosystems to maintain ecological functions, act as sources for 

repopulation after natural disasters such as fire, flood or landslide, and improve the 

resiliency in the face of climate change impacts. The Plan would be stronger if it supported 

the enhancement of and/or protection of documented and regionally significant wildlife 

corridors, especially those that are impacted by infrastructure projects.

Comment noted. The RTP/SCS describes (in Chapter 5) next steps for further developing a 

habitat conservation strategy. Included in the steps is the recommendation to provide 

“incentives for jurisdictions to cooperate across county lines to protect and restore natural 

habitat corridors, especially where corridors cross county boundaries.” The Natural/Farm 

Lands Appendix further supports wildlife corridors in its recommended policies, with the 

specific recommendation to “Encourage and facilitate research, programs and policies to 

identify, protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Additionally, continue support for preserving wildlife corridors and 

wildlife crossings to minimize the impact of transportation projects on wildlife species and 

habitat fragmentation.”

Submitted by California Department of Transportation Submittal 16147 Related Documents

16147.01.1 Executive Summary Include a summary of the allocated funds, if any, for Promoting 

Waking, Biking and other forms of Active transportation, Leveraging Technology, improving 

airport access, and focusing new growth around transit.

Comment noted. Plan expenditures are detailed in Table 6.5 on page 135. Additionally, 

Table 5 in the Transportation Finance Appendix summarizes capital investments in the 

Plan.

16147.01.1 Major Initiative (page 7): In focusing new growth around transit, it is mentioned that the 

policies support the development of HQTAs on areas with frequency services of every 15 

minutes or less during peak commenting hours. Does this mean that Metrolink Stations 

within San Bernardino Valley area will not be considered as HQTA; therefore, no fund will 

be allocated?

SCAG defines HQTAs as areas within one-half mile of high quality transit corridors and 

major transit stops, as defined in SB375; refer to the definition of HQTA in the RTP/SCS 

Glossary. Under this definition, the San Bernardino County Metrolink stations are 

considered as HQTAs since they qualify as major transit stops.

34
holdID Comment Response 

Submitted by California Department of Transportation Submittal 16147 Related Documents

16147.01.1 Financing our Future (page 8): It is presented that out of forecasted expenditures of $556.5 

billion $274.9 billion is budgeted for operations and maintenance and $250.9 billion for 

transportation capital improvement. Explain where $30.7 billion is planned to be spent. 

What is the plan to spend $5.6 billion after deducting $6.9 billion for TDM and $9.2 billion 

for TSM from $30.7 billion?

Plan expenditures are detailed in Table 6.5 on page 135. As indicated in Table 6.5, debt 

service obligations total $30.7 billion.

16147.01.1 02 Where we are today How We Use Land Today (page 25): the positive effects on real 

estate values, retail sales, ...(gentrification) in HQTAs affects the affordability of the 

currently resides low incomes within certain distance of HATAs. Please explain how that can 

be handled and how environmental justice can be served since they will be forced to leave 

to a more affordable area further from the transit hubs?

In Chapter 3, Challenges in a Changing Region, in the section titled Affordability, 

Gentrification, and Displacement, there is a discussion on the challenges of balancing 

increased development near transit infrastructure and the pressure of the displacement of 

disadvantaged communities. In regard to strategies, as part of its Environmental Justice 

Appendix SCAG has put together an Environmental Justice Toolbox of possible mitigation 

measures to address potential impacts to Environmental Justice communities. On page 

196 of the appendix, there is a list specifically for potential resources and strategies 

related to gentrification and displacement. Because many of these strategies concern local 

land use decisions, the toolbox strategies are voluntary but SCAG encourages communities 

to consider them as part of the local decision-making process.

16147.01.1 04 Creating a Plan For Our Future 2016 RTP/SCS Goals (page 60): please explain the 

projects/programs to achieve goal #7 (Actively encourage and create incentives for energy 

efficiency, where possible). Also, please explain how the reduction of funds as a result of 

increase in Elect/Hybrid cars can be addressed.

The SCAG Regional Council has supported State policies and investments focused on 

achieving improved energy efficiency of consumer, fleet, and transit vehicles. SCAG, 

through its Clean Cities Coalition has facilitated local participation in state funding 

programs such CA Energy Commission (CEC) grants, and Air Resources Board programs. In 

addition SCAG has encouraged local jurisdictions and industry partners in adopting 

sustainable energy-efficient building codes. The Plan notes that funding for transportation 

improvements is currently not sustainable, given the projected needs. Projected revenues 

from the gas tax, the historic source of transportation funding, will not meet 

transportation investment needs – and gas tax revenues, in real terms, are actually in 

decline as tax rates (both state and federal) have not been adjusted in more than two 

decades while the number of more fuel efficient and alternative powered vehicles 

continues to grow. It’s vital that we find new ways to make transportation funding more 

sustainable in the long-term, and efforts are underway to explore how we can transition 

from our current system based on fuel taxes to a more direct system based on user fees. 

Recent action by the state Legislature to launch the California Road Charge Pilot Program is 

a critical step in this transition.

Submitted by California Department of Transportation Submittal 16307 Related Documents Link

16307.01 Caltrans commends SCAG for reaching out and engaging state, regional, and local agencies 

and the public in extensive outreach efforts and for developing a comprehensive planning 

process that included Caltrans staff on several committees. We also commend SCAG for 

separating the closely related, but clearly distinct discussions about climate change, 

greenhouse gas (GHG) emissions, and air quality.

Comment noted.

16307.02 Caltrans compliments SCAG on developing strategies that will allow the region to not just 

meet, but to actually exceed the GHG emission reduction goals mandated under SB 375. 

This Draft 2016 RTP/SCS is commendable for its broad vision, which, while recognizing 

mobility as a primary goal, also encompasses sustainability, the economy, employment, air 

quality and GHG emission reduction, safety, public health and integrated planning.

Comment noted.

35
holdID Comment Response 

Submitted by California Department of Transportation Submittal 16307 Related Documents Link

16307.03 Missing RTP Checklist - Please note, per page 32 of the 2010 RTP Guidelines 

(http://www.dot.ca.gov/hq/tpp/offices/orip/rtp/index_files/2010%20RTPGuidelines_Jan20

11_Technical_Change.pdf), all MPOs are required to submit an RTP Checklist with the Draft 

and Final RTP when the document is submitted to Caltrans. This checklist establishes a 

minimum standard for developing the RTP for federal and state RTP requirements. 

California Government Code Section 14032(a) authorizes the CTC to request an evaluation 

of all RTPs statewide to be conducted by Caltrans. A completed checklist also assists in 

providing for an open and transparent public participation process for the general public, 

federal, state and local agencies.

Comment noted. The Caltrans RTP Checklist will be included in the final submittal of the 

2016 RTP/SCS to reviewing agencies.

16307.04 We recommend that SCAG address the newly adopted transportation act, “Fixing America’s 

Surface Transportation Act (FAST Act).” Specifically, this act could be addressed in the 

Status of the Federal Highway Trust Fund section on page 124 as well as in other federal 

funding sections of the Draft RTP.

Comment noted. The Plan has been updated to reflect passage of the FAST Act.

16307.05 Additionally, we would suggest the SCAG add the FAST Act to the glossary of the RTP. Comment noted. Appropriate edit will be incorporated in the Final 2016 RTP/SCS.

16307.06 Per 23 CFR Part 450.322 (g), each RTP shall include a comparison with the California State 

Wildlife Action Plan (SWAP). It is unclear in SCAG’s draft RTP where that comparison is 

being made. We recommend adding a simple comparison to issues that are relevant in the 

region such as climate change, growth, and development with SWAP in the body of the RTP.

The Natural/Farm Lands Appendix references the implementation strategies outlined in 

the RTP/SCS as parallel to the latest State Wildlife Action Plan. SCAG participated in 

multiple stakeholder group meetings with Department of Fish and Wildlife in the 

development of the State Wildlife Action Plan (SWAP). SCAG's participation is documented 

by the CDFW online at 

https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=112376&inline. Moreover, SCAG 

consulted with various land management agencies to refine potential approaches to 

support the conservation of natural lands and farmlands consistent with State 

conservation planning initiatives, including the State Wildlife Action Plan (SWAP), which 

was being updated in tandem with the development of the Draft RTP/SCS. Participants in 

SCAG's Open Space Conservation Working Group including the San Bernardino Association 

of Governments, LA Metro, Los Angeles County Department of Regional Planning, Friends 

of Harbors Beaches and Parks, Orange County Transportation Authority, City of Mission 

Viejo, City of Irvine, The Nature Conservancy, Building Industry Association, The Trust for 

Public Land, Town of Apple Valley, Endangered Habitats League, Amigos de Los Rios, 

Riverside County Transportation Commission, US Fish and Wildlife Service, and the 

California Department of Fish and Wildlife. This consultation ensured policies expressed in 

the Natural and Farm Lands Appendix, when considered jointly with land use strategies 

and transportation investments set forth in Chapter 5, enable the region to work toward 

consistency with State conservation planning initiatives. As acknowledged on p. 7 of the 

Draft Plan, SCAG will continue this collaborative process to ensure regional policy 

alignment with the updated SWAP once approved by the U.S. Fish and Wildlife Service in 

2016.

36
holdID Comment Response 

Submitted by California Department of Transportation Submittal 16307 Related Documents Link

16307.07 The SCAG RTP should mention how it is coordinated and consistent with the Public TransitHuman Services Transportation Plan. Currently, the Draft RTP only includes this information 

in the Transit Appendix. We suggest that SCAG also make reference to this coordination in 

the body of the RTP.

The following text has been added to page 62 of the 2016 RTP/SCS: "Outreach and 

coordination efforts also included work with providers of public transportation, county 

transportation commissions, and designated Consolidated Transportation Services 

Agencies (CTSAs) to ensure consistency with the plans and programs of these agencies, 

including short and long range plans and Coordinated Public Transit Human Services 

Transportation Plans. A fuller discussion of these plans can be found on pages 61-65 of the 

Transit Appendix."

16307.08 The list of projects labels some projects as “non-reportable Transportation Control 

Measures (TCMs)”. We suggest that SCAG provide a definition for this project type.

Comment noted. A definition for "non-reportable transportation control measures" has 

been added to the Glossary. The following de minimis committed TCMs are defined in the 

Final 2015 FTIP Guidelines as non-reportable TCMs for the purpose of TCM timely 

implementation reporting: • Bus/shuttle/paratransit fleet expansion projects with fewer 

than 5 vehicles; • Bus stop improvement projects; • Bicycle facility less than 1 mile and 

pedestrian facility less than 1/4 mile; • Intelligent transportation systems/control system 

computerization projects with fewer than 3 traffic signals; • Changeable message sign 

projects with fewer than 5 signs; • Bike parking facilities, new or expansion, with nine or 

fewer bike lockers/slots; • Expansion of bus station/shelter/transfer facilities with nine or 

fewer bike lockers/slots; and • Rail station expansion with addition of nine or fewer bike 

lockers/slots.

16307.09 Per Section 33 of the 2006 STIP Guidelines, RTPs need to contain a statement regarding 

consistency between projects in the RTP and the Interregional Transportation Improvement 

Program (ITIP). We suggest that SCAG include the consistency statement regarding projects 

in the RTP and the ITIP.

Section 33 of the 2006 STIP Guidelines states, "Projects included in the interregional 

program shall be consistent with the relevant adopted regional transportation plan(s)." 

Caltrans is responsible for developing and administering the Interregional Transportation 

Improvement Program (ITIP) and the State Highway Operations and Protection Program 

(SHOPP). These programs feed directly into SCAG’s FTIP and form the basis of the baseline 

for the RTP/SCS. The FTIP is an integral part of the RTP/SCS and represents the first six 

years of the Plan. Revenue projections for the State Transportation Improvement Program 

(STIP), including the 25 percent of STIP funding for interregional transportation projects in 

the ITIP, incorporate the California Transportation Commission fund estimate and STIP 

fund estimate as described in the Transportation Finance Appendix. See page 23 of the 

Transportation Finance Technical Appendix for details delineating the consistency 

between projects in the RTP and the ITIP.

16307.10 Per 23 CFR Part 450.322(f)(10)(vi), the RTP must address the specific financial strategies 

required to ensure the identified TCMs from the SIP can be implemented. We suggest that 

SCAG further highlight the TCMs from the SIP that will be implemented within the body of 

the RTP. The RTP needs to contain a list of projects specifically identified as TCMs to be 

implemented in the region. While these projects are listed in the Transportation 

Conformity Analysis Appendix, we suggest that SCAG include some details as well as a 

reference to this information in the body of the RTP.

Comment noted. A cross-reference has been added to Chapter 5, under SUMMARY OF THE 

ENVIRONMENTAL MITIGATION PROGRAM/Air Quality. TCM timely implementation is a 

regional transportation conformity requirement. All relevant information has been 

appropriately documented in the Transportation Conformity Analysis Appendix, Section III, 

Timely Implementation of Transportation Control Measures. In addition, the committed 

TCMs will be identified and included in the SCAG's portion of the 2016 South Coast Air 

Quality Management Plan (commonly known as the Appendix IV-C).

16307.11 Affordable Housing - The California Affordable Housing Sustainable Communities Program 

has helped many residents with incomes that are 30 percent below the area median to buy 

housing. Extending this program or other similar programs will continue the process to 

make housing more affordable in Southern California.

The amount of funding available for the 2015-2016 Affordable Housing Sustainable 

Communities (AHSC) program has been increased to $320 million statewide. SCAG is 

providing technical assistance to all AHSC program applicants and encourages jurisdictions 

to consider the program when looking for funding to provide affordable housing in their 

respective communities.

37
holdID Comment Response 

Submitted by California Department of Transportation Submittal 16308 Related Documents Link

16308.01 Page 4 - “California High-Speed Train system is under construction in the Central Valley, and 

scheduled to begin service to Burbank Bob Hope Airport in 2022 and reach Los Angeles 

Union Station in 2028.” California High Speed Rail Authority (CHRSA) may be shifting 

strategy to build the Initial Operating Segment (IOS) North segment first. More details may 

be included in the 2016 CHSRA Business Plan. Please refer to CHRSA comments.

The CHSRA Draft 2016 Business Plan does not alter the 2028 construction completion 

date/2029 revenue operations date for Phase 1 of the high-speed train system connecting 

the San Francisco Bay Area and Merced to Los Angeles and Anaheim. Due to the Business 

Plan adoption schedule, which will occur subsequent to Regional Council adoption of the 

RTP/SCS, any changes to the IOS construction phasing and schedule adopted by CHSRA 

may be incorporated into the RTP/SCS in a future amendment.

16308.02 Page 6 - “The 2016 RTP/SCS calls for an investment in passenger rail of $38.6 billion for 

capital projects and $15.7 billion for operations and maintenance.” Would operations 

include improving service span and frequency?

As noted, the 2016 RTP/SCS includes $38.6 billion for capital projects and $15.7 billion for 

operations and maintenance. This investment includes capital projects to improve 

passenger rail infrastructure to improve speed and service levels, and safety. The 

operations and maintenance funding levels include paying for the higher train volumes 

allowed by the capital improvements.

16308.03 Page 7 - Include a summary of the allocated funds, if any, for the subsections promoting 

walking, biking and other forms of active transportation, leveraging technology, improving 

airport access, and focusing new growth around transit.

Plan expenditures are detailed in Table 6.5 on page 135. Additionally, Table 5 in the 

Transportation Finance Appendix summarizes capital investments in the Plan.

16308.04 Page 7 - “The 2016 RTP/SCS plans for continued progress in developing our regional 

bikeway network, assumes all local active transportation plans will be implemented, and 

dedicates resources to maintain and repair thousands of miles of dilapidated sidewalks.” 

Would there be dedicated funding?

Comment noted. Funding sources are delineated in the Active Transportation Appendix 

and the Transportation Finance Appendix.

16308.05 Page 7 - In focusing new growth around transit, it is mentioned that the policies support 

the development of HQTAs on areas with frequency services of every 15 minutes or less 

during peak commenting hours. Does this mean that Metrolink Stations within San 

Bernardino Valley area would not be considered as HQTA; therefore, no fund would be 

allocated?

SCAG defines HQTAs as areas within one-half mile of high quality transit corridors and 

major transit stops, as defined in SB375; please refer to the definition of HQTA in the 

RTP/SCS Glossary. Under this definition, the San Bernardino County Metrolink stations are 

considered as HQTAs since they qualify as major transit stops (see Exhibit 5.1, page 71).

16308.06 Page 25 - The positive effects on real estate values, retail sales, (gentrification) in HQTAs 

affects the affordability of the currently resides low incomes within certain distance of 

HQTAs. Please explain how that can be handled and how environmental justice can be 

served since they would be forced to relocate to a more affordable area further from the 

transit hubs?

On page 54 in Chapter 3, Challenges in a Changing Region, in the section titled 

Affordability, Gentrification, and Displacement, there is a discussion on the challenges of 

balancing increased development near transit infrastructure and the pressure of the 

displacement of disadvantaged communities. In regard to strategies, as part of its 

Environmental Justice Appendix SCAG has put together an Environmental Justice Toolbox 

of possible mitigation measures to address potential impacts to Environmental Justice 

communities. On page 195 of the appendix, there is a list specifically for potential 

resources and strategies related to gentrification and displacement. Because many of 

these strategies concern local land use decisions, the toolbox strategies are voluntary but 

SCAG encourages communities to consider them as part of the local decisionmaking 

process.

16308.07 There are no references noting where the percentages for the different modes of 

transportation came from.

Comment noted. Appropriate edits have been made to incorporate this comment. 

16308.08 Page 28, Paragraph 2, last sentence - Is there a specific reference within the body of the 

RTP that addresses this concern (re: lack of bike infrastructure)? If there is, we would 

suggest that SCAG reference a link to it in this paragraph. As it is currently written in the 

Draft, it appears that SCAG is noting a problem with bicycle infrastructure but not 

addressing it.

Chapter 2 (Where we are today) focuses on current conditions. Chapter 5 (The Road to 

Greater Mobility and Sustainable Growth) provides strategies that address the conditions 

detailed in Chapter 2. The various appendices to the 2016 RTP/SCS provide more 

information.

38
holdID Comment Response 

Submitted by California Department of Transportation Submittal 16308 Related Documents Link

16308.09 Page 33 - Under Seaports the document lists ‘...117 metric tons of imports and exports...’ 

Consider using Twenty-Foot Equivalent Units (TEU’s) instead of metric ton measurements, 

which is how goods movement interacts with our transportation systems (Ship to Rail and 

State Highway, and Local Roads Pages 3.17-39-40)

Comment noted. 117 million metric tons was used to capture the entire two-way trade 

volume through the San Pedro Bay Ports. While SPB ports are the largest container port 

complex in the nation, they also handle non-containerized goods that are not expressed in 

Twenty-Foot Equivalent Units (TEUs).

16308.10 Page 47 - First paragraph last sentence, needs to be re-stated, regionally there are career 

areas that have seen growth in jobs with increased pay (i.e. Computer Sciences, Medical, 

Engineering, Accounting, Logistics). Please describe more completely the issues related to 

slow or no recovery, following the recession. Include not only the lack of high income jobs 

for the median household, but the inability to access higher paying jobs that are available, 

but require higher education and/or technical skills.

Comment noted. Text has been added: "This is because of not only the lack of high income 

jobs for the median household, but the inability to access higher paying jobs that are 

available, but require higher education and/or technical skills" before the last sentence 

which is "An increase in the number of low-paying jobs, and the resulting lower income, 

has contributed to more people slipping into poverty."

16308.11 Page 53 - The current number of passenger and freight trains seem off on the Union Pacific 

Railroad’s Los Angeles, Alhambra and Yuma Subdivisions

Comment noted. The graphic on page 53 has been updated to correct misrepresentations 

of the train volumes for both passenger and freight.

16308.12 Pages 60-63 - We would recommend relating the California Transportation Plan (CTP) 2040 

to SB 391 as it addresses GHG reduction targets from the transportation sector of AB 32. 

This is an example of what could be added: Senate Bill 391 (SB 391, 2009) requires the 

Caltrans to prepare the CTP, a long-range transportation plan, anticipated for approval in 

the next year, to reduce GHG emissions. GHG emissions must be reduced to 1990 levels 

from current levels by 2020, and 80 percent below the 1990 levels by 2050 as described by 

AB 32 and Executive Order S-03-05. The upcoming CTP 2040 will demonstrate how major 

metropolitan areas, rural areas, and state agencies can coordinate planning efforts to 

achieve critical statewide goals.

Comment noted. Staff has incorporated language into the Plan to address the 

recommendation. SCAG staff has been working with ARB staff in setting the next round of 

regional GHG emission targets. We are committed to setting and meeting ambitious and 

achievable regional GHG reduction targets pursuant to SB 375. SCAG staff has also been 

serving on the Policy Advisory Committee of CTP 2040 and looks forward to continuing 

collaboration with Caltrans on GHG reduction goals, among others.

16308.13 Page 60 - Please explain the projects/programs to achieve goal #7 (Actively encourage and 

create incentives for energy efficiency, where possible).

The SCAG Regional Council has supported State policies and investments focused on 

achieving improved energy efficiency of consumer, fleet, and transit vehicles. SCAG, 

through its Clean Cities Coalition, has facilitated local participation in state funding 

programs such CA Energy Commission (CEC) grants, and Air Resources Board programs. In 

addition, SCAG has encouraged local jurisdictions and industry partners in adopting 

sustainable energy-efficient building codes.

16308.15 Page 61 - What was the percentage of participation in public outreach compared to the 

SCAG population? How diverse were the participants in terms of socioeconomic criteria 

such as education, income?

There are more than 18 million people in the SCAG region. In terms of active engagement 

(defined by physical attendance at one of SCAG's open houses, workshops, elected official 

briefings and public hearings or input provided by online survey), participation was less 

than one percent of the regional population. Details on the outreach performed, including 

presentations at organizational meetings, campaign emails, community events and flyer 

distributions and media outreach, are highlighted in the Public Participation and 

Consultation Appendix. SCAG does not collect demographic or socio-economic data from 

our participants. However, SCAG made great efforts to engage and provide accessible 

materials for traditionally underrepresented communities and limited English proficient 

populations. SCAG held several environmental justice workshops and focus group 

meetings throughout the region to address the concerns of minority and disadvantaged 

communities. SCAG engaged with Spanish, Chinese, Korean and Vietnamese-language 

press, and held meetings with Native American tribal representatives in the region. 

Additional details are provided in the Public Participation and Consultation Appendix.

39
holdID Comment Response 

Submitted by California Department of Transportation Submittal 16308 Related Documents Link

16308.16 Pages 60-65 - It is not mentioned here or in the appendix what the preliminary scenarios 

were before settling on a preferred scenario. A simple infographic on the process leading to 

the preferred scenario would help clarify this section.

Comment noted. As noted on page 63, please see the Appendix: SCS Background 

Documentation for information on the preliminary scenarios.

Submitted by California Department of Transportation Submittal 16313 Related Documents Link

16313.01 Pages 68-73 - We would suggest including a description of SB 743 since this section focuses 

on Transit Oriented Development (TOD) and HQTAs. It would provide background on 

SCAG’s efforts to follow this bill.

Comment noted. A description of SB 743 has been included in the appropriate section of 

Chapter 5.

16313.02 Page 71, EXHIBIT 5.1 - There is a gap in the 2040 rail stations on West Santa Ana Branch 

between Los Angeles and Orange County. The Metro West Santa Ana Branch (Measure R) 

and OCTA West Santa Ana Branch plans (streetcar) should be coordinated. This should be a 

unified transit corridor between Los Angeles and Santa Ana, to provide new travel options 

to I-5 and I-405 in the Gateway Cities and North Orange County.

The West Santa Ana Branch Corridor (RTP ID 1TR1011) project details were developed in 

part as a result of the Pacific Electric Right of Way/West Santa Ana Branch Alternatives 

Analysis Study performed by SCAG in partnership with Metro, OCTA and the Orangeline 

Development Authority/Eco Rapid Transit, which concluded in 2012. The study did 

evaluate a unified transit corridor connecting Los Angeles and Orange Counties. At the 

conclusion of that study, the project steering committee came to a consensus that the Los 

Angeles County portion of the corridor would move forward into further technical 

refinement, and that Orange County would pursue other transit priorities including those 

identified in the renewed Measure M and the then recently enacted 2010 Long Range 

Transportation Plan. This recommendation was forwarded to SCAG's Transportation 

Committee, who voted to adopt it and forwarded these recommendations to Metro and 

OCTA. The project has since moved forward into technical refinement in Los Angeles 

County without an Orange County component. The Orange County/Santa Ana and Garden 

Grove Streetcar (RTP ID 2TR1001), will, however, use part of the Right of Way in central 

Orange County.

16313.03 Page 73 - A table showing which cities have adopted these plans and policies would be 

useful.

Comment noted. In order to encourage “complete communities” that integrate land use 

and transportation, SCAG introduced two new concepts called “Livable Corridors” and 

“Neighborhood Mobility Areas." These concepts are introduced to give local jurisdictions 

ideas for developing sustainably in other contexts besides dense urban High Quality 

Transit Areas (HQTAs). The Livable Corridors concept features land use strategies that are 

appropriate for lower density growth areas that are served by HQTA bus corridors. The 

Neighborhood Mobility Areas concept features low impact land use strategies and lowcost transportation solutions to replace vehicle miles with low GHG travel modes. SCAG’s 

intention is to assist local jurisdictions by providing a framework and allowing maximum 

flexibility in creating “complete communities." SCAG will continue to work with the local 

jurisdictions that show interest in implementing the RTP/SCS land use policies by providing 

information and resources to support local planning activities, such as the Sustainability 

Planning Grant Program and the Active Transportation Program. More information on how 

SCAG has assisted local jurisdictions with the Sustainability Program can be found in the 

Appendix: SCS Background Documentation, beginning on page 61 of the document. SCAG 

will consider presenting a table showing which jurisdictions have adopted relevant plans 

and policies in future RTP/SCS updates.

40
holdID Comment Response 

Submitted by California Department of Transportation Submittal 16313 Related Documents Link

16313.04 Page 78 - In order to strengthen the discussion on “fix-it-first,” suggest citing or adding 

language from the California Transportation Agency’s Infrastructure Priorities: 

http://www.calsta.ca.gov/res/docs/pdfs/2013/CTIP%20Vision%20and%20Interim%20Reco

mmendations.pdf

Comment noted. SCAG will consider citing or adding language from the California 

Transportation Agency’s Infrastructure Priorities.

16313.05 Page 81 - Under paragraph 1, please note that the SHSP is misidentified as the State 

Highway Safety Plan. The correct title is the Strategic Highway Safety Plan. Additionally, we 

would suggest that the SHSP should be added to the glossary of the RTP.

Comment noted. The Draft 2016 RTP/SCS has been updated to reflect the correct title of 

the California's plan and the glossary has been updated with a definition of the Strategic 

Highway Safety Plan.

16313.06 Page 85 - No mention of the Slauson Light Rail Corridor in any other planning documents. 

The Western segment shown on the map is being planned as a bike path. The eastern 

segment, not shown on the map, continues through the Gateway Cities to North Orange 

County. The right of way could be an alternative route for Metro Gold Line Eastside 

extension to Whittier. There is a significant gap on the West Santa Ana Branch between Los 

Angeles County and the Santa Ana Streetcar. This corridor should be planned as a whole 

and not fragmented. The West Santa Ana Branch could provide an alternative to I-5, I-405 

and connect the Gateway Cities to North Orange County.

The Slauson Light Rail Corridor is described in the Harbor Subdivision Transit Corridor 

Alternatives Analysis, published by Metro in 2009. It is referred to as the Redondo Junction 

Crenshaw Corridor in that document. The Metro Eastside Transit Corridor Phase 2 (RTP ID 

1TR0704) has not selected a final alignment, but the final alignment decision will be made 

by Metro. The West Santa Ana Branch Corridor (RTP ID 1TR1011) project details were 

developed in part as a result of the Pacific Electric Right of Way/West Santa Ana Branch 

Alternatives Analysis Study performed by SCAG in partnership with Metro, OCTA and the 

Orangeline Development Authority/Eco Rapid Transit, which concluded in 2012. At the 

conclusion of that study, the project steering committee came to a consensus that the Los 

Angeles County portion of the corridor would move forward into further technical 

refinement, and that Orange County would pursue other transit priorities including those 

identified in the renewed Measure M and the then recently enacted 2010 Long Range 

Transportation Plan. This recommendation was forwarded to SCAG's Transportation 

Committee, who voted to adopt it and forwarded these recommendations to Metro and 

OCTA. The project has since moved forward into technical refinement in Los Angeles 

County without an Orange County component. The Orange County/Santa Ana and Garden 

Grove Streetcar (RTP ID 2TR1001), will, however, use part of the Right of Way in central 

Orange County.

16313.07 Page 88 - “For example, the Rail2Rail pass allows Metrolink monthly pass riders who have 

origin and destination points along the LOSSAN corridor to ride Amtrak. In 2014, the North 

County Transit District (NCTD) reached an agreement with Caltrans Division of Rail (DOR), in 

which five daily Pacific Surfliner trains stop at all non-Pacific Surfliner Amtrak (Coaster) 

stops in San Diego County.” The LOSSAN Board and SCRRA have not reached agreement on 

continuation of Rail 2 Rail. The program may be eliminated.

Comment noted. The inclusion of these existing cooperative fare agreements in the 2016 

RTP/SCS serves to illustrate the benefits of such agreements in increasing passenger rail 

ridership and providing an incentive to attract new riders to the passenger rail services in 

the SCAG region.

16313.08 Page 90, Exhibit 5.3 - The “OC Loop” project is not included. The OC Loop is included as part of the Regional Greenway Network in Chapter 5 (Page 92) 

of the Final RTP/SCS and is part of Exhibit 5.3 Regional Bikeway Network.

16313.09 Page 95, second column Highways and Arterials - the Draft RTP/SCS states “....As part of the 

plan, strategic High Occupancy Vehicle (HOV) gap closures and freeway-to-freeway direct 

HOV connectors are proposed to complete the system.” Please modify to read as ‘....As part 

of the plan, strategic HOV gap closures, freeway-to-freeway direct HOV connectors, and 

HOV direct access ramps need to be proposed as a strategy to complete the system.’

Comment noted. Appropriate edits have been made to incorporate this comment.

41
holdID Comment Response 

Submitted by California Department of Transportation Submittal 16313 Related Documents Link

16313.10 Page 96, Table 5.5 Sample Major Highway Projects Committed by the Counties - The term 

“Committed by the Counties” is misleading. There may be projects on these lists that were 

not environmentally cleared. Caltrans understands there are certain assumptions needed 

to assist with the planning process, but the descriptions should not imply project specifics 

that may be contradictory to any alternatives that still need to be analyzed. Consider 

including language that explains what assumptions were made (particularly in the FTIP), 

why they were needed, and that pending environmental clearance.

Comment noted. Appropriate edits have been made to incorporate this comment.

16313.11 Page 96, Table 5.5 Sample Major Highway Projects Committed by the Counties - List should 

include Mixed Flow (MF) lanes on I-405 between SR-73 and I-605.

Comment noted. Appropriate edits have been made to incorporate this comment.

16313.12 Pages 97-98, Tables 5.6 and 5.7 Major HOV Projects/Freeway-to-Freeway HOV Connectors 

and Express/HOT Lane Network – Consider adding the word ‘Lane’ after HOV to the main 

title for Table 5.6 (to clarify difference from Connector in the next section). Consider 

labeling the tables to reflect “Baseline 2040” or “Plan 2040”.

Comment noted. Appropriate edits have been made to incorporate this comment.

16313.13 Page 113 - It would be good to mention tribal cultural resources in this section since AB 52 

identifies tribal cultural resources as a new addition of mitigation measures in CEQA and 

would require consultation with tribes to assess projects that may impact their resources.

Comment noted. Appropriate corrections to the mitigation measures in the PEIR are 

incorporated and reflected in the Clarifications and Revisions section of the Final PEIR. 

Please also see Chapter 8, Responses to Comments in the PEIR. The environmental 

mitigation measures included in Chapter 5, Environmental Mitigation Measures, of the 

2016 RTP/SCS are consistent with the performance standards-based mitigation approach 

used in the PEIR and reflect the general scope of the PEIR's mitigation measures.

16313.14 Page 118 – Typographical error: “...to smooth extreme congestion to more ARB friendly 

speeds.”

Comment noted. Appropriate edit has been incorporated in the Final 2016 RTP/SCS.

16313.15 Pages 170-171 – The document needs to resolve inconsistencies between narratives and 

tables regarding managed lanes – the Strategic Plan targets expansion of HOV, but not 

Planned Managed Lanes (Page 170), then proceeds to list “congestion pricing 

demonstration projects” and “expanded express/HOT lane network” as major projects on 

Table 9.1 (Page 172).

The Strategic Plan does include managed lane investments. As noted, Table 9.1 indicates 

additional investment in express lanes. Table 9.1 will be modified to also highlight key HOV 

lanes included in the Strategic Plan Project List.

16313.16 Page 171 – The document does not provide enough detail and guidance on the term 

‘Corridor Sustainability Studies’ (CSS).

Comment noted. Please refer to the Highways and Arterials Appendix, which provides 

further information regarding Corridor Sustainability Studies.

42
holdID Comment Response 

Submitted by California Department of Transportation Submittal 16313 Related Documents Link

16313.17 • Page 171 – The major strategic projects for each region are listed in Table 9.1. Imperial, 

San Bernardino and Ventura Counties have one project identified for each region. While in 

the comprehensive list of the strategic projects for the three regions as contained in Project 

List Appendix, Imperial County has 33 projects, San Bernardino County has 3 projects, and 

Ventura County has 3 projects. What criteria was applied to screen out projects? There is 

no information about the approximate costs associated with projects mentioned in the 

documentation. If the major projects are only relevant individually to the region, can we 

add more projects from into the “Major” category? The summary of the regions’ strategic 

projects is as follows:<see attachment> As shown in the above table, the percentage of 

major projects in the strategic plan follows a pattern. The larger regions with bigger shares 

of federal formula Obligation Authority (OA) tend to have lower percentage of major 

projects, probably because of competitions among their long lists of projects. However, 

Imperial County has the “major” percentage on a par with that of Los Angeles. Is this 

indicating the same level of competition among the Imperial strategic projects as that 

among the projects in Los Angeles or another way saying the Imperial region is 

underfunded?

Comment noted. Strategic list of projects are financially unconstrained. These projects are 

identified as potential projects for consideration in the future RTP/SCS, should funding 

become available and consensus emerges to consider these projects as regional priorities. 

The list on page 171 in the main document is intended only for illustrative purposes. 

Please see the Project List Appendix for a complete list of strategic projects identified in 

the Plan.

16313.18 Page 173 – “Metrolink recently completed its long-range Strategic Assessment in 2015 and 

it forecasts growth in the number of daily trains from 165 current weekday trains today to 

240 weekday trains by 2025. In addition, the 2012 Los Angeles – San Diego – San Luis 

Obispo Rail Corridor (LOSSAN) Strategic Implementation Plan (SIP) forecasts up to 310 

weekday Metrolink trains by 2040.” Metrolink would need to operate over 500 trains per 

day to provide the level of service comparable to commuter rail systems in New York, 

Philadelphia, Chicago and the Bay Area. There should be regional funding mechanism to 

provide the level of capital and operating funds needed for this level of service. A Regional 

Express bus system could also fill gaps and provide extensions to the expanded commuter 

rail system.

Comment noted. The 2016 RTP/SCS calls for increased and dedicated funding sources for 

passenger rail. These include additional county sales tax initiatives, the new State Cap-andTrade Transit and Intercity Rail Capital Program, and increased and dedicated federal 

funding.

16313.19 Page 178 – The definition for Baseline says it “is based on the adopted 2011 FTIP.” This 

looks like a carryover from the previous RTP, please correct year to 2015.

Comment noted. Appropriate edit has been incorporated in the Final 2016 RTP/SCS.

Submitted by California Department of Transportation Submittal 16319 Related Documents Link

16319.01 Page 5 - A graphic on this page details the various bicycle classifications included in the 

Caltrans Highway Design Manual (HDM). The HDM was recently updated to include a new 

classification of Class IV facilities. Please update the graphic to include the new narrative of 

Class IV Separated Bikeways, instead of the term “Cycletracks”.

Narrative and graphic updated to reflect the change in the California Highway Design 

Manual.

16319.02 Page 62, Exhibit 27 - A graphic on this page shows many “Regional Bikeways” and “Local 

Class 1 bikeways” detailed in red. According to the latest Orange County Bikeways Map, 

many of those areas included in solid red are not actually Class I bikeways, particularly SR39 (Beach Boulevard) and SR-1 (Pacific Coast Highway). Additionally, SR-133 (Laguna 

Canyon Road) is listed as a Class III bikeway, which is inaccurate as well. Please cross 

reference with OCTA Bikeways Map at (http://www.octa.net/pdf/BikewaysMap_2013-

0504.pdf) and Caltrans Transportation Concept Reports for SR-1, SR-39, and SR-133 

(http://www.dot.ca.gov/dist12/planning/)

Comment noted. Regional Bikeways are highlighted in a larger red line than Class 1 

bikeways to represent the regional route structure in relation to local bikeways and are 

not meant to denote type of bikeway per the legend at bottom of map.

43
holdID Comment Response 

Submitted by California Department of Transportation Submittal 16319 Related Documents Link

16319.03 In general, the report mentions existing HOV lanes and those that are planned. Overall, the 

projects listed in the report are somewhat similar to what we have. The report also 

mentions the success of the SR-91 Express lanes in OC County and the I-10 and I-110 

Express lanes in LA County. The following is stated on page 6 of the Highways and Arterial 

Appendix “...integration of value pricing to better utilize existing capacity and to offer users 

greater travel time reliability and choices. As previously mentioned, Express/High 

Occupancy Toll (HOT) Lanes that are appropriately priced to reflect demand can 

outperform non-priced lanes in terms of throughput, especially during congested periods.”

Comment noted.

16319.04 Also, it discusses Base Year 2012 network compared to Baseline 2040 network and Plan 

2040 network on pages 23 through 26 of the Highways and Arterial Appendix. As stated in 

Table A5 below (Plan 2040), the number of miles of HOV lanes in Los Angeles County shows 

a significant drop from present numbers, whereas HOT lanes have significantly increased as 

compared to Table A3 below (Base Year 2012).

Comment noted. Once HOV lanes are converted to Express Lanes, they are no longer 

counted as pure HOV lanes.

16319.05 The following is stated on page 95 of the Draft 2016-2040 RTP/SCS: “In addition to 

expanding the HOV network, another proposed strategy is to make certain HOV lanes 

continuously accessible. Various highways within Orange County feature this and studies 

show that continuous-access HOV lanes do not perform any worse compared with limitedaccess HOV lanes. Continuous-access HOV lanes give carpoolers greater freedom of 

movement in and out of the HOV lane network...”

Comment noted.

16319.06 Pages 40 map and page 41: Additional HOV projects completed in Los Angeles/Ventura 

Counties between year 2012 and 2015: 1) LA I-5/SR-14 HOV Connector (Dec 2012) 2) LA I-5 

HOV lane from Hollywood Way to SR-118 (June 2015) 3) LA SR-170/I-5 HOV Connector 

(June 2015) 4) VEN 101 HOV lane from Mobile Pier Rd to Santa Barbara County line (March 

2015) I-10 HOV lane project from I-605 to Puente Ave was completed in December 2013. 

Other segments of the I-10 HOV lane project from Puente Avenue to SR-57 are either in 

design phase or under construction. The map on page 41 of the report illustrates as the 

entire segment of the I-10 HOV lane from I-605 to SR-57 as existing. I-5 HOV lane from 

Orange County line to I-605 is currently under construction. The map on page 41 and 

description on page 42 of the report identifies this segment of the HOV lane as being 

completed.

Comment noted. Appropriate edits have been made to incorporate this comment.

16319.07 I-5 from Orange County line to I-605 is also an HOV lane project as stated on pages 33 and 

141 of the project list in the appendix. The map on pages 42 and 94 of the report identifies 

this segment as mixed flow lane only.

Comment noted. On page 41, the I-5 South Corridor project is also identified as an HOV 

improvement.

16319.08 SR-71 from I-10 to San Bernardino County line involves the addition of 1 HOV lane and 1 

mixed-flow lane as stated on pages 35 and 144 of the project list in the appendix. The map 

on pages 42 and 94 of the report identifies this segment as mixed flow lane only.

Comment noted. Appropriate edits have been made to incorporate this comment.

16319.09 The following comments are for HOV/HOT lanes in Los Angeles/Ventura Counties: “The 

result has been 27 more miles of regional HOV lanes on Interstates 5, 405, 10, 215 and 605, 

on State Route 57 and on the West County Connector Project within Orange County.” 

Please consider specifying if the 27 miles is centerline or lane-miles.

Comment noted. Appropriate edits have been made to incorporate this comment.

44
holdID Comment Response 

Submitted by California Department of Transportation Submittal 16319 Related Documents Link

16319.10 We did not see discussion of Senate Bill 788 that authorizes relinquishment of a large 

portion of State Route 86 and resignation of the section by Westmorland.

Comment noted.

16319.11 Page 5 - Table 1, Please Include SR-91 Corridor System Management Plan (CSMP) for 

Orange County (from I-5 to Riverside County).

Comment noted. Appropriate edits have been made to incorporate this comment.

16319.12 Pages 9 & 20 - Maps of unconstrained network do not match tables for planned managed 

lanes – I-5 not included in network (Table 2 vs. Exhibit 8).

Comment noted. Table 2 has been revised to incorporate this comment.

16319.13 Page 10 - Table 5 Highway Investments, consider adding the cost multiplicative factor (e.g. 

millions, billions, etc.).

Comment noted. Appropriate edits have been made to incorporate this comment.

16319.14 Page 10 - Table 5 Highway Investments, there is an Asterisk (*) after HOT Lanes but no 

accompanying footnote explaining what it denotes.

The symbol noted is actually a quote ("), which is a typo and has been corrected.

16319.15 Page 10 - Table 5 Highway Investments, Regional Total $36.1. Consider labeling the table to 

denote which set of projects are included (e.g. Baseline 2040 vs. Plan 2040).

Comment noted. Appropriate edits have been made to incorporate this comment.

16319.16 Page 95 - Please note that Orange County is not the only sub-region that has continuous 

access HOV facilities. (e.g. on the SR-210 between I-15 and I-215).

Comment noted. Appropriate edits have been made to incorporate this comment.

16319.17 Page 96, Table 5.5 Sample Major Highway Projects Committed by the Counties - The term 

“Sample” is misleading. If this list only shows what the county transportation commissions 

have stated in their planning documents, consider revising the title of the table and/or 

include a column stating the source (e.g. LA MTA LRTP, VCTC CTP, OCTA LRTP, ...etc.), or 

consider using the FTIP list as shown on Table 3 of the Highways & Arterials Appendix.

Comment noted. Table 5.5 is intended for illustrative purposes only. Please refer to the 

Project List Appendix for a complete list of projects.

Submitted by California Department of Transportation Submittal 16323 Related Documents Link

16323.01 Revise project cost for Los Angeles State Highway LA0G1116 Route 1: Pacific Coast Highway 

and Parallel Arterials I-105 to I-110: Signal Synchronization (EA 30990 PPNO 4800) to $9,000

Comment noted. We have addressed all modification requests to the Project List as 

submitted by county transportation commissions through the standard RTP long-range 

project list modification and FTIP database update processes. As part of that process, 

modifications to FTIP ID #LA0G1116 have been addressed.

16323.02 Add "Reconfigure" to LA0G874, to read as "Route 405: Reconfigure Crenshaw Blvd On/Off 

Ramps: Construct a New SB I-405 On-Ramp and Freeway & Local Streets Widening [EA 

29360 PPNO 4551]"

Comment noted. We have addressed all modification requests to the Project List as 

submitted by county transportation commissions through the standard RTP long-range 

project list modification and FTIP database update processes. As part of that process, 

modifications to FTIP ID #LA0G874 have been addressed.

16323.03 The Orange County Transportation Authority’s Renewed Measure M (M2) specifies that 

Projects A through M regarding freeway improvements will “add new lanes” or “add 

capacity”. The M2 project descriptions in the 2016 RTP/SCS and PEIR need to be consistent 

with the languages in M2. Otherwise, it could be pre-decisional for upcoming projects. For 

example, District 12 is currently working with OCTA on the preferred alternative for the SR 

55 widening project. The SR 55 project should be described as “Add a new lane in each 

direction on SR 55 between I-405 and I-5” without specifying as “Add a mixed-flow lane.”

Comment noted. SCAG has addressed all modification requests to the Project List as 

submitted by county transportation commissions through the standard RTP long-range 

project list modification and FTIP database update processes. The project descriptions 

included within the Project List are consistent with the funded M2 projects as described in 

the OCTA's Long Range Transportation Plan (Outlook 2035).

45
holdID Comment Response 

Submitted by California Department of Transportation Submittal 16323 Related Documents Link

16323.04 In both Table 1 and Table 2, Orange County, State Highway section,- The description of 

projects on 405 (ORA 030605 and ORA 030605A) refer to phase 1 and phase 2. This project 

will not be phased anymore.

Comment noted. At the moment, the two projects are being carried over into the 2017 

FTIP as two separate projects. We will work with OCTA through future amendment to 

reflect the project as a single project as needed and appropriate.

16323.05 In both Table 1 and Table 2, Orange County, State Highway section – For Project ID 

ORA131303; SR 57 Orangewood to Katella – Add 1 MF Lane Northbound between 

Orangewood and Katella (Utilize Toll Match for RSTP) ENG Only; the dollar amounts are 

different in Table 1 versus Table 2 ($6,500K for FTIP Vs $34,500K for Financially-constrained 

RTP). The correct total project (RTP ID 2TK01116) amount is $124,600 (Project Cost 

$1,000’s). Please clarify the difference.

Comment noted. The project cost for FTIP ID# ORA131303 accounts for the engineering 

(ENG) only, while the project cost for RTP ID# 2TK01116 covers all phases of the project 

throughout right-of-way and construction. Hence the difference in project costs between 

the two Project IDs.

16323.06 Change the completion year for 2H01143-ORA111001 to 2018. Change the completion year 

for 2H01143-ORA111002 to 2017. Change the completion year for 2H01143-ORA990929 to 

2018.

Comment noted. We have addressed all modification requests to the Project List as 

submitted by county transportation commissions through the standard RTP long-range 

project list modification and FTIP database update processes. We will work with OCTA 

through future amendment to reflect the most current completion year for the specified 

projects.

16323.07 Change Route Name for S2160008 to "I-5/MARGUERITE PKWY" Comment noted. Appropriate edits have been made to incorporate this comment.

16323.08 Please include the following tolling projects into the constrained RTP in Orange County: I405 from SR-73 to SR-55; SR-55 from I-405 to SR-91; I-5 from SR-55 to SR-91. The I-605 and 

SR-73 projects in the current draft proposal (Tier 1) will be replaced by the above-listed I405 and I-5 projects, and the SR-55 project will stay the same.

The constrained express lane segments in Orange County may be adjusted or changed to 

reflect the new findings and recommendations from SCAG’s Express Travel Choices Study 

and Caltrans District 12’s Managed Lane Network Study in subsequent amendments to the 

Plan. Both studies are expected to be completed in the summer of 2016.

16323.09 Successful regional implementation of managed lanes is best capitalized by solid toll 

reinvestment strategies. Leveraging toll revenues to fund transit improvements, Complete 

Streets initiatives, Intelligent Transportation System (ITS) technologies, or other eligible 

projects would have profound long-term benefits for the region. HOT facilities are a vital 

funding source and an integral component when completed of a multimodal transportation 

system that would facilitate greater travel choices and reduce regional greenhouse gas.

Comment noted. The Plan includes an extensive network of managed lanes, including a 

regional network of express lanes and HOV lanes extending in five of the six SCAG region 

counties.

Submitted by California Department of Transportation Submittal 16370 Related Documents Link

16370.01 Caltrans commends SCAG for considering some of the health risks associated with the RTP. 

The Health Risk Assessment in Appendix J only analyzed emissions, cancer risk impacts 

associated with Air Quality, and was only focused on several corridors in the region. 

Caltrans recommends that Health Risk/Impacts should first be addressed at the policy level 

and analyze the potential health risks associated with Air Quality, Noise, Hazardous Waste 

and Community Impact for the complete RTP, considering all the projects included in the 

plan.

Comment noted. The 2016 RTP/SCS includes for the first time a broader analysis of the 

public health impacts of the plan within the Public Health Appendix. The policy framework 

within the Public Health Appendix was reviewed by SCAG's policy committees and includes 

seven focus areas that were identified for analysis at the policy level. These include Access, 

Air Quality, Affordable Housing, Climate Adaptation, Economic Opportunities, Physical 

Activity and Transportation Safety. SCAG plans to expand the current policy framework to 

include additional public health analysis in future RTP cycles and will consider these 

suggestions.

46
holdID Comment Response 

Submitted by California High Speed Rail Authority Submittal 16328 Related Documents Link

16328.01 The California High-Speed Rail Authority (Authority) looks forward to continued 

collaboration and advancement of the Memorandum of Understanding with Southern 

California transportation agencies that outlines a shared commitment to improving 

passenger rail service across the region, full integration of high-speed rail (HSR) into the 

regional transportation system and reducing GHG emissions through the funding and 

delivery of local early investment projects that will improve rail service immediately as the 

first step to bringing HSR into the Southern California region. These efforts will also help to 

relieve automobile and train congestion, reduce vehicle emissions including greenhouse 

gas emissions, and improve safety. In addition, the Authority is actively working with its 

partners planning and identifying strategic investments in the Phase 2 Los Angeles to San 

Diego via the Inland Empire corridor, mutually beneficial to HSR service and local, regional 

and intercity service.

Comment noted. The 2016 RTP/SCS includes funding in the financially constrained plan to 

deliver the Southern California High-Speed Rail Memorandum of Understanding projects in 

advance of true high-speed rail arriving in our region. SCAG looks forward to continuing to 

work with the Authority and county transportation commission partners towards this 

progress.

47
holdID Comment Response 

Submitted by California High Speed Rail Authority Submittal 16328 Related Documents Link

16328.02 Beyond the HSR system itself, the Authority—in collaboration with many partner 

agencies—is also implementing a statewide rail modernization plan that will provide nearand long-term benefits to the regional transportation networks that connect to HSR, 

including the San Luis Obispo-Los Angeles-San Diego (LOSSAN) rail corridor, Metrolink, and 

Metro light rail systems. Some of these capital improvements contain funding from The 

Safe, Reliable High- Speed Passenger Train Bond Act for the 21st Century (Proposition 1 A). 

Of the 15 Proposition 1A- funded HSR connectivity projects, five are located in SCAG’s 

jurisdiction: Metrolink Positive Train Control: The project consists of installing predictive 

collision avoidance technology throughout the Metrolink system. As described in the 

2016/2040 RTP/SCS, Metrolink is the first passenger railroad in the nation to have its entire 

system (territory, equipment, and crew) in-service with Positive Train Control (PTC). 

Accordingly, the Southern California Regional Rail Authority (SCRRA) will continue to 

perform version upgrades to its onboard software and upgrades to other PTC subsystems in 

order to maintain compatibility and inter-operability. The implementing agency is SCRRA 

who has received $35 million in Proposition 1A funds for the project. Metrolink High-Speed 

Rail Readiness Program: The project consists of acquisition of 20 high- powered, Tier 4 

locomotives. The implementing agency is SCCRA which has received $68.5 million in 

Proposition 1A funds for the project. An additional $20.2 million remains programmed and 

will be used for the Locomotive Rehabilitation project. Positive Train Control, Los Angeles 

to Fullerton Triple Track: The project includes the installation of PTC components, the scope 

of which includes but is not limited to, the installation of links between key transmission 

stations and control points along the BNSF Railway Company right of way; the installation 

of signal bungalows; and the installation of critical locomotive and cab car on¬board 

equipment. The implementing agency is Caltrans, which has received $2.94 million for the 

construction phase. Positive Train Control, Moorpark to San Onofre: The project will 

implement all aspects of PTC technology along the LOSSAN corridor between Moorpark and 

San Onofre. These improvements will provide direct benefits by improving operations and 

safety for Amtrak and Metrolink trains that serve the LOSSAN corridor. The implementing 

agency is SCCRA, which has received $46.6 million in Proposition 1A funds for the project. 

Regional Connector Transit Corridor: The project consists of construction of a two-mile 

extension that will link the Metro light rail network and provide connections to HSR 

through Downtown Los Angeles, including construction of three new underground light rail 

stations. The implementing agency is Metro which has received $114.9 million in 

Proposition 1A funds for the project.

Comment noted. SCAG appreciates and acknowledges the importance of the statewide rail 

modernization efforts and the Proposition 1A-funded HSR connectivity projects.

16328.03 The Authority is also actively engaged in station area planning activities with many HSR 

Phase 1 station cities to assist cities in planning for the transportation, access, land use, and 

economic effects of a new HSR station and prepare for opportunities for housing and infill 

development around the station locations that aligns with local priorities. Please note that 

the Authority and the Cities of both Burbank and Palmdale have recently entered into 

station area planning contracts.

Comment noted. Station area planning efforts are discussed in the Passenger Rail 

appendix.

48
holdID Comment Response 

Submitted by California Native Plant Society - Orange County Chapter Submittal 16231 Related Documents Link

16231.01 OCCNPS is pleased to see that the California Native Plant Society (CNPS) On-Line Electronic 

Inventory of Rare and Endangered Vascular Plants of California (CNPSEI 2015) is one of the 

technical databases reviewed to develop the 2016 RTP/SCS/PEIR’s bioresource lists. CNPS 

also publishes the online Manual of California Vegetation 

(cnps.org/cnps/vegetation/manual.php), a definitive system for describing vegetation 

statewide that has been accepted by state and federal agencies. The Manual’s system 

would provide more accurate and detailed descriptions of the SCAG region’s vegetation 

than does that used in the 2016 RTP/SCS/PEIR.

Comment noted.

16231.02 OCCNPS’ Emergent Invasive Plants Program (occnps.org/invasives.html), while focusing on 

invasive plant species that are new to Orange County, contains much information that is 

applicable to invasive plants anywhere in the coastal plain portion of the SCAG region; we 

offer it for SCAG’s use. We hope that SCAG will espouse the use of Best Management 

Practices (BMPs) to help prevent the inadvertent spread of invasive plant seeds via 

vehicles, equipment and personnel at transportation-improvement project sites.

Comment noted. SCAG appreciates your contribution to the database.

16231.03 The Natural and Farmlands Appendix provides SCAG with the background and opportunity 

to start implementing a regional conservation program, rather than planning for the future 

of open space in the region. With such implementation, SCAG can take a more serious 

leadership role in regional conservation, can actively seek funding to implement 

conservation efforts by partnering with agencies, transportation commissions and nonprofits. A strong focus on preserving natural lands would be a way that the 2012 Plan can 

come to fruition through the 2016 Plan.

Comment noted.

16231.04 1. Consistency is needed in the maps: SCAG developed its own geographic information 

systems (GIS) dataset, the Natural Resource Inventory, as a result of the 2012 Plan. SCAG 

and its partner organizations put much work into developing the Inventory, and it was 

vetted by numerous organizations. So it is puzzling that so few of the Inventory’s GIS layers 

appear to have been used in the RTP/SCS/PEIR. ’s maps. The Inventory’s baseline 

information is the more accurate and should be the basis for the RTP/SCS/ PEIR, especially 

for the “natural and farmland” maps. For example, there seems to be confusion in the 

terms “undevelopable” and “undeveloped.” The PEIR’s Fig. 3.4.2-5 shows (in Orange 

County) much of Rancho Mission Viejo’s land as Undevelopable. But the Rancho is at this 

time developing its lands according to its 2004 Ranch Plan. (The Ranch Plan includes that 

some 17,000 acres are to be dedicated as preserved open space once its planned 14,000 

dwelling units have been built. So the 17,000 acres may indeed be “undevelopable” but the 

remainder of the Rancho’s lands are certainly developable--though not all are developed at 

this time.) The PEIR’s Fig. 3.11.2-2 and Fig. 3.11.2-5 and Table 3.11.2-2 define the same 

lands as “Undevelopable or Protected.” Conversely, the RTP/SCS’ Natural and Farm Lands 

Appendix Exhibit 3, “Protected Lands in the SCAG Region,” correctly shows the Rancho 

lands as partly private (i.e. developed, or soon to be) and partly as NGO (i.e. the 17,000 

acres that will be The Reserve at Rancho Mission Viejo Habitat Reserve).

Comment noted. Each of the maps identified in the comment serve a distinct purpose and 

as such may reference a different data set to fully address its purpose. The various data 

sets each have their own set of constraints, not limited to richness of data and scale, which 

primarily explains the differences in mapping between PEIR and the RTP/SCS. Maps have 

been clarified to properly identify the purpose of the map and the specific data source.

49
holdID Comment Response 

Submitted by California Native Plant Society - Orange County Chapter Submittal 16231 Related Documents Link

16231.05 2. What Conservation Mechanism(s) Can or Will be Used for Natural and Farmlands 

Preservation? The RTP/SCS/PEIR should identify mechanisms, processes or plans that will 

be employed to combine and marshal the time, energy, political will, strategy and other 

efforts needed to create successful conservation transactions that lead to permanently 

conserved land. Implementing such mechanisms is part of implementing the regional 

conservation program, in which SCAG could take a more serious leadership role now that 

the Natural and Farmlands Appendix provides the background and opportunity. Policies to 

promote development in infill areas is one such mechanism, and likely relieves pressure to 

develop natural and farm lands. But the relief of pressure doesn’t mean the natural and 

farm lands are automatically protected. Unless the lands are formally protected, they likely 

will again be proposed for development, whether or not infill is completed.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your group is 

encouraged to participate in the effort.

16231.06 3. What Mechanism(s) Can or Will be Used to Accommodate Access to Preserved Lands? 

The RTP/SCS/PEIR does not clearly differentiate between access appropriate to city and 

regional parks and access appropriate to habitat lands. Throughout the document, the Plan 

promotes providing more access to existing and new parks as infill projects are built. But 

infill, by definition, takes place within already-built areas. Parks within the built 

environment have fundamentally different purposes and uses than preserved natural 

lands. Such lands typically are focused on preservation of natural habitat and low-impact 

uses (flower-watching, birding, hiking, etc.). Limited and strictly managed public access may 

be part of the conditions under which these mitigation lands were preserved. Promoting 

“more” access to such habitat lands may have significant consequences for these lands and 

their managers.

The term "Natural Lands" is used intentionally to differentiate between potentially 

sensitive habitat areas and urban/suburban parks that provide open space and active 

recreation. Specifically, "Natural Lands" refers to biologically diverse areas and landscapes 

that may provide ecosystem services, such as grasslands, wetlands, deserts, forests, 

shrublands, riparian areas, and other types of habitat lands. Natural Lands is not intended 

to include agricultural croplands, grazing/rangeland, other working lands, or municipal 

parks serving primarily recreational purposes.

16231.07 4. Both Formal And Informal Conservation Plans Are Important: SCAG seems to identify 

formal conservation plans, such as Natural Community Conservation Plans and Habitat 

Conservation Plans (NCCP/HCP), as the much-preferred conservation method. But 

NCCP/HCP programs are only one conservation mechanism and have the limitations of 

being voluntary, property-owner driven and generally only applicable to larger land 

ownerships. SCAG should also promote conservation approaches that are less formal than 

NCCP/HCPs, such as: • The programs of local, regional, state and federal agencies. • The 

campaigns of many conservation organizations, who help facilitate, coordinate and find 

funding for land conservation transactions.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation. Suggestions for strategies 

beyond HCPs and NCCPs will be encouraged and appreciated. Your group is encouraged to 

participate in the effort.

50
holdID Comment Response 

Submitted by California Native Plant Society - Orange County Chapter Submittal 16231 Related Documents Link

16231.08 5. Support for Regional Wildlife Corridors: The RTP/SCS/PEIR’s Natural and Farmlands focus 

would be stronger if it supported the enhancement of and/or protection of documented 

and regionally significant wildlife corridors, especially those that are impacted by 

transportation infrastructure projects. Wildlife corridors allow species to safely migrate 

between preserved lands that are separated by development. The migration allows species 

to maintain genetic diversity across the region, thus helps regional ecosystems to maintain 

ecological functions and resiliency in the face of disturbance (fire, flood, e.g.) and climate 

change impacts. Many efforts are underway across the region to connect landscapes to one 

another. In Orange County, there are two such efforts: • Coast to Cleveland, connecting the 

southern and northern portions of the NCCP Reserve (i.e. connecting the coastal hills to the 

Santa Ana Mountains) across mostly-urbanized central Orange County. This corridor is 

essential to the long-term successful functioning of the overall NCCP Reserve. • ChinoPuente Hills, which connect the northern end of the Santa Ana Mountains (i.e. the 

northerly end of the Peninsular Ranges) and the San Gabriel River Corridor (and thence to 

the Transverse Ranges and beyond). The Chino Hills end of this corridor is mostly in Orange 

County; some of the corridor is in San Bernardino County, most is in Los Angeles County. 

Each of these has tenuous portions, which may be suitable as mitigation projects for nearby 

transportation improvements that are outlined in Appendix B, the 2016 RTP/SCS Project 

List.

Comment noted. The RTP/SCS describes (in Chapter 5) next steps for further developing a 

habitat conservation strategy. Included in the steps is the recommendation to provide 

“incentives for jurisdictions to cooperate across county lines to protect and restore natural 

habitat corridors, especially where corridors cross county boundaries.” The Natural/Farm 

Lands Appendix further supports wildlife corridors in its recommended policies, with the 

specific recommendation to “Encourage and facilitate research, programs and policies to 

identify, protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Additionally, continue support for preserving wildlife corridors and 

wildlife crossings to minimize the impact of transportation projects on wildlife species and 

habitat fragmentation.”

16231.09 6. On p. 177 of the 2016 RTP/SCS it is stated: “... A more climate resilient strategy would be 

to design sidewalks and bike paths with native drought tolerant shade trees. ...” Seven tree 

species are native to the Southern California coastal plain and hills (where much of what’s 

proposed in the RTP/SCS/PEIR will be done). Of those, four are riparian-woodland species, 

needing year-round moisture at their roots, so could not be considered drought-tolerant: 

sycamore (Platanus racemosa), willow (Salix spp.), alder (Alnus racemosa), and poplar 

(Populus spp.). The other three are oaks (Quercus agrifolia, Q. chrysolepis) and California 

black walnut (Juglans californica). These are drought-tolerant once established, but are 

unhappy in poorly drained soils and/or hot exposures. Only the two oaks will grow tall and 

wide enough to accommodate bike paths and sidewalks under their canopies. For the trees’ 

health: • Barriers will be needed along the sidewalks/bike paths, so that the trees’ root 

zones will not be compacted by off-path feet/bikes. Fuchsia-flowered gooseberry (Ribes 

speciosum) would make a natural barrier that would support hummingbirds and other 

wildlife. • The oaks’ fallen leaves must be left to form natural mulch under the canopies, so 

that the mulch layer’s natural nutrient cycling can support and maintain the trees. • No 

underplanting should be done, except of species natively found under oaks, and that only 

in the oaks’ early years. • Routine maintenance should be limited to removal of weeds, 

whose seeds will inevitably be blown in and/or dropped by birds. Oaks large enough to 

form the desired canopies may well be a minimum 25 years old. Planning to grow such 

trees, in large boxes for transplantation to the eventual sidewalks/bike paths, ought to 

begin soon.

Comment noted.

51
holdID Comment Response 

Submitted by California State Legislature Submittal 16287 Related Documents Link

16287.01 We are writing to express our strong support for the continued inclusion of the SR-710 

Freeway Tunnel Project in the Southern California Association of Governments (SCAG) 2016-

2040 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS). A freeway 

tunnel directly comports with several SCAG goals including decreasing time on the road, 

enhancing economic opportunities, and improving air quality. The freeway tunnel has 

strong local support and is consistent with voter mandate and local plans. Almost twothirds (65.5%) of voters in the five cities that currently oppose the freeway tunnel also 

supported Measure R, which explicitly contained the freeway tunnel project. The tunnel, as 

you know, was also adopted in Metro's Long Range Transportation Plan. Most importantly, 

the freeway tunnel would significantly improve air quality and reduce cancer risk for the 

majority of the study area. Unfortunately, lower income minority communities near the 

freeway are more impacted by poor air quality than those in more affluent areas to the 

north. The SR 710 North Study Draft Environmental Impact Report shows that cities south 

of the freeway have existing Cancer Risk levels 20% to over 60% higher than their neighbors 

to the north. This disparity is clearly an unacceptable environmental injustice for the Los 

Angeles Region. A freeway tunnel also maximizes mobility and flow of traffic throughout 

the Los Angeles Region. Traffic must be moved from local streets back onto freeways where 

it was originally designed to go. A freeway tunnel solves this problem and reduces cutthrough traffic on neighborhood streets by 43% or 57,600 vehicles per day. It's critical that 

SCAG maintain support for the tunnel and sustain inclusion of the project in the 2016-2040 

RTP. Completion of the freeway is vital to the health and safety of thousands of Los Angeles 

area residents. We are confident that SCAG will remain steadfast in support for the tunnel 

as the best alternative for completion of the 710 freeway.

Comment Noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description and associated modeling analysis.

Submitted by Center for Demographic Research Submittal 16189 Related Documents Link

16189.01.1 We would like to express support of recommendations by the Orange County Council of 

Governments, the Orange County Transportation Authority, and other Orange County 

agencies whose comments support the Plan with its use of the Orange County’s growth 

forecast, the 2014 Orange County Projections and its updates. We thank you for the 

opportunity and ask for your consideration and response to the following comments: 1. 

Support for the Plan with its use of Orange County’s growth forecast.

Comment noted. Orange County's growth forecast has been utilized in the Plan.

16189.01.2 2. Oppose the selection of the Intensified Land Use Alternative (Alternative 3) in the draft 

PEIR as it does not reflect entitlements, development agreements, and projects recently 

completed or projects under construction in Orange County.

Comment noted. This comment is to support the Policy Growth Forecast. SCAG 

appreciates the input that the Intensified Land Use Alternative is not supported as the 

preferred alternative for the Plan. This information will be presented to SCAG’s Regional 

Council at the time it considers the certification of the Final PEIR and the adoption of a 

preferred alternative for the 2016 RTP/SCS.

16189.01.3 3. Maintain objective, unbiased tone. Comment noted. The Plan has been changed where deemed appropriate.

16189.01.4 4. Provide consistency throughout all the documents regarding the 500 foot “buffer”. Comment noted. The use of the word “buffer” has been omitted from the Plan. However, 

SCAG will continue to utilize the advisory recommendation from ARB’s 2005 Air Quality 

and Land Use Manual to avoid siting new sensitive land uses within 500 feet of a freeway 

or urban roads with 100,000 vehicles per day.

52
holdID Comment Response 

Submitted by Center for Demographic Research Submittal 16189 Related Documents Link

16189.01.5 5. References to “city” or “cities” are changed to “jurisdiction” or “jurisdictions” where 

appropriate.

Comment noted. The Plan has been changed where deemed appropriate.

16189.01.6 6. Remain Technology Neutral- It should be noted that specific examples of technology 

identified are only examples and that future technologies should not be ignored. This will 

allow the document, including mitigation measures, to be more flexible.

Comment noted. SCAG’s policies are technology neutral with regard to supporting zero 

and/or near-zero emissions vehicles. SCAG will continue to support natural gas fleet 

vehicles by hosting and administering the Southern California Clean Cities Coalition. In 

addition, SCAG communicates with Hydrogen Fuel Cell industry partners to exchange 

information and knowledge. Plug-in Electric vehicles are specifically analyzed in the 

RTP/SCS due to the transportation/land use policy nexus regarding charging station siting. 

Regarding mobility innovations such as carsharing, and ridesourcing, SCAG does not view 

these as specific technologies, but rather as emerging transportation modes. In the 

mobility innovations appendix, SCAG identifies various new technologies that show 

promise in meeting the goals of the RTP/SCS, and will continue to support any and all 

mobility innovations.

16189.01.7 7. Other Comments on the Draft 2016 RTP/SCS documents in Tables 1 through 7 below 

which include the OCCOG comment matrices plus additional comments

Comment noted. See specific comment for response.

16189.02 p. 2: Delete Our Vision & Our Overarching Strategy strategies. These sections are highly 

speculative and not necessary for the rest of the document.

Comment noted. We believe this section is important in providing the necessary 

background and context for the development of the rest of the Plan.

16189.03 p.3, column 2, bullet 5 “Millions of people are in poor health... Millions of more people live 

with chronic diseases, such as asthma, every day.” Define ‘poor health’ Cite numbers or 

share of population for region instead of saying “millions”. Provide reference to what 

chronic diseases include.

Comment noted. Changes have been made in the Plan.

16189.04 P. 4, column 2, paragraph 2 Existing statement:“Among the milestones: a one-year 

demonstration of the Express Lanes in Los Angeles County along Interstate 10 and 

Interstate 110 was made permanent in 2014...” Modify to read: “Among the milestones: a 

one-year demonstration of the tolled Express Lanes in Los Angeles County along Interstate 

10 and Interstate 110 was made permanent in 2014...”

The term, "express lanes" has been added to the Glossary. The demonstration project 

referenced included the conversion of HOV or carpool lanes on Interstate 110 Harbor 

Transitway and Interstate 10 El Monte Busway to express lanes—which opened the lanes 

to solo drivers for a toll while maintaining free access to qualified carpools and Clean Air 

Vehicles.

16189.05 p. 7, column 2, paragraph 1 Existing statement: “In many instances, these chargers may 

double the electric range of PHEVs, reducing vehicle miles traveled that produce tail-pipe 

emissions.” Modify to read: “In many instances, the additional chargers will create the 

opportunity to increase the electric range of PHEVs, reducing vehicle miles traveled that 

produce tail-pipe emissions.”

Comment noted. Changes have been made in the Plan.

16189.06 p. 13, column 2, paragraph 2 Existing statement:“Since 2009, every MPO has been required 

to develop a Sustainable Communities Strategy...Once implemented along with the rest of 

the Plan, it will improve the quality of life for all residents of the region.” Modify to read: 

“Since 2009, every MPO in California has been required to develop a Sustainable 

Communities Strategy...Once implemented along with the rest of the Plan, it will improve 

the overall quality of life for all residents of the region.”

Comment noted. Changes have been made in the Plan.

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16189.07 p. 13, column 2, paragraph 3 Existing statement:“But these advances in mobility also have 

the potential to help Baby Boomers maintain their independence as they age.” Modify to 

read: “But these advances in mobility also have the potential to help Baby Boomers, and 

the generations that follow them, maintain their independence as they age.”

Comment noted. Changes have been made in the Plan.

16189.08 p. 14, column 1, paragraph 2 Existing statement:“In Southern California, striving for 

sustainability will require achieving state-mandated targets for reducing greenhouse gas 

emissions from vehicles and federal air quality conformity requirements, and also adapting 

wisely to a changing environment and climate.” Modify to read: “In Southern California, 

striving for sustainability includes achieving state-mandated targets for reducing 

greenhouse gas emissions from vehicles and federal air quality conformity requirements, 

and also adapting wisely to a changing environment and climate.”

Comment noted. Changes have been made in the Plan.

16189.09 p. 14, column 2, paragraph 5 Existing statement: “It is particularly important that the Plan 

consider the consequences of transportation projects on low-income and minority 

communities and minimize negative impacts.” Modify to read: “It is particularly important 

that the Plan consider and minimize the negative impacts of transportation projects, 

especially on low-income and minority communities.”

Comment noted. The existing statement in the Draft Environmental Justice Appendix is 

more in accord with federal and state guidance on the topic.

16189.11 p. 16, column 2 Existing statement: “2. Collaborating with Member Agencies, Jurisdictions 

and Stakeholders. Implementing the Plan will require SCAG to continue working closely 

with its member agencies...” “The agency will also have to work with key stakeholders to 

ensure the Plan benefits the economy and ensures social equity. To ensure that the region 

makes progress on its goals, SCAG will monitor its own progress toward achieving its 

targets and will share this information with relevant partners and the public.” Modify to 

read: “2. Collaborating with Member Agencies, Jurisdictions and Stakeholders. 

Implementing the Plan will require SCAG to continue working closely with its all 

jurisdictions...” “The agency will also have to work with key stakeholders to ensure the Plan 

benefits the economy and promotes social equity. To ensure that the region makes 

progress on its goals, SCAG will monitor its own progress toward achieving its targets and 

will share this information with its partners and the public.”

Comment noted. Changes have been made in the Plan.

16189.12 p. 20, column 1, paragraph 3 Existing statement: “However, of the remaining developable 

land, only a small portion of it can be developed sustainably – meaning it can be reached 

via planned transit service and that it can readily access existing infrastructure (water 

resources, sewer facilities, etc.). According to SCAG land use data, only two percent of the 

total developable land in the region is located in High Quality Transit Areas (HQTAs). A 

more compact land development strategy is needed, which will be discussed in Chapter 5.” 

Modify to read: “However, of the remaining developable land, only a small portion of it can 

be developed as transit-ready infill– meaning it can be reached via planned transit service 

and that it can readily access existing infrastructure (water resources, sewer facilities, etc.). 

According to land use data collected by SCAG, only two percent of the total developable 

land in the region is located in High Quality Transit Areas (HQTAs).

Comment noted. Text has been revised to state: "However, of the remaining developable 

land, only a small portion of it can be developed as sustainable transit-ready infill – 

meaning it can be reached via planned transit service and that it can readily access existing 

infrastructure (water resources, sewer facilities, etc.). According to SCAG's land use data, 

only two percent of the total developable land in the region is located in High Quality 

Transit Areas (HQTAs). A more compact land development strategy is needed, which will 

be discussed in Chapter 5."

54
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16189.13 p. 20, column 1, paragraph 4 Existing statement: “SCAG supports the fact that local 

jurisdictions conduct much of the planning for land use in our region. However, as the 

agency prepared the 2016 RTP/SCS, it needed to organize the many different types and 

classifications of land uses in...” Modify to read: “As the agency prepared the 2016 RTP/SCS, 

it needed to organize the many different land use types and classifications in...”

Comment noted. Existing statement will remain. This statement reflects the Five Guiding 

Principles of the Growth Forecast utilized in the Plan.

16189.14 p. 20, column 1, paragraph 5 Existing statement: "To accurately represent land uses 

throughout the region, SCAG reviewed information from jurisdictions and simplified the 

types and classifications of land use. The agency identified 35 “Place Types”... the Urban 

Footprint Sustainability Planning Model (SPM), which guided and evaluated urban 

development in the Plan in terms of form, scale and function in the built environment.” 

Modify to read: “To accurately represent land uses throughout the region, SCAG 

aggregated information from jurisdictions and simplified the types and classifications of 

land use into a consolidated set of land use types. The agency then converted these 

consolidated land uses into 35 “Place Types”... the Urban Footprint Scenario Planning 

Model (SPM), to demonstrate urban development in the Plan in terms of form, scale and 

function in the built environment.”

Comment noted. Revisions to the Plan have been made as appropriate.

16189.15 p. 20, column 2, paragraph 2 Existing text: “SCAG then sorted the 35 Place Types into three 

Land Development Categories. The agency used these categories to describe the general 

conditions that exist and/or are likely to exist within a specific area. SCAG did not intend to 

have them represent detailed policies for land use, development or growth. Rather, they 

reflect the varied conditions of buildings and roadways, transportation options, and the mix 

of housing and employment throughout the region.” Modify to read: “SCAG then classified 

the 35 Place Types into three Land Development Categories. The agency used these 

categories to: describe the general conditions that exist and/or are likely to exist within a 

specific area; and reflect the varied conditions of buildings and roadways, transportation 

options, and the mix of housing and employment throughout the region.”

Comment noted. Revisions to the Plan have been made as appropriate.

16189.16 p. 21, column 1, paragraph 3 Existing text: “Conversely, some areas, especially near the 

edge of existing urbanized areas, do not have plans for conservation and are susceptible to 

development pressure. ... – meaning these are areas that are home to a high number of 

species and serve as highly functional habitats.” Modified to read: “Some areas, especially 

near the edge of existing urbanized areas, do not have plans for conservation and may be 

slated for development – meaning these areas are home to a high number of species and 

serve as highly functional habitats.” Also- “Some key habitat types are underrepresented 

within the 35 percent of the region already under protection.” Clarify why does there need 

to be an equal share of types of protected land? If not, delete sentence.

Comment noted. Revisions to the Plan have been made as appropriate.

55
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16189.17 p. 22, column 1, paragraph 1 “However, although these housing units are planned and 

zoned for, historical data shows that less than ten percent of the needed affordable 

housing has been built. In contrast, housing construction measured by building permits 

issued meets nearly 90 percent of projected market rate housing needs.” What is the data 

source that reports on building finals by income category? What is the time frame for the 

“less than ten percent”? What is the time period for the data on the market rate housing?

The source of this data are submitted annual progress reports to the California 

Department of Housing and Community Development (HCD) that are required by State 

housing law. The data source time frame is between 2002 and 2014. SCAG acknowledges 

that this data is often incomplete and inconsistently reported and represents only a 

portion of affordable housing building activity. Because of this, SCAG is developing a pilot 

survey to determine how to encourage jurisdictions in the region to submit this 

information to HCD on a more consistent basis so that the data is more accurate than what 

is currently available. This language has been updated to provide a general description of 

affordable housing building activity.

16189.18 p. 22, column 2, paragraph 1 Existing text: “... of our region’s jurisdictions have adopted 

housing elements.” Modify to read: “... of our region’s jurisdictions have certified housing 

elements.”

The housing element compliance report published by the California Department of 

Housing and Community Development (HCD) has two categories listed, adoption status 

and compliance status ("certified"). To reflect the modification to certified, the datapoint 

has been updated as well to reflect those deemed by HCD to have an "in compliance" 

status.

16189.19 p. 22, column 2, paragraph 3 Define “high quality” housing To minimize confusion of terms "high quality housing" and "high quality transit area", the 

text has been slightly revised to clarify that high density housing does not necessarily 

mean subpar amenities or durability and is in fact of quality.

16189.20 p. 23, Figure Define “demand response” in “Passenger Miles by Mode” figure The term Demand Response is defined on page 181, in the Glossary section of the 2016 

RTP/SCS. The definition provided reads as follows: " A transit mode comprised of 

automobiles, vans, or small buses operating in response to calls from passengers or their 

agents to the transit operator, who then dispatches a vehicle to pick up the passengers 

and transport them to their destinations. A demand response operation is characterized 

by vehicles that do not operate over a fixed route or on a fixed schedule except on a 

temporary basis." This definition of demand response service was obtained from the 

National Transit Database (NTD), and is closely related to the NTD data used in the existing 

conditions analyses for public transportation in the 2016 RTP/SCS. The definition is 

consistent with the definitions of demand response provided by the FTA in 49 C.F.R. 

604.3(g) and Circular 2710.2A, and is a public transportation industry standard.

Submitted by Center for Demographic Research Submittal 16190 Related Documents Link

16190.01 p. 24, Exhibit 2.1 Define “High Value Habitat” Add county boundaries to map. The definition for "Habitat Value" has been added to exhibit 2.1. This term more broadly 

explains the content of the map.

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16190.02 p. 25, column 2, paragraph 2 Existing text: “This network includes fixed-route local bus 

lines, community circulators, express and rapid buses, Bus Rapid Transit (BRT), demand 

response,3 light rail transit, heavy rail transit (subway) and commuter rail.4” Modify to 

read: “This network includes fixed-route local bus lines, community circulators, express and 

rapid buses, Bus Rapid Transit (BRT), paratransit,3 light rail transit, heavy rail transit 

(subway) and commuter rail.4”

The term Demand Response is defined on page 181, in the Glossary section of the 2016 

RTP/SCS. The definition provided reads as follows: " A transit mode comprised of 

automobiles, vans, or small buses operating in response to calls from passengers or their 

agents to the transit operator, who then dispatches a vehicle to pick up the passengers 

and transport them to their destinations. A demand response operation is characterized 

by vehicles that do not operate over a fixed route or on a fixed schedule except on a 

temporary basis." This definition of demand response service was obtained from the 

National Transit Database (NTD), and is closely related to the NTD data used in the existing 

conditions analyses for public transportation in the 2016 RTP/SCS. The definition is 

consistent with the definitions of demand response provided by the FTA in 49 C.F.R. 

604.3(g) and Circular 2710.2A, and is a public transportation industry standard. The term 

demand response is also inclusive of services offered that go beyond the statutory 

mandates of the Americans with Disabilities Act (ADA). For instance, the senior dial-a-ride 

service offered by Thousand Oaks Transit offers demand response service to all passengers 

over the age of 65. The term paratransit, as described in 49 C.F.R. 37, typically refers to 

those comparable transportation services that must be provided for individuals unable to 

use fixed route systems.

16190.03 p. 26, column 1, paragraph 2 Existing text: “typically pay 25 percent of the operating and 

maintenance cost of their travel, with the remaining 75 percent paid for by state and local 

public subsidies. Most capital expenditures are also funded with public subsidies, including 

a larger share of federal grants.” Modify text to read: “Transit users directly pay about 25 

percent of the operating and maintenance cost of their travel, with the remaining 75 

percent paid for by state and local public subsidies. Most capital expenditures are also 

funded through various taxes and public subsidies, including a larger share of federal 

grants.”

The text has been changed to read "Transit users typically pay 25 percent of the operating 

and maintenance cost of their travel, with the remaining 75 percent paid for by state and 

local public subsidies. Most capital expenditures are also funded with public subsidies, 

including a larger share of federal grants.”

16190.04 p. 28, column 1, paragraph 2 Existing text: “The regional bike network is evolving but 

remains fragmented. Nearly 500 additional miles of bikeways were built since SCAG’s 2012 

RTP/SCS, but only 3,919 miles of bikeways exist regionwide, of which 2,888 miles are bike 

paths/ lanes (see EXHIBIT 2.3). This is compared with more than 70,000 roadway lane miles. 

One way to quantify bikeway quality and density is to calculate a ratio of bike path to lane 

miles. SCAG’s ratio of bike path/lane miles ratio is 0.039. To put this in perspective, 

Portland, Oregon and San Francisco have bike path/lane ratios to lane miles at 0.054 and 

0.078, which are 38 percent and 100 percent higher than the SCAG region, respectively. 

Our region’s lack of consistent infrastructure discourages all but the most fearless people to 

bike.” Modify text to read: “The regional bike network is expanding but remains 

fragmented. Nearly 500 additional miles of bikeways were built since SCAG’s 2012 RTP/SCS, 

but only 3,919 miles of bikeways exist regionwide, of which 2,888 miles are bike paths/ 

lanes (see EXHIBIT 2.3). This is compared with more than 70,000 roadway lane miles." 

Comment: There is typically only one bike lane in each direction whereas there could be 

multiple traffic lanes in each direction. It is not appropriate to compare lane miles to bike 

lane miles. Comparison, if any, should be to centerline miles. Comparison of bike path/lane 

miles ratio for SCAG region to individual cities is not appropriate.

Text modified, eliminating bike path/lane ratio to lane miles.

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16190.05 p. 28, column 1, paragraph 2 Existing text: “Most walk trips (83 percent) are less than one 

half mile; walkers are often discouraged from traveling farther. Routes to stops and stations 

are often...” Modify text to read: “Most walk trips (83 percent) are less than one half mile; 

walkers are less likely to travel farther. Routes to bus stops and stations are often...”

Text modified, indicating pedestrians discouraged by infrastructure.

16190.06 p. 33, column 1, paragraph 2 Existing text: “A significant amount of travel in the region is 

still by people who choose to drive alone (42 percent of all trips and nearly 77 percent of 

work trips). So, the challenge of getting individuals to seek more environmentally friendly 

alternatives of travel remains.” Modify text to read: “A significant amount of travel in the 

region is still by people who choose to drive alone (42 percent of all trips and nearly 77 

percent of work trips)."

Comment noted. Appropriate edits have been made to incorporate this comment.

16190.07 p. 36, column 2, paragraph 2 “Therefore, any passenger who arrives at or departs from an 

airport in our region is good for the region as a whole.” Move sentence to end of 

paragraph. Reference the Economic & Job Creation Appendix.

Comment noted.

16190.08 p. 54, column 2, paragraph 4 Existing text: “Certainly, the overall quality of life will increase 

for many people.” Modify to read: “The overall quality of life is expected to increase for 

many people.”

Comment noted. Changes have been made in the Plan.

16190.09 p. 55, column 1, paragraph 3 “Chronic diseases including heart disease, stroke, cancer, 

chronic lower respiratory disease and diabetes are responsible for 72 percent of all deaths 

in our region. Millions of more people live with chronic diseases every day.” Cite number 

and source or delete sentence (The second sentence that starts with, "Millions of more 

people..."

Comment noted. Plan changed to provide number and source.

16190.10 p. 56, column 1, paragraph 1 Existing text: “Ongoing drought conditions, water shortages 

due to less rainfall as well as declining snowpack in our mountains, and an agriculture 

industry in crisis have become hard realities in recent years.” Modify to read: “California is 

experiencing ongoing drought conditions, water shortages due to less rainfall as well as 

declining snowpack in our mountains, and an agriculture industry in crisis.”

Comment noted.

16190.11 p. 61, column 1, paragraph 2 Add statement that says “These preliminary scenarios are not 

the ones modeled in the PEIR.”

Comment noted. Changes have been made in the Plan.

16190.12 p. 64, column 1, paragraph 1 Clarification should be made that attendance was selfselected as was the survey participation. Attendees were strongly encouraged by SCAG 

staff to fill out a survey. A more detailed description should be included that explains that 

these results are not scientific.

Comment noted. Paragraph will remain unchanged. More information on the outreach 

process and the surveys can be found in the Appendix: Public Participation and 

Consultation.

16190.13 p. 64, column 2, paragraph 2 “...was also a principal concern, as was access to healthy 

food.” What percentage of respondents elevates an item to a ‘principle concern’?

Comment noted. Language has been revised and further explanation of the survey results 

has been included in the chapter and Appendix. Language has been revised to “Having 

safe areas for walking, biking and physical activity was also a concern, as was access to 

healthy food.”

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16190.14 p. 64, column 2, paragraph 4 “Collectively, the survey responses offered an invaluable 

guide to help finalize the Plan’s investments, strategies and priorities. They reflect how 

regional stakeholders want us to address priority areas such as transit and roadway 

investments, system management, active transportation, land use and public health.” Did 

the survey responses change the Plan? Clarify if a higher priority in making changes was 

afforded to survey respondents’ feedback over jurisdictional and CTC input?

Comment noted. Survey responses informed the development of the Draft 2016 RTP/SCS. 

Numerous responses supported/reflected CTC and jurisdictional input, as well as input 

from stakeholder working groups. Some individual comments related to specific projects 

were received, but in those cases SCAG referred to CTCs for guidance.

16190.15 p. 65, column 1, paragraph 4 Delete text: “Jurisdictions were asked to provide input on the 

growth scenario, including information on specific planned development projects with 

entitlements, other planned projects, or recently completed developments.” Comment: 

During the local input process, SCAG requested feedback on the distribution of new 

households and employment. SCAG did not request information from jurisdictions on 

specific planned development projects with entitlements, other planned projects, and 

recently completed developments. During review of the draft policy growth forecast (PGF) 

in summer 2015, technical errors throughout the draft PGF were identified. These “technical

 errors” in the dataset were that entitlements, development agreements, and projects 

currently under construction or recently completed were not properly reflected. It was 

then that SCAG stated that jurisdictions could provide the information if jurisdictions 

wanted corrections made to the PGF.

Comment noted. Text will not be deleted but language has been added to describe that 

SCAG took additional step of accepting information from jurisdictions regarding specific 

planned development projects with entitlements, other planned projects, and recently 

completed developments in order to improve policy growth forecast.

16190.16 p. 65, column 2, bottom note “*With the exception of the 6 percent of TAZs that have 

average density below the density range of local general plans.” Please clarify the footnote. 

Did SCAG lower the growth or is General Plan buildout expected after 2040?

The TAZs showing lower densities than GP designations are consistent with existing 

conditions and future land use and growth projections provided by local jurisdictions, 

SCAG did not lower the growth.

16190.17 p. 69, column 2, paragraph 1 Existing text: “By 2040, the integrated growth forecast 

projects that these figures will increase by 3.8 million people...” Modify text to read: “By 

2040, the Plan projects that these figures will increase by 3.8 million people...”

Comment noted. Changes have been made in the Plan.

16190.18 p. 70, column 1, paragraph 1 Existing text: “In addition, local jurisdictions should pursue the 

production of permanent affordable housing through deed restrictions or development by 

non-profit developers, which will ensure that some units will remain affordable to lowerincome households.” Modify to read: “In addition, local jurisdictions are encouraged to 

pursue the production of permanent affordable housing through deed restrictions or 

development by non-profit developers, which will ensure that some units will remain 

affordable to lower-income households.”

Comment noted. Changes have been made in the Plan.

16190.19 p. 70, Table 5.1 Add note to table “Adopted in 2013” Note added to table 5.1.

16190.20 p. 73, column 2, paragraph 4 Define “riparian” Comment noted. Riparian is defined on page 21 paragraph 3 of the Natural/Farm Lands 

Appendix: "These include lands that are important and unique habitats and have high peracre habitat values, such as riparian habitat (i.e., areas adjacent to bodies of water such as 

streams or rivers). " The term has also been added to the glossary.

Submitted by Center for Demographic Research Submittal 16191 Related Documents Link

16191.01 p. 76, paragraph 1 How many of these trips are alone vs. with others? Are these linked 

trips/trip segments?

These are linked trips. Text states that 38% of all trips in the region are 3 miles or less, 

which indicates both alone trips and with others.

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16191.02 p. 76, paragraph 3 The narrative implies that Neighborhood Mobility Areas (NMAs) are 

needed for Neighborhood Electric Vehicles (NEVs). If this is not true, reword section to 

allow for flexibility that one is not tied to another exclusively.

Comment noted. The text was revised to clarify that Neighborhood Mobility Area policies 

would be conducive to more Neighborhood Electric Vehicle use, but are not integral to the 

use of NEVs.

16191.03 p. 77 Figure needs title The title for the Neighborhood Mobility Area Illustration has been added.

16191.04 p. 79, Figure 5.2 Clarify if the preservation and operations expenditures apply to the SCAG 

region or California State.

The indicated expenditures apply to the SCAG region.

16191.05 p. 83, column 2, paragraph 5 Existing text: “Bus lanes are even more effective at increasing 

speeds, however in our region there is a dearth of such lanes. Transit agencies should 

heavily lobby local jurisdictions in which they operate to implement them, at least for peakperiod operation.” Modify text: “Bus lanes are even more effective at increasing speeds, 

however in our region there is a dearth of such lanes. SCAG encourages transit agencies 

and local jurisdictions to implement them, where appropriate.”

Comment noted. Changes have been made in the Plan.

16191.06 p. 88, column 1, paragraph 4 Existing text: “The 2016 Active Transportation Plan updates 

the 2012 Active Transportation Plan...” Modify text to read: “The Active Transportation 

portion of the 2016 Plan updates the 2012 Plan...”

Comment noted. Changes have been made in the Plan.

16191.07 p. 89, column 2, paragraph 2 Existing text: “SCAG has developed 12 regionally significant 

bikeways that connect the region." Modify text to read: “SCAG has identified 12 regionally 

significant bikeways that connect the region.”

Comment noted.

16191.08 p. 92, column 1, paragraph 2 Existing text: “The launch date coincided with the decline in 

daylight hours, a period when bicycle and pedestrian collisions peak during the year.” 

Modify text to read: “The launch date coincided with the end of daylight savings time, a 

period when bicycle and pedestrian collisions peak during the year.”

Comment noted. Noting daylight savings time may infer causality rather than correlation, 

as pedestrian involved collisions traditionally continue to remain high during winter 

months. Text revised to read "The launch date coincided with the decline in daylight hours, 

a period when pedestrian collisions begin to peak.”

16191.09 p. 93, column 1, paragraph 4 Define “no-maintenance exercise spots” Revised text to read "exercise spots"

16191.10 p. 103, column 1, paragraph 3 “...figure “2040 Airport Demand Forecasts” on the previous 

page...” Properly label figure and page reference.

Comment noted.

16191.11 p. 105, column 1, paragraph 1 “In recent years, airport operators, CTCs and SCAG have all 

undertaken their own initiatives to improve ground access at the region’s aviation 

facilities.” Clarify what initiatives SCAG has undertaken.

Comment noted. SCAG has worked with the Airport Authorities and the CTCs through the 

RTP/SCS process to identify and include transportation projects in the long range plan that 

enhance and support airport access. More specifically, as an example, SCAG has recently 

initiated a study in partnership with key stakeholders that will explore connectivity 

between LA and San Bernardino County. A key component of this study will be to study 

and identify transit access improvement options to Ontario Airport.

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16191.12 p. 111, column 1, paragraph 2 Existing text: “Building on its strong commitment to the 

environment as demonstrated in the 2012 RTP/SCS, SCAG’s mitigation program is intended 

to function as a resource for lead agencies to consider in identifying mitigation measures to 

reduce impacts anticipated to result from future projects as deemed applicable and 

feasible by such agencies.” Modify text to read: “Building on its strong commitment to the 

environment as demonstrated in the 2012 RTP/SCS, SCAG’s mitigation program is intended 

to function as a resource for lead agencies to consider in identifying mitigation measures to 

reduce impacts anticipated to result from future transportation projects as deemed 

applicable and feasible by such agencies.”

Comment noted. Mitigation measures are categorized into SCAG mitigation measures and 

project-level mitigation measures that are linked with performance standards. Projectlevel mitigation measures are a menu of options for projects envisioned by the 2016 

RTP/SCS that lead agencies can and should consider where applicable and feasible. For a 

complete discussion on the performance standards-based mitigation measures, please see 

Master Response No. 4 in the PEIR.

16191.13 p.111-119 & PEIR Update language on the mitigation measures to be consistent with any 

language changes to the PEIR document.

Comment noted. Appropriate corrections to the mitigation measures in the PEIR are 

incorporated and reflected in the Clarifications and Revisions section of the Final PEIR. 

Please also see Chapter 8, Responses to Comments in the PEIR. The environmental 

mitigation measures included in Chapter 5, Environmental Mitigation Measures, of the 

2016 RTP/SCS are consistent with the performance standards-based mitigation approach 

used in the PEIR and reflect the general scope of the PEIR's mitigation measures.

16191.14 p. 159, column 2, paragraph 2 Existing text: “Since new development is focused in areas 

where infrastructure already exists, there is not as much need to extend or build new local 

roads, water and sewer systems, and parks.” Modify text to read: “Since new development 

is focused in areas where infrastructure already exists, sometimes there is not as much 

need to extend or build new local roads, water and sewer systems, and parks, but in other 

instances, modernization of utilities needs to be considered and completed to 

accommodate the additional usage.”

Comment noted. Changes have been made in the Plan.

16191.15 p. 165, column 1, paragraph 1 Define ‘sensitive receptors” Comment noted. Definition provided in final RTP/SCS. Sensitive receptors are land uses 

where people most vulnerable to poor air quality are likely to be located. SCAG identified 

these areas based on guidance from the California Air Resources Board (CARB), which 

states that "sensitive individuals refer to those segments of the population most 

susceptible to poor air quality (i.e., children, the elderly, and those with pre-existing 

serious health problems affected by air quality). Land uses where sensitive individuals are 

most likely to be located include schools and schoolyards, parks and playgrounds, daycare 

centers, nursing homes, hospitals, and residential communities (sensitive sites or sensitive 

land uses)" (http://www.arb.ca.gov/ch/handbook.pdf).

16191.16 Label Y axis on all figures Revisions made as appropriate in the Demographic and Growth Forecast Appendix.

16191.17 P. 2, column 1, paragraph 3 Add text: “The forecasted land use development patterns 

shown are based on Transportation Analysis Zone (TAZ) level data utilized to conduct 

required modeling analyses. Data at the TAZ level or at a geography smaller than the 

jurisdictional level are advisory only and non-binding, because SCAG sub-jurisdictional 

forecasts are not to be adopted as part of the 2016 RTP/SCS. The advisory sub-jurisdictional 

data shall not be required for purposes of qualifying for future grant funding or other 

incentives or for determining a proposed project’s consistency with the 2016 RTP/SCS for 

any impact analysis required pursuant to the California Environmental Quality Act (CEQA).”

Comment noted. The 2016 RTP/SCS is the product of a bottom-up, iterative local input 

process. SCAG has actively sought consensus from our subregional partners on local SCS 

consistency determination for future funding and other opportunities consistent with the 

core principles specified in Chapter 4. It has been re-emphasized that the preferred 

scenario and corresponding forecast of population, household, and employment growth is 

adopted at the jurisdictional level as part of the 2016 RTP/SCS, and any corresponding subjurisdictional level data and/or maps is advisory only.

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16191.18 P.42-43 How do the SPM Place Types nest into the Land Development Categories? Comment noted. A table that reflects how SPM Place Types nest into the Land 

Development Categories has been added to the "Reference Documents" section at the 

end of the Appendix: SCS Background Documentation.

16191.19 p.6/43 Move the definitions of Urban, Compact Walkable, and Standard Suburban from 

page 43 to page 6 before the maps

Comment noted. A note on the maps has been included to note the definitions are on 

page 43.

16191.20 p. 41, column 1, paragraph 4 Existing text: “Scenario modeling with UrbanFootprint brings 

meaningful, comprehensible, and timely results to those wanting to understand how 

growth and development choices will impact their community, city, or region in the coming 

years and decades.” Modify text to read: “Scenario modeling with UrbanFootprint brings 

meaningful, comprehensible, and timely results to those local jurisdictions wanting to 

understand how growth and development choices will impact their community, city, or 

region in the coming years and decades.”

Comment noted. Changes have been made in the Plan.

Submitted by Center for Demographic Research Submittal 16193 Related Documents Link

16193.01 p. 50, 51, 54, 56 maps Clarify in map legends if growth refers to population, housing and/or 

employment.

Comment noted. Revisions have been made to map legends to reflect data displayed on 

the map.

16193.02 p. 41, column 2, paragraph 2 Existing text: “Since 2012... Developers of UrbanFootprint 

have also met with regional agencies, such as SCAG, Sacramento Area Council of 

Governments (SACOG), and San Diego Association of Governments (SANDAG), Orange 

County Council of Governments (OCCOG).” Modify text to read: “Since 2012... Developers 

of UrbanFootprint have also met with regional agencies, such as SCAG, Sacramento Area 

Council of Governments (SACOG), and San Diego Association of Governments (SANDAG).”

Comment noted. Changes have been made in the Plan.

16193.03 p. 56 column 1, last paragraph Existing text: “The scope of these four scenarios, which were 

developed in consultation with the CEHD Committee and the SCAG’s Technical Working 

Group (TWG), evolved throughout the first five months of 2015.” Modify text to read: 

“These four scenarios were developed in early 2015 by SCAG and their consultant and 

shared, with the CEHD Committee and SCAG’s Technical Working Group (TWG).”

Comment noted. Revisions to the Plan have been made as appropriate.

16193.04 p. 56 column 2, paragraph 2 Existing text: “Conversely, growth focused in urban areas often 

takes advantage of existing infrastructure and more efficient service to higher 

concentrations of jobs and housing.” Modify text to read: “Conversely, growth focused in 

urban areas often takes advantage of existing infrastructure and more efficient service to 

higher concentrations of jobs and housing, but sometimes modernization of utilities needs 

to be considered and completed to accommodate the additional usage.”

Comment noted. Revisions to the Plan have been made as appropriate.

16193.05 P. 58, column 2, paragraph 4 “Saving water also saves on costs, and the RTP/SCS saves 

about $1.2 billion over the span of the plan, and saves households in the SCAG region $93 

million on annual water bills.” Add “Notwithstanding, infrastructure operations and 

maintenance costs require continued funding; further, these costs could offset ratepayer 

savings resulting from the implementation of RTP/SCS policies, conservation efforts, or 

installation and use of efficient appliances.”

Comment noted. The existing statement refers to water costs savings for new growth. 

Assessing impacts of household utility cost savings on potential future utility rates is 

beyond the scope of the Draft RTP/SCS.

62
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Submitted by Center for Demographic Research Submittal 16193 Related Documents Link

16193.06 P. 83, column 2, paragraph 2 Existing text: “The SPM includes a suite of tools and analytical 

engines that help to quickly illustrate alternative plans and policies and to estimate their 

transportation, environmental, fiscal, public health and community impacts.” Modify text 

to read: “The SPM includes a suite of tools and analytical engines that help to quickly 

illustrate alternative plans and policies and to estimate their transportation, environmental, 

fiscal, and public health regional impacts.”

Comment noted. Revision to the Plan have been made.

16193.07 P. 83, column 2, last sentence Delete: “SPM will serve as a common platform for 

communications between SCAG and local jurisdictions in the process of local input and 

public outreach, providing local planners advanced analytical capabilities.”

Comment noted. Sentence has been deleted as requested.

16193.08 Needs to include statement saying that pedestrians and bikes are also responsible (e.g. 

distracted walking by cell phones; bikers with headphones) and isn’t always vehicles as 

cause Everyone needs to be educated and follow the rules and enforcement needs to 

happen for all modes Acknowledge the improvement over time of AT usage and the 

lowering of accident and death rates

Comment noted. The Active Transportation Appendix notes as part of its education and 

encouragement strategy, "Getting more people to bicycle and walk is not just about 

building the infrastructure. They must feel safe biking and walking. Safety campaigns that 

include advertising, public service announcements and media kits are all part of a suite of 

safety education strategies. Other strategies include educating bicyclists, pedestrians and 

motorists on the rights and responsibilities of sharing the road."

16193.09 p. 5 Existing text: “Class I Bikeways ...A Class I Bikeway provides a completely separated way 

designated for the exclusive use of bicycles and/or pedestrians with cross flows by 

motorists minimized. Some of the region’s rivers include Class 1 Bikeways. Increasing the 

number of bikeways rivers may provide additional opportunities for “interested but 

concerned” cyclists.” Modify existing text: “Class I Bikeways ...A Class I Bikeway provides a 

completely separated right-of-way designated for the exclusive use of bicycles and/or 

pedestrians with cross flows by motorists minimized. Some of the region’s rivers include 

Class 1 Bikeways. Increasing the number of bikeways along rivers, utility corridors, and 

flood control channels may provide additional opportunities for “interested but concerned” 

cyclists.”

Comment noted. Changes have been made in the Plan.

16193.10 p.6, column 1 “INTERSECTION TREATMENTS ...In the SCAG region, nearly 44 percent of all 

pedestrian injuries are at intersections.” Define how far away from the intersection an 

accident may occur to be included in the count of pedestrian injuries at intersections

Comment noted. SCAG staff is unaware of the actual distance within an intersection that 

counts toward pedestrian injuries at intersections as these distances are determined by 

investigating officers for each collision.

16193.11 p.6, column 1 Existing text: “COMPLETE STREETS In recognition of the need to 

accommodate various types and needs of roadway users, the State of California adopted 

the Complete Streets Act of 2008 (AB 1358) requiring cities and counties to incorporate the 

concept of Complete Streets to any general plan’s substantive update.” Modify text to 

reflect: “COMPLETE STREETS In recognition of the need to accommodate various types and 

needs of roadway users, the State of California adopted the Complete Streets Act of 2008 

(AB 1358) requiring cities and counties to incorporate the concept of Complete Streets to 

any update to their General Plan’s circulation element.”

Comment noted. Text changed to "In recognition of the need to accommodate various 

types and needs of roadway users, the State of California adopted the Complete Streets 

Act of 2008 (AB 1358) requiring local jurisdictions to incorporate the concept of Complete 

Streets to any substantive update to their General Plan’s circulation element." .

63
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Submitted by Center for Demographic Research Submittal 16193 Related Documents Link

16193.12 p.8, column 1 Existing text: “COLLISIONS AND FATALITIES While the numbers of bicyclists 

and pedestrians are increasing, so are injuries and fatalities, although not as fast as the 

growth in active transportation. In California, 64,127 pedestrians were injured and 3,219 

were killed between 2008 and 2012. In 2012 alone, 702 pedestrians were killed and 13,280 

pedestrians were injured.” Modify existing text: “COLLISIONS AND FATALITIES While the 

numbers of bicyclists and pedestrians are increasing, so are injuries and fatalities, although 

not as fast as the growth in active transportation. In California, 64,127 pedestrians were 

injured and 3,219 were killed between 2008 and 2012. In 2012 alone, 13,280 pedestrians 

were injured and 702 pedestrians were killed.”

Comment noted. Changes have been made in the Plan.

16193.13 p. 17, Table 5 Create separate tables for columns 1 to 3 and columns 3 to 10. Comment noted.

16193.14 p. 24, column 1, paragraph 1 Existing text: “2012 RTP/SCS PROGRESS The 2016 Active 

Transportation Plan ...The Plan examined access to transit, noting that 95 percent of SCAG 

residents would be within walking (0.5 mile) or biking (2 mile) distance from a transit 

station.” Modify existing text: “2012 RTP/SCS PROGRESS The Active Transportation portion 

of the Plan ...The Plan examined access to transit, noting that 95 percent of SCAG residents 

would be within walking (0.5 mile) or biking (2 mile) distance from a transit station.” Define 

what constitutes a ‘transit station’

Incorporated recommended change noting The Active Transportation component of the 

2012 RTP/SCS (2012 Plan) Incorporated recommended change Page 20 of the Active 

Transportation Appendix changed to "The 2012 Plan examined access to transit, noting 

that 95 percent of SCAG residents would be within walking (0.5 mile) or biking (two miles) 

distance from a transit station, defined as a bus station, light rail station, or heavy rail 

station."

16193.15 P. 25, second column, top bullet (last under #4) “Success of this program depends on cities 

and counties conducting these counts and providing the data to SCAG.” Identify funding 

source and acknowledge that this is voluntary effort and may not be a priority, especially 

without funding

Comment noted.

16193.16 P. 25, second column, Bullet 6 Add 4th bullet under #6: “OCCOG is working on a 

comprehensive Complete Streets design manual for the entire county which will be 

completed in 2016.”

Comment noted. Changes have been made in the Plan.

16193.17 P.26, Table 9 Add 4th bullet under #6: “OCCOG is working on a comprehensive Complete 

Streets design manual for the entire county which will be completed in 2016.”

Comment noted. Changes have been made in the Plan.

16193.18 P.26, Table 9 Existing text: Change language for Orange County: Not yet Planned. Modify 

existing text: Change language for Orange County: In Process

Comment noted. Changes have been made in the Plan.

16193.19 p. 27, column 1, and any other references Clarify that the ‘2016 Action Transportation Plan’ 

is not a standalone plan, but is a portion within the RTP.

Incorporated clarification throughout the document.

16193.20 P.66-67, Tables 16 & 17 Add note to Table: “These draft scenarios are not the alternatives 

that were evaluated in the PEIR.”

Comment noted. It may be confusing to readers to reference the PEIR solely as a single 

footnote without context. The PEIR itself provides context over what was evaluated.

Submitted by Center for Demographic Research Submittal 16194 Related Documents Link

16194.01 P. 71 Delete “Strategic Plan Beyond 2040” section. The inclusion of this section is not 

consistent with other appendices. It creates confusion as to what the RTP’s Strategic Plan is.

Comment noted. The comprehensive Strategic Plan is included in the main document 

(Chapter 9 of the 2016 RTP/SCS beginning on page 173) and includes same strategies 

identified in the Active Transportation Appendix. The strategic plan provides an indication 

of what jurisdictions could implement beyond the constraints of the 2016 RTP/SCS.

64
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Submitted by Center for Demographic Research Submittal 16194 Related Documents Link

16194.02 P.8-10, Table 4 Label all Performance Measures that were new in 2016 Plan P.11 Add 

definition of HQTA to map. p.20 LSPT was used for 2012 RTP. Add information on the SPM. 

p. 31, Table 12 Add model sources to bottom of table.

Thank you for taking the time to review the Performance Measures Appendix. Your 

comments have been incorporated into the document as appropriate.

16194.03 Final document should contain hyperlinks to other documents. Spell out Acronyms in 

Tables/Figures Titles e.g. CHIS

Comment noted. Acronyms were removed from chart titles and sources added beneath 

charts.

16194.04 p.1, column 1 Existing text: “Public health is increasingly an area of emphasis for 

Metropolitan Planning Organizations (MPOs) and Departments of Transportation (DOTs) 

across the country, due to the prevalence of chronic diseases such as obesity, 

hypertension, asthma and heart disease.” Modify text to read: “Metropolitan Planning 

Organizations (MPOs) and Departments of Transportation (DOTs) across the country, have 

an opportunity to impact the prevalence of chronic diseases such as obesity, hypertension, 

asthma and heart disease through transportation planning which promotes increased 

physical activity.”

Comment Noted. The proposed changes do not reflect the full extent to which land use 

and transportation affect health outcomes. The Public Health Appendix outlines seven 

focus areas, one of which is physical activity. Changes have been made to the Plan to 

clarify.

16194.05 p.2, column 1 Introduction- first paragraph sentence beginning with “Public health 

outcomes are the product of Social Determinants of Health.....” consider adding “and other 

factors.

Comment noted. Changes have been made to the Plan.

16194.06 p.1, column 2 Existing text: “Climate Adaptation: Support efforts to prevent climate change 

and make the region more resilient to future changes with reductions in VMT and 

greenhouse gas emissions.” Modify text to read: “Climate Adaptation: Support efforts to 

mitigate climate change and make the region more resilient to future changes with 

reductions in VMT and greenhouse gas emissions.”

Comment noted. Changes have been made in Plan.

16194.07 p.2, Figure 1 Arrows should go both ways. Comment noted. Changes have been made to the Plan.

16194.08 p.3, column 1, paragraph 2 Existing text: “Evidence shows that healthier lifestyles and 

improved air quality can improve outcomes, and built environment factors can play a role 

in supporting healthy behaviors.” Modify text to read: “Evidence shows that healthier 

lifestyles and improved air quality can improve outcomes, and built environment factors 

and related conditions can play a role in supporting healthy behaviors.”

Comment noted. Changes have been made to the Plan.

16194.09 p.3, column 2, paragraph 3 Existing text: “The costs of poor population health and chronic 

disease...” Modify text to read: “The costs of poor public health and chronic disease...”

Comment noted. Changes have been made to the Plan.

16194.10 p.3, column 2, paragraph 3 Existing text: “Access to healthy food environments such as 

grocery stores, farmers’ markets and community gardens decreases food insecurity and 

obesity.” Modify text to read: “Access to healthy food environments such as grocery stores, 

farmers’ markets and community gardens can play an important role in food insecurity and 

obesity.”

Comment noted. Changes have been made in the Plan.

16194.11 p.7, column 1, first line Define “weather insurance” Comment noted. Changes have been made to the Plan.

65
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Submitted by Center for Demographic Research Submittal 16194 Related Documents Link

16194.12 p.7, column 2, paragraph 2 Existing text: “... Providing access to jobs with a living wage is 

critical to ensuring communities become and stay healthy.” Modify text to read: “... 

Providing access to education and job training aligned with job opportunities in the region 

is critical to ensuring communities become and stay healthy.”

Comment noted. Changes have been made to the Plan.

16194.13 p.7, column 2, paragraph 3 Existing text: “...Creating infrastructure and facilities that 

encourage active transportation such as biking and walking provides opportunities for 

residents to increase their daily physical activity.” Modify text to read: “...Creating 

infrastructure policies and community conditions and facilities that encourage active 

transportation such as biking and walking provides opportunities for residents to increase 

their daily physical activity.”

Comment noted. Changes have been made to the Plan.

16194.14 p.8, paragraph 3 Consider adding the recommendations for children which has a higher 

standard of one hour per day. This is valuable as jurisdictions look at health co-benefits of 

safe routes to school infrastructure changes and related programming. p.9, all figures 

Recommend using the more current 2014 data. Also, it might be helpful to look at these 

metrics on a smaller level of geography and/or by poverty and/or by race/ethnicity. 

Especially since there are often funding set asides to reach disadvantaged communities, it 

might be interesting to see what each of these indicators looks like at a more refined level. 

The need is not equally distributed throughout any jurisdiction. p.9 Add table with data for 

walking. p.10, column 2 Consider including funding as both a challenge and an opportunity.

p.8 - Comments noted. Changes have been made to the Plan. p.9 - Comments noted. SCAG 

plans to expand its analysis of public health data over the coming years and will 

incorporate these suggestions. However, SCAG believes additional outreach is necessary to 

identify any concerns local jurisdictions might have regarding the incorporation of smaller 

geographic analysis into the Plan. SCAG will incorporate newer data into the 2020 RTP/SCS, 

however, SCAG will continue to use the 2011 CHIS data for the 2016 RTP/SCS to be as 

consistent as possible in reporting base year statistics. p.9 - Comments noted. Changes 

have been made to the Plan. p.10 - Comments noted.

16194.15 p.10, column 1, last sentence Existing text: “Much of our local arterial system is also in need 

of pavement improvements, as local roadways in the SCAG region average a score of 69 out 

of 100 in the Pavement Condition Index (PCI), where a score of 70 or less typically 

translates to conditions that are inadequate.” Modify text to read: “Much of our local 

arterial system is also in need of pavement improvements, as local roadways in the SCAG 

region average a score of 69 out of 100 in the Pavement Condition Index (PCI), where a 

score of 70 or less typically translates to conditions that are more costly to repair.”

Comment noted. Changes have made to the Plan.

16194.16 p.10, column 2, paragraph 4 Existing text: “With more than 18 million people, 191 cities, six 

counties and hundreds of local and regional agencies, Southern California is one of the 

most complex regions on earth. Within the region, health outcomes vary widely based on 

geography, income and race.” Modify text to read: “With more than 18 million people, 191 

cities, six counties and hundreds of local and regional agencies, Southern California is a 

diverse region. Within the region, health outcomes vary widely based on many things, such 

as geography, income and race.”

Comment noted. Changes have been made to the Plan.

16194.17 p. 15, column 2, paragraph 3; & throughout all "500 foot buffer”- be consistent with usage 

and description throughout all documents in whether this is adjacent to just freeways or 

freeways, rail, and high frequency transit corridors. p. 15-20, Tables 5,6,7,8,9,10,11 Cite 

sources of table data. Define SHSP in Table 11

p. 15 - Comment noted. Changes made to the Plan. The use of the word “buffer” has been 

omitted from the Plan. However, SCAG will continue to utilize the advisory 

recommendation from ARB’s 2005 Air Quality and Land Use Manual to avoid siting new 

sensitive land uses within 500 feet of a freeway or urban roads with 100,000 vehicles per 

day. p. 15-20 - Comment noted. Changes have been made to the Plan.

66
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Submitted by Center for Demographic Research Submittal 16194 Related Documents Link

16194.18 p. 16, column 1, paragraph 1 Existing text: “Region-wide, about ten percent of the land area 

within HQTAs is also within the 500 foot buffer of the freeway. To balance regional policy 

goals, the Plan accommodates the vast majority of growth within HQTAs outside of the 500 

feet buffer of freeways...” Modify text to read: “Region-wide, about ten percent of the land 

area within HQTAs is also within 500 feet of the freeway. To balance regional policy goals, 

the Plan accommodates the vast majority of growth within HQTAs but beyond 500 feet of 

freeways...”

Changes have been made to the Plan, and the use of the word “buffer” has been omitted. 

However, SCAG will continue to utilize the advisory recommendation from ARB’s 2005 Air 

Quality and Land Use Manual to avoid siting new sensitive land uses within 500 feet of a 

freeway or urban roads with 100,000 vehicles per day.

16194.19 p. 17, column 1 “Water Consumption” and “Land Consumption” Specify the time period for 

the change or difference in numbers. Compare this to 2040 Baseline. p. 19, column 2 “Public

 Health Work Program” Clarify if this work program was approved by the RC or SCAG staff is 

pursuing these tasks under direction of RC to incorporate more public health into RTP. p. 

22-29 Are these all “best practices” or are they local examples of promising practices? Since 

some of these are in process, are the results are there to show that this particular practice 

has proven efficacy over another? These may have the potential to be best practices. If the 

project is based upon a best practice, it is recommended to link to the best practice so 

other jurisdictional leaders could consider for replication. If it is not already a proven 

practice, suggest calling it something different such as “local promising practices”. Add the 

Complete Streets Guidelines that are being developed in Orange County (which integrates 

in best practices.)

p.17 Comment noted. Changes have been made to the Plan. p.19 Comment noted. In 

2013, the SCAG Regional Council adopted the recommendations of the Public Health 

Subcommittee to "Provide robust public health data and information, as feasible, to better 

inform regional policy, the development of the 2016-2040 RTP/SCS, and support public 

health stakeholder participation," and to "Promote and seek ongoing partnerships with 

regional partners, local public health departments and other stakeholders." The strategies 

and actions in the Public Health Appendix incorporate the Subcommittee 

recommendations and will be adopted as part of the Plan. The title of this section has 

been changed to Plan Implementation to align with other Plan components. p.22-29 

Comment noted. Changes have been made to the Plan to refer to the examples as 

"Initiatives." SCAG will work with jurisdictions across the region to collect additional 

examples of promising initiatives as part the implementation of the Plan.

16194.20 p. 4, Exhibit 2 Exhibit is labeled warehouse & distribution centers but shows manufacturing 

firms total employment. Correct.

Comment noted. The exhibit title has been corrected.

Submitted by Center for Demographic Research Submittal 16237 Related Documents Link

16237.01 Existing statement: "Note: The forecasted land use development patterns shown are based 

on Transportation Analysis Zone (TAZ) level data utilized to conduct required modeling 

analyses. Data at the TAZ level or at a geography smaller than the jurisdictional level are 

advisory only and non-binding, because SCAG sub-jurisdictional forecasts are not to be 

adopted as part of the 2016 RTP/SCS. The data is controlled to be within the density ranges 

of local general plans and/or input received from local jurisdictions. For the purpose of 

determining consistency for California Environmental Quality Act (CEQA) streamlining, lead 

agencies have the sole discretion in determining a local project's consistency with the 2016 

RTP/SCS. Modify to read: “Note: The forecasted land use development patterns shown are 

based on Transportation Analysis Zone (TAZ) level data utilized to conduct required 

modeling analyses. Data at the TAZ level or at a geography smaller than the jurisdictional 

level are advisory only and non-binding, because SCAG sub-jurisdictional forecasts are not 

to be adopted as part of the 2016 RTP/SCS. The advisory subjurisdictional data shall not be 

required for purposes of qualifying for future grant funding or other incentives or for 

determining a proposed project’s consistency with the 2016 RTP/SCS for any impact 

analysis required pursuant to the California Environmental Quality Act (CEQA)."

Comment noted. The 2016 RTP/SCS is the product of a bottom-up, iterative local input 

process. SCAG has actively sought consensus from our subregional partners on local SCS 

consistency determination for future funding and other opportunities consistent with the 

core principles specified in Chapter 4. It has been re-emphasized that the preferred 

scenario and corresponding forecast of population, household, and employment growth is 

adopted at the jurisdictional level as part of the 2016 RTP/SCS, and any corresponding subjurisdictional level data and/or maps is advisory only.

67
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Submitted by City of Alhambra Submittal 16146 Related Documents Link

16146.01 I am writing to express strong support for the continued inclusion of the SR-710 Freeway 

Tunnel Project in the Southern CA Association of Governments (SCAG) 2016-2040 Regional 

Transportation Plan/Sustainable Communities Strategy (RTP/SCS). A freeway tunnel directly 

comports with several SCAG goals including decreasing time on the road, enhancing 

economic opportunities, and improving air quality. The freeway tunnel has strong local 

support and is consistent with voter mandate and local plans. A recent poll shows 2-1 

support for a tunnel, proving that a vocal minority is not representative of the broader 

community. Almost two-thirds (65.5%) of voters in the five cities that currently oppose the 

freeway tunnel also supported Measure R, which explicitly contained the freeway tunnel 

project. The tunnel, as you know, was also adopted in Metro's Long Range Transportation 

Plan. Most importantly, the freeway tunnel would significantly improve air quality and 

reduce cancer risk for the majority of the study area. Unfortunately, lower income, minority 

communities near the freeway are more impacted by poor air quality than those in more 

affluent areas to the north. The SR 710 North Study Draft Environmental Impact Report 

shows that cities south of the freeway have existing Cancer Risk levels 20% to over 60% 

higher than their neighbors to the north. This disparity is clearly an unacceptable 

environmental injustice for the Los Angeles Region. A freeway tunnel also maximizes 

mobility and flow of traffic throughout the Los Angeles Region. Traffic must be moved from 

local streets back onto freeways where it was originally designed to go. A freeway tunnel 

solves this problem and reduces cut-through traffic on neighborhood streets by 43% or 

57,600 vehicles per day.  It's critical that SCAG maintain support for the tunnel and 

sustain inclusion of the project in the 2016-2040 RTP. Completion of the freeway is vital to 

the health and safety of thousands of Los Angeles area residents. I am confident that SCAG 

will remain steadfast in support for the tunnel as the best alternative for completion of the 

710 freeway.

Comment Noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description and associated modeling analysis.

Submitted by City of Anahiem Submittal 16248 Related Documents Link

16248.01 RTP/SCS, Executive Summary, Page 4, Passenger Rail: The description for the California 

High-Speed Train system should include its Phase 1 terminus in Anaheim. Please add 

Anaheim and its anticipated timing to this section and any other descriptions of the 

California High-Speed Train throughout the RTP/SCS and PEIR.

Comment noted. The Phase 1 description has been clarified to incorporate Anaheim.

Submitted by City of Calimesa Submittal 16044 Related Documents

16044.01 Wildlife Corredor's connecting under or over freeways and major Roads. We must provide 

this protection for the wildlife movement.

The RTP/SCS describes (in Chapter 5) next steps for further developing a habitat 

conservation strategy. Included in the steps is the recommendation to provide “incentives 

for jurisdictions to cooperate across county lines to protect and restore natural habitat 

corridors, especially where corridors cross county boundaries.” The Natural/Farm Lands 

Appendix further supports wildlife corridors in its recommended policies, with the specific 

recommendation to “Encourage and facilitate research, programs and policies to identify, 

protect and restore natural habitat corridors, especially where corridors cross county 

boundaries. Additionally, continue support for preserving wildlife corridors and wildlife 

crossings to minimize the impact of transportation projects on wildlife species and habitat 

fragmentation.”

68
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Submitted by City of Claremont Submittal 16340 Related Documents Link

16340.01 The current forecast in the Draft RTP/SCS of completing the Foothill Gold Line in 2040 

should be amended to complete this vitally needed project as soon as possible. No other 

rail project in Los Angeles County is as ready as this one. The project will be ready in 2017 

to break ground and SCAG should find ways to include innovative sources to fully fund the 

$1,216 M project sooner as they are doing with other unfunded rail projects.

The funding identified in the Draft 2016 RTP/SCS for the Foothill Gold Line Extension Phase 

2B is based upon innovative strategies that are not expected to be available in the near 

term. The earliest completion date for this project would be 2035 and the RTP/SCS has 

been adjusted accordingly. Should this project be advanced by Metro as it updates its Long 

Range Transportation Plan, the completion date can be adjusted through a future 2016 

RTP/SCS amendment at the request of Metro.

Submitted by City of Diamond Bar Submittal 16345 Related Documents Link

16345.01 While the overall goal to reduce both the congestion impacts and environmental impacts is 

admirable, we continue to have concerns regarding the component of the 2016 RTP to 

designate only the Pomona (SR-60) Freeway as an 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 business of many 

cities, including Diamond Bar.

Comment noted. SCAG acknowledges the need for continuing analyses and dialogue with 

stakeholders. Please note that the inclusion of the East-West Freight Corridor in the 2016 

RTP/SCS allows for further analyses to be conducted. Specific costs, refined user demand, 

accessibility concerns, designs, and alternative alignments would be identified through a 

project level Environmental Impact Report (EIR) . Further discussion of project mitigation 

concerns would also be addressed through upcoming processes.

16345.02 We still believe it is premature to identify the State Route 60 and the San Jose Creek Wash 

alignments as a viable East-West Freight Corridor Project in the 2016 RTP. We have the 

following specific concerns: • No studies have been conducted regarding the localized air, 

noise, vibration, or visual impacts of an elevated facility 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 acquisition).

Comment noted. The specific impacts of the East-West Freight Corridor project, including 

localized air, noise, vibration, or visual impacts, would be determined through the 

completion of a project-level Environmental Impact Report (EIR). SCAG acknowledges the 

need for continuing analyses and dialogue with stakeholders.

16345.03 • 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.

Comment noted. Numerous potential alignments along alternative freeway corridors were 

considered and analyzed as part of the Comprehensive Regional Goods Movement Study 

and Implementation Plan (2012) and the 2012 RTP/SCS including the I-210, SR-60, I-10, and 

SR-91. This was in addition to other alignments (e.g., the UPRR corridor as noted above, 

hybrid alignments). Right-of-way acquisition was only one criteria considered in 

identification of the proposed alignment of the East-West Freight Corridor. Among other 

criteria considered were proximity to manufacturing facilities, warehousing, and other 

goods movement dependent industries, potential impacts to local residents and 

businesses, and geographic limitations. SCAG acknowledges the need for continuing 

analyses and dialogue with stakeholders.

16345.04 • The “preferred” alignments could potentially conflict with other vital transportation 

projects that include the SR-57/60 Confluence Project, missing freeway connectors 

between SR-60 and SR-57, SR-57 HOV lanes, I-605/SR-60 Mixed Flow and HOV direct 

connectors and the Gold Line light rail extension from East Los Angeles to South El Monte 

near I-605. These are all high priority projects that will be realized in the coming decades 

and are essential to all residents and businesses in Southern California that utilize public 

infrastructure on ' a daily basis.

Comment noted. SCAG acknowledges the need for continuing analyses and dialogue with 

stakeholders to identify the most desirable use for the SR-60 corridor. Please also note 

that analyses to date on the EWFC have not precluded the development of the other 

transportation projects referenced.

16345.05 • Lack of comprehensive review of the use of San Jose Creek Wash, as part of the 

“preferred” alignment for an East-West Freight Corridor from agencies such as L.A. County 

Public Works and the Army Corps of Engineers.

Comment noted. Inclusion of the East-West Freight Corridor in the 2016 RTP/SCS allows 

for further work to be conducted on the project through an Environmental Impact Report 

(EIR).

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holdID Comment Response 

Submitted by City of Diamond Bar Submittal 16345 Related Documents Link

16345.06 • The desired electric or zero-emission goods movement technology does not have any 

large-scale application to verify that it is feasible for this vision.

The 2016 RTP/SCS lays out a regional roadmap to achieving goods movement 

environmental objectives recognizing the technological, operational, and cost challenges 

for the broad scale deployment of zero-emission technologies.

16345.07 Inappropriately including the East-West Freight Corridor in the financially-constrained plan, 

with an estimated project cost of over $23 billion, it is not reasonable to assume the 

Corridor can be afforded within the constrained monies. 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-ofway 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. 

We understand that SCAG is currently conducting a Financial Study focusing on determining 

an initial viable operation segment. We look forward to seeing the results of this study.

In accordance with state and federal requirements, the 2016 RTP/SCS includes a financial 

plan that estimates how much funding will be needed to implement transportation 

investment needs, as well as operate and maintain the transportation system as a whole 

over the life of the Plan. The Plan must demonstrate that there is a balance between the 

estimated costs of the projects and programs described in the Plan and revenue sources 

reasonably expected to be available for transportation investments. SCAG recognizes that 

additional project development work is needed for this corridor, including environmental 

and financial analyses. SCAG has amended the Plan as necessary to update the project 

description and cost estimate.

16345.08 We respectfully request the 2016 RTP and PEIR to consider all possible routes to serve the 

ever-increasing demands of the east-west goods movement between 1-710 and 1-15. It is 

premature to conclude SR-60 is physically or financially feasible, and that better options 

may materialize through further studies.

Comment noted. Inclusion of the East-West Freight Corridor in the 2016 RTP/SCS allows 

for further work to be conducted on the project through an Environmental Impact Report 

(EIR). Further, numerous potential alignments along alternative freeway corridors were 

considered and analyzed as part of the Comprehensive Regional Goods Movement Study 

and Implementation Plan (2012) and the 2012 RTP/SCS including the I-210, SR-60, I-10, and 

SR-91. SCAG acknowledges the need for continuing analyses and dialogue with 

stakeholders.

Submitted by City of Eastvale Submittal 16304 Related Documents Link

16304.01 The 2016 RTP/SCS Project List includes as future Eastvale projects several items that have 

already been completed, under construction, or are not located within Eastvale city limits, 

as follows: 1. Archibald Avenue between the San Bernardino County Line and 65th Street 

will be constructed to widen from 2to 6 lanes.

Comment noted. We have addressed all modification requests to the Project List as 

submitted by county transportation commissions through the standard RTP long-range 

project list modification and FTIP database update processes. We will work with RCTC to 

revise the completion year for RTP 3A01WT124 in a future RTP Amendment.

16304.02 2. Schleisman Road between the San Bernardino County Line/City of Chino and Harrison 

Avenue will be constructed as a 6-lane road throughout that segment within the next four 

years as conditions of approval for adjacent proposed project.

Comment noted. We have addressed all modification requests to the Project List as 

submitted by county transportation commissions through the standard RTP long-range 

project list modification and FTIP database update processes. We will work with RCTC to 

revise the completion year for RTP ID# 3A04WT186 in a future RTP Amendment.

16304.03 3. The ramp improvements identified on the 60 at Milliken in Eastvale may be misidentified 

and should be changed to Etiwanda in Jurupa Valley because Harrel and Iberia are both 

located in Jurupa Valley off Etiwanda. Eastvale staff has no knowledge of ramp 

improvements

Comment noted. We have addressed all modification requests to the Project List as 

submitted by county transportation commissions through the standard RTP long-range 

project list modification and FTIP database update processes. We will work with RCTC to 

revise the Lead Agency within the Project List.

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Submitted by City of El Segundo Submittal 16305 Related Documents Link

16305.01 The City is concerned that the RTP demonstrates a shift in SCAG policy away from 

regionalization as a means of distributing aviation demand and its impacts, toward 

inducing, and thus centralizing demand at LAX by funding removal of existing ground access 

constraints and generally encouraging greater growth. Indeed, unlike previous RTPs, the 

2016 RTP’s core aviation strategy appears to be centralization of the region’s aviation 

activity at LAX. Such a strategy will ensure that the burdens of heightened demand on 

communities like El Segundo surrounding the airport persist well into the 21st century, 

while depriving other communities, like those near Ontario International Airport, of the 

airport growth they desire.

Comment noted. The Airport Ground Access sections details the extensive efforts 

underway throughout the region to improve access to all of the region's airports, not just 

LAX. In addition, the forecast growth rate is higher at the other regional airports than LAX. 

Per Transportation Committee action, SCAG remains committed to regionalization of 

aviation into the future.

16305.02 The City also has serious concerns about the RTP’s 2040 forecast of “constrained” demand 

at LAX: between 82.9 million annual passengers (“MAP”) and 96.6 MAP, representing a 

nearly 30 percent increase over documented passenger levels for 2015. Disturbingly, this 

MAP forecast assumes the approval and completion of local ground access projects that are 

still in the early planning and environmental review stages. These projects include the 

massive, controversial Landside Access Modernization Program (“LAMP”) proposed at LAX, 

for which no environmental impact report (“EIR”) has been released, and the proposed 

Airport Metro Connector. See RTP Project List, Table 2 at 157, 162.

Comment Noted. SCAG recognizes that the projects are pending or will undergo 

environmental review. Environmental clearance is not a prerequisite for including a 

transportation project in the RTP/SCS. As with other projects included within the Project 

List, once a locally preferred alternative (LPA) is identified in the final environmental 

document SCAG will work with the CTC to amend the RTP/SCS as necessary to update the 

project description and associated modeling analysis.

16305.03 The City strongly urges SCAG not to assume completion of local airport ground access 

projects and other capacity enhancing projects at LAX as they are years away from 

realization and may never be implemented due to potential opposition by the airport’s 

stakeholders, including the City of El Segundo. Los Angeles World Airports (“LAWA”), which 

has approval authority over projects at LAX, has completed no environmental review of 

operations above 78.9 MAP—the airport’s operational capacity as set forth in the LAX 

Master Plan, the 2006 Stipulated Settlement Agreement that resulted from Master Plan 

litigation, and the Specific Plan Amendment Study (“SPAS”) LAWA prepared pursuant to the 

Settlement.

Comment Noted. SCAG recognizes that the projects are pending or will undergo 

environmental review. Environmental clearance is not a prerequisite for including 

transportation improvement projects in the RTP/SCS. As with other projects included 

within the Project List, once a locally preferred alternative (LPA) is identified in the final 

environmental document SCAG will work with the CTC to amend the RTP/SCS as necessary 

to update the project description and associated modeling analysis.

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holdID Comment Response 

Submitted by City of El Segundo Submittal 16305 Related Documents Link

16305.04 SCAG’s RTP commitment of over $2 billion toward ground access projects at LAX is 

premature and inappropriately pre-ordains that the airport will expand continuously for the 

next quarter-century. Such a move by SCAG is particularly inappropriate because LAWA 

itself has consistently committed to the community that it is planning for 78.9 MAP, 

nothing more. See LAX Master Plan (2004) at 2-1 (“Alternative D” designed to serve 

“approximately 78 MAP, which is similar to the activity level identified in the scenario 

adopted by SCAG for LAX”), excerpted at Attachment A and available at 

http://www.lawa.org/uploadedFiles/OurLAX/pdf/Final_LAX MP/009 MainDocument Ch 

2.00.pdf; LAX Master Plan Final EIR (2004), Executive Summary available at 

http://www.lawa.org/uploadedFiles/OurLAX/Past Projects and Studies/Past Publicatio 

ns/FEIS EIR Parti-01 ExecutiveSummarv.pdf; 2006 Stipulated Settlement at 9, attached as 

Attachment B: Final LAX SPAS Report (2013) at 1-1 (identifying amendments to the LAX 

Specific Plan that plan for “a practical capacity of 78.9 [MAP]”), excerpted at Attachment C 

and available at 

http://www.lawa.org/uDloadedFiles/SPAS/PDF/LAX%20SPAS%20Final%20SPAS%20 

Report%20Document%20Final%20CD-Web%20Version%2001%2030%202013.pdf: City of 

Los Angeles LAX Specific Plan (2005) at 12 (requiring LAWA to initiate a new specific plan 

amendment study if annual passenger forecast is anticipated to exceed 78.9 MAP), 

available at http://planning.lacitv.org/complan/specplan/pdf/LAX.pdf. As LAWA has not 

completed the public, environmental, and political processes necessary to evaluate such 

massive growth beyond 78.9 MAP, SCAG should not be relying on numbers as high as 96.6 

MAP and the proposed RTP funding for ground access projects at LAX should be reduced 

accordingly.

Comment noted. The 82.9 - 96,6 MAP range for LAX was supported by LAWA and inclusion 

of the ground access projects at LAX was submitted by LAWA via Metro, consistent with 

our planning practice. Nothing in the RTP relieves LAWA of any responsibility to conduct 

project level environmental review according to state and federal guidelines.

16305.05 Purporting to calculate existing “airfield” and “terminal” capacity constraints at each 

“constrained” airport in the region, the RTP concludes that “the [2040] capacity of LAX is in 

the range of 82.9 MAP to 96.6 MAP, limited by the airfield, based on the runway 

configuration described ... in the SPAS.” RTP Aviation & Ground Access Appendix 22. See 

also id. at 19 (“airfield” constraint looks at runways’ and taxiways’ overall aircraft capacity; 

“terminal” constraint looks at passenger gates as a limiting factor on demand). This forecast 

is as much as 30 percent higher than documented passenger levels in 2015, and 25 percent 

higher than LAWA’s current planned capacity of 78.9 MAP, all using the same airport 

facilities (i.e., gates and airfield) that LAWA’s own recent environmental review documents 

consistently conclude would result in serving 78.9 MAP.

The 82.9 to 96.6 MAP range is not a demand forecast. It is an estimate of the upper bound 

of the physical capacity of the airport. We believe the actual demand at LAX could be even 

higher by 2040, if it was not capacity constrained. This estimate is consistent with LAWA's 

current planning efforts for its facilities based on the gate cap of 153 imposed by the 

settlement agreement through 2020. This is further explained in the Analysis of Airport 

Capacity which has been placed on SCAG's website: 

http://www.scag.ca.gov/Documents/AnalysisOfAirportCapacityConstraints.pdf

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Submitted by City of El Segundo Submittal 16305 Related Documents Link

16305.06 The Master Plan, SPAS, and the 2006 Settlement establish a maximum operational capacity 

of 78.9 MAP. The Master Plan’s design for a total of 153 gates is based on a maximum 

capacity of 78.9 MAP. See SPAS Draft EIR (2012) at 2-4, excerpted at Attachment E. LAWA’s 

recent environmental review of all airport development projects consistently assumes this 

capacity for the purpose of evaluating projects’ environmental impact. See, e.g., Draft EIR, 

Midfield Satellite Concourse (“MSC”) (March 2014) at 4-16 fn. 10 (stating project would 

comply with LAX Master Plan gate cap limit), excerpted at Attachment F: “MSC North 

FAQs,” available at http://www.lawa.org/mscnorth/faq.aspx (stating MSC Program will 

comply with 2006 Stipulated Settlement “at all times”). These documents are not mere 

paper exercises, but rather official representations to the public regarding LAWA’s plans for 

the future of LAX as it relates to surrounding residential and other sensitive land uses. The 

City of El Segundo and the public generally have participated actively in the evaluation of 

LAX development plans and relied in good faith on LAWA’s representations about 

constrained growth at LAX, one of the busiest airport in the United States.

Comment noted. The 82.9 - 96.6 MAP range for LAX was supported by LAWA. Nothing in 

the RTP relieves LAWA of any responsibility it has to conduct its own environmental 

reviews in accord with State and Federal law.

16305.07 Thus, the sudden and unprecedented increase in the LAX passenger forecast is a blow to 

the public’s faith in SCAG as the region’s foremost planning agency, and in LAWA as the 

operator of LAX. Increasing the airport’s capacity for planning purposes is a public process 

that must begin at LAWA and involve the full LAX stakeholder community. Furthermore, 

SCAG’s prior statements regarding the importance of the 78.9 MAP cap call into question 

the proposed RTP’s compliance with SCAG’s mandate under State law to “prepare and 

adopt a regional transportation plan directed at achieving a coordinated and balanced 

regional transportation system, including, but not limited to... aviation facilities and 

services.” Gov. Code § 65080(a) (emphasis added). The public could reasonably assume 

that SCAG has been listening to LAWA, to the exclusion of other interested stakeholders.

Comment noted. The individual airport demand forecasts were developed through a 

public process, including review by SCAG's Aviation Technical Advisory Committee, 

Transportation Committee and Regional Council. Nothing in the RTP relieves LAWA of any 

responsibility it has to conduct its own environmental reviews in accord with State and 

Federal law.

16305.08 LAWA, not SCAG, must take principal responsibility for an open, public process to evaluate 

any potential increase in the passenger forecast for LAX beyond the 78.9 MAP number 

currently contained in LAWA’s approved plans for LAX. For example, LAWA could elect to 

update the LAX Master Plan and SCAG could then include the resulting capacity numbers in 

a future RTP. SCAG should not, as currently proposed, “get out ahead” of LAWA on this 

important issue, as doing so would improperly and prematurely give credence to LAWA’s 

new plan to abruptly depart from its historic assurances to the public before conducting 

proper environmental analysis of the actual impacts of increased passenger forecast.

Comment noted. SCAG agrees that LAWA has the responsibility to evaluate the potential 

impact of any future development at LAX. The 82.9 – 96.6 MAP range for LAX was 

supported by LAWA.Nothing in the RTP relieves LAWA of any responsibility it has to 

conduct its own environmental reviews in accord with State and Federal law.

16305.09 For the foregoing reasons, the City of El Segundo requests that SCAG delay further action 

on the proposed 2016 RTP until the Plan is revised to reflect the capacity for LAX 

established and analyzed in LAWA’s planning documents; in other words, 78.9 MAP.

Comment noted. As the preparer of the RTP/SCS, SCAG has the responsibility to prepare 

an independent assessment of the demand for and capacity of the region's transportation 

system. With regard to aviation, SCAG conducted its own analysis and sought input and 

feedback from the operators of each airport in the region, to gain the benefit of their 

detailed knowledge of their facilities. SCAG also held public meetings on its aviation 

analysis with its various committees and Board. The present RTP meets its obligation to 

present a fair and honest assessment of the region's aviation system.

Submitted by City of Glendale Submittal 16341 Related Documents Link

16341.01 Additionally, we wanted to point out that Table 34, "Transit Agencies Providing Data to 

Google via GTFS" in the Transit appendix, incorrectly omits the Glendale Beeline.

Glendale Beeline has been added to the table.

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Submitted by City of Glendale Submittal 16341 Related Documents Link

16341.02 In light of our comments on the 2012 Draft RTP/SCS, we remain concerned about the need 

for funding of local transportation agencies, including the Glendale Beeline. Local transit 

agencies continue to play a critical role in RTP/SCS transit and rail policies, and as first-last 

mile connections to existing and planned light rail, commuter rail, Bus Rapid Transit, and 

High-Speed Rail service. This is particularly important given the lack of funding allocated to 

local transit programs in the proposed Los Angeles County Measure R sales tax extension.

We concur that additional funding is needed to address projected needs, including funding 

for local transit services. Note that the Plan does not assume funding from a potential 

additional sales tax measure or an extension of Measure R within Los Angeles County. If 

such an additional sales tax measure is approved by Los Angeles County voters, it can be 

incorporated into the Plan through subsequent amendments. In addition, SCAG invites 

staff from all transit providers to participate in the quarterly meetings of the Regional 

Transit Technical Advisory Committee (RTTAC). In the future, this could be a great forum 

for Glendale Beeline staff to present their concerns regarding funding for local operations 

in the regional transportation planning process.

16341.03 The Red Line Extension to Bob Hope Airport remains on the Financially-Constrained RTP 

Projects list, while the Metro Red and Orange Line Extensions to Bob Hope Airport, SR-134 

Transit Corridor connecting North Hollywood and Pasadena via Glendale, and 

Burbank/Glendale LRT projects remain in the list of Strategic Projects. The City of Glendale 

remains of the opinion that all five of these key transit projects should be considered 

among the first tier for "reasonably available revenue" on the Financially- Constrained list.

Comment noted. The SR 134 Transit Corridor connecting the North Hollywood Red and 

Orange Line stations to the Metro Gold Line in Pasadena via Glendale is a financiallyconstrained project (RTP ID# 7120009) in the 2016 RTP/SCS. It is shown on Exhibit 18 in the 

Transit Appendix. The Metro Orange Line BRT extension to Burbank Bob Hope Airport is a 

Strategic Plan project (RTP ID# S1120001) as well as the Burbank/Glendale LRT project 

(RTP ID# S1120013). Should Metro request the advancement of a Strategic Plan project 

into the RTP/SCS after it updates it long-range transportation plan and/or after voter 

approval of a new countywide sales tax measure, this could be accommodated in a future 

RTP/SCS amendment.

16341.04 We commend the additional allocation of funding for Active Transportation in the Draft 

2016 RTP/SCS; however, while the allocation has roughly doubled, from $6.7 billion to 

$12.9 billion, it remains just 2.3% of the total RTP budgeted amount of $556.5 billion. We 

continue to believe Active Transportation should play a larger role in regional efforts to 

improve air quality, reduce Vehicle Miles Traveled, and reduce GHG emissions; and we 

again recommend a greater allocation than currently proposed.

Comment noted. Active transportation is part of a fiscally constrained multi-modal 

transportation plan. Because of the financial constraints, no transportation mode is funded 

to meet 100% of its needs.

16341.05 Finally, consistent with a 2009 vote of the Glendale City Council, the City of Glendale must 

reiterate its opposition to any "gap closure" of SR-710 between 1-10 and SR-134/1-210, 

studies of which are included in the Financially Constrained list for funding using 

"reasonably available revenue." We believe the $70.4 million allocated to this project in the 

RTP should instead be spent on multi-modal alternatives that benefit corridor mobility and 

air quality; examples include expanding mass transit systems, maintaining and preserving 

existing infrastructure, and further increasing the use of rail for long-distance goods 

movement from the ports of Long Beach and Los Angeles.

Comment noted. The environmental analysis of the SR-710 North project is programmed 

in the Federal Transportation Improvement Plans (FTIP) and already underway. SCAG 

recognizes that the project is currently pending environmental review. As with other 

projects included within the Project List, when the SR-710 North Study EIR/EIS process is 

complete and a locally preferred alternative (LPA) is identified in the final environmental 

document SCAG will work with Metro to amend the RTP/SCS as necessary to update the 

project description and associated modeling analysis.

Submitted by City of Irvine Submittal 16306 Related Documents Link

16306.01 The City of Irvine concurs with the comments SCAG will receive from the OCCOG and the 

OCTA. The City requests that SCAG respond to all of the comments detailed in the OCCOG 

and OCTA letters and to act upon any changes advocated by OCCOG, of which the City is a 

member agency.

Comment noted.

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Submitted by City of Irvine Submittal 16306 Related Documents Link

16306.02 Overall, the City of Irvine supports the 2016-2040 RTP/SCS growth forecast and the 

adoption of the growth forecast at a geographic level no lower than the jurisdictional level. 

The 2016-2040 RTP/SCS growth forecast accurately reflects the City of Irvine data that was 

incorporated into the Orange County Projections 2014. The 2016-2040 RTP/SCS growth 

forecast reflects all entitlements, development agreements, and projects recently 

completed or under construction in the City of Irvine.

Comment noted.

16306.03 I have requested at various SCAG meetings, and at our meeting on September 3, 2015, that 

the 2016-2040 RTP/SCS and all alternatives be based on the Policy Growth Forecast that 

includes the technical corrections provided by the Center for Demographic Research, on 

behalf of the City of Irvine.

Comment noted, this comment is to support the Policy Growth Forecast.

16306.04 The 2016-2040 RTP/SCS assumes that almost no new growth will occur within 500 feet of a 

freeway or busy transportation corridor. The 2016-2040 RTP/SCS states that a “buffer” is 

consistent with the California Air Resources Board’s 2005 advisory guidance that housing be 

discouraged within 500 feet of high volume roadways such as freeways. It is important to 

note that CARB’s guidance is not a prohibition of development near high-volume roadways. 

SCAG’s “buffer” strategy eradicates growth in these areas that are otherwise rich in 

connections to jobs, retail and housing accessible by many transportation modes. The 

proposed “buffer” does not reflect the availability of mitigation measures to address nearroadway emissions that remain despite a dramatic reduction of diesel emissions in the last 

decade. This strategy is a short-term response and problematic because it prevents the 

kind of density and proximity between land uses that actually reduce trips and associated 

vehicle mileage traveled (VMT). As vehicle engines and fuels become cleaner, the “buffer” 

strategy will become obsolete yet will leave behind a legacy of inefficient land use patterns. 

Throughout the SCAG Region, the prevailing existing land use patterns include residential 

and sensitive receptor uses within 500 feet of major transportation corridors. In many 

cases, these areas demonstrate compact development form and serve as affordable 

housing. Removing this massive portion of land from availability for use is premature and 

counter to the overarching principles of SB 375 to locate housing near job centers and 

previously urbanized areas.

Comment noted. The Draft RTP/SCS does not assume new growth will be prohibited within 

500 feet of a freeway or busy roadway. Region-wide, projected growth within 500 feet of a 

freeway or busy roadway reflects local input data. The Draft RTP/SCS encourages local 

jurisdictions to establish their own policies to direct growth outside these areas based on 

factors covered in the Appendix: Environmental Justice. The use of the word “buffer” has 

been omitted from the Plan. However, SCAG will continue to utilize the advisory 

recommendation from ARB’s 2005 Air Quality and Land Use Manual to avoid siting new 

sensitive land uses within 500 feet of a freeway or urban roads with 100,000 vehicles per 

day.

16306.05 There needs to be consistency throughout all the documents regarding the 500 foot 

“buffer.” Specifically: • The word “buffer” should not be used. • The amount of distance 

should be clarified (the documents have various ranges from 500 feet to 1,000 feet). • 

Where the distance is measured from should be clarified (e.g., centerline, edge of roadway, 

edge of right of way) should be included. • The types of transportation corridors being 

identified should be clarified (e.g., freeways, high quality transit corridors, high volume 

corridors, rail etc.). • Clarify that the emphasis should be on mitigation not prohibition of 

development. • Clarify there is a conflict with discouraging development within 500 feet of 

these transportation corridors now and that with changes in emissions reductions and fleet 

changes over time that development within 500 feet will not need to be discouraged in the 

future. A mitigation approach will allow for flexibility with the changing fleet mix in the 

future.

• Comment noted. The use of the word “buffer” has been omitted from the Plan. 

However, SCAG will continue to utilize the advisory recommendation from ARB’s 2005 Air 

Quality and Land Use Manual to avoid siting new sensitive land uses within 500 feet of a 

freeway or urban roads with 100,000 vehicles per day. • Comment noted. Changes have 

been made where appropriate. • Comment noted. The distance measured is edge of 

roadway. •Comment noted. The transportation corridor being identified is a freeway. • 

Comment noted. The RTP/SCS does not contain a policy that prohibits development within 

these areas. It encourages local jurisdictions to establish their own policies to limit growth 

in these areas based on factors covered in the Appendix: Environmental Justice – the 

emphasis is on mitigation.

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Submitted by City of Irvine Submittal 16306 Related Documents Link

16306.06 Throughout the documents, there are specific examples of technology identified. It should 

be noted these are only examples and future technologies should not be ignored or 

excluded from meeting the goals of the 2016-2040 RTP/SCS. This will allow the document, 

including mitigation measures, to be more flexible. At the 2016 Consumer Electronics 

Show, the Ehang 184 was showcased. The all-electric drone developed by Chinese UAV 

manufacturer Ehang, is capable of carrying a 100kg person for 23 minutes at speeds of 100 

kph. It is unknown if this type of technology will reach general use, but a technology that 

would have the potential to significantly reduce VMT, traffic congestion, and emissions 

should not be excluded from the plan.

Comment noted. SCAG’s policies are technology neutral with regard to supporting zero 

and/or near-zero emissions vehicles. SCAG will continue to support natural gas fleet 

vehicles by hosting and administering the Southern California Clean Cities Coalition. In 

addition, SCAG communicates with Hydrogen Fuel Cell industry partners to exchange 

information and knowledges. Plug-in Electric vehicles are specifically analyzed in the 

RTP/SCS due to the transportation/land use policy nexus regarding charging station siting. 

Regarding mobility innovations such as carsharing, and ridesourcing, SCAG does not view 

these as specific technologies, but rather as emerging transportation modes. In the 

mobility innovations appendix, SCAG identifies various new technologies that show 

promise in meeting the goals of the RTP/SCS, and will continue to support any and all 

mobility innovations.

Submitted by City of Irvine Submittal 16366 Related Documents Link

16366.05 Language throughout the 2016-2040 RTP/SCS and the associated appendices has a 

tendency to be leading and dramatic in its emphasis of certain key issues such as active 

transportation and public health. While these issues are important, it is recommended that 

the document utilize an unbiased, objective tone. The City of Irvine recommends the 

removal of “Our Vision” and “Our Overarching Strategy” from the Executive Summary of 

the document. These two sections are highly speculative and are not necessary to the 

document. “Our Vision” and “Our Overarching Strategy” go above and beyond the 

requirements of the RTP. Additional examples of overly emphatic language are outlined in 

the enclosed matrix.

Comment noted. We believe this section is important in providing the necessary 

background and context for the development of the rest of the Plan.

16366.06 “Can and Should” As indicated in the PEIR, state law provides that it is appropriate to 

indicate in mitigation measures that they “can and should” be implemented where the 

authority to implement the measures rest with agencies other than SCAG. The language 

conveys to local agencies an affirmative obligation to address each mitigation measure, 

irrespective of whether such agencies deem the measures applicable to a particular project 

or duplicative of their own or other governmental agencies’ regulatory measures. The City 

of Irvine recognizes SCAG’s use of the words “can and should” are derived from the 

California Environmental Quality Act (CEQA), at Public Resources Code sections 21081 and 

2155.2(b)(5)(B)(ii) and the CEQA Guidelines, including section 15091(a)(2). Given the 

express limitation of SB 375 upon respective local agencies’ land use authority, the City of 

Irvine deems any language seemingly imposing affirmative obligations contrary to SB 375 to 

be inappropriate. The use of the language “can and should” for mitigation measures 

addressed to local agencies should be revised as follows: “Can and Should” 

Recommendations: Change language in all project level mitigation measures to read 

“should consider where applicable and feasible.” This change will clarify that the project 

level mitigation measures are a menu of options.

Comment noted. Please see Master Response No. 4 and Response to Comment No. 4 in 

the City of Irvine comment letter (Comment Letter 19) in the Response to Comments of 

the proposed Final PEIR.

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Submitted by City of Irvine Submittal 16367 Related Documents Link

16367.01 On page 163 of Appendix 8 to the PEIR, the following change should be made to 2016-2040 

RTP/SCS Project ID 2120006: Existing text: "Project feasibility study of six miles of new 

roadways including Trabuco Road, 0 Street, and Marine Way." Revised text: "Project 

feasibility study of two miles of new roadways including Marine Way." The modification is 

consistent with information submitted by the City of Irvine to OCTA.

Comment noted. The FTIP projects included within the RTP/SCS Project List incorporates 

the adopted 2015 FTIP and Amendments 1 – 7, and 12. Regarding Project #2120006, the 

description has been updated through a subsequent amendment and will be reflected in 

the 2017 FTIP list of projects.

Submitted by City of Irwindale Submittal 16171 Related Documents Link

16171.01 We are pleased that Southern California Association of Governments (SCAG) is including 

the Foothill Gold Line from Glendora to Montclair in the Draft Regional Transportation 

Plan/Sustainable Communities Strategy (RTP/SCS) under the financially constrained plan. 

However, the RTP/SCS forecasts completion of the project in 2040, almost two decades 

beyond the current plan while also understating the project costs. The Foothill Gold Line is 

a critically needed link that will connect a dozen universities, the LA County Fairplex, and LA 

County with San Bernardino and Riverside Counties at the Montclair TransCenter. The 

Foothill Gold Line will alleviate traffic on one of the most heavily congested corridors which 

is expected to assume the majority of the population and employment growth in the 

coming decades. The Glendora to Montclair segment is estimated to achieve 18,300 daily 

boardings by reducing Vehicle Miles Traveled (VMT) by 111,000 and reduce emission 

burden levels resulting in beneficial effect on CO, TOG, Nox, PM10 and PM 2.5 levels. The 

current forecast in the Draft RTP/SCS of completing the Foothill Gold Line in 2040 is too late 

and should be amended to complete this vitally needed project as soon as possible. No 

other rail project in Los Angeles County is as ready as this one. The project will be ready in 

2017 to break ground and SCAG should find ways to include innovative sources to fully fund 

the $1,216 M project sooner as they are doing with other unfunded rail projects.

The funding identified in the Draft 2016 RTP/SCS for the Foothill Gold Line Extension Phase 

2B is based upon innovative strategies that are not expected to be available in the near 

term. The earliest completion date for this project would be 2035 and the RTP/SCS has 

been adjusted accordingly. Should this project be advanced by Metro as it updates its Long 

Range Transportation Plan, the completion date can be adjusted through a future RTP/SCS 

amendment at the request of Metro.

Submitted by City of La Canada Flintridge Submittal 16333 Related Documents Link

16333.01 We respectfully request that SCAG eliminate the SR-710 North Project from the 2016 

RTP/SCS. First, the Freeway Tunnel Alternative is flawed and unnecessary, failing to provide 

a real solution to the region's transportation needs. Second, the Freeway Tunnel would be 

inconsistent with the RTP/SCS's goal that transportation projects be sustainable and 

environmentally protective. Third, there are viable alternatives to the Freeway Tunnel that 

improve mobility and expand transportation options while limiting dependence on 

personal vehicles.

Comment Noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description and associated modeling analysis.

Submitted by City of La Habra Submittal 16049 Related Documents

16049.01 I recommend zooming in the bicycle trail maps so that you can actually see what cities the 

routes go through. For instance, the Orange County Loop bike trail is zoomed out so far you 

can't see what the cities the route touches. For a staff person who knows the details more 

intimately, it's fine, but for the general public or lay-person, the map is almost unreadable. 

Thanks

Comment noted: The Regional Bikeways maps denote proposed routes that cover the 

majority of the 38,000 square mile region and are displayed primarily for illustrative 

purposes, not navigation. Individual routes may also change as they are finalized by the 

local implementing jurisdictions.

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Submitted by City of La Habra Submittal 16049 Related Documents

16049.02 General question - are the light rail future extensions ranked? If not, it might be good to 

show the rankings of the projects to show which ones are more likely to be built as 

compared to the lower ranking projects.

SCAG does not rank projects within the context of the RTP/SCS. Project implementation 

schedules (estimated year of completion) are identified in the Project List Appendix.

16049.03 Map comment for light rail - I recommend zooming in the maps where possible to show 

what cities the light rail/heavy rail/commuter rail extension projects touch. The maps are 

zoomed out so far to show the whole Southern California region that it is difficult to see 

exactly where these projects are occurring.

Exhibits 12 through 17 on pages 68 through 73 of the Transit Appendix to the Draft 2016 

RTP/SCS contain more localized maps of existing services and planned transit capital 

investments.

Submitted by City of Laguna Niguel Submittal 16335 Related Documents Link

16335.01 I recently reviewed the comments submitted by the Orange County Council of Government 

(OCCOG) in association with a number of cities, including our neighboring City of Mission 

Viejo, and I, as an individual Council Member, would like to express my concurrence with 

their findings. I appreciate SCAG's efforts in developing a plan that is critical to the region's 

ability to receive federal funding for transportation projects, improve mobility, support 

sustainable development, operate and maintain the transportation system, and meet the 

region's greenhouse gas emission reduction targets and other air quality standards.

Comment noted.

Submitted by City of Lake Forest Submittal 16309 Related Documents Link

16309.01 We appreciate the ongoing coordination on the growth forecast between SCAG and the 

Center for Demographic Research (CDR) at California State University, Fullerton to ensure 

that the 2014 Orange County Projections (OCP) and its updates were included in the 2016 

RTP/SCS. In addition, we appreciate that all entitlements, development agreements, and 

projects recently completed or under construction, as provided to you in our July 10, 2015 

correspondence, were properly reflected in the 2016 RTP/SCS growth forecast.

Comment noted.

Submitted by City of Los Angeles Submittal 16262 Related Documents

16262.01 Add pending project for LA River from its master plan. The Los Angeles River is considered as part of the 2016 RTP/SCS. Please see the Active 

Transportation Appendix. The River is considered both a regional greenway, and part of 

the regional bikeway network.

16262.02 It is important to delineate between walking and cycling both have very different 

demographics.

Comment noted. Walking and bicycling in the SCAG region is discussed in greater detail in 

the Active Transportation Appendix.

16262.03 There are images of bulb out that have water filtration features but no mention of green 

streets has a method to reduce and/or calm traffic. It is is line with goals mentioned in pg 

122 for biological resources as they have several benefits.

Comment noted. Traffic calming can include green streets.

16262.04 Pg. 115 There is no mention large water restoration programs or local water policies like LA 

River Revitalization Master Plan, One Water, prop 1 and prop o.

Comment noted. Page 97 of the RTP/SCS supports the integration of river restoration 

programs and active transportation in the formation of urban greenways as part of the 

Regional Greenway Network.

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Submitted by City of Los Angeles - Department of City Planning Submittal 16155 Related Documents Link

16155.01 Given the severity of the housing affordability crisis faced by the region, and the direct 

impact unaffordability has on Plan goals such as mobility, air quality and economic wellbeing, the City of Los Angeles expected the housing topic to receive a higher overall profile 

throughout the report. When the topic was addressed in detail, it often did so in ways that 

may inadvertently be counter-productive to many of the Plan’s goals. SB 375, which 

established the requirement to create a sustainable communities strategy, is meant to 

better coordinate planning for transit and housing. Planning for housing is one of the 

primary purposes of the SCS. Three of the eight statutory requirements in Health and 

Safety Sec. 65080 (b)(2)(B) involve housing, including a consideration of the state housing 

goals and the identification of areas within the region sufficient to house “all the 

population of the region, including all economic segments of the population” as well as “an 

eight-year projection of the regional housing need for the region.” It is not clear in the Plan 

how or where these housing-related requirements would be satisfied. The 2016 RTP/SCS 

acknowledges that the region only built 10% of the housing necessary for those with low 

incomes during the previous period and missed its targets for above moderate income 

households as well. The 8-year regional housing needs assessment for the SCAG region is 

for 412,000 new housing units, more than 270,000 of which are supposed to be affordable 

for those with moderate income or less. The SCS should help answer how and where the 

region should grow to ensure the housing needs of more are met and lead on the hard 

policy choices that need to be made around housing, particularly in this time of limited 

public funding. Examples of an overall lack of focus on housing affordability includes: • The 

list of nine 2016 RTP/SCS Goals (pg. 60) does not mention housing. • The sections titled 

“What Will We Accomplish” and “How Will We Ensure Success” in the Executive Summary 

(pg. 8 and 9) do not mention any housing related goals. • There is little discussion of how 

unaffordability undermines the goals of the RTP/SCS, including suburban sprawl, longer job 

commutes, higher vehicles mile travelled and greenhouse gas emissions, etc. While the 

Plan contains a statement that transit investments and strategies will be most effective if 

“coordinated with land use strategies such as TOD and providing affordable housing” (pg. 

92), this discussion should occur earlier in the document and be expanded. • The scale of 

the housing problem is not adequately addressed. For example, under the “Challenges We 

Face” section (pg. 3 - Executive Summary), the Plan summarizes the region’s housing 

problems simply as: “Housing prices are increasing: Housing prices are rising steadily and 

affordability is declining...” This language simply fails to capture the magnitude of the crisis 

facing the region. The Los Angeles metro area not only has the lowest affordability rate in 

the country, but no area of the country has ever seen incomes and housing costs so out of 

whack as they are today in Los Angeles. When taking into account the high cost of housing, 

LA County has been recently identified as having the highest effective poverty rates in the 

State[1]. • The section titled “Our Progress Since 2012” does not mention the progress 

towards meeting the region’s housing needs as expressed through the required Regional 

Housing Need Assessment (RHNA) allocation. Nor does it describe how past residential 

growth trends met prior goals. These are two of the primary components of the Sustainable 

Communities Strategy (per 65080 (b)(2)(B). State legislation around housing funding is 

mentioned, but not other significant laws such as AB 2222 (2014) and AB 744 (2015).

SCAG acknowledges that progress on affordable housing has been insufficient in meeting 

the needs of the region. The language of the draft 2016 RTP/SCS has been edited to draw 

more attention to the dire need of affordable housing in the region. As a regional planning 

agency, SCAG encourages jurisdictions to consider different strategies to utilize at the local 

level to promote the development of affordable housing, and SCAG has included an 

affordable housing strategy toolbox for jurisdictions as part of the affordable housing 

section in chapter 3. We are committed to working with our local jurisdictions to ensure 

that their housing elements are in compliance with State housing law and offer technical 

assistance for affordable housing grant programs such as the Affordable Housing & 

Sustainable Communities (AHSC) program, California Department of Housing and 

Community Development Transit-Oriented Development (TOD) grant, and establishing 

community revitalization and investment agency or enhanced infrastructure financing 

districts. The draft RTP/SCS on page 54 has been updated to reflect your comments on 

highlighting issues associated with unaffordability and the effectiveness of considering 

both transit and land use strategies. In regard to monitoring progress made in affordable 

housing built, SCAG is developing a pilot survey to determine affordable housing building 

activity in the region. Currently available data by jurisdiction is incomplete and 

inconsistent and SCAG will be working to increase the State-mandated annual progress 

report submittal rates in the region.

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Submitted by City of Los Angeles - Department of City Planning Submittal 16155 Related Documents Link

16155.02.1 2. Provide greater clarity in the discussion of gentrification and displacement Demographic 

change is an important contributor to regional land use outcomes and equity concerns. The 

Department appreciates the Plan’s interest and concern for the issues of gentrification and 

displacement, particularly in relation to areas around transit stations (e.g. pgs. 12, 54, 69, ), 

and is grateful for the amount of data and research devoted to this complicated subject. 

We also agree with the assessment that jurisdictions need to be sensitive to this topic and 

work to employ strategies that mitigate potential negative impacts on communities. 

Unfortunately, some of the discussion and conclusions on these topics, as presently 

worded, could be misconstrued or cause confusion about intended policy objectives, and 

potentially result in less housing affordability. Given the importance of the topic, the 

Department requests that the sections below be reconsidered. • The definition of 

“displacement” in the Glossary may be partially responsible for potential confusion. The 

definition appears to refer only to a process that “drives out” existing residents and 

businesses. It does not include the (much more common) process whereby lower income 

residents become unable to access properties in certain areas due to increasing housing 

prices (often referred to as “exclusionary displacement”). This limited definition influences 

the discussion of the process and strategies to respond. • There is an apparent disconnect 

between the evidence on gentrification presented in the Plan and some of the claims being 

made. The detailed study in the Environmental Justice Appendix found “no statistical 

significance” in the difference of demographic change occurring in transit-oriented areas of 

the SCAG region versus outside them. Despite this lack of evidence, the Plan often 

discusses new investment in transit-oriented communities as a cause for rising home prices 

and displacement (pgs. 3, 55, 163). This language needs to be carefully worded to avoid 

inadvertently undermining transit-oriented investment (such as transit infrastructure and 

housing) that is complementary to the Plan’s objectives.

The definition of displacement in the glossary has been updated to include the specific 

problem of housing inaccessibility to gentrifying areas for lower income residents. SCAG 

acknowledges the challenge of balancing the transit-oriented investment with the risk of 

gentrification and displacement of disadvantaged communities. However, gentrification 

can still occur without the conclusive identification of its cause. The discussion on page 55 

indicates that there is evidence that gentrification is occurring and indicates that lowincome communities near transit infrastructure may face displacement in the overall 

context of affordability but does not discuss a primary cause. The discussion on page 163 

indicates that growth patterns point to transit investment as a likely cause but as indicated 

in the Environmental Justice appendix, there is no statistical significance because current 

studies are inconclusive as to whether transit investment is definitively its cause. SCAG will 

be conducting future studies to monitor and study growth patterns in transit investment 

areas for further research on gentrification and displacement.

16155.02.2 • The Environmental Justice Appendix relies on a variety of indicators to evaluate various 

equity issues in relation to Plan objectives like growth in transit-oriented communities (jobshousing balance, median income, median rents, Hispanic population, etc.) We’d suggest 

adding some additional factors that are worthy of analysis and monitoring. These include 

cost burdens for renters and owners, transportation costs, the price of single-family homes 

versus condos and including Black and Asian households (in addition to Hispanic) in this 

metric.

SCAG has added additional information on the cost burden for renters and owners, along 

with impacts for African American and Asian households to enhance the 

gentrification/displacement analysis. Other suggested variables will be taken into account 

for future analysis.

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Submitted by City of Los Angeles - Department of City Planning Submittal 16155 Related Documents Link

16155.03 3. Provide greater clarity on how local jurisdictions are to determine SCS Consistency of a 

given project Increasingly, important areas of State land use and environmental policy are 

requiring a determination of “SCS consistency.” Examples include the recent CEQA 

streamlining efforts mentioned in the Plan but also Cap and Trade mitigation funding, 

Enhanced Infrastructure Finance Districts and, analyzing greenhouse gases for CEQA 

purposes. The ability for a local jurisdiction to be able to accurately and efficiently establish 

whether a project, plan or program is consistent with the SCS has therefore gained 

prominence. The current RTP/SCS is a high‐level planning document that sets out 

transportation policies for the region, but does not provide specific policies for local 

agencies to use in advancing land use strategies. To the limited extent SCS consistency is 

discussed in the Plan, is the statement that “lead agencies such as local jurisdictions have 

the sole discretion in determining a local project’s consistency with the 2016 RTP/SCS” (for 

example, pg. 65 and throughout the SCS Background Documentation Appendix). This 

statement, unfortunately, does not provide much direction or clarity as to how local 

jurisdictions, or anyone else, should evaluate consistency with the SCS. SCS consistency is 

an emerging area of state law without many precedents or interpretations. Other MPOs 

have provided guidance in their Plans, as well as separate consistency checklists, for their 

local jurisdictions. The current draft 2016 RTP/SCS offers insufficient information on which 

to base sound decisions. An unintended result is that projects, plans and programs in the 

SCAG region could be at a disadvantage with other regions. As an example, SB 375 

references project consistency (for Transit Priority Projects using CEQA streamlining) as 

whether or not the project matches the “general use designation, density, building 

intensity, and applicable policies specified for the project area in the SCS.” We believe there 

are several issues associated with the Plan that make this task very difficult for local 

jurisdictions. (see next comment)

Comment noted. SCAG acknowledges that SCS consistency is becoming a more frequent 

criteria in state law and state programs. SCAG maintains that local jurisdictions have the 

sole discretion in determining a local project's consistency with the 2016 RTP/SCS. That 

said, SCAG serves as resource to local jurisdictions to assist them in making their 

consistency determinations.

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Submitted by City of Los Angeles - Department of City Planning Submittal 16155 Related Documents Link

16155.04 1) In order for a local jurisdiction to claim SCS consistency, it should be shown that a project 

or plan is in line with the “applicable policies” mentioned in the Plan. While six Land Use 

Strategies are presented in Chapter 5, the Plan does not clearly identify local policies that 

could advance its Policy Goals. Policies can be inferred from the Plan’s text, but nowhere 

are they specifically identified or described. Although SB 375 does not empower SCAG to 

impose its land use strategies or policies on its member local jurisdictions, SCAG can 

suggest or recommend the sorts of local policies that would advance the six Land Use 

Strategies at the local level. This would be useful to the city in its effort to promote the 

RTP/SCS’s vision and benefit from the opportunities established under state law. As such, 

the utility of the 2016 RTP/SCS Land Use Strategies would be substantially improved by 

adding a discussion of “Supportive Local Policies” to the discussion of each in Ch. 5. 2) 

Within the 2016 RTP/SCS, two new concepts are introduced around the idea of creating 

“complete communities.” They are “Livable Corridors,” and “Neighborhood Mobility 

Areas.” The discussion of Livable Corridors beginning on page 74 (Chapter 5) is an example 

of insufficient policy guidance. It states that “The Livable Corridor Strategy specifically 

advises local jurisdictions to plan and zone for increased density at key nodes along the 

corridor and replacement of single‐story under‐performing strip retail with well‐designed 

higher density housing and employment centers.” (emphasis added) Similarly, the 

discussion of Neighborhood Mobility Areas that follows states that: “The Neighborhood 

Mobility Areas strategy represents a set of state and local policies to encourage the use of 

active and other non‐automotive modes of transportation, particularly for shorts trips in 

many suburban areas...” (emphasis added). Unfortunately, the Department does not see 

that any such advice is actually provided, nor are any state and local policies identified in 

the RTP/SCS. Further, there are no maps nor figures in the RTP/SCS that identify Livable 

Corridors or Neighborhood Mobility Areas. Without maps, the city cannot readily 

determine where Livable Corridors or Neighborhood Mobility Areas are located (or should 

be located) within its jurisdiction, limiting its ability to apply these strategies. Exhibits to 

illustrate the locations of Livable Corridors and Neighborhood Mobility Areas would be 

helpful.

Comment noted. Response to 1) Land use in the RTP/SCS is based on the five (5) guiding 

principles approved by the Regional Council on November 5, 2015. These guiding 

principles were utilized for the Policy Growth Forecast (PGF). The PGF envisions future 

regional growth that is coordinated with the transportation system improvements of the 

approved in the previous 2012 RTP/SCS, as well as anticipated new transportation projects 

planned by the region’s CTCs and transit providers. It also incorporates best practices for 

increasing transportation choices, reducing our dependence on personal automobiles, 

allowing future growth in walkable, mixed-use communities and in HQTAs, and further 

improving air quality. The guiding principles below served as the basis for developing the 

PGF: • Principle #1: The Draft PGF for the 2016 RTP/SCS shall be adopted by the Regional 

Council at the jurisdictional level, thus directly reflecting the population, household and 

employment growth projections derived from the local input and previously reviewed and 

approved by SCAG’s local jurisdictions. The PGF maintains these projected jurisdictional 

growth totals, meaning future growth is not reallocated from one local jurisdiction to 

another. • Principle #2: The Draft PGF at the Transportation Analysis Zone (TAZ) level is 

controlled to be within the density ranges of local general plans or input received from 

local jurisdictions in this most recent round of review. • Principle #3: For the purpose of 

determining consistency for CEQA, lead agencies such as local jurisdictions have the sole 

discretion in determining a local project's consistency with the 2016 RTP/SCS. • Principle 

#4: TAZ level data or any data at a geography smaller than the jurisdictional level is 

included in the Draft PGF only to conduct the required modeling analysis and is therefore, 

only advisory and non-binding because SCAG’s sub-jurisdictional forecasts are not to be 

adopted as part of the 2016 RTP/SCS. After SCAG’s adoption of the PGF at the 

jurisdictional level, the TAZ level data may be used by jurisdictions in local planning as it 

deems appropriate and there is no obligation by a jurisdiction to change its land use 

policies, General Plan, or regulations to be consistent with the RTP/SCS. SCAG staff plans 

to monitor the use of this data after the adoption of the RTP/SCS to encourage 

appropriate use. • Principle #5: SCAG staff continues to communicate with other agencies 

who use SCAG sub-jurisdictional level data to ensure that the “advisory & non-binding” 

nature of the dataset is appropriately maintained. SCAG established the PGF based on the 

guiding principles in order to provide maximum flexibility for the local jurisdictions. It is the 

direction of the Regional Council to maintain local land use authority. The six Land Use 

Strategies relate directly to the PGF principles and are meant to provide a foundation for 

local jurisdictions to implement the vision of the RTP/SCS. Response to 2) SCAG has revised 

the text of “Livable Corridors” and “Neighborhood Mobility Areas” to reflect utilization as 

“strategies”, not policies. With SB 375, SCAG is tasked with integrating land use and 

transportation. The land use policies listed in Chapter 5, under the “Our Strategies for 

Transportation and Land Use” section, are the foundational policies that guided the 

development of the RTP/SCS land use strategies. In order to encourage “complete 

communities” that integrate land use and transportation, SCAG introduced two new 

concepts called “Livable Corridors” and “Neighborhood Mobility Areas." These concepts 

are introduced to give local jurisdictions ideas for developing sustainably in other contexts 

besides dense urban High Quality Transit Areas (HQTAs). The Livable Corridors concept 

features land use strategies that are appropriate for lower density growth areas that are 

served by HQTA bus corridors. The Neighborhood Mobility Areas concept features low 

impact land use strategies and low-cost transportation solutions to replace vehicle miles 

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Submitted by City of Los Angeles - Department of City Planning Submittal 16155 Related Documents Link

with low GHG travel modes. SCAG’s intention is to assist local jurisdictions by providing a 

framework and allowing maximum flexibility in creating “complete communities”. SCAG 

will continue to work with the local jurisdictions that show interest in implementing the 

RTP/SCS land use policies by providing information and resources to support local planning 

activities, such as the Sustainability Planning Grant Program and the Active Transportation 

Program. Programs and policies at both the state and local level are in place that will assist 

local jurisdictions in creating “complete communities”, such as the Active Transportation 

Program at the state level, and, for example, the First-Last Mile Strategic Plan from Los 

Angeles County Metropolitan Authority (Metro).

16155.05 3) Although not explicit in the RTP/SCS, the City of Los Angeles understands the 2040 

“Forecasted Regional Development Types” maps” found in the Background Documentation 

Appendix (Exhibits 1-33) are to be used in determining whether a project is consistent with 

the SCS. There are 2012 (baseline) and 2040 (proposed plan) maps for each geographic 

subregion. A SCS consistency argument for a project should show that a project or plan is 

aligned with the general use category and density and intensity shown on the 2040 maps. 

Unfortunately, the Development Type maps for the City of Los Angeles (Exhibit 13 and 14) 

are presented at such a scale to make them largely illegible from a user’s perspective. It 

simply is not possible to make an accurate determination in what color (i.e. Development 

Type designation) a given site in the City is located within. As such, the City respectfully 

requests the following: a. The Development Type maps shown for the City of Los Angeles 

(and perhaps any other geography of a similar large scale) should be broken up into 

zoomed-in sub-regional quadrants, or at least be made available to local jurisdictions that 

request them. b. Development Type maps should contain additional information such as 

major streets and transit lines to help orient users. c. Even when the correct Development 

Type can be understood for a given parcel, it is unclear how exactly to interpret such 

information as to general use, density and intensity. There does not appear to be a guide 

that translates the three Development Types (Urban, Compact, Standard) into use 

categories or density and intensity ranges. As far as we can tell, there is only a paragraph 

description of each of these critical SCS designations (pg. 20 of the Plan). Through use of 

the Scenario Planning Model, Place Types are the foundation of the forecasted 

Development Types maps. Place Types do have uses, densities and intensities expressed in 

a usable manner in the Plan, however local jurisdictions don’t have ready access to the 

information. Therefore, background data on Development Type, including the underlying 

Place Type should be provided to local jurisdictions that request it. The information would 

remain advisory in nature, but could be helpful in supporting a SCS consistency analysis in 

many instances. In addition, more information to translate the three Development Type 

categories into use categories or density and intensity ranges should be included in the 

Plan. (cont.)

Comment noted. Response to 3)a. Comment noted. The Forecasted Development Types 

maps will be made available to local jurisdictions as requested. Response to 3)b. Comment 

noted. The SCAG region covers about 38,600 square miles, and including additional 

information on the maps will create maps unsuitable for viewing. Response to 3)c. 

Comment noted. A table has been provided that places Scenario Planning Model Place 

Types into Land Development Categories.

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Submitted by City of Los Angeles - Department of City Planning Submittal 16155 Related Documents Link

16155.06 (cont. from previous) d. It is unclear how gradations between each Development Type 

category should be treated (e.g. the orange color between Urban red and Compact yellow). 

The gradations effectively create five Development Type categories, two of which are 

completely undefined. 4) The footnote at the bottom of each Development Type map in 

the SCS Background Documentation Appendix (Exhibits 1-3) raises several questions and 

concerns. a. One sentence in the footnote says “Data at the TAZ level or at a geography 

smaller than the jurisdictional level are advisory only and non-binding, because SCAG subjurisdictional forecasts are not to be adopted as part of the 2016 RTP/SCS.” While the 

Department understands the meaning, this sentence could be read as meaning that the 

Development Type maps, which are based on the TAZ level data, should not be used as part 

of establishing SCS consistency. When combined with a lack of other direction in the Plan, 

the phrase may raise unnecessary confusion. b. Another sentence in the footnote says “For 

the purpose of determining consistency for California Environmental Quality Act (CEQA) 

streamlining, lead agencies have the sole discretion in determining a local project's 

consistency with the 2016 RTP/SCS.” This sentence should be broadened to include the 

increasingly diverse areas of state policy that references SCS consistency. 5) The 2016 

RTP/SCS Plan appears to use three different terms to refer to the same thing. The Plan uses 

the term “Development Category”, to refer to the Urban, Compact and Standard 

designations, while the SCS Background Documentation Appendix uses the terms 

“Development Type” on the maps and “Land Development Category.” This should be 

reconciled to avoid confusion. 6) To address many of these concerns, SCAG could create a 

“SCS Consistency” section of the plan. Key factors should include means to interpret 

consistency with Development Type maps, a list of key GHG-related policies, a list of 

relevant SCS EIR GHG mitigation measures, and quantitative analysis that a project does not 

conflict with the GHG reduction target with the county or region where relevant. Other 

metropolitan planning organizations have created “SCS Consistency Checklists” and other 

more helpful information to guide decision-makers.

Response to 3)d. Comment noted. The gradation between the colors of each Land 

Development Category (LDC) shown on the maps is meant to represent a range amongst 

the Place Types that fall within one use of the LDC. For example, the “Town”, “Village” and 

“Neighborhood” Place Types fall within the “Compact” LDC. Response to 4)a. and b. 

Comment noted. The 2016 RTP/SCS is the product of a bottom-up, iterative local input 

process. SCAG has actively sought consensus from our subregional partners on local SCS 

consistency determination for future funding and other opportunities consistent with the 

core principles specified in Chapter 4. It has been re-emphasized that the preferred 

scenario and corresponding forecast of population, household, and employment growth is 

adopted at the jurisdictional level as part of the 2016 RTP/SCS, and any corresponding subjurisdictional level data and/or maps is advisory only. There are certain State programs 

such as the Affordable Housing Sustainable Communities (AHSC) program administered by 

the Strategic Growth Council asks applicants to demonstrate how a specific project 

"supports implementation of an applicable SCS," and does not utilize the term 

"consistency." Response to 5) Comment noted. Documentation has been revised to avoid 

confusion. Response to 6) Comment noted.

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Submitted by City of Los Angeles - Department of Transportation Submittal 16178 Related Documents Link

16178.01 Regarding the Strategic Plan list, since the approval of the 2012 RTP, the City of Los Angeles 

has adopted significant mobility-related policy directives aimed at creating a safer and 

more sustainable City with convenient mobility choices for all users of the transportation 

system. Namely, Mobility Plan 2035, the Great Streets Initiative, Great Streets for Los 

Angeles - LADOT Strategic Plan, and the Vision Zero Initiative have been released or 

adopted since the last RTP cycle. Also, in April 2015, Mayor Eric Garcetti released the City's 

first ever sustainability plan - the Sustainable City pLAn. The Plan includes mobility and 

environmental targets including GHG reduction goals (60% reduction by 2035), VMT-percapita reduction goals (10% reduction by 2035) and mode share targets (50% of all trips by 

walk, bike or transit by 2035). Together with SCAG's continued leadership at the regional 

level, these local plans and initiatives will help achieve the goal of a truly sustainable 

transportation future. Working with Metro on the update of the Long Range Transportation 

Plan (last adopted in 2009), the City of Los Angeles has developed a comprehensive list of 

projects that include rail, transit, shared-use mobility, active transportation, first/last mile 

solutions, goods movement, and highway and freeway improvements. Collectively, these 

projects are expected to enhance safety, mobility and accessibility for all transportation 

users, while helping to achieve the goals of the Sustainable City pLAn. These projects 

should be included in the RTP Strategic Plan, pending further refinement and funding 

availability. Inclusion in the Strategic Plan does not obligate the City to implement the 

projects, but facilitates further consideration of the projects. The project descriptions will 

be provided to SCAG under separate cover for inclusion in the Strategic Plan.

Comment noted. SCAG has reviewed and incorporated the projects as part of the strategic 

portion of the Project List.

16178.02 Consistency with the SCS has recently been a key requirement, and will likely become more 

so, for proposed affordable housing and other projects to receive State funding. For 

example, the recent Affordable Housing & Sustainable Communities (AHSC) grants required 

consistency with the SCS. It is likely that in the future consistency with the SCS for funding 

opportunities will also apply to certain types of proposed transportation projects. 

Accordingly, the City requests that the RTP/SCS include language that states that SCS 

"consistency" for funding and other incentives will be determined using data approved by 

the local jurisdictions for such purposes. The objective of this comment is that only SCS 

data that the City has reviewed and approved shall be utilized. Inserting such language into 

the SCS is particularly important given the magnitude of funding likely to be available that is 

linked to consistency with the SCS. It is anticipated that billions of dollars in Cap and Trade 

funding will be available statewide over the next several years for programs and projects 

that are consistent with the SCS, pursuant to the goals of AB 32 and SB 375. In addition, 

other recent laws, including SB 628 pertaining to Enhanced Infrastructure Financing 

Districts (ElFDs), are also linked to implementation of the SCS. The City wishes to meet the 

threshold requirements and effectively compete for these types of funding programs and 

qualify for these incentives.

Comment noted. The 2016 RTP/SCS is the product of a bottom-up, iterative local input 

process. SCAG has actively sought consensus from our subregional partners on local SCS 

consistency determination for future funding and other opportunities consistent with the 

core principles specified in Chapter 4. It has been re-emphasized that the preferred 

scenario and corresponding forecast of population, household, and employment growth is 

adopted at the jurisdictional level as part of the 2016 RTP/SCS, and any corresponding subjurisdictional level data and/or maps is advisory only.

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Submitted by City of Los Angeles - Department of Transportation Submittal 16178 Related Documents Link

16178.03 The Scenario Planning Model of the SCS is based on modeling several datasets, including 

Tier Two Traffic Analysis Zone (TAZ) demographic data, and Tier Three Scenario Planning 

Zone (SPZ) land use place types. For the City, there are approximately 2,000 TAZs and 

25,000 SPZ place types (about a 1:12 ratio). Each of the 25,000 SPZs is assigned one of 35 

possible place types for modeling purposes. The City Planning staff has reviewed the 2,000 

TAZ dataset for the City's projected population, housing and employment through 2040, 

but has not reviewed or approved either the SPZ methodology or actual place type maps 

for the City. It should also be noted that the Tier 3 SPZ data and place type maps have not 

been reviewed by staff of SCAG's fifteen subregions. Therefore, the City requests that 

language substantially similar to the following be inserted into both the appropriate maps 

and text of the Background Documentation appendix of the SCS: "For purposes of 

qualifying for future funding opportunities and/or other incentive programs, advisory subjurisdictional data used to determine consistency with the Sustainable Communities 

Strategy should only be used at the discretion and with the approval of the local 

jurisdiction. Sub- jurisdictional data includes, but is not limited to, the Tier 2 Traffic Analysis 

Zone (TAZ) dataset and the Tier 3 Scenario Planning Zone (SPZ) data and maps."

Comment noted. The 2016 RTP/SCS is the product of a bottom-up, iterative local input 

process. SCAG has actively sought consensus from our subregional partners on local SCS 

consistency determination for future funding and other opportunities consistent with the 

core principles specified in Chapter 4. It has been re-emphasized that the preferred 

scenario and corresponding forecast of population, household, and employment growth is 

adopted at the jurisdictional level as part of the 2016 RTP/SCS, and any corresponding subjurisdictional level data and/or maps is advisory only.

16178.04 DIRECT the Department of Transportation to request that SCAG include the updated 

project cost estimate of $250 million for the Downtown LA Streetcar project (FTIP ID 

#LAOG901).

Comment noted. The FTIP projects included within the RTP/SCS Project List incorporates 

the adopted 2015 FTIP and Amendments 1 – 7, and 12. Regarding FTIP ID #LA0G901, as it 

currently stands the amount of $125,000,000 has been carried over to the 2017 FTIP. 

Please consult with Metro FTIP staff to make the necessary changes including project cost 

for inclusion as part of the 2017 FTIP.

Submitted by City of Los Angeles - Department of Transportation Submittal 16192 Related Documents Link

16192.01 Greetings, On behalf of the City of Los Angeles, I am submitting five project lists to be 

added to the Strategic Plan of the Project List Appendix of the 2016 RTP/SCS. The project 

lists, representing five Metro "subregions", are as follows: Arroyo Verdugo COG, Central 

Subregion, San Fernando Valley COG, South Bay Cities COG, and Westside Cities COG. It 

should be noted that, except for Central Subregion, the above referenced lists contain 

projects from multiple cities, including Los Angeles. If you have any questions or need 

additional information, please contact me. Thank you, Miles Mitchell

Comment noted. Edits have been made to incorporate this comment.

Submitted by City of Los Angeles - Department of Transportation Submittal 16215 Related Documents Link

16215.01 The first project (top row) on the attached Financially Constrained Project list, for the City 

of Los Angeles, should have an RTP ID # of LAF5317. This project is also on the FTIP list with 

an FTIP ID # of LAF5317. Thank you very much.

Comment noted. Changes have been made in the Plan.

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Submitted by City of Mission Viejo Submittal 16275 Related Documents Link

16275.01 The 2016 RTP/SCS incorporates a growth forecast for the City of Mission Viejo that the City 

of Mission Viejo has reviewed, corrected, and fully supports. Our review concludes that the 

2016-2040 RTP/SCS growth forecast accurately reflects the amount and distribution of 

population, households and employment at the citywide and traffic analysis zone levels for 

the City of Mission Viejo, from Year 2012 (Existing) through Year 2040. Further, the 2016-

2040 RTP/SCS growth forecast accurately reflects the amount and location of all residential 

and non-residential entitlements, development agreements, and projects  recently 

completed and constructed within the City of Mission Viejo during the plan timeframe. The 

City of Mission Viejo thus fully supports the 2016-2040 RTP/SCS growth forecast, and fully 

supports the adoption of this growth forecast at a geographic level no lower than the 

jurisdictional level.

Comment noted.

16275.02 The City of Mission Viejo supports the comments on the draft 2016 RTP/SCS and draft 

Program EIR, as outlined in the Orange County Transportation Authority's (OCTA) January 

11, 2016 comment letter and the Orange County Council of Government’s (OCCOG) January 

28, 2016 comment letter. These comments identify policy and technical issues that are of 

concern to Orange County, and the City of Mission Viejo respectfully requests that SCAG 

respond to the comments detailed in said referenced transmittals.

Comment noted.

Submitted by City of Montclair Submittal 16332 Related Documents Link

16332.01 We are pleased that Southern California Association of Governments (SCAG) is including 

the Foothill Gold Line from Glendora to Montclair in the Draft Regional Transportation 

Plan/Sustainable Communities Strategy (RTP/SCS) under the financially constrained plan. 

However, the RTP/SCS forecasts completion of the project in 2040, almost two decades 

beyond the current plan while also understating the project costs. The Foothill Gold Line is 

a critically needed link that will connect a dozen universities, the LA County Fairplex, and LA 

County with San Bernardino and Riverside Counties at the Montclair Transcenter. The 

Foothill Gold Line will alleviate traffic on one of the most heavily congested corridors which 

is expected to assume the majority of the population and employment growth in the 

coming decades. The Glendora to Montclair segment is estimated to achieve 18,300 daily 

boardings by reducing Vehicle Miles Traveled (VMT) by 111,000 and reduce emission 

burden levels resulting in beneficial effect on CO,TOG, Nox, PM10, and PM2.5 levels. The 

current forecast in the Draft RTP/SCS of completing the Foothill Gold Line in 2040 is too late 

and should be amended to complete this vitally needed project as soon as possible. No 

other rail project in Los Angeles County is as ready as this one. The project will be ready in 

2017 to break ground and SCAG should find ways to include innovative sources to fully fund 

the $1,216 million project sooner as they are doing with other unfunded rail projects.

The funding identified in the Draft 2016 RTP/SCS for the Foothill Gold Line Extension Phase 

2B is based upon innovative strategies that are not expected to be available in the near 

term. The earliest completion date for this project would be 2035 and the RTP/SCS has 

been adjusted accordingly. Should this project be advanced by Metro as it updates its Long 

Range Transportation Plan, the completion date can be adjusted through a future 2016 

RTP/SCS amendment at the request of Metro.

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Submitted by City of Monterey Park Submittal 16136 Related Documents Link

16136.01 I am writing on behalf of the City of Monterey Park to express our strong support for the 

continued inclusion of the SR-710 Freeway Tunnel Project in the Southern California 

Association of Governments (SCAG) 2016-2040 Regional Transportation Plan/Sustainable 

Communities Strategy (RTP/SCS). A freeway tunnel directly comports with several SCAG 

goals including reduction of time on the road, enhancement of economic opportunities and 

air quality improvements. The freeway tunnel has strong local support and is consistent 

with voter mandate and local plans. A recent poll shows 2-1 support for a tunnel, proving 

that a vocal minority is not representative of the broader community. Almost two-thirds 

(65.5%) of voters in the five cities that currently oppose the freeway tunnel also supported 

Measure R, which explicitly contained the freeway tunnel project. The tunnel, as you know, 

also was adopted in Metro’s Long Range Transportation Plan. Most importantly, the 

freeway tunnel would significantly improve air quality and reduce cancer risk for the 

majority of the study area. Unfortunately, lower income, minority communities near the 

freeway are more impacted by poor air quality than those in more affluent areas to the 

north. The SR-710 North Study Draft Environmental Impact Report shows that cities south 

of the freeway have existing Cancer Risk levels 20% to over 60% higher than their neighbors 

to the north. This disparity is clearly an unacceptable environmental injustice for the Los 

Angeles Region. A freeway tunnel also maximizes mobility and flow of traffic throughout 

the Los Angeles Region. Traffic must be moved from local streets back onto freeways where 

it was originally designed to go. A freeway tunnel solves this problem and reduces cutthrough traffic on neighborhood streets by 43% or 57,600 vehicles per day. It is critical that 

SCAG maintain support for the tunnel and sustain inclusion of the project in the 2016-2040 

RTP/SCS. Completion of the freeway is vital to the health and safety of thousands of Los 

Angeles area residents. We are confident that SCAG, along with the City of Monterey Park, 

will remain steadfast in support for the tunnel as the best alternative for completion of the 

710 freeway.

Comment Noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description and associated modeling analysis.

Submitted by City of Moreno Valley Submittal 16060 Related Documents

16060.01 How much oversight does SCAG maintain on the identified Regional Trail network? The 

specific example would be the Santa Ana River Trail (SART). Certain agencies may not 

implement the minimum design that is envisioned in the Regional context (diverting the 

trail to the arterial street network, providing minimal width / no amenities, and not 

preserving right of way for the complete network). There needs to be unity on how the 

final facility will operate. Additionally, there needs to be consistent maintenance 

throughout the trail network to maintain safety and proper operation of the regional trail. 

There should be an underlying guiding document that would address these issues.

Comment noted. Regional trails, such as the 115 mile Santa Ana River Trail would be 

implemented by local agencies where the trail is within their jurisdiction. Minimum 

standards/requirements and signage are established by the California Highway Design 

Manual (Chapter 1000) and California Manual for Uniform Traffic Control Devices (Chapter 

9) respectively. Maintenance jurisdiction would also be the local jurisdiction's 

responsibility. An underlying guiding document may be considered as implementation 

plans are developed.

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Submitted by City of Moreno Valley Submittal 16061 Related Documents

16061.01 My concern is regarding safety on the I 60 corridor between the city of Moreno Valley and 

the city of Beaumont, commonly referred to as the badlands. The drive into the badlands 

even though it is getting a truck climbing lane is still remain dangerous and congested. 

When is this gap expected to be improved to it's ultimate condition?

Comment noted. Safety of traveling public on our highway system is of utmost importance 

and accordingly the 2016 RTP/SCS identifies this issue, in general, as a high priority for the 

region. We do not disagree with your observation that certain segments of I-60 may be 

considered dangerous and congested by the public and more needs to be done. Caltrans 

District 8, the agency overseeing the state highway system within the counties of Riverside 

and San Bernardino has prepared a transportation concept report (TCR) for SR-60 

forecasting conceptual improvements for future needs along the corridor. This may 

address some of your concerns. But, it takes some lead time between conceptualizing a 

solution to a problem to finding the funds needed to implement the solution and actual 

implementation. SCAG will work with District 8 to look at this issue in our future planning 

efforts.

Submitted by City of Rancho Mirage Submittal 16174 Related Documents Link

16174.01 January 21, 2016 Via Email Draft 2016 RTP/SCS Comments Attn: Courtney Aguirre Southern 

California Association of Governments 818 W. 7th Street, 12th Floor Los Angeles, CA 90017 

Re: Draft 2016 RTP/SCS Comments Dear Ms. Aguirre: Thank you for providing us with the 

opportunity to review and comment on the Draft 2016 RTP-SCS. It is quite clear that much 

time, effort and thought went into the development of said document, and we recognize 

the challenges that you face in trying to address current and future transportation needs 

within such a vast and diverse region. The purpose of this letter is to reinforce some of the 

ideologies which are presented in the Plan (Draft 2016 RTP-SCS), and to promote a more 

targeted approach to transportation planning in the Coachella Valley. It is stated multiple 

times that this Plan seeks to “place a priority on investing in the transportation system that 

we already have,” and “that deferring maintenance of infrastructure leads to costlier 

repairs in the future.” We here at the City of Rancho Mirage also embrace this philosophy. 

There are many miles of dilapidated streets and sidewalks throughout the Coachella Valley 

that are in desperate need of repair. A targeted local approach to transportation 

investment would be much more beneficial to the Coachella Valley than a new large scale 

regional project (CV-Link), which would only add to the collection of infrastructure that 

requires ongoing maintenance. Furthermore, by dedicating such large investments to the 

CV-Link project, in lieu of addressing current deficiencies, existing disparities throughout 

our region will be intensified, leading to continued deterioration of the system and costlier 

future repairs. An incremental approach to the repair and maintenance of the current 

transportation network will do more to strengthen our region than would a large scale 

project which will be used primarily for recreational purposes. Thank you again for the 

opportunity to comment on the Draft 2016 RTP-SCS; we appreciate the chance to be 

included in the region’s visioning and to share our concerns. Sincerely, Jeremy Gleim 

Planner City of Rancho Mirage CC: Randal K. Bynder, City Manager Isaiah Hagerman, 

Director of Administrative Services

Comment noted. Though the 2016 RTP/SCS is grounded in a system management 

approach, which prioritizes protecting our previous investments and getting the most out 

of every component of our system, the Plan is also grounded in a multimodal approach 

towards addressing congestion. This multimodal approach prioritizes providing people 

with more options for getting around the region, including transit, bicycling, and walking. 

Essentially, the Plan aims to reduce single occupancy vehicle (SOV) demand on our 

highways and local arterials so that the region can experience reduced congestion and 

other negative impacts (e.g., poor air quality). The specific project referenced, the CV-Link 

project, was prioritized at the county-level and will provide people with alternatives to 

driving.

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Submitted by City of Riverside Submittal 16069 Related Documents

16069.01 corridor from 15 freeway to 241 freeway is needed to serve region. Comment noted. The project listed as RTP ID# S3160001 in the Strategic Plan portion of 

the Project List is intended to serve this purpose. SCAG will consider including this project 

in the constrained plan in the future upon identification of needed funding and 

concurrence of implementing agencies.

Submitted by City of Riverside Submittal 16246 Related Documents

16246.01 The 2016 Draft Plan recognizes the changing region and places emphasis that SCAG 

encompasses one of the biggest and most influential metropolitan regions in the world. 

Consequently it is imperative that the regional transportation system drafted in the plan 

promotes an equitable plan for economic growth and sustainability. As one of the six 

counties in SCAG’s region, Riverside and San Bernardino have not seen as much support or 

funds compared to Orange and Los Angeles County. The metropolitan statistical area 

population of the Inland Empire is over 4.2 million people and is the 13th largest 

metropolitan area in the United States. It is necessary for SCAG to focus on the needs of 

the Inland Empire rather than continuously promote the needs of Los Angeles County. In 

recent years there have been informal discussions and the idea of formalizing an 

Association to represent the needs of the communities in the IE. It is essential to recognize 

the Inland Empire as we work towards preserving and expanding a sustainable regional 

transportation system.

Comment noted.

Submitted by City of San Clemente Submittal 16311 Related Documents Link

16311.01 The City of San Clemente concurs with the comments SCAG will receive from the Orange 

County Council of Governments (OCCOG) and the Orange County Transportation Authority 

(OCTA). The City requests that SCAG respond to all of the comments detailed in the OCCOG 

and OCTA letters and to act upon any changes advocated by OCCOG, of which the City is a 

member agency.

Comment noted.

16311.02 Overall, the City of San Clemente supports the 2016-2040 RTP/SCS growth forecast and the 

adoption of the growth forecast at a geographic level no lower than the jurisdictional level. 

The City of San Clemente supports The Plan since the growth forecast accurately reflects 

Orange County’s Projections dataset. The Plan growth forecast reflects entitlements, 

development agreements, and projects recently completed or under construction in 

Orange County. The City of San Clemente appreciates the ongoing coordination between 

SCAG and the Center for Demographic Research (CDR) at California State University 

Fullerton on behalf of all Orange County jurisdictions. The Orange County Projections have 

been used by the Orange County Transportation Authority (OCTA) in the development of its 

Orange County Long-Range Transportation Plan demonstrating that Orange County has 

integrated transportation and land use planning for decades.

Comment noted.

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Submitted by City of San Clemente Submittal 16311 Related Documents Link

16311.03 Language throughout the draft 2016 RTP/SCS and the associated appendices has a 

tendency to be leading and dramatic in its emphasis of certain key issues such as active 

transportation and public health. While these issues are important, it is recommended that 

the document utilize a more unbiased, objective tone. For example, the City of San 

Clemente recommends the removal of "Our Vision” and "Our Overarching Strategy” from 

the Executive Summary of the document. These two sections are highly speculative and are 

not necessary to the document. "Our Vision” and "Our Overarching Strategy” go above and 

beyond the requirements of the RTP. Additional examples of overly emphatic language are 

outlined in Attachment 1.

Comment noted. We believe this section is important in providing the necessary 

background and context for the development of the rest of the Plan.

16311.04 The Draft RTP assumes that almost no new growth will occur within 500 feet of a freeway 

or busy transportation corridor. The Draft RTP states that a “buffer” is consistent with the 

California Air Resources Board’s 2005 advisory guidance that housing be discouraged within 

500 feet of high volume roadways such as freeways. It is important to note that CARB’s 

guidance is not a prohibition of development near high-volume roadways; nevertheless, 

SCAG’s “buffer” strategy eradicates growth in these areas that are otherwise rich in 

connections to jobs, retail and housing accessible by many transportation modes. 

Furthermore, the proposed “buffer” does not reflect the availability of mitigation measures 

to address near-roadway emissions that remain despite a dramatic reduction of diesel 

emissions in the last decade. At best, this strategy is a short-term response and problematic 

because it prevents the kind of density and proximity between land uses that actually 

reduce trips and associated VMT. As vehicle engines and fuels become cleaner, the “buffer” 

strategy will become obsolete yet will leave behind a legacy of inefficient land use patterns. 

Moreover, throughout the SCAG Region, the prevailing existing land use patterns include 

residential and sensitive receptor uses within 500 feet of a major transportation corridor. In 

many cases, these areas demonstrate compact development form and serve as affordable 

housing. Removing this massive portion of land from availability for use is premature and 

counter to the overarching principles of SB375 to locate housing near job centers and 

previously urbanized areas.

Comment noted. The Draft RTP/SCS does not assume new growth will be prohibited within 

500 feet of a freeway or busy roadway. Region-wide, projected growth within 500 feet of a 

freeway or busy roadway reflects local input data. The Draft RTP/SCS encourages local 

jurisdictions to establish their own policies to direct growth outside these areas based on 

factors covered in the Appendix: Environmental Justice. The use of the word “buffer” has 

been omitted from the Plan. However, SCAG will continue to utilize the advisory 

recommendation from ARB’s 2005 Air Quality and Land Use Manual to avoid siting new 

sensitive land uses within 500 feet of a freeway or urban roads with 100,000 vehicles per 

day.

16311.05 There needs to be consistency throughout all the documents regarding the 500 foot 

“buffer”: • The word “buffer” should not be used. • Clarify the amount of distance (the 

documents have various ranges from 500 feet to 1,000 feet) • Clarification on where 

distance is measured from (e.g. centerline, edge of roadway, edge of right of way) • Types 

of transportation corridors being identified (e.g. freeways, high quality transit corridors, 

high volume corridors, rail etc.) • Clarify that the emphasis should be on mitigation, not on 

discouraging development. o Resolve the conflict with discouraging development within 

500 feet of transportation corridors and regional goals for emission reductions. With 

reductions in emissions and fleet changes over time, it will be unnecessary and 

counterproductive to use this mitigation approach.

• Comment noted. The use of the word “buffer” has been omitted from the Plan. 

However, SCAG will continue to utilize the advisory recommendation from ARB’s 2005 Air 

Quality and Land Use Manual to avoid siting new sensitive land uses within 500 feet of a 

freeway or urban roads with 100,000 vehicles per day. • Comment noted. Changes have 

been made where appropriate. • Comment noted. The distance measured is edge of 

roadway. • Comment noted. The transportation corridor being identified is a freeway. • 

Comment noted. The RTP/SCS does not contain a policy that prohibits development within 

these areas. It encourages local jurisdictions to establish their own policies to limit growth 

in these areas based on factors covered in the Appendix: Environmental Justice – the 

emphasis is on mitigation.

16311.06 Throughout the documents, specific examples of technology are identified. It should be 

noted that these are only examples and that future technologies should not be ignored or 

excluded from meeting the goals of the RTP/SCS. This will allow the document, including 

mitigation measures, to be more flexible.

Comment noted. SCAG’s policies are technology neutral with regard to supporting zero 

and/or near-zero emissions vehicles. SCAG will continue to support natural gas fleet 

vehicles by hosting and administering the Southern California Clean Cities Coalition. In 

addition, SCAG communicates with Hydrogen Fuel Cell industry partners to exchange 

information and knowledge.

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Submitted by City of San Clemente Submittal 16311 Related Documents Link

16311.07 a. Under plan sections of LIVABLE CORRIDORS, NEIGHBORHOOD MOBILITY AREAS, 

LOOKING AHEAD, and “Encouraging Active Transportation for Short Trips”, include 

roundabouts and Intersection Control Evaluations similar to Caltrans Directive 13-02. Under 

Livable Corridors and neighborhood mobility areas- Change graphics to replace traffic signal 

with a modern day roundabout. Refer to the following resources: • Alternative 

Intersections/Interchanges: Informational Report (AIIR) 

http://www.fhwa.dot.gov/publications/research/safety/09060/ • FHWA Roundabout 

Website (http://safety.fhwa.dot.gov/intersection/roundabouts/) • Roundabouts: An 

Informational Guide, Second Edition (NCHRP Report 672) (.pdf file) 

http://onlinepubs.trb.org/onlinepubs/nchrp/nchrp_rpt_672.pdf

Comment noted. Roundabouts as treatments are increasing in use along low speed streets 

throughout California, such as in Long Beach, La Jolla and Pasadena (which also includes 

stop signs). Roundabouts have been added to the list of complete streets treatments for 

Neighborhood Mobility Areas.

16311.08 b. To address all the goals mentioned in the plan, the plan should include a strategy to 

replace traffic signals with modern day roundabouts where feasible. This one action would 

do more to further the principal goals mentioned in this Plan more than any other strategy 

mentioned.

Comment Noted. SCAG supports the use of roundabouts in Southern California where 

applicable and appropriate. SCAG has actually hosted a Roundabouts session as part of the 

Toolbox Tuesdays series. Documentation can be found at 

http://sustain.scag.ca.gov/Pages/Online-Training-Materials.aspx

16311.09 c. Under MOBILITY INNOVATIONS - include in the white paper the analysis and benefits of 

replacing traffic signals and all way stops with roundabouts.

Comment Noted. SCAG has supported the use of roundabouts in Southern California by 

hosting a Roundabouts session as part of the Toolbox Tuesdays series. Documentation can 

be found at http://sustain.scag.ca.gov/Pages/Online-Training-Materials.aspx

16311.10 d. Include Roundabout Intersection Evaluation projects in the project list throughout SCAGs 

communities.

Comment Noted. Most of the projects featured in the Plan's Project List Appendix were 

provided by the six County Transportation Commissions (CTCs), in which decisions to 

modify and/or add projects must come through the CTCs. However, SCAG does support 

the use of roundabouts in Southern California where applicable and appropriate. SCAG has 

actually hosted a Roundabouts session as part of the Toolbox Tuesdays series. 

Documentation can be found at http://sustain.scag.ca.gov/Pages/Online-TrainingMaterials.aspx

Submitted by City of San Gabriel Submittal 16342 Related Documents Link

16342.01 It's critical that SCAG maintain support for the tunnel and sustain inclusion of the project in 

the 2016-2040 RTP. Completion of the freeway is vital to the health and safety of 

thousands of Los Angeles area residents. On behalf of the City of San Gabriel, I am 

confident that SCAG will remain steadfast in support for the tunnel as the best alternative 

for completion of the 710 freeway.

Comment noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description and associated modeling analysis.

Submitted by City of Santa Clarita Submittal 16334 Related Documents Link

16334.01 High Quality Transit Areas Exhibit 5.1 in the draft RTP/SCS document identifies High Quality 

Transit Areas (HQTA) within the SCAG region. In the 2012 RTP/SCS, three HQTAs were 

identified in Santa Clarita. These areas corresponded to the three Metrolink stations 

located within the City. Exhibit 5.1 in the draft RTP/SCS document appears to have 

downgraded the three HQTAs in the City to “Rail Stations.” It is unclear if these rail stations 

are considered HQTAs by SCAG. If they are not, the City recommends attaching the HQTA 

designation to each of the three Metrolink stations located within the City of Santa Clarita.

Rail stations are considered major transit stops and are included in the definition of HQTAs 

(see RTP/SCS Glossary definition of HQTA). Exhibit 5.1 has been clarified.

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Submitted by City of Santa Clarita Submittal 16334 Related Documents Link

16334.02 As one of the communities directly impacted by the California High-Speed Rail Authority’s 

(CHSRA) proposed project, the City of Santa Clarita will continue to closely monitor the 

progress of the overall project and will actively participate in the environmental review 

process for the Palmdale to Burbank section. We recognize that SCAG is supportive of 

Phase I of the proposed High-Speed Rail project, primarily predicated on the Memorandum 

of Understanding (MOU) in which a $1 billion investment is committed to local rail 

improvements within Southern California. Inasmuch as there is a lack of agreement among 

SCAG’s membership regarding the proposed High-Speed Rail project, the City of Santa 

Clarita strongly recommends the inclusion of clarifying language within the 2016 RTP/SCS. 

In recognition of concerns by some communities in the SCAG Region, Transportation 

Committee Chairman Alan Wapner clarified the basis upon which SCAG is supporting the 

CHSRA project during remarks he made at the December 3, 2015, Regional Council 

meeting. In essence, Mr. Wapner reiterated that SCAG’s support for the project is based 

upon the commitment contained within the MOU for the expenditure of $1 billion on local 

rail improvements. We believe that incorporating a statement reflecting Chairman 

Wapner’s clarifying comments would be appropriate. Mr. Wapner stated to the Regional 

Council, “So once again, I want to remind you that what we are voting on is the inclusion of 

the portion that falls within the SCAG region in return for the CHSRA’s commitment to the 

expenditure of $1 billion on local rail improvements, which is extremely important to us 

here in Southern California. And the draft plan includes only support for Phase 1 of the highspeed rail project.”

Comment noted. The commitment to the $1 billion in regional investments as identified in 

the Southern California High-Speed Rail MOU is discussed in detail in the Passenger Rail 

section of Chapter 5 of the 2016 RTP/SCS. SCAG and the other Southern California 

agencies who are signatories to the MOU are working to advance the MOU projects and 

obtain funding from the California High-Speed Rail Authority to deliver these "bookend" 

projects.

16334.03 The City of Santa Clarita deeply appreciates SCAG staff working with City staff to accurately 

refine the population numbers contained within the Draft RTP/SCS. The City of Santa Clarita 

completed significant annexations in 2012 that substantially increased the City’s population 

by well over 10 percent. We are pleased to see that the population numbers contained 

within the Draft RTP/SCS are consistent with the completed annexations and future City 

growth forecasts. * Please refer to table in letter for specific population estimates* The City 

of Santa Clarita anticipates the occurrence of annexations between the current date and 

2040. Because the nature and extent of these annexations is unknown at this time, it is not 

possible to estimate how these future annexations will impact the City’s population. The 

City will continue to coordinate with SCAG regarding changes to population data as future 

RTP/SCS cycles occur.

Comments noted. SCAG will continue to work with the City of Santa Clarita to update its 

local growth forecast in future RTP/SCSs.

16334.04 Exhibit 5.4 of the draft RTP/SCS document identifies High Occupancy Vehicle (HOV) Lane 

projects throughout the SCAG region. One of the HOV Lane projects is identified within the 

Santa Clarita Valley. If the HOV Lane project within the Santa Clarita Valley is considered for 

change to a High Occupancy Toll (HOT) Lane project, the City strongly recommends that 

extensive additional public outreach and inter-agency coordination be conducted by SCAG 

and/or any responsible agency to ensure that the appropriate type of project is ultimately 

identified. Currently, there is not local consensus on whether a HOT Lane project is 

appropriate or acceptable in our community.

Comment noted. The Plan includes the indicated segment of I-5 in the Santa Clarita Valley 

as HOV lanes in Exhibit 5.4. Please see Exhibit 8 in the Highways and Arterials Appendix for 

the regional express lane network included in the Plan, which does not include this section 

of I-5 within the Santa Clarita Valley.

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Submitted by City of Santa Paula Submittal 16197 Related Documents

16197.01 Looking this over for the City of Santa Paula - just curious, on page 172, Table 9.1, under 

Ventura County, the "Santa Paula Branch Line" is referenced. I'm having trouble finding 

more information on what that project is, exactly. Is it part of the High Speed Rail project? 

Or XpressWest?

Comment noted. The Santa Paula Branch Line is a potential future passenger rail corridor 

in Ventura County connecting the East Ventura Metrolink station with Los Angeles County, 

roughly following SR 126 through Fillmore and Santa Paula. It is an unfunded strategic plan 

project (RTP ID S512002) submitted by the Ventura County Transportation Commission.

Submitted by City of South Pasadena Submittal 16214 Related Documents Link

16214.01 The City of South Pasadena (City) appreciates the opportunity to review and comment on 

the Southern California Association of Governments (SCAG) Draft 2016 Regional 

Transportation Plan and Sustainable Communities Strategy (RTP/SCS); and Draft Program 

Environmental Impact Report (SCH#2015031035, PEIR). As a member of the 5-Cities 

Alliance (Glendale, La Canada Flintridge, Pasadena, Sierra Madre, and South Pasadena), the 

City adopts the comments provided in the letter submitted by Shute, Mihaly, and 

Weinberger, LLP on behalf of the 5-Cities Alliance regarding the SC AG Draft 2016 RTP/SCS 

and PEIR. The City provides the following additional comments, and requests that SCAG 

make clear in its Final 2016 RTP/SCS and PEIR that the State Route 710 Tunnel Alternative 

(SR-710 Tunnel) has been excluded from the list of constrained projects. While the 

longstanding SR-710 debate spans decades, in the four years since SCAG last developed an 

RTP/SCS, actions by the Legislature and other agencies now hasten an end to the 

controversy and point SCAG and the corridor communities toward a series of constructive 

and non-harmful transportation improvements.

Comment noted. The 710 project is included in the voter-approved Measure R sales tax 

measure and in Metro's Long Range Transportation Plan, as well as in previous SCAG RTPs. 

SCAG understands that a project specific environmental analysis is underway by the lead 

agency, which will consider project impacts including environmental and traffic and 

mobility impacts, and identify mitigation measures as required. Upon the completion of 

this effort and selection of a preferred alternative by Metro, SCAG will work with Metro to 

amend the RTP as necessary to update the project description and associated modeling 

analysis. Regarding financial constraint, SCAG’s analysis and documentation of reasonably 

available sources demonstrates consistency with federal requirements. The full text of the 

federal requirements can be found in 23 CFR 450.322. The applicable federal regulations 

clearly indicate an RTP meets the financial constraint requirement by including “sufficient 

financial information for demonstrating that projects” in the plan “can be implemented 

using committed, available, or reasonably available revenue sources, with reasonable 

assurance that the federally supported transportation system is being adequately 

operated and maintained.” The proposed project cost of $5.6 billion represents the worst 

case scenario for project cost as a place holder for the project. Actual cost associated with 

the LPA will be reflected in the future RTP/SCS once the LPA is identified.

16214.02 Below, the City reiterates the comments that it made during the 2008 and 2012 RTP/SCS 

comment periods regarding the lack of “committed, available, or reasonably available” 

funding for freeway projects; and the adverse air quality impacts associated with the 

inclusion of the SR- 710 freeway in the RTP/SCS, jeopardizing the Clean Air Act (CAA) 

localized conformity in the San Gabriel Valley. The City also summarizes developments in 

the intervening four years that reinforce the City's 2008 and 2012 comments, and remove 

any remaining doubt that the SR-710 Tunnel lacks funds and threatens localized CAA 

nonconformity. The City next challenges SCAG's assertion that the alignment is "to be 

determined," establishing from the draft RTP/SCS and PEIR that the true project proposed 

by SCAG remains the SR-710 Tunnel. The City then details its comments on SCAG's air 

quality analysis, and concludes with a solution that will work for SCAG and the corridor 

communities: developing a "Beyond the 710 series of corridor improvements.

Comment noted. SCAG’s analysis and documentation of reasonably available sources 

demonstrates consistency with federal requirements. The full text of the federal 

requirements can be found in 23 CFR 450.322. The applicable federal regulations clearly 

indicate an RTP meets the financial constraint requirement by including “sufficient 

financial information for demonstrating that projects” in the plan “can be implemented 

using committed, available, or reasonably available revenue sources, with reasonable 

assurance that the federally supported transportation system is being adequately 

operated and maintained.” Under the U.S. Department of Transportation Metropolitan 

Planning regulations and the EPA’s Transportation Conformity regulations, the 2016 

RTP/SCS is required to pass the following four conformity tests in order to demonstrate 

transportation conformity: 1) Regional Emissions, 2) Timely Implementation of 

Transportation Control Measures (TCMs), 3) Financial Constraint, and 4) Interagency 

Consultation and Public Involvement. The Regional Council adopts the initial 

transportation conformity determination, while FHWA/Federal Transit Administration 

(FTA) approves the final transportation conformity determination for the 2016 RTP/SCS. As 

documented in the Transportation Conformity Appendix, the 2016 RTP/SCS meets all 

federal transportation conformity requirements and demonstrates transportation 

conformity. The findings associated with the conformity tests are described in detail in the 

Transportation Conformity Appendix.

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Submitted by City of South Pasadena Submittal 16214 Related Documents Link

16214.03 The SR-710 Tunnel Should Be Removed from the Constrained List The following 

developments establish that it is unrealistic -- legally, economically, and environmentally -- 

to expect that an SR-710 Tunnel would ever be funded or constructed. For these reasons 

SCAG should remove the tunnel from its constrained list in the Final RTP/SCS and PEIR, and 

invest the region's limited financial resources in projects that have earned enthusiastic 

community support. Within the past four years the City’s ability to veto any freeway 

construction within its jurisdiction has been restored through the Legislature’s repeal of 

Streets and Highway Code section 100.4 and its restoration of rights under Streets and 

Highways Code section 100.2. In addition, enactment of Government Code section 54237.8 

in 2013 eliminated any further consideration of a surface freeway within the SR-710 North 

Draft Environmental Impact Report/Environmental Impact Statement (EIR/EIS). The State's 

commitment terminating the surface freeway has been confirmed in the May 13, 2015 

judgment dismissing City of South Pasadena v. Slater, United States District Court (U.S.D.C.) 

no. CV-98-6996-DP.

Comment noted. Regarding financial constraint, SCAG’s analysis and documentation of 

reasonably available sources demonstrates consistency with federal requirements. The full 

text of the federal requirements can be found in 23 CFR 450.322. The applicable federal 

regulations clearly indicate an RTP meets the financial constraint requirement by including 

“sufficient financial information for demonstrating that projects” in the plan “can be 

implemented using committed, available, or reasonably available revenue sources, with 

reasonable assurance that the federally supported transportation system is being 

adequately operated and maintained.”

16214.04 The formal opposition of the three principal cities (Los Angeles, Pasadena, and South 

Pasadena) through which the SR-710 Tunnel would course precludes its lawful 

construction. Indeed, Caltrans has acknowledged that the SR-710 tunnel cannot be 

constructed without “modifications to freeway agreements from Alhambra, Los Angeles, 

South Pasadena, and Pasadena.” (Caltrans Draft EIR/EIS p. 2-113) Freeway agreements are 

required by Caltrans regulations whether or not city streets are closed. (Streets and 

Highways Code, §100.2; Caltrans Project Development Procedures Manual, p. 24-4; City of 

South Pasadena v. Department of Transportation (1994) 29 Cal. App. 4th 1280, 1284.) By 

formal actions the City Councils and Mayors of Los Angeles, Pasadena, and South Pasadena 

have explicitly opposed construction of the SR-710 North Tunnel Alternative. (Los Angeles 

Resolution 12-0002-S82 of August 28, 2012; Pasadena Motion of April 13, 2015; and South 

Pasadena Resolution 7420 of July 15, 2015.) Moreover, the SR-710 Tunnel cannot be 

advanced as “closing the 710 gap”, as the Draft RTP/SCS signifies at page 37 of Appendix B; 

nor can the wishbone construction in Pasadena be described, as the Caltrans Draft EIR/EIS 

attempted at page 1-5, as “[e]xisting SR-710.” By order of the United States District Court 

for the Central District of California, the wishbone construction was allowed in 1976 as an 

exception to the 1973 injunction as a component of the I-210 interchange, sponsored by 

the 1-210 contract. The U.S.D.C. opinion records that “only the southern portion of the 

Long Beach Freeway has been completed and now terminates at Valley Boulevard.” (City of 

South Pasadena v. Volpe (C.D. Cal. 1976) 417 F. Supp. 854, 858.)

Comment noted. The project with RTP ID 1M0101 was submitted by Los Angeles County 

Metro with the following project description, "SR-710 North Project Study Alternatives 

(Alignment TBD).” Requests to modify projects included within the RTP/SCS must come 

directly from the County Transportation Commissions, in this case, Metro.The Project List 

entry for the 710 North Project is the approved project description in the adopted Federal 

Transportation Improvement Program (FTIP).

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Submitted by City of South Pasadena Submittal 16214 Related Documents Link

16214.05 Only $740 million of Los Angeles County Measure R funds remain for construction of a San 

Gabriel Valley transportation project. These Measure R funds are not specifically 

designated for the SR-710 Tunnel, as the Second District Court of Appeal found when it 

denied the claims of the Cities of South Pasadena and La Canada Flintridge that the Los 

Angeles County Metropolitan Transportation Authority (Metro) had pre-determined 

selection of the SR-710 Tunnel in violation of the California Environmental Quality Act 

(CEQA). In its trial and appellate briefs, Metro represented that "Measure R ... does not 

commit Metro to any projects," and that "if a 710 Tunnel is not pursued ... the funds 

‘earmarked” for a possible tunnel can be applied to other projects or programs." The 

appellate court ruled that, notwithstanding the inclusion of the SR-710 tunnel in the 2008 

RTP and in Measure R, "[Metro] did not promise the public a 710 tunnel. Measure R 

literature includes the 1-710 North Gap Closure (Tunnel) in a list of ‘Proposed Projects and 

Programs.’ (Italics added.) Ordinance Section 11, paragraph (a) discloses that [Metro] ‘may 

amend this Ordinance, including Attachment A [the expenditure plan] ... for any purpose.’” 

(City of South Pasadena, City of La Canada Flintridge v. Los Angeles County Metropolitan 

Transportation Authority; California Department of Transportation RPI) (2011) 2d Civil No. 

B221118, unpublished opinion.)1 On August 20, 2015 San Gabriel Valley Council of 

Governments’ (SGVCOG) Governing Board voted to omit the SR-710 Tunnel project from its 

Mobility Matrix Transportation Project Priority List. This momentous change reflects the 

SGVCOG’s realization that the SR-710 Tunnel project poses a significant drain on future 

transportation funding in the region. Similarly, the Los Angeles County Metropolitan 

Transportation Authority (Metro) has omitted the SR-710 from the Subregional Stakeholder 

Draft Project Priorities list for the potential 2016 sales tax measure. As SCAG moves forward 

finalizing its Draft 2016 RTP/SCS, SCAG should replace the controversial SR-710 Tunnel with 

a more financially responsible and sustainable transportation solution.

Comment noted. RTP ID 1M0101 includes the following project description, "SR-710 North 

Project Study Alternatives (Alignment TBD)" and includes the following footnote, "This 

project is currently pending environmental review. As with other projects included within 

the Project List, when the SR-710 North Study EIR/EIS process is complete, the 2016 

RTP/SCS will be updated to reflect the Locally Preferred Alternative (LPA) as identified in 

the final environmental document."

16214.06 In sum, beyond the SR-710 Tunnel's legal infeasibility, the funds necessary to design and 

build the SR-710 Tunnel have not been identified, let alone committed. Continued inclusion 

of the SR-710 Tunnel fails to meet the federal requirement that any project listed as fiscally 

constrained must establish that funds for it are “committed, available, or reasonably 

available.” (23 C.F.R. §450.104.) For these reasons the project cannot remain on the 

constrained list of RTP/SCS projects.

Comment noted. Regarding financial constraint, SCAG’s analysis and documentation of 

reasonably available sources demonstrates consistency with federal requirements. The full 

text of the federal requirements can be found in 23 CFR 450.322. The applicable federal 

regulations clearly indicate an RTP meets the financial constraint requirement by including 

“sufficient financial information for demonstrating that projects” in the plan “can be 

implemented using committed, available, or reasonably available revenue sources, with 

reasonable assurance that the federally supported transportation system is being 

adequately operated and maintained.”

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holdID Comment Response 

Submitted by City of South Pasadena Submittal 16214 Related Documents Link

16214.07.1 Although the RTP/SCS Claims to be SR-710 Alternative Neutral, It and the PEIR Repeatedly 

Identify the Project as the SR-710 Tunnel Perhaps recognizing the legal and political 

vulnerability of expressly propounding the SR-710 Tunnel as part of the RTP/SCS, Appendix 

B page 149 describes the project as "SR-710 North Extension (Alignment TBD)." A footnote 

seeks to explain this agnosticism by claiming that project environmental review will select 

the project, which will be subsequently amended into the RTP/SCS. Notwithstanding the 

purported agnosticism regarding SR-710 alternatives, the body of the RTP/SCS and PEIR 

reveal that the Appendix B listing is at best inaccurate, and possibly deceptive and 

dishonest. As shown below, from "alternative neutral," the draft documents actually select 

the SR-710 Tunnel: The draft FTIP, Appendix B page 37, seeks funding "to close the 710 

freeway gap." Listing the project as a “freeway gap closure” only maintains the fiction that 

the project itself is a freeway, the only version of which remains is the SR-710 Tunnel. The 

Appendix B "System" designation of the project as a "State Highway," like the "Route #" of 

SR-710 (appendix B, pp. 37, 149) further defines the actual project as the SR-710 Tunnel, 

which is the only state highway alternative identified in the Caltrans 710 North Study. The 

draft PEIR describes the SR-710 North Project as a toll lane. (See, e.g., Figure 2.4.2- 1: Major 

Highway Projects; Figure 2.4.2-5: Major Toll Projects.) The only Caltrans 710 North Project 

alternative that calls for a toll road is the Freeway Tunnel.

Comment noted. Page 37 and 149) The Project List entry for the SR-710 environmental 

studies within the RTP/SCS is the approved project description in the adopted Federal 

Transportation Improvement Program (FTIP) which is solely programmed for 

environmental studies. Regarding system classification and route #, the SR-710 North 

project has historically been classified as a state highway. As previously mentioned, when 

the SR-710 North Study EIR/EIS process is complete and a locally preferred alternative 

(LPA) is identified in the final environmental document, SCAG will work with Metro to 

amend the RTP/SCS as necessary to update the project description and associated 

modeling analysis.

16214.07.2 The draft PEIR relies on tolls received from the SR-710 North Project to partially fund its 

“financially constrained Plan.” (See Figure 2.4.2-5.) Specifically, the draft PEIR at page 2-26 

identifies $23.5 billion from highway tolls as part of its “innovative funding strategies.” 

Again, only the SR-710 Tunnel is proposed to generate tolls, revealing that the tunnel forms 

the project included in the 2016 RTP/SCS. In addition to the above references the City 

submits the attached Supplemental Questions and Comments regarding the Draft RTP/SCS 

and PEIR as Attachment 1.

RTP ID 1M0101 includes the following project description, "SR-710 North Project Study 

Alternatives (Alignment TBD)" and includes the following footnote, "This project is 

currently pending environmental review. As with other projects included within the 

Project List, when the SR-710 North Study EIR/EIS process is complete, the 2016 RTP/SCS 

will be updated to reflect the Locally Preferred Alternative (LPA) as identified in the final 

environmental document." As noted in the Plan and in the Transportation Finance 

Appendix, the highway toll revenue included under the New Revenue Sources/Innovative 

Financing is associated with the East-West Freight Corridor and regional express lane 

network.

16214.08.1 SCAG's modeling for the RTP/SCS is premised on an SR-710 project consisting of four toll 

lanes in each direction — the SR-710 Tunnel — and no other project alternative. (Email 

correspondence between C. Aguirre and M. Lin, included herein as Attachment 2.)

Comment noted. As part of the Regional Travel Demand Model, only one alternative can 

be modeled. The modeling assumptions provided to SCAG have not changed since the 

2012 RTP/SCS. SCAG will work with Metro to amend the RTP/SCS as necessary to update 

the project description and associated modeling analysis once a locally preferred 

alternative (LPA) is identified.

16214.08.2 SCAG’s RTP/SCS stated project cost of $5.6 billion, at Appendix B page 149 also identifies 

the SR-710 Tunnel as the selected alternative, as that is the only alternative whose 

estimated cost matches that amount. The other alternatives are less than half that cost. 

See SR- 710 North Study, Executive Summary at pp. 5,8,10 and 14.

Comment noted. The project with RTP ID 1M0101 was submitted by Los Angeles County 

Metro with the following project description, "SR-710 North Project Study Alternatives 

(Alignment TBD)." Requests to modify projects included within the RTP/SCS must come 

directly from the County Transportation Commissions, in this case Metro. SCAG included 

the following footnote to describe the current status of the project, "This project is 

currently pending environmental review. As with other projects included within the 

Project List, when the SR-710 North Study EIR/EIS process is complete, the 2016 RTP/SCS 

will be updated to reflect the Locally Preferred Alternative (LPA) as identified in the final 

environmental document."

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holdID Comment Response 

Submitted by City of South Pasadena Submittal 16214 Related Documents Link

16214.09 The SR-710 Tunnel Is Inconsistent with Most Goals Expressed in the Draft 2016 RTP/SCS 

SCAG’s Initiatives Inclusion of the Tunnel Alternative in the Final RTP/SCS and PEIR would 

go against many of the valid major initiatives established by the Draft 2016 RTP/SCS, 

including: • Preserving the Transportation System We Already Have (Fixing it First) - 

continuing to allocate funding towards the study and construction of the Tunnel Alternative 

diverts scarce funding resources away from important system preservation projects and 

further expands the highway system beyond what may reasonably be maintained based on 

current funding projections • Expanding Our Regional Transit System to Give People More 

Alternatives to Driving Alone - the proposed Tunnel Alternative fails to expand the regional 

transit system • Expanding Passenger Rail - the proposed Tunnel Alternative fails to expand 

passenger rail and further propagates single-occupancy vehicle usage • Improving Highway 

and Arterial Capacity - the Tunnel Alternative does not focus on technology and 

system/demand management strategies that would effectively increase highway and 

arterial capacity, rather the expansion of the highway system would further induce demand 

along already congested highways and arterials causing significant strain on the operations 

and maintenance of the existing system • Managing Demand on the Transportation 

System - contrary to this initiative the Tunnel Alternative would induce demand, resulting 

in an increase in Vehicle Miles Traveled (VMT) • Optimizing the Performance of the 

Transportation System - the high cost of the proposed Tunnel Alternative would reduce 

available highway funding for Transportation System Management (TSM), Intelligent 

Transportation Systems (ITS) improvements, and other key transportation projects in the 

region • Promoting Walking, Biking and Other Forms of Active Transportation - the 

proposed Tunnel Alternative would not promote short trips or the use of active 

transportation in the region • Strengthening the Regional Transportation Network for 

Goods Movement - many proponents of the Tunnel Alternative have stated that they 

would not support the inclusion of truck traffic in the tunnel • Focusing New Growth 

Around Transit - development of a highway alternative reduces the amount of 

opportunities for growth around new transit in the San Gabriel Valley

Comment noted. The 2016 RTP/SCS is rooted upon a multi-modal approach towards 

addressing congestion and provides individuals with various options ranging from transit, 

bicycling, and walking as a means towards reducing single occupancy demand (SOV) 

demand on our highways and local arterials. As one of strategies for highways and 

arterials, the system management approach serves to address congestion by reducing 

demand and increasing efficiency without the need for expansion through the use of 

transportation system management (TSM) and transportation demand management 

(TDM) strategies. Examples of TSM/TDM include providing real time traffic information, 

advanced ramp metering, and incentivizing carpooling. However, in addition to those 

strategies, the system management approach also includes a strategy built upon the 

existing transportation network for all modes of travel including rail and roadways. SCAG 

recognizes that the SR-710 North project is currently pending environmental review. As 

with other projects included within the Project List, when the SR-710 North Study EIR/EIS 

process is complete and a locally preferred alternative (LPA) is identified in the final 

environmental document, SCAG will work with Metro to amend the RTP/SCS as necessary 

to update the project description and associated modeling analysis.

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Submitted by City of South Pasadena Submittal 16214 Related Documents Link

16214.10 SR-710 Tunnel is Inconsistent with Recent Legislation Furthermore, inclusion of the SR-710 

Tunnel conflicts with the principles and goals of recent legislation including Assembly Bill 32 

(AB 32) and Senate Bill 375 (SB 375). The SR- 710 Tunnel would induce demand, increase 

vehicle miles traveled (VMT), and result in an increase in greenhouse gas (GHG) emissions. 

This inclusion is contrary to the requirements set forth by AB 32 to reduce GHG emissions. 

A SR-710 freeway is a mid-20lh Century project that is not capable of achieving the state’s 

goals of improved air quality or the transportation demands of the region. Similarly, the 

California Supreme Court’s recent rejection of the EIR for the Newhall Ranch project 

(Center for Biological Diversity v. California Dept, of Fish and Wildlife (2015) 62 Cal.4th 204 

indicates that impacts of induced demand and their relation to GHG emissions must be 

taken seriously. In addition to conflicting with recent legislation, inclusion of the SR-710 

would directly contradict the Caltrans Strategic Management Plan and California Air 

Resources Board reduction goals to implement AB 32. As the Metropolitan Planning 

Organization for the region, SCAG should take the lead in developing policies that are able 

to efficiently and effectively improve air quality, by promoting and advocating 

transportation projects that would actually reduce VMT and GHG emissions. By including 

the SR-710 Tunnel in the Draft 2016 RTP/SCS simply because the project was included in 

the 2012 RTP/SCS or Metro’s 2009 Long Range Transportation Plan (LRTP), SCAG is 

defaulting into a passive role in the planning process.

Comment noted. The RTP/SCS must demonstrate compliance with SB 375 and the Federal 

Clean Air Act . However, compliance with these regulatory requirements is not predicated 

on a single project, such as the I-710 project. Demonstration of SB 375 GHG reduction 

target achievement and federal transportation conformity is analyzed at the regional level, 

looking at regional package of projects, programs and policies contained in the 2016 

RTP/SCS.

16214.11 SR-710 Tunnel Project Cost Is Not Committed, Available or Reasonably Available Although 

RTP ID 1M0101 states “Alignment TBD,” as stated on page 4 above, the project cost of $5.6 

billion identifies the SR-710 Tunnel as the selected alternative. Furthermore, as set forth on 

pages 2-3 above, the $5.6 billion is not “committed, available, or reasonably available.” 

Additional tunnel “commitments” are highly unlikely to be forthcoming from the 

anticipated sales tax measure (Measure R2) on the November 2016 ballot, since Metro has 

omitted the project from its Subregional Stakeholder Draft Project Priorities list for 

Measure R2. SCAG’S previous error of including the SR-710 in the 2012 Constrained Plan 

should be remedied in the Draft 2016 RTP/SCS by moving the project to the Strategic Plan. 

Even if theremaining $740 million Measure R funds were truly “committed” to the SR-710 

Tunnel (which they are not, as discussed earlier), they are woefully inadequate to meet the 

project cost of the single-bore tunnel, let alone the dual-bore tunnel variation. Thus, the 

California Transportation Commission (CTC) in its April 1, 2015 letter to former 

Assemblymember Anthony Portantino pointed to the ongoing lack of a defensible project 

cost determination, a deficiency that also ignores the Federal Highway Administration 

(FHWA) further requirement in the 710 corridor to cure “[c]ontinued uncertainty regarding 

the financing of [the SR-710 freeway] project and the failure to develop a comprehensive 

financial plan for its implementation.” (FHWA environmental re-evaluation withdrawing the 

1998 federal approval, p. 7 (December 17, 2003).)

SCAG’s analysis and documentation of reasonably available sources demonstrates 

consistency with federal requirements. The full text of the federal requirements can be 

found in 23 CFR 450.322. The applicable federal regulations clearly indicate an RTP meets 

the financial constraint requirement by including “sufficient financial information for 

demonstrating that projects” in the plan “can be implemented using committed, available, 

or reasonably available revenue sources, with reasonable assurance that the federally 

supported transportation system is being adequately operated and maintained.”

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Submitted by City of South Pasadena Submittal 16214 Related Documents Link

16214.12 The Highways and Arterials Appendix Consistently Identifies the SR-710 Tunnel as the 

Transportation Project in the 710 Corridor The Accuracy of the Transportation Model 

Results Is in Question The inappropriate inclusion of the SR-710 Tunnel in the Draft 2016 

RTP/SCS further calls into question the accuracy of the SCAG Transportation Model. This 

error is especially relevant since the SR-710 North Draft EIR/EIS was released many months 

before the Draft RTP/SCS and PEIR were issued. Although SCAG does not specifically state 

that the SR-710 project has been identified as the SR-710 Tunnel as set forth at pages 3-4 

above, the exhibits and project descriptions all and uniformly indicate that the project 

included in the Draft 2016 RTP/SCS is the SR-710 Tunnel. Nevertheless, the SR-710 North 

Draft EIREIS demonstrates that the SR-710 Tunnel would not improve traffic but would 

simply shift traffic congestion to other areas in the region. Indeed, certain streets in the 

cities of Alhambra, Rosemead, Pasadena, San Marino, and South Pasadena would become 

more congested as a result of cut-through traffic associated with the Tunnel Alternative. 

Failure to remove the SR-710 Tunnel from the 2016 RTP/SCS would raise questions 

regarding the validity of the Transportation Model since the SR-710 Tunnel would induce 

demand, increase VMT, and worsen air quality in the region. While SCAG staff has cited 

federal conformity requirements as the reasoning for including the SR-710 Tunnel in the 

Transportation Model and Draft 2016 RTP/SCS, no state or federal authority requires SCAG 

to include all of the projects listed in Metro’s 2009 LRTP. Finally, inclusion of the SR-710 

Tunnel is not necessary to secure regional air quality conformity. Indeed, comments of the 

federal and regional air quality authorities, summarized on page 7 below, conclude that the 

SR-710 Tunnel would produce localized air quality nonconformity.

Comment noted. As part of the Regional Travel Demand Model, only one alternative can 

be modeled. The modeling assumptions provided to SCAG have not changed since the 

2012 RTP/SCS. SCAG modeled the SR-710 North Project Study as four toll lanes in each 

direction since it is the most conservative scenario with respect to environmental impacts. 

This does not express SCAG's preference for this alternative. SCAG will work with Metro to 

amend the RTP/SCS as necessary to update the project description and associated 

modeling analysis once a locally preferred alternative (LPA) is identified.

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holdID Comment Response 

Submitted by City of South Pasadena Submittal 16214 Related Documents Link

16214.13 SCAG Should Consider Inclusion of the Beyond the 710 Initiative As a member of the 

Connected Cities and Communities (C3) the City has participated in the development of the 

Beyond the 710: Moving Forward - New Initiative for Mobility and Community (Beyond the 

710, included herein as Attachment 6). This initiative was developed in collaboration with 

nongovernmental advocates such as the National Trust for Historic Preservation, Natural 

Resources Defense Council, 5-Cities Alliance, and other public stakeholders. The Beyond the 

710 initiative provides a valid staring point to engage local communities and explores 

potential solutions to enhance the quality of life for communities through innovative 

strategies similar to SCAG’s 2016 Draft RTP/SCS Land Use Strategies, including: • Reflect the 

Changing Population and Demands - most of Los Angeles County is already developed and 

leaves little room for new forms of development, the Beyond the 710 Initiative provides the 

cities of Los Angeles and Pasadena with the opportunity to revitalize underutilized land 

with strategic infill and investment that may benefit the region • Focus New Growth 

Around Transit - the Beyond the 710 Initiative promotes the development of compatible 

land uses around new transit hubs, in areas that currently do not provide substantial public 

transit • Plan for Growth Around Livable Corridors - the Beyond the 710 aims to use 

innovative and sustainable transportation strategies such as “Complete Streets” or 

“Complete Corridors” to promote the use of active transportation and create more livable 

communities • Provide More Options for Short Trips - by replacing the focus on a car 

dependent mode, such as the SR-710 Tunnel, the Beyond the 710 aims to provide 

stakeholders with greater mobility options such as transit and active transportation by 

building up the transit and bicycle network in the area • Support Local Sustainability 

Planning- the C3 has worked with local stakeholder groups to develop an understanding of 

the type of development that is desired around the north and south stub • Protect Natural 

Land - the Beyond the 710 includes strategies to create new open space and restoration of 

the Arroyo Rosa de Castilla creek.

Comment noted. SCAG is not the project sponsor for the SR-710 North project. Please 

work with the Los Angeles County Metro regarding the integration of Beyond the 710 

initiative as part of the Locally Preferred Alternative (ILPA) to be considered. As with other 

projects included within the Project List, when the SR-710 North Study EIR/EIS process is 

complete and a LPA is identified in the final environmental document, SCAG will work with 

Metro to amend the RTP/SCS as necessary to update the project description and 

associated modeling analysis.

16214.14 SCAG could take a leadership role with the SR-710 by adopting the Beyond the 710 

Initiative as a starting point to further develop an East Los Angeles/Pasadena or West San 

Gabriel Valley Mobility Plan similar to SCAG’s previous Corridor Planning studies. By 

evaluating the SR-710 corridor SCAG may clearly identify the mobility problems of the 

region and develop sustainable solutions that adhere to the goals and objectives outlined 

in the Draft 2016 RTP/SCS.

Comment noted. SCAG is not the project sponsor for the SR-710 North project. Please 

work with the Los Angeles County Metro regarding the Beyond the 710 initiative as a 

Locally Preferred Alternative (ILPA) to be considered. As with other projects included 

within the Project List, when the SR-710 North Study EIR/EIS process is complete and a LPA 

is identified in the final environmental document, SCAG will work with Metro to amend 

the RTP/SCS as necessary to update the project description and associated modeling 

analysis.

Submitted by City of South Pasadena Submittal 16221 Related Documents Link

16221.01 • Page 6 - Major Initiatives: Improving Highway and Arterial Capacity; “The 2016 RTP/SCS 

calls for investing $54.5 billion in capital improvements... This includes focusing on 

achieving maximum productivity by adding capacity primarily by closing gaps in the 

system...” o Does the $54.5 billion estimate include the $5.636 billion needed to complete 

the Tunnel Alternative?

The $54.5 billion figure under the "Improving Highway and Arterial Capacity" section is the 

sum of capital improvements for the state highway system and regionally significant local 

streets and roads throughout the region. RTP ID 1M0101 is included in this figure. RTP ID 

1M0101 includes the following project description, "SR-710 North Project Study 

Alternatives (Alignment TBD)" and includes the following footnote, "This project is 

currently pending environmental review. As with other projects included within the 

Project List, when the SR-710 North Study EIR/EIS process is complete, the 2016 RTP/SCS 

will be updated to reflect the Locally Preferred Alternative (LPA) as identified in the final 

environmental document."

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Submitted by City of South Pasadena Submittal 16221 Related Documents Link

16221.02 • Page 38 - Our Progress Since 2012: Highways; “The expansion of highways has slowed 

considerably over the last decade because of land, financial, and environmental 

constraints. Still, several projects have been completed since 2012 to improve access and 

close critical gaps and congestion chokepoints in the regional network. These include the 

Interstate 5 South Corridor Project in Los Angeles County;... among others.” o Clarify; which 

other projects are considered “highway gaps”? Does SCAG consider the SR-710 North a 

“highway gap”?

Comment noted. Please refer to the Project List for a complete list of improvements 

including gap closure projects. As part of the Regional Travel Demand Model, only one 

alternative can be modeled. The modeling assumptions provided to SCAG have not 

changed since the 2012 RTP/SCS. SCAG modeled the SR-710 North Project Study as four 

toll lanes in each direction since it is the most conservative scenario with respect to 

environmental impacts. This does not express SCAG's preference for this alternative. SCAG 

will work with Metro to amend the RTP/SCS as necessary to update the project description 

and associated modeling analysis once a locally preferred alternative (LPA) is identified.

16221.03 • Exhibit 2.2: 2012 Base Year Transit Network; includes a “Rapid Bus and Bus Rapid Transit” 

for 2012 Base Year o Clarify; is this the BRT alternative from the SR-710 North Project EIR?

No, the SR-710 North Project EIR BRT alternative was not included in Exhibit 2.2. The base 

year transportation network includes only facilities and services that were in operation by 

the close of Fiscal Year 2011-12.

16221.04 • Exhibit 5.2: 2040 Transit Network Planned and Existing; includes a “Rapid Bus and Bus 

Rapid Transit” for 2012 Base Year o Clarify; is this the BRT alternative from the SR-710 

North Project EIR?

No, the SR-710 North Project EIR BRT alternative was not included in Exhibit 5.2. The base 

year transportation network includes only facilities and services that were in operation by 

the close of Fiscal Year 2011-12. The 2012 base year projects identified here were those 

that meet the above definition.

16221.05 • Exhibit 5.4: Major highway Projects; includes an “Improvement TBD” o Should be 

removed since the alignment/mode has yet to be determined and may not necessarily be a 

highway project.

Comment noted. As part of the Regional Travel Demand Model, only one alternative can 

be modeled. The modeling assumptions provided to SCAG have not changed since the 

2012 RTP/SCS. SCAG modeled the SR-710 North Project Study as four toll lanes in each 

direction since it is the most conservative scenario with respect to environmental impacts. 

This does not express SCAG's preference for this alternative. SCAG will work with Metro to 

amend the RTP/SCS as necessary to update the project description and associated 

modeling analysis once a locally preferred alternative (LPA) is identified.

16221.06 • Page 95 - Highways and Arterials “However, given that critical gaps and congestion 

chokepoints still existing with the network, improvements beyond TSM and TDM strategies 

need to be considered. Closing these gaps to complete the system will allow residents and 

visitors alike to enjoy improved access to opportunities such as jobs, education, recreation 

and healthcare.” o Does SCAG consider the SR-710 North a “highway gap”? If so, what is 

the reasoning it is considered a “gap”? What is the basis for determining if there is a “gap” 

in the system?

Comment noted. 2016 RTP/SCS does not necessarily identify the SR-710 North project as a 

gap project. However, inclusion of this project without commitment to a specific 

alternative in the 2016 RTP/SCS is an acknowledgement of transportation need in this 

corridor. The projects as provided by the CTC's include several gap closures which are 

typically deemed as improvements to close gaps within the existing network as a means to 

improve mobility. Please refer to the Project List for a complete listing of projects included 

in the RTP/SCS.

16221.07 • Page 95 - Highways and Arterials “Although we recognize that we can no longer rely on 

system expansion alone to address our mobility needs, critical gaps and congestion 

chokepoints in the network still hinder access to certain parts of the region. County 

transportation plans have identified projects to close the gaps, eliminate congestion 

chokepoints and complete the system. Such improvements are included in the 2016 

RTP/SCS.” o Does this mean that ALL projects included in Metro’s Long Range Plan will be 

included in the 2016 RTP/SCS?

Comment noted. Yes, the RTP/SCS is consistent with Metro's 2009 Long Range 

Transportation Plan (LRTP). Once Metro updates the LRTP, SCAG will amend the RTP/SCS 

to maintain consistency if and as needed.

16221.08 • Table 5.5: Sample Major Highway Projects Committed by the Counties o Does not include 

the SR-710 North o Why does SCAG include the SR-710 in their Exhibit 5.4: Major Highway 

Projects if it is not included as a County committed project? o Are there additional projects 

that are currently not included in this list?

Comment noted. Table 5.5 only provides a sample of major highway projects and is 

intended for illustrative purposes only. Please refer to the Project List which includes a 

complete listing of projects included within the RTP/SCS.

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Submitted by City of South Pasadena Submittal 16221 Related Documents Link

16221.09 • Exhibit 3: Major Toll Projects by Counties; includes toll lanes (plan 2040) for the SR-710 

North project o Should be removed since the alignment/mode has yet to be determined.

Comment noted. SCAG will consider revising the map to indicate improvement has yet to 

be determined.

16221.10 • Exhibit 5: Major Highway Projects; includes a “Improvement TBD” o Should be removed 

since the alignment/mode has yet to be determined and may not necessarily be a highway 

project.

Comment noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document, SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description, associated modeling analysis, and exhibits.

16221.11 • Exhibit 9: Baseline 2040 to Plan 2040 Freeway Speed Changes, PM Peak; includes a “5.0 or 

greater increase” in speed along the SR-710 North o Clarification regarding which 

alignment/mode should be provided. o Should be removed since the alignment/mode has 

yet to be determined.

Comment noted. As part of the Regional Travel Demand Model, only one alternative can 

be modeled. The modeling assumptions provided to SCAG have not changed since the 

2012 RTP/SCS. SCAG modeled the SR-710 North Project Study as four toll lanes in each 

direction since it is the most conservative scenario with respect to environmental impacts. 

This does not express SCAG's preference for this alternative. SCAG will work with Metro to 

amend the RTP/SCS as necessary to update the project description and associated 

modeling analysis once a locally preferred alternative (LPA) is identified.

16221.12 • Exhibit A2: Plan 2040 Number of Freeway Lanes (mixed-flow and toll); includes a 4-lane in 

each direction freeway along the SR-710 North o Should be removed since the 

alignment/mode has yet to be determined.

Comment noted. As part of the Regional Travel Demand Model, only one alternative can 

be modeled. The modeling assumptions provided to SCAG have not changed since the 

2012 RTP/SCS. SCAG modeled the SR-710 North Project Study as four toll lanes in each 

direction since it is the most conservative scenario with respect to environmental impacts. 

This does not express SCAG's preference for this alternative. SCAG will work with Metro to 

amend the RTP/SCS as necessary to update the project description and associated 

modeling analysis once a locally preferred alternative (LPA) is identified.

16221.13 • Exhibit A7: Baseline 2040 to Plan 2040 Freeway Speed Changes, AM Peak; includes a “5.0 

or greater increase” in speed along the SR-710 North o Clarification regarding which 

alignment/mode should be provided. o Should be removed since the alignment/mode has 

yet to be determined.

Comment noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document, SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description, associated modeling analysis, and exhibits.

16221.14 • Exhibit A12: Baseline 2040 to Plan 2040 Freeway Speed Changes - PM peak; includes a 

“5.0 or greater increase” in speed along the SR-710 North o Clarification regarding which 

alignment/mode should be provided. o Should be removed since the alignment/mode has 

yet to be determined.

Comment noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document, SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description, associated modeling analysis, and exhibits.

16221.15 • Page 37 - FTIP Project ID: 18790 “to close the 710 freeway gap” o Remove “freeway gap” 

language o Change the project description to the SR-710 North Project

Comment noted. The Project List entry for the 710 environmental studies is the project 

description in the adopted Federal Transportation Improvement Program (FTIP). FTIP 

description changes must be requested through the standard FTIP database update 

process.

16221.16 • Page 148 - Financially-Constrained RTP Projects ID 18790 “Route 710: Study to perform 

alternative analysis, engineering and environmental studies to close 710 freeway gap”, 

completion year 2025, $70,454 o Remove “freeway gap” language o Change the project 

description to the SR-710 North Project

Comment noted. The Project List entry for the 710 environmental studies is the project 

description in the adopted Federal Transportation Improvement Program (FTIP). FTIP 

description changes must be requested through the standard FTIP database update 

process.

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Submitted by City of South Pasadena Submittal 16221 Related Documents Link

16221.17 • Page 149-Financially-Constrained RTP Projects ID 1M0101 “SR-710North Project Study 

Alternatives (Alignment TBD)”, completion year 2025, $5,636,000 o Change the System 

from “State Highway” to “Other” o Move the RTP Project ID 1M0101 to the Strategic 

Project list o Why is the Project Cost listed as $5.636 billion? Does this indicate that the 

project is the Tunnel Alternative?

Comment noted. The 710 project is included in the voter-approved Measure R sales tax 

measure and in Metro's Long Range Transportation Plan and was submitted by Metro for 

inclusion as part of the financially constrained RTP Project List. Requests to modify projects 

included within the RTP/SCS must come directly from the County Transportation 

Commissions, in this case Metro. Project cost of $5.636 billion represents the worst case 

alternative, which will be replaced with the revised cost through an amendment to the 

2016 RTP/SCS once a locally preferred alternative is approved.

16221.18 • Page 340 - Strategic Projects RTP ID S1120082 “SR-710 Transportation Improvement 

Options” o Clarify which improvements? Is this related to the SR-710 North Project?

Strategic Plan component of the RTP/SCS are unfunded and would require future funding 

and commitments. This project is intended to capture all potential improvements along SR710, including those identified through the CEQA review process for the SR-710 North that 

is still in progress, without committing to any specific alternative. If and when additional 

details and funding commitments are identified through future planning initiatives, some 

of the elements of improvement on this corridor could move forward as financially 

constrained project through future amendment or update to the RTP/SCS.

16221.19 • Page 345 - Strategic Projects RTP ID S1120031 “North-South Rail Corridor between Port 

Communities of Los Angeles/Long Beach and Arroyo Verdugo Subregion-SR-710 

Transportation Improvement Options” o Clarify; is this the LRT alternative from the SR-710 

North Project EIR?

The Strategic Plan component of the RTP/SCS is unfunded and would require future 

funding and commitments. In addition, more consensus would be needed and in some 

cases further studies would be warranted before specific projects could move forward. 

This project is intended to capture all potential improvements on the rail corridor between 

the ports of Los Angeles and Long Beach and Arroyo Verdugo Subregion, including those 

identified through the CEQA/NEPA review process for the SR-710 North that is still in 

progress, without committing to any specific alternative. If and when additional details and 

funding commitments are identified through future planning initiatives, some of the 

elements of improvement on this corridor could move forward as a financially constrained 

project through future amendment or update to the RTP/SCS.

16221.20 • Page 4: County RTP Projects; includes “SR-710 north project (improvements TBD) from 

Valley Blvd. to California Blvd./Pasadena Ave.”; and Cost “$5.3 B”. o Remove “from Valley 

Blvd. to California Blvd./Pasadena Ave.” language o Why is the Project Cost listed as $5.636 

billion? Does this indicate that the project is the Tunnel Alternative?

Comment noted. The 710 project is included in the voter-approved Measure R sales tax 

measure and in Metro's Long Range Transportation Plan and was submitted by Metro for 

inclusion as part of the financially constrained RTP Project List. Requests to modify projects 

included within the RTP/SCS must come directly from the County Transportation 

Commissions, in this case Metro. The proposed project cost of $5.6 billion represents the 

worst case scenario for project cost as a place holder for the project. Actual cost 

associated with the LPA will be reflected in the future RTP/SCS once the LPA is identified.

Submitted by City of Tustin Submittal 16310 Related Documents Link

16310.01 1. The City of Tustin supports the 2016-2040 RTP/SCS growth forecast for Orange County 

and the adoption of the growth forecast at a geographic level no lower than the 

jurisdictional level. This level of the growth forecast accurately reflects Orange County's 

Projections dataset. Because the Intensified Land Use Alternative (Alternative 3) in the 

DPEIR does not include the technically corrected growth forecast for Orange County, the 

City of Tustin would not support the consideration of Alternative 3 as the preferred 

alternative or for any other purpose.

Comment noted; this comment is to support Policy Growth Forecast.

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Submitted by City of Tustin Submittal 16310 Related Documents Link

16310.02 The Draft RTP/SCS incorrectly assumes that most new housing in the SCAG region will be 

constructed more than 500 feet from a freeway or other major transportation corridor. This 

assumption is based on the California Air Resources Board's (CARB) 2005 advisory guidance 

that new housing be discouraged within 500 feet of high volume roadways, including 

freeways, due to roadway emissions. This guidance from CARB does not prohibit housing 

development near major roadways. However, SCAG's "buffer" strategy assumes little 

growth in these areas, which are often highly accessible to employment, retail, and housing 

centers that are connected through various transportation modes. Further, the use of the 

"buffer" strategy does not take into account the many mitigation measures that are 

available to address roadway emissions, nor the significant reduction in diesel emissions 

over the last decade. The implementation of a "buffer" strategy will discourage proximity 

and accessibility between different land uses that often reduce vehicle trips and vehicle 

miles traveled. As technology advances and vehicle engines and fuels become less 

polluting, the "buffer" strategy will become more obsolete. The "buffer" strategy is also 

contrary to the overarching principles of SB 375 to locate housing near job centers, existing 

urban areas, and transportation opportunities. Therefore, the City of Tustin urges that the 

"buffer" strategy be removed from the Draft RTP/SCS and that the Draft RTP/SCS 

emphasize the use of mitigation for housing developments that may be exposed to higher 

levels of roadway emissions, rather than discourage such development.

Comment noted. The Draft RTP/SCS does not assume new growth will be prohibited within 

500 feet of a freeway or busy roadway. Region-wide, projected growth within 500 feet of a 

freeway or busy roadway reflects local input data. The Draft RTP/SCS encourages local 

jurisdictions to establish their own policies to direct growth outside these areas based on 

factors covered in the Appendix: Environmental Justice. The use of the word “buffer” has 

been omitted from the Plan. However, SCAG will continue to utilize the advisory 

recommendation from ARB’s 2005 Air Quality and Land Use Manual to avoid siting new 

sensitive land uses within 500 feet of a freeway or urban roads with 100,000 vehicles per 

day.

16310.03 6. The City of Tustin participates on the Orange County Council of Governments (OCCOG) 

Board and OCCOG Technical Advisory Committee. Although the comments from the 

OCCOG Board on the Draft RTP/SCS and PEIR are not fully restated in this comment letter, 

the City of Tustin concurs with the comments identified by the OCCOG Board in its letter to 

SCAG, dated January 28, 2016. A copy of the OCCOG letter is attached for reference.

Comment noted.

Submitted by Climate Plan Submittal 16327 Related Documents Link

16327.01 Measuring progress on the last plan We enclose the Executive Summary of our forthcoming 

report, “Toward a Sustainable Future: Is Southern California On Track? From Vision to 

Action: Measuring Progress on Southern California’s Sustainable Community Strategy.” Our 

report measures progress in the implementation of the 2012 RTP/SCS and presents lessons 

learned. We believe this will be useful and informative in finishing the 2016 plan to make 

sure that it is actually implemented—to live up to the plan’s potential to meet required 

climate goals while creating a more healthy, prosperous, and sustainable region for all. We 

want to particularly thank SCAG’s research staff for the assistance they provided and 

encourage support for their work to collect more and better data—which is much 

needed—on implementation. * Please review report attached to letter.

Thank you for your comments and for your enclosure. SCAG is aware of the report being 

prepared by ClimatePlan. We share your belief in the critical importance of monitoring 

progress toward achieving the regional sustainability objectives outlined in the 2016 

RTP/SCS in a continuous, on-going manner. One of the new tools we will be introducing 

this year to assist in our on-going monitoring efforts is the web-based 'REVISION' tool 

which will be available for use by local and regional planners and decision-makers, as well 

as to members of the public. REVISION will allow users to analyze current conditions and 

emerging trends in land use, transportation, housing, socio-economics, and demographics 

at the local level. We sincerely applaud your endeavors in supporting implementation of 

the RTP/SCS and encourage your continued participation in our sustainability planning 

activities in support of the 2016 RTP/SCS.

16327.02 Revising the new plan Our partners have also submitted additional comment letters, with 

more detailed input on the current draft plan but we wanted to submit this together, as we 

have put considerable work into it together, to inform the new plan. We are hoping for a 

transparent, inclusive fair process as comments are collected and incorporated to revise 

the draft plan.

Comment noted. All formal comments received have been responded to and will be 

presented to SCAG policymakers to be considered as part of the Final 2016 RTP/SCS.

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Submitted by Cyrus Planning Submittal 16208 Related Documents

16208.01.1 I admire that SCAG is recognizing many of the problems that exist today. However their 

solutions to do not effectively target the problems and bring superb alternatives. I am in 

favor of providing all ranges of transportation from transit to free flowing car travel and 

also in favor of all housing types to be easily implemented from high-density mixed-use 

development to large lot single family homes. The transit options ranging from bus, light 

rail, Metro, Metrolink, and the High Speed Rail although have benefits, do not fully provide 

a real effective alternative for transportation. Other more cost effective, greater speed 

technologies that are more up-to-date ranging from SkyTran (personal rapid transit) and 

the Hyperloop (High-speed travel far faster and actually being planned and tested in 

California) are hardly even presented in the regional plan. SCAG will need to make some 

updates. Besides, it necessary to know why SCAG is rarely focusing on these methods for 

transportation which as a matter of fact will decrease our dependency for fossil fuels, 

reduce energy use per-person, decrease emissions, substantially reduce traffic for vehicle 

and airline travel, and reduce private and public sector costs.

Comment Noted. The RTP/SCS focuses on transit systems that are being pursued by our 

partner County Transportation Commissions (CTCs). Personal Rapid Transit (PRT) has only 

been deployed in a few limited cases around the world. Though automated connected 

vehicle technology may rekindle interest in PRT, most automakers and technology 

companies are developing vehicles to operate legally on existing roadways. The hyperloop 

and other untested advanced technologies are being pursued by private sector interests 

and may warrant further consideration after further development.

16208.01.2 Also many of the infill projects (Although this is a concern that is addressed by developers 

and cities) are not as effective as making trips shorter and attracting pedestrians 

effectively. The layouts, design, and features are not as attractive as the mixed-use projects 

in the early 20th century. We must learn to absorb some of those features.

Comment noted. With SB 375, SCAG is tasked with integrating land use and 

transportation. One of the 2016 RTP/SCS land use strategies is to focus new growth 

around transit. Land use policy in the vicinity of transit stations and amenities fall under 

the authority of the local governing jurisdiction. The SCS and SB 375 does not require a 

jurisdiction’s land use policies and regulations be consistent with the SCS. While the SCS is 

intended to provide a regional policy foundation that local governments may build upon if 

they so choose, it is clear that local jurisdictions maintain local land use authority. A 2016 

RTP/SCS foundational land use policy that seeks to create opportunities for shorter trips 

and attract pedestrian activity is developing "complete communities." In order to 

encourage “complete communities” that integrate land use and transportation, SCAG 

introduced two new concepts called “Livable Corridors” and “Neighborhood Mobility 

Areas." These concepts are introduced to give local jurisdictions ideas for developing 

sustainably in other contexts besides dense urban High Quality Transit Areas (HQTAs). The 

Livable Corridors concept features land use strategies that are appropriate for lower 

density growth areas that are served by HQTA bus corridors. The Neighborhood Mobility 

Areas concept features low impact land use strategies and low-cost transportation 

solutions to replace vehicle miles with low GHG travel modes. SCAG’s intention is to assist 

local jurisdictions by providing a framework and allowing maximum flexibility in creating 

“complete communities”. SCAG will continue to work with the local jurisdictions that show 

interest in implementing the RTP/SCS land use policies by providing information and 

resources to support local planning activities, such as the Sustainability Planning Grant 

Program and the Active Transportation Program.

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Submitted by Eastern Coachella Valley Coalition Submittal 16325 Related Documents Link

16325.01 SCAG’s “Framework for Sustainable Growth” Does Not Include Models for Rural Regions 

Hundreds of communities distributed throughout the SCAG region are simply not dense 

enough, nor will they qualify, for the models that SCAG lays out for sustainable 

development: Livable Corridors, High Quality Transit Areas (HQTAs) and Neighborhood 

Mobility Areas (NMAs), as they are currently defined. While the concept of NMAs expands 

the model of sustainable growth and development beyond the confines of an HQTA, it is 

not suitable for many small urban and rural communities given anticipated population 

densities, intersection densities and level of retail connections. We recommend SCAG 

undertake a comprehensive analysis of best practices and models for sustainable growth in 

more rural sub-regions and create appropriately scaled models for development and 

investment. SCAG should use this analysis to plan for and develop proper scale of retail and 

density, access to appropriate transit options, access to active travel, and best practices for 

rural infill development.

With SB 375, SCAG is tasked with integrating land use and transportation. The land use 

policies listed in Chapter 5, under the “Our Strategies for Transportation and Land Use” 

section, are the foundational policies that guided the development of the RTP/SCS land 

use strategies. In order to encourage “complete communities” that integrate land use and 

transportation, SCAG introduced two new concepts called “Livable Corridors” and 

“Neighborhood Mobility Areas." These concepts are introduced to give local jurisdictions 

ideas for developing sustainably in other contexts besides dense urban High Quality 

Transit Areas (HQTAs). The Livable Corridors concept features land use strategies that are 

appropriate for lower density growth areas that are served by HQTA bus corridors. The 

Neighborhood Mobility Areas concept features low impact land use strategies and lowcost transportation solutions to replace vehicle miles with low GHG travel modes. SCAG’s 

intention is to assist local jurisdictions by providing a framework and allowing maximum 

flexibility in creating “complete communities”. SCAG will continue to work with the local 

jurisdictions that show interest in implementing the RTP/SCS land use policies by providing 

information and resources to support local planning activities, such as the Sustainability 

Planning Grant Program and the Active Transportation Program.

16325.02 The SCS’s Guiding Principle of Prioritizing Investment to Existing Multi-Modal 

Transportation Systems Will Perpetuate Underinvestment in Communities with Inadequate 

Transit and Infrastructure SCAG’s Guiding Policy 2 (pg. 61) is as follows: "Ensuring safety, 

adequate maintenance, and efficiency of operations on the existing multimodal 

transportation system should be the highest RTP/ SCS priorities for any incremental funding 

in the region” (emphasis added). This policy perpetuates historic patterns of 

underinvestment in communities with severely inadequate transportation infrastructure or 

void of multi-modal transportation. Many of the region's rural unincorporated DACs are 

marked by dirt roads, inexistent bicycle and pedestrian facilities and deficient transit 

services. Severe poverty matched with chronic underinvestment has left many DACs, 

particularly rural DACs, without the basic features of healthy and sustainable communities. 

SCAG must prioritize improving and transit service and addressing lack of pedestrian and 

bike facilities in existing communities. We recommend SCAG rewrite this guiding policy to 

prioritize investment in existing, or be inclusive of communities that lack infrastructure and 

multi-modal transportation. Funds should serve existing communities, especially the most 

disadvantaged, even when infrastructure does not currently exist in those places. In 

subsequent sections of this letter we identify programs and policies that will secure 

investments in communities most in need of transit and infrastructure investment and 

upgrades.

Comment noted. As you may be aware, our transportation system has become 

increasingly compromised by decades of underinvestment. The quality of many of our 

roads, highways, bridges, transit, and pedestrian and bicycle facilities is deteriorating, and 

the longer they deteriorate, the more expensive they will be to fix in the future. The 2016 

RTP/SCS prioritizes system preservation so that we can maintain the system we already 

have and aim to use what we have better. The Plan includes strategies for expanding our 

passenger rail and transit networks, as well as our regional bikeway and pedestrian 

facilities so that people have more alternatives to driving alone. The Plan also includes 

strategies for closing critical gaps in our highways and arterials network. Please refer to the 

"Geographic Distribution of Transportation Investments" section in the Environmental 

Justice Appendix for a breakdown of these such improvements in rural and disadvantaged 

communities. As can be seen from this section, transportation investments by mileage in 

rural and disadvantaged communities are in proportion or larger than these area's share of 

the region's population.

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Submitted by Eastern Coachella Valley Coalition Submittal 16325 Related Documents Link

16325.03 The SCS reflects insufficient investment in transit for disadvantaged, rural communities The 

SCS does not reflect improved transit options and increased access to opportunity through 

alternate modes of transportation for residents of the Eastern Coachella Valley. Many 

residents have no adequate transit and have no access to employment and educational 

options in the western half of the Coachella Valley as a result. As noted in the coalition 

letter, increases in transit investment throughout the SCAG region reflect increased 

investment primarily in Los Angeles County. The RTP does not reflect increased transit 

investments as a share of overall RTP transportation investments in the Inland Empire, thus 

reinforcing reliance on personal vehicles and impeding opportunity for those without 

access to cars. Our review of the project list for projects located in Eastern Riverside County 

reflects inadequate investments in communities most in need of improved transit and 

connectivity. Instead of robust investment in transit, the local transit agency seems to be 

investing more in the agency’s own facility improvements than increased service. 

Furthermore, the project list illustrates greater investment and prioritization for transit 

projects linking West Coachella Valley residents with employment options in the western 

portion of Riverside County (Projects RIV30506 and RIVII407) as compared to transit 

projects linking East Coachella Valley residents with employment options in Palm Springs, 

Indian Wells and other cities in the western Coachella Valley (Project RIV130505). SCAG in 

its RTP should include a breakdown of investment by mode by region to better illustrate 

the extent to which different counties and sub-regions are prioritizing alternative 

transportation modes. Similarly, SCAG should assess the extent that investments reflect 

needs and impacts identified in the EJ element and through other needs assessments. 

SCAG should also ensure that transportation and transit agencies provide transparent and 

open processes to receive feedback on proposed transportation projects. Finally, through 

programs and policies, SCAG should incentivize increased investment for transit in 

communities and regions that do not adequately serve their residents.

Improvements in roadway, transit, and bicycle mileage are broken down by area of 

concern and compared to the region as a whole in the Geographic Distribution of 

Transportation Investments section of the Environmental Justice Appendix. As can be seen 

from Tables 30-32, investments are targeted in areas that have a high concentration of low 

income and minority population.

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Submitted by Eastern Coachella Valley Coalition Submittal 16325 Related Documents Link

16325.04 Efforts to Strengthen Regional Goods Movement Must Serve Local Communities as Well 

Goods movement is a driving force behind transportation planning and investments in the 

Inland Empire, as 40% of the nation’s goods travel through the Inland Empire. A myopic 

approach to prioritizing planning and investing in the movement of objects over people has 

put residents in the Inland Empire at a disadvantage, where goods can pass through the 

region, but those who live in the region have limited neighborhood level mobility and 

limited transportation options. Goods movement investments target high speed trade 

corridors, SCAG fails to identify ample opportunities to improve resident mobility through 

pedestrian and bicycle retrofits. Furthermore, goods movement does and will have 

negative environmental and health impacts on nearby communities unless there are 

protections in place from emissions and other traffic impacts. SCAG should highlight 

opportunities for improving pedestrian, bicycling and other forms of active travel as an 

integral component when fixing highways to transport goods while also looking at 

technologies and investments designed to eliminate negative local impacts of goods 

movement. We urge SCAG provide policy guidance and best practices that require repair, 

maintenance and rehabilitation projects to include meaningful Complete Streets project 

components. We recommend SCAG include guidance for public participation in all of its 

strategies, initiatives, themes and implementation of guiding policies. The region could 

seize the opportunity to receive meaningful input from residents and ensure that 

investments serve dual purposes, fix crumbling systems, and provide improved mobility for 

residents.

Comment noted. in the Active Transportation Appendix to the 2016 RTP/SCS, (beginning 

on Page 69), the Plan Implementation section details various strategies for implementing 

active transportation, including complete streets. 2016-2040 RTP/SCS Goods Movement 

Environmental Strategy emphasizes coordinated strategies that support state and regional 

initiatives to reduce harmful pollutants from goods movement activities. The Plan 

continues to focus on the long-term goal of a zero-emission goods movement system 

where technically feasible and economically viable, while also integrating near zeroemissions technologies that serve as bridging options to continue to reduce emissions. 

Broad deployment of zero-and near zero-emission transportation technologies in the 2023 

to 2040 timeframe is a critical and significant undertaking with technological, cost and 

operational challenges. In recognizing this, the 2016 RTP/SCS outlines a roadmap for 

developing and deploying needed technologies, along with key action steps for public 

sector agencies to help move the region to that objective.

16325.05 Create Targeted Programs and Policies to Direct Funding for Planning and Investment in 

Disadvantaged and Rural Communities Many small urban and rural communities 

throughout SCAG lack comprehensive multi-modal transportation plans. Without plans in 

place, systematic improvements to active transportation infrastructure, improved first 

mile/last mile access and improved transit will be incomplete and ineffective. Furthermore, 

SCAG’s local sustainability strategy should include best practices as well as clear and explicit 

guidance on planning practices to ensure rural disadvantaged community residents 

participate in and benefit from SCAG’s climate resilience and sustainability strategies. As 

noted in the Coalition letter, we recommend SCAG target Sustainability Planning Grants to 

disadvantaged communities, and especially rural, disadvantaged communities that lack 

plans, models and programs designed to secure and promote sustainable development. For 

example, funds could support: feasibility studies; walk and bike counts for data poor 

communities; travel needs assessments; and community-driven multi-modal mobility plans. 

Also included in the Coalition letter, we recommend SCAG create a working group and 

dedicate full time staff to address equity issues throughout the region. Furthermore, we 

recommend SCAG create an equity or disadvantaged community advisory board with broad 

stakeholder representation.

Comment Noted. The past two calls for projects for the Sustainability Grant Program (2010 

and 2013) have included "need for assistance" as one scoring criterion. Additionally, SCAG 

intentionally keeps the application process simple and streamlined to encourage 

jurisdictions with constrained capabilities to apply. Finally, the program is designed to 

provide direct and streamlined technical assistance. This allows the jurisdictions to focus 

attention on managing the work, and not administering the grant.

109
holdID Comment Response 

Submitted by Eastern Coachella Valley Coalition Submittal 16325 Related Documents Link

16325.06 SCAG Must Improve Transparency and Adequacy of Information to Allow for Fair and 

Informed Decision-Making Processes Long term transportation and land use planning 

requires robust involvement from impacted communities. Such involvement can only 

happen with access to comprehensible data and information, and access to decisionmaking processes. Definition of Urban Not Contextually Appropriate SCAG’s definition of 

"rural” communities, is inaccurate and inconsistent throughout the plan. The EJ element 

defines rural as communities with 2,500 residents. This definition is overly restrictive and 

excludes communities - like Thermal, Mecca and North Shore - that are rural by most 

definitions of rural used by state and federal agencies. At the same time, other sections of 

the RTP uses data for "rural” communities with no definition as to what constitutes a rural 

community. We recommend SCAG refine the definition of rural to be more consistent with 

state and federal programs. For example, SCAG could use the definition established by the 

State’s Cap and Trade Affordable Housing and Sustainable Communities (AHSC) Program as 

an example to inform its definition. We recommend SCAG define rural through robust 

public participation processed to create a definition unique and appropriate for the region.

Thank you for your comment. The boundary for urban and rural areas in the 

Environmental Justice Appendix was established by the U.S. Census Bureau in the 2010 

Decennial Census and was updated by Caltrans in consultation with FHWA in 2014. 

Although this represents a reliable geography, SCAG recognizes that the Affordable 

Housing and Sustainable Communities (AHSC) Program does not utilize this same 

boundary. Additional consultation with stakeholders will be considered to reconcile the 

differences between the AHSC guidelines and the U.S. Census Bureau/Caltrans/FHWA. To 

clarify, the boundary for rural areas utilized in SCAG's Environmental Justice Appendix 

includes all areas with population under 2,500. As such, Thermal, Mecca, and North Shore 

qualify as rural areas. These areas also have some of the highest concentrations of 

minority and low income population in the region, and therefore are included in the 

"Communities of Concern" geography utilized in the Environmental Justice analysis of the 

Plan.

16325.07 Limited Analysis of Job Growth in the Region The analysis presented on projected job 

growth lacks a sub-regional analysis or a job-sector analysis. SCAG emphasizes the 

differences between commute times for high wage and low wage workers and the 

commute times for residents of the inland regions as compared to workers in the coastal 

region, indicating that SCAG’s job’s growth analysis should consider jobs housing fit which, 

in turn, would require an analysis of job growth by section and by sub-region. SCAG’s 

analysis of jobs growth fails to do so. We recommend that SCAG conduct an analysis that 

considers job type, distribution of jobs by sub-region, and job-readiness by sub-region. That 

analysis will, in turn, guide policies to promote jobs housing fit and economic development.

Comment noted. Given the nature of the REMI model used to conduct the Economic & Job 

Creation Analysis of the 2016-2040 Regional Transportation Plan/Sustainable Communities 

Strategy (RTP/SCS), which is built on county-level analysis, the economic impacts and job 

creation impacts for geographic areas smaller than counties would not be technically 

possible. The REMI model is the most technically advanced/sophisticated and 

geographically-detailed economic impact model currently available. Such an analysis 

would also be outside of the scope of the RTP/SCS. Outside of the RTP/SCS, SCAG has 

conducted or commissioned a variety of economic reports. These include the County 

Economic Reports that are prepared for the annual Southern California Economic Summit, 

as well as the program booklet from the most recent Southern California Economic 

Summit, which provided a brief description of RTP/SCS job creation by industry and 

occupational category at the SCAG regional level.

16325.08 Lack of Long Range Transportation Plans in the Region Currently only three of SCAG’s 

County Transportation Commissions have a Long Range Transportation Plan (LRTP): The Los 

Angeles County Metropolitan Transportation Authority (LACMTA), the Orange County 

Transportation Authority (OCTA), the San Bernardino Associated Governments (SANBAG). 

Because the CTCs without an LRTP do not actively seek public input or have a transparent 

process for such feedback, the only chance to review projects is through the RTP/SCS 

review, which provides limited ground level detail. The absence of uniform planning in the 

region makes it difficult to assess the regional cohesion of the data presented in the Plan. 

Comparing data from a county with an LRTP to one lacking an LRTP does not provide clear 

comparable data. We recommend SCAG prioritize incentivizing LRTPs for the entire region. 

Clarity of Information between FTIP Project List and Financially Constrained RTP List The 

Project List is does not present clear information, some projects have two project IDs, (i.e. 

page 249, projects: 30M0701-RIV071263 and 3RL04-RIV110408). The lack of clarity makes it 

difficult to understand how distinct agencies prioritize their investments and project 

programming, calling into question accuracy and integrity of the lists.

Comment noted. There is no statutory requirements for the CTCs to prepare long range 

transportation plans. Given the scale and diversity of our region, the flexibility for each of 

the CTCs to chose their own path to plan and implement transportation projects is a 

reasonable one. Regarding the Project List, more specifically Table 2 - Financially 

Constrained RTP Projects, the reason projects have two project IDs is to indicate that the 

project is also programmed in the FTIP (Table 1) in which second project ID provided is the 

associated FTIP ID.

110
holdID Comment Response 

Submitted by Eastern Coachella Valley Coalition Submittal 16325 Related Documents Link

16325.09 Critical information is not included in the Plan The Plan and the appendices do not 

adequately present transportation system expenditures per mode by county and subregion. Information disaggregated per mode, county and sub-region facilitates improved 

understanding of expenditures per mode and how residents will have access to those 

modes. The primary function of the RTP/.SCS is to present comprehensive growth 

projections for the entire region. The maps throughout the Plan are inadequate at best, 

they are small and do not provide enough detailed information to properly asses where 

new growth and growth in existing communities is targeted. We recommend SCAG present 

transportation expenditures broken down per COG and transportation modes (Bus, Bus 

Rapid Transit (BRT), Light Rail Transit (LRT), Heavy Rail, Commuter Rail, High Speed Rail, 

Active Transportation-bicycling and pedestrian, Transportation Demand Managementcarpools, Vanpools, ridesharing) and improved, detailed growth and employment maps.

Comment noted. In accordance with state and federal requirements, the 2016 RTP/SCS 

includes a financial plan that estimates how much funding will be needed to implement 

transportation investment needs, as well as operate and maintain the transportation 

system as a whole over the life of the Plan. The Plan must demonstrate that there is a 

balance between the estimated costs of the projects and programs described in the Plan 

and revenue sources reasonably expected to be available for transportation investments. 

Table 6.1 details the core revenue forecast by county. The Project List Appendix details 

projects included in the Plan for each county. Maps of investments included in the Plan are 

available throughout the main document and appendices.

16325.10 Finally, we recommend SCAG incorporate improved quantification methods to determine 

actual impacts and improvements of the RTP/SCS in environmental justice communities 

over the life of the Plan. Current tracking methods described in the EJ analysis are not 

sufficient nor do they provide meaningful information to determine actual impacts of the 

Plan.

Comment noted. SCAG will continue to enhance our environmental justice efforts in the 

region by evaluating methods for monitoring the impacts on minority and low income 

communities over the life of the RTP/SCS.

Submitted by Encino Neighborhood Council Submittal 16052 Related Documents

16052.01 LA996425 SEPULVEDA TUNNEL REVERSE LANE. Since the new I-405 Skirball S off-ramp 

being moved and a new Northbound lane added from the ramp to the Skirball Bridge on 

Sepulveda Blvd, the congestion is gone and the need for the reversible lane is gone. Do not 

waste money on this project. There is no support for this project.

Comment noted. Since the completion of the improvements on I-405, additional 

improvement needs in this corridor, including Sepulveda Boulevard, are being further 

examined. SCAG will work with Metro and Caltrans to reflect the ultimate improvement 

configuration in this corridor in the future RTP/SCS amendments or updates as appropriate.

Submitted by Encino Neighborhood Council Submittal 16076 Related Documents

16076.01 The Encino Neighborhood Council on 4/25/2012 voted against LA996425. The new SCAG 

2016 still has the same item on the books. Yesterday at the Encino Neighborhood Council 

Traffic/Transportation meeting another motion passed regarding the same item. 

MOTION:The Encino Neighborhood Council Traffic/Transportation Committee does not 

support LA996425, a reverse lane in the Sepulveda Blvd Tunnel under Mulholland Dr. The 

new Northbound lane on Sepulveda Blvd from the S 405 Skirball off-ramp to the Skirball 

Bridge has reduced PM congestion. Vote: 5/0/0 The new lane adds 33% more capacity on 

Sepulveda Blvd Northbound.

Comment noted. Since the completion of the improvements on I-405, additional 

improvement needs in this corridor, including Sepulveda Boulevard, are being further 

examined. SCAG will work with Metro and Caltrans to reflect the ultimate improvement 

configuration in this corridor in the future RTP/SCS amendments or updates as appropriate.

Submitted by Encino Neighborhood Council Submittal 16176 Related Documents

16176.01 LA 996425 Sepulveda Blvd. Tunnel The Encino Neighborhood Council does not support a 

reverse lane in the Sepulveda Blvd tunnel under Mulholland Dr. The new Northbound lane 

on Sepulveda Blvd from the S I-405 Skirball exit to the Skirball Bridge has reduced PM 

congestion significantly. This motion was passed at the January 27, 2016 meeting of the 

Encino Neighborhood Council with a vote of 13- yes, 1-no.

Comment noted. Since the completion of the improvements on I-405, additional 

improvement needs in this corridor, including Sepulveda Boulevard, are being further 

examined. SCAG will work with Metro and Caltrans to reflect the ultimate improvement 

configuration in this corridor in the future RTP/SCS amendments or updates as appropriate.

111
holdID Comment Response 

Submitted by Endangered Habitats League Submittal 16250 Related Documents Link

16250.01 The 2012 RTP/SCS provided an important stepping stone for the 2016 Plan. In previous 

Plans, natural lands and farmlands were handled under the banner of “land use.” In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn’t be overlooked. We 

believe the opportunity before you isn’t to “plan for” the future of open space in the 

region—as that’s what you’ve been doing since the 2012 Plan. Instead, we believe SCAG 

can now start “implementing” a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. We and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16250.02 Our organization supports the idea that as new growth occurs it should focus on the 

existing infill areas. This is consistent with the finding in the SCAG surveys where 

respondents preferred to see existing urban areas built upon before greenfields are 

targeted for development, especially those at the Wildland-Urban Interface. When 

developments are built in infill areas, it helps pressure from the fringe but is not sufficient. 

Just because the pressure is relieved doesn’t mean the land then automatically becomes 

protected. The Plan fails to outline exactly how (or with what mechanism) these fringe 

lands (or any lands) will actually be protected. Numerous organizations, ours included, 

focus their work on preservation of important habitat lands. A lot of time, energy, political 

will, strategy and other efforts combine to create a successful conservation transaction that 

leads to permanently conserved lands. SCAG must identify the mechanism, process or plan 

on how the greenfield lands will be protected.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16250.03 The current federal transportation bill, FAST Act, supports understanding transportation 

impacts on natural resources. The previous bill, MAP-21, supported restoring and 

maintaining environmental functions (i.e., wildlife corridors) affected by the infrastructure 

projects in the RTP. SCAG has even supported efforts in Los Angeles County to create a 

wildlife corridor over the 101 Freeway. Many efforts are underway across the region to 

connect landscapes to one another. This is very important to the region and its biodiversity. 

Wildlife corridors allow species to migrate and forage and expand genetic diversity. These 

corridors also allow ecosystems to maintain ecological functions, act as sources for 

repopulation after natural disasters such as fire, flood or landslide, and improve the 

resiliency in the face of climate change impacts. The Plan should support the enhancement 

of and/or protection of documented and regionally significant wildlife corridors, especially 

those that are impacted by infrastructure projects.

Comment noted. The RTP/SCS describes (in Chapter 5) next steps for further developing a 

habitat conservation strategy. Included in the steps is the recommendation to provide 

“incentives for jurisdictions to cooperate across county lines to protect and restore natural 

habitat corridors, especially where corridors cross county boundaries.” The Natural/Farm 

Lands Appendix further supports wildlife corridors in its recommended policies, with the 

specific recommendation to “Encourage and facilitate research, programs and policies to 

identify, protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Additionally, continue support for preserving wildlife corridors and 

wildlife crossings to minimize the impact of transportation projects on wildlife species and 

habitat fragmentation.”

112
holdID Comment Response 

Submitted by Environmental Coalition Support for Natural and Link

Farmland Policies

Submittal 16255 Related Documents

16255.01 SCAG has a tremendous opportunity with the 2016 Plan. Much of the last four years has 

been spent researching, gathering and vetting the data, surveying local jurisdictions, 

completing an assessment, and planning a comprehensive six-county wide Conservation 

Program. The Coalition believes SCAG has the leadership in place, the homework done, the 

support by the conservation community, and the interest and attention of the resource 

agencies to now transition to actually implementing the Conservation Program.

Comment noted.

16255.02 In 2013, funded through federal dollars made available to MTC and additional funds from 

the State Coastal Conservancy), 23 PCA projects were funded totaling nearly $12 million. 

For use in 2018, MTC has already authorized $16.4 million for PCA funding with an 

anticipated call for projects in early 2017. The PCAs are also eligible for other sources of 

local, regional, state, and federal funding to leverage the MTC One Bay Area Grant program 

dollars. SCAG with its natural lands and infill focus is uniquely situated to replicate this type 

of program for the Southern California region. If you do this, you will be the second region 

in the nation that we know of that has such a program in place. Much of the baseline work 

of understanding where the high value habitat areas are located has already been 

completed since the last RTP/SCS. While there continue to be other filters that can inform 

decisions, SCAG has a nearly complete Regional Conservation Plan that could be used to 

launch a similar program here. Additionally, the majority of development sites targeted for 

the anticipated population growth here are less than a mile from transit. This piece is also 

already in place. The 2016 Southern California Conservation Coalition wholly supports this 

type of unique program and funding mechanism to achieve both compact infill 

developments where transit and employment centers already exist, while simultaneously 

funding conservation work to protect greenfield sites at the fringe (where less dense, more 

auto-dependent and fire-prone development pressures exist).

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16255.03 Existing text: "Policy #1 - Expanding on the Natural Resource Inventory Database and 

Conservation Framework & Assessment by incorporating strategic mapping layers to build 

the database and further refine the priority conservation areas. Specifically: • Further 

investing in mapping and habitat and farmland data tracking. • Working with County 

Transportation Commissions to support their county-level efforts at database building." 

Modify to read: "Policy #1 - Expanding on the Natural Resource Inventory Database and 

Conservation Framework & Assessment by incorporating strategic mapping layers to build 

the database and further refine the priority conservation areas. Specifically: • Further 

investing in mapping of habitat and farmland including data tracking and gathering. • 

Working with County Transportation Commissions to support their county-level efforts at 

database building. • Coordinate data sharing with partners and stakeholders to assist with 

regional conservation planning efforts. • Use the Combined Habitat Assessment Protocol 

data as an overlay to integrate regional land use planning and ensure that future growth 

avoids greenfield sites, especially those identified as high value habitat lands."

Comment noted.

113
holdID Comment Response 

Submitted by Environmental Coalition Support for Natural and Link

Farmland Policies

Submittal 16255 Related Documents

16255.04 Existing text: "Policy #2 - Encouraging CTCs to develop advance mitigation programs or 

include them in future transportation measures. Specifically. • Funding pilot programs that 

encourage advance mitigation including data and replicable processes • Participating in 

state level efforts that would support regional advanced mitigation planning in the SCAG 

region • Supporting the inclusion of advance mitigation programs at county level 

transportation measures" Modify to read: "Policy #2 - Encouraging CTCs to develop 

advance mitigation programs, include them in future transportation measures, and 

leverage existing programs. Specifically. • Funding pilot programs for CTCs that do not have 

advance mitigation programs, including data gathering for Greenprint creation. • 

Participating in state level efforts that would support regional advanced mitigation planning 

in the SCAG region • Supporting the inclusion of advance mitigation programs at county 

level transportation measures • Provide matching dollars to CTCs with advance mitigation 

programs to acquire, restore, and manage natural lands."

Comment noted.

16255.05 Existing text: "Policy #3 - Aligning with funding opportunities and pilot programs to begin 

implementation of the Conservation Plan through acquisition and restoration. Specifically. •

 Seeking planning funds, such Cap-and-Trade auction proceeds that could help prepare for 

local action on acquisition and restoration. • Supporting county transportation 

commissions and other partners. • Continuing support of the State Wildlife Action Plan 

2015 Update13 and its implementation." Modify to read: "Policy #3 - Aligning with and 

seeking funding opportunities and pilot programs to begin implementation of the 

Conservation Plan through acquisition and restoration. • Seeking funds, such as planning 

grants and Cap-and-Trade auction proceeds, that could allow for local or regional action on 

acquisition and restoration. • Supporting county transportation commissions and other 

partners. • Continuing support of the State Wildlife Action Plan 2015 Update13 and its 

implementation. • Seek funding for a pilot program to digitally map and quantify carbon in 

the vegetation and soils."

comment noted.

16255.06 Existing text: "Policy #4 - Providing incentives to jurisdictions that cooperate across county 

lines to protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Specifically. • Working with stakeholders to identify incentives. • 

Considering providing sustainability planning grants or seeking funding that help protect 

habitat corridors, especially across county boundaries." Modify text to read: "Policy #4 - 

Providing incentives to jurisdictions that cooperate across county lines to protect and 

restore natural habitat corridors, especially where corridors cross county boundaries. 

Specifically. • Working with stakeholders to identify incentives and collaboration 

opportunities. • Considering providing sustainability planning grants or seeking funding 

that help protect habitat corridors, especially across county boundaries. • Encourage 

projects that provide a net environmental benefit to wildlife connectivity." As you can see, 

our main interest focuses on actual implementation of the Conservation Program 

developed by SCAG. We individually and collectively offer our assistance to SCAG as this 

process unfolds and as the Plan gets implemented. We urge SCAG to consider 

implementing a program similar to the One Bay Area Grant program to get this effort 

moving forward.

Comment noted.

114
holdID Comment Response 

Submitted by Five Point Communities Submittal 16315 Related Documents Link

16315.01 Our concerns, as discussed below, are that the Draft 2016 RTP/SCS does not reflect our 

current entitlements for Great Park Neighborhoods. As a result, the Draft 2016 RTP/SCS 

underestimates the amount of development planned for Planning Area 51 in the City of 

Irvine.

The Policy Growth Forecast of Orange County for the 2016 RTP/SCS was developed 

through close collaborations with CSU-Fullerton and reviewed by the City of Irvine. The 

Great Park neighborhoods entitlement was fully considered at the time the forecast was 

developed.

16315.02 Heritage Fields has completed a review of the Draft 2016 RTP/SCS growth forecasts at the 

Traffic Analysis Zone (TAZ) level and it is not consistent with our existing, vested, 

entitlements, and substantially underestimates the amount of growth planned for the area, 

and does not capitalize on the potential for future growth consistent with the strategies in 

the RTP.

Comment noted. The TAZ level Policy Growth Forecasts for Orange County and the City of 

Irvine were developed using technical corrections provided by CSU-Fullerton Center for 

Demographic Research (CDR) and the City of Irvine. As such the Policy Growth forecasts 

reflects all existing and vested entitlements in Orange County as submitted to SCAG, 

including the Heritage Field project.

16315.03 In addition, there are uses planned for the Great Park itself, which do not appear to be 

reflected in the RTP’s estimates of future land uses.

Comment noted. Population, housing and employment growth are based on information 

provided by local jurisdictions (including the City of Irvine) and other stakeholders through 

a transparent and collaborative process when SCAG developed the Policy Growth Forecast 

in 2015.

16315.04 Heritage Fields recommends that the 2016 RTP/SCS and all alternatives be based on the 

Policy Growth Forecast that includes the technical corrections provided by the Center for 

Demographic Research, on behalf of the City of Irvine.

The growth forecast, including Irvine projections for the 2016 RTP/SCS, is based on the 

policy growth forecast with all technical corrections from CSU-Fullerton CDR.

16315.05 It is our understanding that there are different levels of TAZ data (Regional TAZ, SubRegional [COG] TAZ, and Scenario Planning Zones) and that the Scenario Planning TAZ level 

demographic assumptions in the SCAG 2016 RTP Model may differ greatly from 

cities/counties existing and General Plan forecasts. If the SCAG 2016 RTP Model is not 

consistent with local forecasts at the Scenario Planning TAZ, then future projects would be 

consistent with a City's General Plan, but would not be consistent with the SCS, meaning 

that it may not achieve the SCAG's region’s SB 375 targets.

Scenario planning zonal level data are controlled to be consistent with existing county/city 

and General Plan forecasts.

16315.06 The large margin of error between the SCAG 2016 RTP Model and local demographic 

forecast would problematic with regards to future consistency findings in CEQA documents. 

A project that is consistent with the General Plan may not be consistent with the SCS, which 

is contrary to the intent of the SCS. As a result, these discrepancies between the 2016 

RTP/SCS and the adopted Irvine General Plan must be corrected prior to adoption of the 

2016 RTP/SCS.

The Policy Growth Forecast of Orange County for the 2016 RTP/SCS was developed 

through close collaboration with CSU-Fullerton and reviewed by the City of Irvine.

16315.07 We also do not understand why Exhibit 5.1 of the Draft 2016 RTP/SCS does not designate 

Irvine Station as a High Quality Transit Area (HQTA) in 2040. We understand that a HQTA is 

generally a walkable transit village or corridor, consistent with the adopted RTP/SCS , that 

has a minimum density of 20 dwelling units per acre and is within a 14 mile of a wellserviced transit stop with 15-minute or less service frequency during peak commute hours. 

The area around the Irvine Station is designated as 8.1B Trails and Transit Oriented 

Development, which allows mixed-use development up to 50 units per acre and unlimited 

building heights within 14 mile of Irvine Station. As a result, we believe that consistent with 

SCAG’s definition of a HQTA, Irvine Station should be designated as such in the Draft 2016 

RTP/SCS for 2040.

Exhibit 5.1 does indicate the Irvine Station as both a rail station and HQTA in the 2016 

RTP/SCS. Rail stations are considered major transit stops and are included in the definition 

of HQTAs (see RTP/SCS Glossary definition of HQTA). Exhibit 5.1 has been clarified.

115
holdID Comment Response 

Submitted by Five Point Communities Submittal 16315 Related Documents Link

16315.08 We would also like to note that the land around the Irvine Station provides substantial 

opportunities for intensification of land uses beyond that currently allowed by the Irvine 

General Plan due to its location near the multimodal Irvine Station.

Comment noted. Population, housing and employment growth are based off information 

provided by the local jurisdictions, including existing general plans.

16315.09 We would encourage coordination between SCAG and Heritage Fields so that the 2016 

RTP/SCS accurately reflects population, housing, and employment growth consistent with 

our existing entitlements.

The Policy Growth Forecast reflects entitlements in the City of Irvine, including Heritage 

Fields through the coordination with City of Irvine and CSU-Fullerton Center for 

Demographic Research. SCAG staff will continue to collaborate with local jurisdictions and 

developers to develop an accurate database to reflect the entitlements as appropriate.

Submitted by Friends of Harbors, Beaches, and Parks Submittal 16330 Related Documents Link

16330.01 The 2012 RTP/SCS provided an important stepping stone for the 2016 Plan. In previous 

Plans, natural lands and farmlands were handled under the banner of "land use." In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn't be overlooked. We 

believe the opportunity before you isn't to "plan for" the future of open space in the 

region—as that's what you've been doing since the 2012 Plan. Instead, we believe SCAG 

can now start "implementing" a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. FHBP and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16330.02 And as it relates to the Natural and Farmlands Appendix, there are also errors there as well. 

The following Plans are missing from the approved or implemented section within this 

document (pages 1-2): • Lower Colorado River Multi-Species Conservation Plan (approved 

in 2005) • West Mojave HCP (approved in 2006) • Orange County Southern HCP (approved 

in 2007) • City of Colton HCP (approved in 2015)

Comment noted. The list of approved or implemented projects was acquired from the 

California Department of Fish and Wildlife's website, which was last updated in August, 

2015.(https://www.wildlife.ca.gov/Conservation/Planning/NCCP).

16330.03 The Appendix states the following Plans are approved or are in implementation, but they 

are not: • Desert Renewable Energy Conservation Plan (DRECP) (expected approval in 

March 2016) • OCTA Measure M2 NCCP/HCP (expected approval June 2016)

Comment noted. The list of approved or implemented projects was acquired from the 

California Department of Fish and Wildlife's website, which was last updated in August, 

2015.(https://www.wildlife.ca.gov/Conservation/Planning/NCCP).

16330.04 Conservation Plans vs. Planning Areas (PEIR and Natural and Farmlands Appendix) There 

appears to be confusion in the Biological Resources Section 3.4 (page 3.4-52) and Appendix 

(pages 1-2) as to the land "afforded long term protection" under existing NCCPs and HCPs. 

For example, the PEIR identifies that more than 20 million acres are protected because of 

these plans. There is no consistent way each plan is reviewed or explained and no 

calculations laid out as to how the 20 million acres was reached.

Comment noted. The text in the Natural/Farm Lands Appendix has been updated.

116
holdID Comment Response 

Submitted by Friends of Harbors, Beaches, and Parks Submittal 16330 Related Documents Link

16330.05 We agree that certain geographies are more vulnerable to development pressure than 

others. We also support focusing development away from the high value habitat, but 

strongly disagree with the statement that many "edge" lands do not have plans for 

conservation. What is the basis for this statement? What evidence do you have that 

substantiates this conclusion? What type of conservation plan is being included or 

excluded?

Data about habitat value was compiled using a multi-species habitat evaluation method, 

Combined Habitat Assessment Protocols (CHAP) for the entire SCAG region. The 

methodology and findings are explained in detail in the Conservation Framework and 

Assessment report, which was commissioned to account for impacts and improvements in 

a consistent manner across all habitats and landscapes. The report is available for 

download here: 

http://sustain.scag.ca.gov/Sustainability%20Portal%20Document%20Library/SCAG%20Final

%20Conservation%20Framework%20%20Assessment_Feb.pdf. Exhibit 1 of the 

Natural/Farm Lands Appendix, the SCAG Region Habitat Evaluation Map, displays this data 

for the region. Information about conservation plans was acquired from the California 

Protected Areas Data Portal (CPAD). CPAD provides GIS data that are owned in fee and 

protected for open space purposes by over 1,000 public agencies and non-profit 

organizations. The portal can be found here: http://www.calands.org/. Exhibit 2 of the 

Natural/Farm Lands Appendix, Protected Lands in the SCAG Region Map, displays this data 

for the region.

16330.06 This is an important reminder that NCCP/HCPs are not the end all in conserving important 

lands. They are voluntary and property owner driven, typically only applying to larger 

ownerships/geographies. Just because it isn't within an existing NCCP/HCP (a formal 

conservation plan) doesn't mean it isn't important to conserve. Many local, regional, state, 

and federal agencies may have other mechanisms, processes, programs, plans, 

documentation, and goals for regional conservation not captured in an NCCP/HCP. For 

example, the California Department of Fish and Wildlife (CDFW) has a process called the 

Conceptual Area Protection Plan (CAPP). CAPPs provide an initial evaluation of properties 

considered for acquisition and when funds are available, if the CAPP is approved, lands can 

be acquired through state funding. CAPPs are a formal process for CDFW, but likely do not 

overlap with an NCCP/HCP.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation. Suggestions for strategies 

beyond HCPs and NCCPs will be encouraged and appreciated. Your group is encouraged to 

participate in the effort.

16330.07 Many non-profits have ongoing efforts to acquire and preserve important landscapes that 

are also not included in a formal or informal conservation plan yet. In fact, most non-profits 

exist and focus their work on a specific geography. For example, using FHBP's Greenprint, 

called the Green Vision Map, the entirety of Orange County has been coded in a tiered 

system creating a wish list of properties—many of which are at the WUI. This Greenprint 

covers an entire county. Many non-profits, and state and federal agencies have also already 

done a lot of the leg work for preservation of habitat lands, but may not have publically 

identified lands along the urban fringe. In other words, unless the conservation plan/effort 

is tied to a County Transportation Commission or local land use authority (city or county) 

that puts the Plan forward, it appears to be dismissed by SCAG. However, the reality is 

conservancies (public and private) exist to protect lands in their natural state. For example, 

The Trust for Public Land may have an option to buy important lands that are neither in a 

CAPP or formal conservation plan, but agencies funding the project agree it should be 

protected. State and federal agencies also focus on important areas to build a reserve, 

connect to another reserve, protect specific species, etc. This should be seen as an 

opportunity to partner and work collaboratively. Therefore, the definition of "conservation 

plan" in the RTP/SCS statement can have a lot of implied meanings and should be clarified.

Information about conservation plans was acquired from the California Protected Areas 

Data Portal (CPAD). CPAD provides GIS data that are owned in fee and protected for open 

space purposes by over 1,000 public agencies and non-profit organizations. The portal can 

be found here: http://www.calands.org/. Exhibit 2 of the Natural/Farm Lands Appendix, 

Protected Lands in the SCAG Region Map, displays this data for the region.

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holdID Comment Response 

Submitted by Friends of Harbors, Beaches, and Parks Submittal 16330 Related Documents Link

16330.08 Existing text: "Many natural land areas near the edge of existing urbanized areas do not 

have plans for conservation and are vulnerable to development pressure." Modify to read: 

""Many natural land areas especially those near the edge of existing urbanized areas are 

vulnerable to development pressure. While some areas have formal conservation plans in 

place, other geographies rely on state and federal resource agencies and non-profits for 

inclusion in conservation efforts."

Comment noted.

16330.09 With an anticipated population growth of 20% (nearly 3.8 million people) by 2040 (page 47) 

this adds considerable pressure to our existing parkland. [Note: the Appendix states 17°% 

on page 1 - the documents should be internally consistent.]Studies conducted by Friends of 

Harbors, Beaches and Parks (See Attachment 4 - FHBP Park Score Study for Orange County) 

and The City Project (go to: www.MapJustice.org) demonstrate our communities do not 

have enough parkland to meet the existing demand. Local land use authorities have an 

obligation to meet the Quimby Act (which aims for three acres of parkland per 1,000 

residents). With an anticipated population boom of 3.8 million more people, this equates to 

more than 11,400 acres that should automatically be added to the local and regional park 

system as the growth occurs. These parks tend to be protected as turf parks or active/high 

intensity parks (with tennis courts, baseball and soccer fields, etc. This preservation is 

separate from the ongoing formal and informal conservation efforts by agencies, CTCs, and 

non-profits—many of which are protecting lands for entirely different reasons.

Park accessibility is an integral part of sustainable communities as it improves public 

health, air quality, and quality of life. Providing parks within infill areas has a different set 

of challenges that varies by jurisdiction. SCAG encourages jurisdictions to look at funding 

sources, such as the California Department of Housing and Community Development 

(HCD) Housing-related Parks program, to help build and maintain local parks. The Housingrelated Parks program awards money to build and maintain parks based on the number of 

affordable housing units a jurisdiction has built, which can help increase park accessibility 

in traditionally underserved areas. SCAG will continue to provide jurisdictions information 

regarding funding opportunities and encourage jurisdictions to provide parks as part of 

their long-range plans. The term "Natural Lands" is used intentionally to differentiate 

between potentially sensitive habitat areas and urban/suburban parks that provide open 

space and active recreation. Specifically, "Natural Lands" refers to biologically diverse 

areas and landscapes that may provide ecosystem services, such as grasslands, wetlands, 

deserts, forests, shrublands, riparian areas, and other types of habitat lands. Natural Lands 

is not intended to include agricultural croplands, grazing/rangeland, other working lands, 

or municipal parks serving primarily recreational purposes.

16330.10 As indicated on page 13 of the RTP/SCS, infill developments promote active transportation 

and improve access to amenities such as parks and natural lands. While the document 

(page 2) indicates that residents utilize the natural lands and recreational areas as a respite 

from the busy life in the city, unfortunately unless new and additional parks are created for 

the new influx of people, the limited existing parks will suffer even more from overuse and 

abuse. Creating new parks lessens the impacts on existing parks and maintains the balance 

for recreational uses needed when housing is added. Another Land Use Policy of the Plan is 

to "ensure adequate access to open space and preservation of habitat" (page 69), but 

nowhere does it state how additional lands will be preserved to accommodate the 

anticipated growth without severely impacting the existing protected natural lands from 

recreational overuse.

Park accessibility is an integral part of sustainable communities as it improves public 

health, air quality, and quality of life. Providing parks within infill areas has a different set 

of challenges that varies by jurisdiction. SCAG encourages jurisdictions to look at funding 

sources, such as the California Department of Housing and Community Development 

(HCD) Housing-related Parks program, to help build and maintain local parks. The Housingrelated Parks program awards money to build and maintain parks based on the number of 

affordable housing units a jurisdiction has built, which can help increase park accessibility 

in traditionally underserved areas. SCAG will continue to provide jurisdictions information 

regarding funding opportunities and encourage jurisdictions to provide parks as part of 

their long-range plans. The term "Natural Lands" is used intentionally to differentiate 

between potentially sensitive habitat areas and urban/suburban parks that provide open 

space and active recreation. Specifically, "Natural Lands" refers to biologically diverse 

areas and landscapes that may provide ecosystem services, such as grasslands, wetlands, 

deserts, forests, shrublands, riparian areas, and other types of habitat lands. Natural Lands 

is not intended to include agricultural croplands, grazing/rangeland, other working lands, 

or municipal parks serving primarily recreational purposes.

118
holdID Comment Response 

Submitted by Friends of Harbors, Beaches, and Parks Submittal 16330 Related Documents Link

16330.11 The reality on the conservation-front is, that there are a lot of natural lands left to protect 

across the SCAG region. Furthermore, land conservation occurs for many reasons, such as: 

species protection, wildlife corridor enhancements, mitigation lands, NCCP/HCP lands, and 

even local and regional parks. Not all parkland is available for recreational use (hiking, 

biking, equestrian, etc.). Many lands have restrictions or managed access due to legal 

requirements (deed restrictions), mitigation and permit requirements, and/or conservation 

easements. Simply providing "more" access may have significant consequences for the land 

manager.

Comment noted.

16330.12 The 2012 RTP/SCS indicated 742 square miles (474,880 acres) of greenfield lands in the 

Baseline (business-as-usual scenario) would be converted into more urban uses, but with 

the 2012 Plan in place it would reduce the conversion to 334 square miles (213,760 acres). 

Four years later, with the 2016 Plan, the document indicates (Table 8.1 - pages 150 and 

153) the 2040 Baseline (business-as-usual scenario) would result in the conversion of 154 

square miles (95,860 acres) of greenfield lands into more urban uses. With the Plan in 

place, the document states (pages 9, 147, and 148) only 118 square miles (75,520 acres) 

would be converted to more urban uses. A 23.4% reduction, as proposed by the 2016 Plan, 

provides a solid start to improved sustainability [and conservation]. But, as page 20 

indicates, current conservation efforts are underway and this reduced land conversion does 

NOT account for those efforts. We would anticipate the greenfield acreage converted to 

urban uses to be even lower.

Comment noted. The 23.4% reduction does not account for current conservation efforts 

that are underway. As the tool utilized to measure this reduction - Urban Footprint 

Scenario Planning Model - currently exists, new growth is analyzed and measured. 

However, as these analysis tools continue to evolve, research and development will focus 

on measurements that include existing growth.

16330.13 We continue to urge SCAG to promote infill developments, and encourage local and 

regional land use authorities to halt building at the WUI. As the survey SCAG conducted 

indicates (page 64), the clear majority of respondents supported development in existing 

urban areas rather than into our natural and farmlands. On page 63, the document also 

accurately notes that varying combinations of land use and transportation strategies lead 

to different rates of land consumption, among other things. This is exactly the type of 

information our decision makers need to have when making important land use decisions 

relating to infill and greenfield development.

Comment noted.

119
holdID Comment Response 

Submitted by Friends of Harbors, Beaches, and Parks Submittal 16330 Related Documents Link

16330.14 The Plan also notes that climate change will have impacts to natural habitats and overall 

biodiversity (page 56). In addition to coastlines being vulnerable to sea level rise and 

destructive storm surges, many of the transportation infrastructure (roads, highways, and 

rail lines) that already exists is vulnerable as well. A study conducted by the Pacific Institute 

may be helpful for SCAG in understanding what a 1.4 meter (4.6 feet) sea level rise has the 

potential to impact. (See Attachment 5 - Vulnerable Infrastructure) For example, with a 1.4 

meter sea level rise, Ventura County has 7.7% of its roadways impacted, Los Angeles 

County has 18%, and Orange County has 9%. Another example, with a 1.4 meter sea level 

rise, Ventura has 10 miles of rail lines impacted, Los Angeles County has 14 miles, and 

Orange has 6.6 miles impacted. As noted in the Plan, we agree that your response to 

climate change impacts requires cooperation, creative thinking, and better use of limited 

resources (page 56). On page 13, the Plan discusses making communities more resilient to 

the impacts of climate change, but we also see a connection to ensuring our wildlands are 

more resilient to the effects as well. Guaranteeing our wildlife and plant species have the 

ability to reach other elevations through permanent connections between protected lands 

is essential to ensuring this region's biodiversity is retained and functional in the future.

Comment noted. SCAG has begun a process to analyze vulnerability of the regional transit 

system to climate change. Additionally, Caltrans is assessing vulnerability of the state 

highway system to climate change. These studies will likely be completed prior to the 2020 

RTP/SCS and findings potentially incorporated into the 2020 RTP/SCS.

16330.15 Preserving natural lands comes in many forms. While, we support the general idea that as 

new growth is concentrated in existing urban areas (page 16) mainly concentrated at the 

HQTA (per Huasha Lui at the Elected Official Briefing in OC on January 20, 2016), the 

pressures to develop the fringe lands are decreased. The reality remains that some 

mechanism (local land use plan, policy, ordinance, etc.) and entity (local, regional, state or 

federal or even non-profit) needs to spearhead the conservation effort. Just because you 

say growth will be focused in the urban areas, doesn't automatically protect the fringe 

areas. It likely alleviates some pressure on the fringe areas, but this may only be temporary. 

Often times there is significant coordination, funding and support that must be organized 

before natural lands are protected. For example, within the Land Use Policies (page 108) 

the document notes that the 2016 Plan itself leads to, among other things, "the 

preservation of natural lands," however the Plan fails to state exactly how that will occur. 

The Plan lacks a mechanism for actually protecting resource rich lands. This should be 

corrected and suggestions are in the revised Natural and Farmland policy language included 

in the Coalition letter submitted January 29, 2016. References to this concern occur on the 

following pages as well: 14, 16, 78, 108, and 159.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16330.16 Ninety percent of the survey respondents supported protecting natural habitats (page 64). 

This is important information for our decision makers to have—it should be highlighted and 

enacted. The Plan has advanced well since 2012 and as the document states (page 111) 

"Building on this effort has the potential to create a regional conservation program that 

stakeholders such as CTCs, cities, agencies, and non-profits can align with and support." We 

agree. Let's work on the mechanism and funding by which land can be protected in the 

SCAG region and the environmental community and resources agencies will engage and 

support this effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16330.17 The Plan indicates on page 70 that there are numerous benefits to focusing new growth 

around HQTA. A clear benefit to focusing development at HQTA is also a reduction in 

greenfield development. We believe this should be included in your list of benefits.

Comment noted.

120
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Submitted by Friends of Harbors, Beaches, and Parks Submittal 16330 Related Documents Link

16330.18 Exhibit 2.1 (page 23) has a colorful map indicating the per acre habitat value of lands across 

the SCAG region. While this designation likely came from the CHAP mentioned earlier, we 

should note that there is a huge difference between the concrete "urban" landscape and 

the undeveloped "agricultural" landscape. Separating the Urban from the Agricultural 

layers in the map would provide a better delineation of the types of resources in the 

program—after all these policies address the Natural Lands and Farmlands. Furthermore, 

the California Department of Conservation has mapped the "prime agricultural lands" for 

the state and every county in the SCAG region is included in this mapping. Prime 

agricultural lands are defined by two important criteria. First, the land use: "has been used 

for irrigated agricultural production at some time during the four years prior to the 

Important Farmland Map date. Irrigated land use is determined by FMMP (Farmland 

Mapping and Monitoring Program) staff by analyzing current aerial photos, local comment 

letters, and related GIS data, supplemented with field verification." Second, the soil type: 

"The soil must meet the physical and chemical criteria for Prime Farmland or Farmland of 

Statewide Importance as determined by the USDA [United States Department of 

Agriculture] Natural Resources Conservation Service (NRCS)." Furthermore, the designation 

of "prime" refers to the agricultural use. (Source: California Department of Conservation, 

Prime Farmlands as Mapped by the FMMP 

http://www.conservation.ca.gov/dlrp/fmmp/overview/Pages/prime farmland fmmp.aspx) 

Why isn't the SCAG Natural Resource Inventory Database used as the base layer for this 

map?

Commented noted. Each of the maps identified in the comment serve a distinct purpose 

and as such may reference a different data set to fully address its purpose. The various 

data sets each have their own set of constraints, not limited to richness of data and scale, 

which primarily explains the differences in mapping between PEIR and the RTP/SCS. Maps 

have been clarified to properly identify the purpose of the map and the specific data 

source.

16330.19 Many efforts are underway across the SCAG region to connect the landscapes to one 

another. For example, efforts are underway to create a mountain lion corridor at Liberty 

Canyon to connect the Santa Monica Mountains in Los Angeles County to other preserved 

open space areas. In Riverside County, efforts are underway to connect lands in the San 

Jacinto Range with the San Gorgonio Range within the San Bernardino National Forest. 

Without connections for our large predators the entire ecosystem is impacted. The RTP/SCS 

has an opportunity to support documented wildlife corridors that are impacted by 

infrastructure projects. The research conducted by SC Wildlands and its South Coast 

Missing linkages project should be at the forefront of this effort. (See Attachment 6 - South 

Coast Missing Linkages Study)

Comment noted. The RTP/SCS describes (in Chapter 5) next steps for further developing a 

habitat conservation strategy. Included in the steps is the recommendation to provide 

“incentives for jurisdictions to cooperate across county lines to protect and restore natural 

habitat corridors, especially where corridors cross county boundaries.” The Natural/Farm 

Lands Appendix further supports wildlife corridors in its recommended policies, with the 

specific recommendation to “Encourage and facilitate research, programs and policies to 

identify, protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Additionally, continue support for preserving wildlife corridors and 

wildlife crossings to minimize the impact of transportation projects on wildlife species and 

habitat fragmentation."

16330.20 Greenfields are defined within the Plan's glossary. Please define "agricultural lands." (page 

178).

"Agricultural Lands" has been added to glossary.

Submitted by Friends of Harbors, Beaches, and Parks Submittal 16331 Related Documents Link

16331.01 The RTP/SCS promotes building on the 2012 Plan with the aim to serve as a resource for 

lead agencies (page 109). This is a commendable goal. That said, SCAG could offer 

assistance through the use of the CHAP and Natural Resource Inventory Database layers by 

providing the data to those agencies or even suggesting potential mitigation sites with high 

per acre habitat value.

Comment noted.

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holdID Comment Response 

Submitted by Gateway Cities Council of Governments Submittal 16266 Related Documents Link

16266.01 SCAG staff has met many times with the Gateway Cities COG staff and with the Planning 

Directors of our member jurisdictions to discuss the methodology of plan development. We 

understand that, of necessity, SCAG must make certain assumptions about where growth 

will occur within our jurisdictions, even though these assumptions might differ from the 

jurisdictions’ own plans, and that our jurisdictions will not be bound by SCAG’s 

assumptions. In order to meet regional goals, the Draft RTP/SCS recommends and assumes 

many different approaches to “sustainable” planning to reduce GHG – including strategies 

such as complete streets, “complete communities,” sustainable zoning codes, and 

neighborhood mobility areas, among others. Our concern is whether these strategies rest 

on a solid technical and analytical foundation. For example, the plan in some places refers 

to “urban/compact/suburban” development, but to the best of our understanding, these 

three categories do not directly correspond to the multiple place types in the Scenario 

Planning Model. It thus appears that different land use categories are used to underpin 

different analyses in the plan, rather than all categories being consistent. This analytical 

foundation is important because of the RTP/SCS’s growing emphasis on active 

transportation, especially bike investments, infrastructure, and programs. It is difficult to be 

confident that these investments are appropriate if they are not well supported by analysis 

showing they can make a real difference in reaching air quality or GHG goals. As a region, 

we shouldn’t invest in a mode unless it can pull its weight in terms of plan performance, or 

be appropriately funded in concert with other strategies.

As noted on page 20 of the RTP/SCS, 35 “Place Types” were utilized in the urban setting 

design tool (Urban Footprint Scenario Planning Model (SPM)) – it is the Place Types that 

factor into the modeling analyses. Land Development Categories (LDCs) are utilized in 

order to describe general conditions within areas of the SCAG region and do not play a role 

in the modeling analyses. The 35 Place Types were then sorted into the three LDCs. A table 

has been added in the Appendix: SCS Background Documentation and displays which LDC 

the 35 Place Types are categorized in to ensure consistency amongst the variety of land 

uses that represents the SCAG region.

16266.02 Exhibit 5.1 presents the high-quality transit areas (HQTA) projected for 2040. It appears 

that several of the planned light-rail corridors for the Gateway Cities are not shown as 

HQTA on this map, which is surprising. We believe the exhibit should be amended to 

include the corridors for the following projects: • West Santa Ana Branch (Eco Rapid Transit 

Project) • Green Line Eastern Extension (Norwalk) • Gold Line Eastside Extension, Phase II – 

Washington Blvd. Alignment.

The West Santa Ana Branch Corridor (RTP ID 1TR1011) and Metro Green Line Norwalk 

Extension (RTP ID 1120005) are labeled as 2040 Plan Rail Stations in Exhibit 5.1, and the 

Metro Eastside Transit Corridor Phase 2 (RTP ID 1TR0704) is labeled as Rail Station 

Alternatives (2040 Plan). Rail stations are considered major transit stops and are included 

in the definition of HQTAs (see RTP/SCS Glossary definition of HQTA). Exhibit 5.1 has been 

clarified.

16266.03 As you know, the Gateway Cities COG has worked closely with our member jurisdictions to 

develop an extensive, long-range Strategic Transportation Plan. In addition, we have 

worked with LA County MTA to express our priorities for major projects to be included in a 

potential sales tax ballot measure later this year. Due to the format in which the 2016-2040 

RTP/SCS project lists are presented, it is difficult to be sure whether all of our projects are 

appropriately included in the regional plan. Based on our review, it appears that the SR 60/I605 HOV direct connector project is listed only in the Strategic Plan, which indicates that it 

does not have any funding source identified. This project is among the Gateway Cities 

COG’s priorities for the potential 2016 MTA ballot measure and thus should be included in 

the financially constrained plan.

Comment Noted. It is correct, the SR-60/I-605 HOV connector project is currently under 

the strategic portion of the Project List under RTP ID# S1120056. However, should Metro's 

ballot measure be approved, SCAG will work with Metro to amend the RTP/SCS to reflect 

newly funded projects as part of the financially constrained portion of the Plan.

122
holdID Comment Response 

Submitted by Golden State Gateway Coalition Submittal 16165 Related Documents Link

16165.01 Description of I-5 North Capacity Enhancement Project in Table 4, although a highly 

desirable start, is only a partial description of the planned and environmentally cleared 

project. Currently reads: "Add 1 HOV lane in each direction from Weldon Canyon Road to 

SR-14 by 2017 at a cost of $410 million." Suggested correction: Add 1 HOV lane in each 

direction, auxiliary lanes, truck lanes and bridge modifications from SR-14 through Castaic 

by 2020 at a cost of $785 million.

Comment noted. Table 4 of the Highways and Arterials appendix is intended for illustrative 

purposes only. All of the project elements as described are accounted for and reflected 

within the Project List appendix.

Submitted by Grants To You Submittal 16024 Related Documents

16024.01.2 Planning for the most important items. This plan seems to include both critical needs and 

not so much. For example we have money for fixing the freeways but we also have money 

for a regional bike path network. How many people use the freeways and how many will 

use the bike paths?

Comment noted. Based on the SCAG Regional Travel Demand Model, 85 percent of all 

trips in the region are currently made by vehicle. Active transportation trips (e.g., walking, 

bicycling, etc.) account for 12 percent of all trips.

16024.01.3 We also have funding for high speed rail. How many people will abandon their cars and 

instead take the train and isn't this a State initiative? Why would Ventura County taxpayers 

be paying for any part of high speed rail? Finally, what is wrong with the current Metrolink 

system that it requires major funding?

The California High-Speed Rail is a State of California project, partially funded by a statewide proposition passed by voters in 2008 (Proposition 1A). The 2016 RTP/SCS does not 

direct state or federal gas tax or local transportation sales tax revenues to support this 

project. Once in operation, it will provide an additional travel choice to the State's 

increasingly congested highways and airports. The 2016 RTP/SCS includes investments in 

Metrolink to increase service, improve safety, and operate and maintain the existing and 

planned system. The Metrolink system is funded through a combination of ticket fares and 

local funding from Metrolink's member county transportation commissions, including 

Ventura County.

16024.01.3 Why don't the planners decide what is the most important transportation need and fund 

that instead of one again burdening the middle class with more taxes. Please get off the 

back of the middle class.

Comment noted. The Draft 2016 RTP/SCS includes goals, policies, strategies, and project 

priorities that have been developed with input from the public through dozens of public 

engagement opportunities, local governments, county transportation commissions (CTCs), 

the California Department of Transportation (Caltrans), tribal governments, non-profit 

organizations, businesses, and local stakeholders within Imperial, Los Angeles, Orange, 

Riverside, San Bernardino, and Ventura counties. In accordance with state and federal 

requirements, the Draft 2016 RTP/SCS includes a financial plan that estimates how much 

funding will be needed to implement recommended transportation investments, as well as 

operate and maintain the transportation system as a whole over the life of the Plan. The 

Plan must demonstrate that there is a balance between the estimated costs of the projects 

and programs described in the Plan and revenue sources reasonable expected to be 

available for transportation investments.

123
holdID Comment Response 

Submitted by Highgrove Municipal Advisory Council Submittal 16175 Related Documents Link

16175.01 We have written support from residents, business owners, civic organizations, and Senators 

from both Riverside and San Bernardino Counties who have supported a Metrolink station 

at Highgrove for the last 14 years. This includes written support from the cities of Grand 

Terrace, Loma Linda and Colton all of which are in San Bernardino County. Highgrove is in 

the un-incorporated part of Riverside County near the county line and is 7 rail miles south 

of the San Bernardino Metrolink station and 3.5 rail miles north of the Riverside Metrolink 

station. The land needed for a Metrolink station is 17.22 acres of vacant land that is owned 

by and under the jurisdiction of the Riverside County Transportation Commission that could 

easily be used for a parking lot for commuters who want to travel between San Bernardino 

and Riverside Counties or to Oceanside where there are connections to San Diego and Los 

Angeles. The 17.22 acres are already owned by the Riverside County Transportation 

Commission and is a pie shaped piece of vacant property that RCTC bought for a curved 

track to connect the new Perris Valley Line track to the BNSF main line track that is the 

Inland Empire/Orange County Line. The Inland Empire/Orange County Line has daily 7 day a 

week Metrolink trains that pass right next to the west side of RCTC's property at Highgrove 

that go between the two counties but RCTC has opposed this station location for the last 14 

years. RCTC has constructed a curved track through this property but they only need the 

width of the track to connect the Perris Valley Line to the Inland Empire/Orange County 

Line. The remainder of this vacant property is the location needed for a Metrolink parking 

lot and RCTC already has $5,347,500.00 invested in this property they do not need for the 

Perris Valley Line connection, but they refuse to build a parking lot on their excess 

property. This parking lot/station is the most efficient use of transportation funds because 

the IE/OC Metrolink timetable is already in place, the existing Metrolink trains go in both 

directions between the 2 counties every day including week-ends that is right next to 

RCTC’s property, and all that is needed is a parking lot and station platform.

Comment noted. SCAG works with the county transportation commissions to develop the 

transportation investment strategies in the RTP/SCS. Commuter rail station locations in 

Riverside County are determined through a local planning process led by the Riverside 

County Transportation Commission.

16175.02 There is a paved entry road for parking on the inside of the curved track at the base of the 

new Iowa Ave. overpass and Villa St. is a paved road for access for parking on the outside of 

the curved track. Within a 2 mile radius of the Highgrove location there are over 33,000 

residents and that does not include the 1,409 new homes that are being built 1 mile east of 

the Highgrove station location. New residents are now living in phase 1 with phase two 

being sold in the new Spring Mountain Ranch development. It is important to understand 

that a parking lot/station at Highgrove will not interfere with the Perris Valley Line because 

the connecting curved track is already in place. The Marlborough Ave. station on the Perris 

Valley Line is almost completed but RCTC also owns 17.22 acres only one mile away for the 

curved track at Highgrove. Also very important is that commuters from the new 

Marlborough Ave. Metrolink station on the Perris Valley Line will not be able to get to San 

Bernardino because the Perris Valley Metrolink trains will only go to Perris or Riverside. But 

the west side of RCTC's property at Highgrove is where the daily Metrolink trains operate 

between Riverside and San Bernardino Counties. Our Congressman and 3 of his staff visited 

this location and Congressman Takano feels that even though RCTC owns 2 properties only 

one mile apart, both Metrolink stations are needed because they have different 

destinations.

Comment noted. SCAG works with the county transportation commissions to develop the 

transportation investment strategies in the RTP/SCS. Commuter rail station locations in 

Riverside County are determined through a local planning process led by the Riverside 

County Transportation Commission.

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holdID Comment Response 

Submitted by Highgrove Municipal Advisory Council Submittal 16175 Related Documents Link

16175.03 Please visit our website: www.highgrovehappenings and review the map; concept map of 

the Highgrove location where all of the area between Villa St. and the Drainage Channel is 

vacant land except for the curved red line which is the track that connects the two railroads 

(the parking lines do not exist but have been added as a concept), Supporting Docs; 8 years 

of comments; Station costs; uneconomic remnant (that shows RCTC is only charging 38% of 

the cost they paid for the Highgrove property to the Perris Valley Line (which is 

$3,277,500.00 instead of $8,625,000.00) meaning they have $5,347,500 invested in excess 

vacant land at Highgrove, and; RCTC’s inappropriate actions to prevent a Highgrove 

Metrolink Station 2004 to 2010. This project meets the requirements of the RTP/SCS 

because it will address the "transportation and land use challenges of the region" on both 

sides of the Riverside San Bernardino County line that is already connected to the 

Metrolink commuter rail system and is only 1⁄2 mile from the Center St. exit of the I-215 

freeway.

Comment noted. SCAG works with the county transportation commissions to develop the 

transportation investment strategies in the RTP/SCS. Commuter rail station locations in 

Riverside County are determined through a local planning process led by the Riverside 

County Transportation Commission.

Submitted by Highgrove Municipal Advisory Council Submittal 16338 Related Documents Link

16338.01 We have written support from residents, business owners, civic organizations, and Senators 

from both Riverside and San Bernardino Counties who have supported a Metrolink station 

at Highgrove for the last 14 years. This includes written support from the cities of Grand 

Terrace, Loma Linda and Colton all of which are in San Bernardino County.

Comment noted. SCAG works with the county transportation commissions to develop the 

transportation investment strategies in the RTP/SCS. Commuter rail station locations in 

Riverside County are determined through a local planning process led by the Riverside 

County Transportation Commission.

16338.02 This project [Highgrove Metrolink Station] meets the requirements of the RTP/SCS because 

it will address the "transportation and land use challenges of the region" on both sides of 

the Riverside San Bernardino County line that is already connected to the Metrolink 

commuter rail system and is only 1⁄2 mile from the Center St. exit of the I-215 freeway.

Comment noted. SCAG works with the county transportation commissions to develop the 

transportation investment strategies in the RTP/SCS. Commuter rail station locations in 

Riverside County are determined through a local planning process led by the Riverside 

County Transportation Commission.

125
holdID Comment Response 

Submitted by Hills For Everyone Submittal 16170 Related Documents

16170.01 Thank you for the opportunity to comment on the Southern California Association of 

Governments (SCAG) 2016 Regional Transportation Plan (RTP) and Sustainable Community 

Strategy (SCS) and the Program Environmental Impact Report (PEIR). Following the release 

of the 2012 RTP/SCS, Friends of Harbors, Beaches and Parks (FHBP) coordinated a crosscounty regional conservation coalition focused on the inclusion of natural lands mitigation 

and policies within that SCAG plan. Our organization, Hills for Everyone is now a part of this 

growing coalition in 2016. Hills for Everyone has been working in Los Angeles, Orange, San 

Bernardino and Riverside Counties since 1977, Our mission is to protect the unique and 

disappearing landscapes in the Puente-Chino Hills Wildlife Corridor. We have had important 

successes since our inception including the establishment of the 14,100 acre Chino Hills 

State Park and the conservation of the Coal Canyon Biological Corridor. The 2012 RTP/SCS 

provided an important stepping stone for the 2016 Plan. In previous Plans, natural lands 

and farmlands were handled under the banner of “land use.” In this new Plan, however, 

they are their own category. This is a great milestone in conservation planning for the 

region and SCAG. Additionally, the creation of a Natural and Farmlands Appendix provides 

important opportunities for SCAG that shouldn’t be overlooked. We believe the 

opportunity before you isn’t to “plan for” the future of open space in the region—as that’s 

what you’ve been doing since the 2012 Plan. Instead, we believe SCAG can now start 

“implementing” a regional conservation program. We strongly urge SCAG to take a more 

serious leadership role by actively seeking funding to implement conservation efforts by 

partnering with agencies, transportation commissions and non-profits to see that the Plan 

created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant Program 

in Northern California is a program that we believe can be replicated in Southern California. 

We and other coalition members would gladly assist with this implementation effort. 

We’ve reviewed the RTP/SCS and PEIR and offer the following comments and suggestions 

for inclusion in the Plan with the intent to clarify/strengthen the language, as well as link 

the goals of the RTP and SCAG’s mission with the Natural and Farmland policies.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation programs. Your group is 

encouraged to participate in the effort, including exploring innovative options such as the 

One Bay Area grant program.

16170.02.1 Amendments to the Open Space Maps in the PEIR Maps contained within the PEIR, RTP, 

SCS and Appendix should be internally consistent and they are not. For example, each map 

that shows “open space” or “protected lands” should be using the same base dataset but 

they do not. The 2012 Plan resulted in the creation of SCAG’s very own geographic 

information systems (GIS) dataset: the Natural Resource Inventory. It is more accurate than 

what is in the document now and it has been vetted by numerous organizations. That’s why 

it is surprising to see that so few of SCAG’s own GIS layers were actually used in the 

documents’ maps. We urge SCAG to honor its own work and that of its partner 

organizations by using this dataset as the basis for natural and farmland mapping. Let’s 

move forward with the same baseline information.

Comment noted. Each of the maps identified in the comment serve a distinct purpose and 

as such may reference a different data set to fully address its purpose. The various data 

sets each have their own set of constraints, not limited to richness of data and scale, which 

primarily explains the differences in mapping between PEIR and the RTP/SCS. Maps have 

been clarified to properly identify the purpose of the map and the specific data source.

126
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Submitted by Hills For Everyone Submittal 16170 Related Documents

16170.02.2 Identify a Conservation Mechanism for the Natural and Farmlands Preservation Our 

organization supports the idea that as new growth occurs it should focus on the existing 

infill areas. This is consistent with the finding in the SCAG surveys where respondents 

preferred to see existing urban areas built upon before greenfields are targeted for 

development, especially those at the Wildland-Urban Interface. When developments are 

built in infill areas, it likely relieves pressure from the fringe. However, the Plan fails to 

outline exactly how (or with what mechanism) these fringe lands (or any lands) will actually 

be protected. Just because the pressure is relieved doesn’t mean the land then 

automatically becomes protected. Numerous organizations, ours included, focus their work 

on preservation of important habitat lands. A lot of time, energy, political will, strategy and 

other efforts combine to create a successful conservation transaction that leads to 

permanently conserved lands. SCAG must identify the mechanism, process or plan on how 

the greenfield lands will be protected. Formal Versus Informal Conservation Plans—All Are 

Important SCAG focused many sections of the document on formal conservation plans, in 

the form of Natural Community Conservation Plans and Habitat Conservation Plans 

(NCCP/HCP), as the conservation method most identified by the agency. It is important to 

note that NCCP/HCP programs are only one conservation mechanism and they have 

limitations. For example, they are voluntary, property owner driven and generally only 

apply to larger land ownerships.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation programs. Your group is 

encouraged to participate in the effort.

16170.03.1 Efforts underway by local, regional, state and federal agencies outside of these formal plans 

should not be discounted and must be included. Furthermore, many conservation 

organizations help facilitate, coordinate and find funding for land conservation 

transactions. We believe the conservation approach promoted by SCAG should include all 

of the ways land is protected, including those less regulated methods of conservation 

outside of NCCP/HCP programs.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation programs. Your group is 

encouraged to participate in the effort.

16170.03.2 SCAG’s Support of Regional Wildlife Corridors The current federal transportation bill, FAST 

Act, supports understanding transportation impacts on natural resources. The previous bill, 

MAP-21, supported restoring and maintaining environmental functions (i.e., wildlife 

corridors) affected by the infrastructure projects in the RTP. SCAG has even supported 

efforts in Los Angeles County to create a wildlife corridor over the 101 Freeway. Many 

efforts are underway across the region to connect landscapes to one another. This is very 

important to the region and its biodiversity. Wildlife corridors allow species to migrate and 

forage and expand genetic diversity. These corridors also allow ecosystems to maintain 

ecological functions, act as sources for repopulation after natural disasters such as fire, 

flood or landslide, and improve the resiliency in the face of climate change impacts. The 

Plan would be stronger if it supported the enhancement of and/or protection of 

documented and regionally significant wildlife corridors, especially those that are impacted 

by infrastructure projects. Conclusion Thank you for reviewing our comments and we look 

forward to working with SCAG on the implementation of this Plan, especially as it relates to 

the Natural and Farmlands Appendix. Should you need to contact me, I can be reached at 

714-996-0502. In addition, we request to be included on any notifications (electronic or 

otherwise) about this policy’s creation and implementation, please send information to 

Claire@schlotterbeck.net

Comment noted. The RTP/SCS describes (in Chapter 5) next steps for further developing a 

habitat conservation strategy. Included in the steps is the recommendation to provide 

“incentives for jurisdictions to cooperate across county lines to protect and restore natural 

habitat corridors, especially where corridors cross county boundaries.” The Natural/Farm 

Lands Appendix further supports wildlife corridors in its recommended policies, with the 

specific recommendation to “Encourage and facilitate research, programs and policies to 

identify, protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Additionally, continue support for preserving wildlife corridors and 

wildlife crossings to minimize the impact of transportation projects on wildlife species and 

habitat fragmentation.” SCAG is committed to continuing leading the efforts in facilitating 

the bottom up process for a sustainable future focusing on conserving natural lands.

127
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Submitted by Imperial County Transportation Commission Submittal 16188 Related Documents Link

16188.01 Thank you for the opportunity to review the Draft 2016 Regional Transportation 

Plan/Sustainable Communities Strategy (RTP/SCS). We have no specific comments at this 

time. We believe that the Southern California Association of Governments staff has done a 

great job to incorporate our Imperial County planned projects, land use and sustainable 

community strategies. The Draft 2016 RTP/SCS meets all of our state and federal mandates 

for metropolitan planning and achieving greenhouse gas emission reduction goals.

Comment noted.

Submitted by Imperial County Transportation Commission Submittal 16351 Related Documents

16351.01 Just so, you know, we're providing technical comments in writing and just appreciate the 

staff doing all the effort for this plan as we believe it meets the Federal requirements for air 

quality conformity and financial constraints as well as the SB375 requirements for meeting 

our greenhouse gas emissions that is, certainly, a big deal to us all. So, just appreciating 

that, also, expressing our appreciation for SCAG in its efforts to help us with our active 

transportation efforts, the planning studies and grants that our cities and ICTC is pursuing 

to help us move forward in that effort.

Comment noted.

16351.02 Financing those active transportation projects is a challenge for us and the assistance of 

SCAG has helped us with those types of grants, even at times when we were not as 

successful as we'd like to be with the statewide grants that are available.

Thank you for your comment. The Plan Implementation section of the Active 

Transportation Appendix elaborates on how SCAG will continue to collaborate with local, 

state and federal partners to help implement the plan.

Submitted by Inland Action Submittal 16140 Related Documents

16140.01 Supporting natural gas options where applicable- it is effective and uses current 

technology. No reason for delay on completing these options.

Comment noted. SCAG’s policies are technology neutral with regard to supporting zero 

and/or near-zero emissions vehicles. SCAG will continue to support natural gas fleet 

vehicles by hosting and administering the Southern California Clean Cities Coalition.

Submitted by Inland Action Submittal 16352 Related Documents

16352.01 So, one of the huge issues that we identified in Inland Action is that in 2023 under the 

Clean Air Act we will lose our federal funding. And all this will tell you that don't worry we 

won't let that happen, but the fact is that's what the law is today. We lose all federal 

funding if we don't meet the standard setup of the Clean Air Act. And our ability to meet 

those strict standards looks pretty grim. Regardless, we must address goods movement, 

clean technology and readily available options. And so, I just wanted to point at a couple of 

things that we have noticed, appreciated and want to draw attention to and, hopefully, the 

public will as well.

Comment noted. The South Coast State Implementation Plan (SIP) demonstrating 

attainment with the 1997 8-hour National Ambient Air Quality Standard (NAAQS) by 2023 

has been approved by the U.S. Environmental Protection Agency. The upcoming 2016 

South Coast Air Quality Management Plan is also expected to address the 2023 ozone 

attainment. Therefore, this region is not expected to lose federal funding in 2023 due to 

issues related to the Clean Air Act.

128
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Submitted by Inland Action Submittal 16352 Related Documents

16352.02 We appreciate that allowing businesses to choose their way of getting to the clean air goals 

through deciding whether it is going to be through electrical, natural gas or whatever 

format they want to use as long as they get their allowing them that flexibility is considered 

a process and it also engages with the end goal so I appreciate that. A couple of things that 

have to do with current technology and, I think, we're going to get this done in the next 8 

years, we have to use what is available now, in particular, there advocacy in the report for, 

without reading it altogether, but I want to say on page 7 they want to implement zero 

near zero emission freight systems, well, that's available now through using natural gas. It's 

another option and we support that. Also, more emission trucks and locomotives. In here in 

this part of the Inland Empire the emissions of locomotives is a huge issue. The most readily 

available option is going to be transferring them into natural gas. And I think that's -- we 

applaud doing that and doing that sooner rather than later because we need to meet this 

goal within 8 years. Also, to get to near zero emissions some of the gas tendered [sic] cars, 

the G-4 engines that can be retrofitted with diesel appropriately can be with natural gas 

now and we encourage them to do that.

Broad deployment of zero-and near zero-emission transportation technologies is a critical 

and significant undertaking with technological, cost and operational challenges. In 

recognizing this, the 2016 RTP/SCS integrates commercially available technologies to serve 

as bridging options to a longer-term strategy for reducing emissions.

16352.03 And the same thing is true with all rail locomotives. That includes -- if we scan the SCAG 

region they can be transformed to natural gas and this is the readily available technology to 

let us get to a positive output right away.

Comment noted. Locomotive propulsion systems decisions are the responsibility of 

Amtrak, Metrolink and the freight railroads in our region. Notably, Metrolink is moving to 

an all Tier 4 locomotive fleet in the next few years. These locomotives are over 85% 

cleaner than Metrolink's oldest locomotives that are still in operation. SCAG is cognizant of 

the need to incorporate evolving technologies with plans for new infrastructure. These 

include technologies to fuel vehicles, as well as to charge batteries and provide power. 

Chapter 5 of the RTP/SCS discusses a regional strategy for deployment of commercially 

available low-emission locomotives while advancing technologies toward phased 

implementation of zero- and near-zero emission systems.

16352.04 We need to meet -- we're not going to meet these goals, but if we don't make every effort 

to do it we're not going to have much more legal power to be able adjust federal 

transportation dollars. And without that, we will be, you know, that is half of our road 

budget now so we can hardly do with what we have. We must have with it -- I can't imagine 

where we would be. So, I encourage the things in this report that are readily available, 

particularly, the ones that incorporate natural gas because that is the technology available 

right now and there is no reason to hesitate in doing that.

Comment noted.

Submitted by Inland Empire Biking Alliance Submittal 16138 Related Documents Link

16138.01 Better standards for future projects to ensure that transit and alternative transportation 

are included as part of all projects, make number of people moved the highest priority.

Comment noted. The Active Transportation component promotes "complete streets" as a 

funding strategy, where projects are planned, designed and built for all roadway users 

(within the context of the street and land-use). This reduces the costs of implementing 

active transportation as separate projects.

129
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Submitted by Inland Empire Biking Alliance Submittal 16138 Related Documents Link

16138.02 Include transit as a mitigation measure to all newly developed projects. Comment Noted. SCAG appreciate your suggestions to include transit as a mitigation 

measure for all newly developed projects. SCAG has recommended a performance 

standards-based mitigation measures approach that clearly laid out a region-wide strategy 

to reduce impacts from roadway congestion, improve smart use of land, and encourage 

alternative transit. The mitigation measures include transit and active transportation 

strategies with specified performance standards including targets for VMT reduction. SCAG 

PEIR mitigation measures have considered and incorporated strategies based on inclusion 

of a variety of transit and transportation options, including active transit strategies to 

manage travel demand and reduce sprawl from automobile congestion in the long range 

transportation planning horizon. Also see Master Response No. 2 and Master Response 

No. 4.

16138.03 Pilot VMT-based analysis to assist OPR's implementation Comment noted. In fulfillment of provisions of Senate Bill 743, which was signed into law 

in September 2013, the Governor’s Office of Planning & Research (OPR) is currently 

updating the CEQA Guidelines. Throughout this process, SCAG has been coordinating 

closely with OPR staff to ensure that the views and concerns of our region are known and 

acknowledged before the proposed updates to the CEQA Guidelines are finalized.

16138.04 Encourage active modes for shortest trips and to transit. Comment noted. The active transportation component recommends strategies for transit 

integration and short trips.

Submitted by Inland Empire Biking Alliance Submittal 16157 Related Documents

16157.01 I would like to request a breakdown of the transportation finance per county; what county 

gets what RTP/SCS money and what type of projects are the counties going to spend the 

money on. This information is currently not included in the Draft RTP/SCS nor available on 

the seperate county websites. A county breakdown is the format of table 6.5 would be 

perfect. Thank you very much.

Table 6.1 details the core revenue forecast by county. The Project List Appendix details 

projects included in the Plan for each county.

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Submitted by Inland Empire Biking Alliance Submittal 16239 Related Documents

16239.01 Extended Pacific Surfliner to SF is good CP Benson to CP Central should be prioritized and 

expedited in addition to CP Lilac to CP Rancho Study potential of running Metrolink express 

that includes San Bernardino, Ontario by way of Colton Double-track all Metrolink stations 

if longer portions are problematic LAUSMP - include bikeway under station as part of 

widening Freight needs more slots; investments such as Alameda Corridor that use tax 

dollars need to increase option for passenger rail Metrolink to San Jacinto must NOT be 

hampered by SR-79 realignment project Include Metrolink to Temecula via SR-79 

realignment project Split the CP Raymer to CP Bernson project Coachella Valley Rail Service 

should explore possibility of planning a connector to Redlands Rail via California St. in 

Redlands to provide better service/access to San Bernardino, Pomona, and San Gabriel 

regions Bike accessibility should be analyzed for a minimum radius of two miles, include 

Class IV facilities LA-CV rail should study California Street Connector in Redlands as integral 

part of the proposal, be willing to use money to mitigate UP elsewhere LancasterBakersfield should see further study including double-tracking UP to account for potential 

change in HSR schedule DMU for Rosamond-Lancaster service? Rail service to Imperial 

Valley, possibly by extending Coachella rail Increase funding toward speed and service 

improvements to expedite EIS of benefits of CAHSR, build ridership to further support 

capacity increase

Comment noted. The 2016 RTP/SCS includes $38.6 billion for passenger rail capital 

projects and $15.7 billion for operations and maintenance. This investment includes 

capital projects to improve passenger rail infrastructure to improve speed and service 

levels, and safety. The operations and maintenance investment includes paying for higher 

train volumes allowed by these capital improvements. SCAG works with its six member 

county transportation commissions to develop the transportation investment strategies in 

the 2016-2040 RTP/SCS. Passenger rail services, including alignments, routes and station 

locations are determined through a bottom-up planning process led by these commissions.

Submitted by Inland Empire Biking Alliance Submittal 16329 Related Documents Link

16329.01 Our letter is in response to the Draft 2016 Regional Transportation Plan/Sustainable 

Communities Strategy document that has been released and available for review. We have 

reviewed the document and have developed comments in response to what is and is not 

proposed. There are several highlights to be noted, including the regional network of nonmotorized paths. However, we are also disappointed by quite a lot of the proposals and are 

especially flummoxed to see that more is not being done to encourage the use of bicycles 

for commuters. As cities and regions around the world continue to provide ever-increasing 

amenities for bicyclists and are seeing success in achieving reductions in congestion and 

improved air quality due to increased use of bicycles, it is inconceivable as to why a much 

stronger promotion of bicycling as a solution to the region’s problems is not being pursued 

in 2016. Such an oversight is inexcusable and represents a failure of vision and leadership at 

several levels.

Comment noted. The plan supports bicycle commuting in several ways. It invests $2.2 

billion in First/Last Mile strategies that encourage bicycling and walking to transit. It 

invests $3.7 billion in local bikeways (fully building out most local bicycle plans), Regional 

Bikeways and Regional Greenways. This build-out of the bikeway network develops 

bikeway density at the local level and regional connectivity that encourages commuting as 

well as recreational/utilitarian bicycling. SCAG's safety and encouragement campaigns 

continue to focus on safety, and encouragement, including at the employer level to help 

increase the number of bicycle commuters. SCAG's land-use strategies include building 

higher density housing near major transit stations and urban centers, reducing the 

commute distances for many resident to that which may be walkable or bikeable, 

particularly with transit.

16329.02 The Active Transportation (AT) Appendix provides a little depth to what is otherwise a topic 

that receives far too little attention in the 2016 RTP/SCS. However, while the Appendix 

paints a picture of a blossoming and encouraging environment for active transportation 

and bicycling in the SCAG region, it is short on the details pertaining to planning and 

funding, especially for the Inland Empire.

Comment noted. SCAG's Active Transportation Appendix incorporates all published local 

active transportation plans, including those from Imperial County, Western Riverside 

County, Coachella Valley and San Bernardino County. The Active Transportation Appendix 

also notes that $12.9 Billion can be allocated to active transportation through several 

categories. Local jurisdictions are responsible for implementation, and what sources of 

funding will be used.

131
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Submitted by Inland Empire Biking Alliance Submittal 16329 Related Documents Link

16329.03 Turning to the Project List Appendix also is exceedingly light on specifics, especially of the 

greenway network laid out in Exhibit 12 Regional Bikeway Network of the AT Appendix. 

While a few trails a identified, they are absolutely dwarfed by plans to increase automobile 

capacity and the actual word “greenway” appears only twice in the entire Project List 

Appendix; Figure 1. Additionally, it’s uncertain how many of the few trails identified will 

provide linkages that aren’t primarily recreational in focus.

Comment noted. The six county SCAG region is a vast and diverse region, geographically as 

well as demographically. Accordingly, the 2016 RTP/SCS recognizes that a "one size fits all" 

approach will not work for our region. So, the plan is multi-modal and aims to address 

transportation needs of all segments of our society across our expansive region by 

expanding and enhancing travel choices. The plan creates opportunities to engage in a 

healthy and active lifestyle through a significant increase in investment in Active 

Transportation modes. At the same time, the plan also recognizes that over 90% of the 

trips will continue to rely on our roadways, particularly in places like Riverside and San 

Bernardino counties. So, strategic improvements to our roadways to improve safety and 

congestion must be a part of any sensible long term plan. In addition, investments to our 

roadways also serve to benefit other modes including transit and active transportation. 

Furthermore, it should be noted that many of these roadway improvement projects are 

part of a commitment made by the counties to their residents in the passing of local 

option sales tax measures that fund many of these projects. In addition, active 

transportation plans from local jurisdictions are included, beyond the project listings 

provided by the CTCs. These include the Imperial County Bicycle Plan, Western Riverside 

County Non-Motorized Transportation Plan, Coachella Valley Non-Motorized 

Transportation Plan, CVLink, and the San Bernardino County Non Motorized 

Transportation Plan.

16329.04 Other issues with the AT Appendix appear early on. Per CA Streets & Highways Code 

§890.3, bicyclists traveling for transportation purposes beyond just work are still 

considered commuters. Yet, the document attempts to split commuters into two separate 

groups of people going to work and people biking for other transportation-related reasons 

when the reality is that no division is needed. All bicyclists traveling for transportation, 

whether heading to work or going to a store/school/etc. on a “utilitarian” trip all have the 

same goal and desire from the system: to be able to travel to their destination in as direct a 

journey as possible with as few stops as possible. Trying to dissect commuters into two 

separate subgroups and is unnecessary and does a disservice to all. All wasn’t doom and 

gloom. We were inspired by the Level of Traffic Stress ranking and models presented in 

Table 1 of the AT Appendix. It serves as great model to adopt and to strive toward. SCAG 

policies need to be updated to include LTS2 bikeways as the default. Additionally, SCAG and 

the member jurisdictions must set a goal of ensuring that all residents live a maximum of a 

mile from a LTS2 bikeway within five years, a half mile within 10 years, and a quarter mile 

by the horizon year. This standard needs to also extend to new developments to ensure 

that they either fall within the limits or build the facility as part of construction. These 

facilities must also connect the communities to others surrounding and to the greater 

region as a whole. Cul-de-sac developments should be exploited to provide connectivity for 

non-motorized users by way of an off-street network that provides greater freedom of 

movement than driving on the road would.

Comment noted. It is recognized in the plan that one trip can involve several purposes and 

no one fits neatly into one category. The text has been updated to reflect that. As SCAG 

and its member communities develop implementation plans, and update local active 

transportation plans, various performance metrics and standards will be developed. 

However, local jurisdictions have final implementation authority over building LTS 

networks.

132
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Submitted by Inland Empire Biking Alliance Submittal 16329 Related Documents Link

16329.05 We also have several other comments, grouped together below based on the page where 

they are found. Page 5: · more encouragement of bike boulevard treatments · Illustration of 

Class IV bikeways is inaccurate, would be more appropriate for use for Class IIs Page 6: · 

Roundabouts as an effective intersection and should be encouraged as default at all 

intersections, especially as part of new construction · Remove/disallow free right turn lanes 

· Complete Streets strategies need to go a step further beyond just "allowing" or "enabling" 

access by removing car-centric designs driven by LOS and establishing metrics such as 

people per hour to determine success Page 7-8: Land use · Cul-de-sac can be open and 

include connections for non-motorized users · Disincentives driving Safety (page 8-9) · 

Increase in injuries should be addressed, but in itself is not as problematic if participation is 

increasing faster · Addressing hotspots or common factors should be focus · Lack of lighting 

identified, is a real issue in Inland Empire, yet no concrete steps identified for addressing 

that problem Existing bikeways (page 15-19) · Inland Empire needs to focus on more 8-80 

facilities · Greater use of Class IV facilities · Class III bikeways on arterials cannot be 

considered anywhere near adequate, should barely be considered bikeways · Much more 

attention needs to be paid toward improving connections among IE cities and especially 

between the two counties · Bike parking is extremely lacking, more bike corrals need to be 

encouraged, especially in new construction

Page 5 - Class IV bikeways graphic has been revised. Page 6 - Revised Intersection 

Treatment, new bullet added: "Roundabouts on low-speed streets (slows traffic, but can 

improve traffic flow)" - Local Jurisdictions have sole authority over allowing free right turn 

lanes. - Complete Streets Strategies. Comment noted. Changes in California Law will 

change how LOS is stressed. Page 7-8 - Comment noted Page 8-9 - Comments noted. 

Review of safety data indicates the majority of bicycle collisions occur during daylight 

hours. Data includes street light conditions, but does not clearly identify bicycle lighting 

Pages 15-19 Comments noted.

16329.06 The bicycle can be one of the most effective methods of dealing with congestion in the 

majority of the SCAG region. With a capacity that is several multiples of the hourly capacity 

of a vehicular lane, encouraging biking provides what is probably the best return on 

investment for increasing capacity. While regional work commutes may stretch longer than 

many people are willing to ride, bicycles should still be integral to strategies to reduce 

motor vehicle travel. Shorter trips to stores, appointments, and especially of parents taking 

children to school can be greatly reduced, freeing up roadway capacity for people driving 

for longer distances that are infeasible to bike. Additionally, improving connections to 

transit, including parking at transit, is integral to providing options for those who are 

traveling longer distances. Unfortunately, there is much work to be done to bring the 

Congestion Management Appendix up to snuff in regards to using bikes to their fullest 

potential. However, the good news is that a few small changes would greatly address that 

issue. We are identifying them below. Their inclusion in the final document will go far 

toward ensuring that this oversight does not continue. - MULTI-MODAL PERFORMANCE is 

identified as being measured, but no mention is made about it being tracked over time and 

is mum in regards to active transportation. It needs to be changed to explicitly identify that 

it will be tracked over time and that active transportation will be part of it. - Change the 

word “and” in TRANSPORTATION DEMAND MANAGEMENT (TDM) to “by”. - Add a metric 

that measures Active Transportation to the Mobility and Accessibility portion of the 2016 

RTP/SCS Performance Measures identified in Table 1.

Comment noted. SCAG's Congestion Management Process, as detailed in the Congestion 

Management Appendix of the 2016 RTP/SCS, includes measuring Active Transportation 

Measures and tracking these measures over time. These are detailed on page 7 of the 

appendix and include measuring and tracking modal share, and measuring and tracking 

the mileage of bicycle facilities (Classes 1, 2 and 3).

133
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Submitted by Inland Empire Biking Alliance Submittal 16329 Related Documents Link

16329.07.1 Perhaps the most perverse of all the Appendices is the one dedicated to Highways and 

Arterials. Despite all the proposals and platitudes to change included throughout the 

RTP/SCS and this very Appendix, a closer read through it and the Project List reveal the 

truth: it’s almost all just doublespeak for widening roads and continuing the failed strategy 

of attempting to build out of congestion with wider roads. This is especially true in regards 

to the Inland Empire, as the vast majority of the projects identified and expenditures 

planned for Riverside and San Bernardino counties all start with “widen”, despite the Inland 

region already failing to even maintain a good state of repair on what exists. That must be 

improved before expansion occurs. While there is potential for the widenings to serve all 

users, it requires that strong complete streets policies that truly serve, not just 

accommodate, all modes be in place. Such policies would focus on making sure that moving 

people, not cars, is the primary concern. We have several Guiding Principles · System 

monitoring needs to include measurements of active transportation

Comment noted. The six county SCAG region is a vast and diverse region, geographically as 

well as demographically. Accordingly, the 2016 RTP/SCS recognizes that a "one size fits all" 

approach will not work for our region. So, the plan is multi-modal and aims to address 

transportation needs of all segments of our society across our expansive region by 

expanding and enhancing travel choices. The plan creates opportunities to engage in a 

healthy and active lifestyle through a significant increase in investment in Active 

Transportation modes. At the same time, the plan also recognizes that over 90% of the 

trips will continue to rely on our roadways, particularly in places like Riverside and San 

Bernardino counties. So, strategic improvements to our roadways to improve safety and 

congestion must be a part of any sensible long term plan. In addition, investments to our 

roadways also serve to benefit other modes including transit and active transportation. It 

should be further noted that we have more than doubled our investments in Active 

Transportation since the adoption of 2012 RTP/SCS to almost $13 billion. Our investments 

in Passenger Rail, Transit and Active Transportation together account for more than 50% of 

our investments in the 2016 RTP/SCS. Furthermore, with the renewal of Deputy Directive 

64-R2, Complete Streets - Integrating the Transportation System, Caltrans has placed an 

even greater emphasis towards the consideration of pedestrians and bicyclists throughout 

all phases of a project. Therefore, it is only a matter of time before complete street ideals 

are fully integrated as part of the capital improvement projects. It should also be noted 

that many of these roadway improvement projects are part of the commitment made by 

the counties to their residents in passing the local option sales tax measures that fund 

many of these projects. As SCAG and its member communities develop implementation 

plans, and update local active transportation plans, various performance metrics and 

standards will be developed. SCAG is working with partner agencies to improve 

measurement and documentation of active transportation trips in the region, including 

better documentation of active transportation in the Federal Transportation Improvement 

Program (FTIP) submittals, including active transportation as part of larger infrastructure 

or maintenance projects.

16329.07.2 · Mention at least one active transportation-oriented TSM Active Transportation is considered part of a Transportation Demand Strategy (TDM), not a 

Transportation System Management (TSM). TDMs provide alternatives to peak period 

single occupancy vehicles, such as transit, walking or biking,, telecommuting and flexible 

work-shifts, thereby reducing the demand for automobile driving. TSMs are about 

reducing congestion through the transportation system. TSMs can include traffic signal 

synchronization, freeway on-ramp metering, eliminating bottlenecks on freeways and 

emergency freeway response. The 2016 RTP/SCS Active Transportation Appendix 

incorporates regional trip strategies, short trip strategies and transit access strategies all 

considered transportation demand management.

16329.07.3 · All capacity increases MUST include increase in transit and active transportation as well 

and cannot be dependent on only occurring "where feasible". If transit and active 

transportation are “not feasible”, there's really no reason for an expansion.

Comment noted.

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Submitted by Inland Empire Biking Alliance Submittal 16329 Related Documents Link

16329.07.4 · ALL streets are for ALL users, complete streets CANNOT rely only on being done "where 

feasible and practical". They MUST be included as the guiding principle for ALL projects 

with robust opt-out clauses based on the design life of the facility in question.

Comment noted. SCAG recognizes the context of the roadway as a consideration for the 

type of complete street treatment. Some complete streets treatments may not be feasible 

(e.g. a bike lane on a freeway), while others may be feasible (e.g., a separated bikeway 

next to a freeway).

16329.07.5 Corridor Mobility and Sustainability Improvement Plans · "optimize corridor performance" 

needs to ensure that corridors are optimized for ALL modes · CSMPs must have a complete 

streets approach with strong exception clauses to ensure that easy outs can’t occur 

Additional System Management Initiatives needs to include greater focus on transit signal 

priority Arterials should carry less of overall traffic, more of transit/active traffic 

Performance Results · Crucial error, they must NOT be solely based on vehicle-hours of 

delay · Performance results MUST include the currently glaringly absent measurement of 

delay incurred by users traveling by active transportation and transit in the analysis

Comment noted.

16329.08 We agree with the reasoning that went behind the name of this Appendix. Bicycles are by 

no means a new invention, but they continue to hold an extremely large potential in 

helping SCAG and its member jurisdictions address the mobility challenges and 

opportunities that face the region. We would encourage that more experimentation be 

included, especially of parking opportunities with transit. There should be a much greater 

focus on increasing access to transit all over the region as well to ensure that it is easily 

accessible by all.

Comment noted.

16329.09 The Performance Measure Appendix is another window into the lip service being given to 

alternative solutions by the RTP/SCS. Too many of the metrics proposed are car-centric and 

are just a continuation of flawed policies of the last half-century. Despite the passage of SB 

743 in 2013 and continual work by the State on an alternative to LOS, it is apparent that 

trying to make sure that there’s space for everyone to drive at 65 MPH and be at the front 

of every queue has played a large role in guiding the parts of the Plan, especially in the 

Inland Empire. With continued admission on all fronts and levels of government that 

building bigger roads only results in more people KSI, it is inexcusable to see the magnitude 

to which LOS-based “capacity” is being promoted by a Plan that aims to be sustainable. 

Introduction · Maximize mobility for people and goods · Maximize productivity of 

transportation system <-- arterials is not the way · Make the existing environment also 

provide better bike/ped · Mobility and Accessibility metric needs to address delay incurred 

by transit and active transportation users 2016 RTP/SCS Outcomes & Performance 

Measures · Reliability needs to include a metric to measure variability of travel time for 

transit and active transportation · Mobility MUST include a measurement of Person Delay 

for transit Performance Measure for On-Going Regional Monitoring · Vehicle delay and nonrecurrent delay cannot be the only measures used to determine performance · Delay for 

travelers going by active means or transit MUST also be included · Inexcusable that Plan will 

only improves biking mode share by 0.2% over 25 years · Needs to include a metric 

measuring how many residents live within 1/2 mile of a maximum LTS2 bikeway · Exhibit 4 

is laughably unrealistic without significant investments in alternative transportation far 

beyond what is outlined by the Plan

Comments noted. Thank you for taking the time to review and comment on the 

Performance Measures appendix to the draft 2016 RTP/SCS. Regarding SB 743, SCAG has 

been coordinating closely with the Governor's Office of Planning and Research (OPR) to 

ensure that the update to the CEQA Guidelines is conducted in a manner that will ensure 

successful implementation throughout the SCAG region. In accordance with SB 743, motor 

vehicle delay will no longer be considered a transportation impact under CEQA. 

Implementation of SB 743 is designed to encourage more transit-oriented, mixed-use 

development in centrally located areas, as well as promote the development of bicycle and 

pedestrian infrastructure and amenities within these highly accessible areas, thereby 

reducing regional greenhouse gas emissions. These same regional sustainability goals are a 

primary focus of the 2016 RTP/SCS and of the range of performance indicators that 

support it. We agree that enhanced performance monitoring metrics for our transit system 

and active transportation infrastructure are desirable to ensure we stay on track toward 

achieving our regional sustainability goals. SCAG will continue to work with our state, 

regional, and local partners to seek and incorporate improved monitoring methodologies 

in these areas as they become available.

135
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Submitted by Inland Empire Biking Alliance Submittal 16329 Related Documents Link

16329.10 In conclusion, we are not confident that the current Draft SCAG 2016 RTP/SCS will be 

beneficial for many bicyclists of the Inland Empire. Many currently quiet roads are slated to 

be ballooned to outrageous proportions, degrading the LTS of the riding conditions and 

leaving bicyclists without reasonable alternatives. Though the Plan includes many 

comments and possibilities for what could occur in the future, the Inland Empire is left and 

decidedly stuck in the height of car-centric planning and design. This needs to be corrected 

and addressed by both SCAG and the member jurisdictions. As the Inland Empire continues 

to grow, it cannot continue to be paved over in a bid to keep cars moving. Other measures 

need to be explored to their fullest extent, including bicycles. With much developable 

opportunity still existing, the opportunity exists to provide ideal provisions from inception. 

We hope to see those used to their fullest extent to provide a model environment for the 

region, nation, and even the international community. But it requires a vision of 

improvement. We hope that vision can become a reality.

Comment noted. The Plan Implementation section of the Active Transportation Appendix 

(Page 69) delineates actions SCAG will take in collaboration with stakeholders and local, 

state and federal partners to help implement the Active Transportation component of the 

2016 RTP/SCS. The Appendix also encourages local jurisdictions to incorporate active 

transportation into new road construction as well as maintenance. However, final 

implementation decisions are at the local jurisdiction level.

Submitted by John Wayne Airport Submittal 16219 Related Documents Link

16219.01 In reviewing the Draft 2016 RTP/SCS, it appears that most of the information accurately 

reflects the JWA data and information provided to SCAG. However, we request correction 

to two items as follows: 1. In the Draft 2016 RTP/SCS Aviation and Ground Access Appendix, 

page 21, it is stated that John Wayne Airport has thirteen bridged gates that accommodate 

aircraft design group (ADG) IV aircraft, specifically the Boeing 757 aircraft. Although that is 

correct from a gate design standpoint, it is critical to note that currently only six of JWA’s 

twenty bridged gates are actually used to accommodate a 757-200 aircraft. This is the 

result of a gradual phasing out of the aircraft by the airlines, the age of the aircraft, and the 

lack of future production. Therefore, it is likely that even fewer than six JWA gates will be 

used for this ADG IV aircraft in the future. Because of the document’s assumptions related 

to existing and future JWA gate accommodations for the 757-200 aircraft, the JWA terminal 

capacity appears to be overestimated. Specifically, page 21 states that based upon the 

estimated maximum number of operations per gate, average seat capacity and load 

factors, the existing JWA terminal would have a capacity of 16 million annual passengers 

(MAP). However, based upon analysis done in JWA’s 2014 Capacity Analysis Technical 

Report (AECOM 2014), which was provided to SCAG, terminal gate capacity would be 

exceeded at approximately 12.3 MAP. We therefore request that the JWA terminal capacity 

be reevaluated and corrected based upon the JWA 2014 Capacity Analysis Technical 

Report.

Comment noted. The comment is correct that the 757 aircraft is no longer in production 

and likely to be removed from airline fleets as the existing planes age, new ADG III aircraft 

such as the Boeing 737MAX-9 and the Airbus A321neo will have passenger capacities 

similar to or exceeding the 185 seats assumed for ADG IV aircraft in the analysis. 

Therefore, the estimate in the RTP is reasonable as an upper bound on the capacity of 

John Wayne Airport. Based on the airfield capacity, the RTP/SCS assumed an overall 

airport capacity of 12.5 MAP, which is only slightly greater than the 12.3 described in the 

comment.

16219.02 2. On page 34 of the Draft 2016 RTP/SCS Aviation and Ground Access Appendix, the text 

states, “John Wayne Airport is located in the City of Santa Ana, in Orange County, near the 

cities of...” Please correct this to read, “John Wayne Airport is located in unincorporated 

Orange County, near the cities of...”

Comment noted. Appropriate edit has been incorporated into the Final 2016 RTP/SCS.

136
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Submitted by La Habra 2025 Submittal 16163 Related Documents Link

16163.01 The 2012 RTP/SCS provided an important stepping stone for the 2016 Plan. In previous 

Plans, natural lands and farmlands were handled under the banner of “land use.” In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn’t be overlooked. We 

believe the opportunity before you isn’t to “plan for” the future of open space in the 

region—as that’s what you’ve been doing since the 2012 Plan. Instead, we believe SCAG 

can now start “implementing” a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. We and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation programs. Your coalition is 

encouraged to participate in the effort.

16163.02 The Plan outlines that the region anticipates an additional 3.8 million people by 2040 

providing increased pressure on our existing parkland. Studies document that many 

communities in the Southern California region already do not have enough parkland as 

outlined by the Quimby Act (3 acres per 1,000 residents). The City of La Habra is 100 acres 

short of meeting its, "2.5 acres of parkland per 1000 people", General Plan requirement. 

Now is the time to acquire more regional open-space. In the future, these regional parks 

will become even more valuable. Throughout the document, the Plan promotes providing 

more access to these existing parks as infill projects are built, but nowhere does it state 

how additional parks will be created. The mechanism is missing. More importantly, these 

city parks are fundamentally different than habitat-focused parks. Usually city and regional 

parks include high intensity recreation oriented activities, like soccer and baseball fields, 

and are turfed. The types of land acquired as mitigation or through local conservation 

efforts typically are focused on preservation of natural habitat and less intensive uses 

(birding, hiking, etc.). In fact, many of these mitigation lands have limited or managed 

public access. Providing “more” access to either high or low intensity parks and/or habitat 

lands may have significant consequences for the land manager. The document needs to 

address the impacts to local parks with increased access from expanding populations. The 

document also needs to address how additional lands will be protected, i.e., what 

mechanism will be used?

Comment noted.

137
holdID Comment Response 

Submitted by La Habra 2025 Submittal 16163 Related Documents Link

16163.03 The current federal transportation bill, FAST Act, supports understanding transportation 

impacts on natural resources. The previous bill, MAP-21, supported restoring and 

maintaining environmental functions (i.e., wildlife corridors) affected by the infrastructure 

projects in the RTP. SCAG has even supported efforts in Los Angeles County to create a 

wildlife corridor over the 101 Freeway. Many efforts are underway across the region to 

connect landscapes to one another. This is very important to the region and its biodiversity. 

Wildlife corridors allow species to migrate and forage and expand genetic diversity. These 

corridors also allow ecosystems to maintain ecological functions, act as sources for 

repopulation after natural disasters such as fire, flood or landslide, and improve the 

resiliency in the face of climate change impacts. The Plan would be stronger if it supported 

the enhancement of and/or protection of documented and regionally significant wildlife 

corridors, especially those that are impacted by infrastructure projects.

Comment noted. The RTP/SCS describes (in Chapter 5) next steps for further developing a 

habitat conservation strategy. Included in the steps is the recommendation to provide 

“incentives for jurisdictions to cooperate across county lines to protect and restore natural 

habitat corridors, especially where corridors cross county boundaries.” The Natural/Farm 

Lands Appendix further supports wildlife corridors in its recommended policies, with the 

specific recommendation to “Encourage and facilitate research, programs and policies to 

identify, protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Additionally, continue support for preserving wildlife corridors and 

wildlife crossings to minimize the impact of transportation projects on wildlife species and 

habitat fragmentation.”

16163.04 Now is the time for a "Regional Bike Trail System Implementation Plan". Comment noted. Once the 2016 Regional Transportation Plan/Sustainable Communities 

Strategy is approved, SCAG will work with stakeholders to begin implementation of active 

transportation strategies.

Submitted by Laguna Canyon Foundation Submittal 16280 Related Documents Link

16280.01 The 2012 RTP/SCS provided an important stepping stone for the 2016 Plan. In previous 

Plans, natural lands and farmlands were handled under the banner of “land use.” In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn’t be overlooked. We 

believe the opportunity before you isn’t to “plan for” the future of open space in the 

region—as that’s what you’ve been doing since the 2012 Plan. Instead, we believe SCAG 

can now start “implementing” a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. We and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16280.02 We are pleased to see an Appendix devoted directly to natural and farmlands protection in 

the 2016 Plan. We are glad that the Plan contains specific strategies addressing natural land 

and farmlands issues. This is certainly a step in the right direction. The culmination of the 

work from the last RTP/SCS is clearly visible in this Draft Plan. SCAG has demonstrated that 

Metropolitan Planning Organizations can play a vital, thoughtful and science-based role in 

mitigating impacts to our natural environment from transportation, infrastructure and 

other development projects. By incorporating natural and farmlands protection strategies 

into your policy document, we believe the many benefits of this broad-based conservation 

approach will be realized sooner than expected. Thank you for your leadership.

Comment noted.

138
holdID Comment Response 

Submitted by Laguna Canyon Foundation Submittal 16280 Related Documents Link

16280.03 Identify a Conservation Mechanism for the Natural and Farmlands Preservation Our 

organization supports the idea that as new growth occurs it should focus on the existing 

infill areas. This is consistent with the finding in the SCAG surveys where respondents 

preferred to see existing urban areas built upon before greenfields are targeted for 

development, especially those at the Wildland-Urban Interface. When developments are 

built in infill areas, it likely relieves pressure from the fringe. However, the Plan fails to 

outline exactly how (or with what mechanism) these fringe lands (or any lands) will actually 

be protected. Just because the pressure is relieved doesn’t mean the land then 

automatically becomes protected. Numerous organizations, ours included, focus their work 

on preservation of important habitat lands. A lot of time, energy, political will, strategy and 

other efforts combine to create a successful conservation transaction that leads to 

permanently conserved lands. SCAG must identify the mechanism, process or plan on how 

the greenfield lands will be protected.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your group is 

encouraged to participate in the effort.

16280.04 SCAG’s Support of Regional Wildlife Corridors The current federal transportation bill, FAST 

Act, supports understanding transportation impacts on natural resources. The previous bill, 

MAP-21, supported restoring and maintaining environmental functions (i.e., wildlife 

corridors) affected by the infrastructure projects in the RTP. SCAG has even supported 

efforts in Los Angeles County to create a wildlife corridor over the 101 Freeway. Many 

efforts are underway across the region to connect landscapes to one another. This is very 

important to the region and its biodiversity. Wildlife corridors allow species to migrate and 

forage and expand genetic diversity. These corridors also allow ecosystems to maintain 

ecological functions, act as sources for repopulation after natural disasters such as fire, 

flood or landslide, and improve the resiliency in the face of climate change impacts. The 

Plan would be stronger if it supported the enhancement of and/or protection of 

documented and regionally significant wildlife corridors, especially those that are impacted 

by infrastructure projects.

Comment noted. The RTP/SCS describes (in Chapter 5) next steps for further developing a 

habitat conservation strategy. Included in the steps is the recommendation to provide 

“incentives for jurisdictions to cooperate across county lines to protect and restore natural 

habitat corridors, especially where corridors cross county boundaries.” The Natural/Farm 

Lands Appendix further supports wildlife corridors in its recommended policies, with the 

specific recommendation to “Encourage and facilitate research, programs and policies to 

identify, protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Additionally, continue support for preserving wildlife corridors and 

wildlife crossings to minimize the impact of transportation projects on wildlife species and 

habitat fragmentation.”

Submitted by Laguna Greenbelt, Inc. Submittal 16281 Related Documents Link

16281.01 It’s time for SCAG to implement a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that should be replicated in Southern California.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your group is 

encouraged to participate in the effort.

139
holdID Comment Response 

Submitted by Latham and Watkins LLP Submittal 16316 Related Documents Link

16316.01 Given the importance of the RTP/SCS for future planning, the designations as to the Chavez 

Ravine property located immediately north of downtown Los Angeles should be clarified. 

We understand that the Draft 2016 RTP/SCS designates much of the Chavez Ravine 

property as Urban land use, with portions Compact land use, and much of the property as a 

2040 Plan High Quality Transit Area. Recognizing that this is an integrated site, SCAG should 

designate the entirety of the Chavez Ravine property as Urban land use and High Quality 

Transit Area. Such designations can encourage opportunities for meaningful transit to the 

area and Elysian Park, as well as support reinvestment in adjacent neighborhoods that have 

been designated as SB 535 Disadvantaged Communities.

Comment noted. SCAG’s SCS is built upon local input from local jurisdictions. 35 “Place 

Types” were utilized in the urban setting design tool (Urban Footprint Scenario Planning 

Model (SPM)). It is the Place Types that factor into the modeling analyses. Land 

Development Categories (LDCs), which "Urban" and "Compact" designations are categories 

of, are utilized in order to describe general conditions within areas of the SCAG region and 

do not play a role in the modeling analyses. LDCs and Place types are utilized because of 

the size of the SCAG region and the variety of land uses. The 35 Place Types were then 

classified into the three LDCs. The "Forecasted Regional Development Types" maps have 

been developed for the purpose of modeling performance. SB 375 legislation does not 

require that a jurisdiction’s land use policies and regulations, including its general plan, be 

consistent with the SCS. City of Los Angeles staff were involved in the review of land use 

designations utilized in the RTP/SCS.

Submitted by Latham and Watkins LLP Submittal 16336 Related Documents Link

16336.01 We commend SCAG for its visionary leadership in developing a regional transportation plan 

and sustainable communities strategy, in particular the theme of “integrating strategies for 

land use and transportation” and focusing new housing and employment around transit. 

Given the importance of the RTP/SCS for future planning, the designations as to the Chavez 

Ravine property located immediately north of downtown Los Angeles should be clarified. 

We understand that the Draft 2016 RTP/SCS designates much of the Chavez Ravine 

property as Urban land use, with portions Compact land use, and much of the property as a 

2040 Plan High Quality Transit Area. Recognizing that this is an integrated site, SCAG should 

designate the entirety of the Chavez Ravine property as Urban land use and High Quality 

Transit Area. Such designations can encourage opportunities for meaningful transit to the 

area and Elysian Park, as well as support reinvestment in adjacent neighborhoods that have 

been designated as SB 535 Disadvantaged Communities.

Comment noted. SCAG’s SCS is built upon local input from local jurisdictions. 35 “Place 

Types” were utilized in the urban setting design tool (Urban Footprint Scenario Planning 

Model (SPM)). It is the Place Types that factor into the modeling analyses. Land 

Development Categories (LDCs), which "Urban" and "Compact" designations are categories 

of, are utilized in order to describe general conditions within areas of the SCAG region and 

do not play a role in the modeling analyses. LDCs and Place types are utilized because of 

the size of the SCAG region and the variety of land uses. The 35 Place Types were then 

classified into the three LDCs. The "Forecasted Regional Development Types" maps have 

been developed for the purpose of modeling performance. SB 375 legislation does not 

require that a jurisdiction’s land use policies and regulations, including its general plan, be 

consistent with the SCS. City of Los Angeles staff were involved in the review of land use 

designations utilized in the RTP/SCS.

Submitted by Leadership Counsel for Justice and Accountability Submittal 16354 Related Documents Link

16354.01 I represent organizations in the Inland Empire and we've noticed that a lot of the strategies 

of models for growth are focused on transit oriented development and high quality transit 

areas which are really fabulous cornerstones for good planning, but somehow don't really 

fit with a lot of these realities in the Inland Empire. In the Inland Empire and it is very well 

noted in the RTP/SCS itself that, you know, we have the worst job/housing balance in the 

region. Inland Empire employees have to travel the farthest distance and we'd like to see 

SCAG prioritize investment in transit. I know that some people think that transit doesn't 

work but transit doesn't work because we don't have the infrastructure in the IE. Only .5 

percent of low income people in the IE actually have access to a decent and efficient transit 

stop. We'd like to see models for growth that can be more adaptable and appropriate for a 

not so-densely populated urban region like Los Angeles. We would like to see something 

like the neighborhood mobility areas or the high quality transit corridors, maybe, adjusted 

to suit the realities of less densely populated regions within SCAG. Growth models, SCAG 

should really uplift best practices throughout the region, specifically, in the Inland Empire 

that show good strategies for smart growth in a rural community like how instant in those 

developments is done in a less densely populated community.

Comment noted. In order to encourage “complete communities” that integrate land use 

and transportation, SCAG introduced two new concepts called “Livable Corridors” and 

“Neighborhood Mobility Areas." These concepts are introduced to give local jurisdictions 

ideas for developing sustainably in other contexts besides dense urban High Quality 

Transit Areas (HQTAs). The Livable Corridors concept features land use strategies that are 

appropriate for lower density growth areas that are served by HQTA bus corridors. The 

Neighborhood Mobility Areas concept features low impact land use strategies and lowcost transportation solutions to replace vehicle miles with low GHG travel modes. SCAG’s 

intention is to assist local jurisdictions by providing a framework and allowing maximum 

flexibility in creating “complete communities”. SCAG will continue to work with the local 

jurisdictions that show interest in implementing the RTP/SCS land use policies by providing 

information and resources to support local planning activities, such as the Sustainability 

Planning Grant Program and the Active Transportation Program.

140
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Submitted by Leadership Counsel for Justice and Accountability Submittal 16354 Related Documents Link

16354.02 How different acceptabilities of ride sharing could be uplifted and folded into a more 

formal transit network so that when we are looking for a different funding sources that 

prioritize transit and development we're not excluding non-traditional forms of transit. 

We're also allowing for our growth models to be reactive and adaptive to the different 

kinds of realities throughout SCAG.

Comment noted. The 2016 RTP/SCS includes investments in a broad array of 

transportation strategies and improvements including traditional ridesharing such as 

vanpooling and carpooling, as well as newer strategies such as car sharing and bike 

sharing. These strategies are detailed in the Active Transportation and first/last mile 

sections of the plan.

16354.03 Another thing that we hear that SCAG did and I have brought this up before and I know 

that your team is really great at looking at different ways of qualifying and identifying 

communities within the subregions; but, again, I do want to bring up the point again that 

the definition of rural of, basically, anything of 2,500 or below is rural and 2,500 and above 

is urban, I think kind of limits the ability for SCAG to really predict growth in this variety of 

communities, right. I don't think an area like Thermal [phonetic] California which is largely a 

farm worker community shouldn't even be qualified as urban. But there are opportunities 

for smart growth, there are opportunities to look at what a neighborhood mobility area 

could look like in a less-densely populated. How do we promote and uplift those strategies 

for growth and invest in an existing communities so that we're not consistently building 

new communities to adapt to where there is transit and we really need better indicators to 

where we need to invest in gaps in our system; right.

Comment noted. The boundary for urban and rural areas in the Environmental Justice 

Appendix was established by the U.S. Census Bureau in the 2010 Decennial Census and 

was updated by Caltrans in consultation with FHWA in 2014. Although this represents a 

reliable geography, SCAG recognizes that the Affordable Housing and Sustainable 

Communities (AHSC) Program does not utilize this same boundary. Additional consultation 

with stakeholders will be considered to reconcile the differences between the AHSC 

guidelines and the U.S. Census Bureau/Caltrans/FHWA. To clarify, the boundary for rural 

areas utilized in SCAG's Environmental Justice Appendix includes all areas with population 

under 2,500. As such, Thermal, Mecca, and North Shore qualify as rural areas. These areas 

also have some of the highest concentrations of minority and low income population in 

the region, and therefore are included in the "Communities of Concern" geography utilized 

in the Environmental Justice analysis of the Plan. In order to encourage “complete 

communities” that integrate land use and transportation, SCAG introduced two new 

concepts called “Livable Corridors” and “Neighborhood Mobility Areas." These concepts 

are introduced to give local jurisdictions ideas for developing sustainably in other contexts 

besides dense urban High Quality Transit Areas (HQTAs). SCAG’s intention is to assist local 

jurisdictions by providing a framework and allowing maximum flexibility in creating 

“complete communities."

16354.04 And we'd like to see strategies that really uplift and prioritize investment in the regions of 

SCAG that are kind of falling behind. I'd also like to see SCAG really address the issue of 

disadvantaged communities in a much flippant [phonetic] and strategic way throughout the 

plan. SCAG houses 68 percent of California's disadvantaged communities it shouldn't be left 

in appendix. Prioritizing and investing in disadvantaged communities throughout our region 

should be part of the plan, it should be an initiative within itself and it should be prioritized 

in all the different areas. And I think SCAG has a lot of jurisdictions that can really 

demonstrate great practices of how to prioritize investments in disadvantaged 

communities.

Comment noted. SCAG will evaluate potential tools to enhance local jurisdiction's 

competitiveness for grants that target disadvantaged communities. The inclusion of 

analysis in the Environmental Justice Appendix that examines demographic trends and 

specifically addresses impacts of the Plan on disadvantaged communities is one step in this 

direction.

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Submitted by Letterly Environmental and Land Planning Management Submittal 16272 Related Documents Link

16272.01 Cameron Ranch is a project located in TAZ 43457100 south of the City of Banning in 

incorporated Riverside County. The project is located on assessor parcel numbers 544-050-

011 and 544-050-006 comprising approximately 630 acres. A notice of preparation to 

prepare an environmental impact report was issued on June 10, 2013 and is attached for 

your reference . An administrative draft environmental impact report is now in 

development. The development application includes a Tentative Tract Map (TTM # 36410) 

and General Plan Amendment (GPA # 996). The development application proposes the 

development of 154 single-family residential lots. It is our understanding that the 

generalized Riverside County growth projections accommodate reasonably foreseeable 

projects and the generalized growth projections are not allocated on a project TAZ basis. 

Please confirm our understanding.

Comment noted. While SCAG received specific TAZ level information from both Riverside 

County and Banning's planning departments during the development of the growth 

forecast, no growth information was received for this particular TAZ (43457100). This 

project was not included in the County's General Plan. SCAG will discuss this project with 

the County/City for future forecast development. We also encourage commenter to 

coordinate with the County and Banning to ensure the project is considered in their 

planning efforts.

Submitted by Local Agency Formation Commission for San Link

Bernardino County

Submittal 16282 Related Documents

16282.01 There are six LAFCOs within the SCAG region: Los Angeles LAFCO, Orange LAFCO, Riverside 

LAFCO, San Bernardino LAFCO, Imperial LAFCO, and Ventura LAFCO. The spheres of 

influence that have been adopted by these LAFCOs should have been considered when 

developing the RTP/SCS. However, neither the 2016 RTP/SCS nor the Draft PEIR takes into 

consideration the spheres of influence for any of the cities and/or special districts within 

the entire region.

Spheres of influence were considered in the development of the 2016 RTP/SCS land use 

and growth forecast in several ways. First, GIS staff collected official SOI boundary files 

from all SCAG region LAFCOs and produced had copy data/map books for each of the 

SCAG region 197 local jurisdictions. All the SOI shape files are available on SCAG's FTP site 

for download. Second, SCAG staff went through with each local jurisdiction on their SOI 

boundary and map when conducting one-on-one meetings with local jurisdictions. Finally, 

TAZs under SOI were given growth priority over non-SOI TAZs and those TAZ level growth 

forecast were also reviewed by local jurisdictions. This forecast was used for the analysis in 

the PEIR.

Submitted by Los Angeles Area Chamber of Commerce Submittal 16273 Related Documents Link

16273.01.2 The RTP/SCS document does a good job of developing long–range regional plans and 

strategies that provide practical movement of people and goods, while enhancing 

economic growth, facilitating international trade and improving the environment and 

quality of life.

Comment noted.

16273.01.3 The Chamber is pleased the RTP/SCS used a transparent, inclusive decision making 

approach that engaged all stakeholders impacted by the RTP/SCS.

Comment noted. SCAG will consider this comment in assessing its outreach activities.

16273.01.4 SCAG’s emphasis on transportation- transit and highways, active transportation, goods 

movement, housing and land use, energy and environment- in addition to workforce 

development, education, innovation and technology address the most significant needs of 

the region.

Comment noted.

16273.01.5 With the goods movement sector contributing to nearly one-third of the regional economy, 

efficient transportation of goods through transit corridors and arterials is especially 

significant in the RTP/SCS to maintain competitive, thriving economy.

The 2016-2040 RTP/SCS identifies nearly $75 billion necessary to continue to move freight 

through 2040. We agree that this is an important contributor to our economy.

142
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Submitted by Los Angeles Area Chamber of Commerce Submittal 16273 Related Documents Link

16273.01.6 We’d like to highlight that with decreasing gas tax revenue for transportation projects, it is 

crucial that funding for transportation projects and revenue for all goals outlined in the 

RTP/SCS be attainable and innovative sources to fund projects, while addressing diverse 

funding streams. Closing the funding gap is paramount to achieving the goals of this plan.

Comment noted. We concur.

Submitted by Los Angeles County - Department of Public Health Submittal 16264 Related Documents Link

16264.01 In the EJ Appendix, SCAG identifies gentrification as an issue in transit oriented 

communities (TOCs) and states that this could cause the displacement of minority and lowincome households. We applaud SCAG for including a performance measure to monitor 

growth in TOCs. However we recommend that SCAG track the number of very low, low and 

moderate income housing units available and constructed as a way of gauging progress 

toward implementation of the 2013-2021 Regional Housing Needs Assessment. As our 

regional Planning agenda we encourage SCAG to work with local jurisdictions on land use 

and affordable housing strategies that prevent and reduce gentrification and displacement 

of minority and low income residents. We encourage SCAG and the Regional Council to 

identify ways to do this within the RTP/SCS or in the work plan to be created upon 

adoption. Technical assistance programs, tools, and policies must be identified to assist 

member jurisdictions in maximizing the benefits of transit investments for housing and 

decrease the potential for displacement of minority and low-income populations. SCAG is 

well positioned to encourage jurisdictions to develop local affordable housing policies near 

transit. For example, the County of Los Angeles is currently developing a comprehensive 

plan to combat homelessness that includes consideration of land use strategies that could 

be adopted by local jurisdictions through the SCAG region. These polices include options 

such as: - An affordable housing benefit fee program, also known as a linkage fee, which 

would charge a fee on all new development to support the production of affordable 

housing. - An incentive zoning and "value capture" strategy based on the concept that 

infrastructure and planning actions such as zone changes can increase land values which 

can be redirected toward the public good, such as affordable housing. - A density bonus 

ordinance that can incentivize the development of affordable housing in exchange for 

greater density. SCAG could play a key regional leadership role in encouraging member 

jurisdictions to develop policies such as these in communities where transit investment 

have or will be made. SCAG could also play a roles at the State level with respect to housing 

policies near transit. Finally, we recommend SCAG convene a task force to assist local 

jurisdictions with best practice tools to address the complex issue of gentrification and 

displacement around transit.

SCAG will consider emerging and persistent regional issues, including suggestions from the 

comment process, and may propose new task forces/sub-committees as needed. In regard 

to strategies for gentrification and displacement, as part of its Environmental Justice 

Appendix SCAG has put together an Environmental Justice Toolbox of possible mitigation 

measures to address potential impacts to disadvantaged communities. On page 195 of the 

appendix, there is a list specifically for potential resources and strategies related to 

gentrification and displacement. Because many of these strategies concern local land use 

decisions, the toolbox strategies are voluntary but SCAG encourages communities to 

consider them as part of the local decisionmaking process along with traditionally 

identified tools, such as density bonus ordinances, to help build affordable housing. At the 

State level, SCAG has been meeting with the California Department of Housing and 

Community Development (HCD) and other stakeholder groups to encourage affordable 

housing near transit and remove or streamline barriers for development.

Submitted by Los Angeles County - Department of Public Health Submittal 16292 Related Documents Link

16292.01 We are pleased to see the inclusion of the Public Health Appendix, which describes the 

impact of different land use and transportation scenarios on public health outcomes such 

as physical activity, chronic disease, and air quality. Furthermore, the inclusion of 

performance measures helps demonstrate the health impacts of the RTP/SCS and measure 

progress as projects are implemented.

Comment noted.

143
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Submitted by Los Angeles County - Department of Public Health Submittal 16292 Related Documents Link

16292.02 The RTP/SCS has the potential to improve health outcomes in our region by planning for 

transportation investments that will improve access to jobs, schools, parks, natural 

environments, nutritious foods, and health care. However, these same transportation 

investments may also create unintended negative health impacts by decreasing housing 

affordability and increasing displacement of minority and low-income residents.

A part of its Environmental Justice Appendix, SCAG has put together an Environmental 

Justice Toolbox of possible mitigation measures to address potential impacts to 

Environmental Justice communities. On page 196 of the appendix, there is a list specifically 

for potential resources and strategies related to gentrification and displacement. Because 

many of these strategies concern local land use decisions, the toolbox strategies are 

voluntary but SCAG encourages communities to consider them as part of the local decisionmaking process.

16292.03 In the Environmental Justice Appendix, SCAG identifies gentrification as an issue in transit 

oriented communities (TOCs) and states that this could cause the displacement of minority 

and low-income households. We applaud SCAG for identifying a gentrification and 

displacement performance measure in the RTP/SCS and for stating that the agency will 

continue to monitor growth in TOCs. However, we recommend that SCAG track the number 

of very low, low, and moderate income housing units available and constructed as a way of 

gauging progress toward implementation of the 2013-2021 Regional Housing Needs 

Assessment.

Jurisdictions are required by State housing law to submit to the California Department of 

Housing and Community Development (HCD) an annual progress report that tracks 

housing building activity by RHNA income category. SCAG acknowledges that this data is 

often incomplete and inconsistently report and represents only a portion of affordable 

housing building activity. Because of this, SCAG is developing a pilot survey to determine 

how to encourage jurisdictions in the region to submit this information on a more 

consistent basis so that there the data is more accurate than what is currently available.

16292.04 We also encourage SCAG, as our regional planning agency, to play a leadership role in 

working with local jurisdictions on land use and affordable housing strategies that prevent 

and reduce gentrification and displacement of minority and low income residents. We 

encourage SCAG and the Regional Council to identify ways to do this within the RTP/SCS or 

in the work plan to be created upon its adoption. Technical assistance programs, tools, and 

policies must be identified to assist member jurisdictions in maximizing the benefits of 

transit investments for housing and decrease the potential for displacement of minority 

and low-income populations. SCAG is well positioned to encourage jurisdictions to develop 

local affordable housing policies near transit. For example, the County of Los Angeles is 

currently developing a comprehensive plan to combat homelessness that includes 

consideration of land use strategies that could be adopted by local jurisdictions throughout 

the SCAG region. These policies include options such as: • An affordable housing benefit 

fee program, also known as a linkage fee, which would charge a fee on all new 

development to support the production of affordable housing. • An incentive zoning and 

“value capture” strategy based on the concept that infrastructure and planning actions 

such as zone changes can increase land values which can be redirected toward the public 

good, such as affordable housing. • A density bonus ordinance that can incentivize the 

development of affordable housing in exchange for greater density. SCAG could play a key 

regional leadership role in encouraging member jurisdictions to develop policies such as 

these in communities where transit investments have or will be made. SCAG could also play 

a role at the State level with respect to housing policies near transit. Finally, we 

recommend that SCAG convene a task force specifically to assist local jurisdictions with best 

practice tools to address the complex issues of gentrification and displacement around 

transit. The task force should include affordable housing experts, transit agencies, city 

officials, public health practitioners, and others.

A part of its Environmental Justice Appendix SCAG has put together an Environmental 

Justice Toolbox of possible mitigation measures to address potential impacts to 

Environmental Justice communities. On page 195 of the appendix, there is a list specifically 

for potential resources and strategies related to gentrification and displacement. Because 

many of these strategies concern local land use decisions, the toolbox strategies are 

voluntary but SCAG encourages communities to consider them as part of the local 

decisionmaking process. SCAG will consider emerging and persistent regional issues, 

including suggestions from the comment process, and may propose new task 

forces/subcommittees as needed. SCAG is also exploring ways to address social equity 

issues, including potential gentrification and displacement, beyond the RTP/SCS process, 

and will continue to work with stakeholders to discuss challenges and potential strategies 

for the SCAG region in affordable housing planning and production.

144
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Submitted by Los Angeles County - Department of Regional Planning Submittal 16254 Related Documents

16254.01 One of the highlights in RTP/SCS 2016 is an emphasis on development along HQTA (High 

Quality Transit Areas). While Transit-Oriented Development (TOD’s) offers great benefits to 

the community and region, it often creates undesired impact, such as displacement, which 

could be mitigated by other policies or strategies. The Los Angeles County will be looking at 

value capture strategies as a way to examine and minimize the impact of displacement 

from TOD. Some examples include: expanding application of density bonus, establishing 

mandatory inclusionary zoning, or building value capture tools into community plans. 

Similar policies and strategies in RTP would help jurisdictions balance between 

development and sustainability. The County’s value captures strategies are outlined in the 

attached Equity report as well as the Board motion on Development and Implementation of 

Equitable Development Tools. We are also open to sharing the process and outcome as we 

move forward with development of these tools.

Comment noted. The 2016 RTP/SCS looks into and analyzes the impacts of TOD, such as 

displacement. SCAG is encouraged Los Angeles County is looking into value capture 

strategies as a way to examine and minimize the impact of displacement from TOD. SCAG 

will welcome the County to share the processes and outcomes of the Equitable 

Development Tools. Beyond the analyses of displacement in "performance areas" 

(contained in the Environmental Justice Appendix), it is the direction of the Regional 

Council to maintain local land use authority, thus including strategies such as density 

bonuses, establishing mandatory inclusionary zoning or building value capture tools go 

beyond SCAG's authority.

16254.02 In terms of Environmental Justice policies, it would be helpful to prioritize grant distribution 

among disadvantaged communities and to provide frameworks for jurisdictional 

collaboration as many disadvantaged communities cross jurisdictional boundaries. It would 

be very helpful to see in RTP tools that identify such communities by various factors 

(something similar to CalEnviroscreen, but more region- or local-specific). The Los Angeles 

County is currently developing an ‘Equity Scorecard’, which would be used in identify 

disadvantaged communities in County areas. If RTP provides guidelines on prioritizing, or 

frameworks for development of such a tool, it would help reduce duplicate efforts by local 

jurisdictions and increase regional consistency.

Comment noted. SCAG will evaluate potential tools to enhance local jurisdictions' 

competitiveness for grants that target disadvantaged communities.

Submitted by Los Angeles County - Metropolitan Transportation Link

Authority

Submittal 16183 Related Documents

16183.01 Pg. 4, column 2, bullet 2 – Reads: “Utilitarian walkers requiring easy, attractive and safe 

access to retail, dining and other attractions.” Suggested edits: Utilitarian walkers requiring 

safe access to vital services including medical, grocery, public transit, child care, retail, and 

other key destinations.

Incorporated suggested edit.

16183.02 Pg. 4, column 2, bullet 3 Reads: “Recreation and fitness pedestrians requiring good quality 

infrastructure for fast walking/jogging.” Suggested edits: Recreation and fitness pedestrians 

requiring safe and unobstructed quality infrastructure for unimpeded walking/jogging.

Incorporated recommended edit.

16183.03 Pg 15 Discussion of LA County does not recognize adopted and current efforts by Metro, 

e.g.: Complete Streets Policy, First/Last Mile Strategic Plan, Bike Share, LA River Bike Path 

Gap Closure, etc. and forthcoming Metro Active Transportation Strategic Plan. Also several 

cities in the San Gabriel Valley have adopted a regional bike plan. The RTP should be 

updated to reflect current activities for LA County.

Inserted language regarding various active transportation planning activities in Los Angeles 

County.

145
holdID Comment Response 

Submitted by Los Angeles County - Metropolitan Transportation Link

Authority

Submittal 16183 Related Documents

16183.04 Pg 15 Bike lockers and secure bike rooms (self-serve and attended) currently exist for long 

term. Need to better define/describe what bike parking stations are as some provide 

additional attended services to support bike commuters such as at El Monte, Long Beach 

and Santa Monica. Pasadena does not have a bike station. Also Burbank, Covina and 

Claremont have self-serve bike stations. Should note to mention that bicycle lockers also 

have issues with maintenance and the required space and footprint they take up. 

Document should also recognize education on how to properly lock a bicycle. Often time 

people use cable locks for locking their bike that are easily defeated. Important for people 

to be responsible for their own property through preventable measures.

Comment noted. Language inserted regarding definitions of racks, lockers and stations. 

Issues of maintenance, and bicycle lock education are beyond the purpose of this 

appendix.

16183.05 Pg. 18 Statement “Bicycle-racks are often located within an office building’s parking garage 

(providing increased security over bicycle racks on public sidewalks)...” This is not 

necessarily true as bike racks at the street level have more “eyes” on them. Whereas, bike 

racks in hidden places such as parking garages can be very susceptible to theft.

Removed language in parenthesis mentioning increased security.

16183.06 Pg. 19 Include 2014 existing LA County bikeway conditions not 2012: Facility Type as of 

2014 Class 1 305.29 Class 2 835.5 Class 3 522.26 Cycle Track 4.2

Comment noted. 2012 is considered the base year for the 2016 RTP/SCS. Therefore, 

county bikeway totals are represented by 2012 totals.

16183.07 Pg. 18 The 2012 National Household Travel Surveys indicated that bike trips for SCAG 

region were calculated at 1.9%. In the 2016 draft it indicates that the bike mode share for 

the CA household survey is 1.12%. This is a significant reduction; please verify that the 

figures are accurate.

Comment noted. Both data sets are correct. The 2012 Regional Transportation 

Plan/Sustainable Communities Strategy used data from the 2008 National Household 

Travel Survey which provided the percentages referenced fro the 2012 RTP/SCS. The 2016 

RTP/SCS uses data from the 2012 California Household Travel Survey. The 2008 data was 

weighted differently (unlinked trips) when compared to the data from the 2012 California 

Household Survey, which was weighted internally by SCAG (linked trips). In addition, the 

region was impacted in 2008 by a rapidly declining economy and high gas prices, which 

may have temporarily spiked walking and bicycling mode share during the survey period.

16183.08 Pg. 20 Same for Pedestrian mode share 2012 NHTS CA SCAG region indicated 19.24% and 

now for draft 2016 it is 16.8%. Please verify accuracy of figures and/or provide discussion 

on reduction/change.

Comment noted. Both data sets are correct. The 2012 Regional Transportation 

Plan/Sustainable Communities Strategy used data from the 2008 National Household 

Travel Survey which provided the percentages referenced fro the 2012 RTP/SCS. The 2016 

RTP/SCS uses data from the 2012 California Household Travel Survey. The 2008 data was 

weighted differently (unlinked trips) when compared to the data from the 2012 California 

Household Survey, which was weighted internally by SCAG (linked trips). In addition, the 

region was impacted in 2008 by a rapidly declining economy and high gas prices, which 

may have temporarily spiked walking and bicycling mode share during the survey period.

16183.09 Pg. 25 “...has developed a bicycle to transit access plan Bicycle Transportation Strategic Plan 

(2006)...” (delete "bicycle to transit access plan" text from this sentence)

Rephrased bullet to read: The Los Angeles County Metropolitan Transportation Authority 

(Metro) developed a Bicycle Transportation Strategic Plan (2006) and is developing an 

Active Transportation Strategic Plan for 2016.

16183.10 Pg. 28 Verify that preliminary cost estimates are carefully identified. For example, $194 

million identified for 755 miles of “Greenways” comes out to $256,954/mile. This is a very 

low estimate for Class 1 and Class 4 bikeway construction costs. Bike path projects 

estimated for FHWA by the UNC Highway Safety Research Center in 2013 were between 

$500K to $4.2 mil/mile (pg. 12).

Comment noted. Corrected Table to read that Greenways Cost estimate is $2.6 Billion and 

Regional Bikeways cost estimate is $194 Million (the two totals were reversed).

146
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Submitted by Los Angeles County - Metropolitan Transportation Link

Authority

Submittal 16183 Related Documents

16183.11 Pg. 28 Total estimate for active transportation needs seem low. Provide details on the 

underlying assumptions. Suggest providing clear performance metrics and benchmarks to 

evaluate how the region is doing to meet the goals laid out in the 2016 Active 

Transportation Plan.

In developing the cost estimates for active transportation needs, SCAG staff reviewed 

recent expenditures and planned/forecast expenditures regarding similar projects for each 

county within the SCAG region. SCAG estimates for 224 High Quality Rail Stations is 

consistent with low estimate per station laid out for the LA County Metro Draft Active 

Transportation Strategic Plan, for capital improvements and maintenance. Because the 

RTP/SCS is a fiscally constrained plan, SCAG was not able to include the high estimate per 

station. Metro will be proposing a more expansive first mile/last mile strategy (than what 

SCAG is proposing) in its Active Transportation Strategic Plan when released. Once Metro’s 

plan is released, SCAG will work with Metro to better integrate the two plans and identify 

additional revenue sources. Bikeway estimates are based on costs for each county, 

recognizing that the cost for a Class 1 bikeway in Imperial County would be different than 

that in Los Angeles County. Metro’s proposed annual Education and Encouragement 

Campaign is significantly larger than SCAG’s planned outreach activities, which is focused 

on Safe Routes to School and SCAG safety/encouragement campaigns (not local 

campaigns). SCAG's Active Transportation Appendix Plan Implementation section (page 69) 

establishes steps SCAG will take to meet the goals of the Appendix. SCAG will develop 

additional metrics and benchmarks as data becomes more available.

16183.12 Pg. 55 (4th paragraph) A “plan” for bike share is cited with no reference. These appear to 

be general statistics for bike share programs worldwide rather than assumptions made for 

a specific plan and should be reflected as such. Reflect information on Metro’s Countywide 

Bike Share Program.

Comment noted. As bike share is a new concept for Southern California, and at the time of 

writing the draft RTP/SCS, local plans were still in development. An overview of the bike 

share concept was included as well as levels of success from similar sized bike share 

programs. Existing language reflects benefits attributed to the similar programs and not to 

any specific bike share plan or project in Southern California. In the final RTP/SCS, 

references were made to established roll outs in Santa Monica, planned roll outs by Los 

Angeles County Metro and Long Beach, indicating that growth of bike share would likely 

expand beyond their initial plans.

16183.13 Pg. 61 Regional bikeways should include those recommended by Metro’s ATSP. Metro's draft ATSP is still in development and will not be released until mid 2016. 

Assuming comment is regarding the 2006 Bicycle Transportation Strategic Plan (BTSP). 

SCAG's regional bikeway network is consistent with the 2006 BTSP. While not specifically 

referencing the 10 year old BTSP, SCAGs Regional Bikeway Network and Regional 

Greenway network include and/or update most gap closures recommended (beginning on 

page 99 of the BTSP), as well as develop defined route structures. Added following 

language to the Active Transportation Appendix: The Regional Greenway and Bikeway 

Networks are developed from local existing and planned bikeways and closing gaps. As 

new bikeways are developed, such as through the Orange County Strategic Bikeway 

Network and the Los Angeles County (draft) Active Transportation Strategic Plan, they will 

be incorporated into the networks.

16183.14 Pg. 20, paragraph 6, last line--states that the scenarios and sensitivity tests yielded a range 

of airfield capacities from 82.9 to 96.6 MAP, but does not state the year(s). Please specify 

the year(s) for the MAP projections.

The airfield capacity range of 82.9 to 96.6 MAP referenced in the comment is an estimate 

of how many passengers the planned ultimate facility (according to approved plans) could 

accommodate. It is not a projection of demand for a future year. Therefore, there is no 

year associated with the MAP range.

147
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Submitted by Los Angeles County - Metropolitan Transportation Link

Authority

Submittal 16183 Related Documents

16183.15 Pg. 5 (Exhibit 3), the I-210 east of Glendora is not included in the Final Primary Freight 

Network, yet SCAG’s many analyses include this stretch along I-210 to I-15 and indicate 

serious congestion. SCAG should address this inconsistency.

Comment noted. The Primary Freight Network is a federal designation based on data 

readily available to USDOT. While the segment of I-210 between SR-57 and I-15 is not 

included in the Federal Primary Freight Network, SCAG and its regional partners consider it 

as an important segment of our goods movement corridor serving both the region and the 

nation. To this end, SCAG will continue including this segment in on-going regional 

transportation system analyses. Please also note that SCAG has submitted corrections to 

USDOT in prior comments regarding the Primary Freight Network.

16183.16 Pg. 13, under “... Drivers”, the Air Quality subject should be expanded to a discussion of 

CO2 emissions concerns and reference SB2, etc., as developed on Page 40.

This section is only intended to be a short description of current issues facing the region 

that are explained later in the document. However, some additional clarifying language 

has been added. 

16183.17 Pg. 44, there is no mention of Cap and Trade Program’s Greenhouse Gas Reduction Fund as 

a funding source for the development of vehicle prototypes and infrastructure 

demonstrations. This should be highlighted as an opportunity for zero-emission technology 

research and development.

Language has been added noting the Cap and Trade program may be a source of funding 

to support new clean technologies.

16183.18.1 Pg. 6 - Additional System Initiatives - Recommend adding Caltrans ATM Study on I-105 and 

the RIITS and IEN Data Exchange efforts.

Comment noted. Appropriate edits have been made to incorporate this comment.

16183.18.2 Overall - Comment - Recommend discussing Freight Signal Priority. Please refer to the Goods Movement Technical Appendix as Freight ITS applications (which 

include Freight Signal Priority) are more broadly addressed.

16183.19 Page 7 - First/Last Mile Strategies - Recommend discussing Ride Sourcing as a potential 

strategy.

Comment noted. Discussion has been added.

16183.20 Page 7 - Automated/Connected Vehicles - Recommend discussing potential impact of 

AV/CV on age profile of licensed drivers.

Comment noted. Discussion has been added.

Submitted by Los Angeles County - Metropolitan Transportation Link

Authority

Submittal 16184 Related Documents

16184.01 Page 9 - ITS-Roadways - Recommend adding discussion on ATM (Active Traffic 

Management) strategies.

Comment noted.

16184.02 There is currently policy language supporting urban greening as a component of a larger 

natural lands strategy. We support this as consistent with Metro’s Urban Greening Plan and 

Toolkit, but would further request that SCAG include in “Strategies, Next Steps and 

Recommendations” a commitment to further integrate greening strategies into regional 

planning efforts.

Comment noted. Text has been revised to reflect the suggestion.

16184.03 Pg. 2, First paragraph under Metrolink--The South Perris connection will be in operation in 

2016.

This comment has been incorporated into the Passenger Rail Appendix.

148
holdID Comment Response 

Submitted by Los Angeles County - Metropolitan Transportation Link

Authority

Submittal 16184 Related Documents

16184.04 Pg. 2, Second paragraph under Metrolink--Metro owns 40% of the Ventura County Line 

within L.A. County. “Much of the track is owned by the the Member Agencies of Metrolink 

and/or the freight railroads.” Suggest referring to the CTCs that are Member Agencies of 

Metrolink as being a Member Agency.

Comment noted. This comment has been incorporated into the Passenger Rail Appendix.

16184.05 Pg. 2, Third Paragraph--Perris Valley will begin operations in 2016. PTC will begin operations 

in 2016.

This comment has been incorporated into the Passenger Rail Appendix.

16184.06 Pg. 4, Second paragraph--Metrolink will be operating the efficient locomotives in 2017. Pg. 

4, First paragraph under Metrolink’s history--The Ventura line started in 2002.

A) This comment has been incorporated into the Passenger Rail Appendix. B) Comment 

noted. The Ventura County Line was one of Metrolink's inaugural lines beginning service 

on October 26, 1992.

16184.07 Pg. 4, Second paragraph under high speed rail--It has been almost 20 years for the 

development of HSR. Pg. 7, In the MOU paragraph--The language should state “$1B from 

Proposition 1A and other funds” That is the language in the MOU.

Pg. 4, Second paragraph - Comment noted. Pg. 7, In the MOU paragraph - Comment noted. 

The text has been edited to be consistent with language in the MOU.

16184.08 Pg. 9 and throughout the document--Should state that the projects are for operational 

efficiency. Although ultimate capacity is a benefit, operational efficiency is the key. Under 

the Master Plan--SCRIP preceded the Master Plan. The Master Plan accommodates SCRIP.

Comment noted. This comment has been incorporated into the Passenger Rail Appendix.

16184.09 Pg. 11, Under the Freight paragraph include language about the agencies owning the right 

of way that the freights operate on as tenant railroads.

Comment note. This comment has been incorporated into the Passenger Rail Appendix.

16184.10 Pg. 13, Add two projects--Bob Hope Airport/Hollywood Way Station; and Bob Hope Airport 

Station Pedestrian Bridge

Comment noted. This comment has been incorporated into the Passenger Rail Appendix.

16184.11 Pg. 18, The Perris Valley Line will open for revenue service in 2016. This comment has been incorporated into the Passenger Rail Appendix.

16184.12 Pg. 24, The pedestrian bridge at the Bob Hope Airport Station is not Phase 2 of RITC. Add 

language about the new Bob Hope Airport/Hollywood Way Station.

Comment noted. This comment has been incorporated into the Passenger Rail Appendix.

16184.13 Pg. 26, The Metro Orange Line is connected to SCRRA in Chatsworth. Comment noted. This section is discussing gap closures, and the Orange Line is discussed 

in the context of the existing service gap between the Metro Orange Line in North 

Hollywood and the Gold Line in Pasadena.

16184.14 Pg. 9, Los Angeles Union Station Master Plan, 1st bullet, add “expanded multi-modal” 

between “new” and “passenger concourse” and replace “the current tunnel” with 

“currently called the “tunnel”” (“a new expanded multimodal passenger concourse (the 

current tunnel currently called the “tunnel”) that would be widened)”

This comment has been incorporated into the Passenger Rail Appendix.

16184.15 Pg. 9, 5th bullet add “accommodating” before “future tracks”—it should read 

“accommodating future tracks and platforms for the CA HSR project”; Pg. 9, 7th bullet 

delete “new and” and replace with “3.25 million square feet of” It should read, “3.25 

million square feet of improved retail and transit-oriented development (TOD) uses.” Pg. 9, 

ADD 8th bullet: “improved pedestrian and bike network”

Pg. 9, 5th bullet - This comment has been incorporated into the Passenger Rail Appendix. 

Pg. 9, 7th bullet - This comment has been incorporated into the Passenger Rail Appendix. 

Pg. 9 ADD 8th bullet - This comment has been incorporated into the Passenger Rail 

Appendix.

149
holdID Comment Response 

Submitted by Los Angeles County - Metropolitan Transportation Link

Authority

Submittal 16184 Related Documents

16184.16 Pg. 12: insert “SCRIP run through tracks and to incorporate the” before larger passenger 

concourse and replace “has been approved” with “was developed”. It should read: “An 

additional component of the work is to study the effects of raising the entire platform areas 

in order to accommodate the SCRIP run-through tracks and to incorporate the larger 

passenger concourse that was developed-as part of the Union Station Master Plan...

This comment has been incorporated into the Passenger Rail Appendix.

16184.17 Pg. 140, RTP ID #1TR1012, California High-Speed Rail Phase I – Env/PE, should have the 

Lead Agency as “California High Speed Rail Authority”. It is currently blank. The completion 

date is listed as 2011, and SCAG may want to update this. Pg. 147, RTP ID # 1122005, SR138 Loop Road – this project is not in the Metro 2009 LRTP, and the Lead Agency is listed as 

“TBD”. This should be clarified that the project is not a Metro-funded project. Pg. 148, RTP 

ID #1C0401, “I-710” project, Lead Agency should read “Los Angeles County MTA”, as this is 

a project from Metro’s 2009 LRTP. Lead Agency is currently blank. Pg. 148, RTP ID # 

1M1002, “I-710 Early Action Projects”, Lead Agency should be “Los Angeles County MTA”, 

as this is a project from Metro’s 2009 LRTP. “Lead Agency” is currently blank. The 

completion year should be “2022” and it is currently “2025”. Pg. 150, RTP ID # 1120005, 

Metro Green Line Extension—this is a project assumed to be funded with innovative 

financing, and not a constrained project in Metro’s 2009 LRTP. Pg. 150, RTP Project # 

1TR1011, West Santa Ana Branch ROW Corridor -- this is a project assumed to be funded 

with innovative financing, and not a constrained project in Metro’s 2009 LRTP. Pg. 154., RTP 

#10M08D01, this is TIP #LA0G159, and is nearly complete. This should be moved into the 

TIP section. Pg. 157, RTP #UT101, Metro Purple Line Westside Subway Extension Section 3 – 

Century City to Westwood/VA Hospital—the completion year should be 2035 (12/31/2015), 

and the Project Cost is $2,157,100 (YOE). Also, this listing is duplicative of a listing on page 

158. Please correct and list only once. Pg. 157, RTP ID # 1TR0101 (TIP # LA0G1162), Airport 

Metro Connector, the completion date is 07/01/2023. Pg. 158, RTP ID #1TR1003 (EIR is TIP 

# LA0G642) – This appears to be a duplicate of the incorrect entry listed above on page 

157. There needs to be only one “Metro Purple Line Subway Extension Section 3”, 

completion date of 12/31/2035 with a project cost of $2,157,100. Please delete one of the 

duplicates. Pg. 158, RTP ID #1TR1017 – please delete this project. Pg., 158, RTP ID 

#1TR1020 – Please delete this project.

Comment noted. We have addressed all modification requests to the Project List as 

submitted by county transportation commissions through the standard RTP long-range 

project list modification and FTIP database update processes.

150
holdID Comment Response 

Submitted by Los Angeles County - Metropolitan Transportation Link

Authority

Submittal 16184 Related Documents

16184.18 General – The SCS Technical Appendix provides a clear and sound description of how the 

2016 RTP/SCS complies with SB 375, both from a content and process standpoint. We are 

confident that the Plan as presented will be approved by ARB. Metro explicitly partners 

with SCAG on SCS development and implementation through the SCAG/Metro Joint 

Resolution and Work Program, most recently adopted by the Metro Board of Directors on 

May 28, 2015. The Plan and Appendix could be strengthened through further discussion of 

Joint Work Programs, including acknowledging completed efforts and identifying future 

initiatives that will advance the goals of the Plan. For example, the scenario planning 

exercise described in the appendix prompts preliminary steps in addressing sea level rise 

and other climate vulnerabilities as well as habitat protection needs. Through the plan, 

SCAG should describe and commit future planning activities in these areas or others. 

Similarly, the Metro Board has adopted various sustainability policies acknowledging 

climate adaptation needs, and would suggest that sea level rise and climate vulnerabilities 

be explicitly included as priorities in the adopted plan, as opposed to a factor in a scenario 

exercise that does not influence policy and future activities. Also, of note, the updated 

SCAG/Metro Joint Work Program commits a coordinated effort on deploying future 

planning funding, particularly from SCAG’s Sustainability Planning Grant program. We 

would request that the Plan clearly acknowledge this commitment and further commit that 

future planning funding will be allocated in consultation with Metro such that priority 

activities are given consideration, and that local planning projects are structured 

appropriately for near term funding opportunities such as the Cap-and-Trade Affordable 

Housing and Sustainable Communities Program, the California Active Transportation 

Program, and the Metro Call For Projects.

Comment noted. The Regional Council supports the Joint Work Programs between SCAG 

and each County Transportation Commission as collaborative mechanisms for the 

implementation of various land use and transportation policies in the 2016 RTP/SCS. SCAG 

staff included sea level rise and climate vulnerabilities as a part of the scenario exercise as 

a way of introducing these issues to the SCAG Regional Council and Policy Committees. 

There is a large portion of SCAG's region not directly affected by sea level rise, so there is a 

need to educate and bring these items up for discussion and consideration. Vulnerability 

and risk assessments at the regional level will require collaboration and commitment from 

a variety of stakeholders. SCAG is encouraged the Metro Board has adopted various 

sustainability policies acknowledging climate adaptation needs, and would like to conduct 

further work on these items via the SCAG/Metro Joint Resolution and Work Program.

16184.19 Among other items, Metro collaborates with SCAG on the development and 

implementation of the First/Last Mile Strategic Plan. As such, we appreciate the emphasis 

on first/last mile implementation (transit/active transportation integration) with the Draft 

RTP/SCS and the SCS Technical Appendix. The appendix could do more to acknowledge and 

be consistent with Metro’s recent work on this subject. In particular the estimated regionwide funding need for first/last mile, as reflected in the Active Transportation Appendix is 

substantially lower than our own estimates for Los Angeles County alone prepared for the 

current Active Transportation Strategic Plan effort. We encourage SCAG to coordinate with 

us on this aspect of the Plan.

SCAG estimates for 224 High Quality Rail Stations are consistent with low estimate per 

station laid out for the LA County Metro Draft Active Transportation Strategic Plan, for 

capital improvements and maintenance. Metro will be proposing a more expansive first 

mile/last mile strategy in its draft Active Transportation Strategic Plan when released. 

Once Metro’s plan is released, SCAG will continue to work with Metro to better integrate 

the two plans.

16184.20 We appreciate the inclusion emerging transportation technologies within the scenario 

planning exercises, as this is consistent with Metro’s policies and work products including 

the Countywide Sustainability Planning Policy, First/Last Mile Strategic Plan and emerging 

pilot projects. As a technical matter, we are unclear on why the use of ride share and ride 

hailing services would be reflected in a direct reduction in VMT. It would seem more 

supportable through data as well as more consistent with policy goals to reflect these travel 

choices through an assumed reduction in vehicle ownership.

Comment noted. Car sharing was analyzed using an off-model methodology developed by 

the Metropolitan Transportation Commission (MTC) for the Plan Bay Area 2013, refined 

and validated by the California Air Pollution Control Officers Association (CAPCOA), and 

used by the San Diego Association of Governments (SANDAG) for that agency’s “San Diego 

Forward: The Regional Plan.” SCAG staff developed a similar off-model methodology for 

ridesourcing (ride hailing). We agree that eventually these new transportation modes will 

be best modeled through behavioral choices made in the transportation model. There is 

growing evidence of correlation between urban form to household vehicle ownership and 

subsequent travel behavior. However at this time there is insufficient data to establish 

precise numerical assumptions for use in the model. We look forward to collecting more 

data as the next plan is developed.

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Submitted by Los Angeles County - Metropolitan Transportation Link

Authority

Submittal 16185 Related Documents

16185.01 Pg. 10, near bottom of page (concept also applies to page 26): New Starts: “As with the 

FHWA sources, fuel consumption declines by 0.9 percent (in real terms) annually.” We 

would like to suggest it state that, “As with the FHWA sources, fuel consumption declines 

by 0.9 percent (in real terms) annually making it increasingly difficult for Congress to back 

fill with general funds.” Pg. 23, top of page: ...State Transit Assistance (STA) are included 

under this source (meaning Local Agency Funds for LA County). STA should be included 

under State sources on page 24.

Although the United States Congress has authorized $141.1 billion in transfers from the 

General Fund to the Federal Highway Trust Fund to keep it solvent, the 2016 RTP/SCS does 

not assume that Congress will continue to make these transfers as part of the core 

revenue projections. Rather, the Plan includes forecasted revenues from new funding 

sources that are reasonably expected to be available. Reasonably available sources include 

short-term adjustments to gas excise tax rates and the long-term replacement of gas taxes 

with mileage-based user fees (or equivalent fuel tax adjustment). The language on page 23 

has been revised to remove State Transit Assistance (STA).

Submitted by Los Angeles County Business Federation Submittal 16286 Related Documents Link

16286.01.1 BizFed and its members are pleased to see the attention paid to the process and vision of 

the region’s most influential plan that affects sectors in transportation, land use and 

development, energy and environment, and technology and innovation and workforce 

development and education.

Comment noted.

16286.01.2 We want to call special attention to SCAG’s RTP/SCS vision as it relates to goods 

movement/freight/logistics. These sectors represent one-third of the state’s economic 

growth, and addressing the goods movement corridor bottlenecks are key to enabling this 

growth to continue.

The 2016-2040 RTP/SCS makes identification of major truck bottlenecks a priority and 

allocates nearly $5 billion in the Plan to address them.

16286.01.3 Paralleled investments in transit and development will be the catalysts in reducing overall 

emissions and spurring economic growth throughout the region.

Comment noted.

16286.01.4 Targeting the growth in the region’s housing, transportation, and business sectors to be 

most beneficial to ensure a stable and thriving economy is the top priority. Then the 

attention paid to the “haves and have nots” in our region was excellent in showing a desire 

to formulate a regional plan that provides a positive economic impact for everyone.

Comment noted.

16286.01.5 Additionally, we are pleased to see the inclusion of technology neutral solutions in the plan. Comment noted.

152
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Submitted by Los Angeles County Business Federation Submittal 16286 Related Documents Link

16286.01.6 And finally, the extended time period that SCAG provided for stakeholder feedback was a 

valuable adjustment that ensured the effective input from stakeholders from around the 

region. While this is a strong document and we feel it addresses many important factors we 

want to highlight the need to seek innovative and flexible funding options to bring the 

RTP/SCS to fruition. This is paramount in achieving the public and business community’s 

participation. BizFed is pleased with the effort put forth by SCAG in developing this plan 

and support its overall vision, especially when a diverse set of funding resources are 

identified and pursued. We have great confidence in the draft plan set forth by SCAG to 

provide a foundation of investment to improve the future of SCAG’s six county region. 

Once again BizFed wants to commend your work and effort in developing the 

comprehensive Regional Transportation Plan and Sustainable Communities Strategy to 

address the myriad needs for a region as diverse as Southern California. BizFed and our 

members look forward to continued collaboration on not only the 2016 RTP/SCS, but on 

implementing the projects it contains so that together we can build a resilient economy to 

serve our great region.

Comment noted.

Submitted by Los Angeles World Airports Submittal 16372 Related Documents Link

16372.01 In an effort to further partner with SCAG's Aviation Technical Advisory Committee, LAWA 

recommends SCAG convene a working group of the region's airports, transportation 

agencies, SCAG members, and other key stakeholders to help identify strategies and 

policies aimed at distributing commercial traffic and goods movement across the region. 

LAWA looks toward to actively participating on such a SCAG Committee.

Comment noted.

Submitted by Los Cerritos Wetlands Land Trust Submittal 16293 Related Documents Link

16293.01 The 2012 RTP/SCS provided an important stepping stone for the 2016 Plan. In previous 

Plans, natural lands and farmlands were handled under the banner of “land use.” In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn’t be overlooked. We 

believe the opportunity before you isn’t to “plan for” the future of open space in the 

region—as that’s what you’ve been doing since the 2012 Plan. Instead, we believe SCAG 

can now start “implementing” a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. We and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

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Submitted by Los Cerritos Wetlands Land Trust Submittal 16293 Related Documents Link

16293.02 We are pleased to see an Appendix devoted directly to natural and farmlands protection in 

the 2016 Plan. We are glad that the Plan contains specific strategies addressing natural land 

and farmlands issues. This is certainly a step in the right direction. The culmination of the 

work from the last RTP/SCS is clearly visible in this Draft Plan. SCAG has demonstrated that 

Metropolitan Planning Organizations can play a vital, thoughtful and science-based role in 

mitigating impacts to our natural environment from transportation, infrastructure and 

other development projects. By incorporating natural and farmlands protection strategies 

into your policy document, we believe the many benefits of this broad-based conservation 

approach will be realized sooner than expected. Thank you for your leadership.

Comment noted.

Submitted by March Joint Powers Authority Submittal 16210 Related Documents

16210.01 Active Transportation Exhibit 28 does not show existing and planned bikeways within the 

March JPA land use jurisdiction in Riverside County. Class two bike lanes are existing on 

Meridian Parkway, and are planned on Krameria Avenue, Van Buren Boulevard and Village 

West Drive within the March JPA.

Comment noted. Exhibit 28 updated to reflect existing bikeways. Krameria Ave, Street "Y" 

and Village Drive West do not yet appear as planned roadways in geodata and therefore 

cannot reflect planned bikeways in the Active Transportation Appendix. The planned 

bikeways will be incorporated as SCAG's geodata is updated.

16210.02 The Project List should include the Van Buren Boulevard widening project, which is on the 

WRCOG TUMF NW Zone TIP and is in the process of construction. The following 

information should be inserted for in the Riverside County section, approximate pages 61 - 

68: SYSTEM: LOCAL HIGHWAY, FTIP ID: ?, ROUTE: 0, DESCRIPTION: IN WESTERN RIVERSIDE 

COUNTY WITHIN THE MARCH JOINT POWERS AUTHORITY: VAN BUREN BOULEVARD 

WIDENING: FROM I-215 TO BARTON STREET, WIDEN FROM 4 TO 6 LANDES, INCLUDING 

ADDITION OF CLASS 2 BIKE LANES, SIDEWALKS, LANDSCAPE MEDIAN AND TRAFFIC SIGNAL 

UPGRADES, PROJECT COST: $5,200

Comment noted. The project you are referencing is FTIP ID# RIV060121 which was marked 

as complete under the 2015 FTIP with a completion date of 2/28/2014. Since the project is 

complete it is no longer listed within the Project List.

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Submitted by Metro Gold Line Foothill Extension Construction Link

Authority

Submittal 16337 Related Documents

16337.01 We are pleased that the Southern California Association of Governments (SCAG) is 

including the Foothill Gold Line from Glendora to Montclair in the Draft Regional 

Transportation Plan/Sustainable Communities Strategy (RTP/SCS) under the financially 

constrained plan. However, the RTP/SCS forecasts completion of the project in 2040, 

almost two decades beyond the current planned schedule while also understating the 

project costs. The Foothill Gold Line is a critically needed link that will connect a dozen 

universities, the LA County Fairplex, and LA County with San Bernardino and Riverside 

Counties at the Montclair TransCenter. The Foothill Gold Line will alleviate traffic on one of 

the most heavily congested corridors which is expected to assume the majority of the 

subregion’s population and employment growth in the coming decades. The Glendora to 

Montclair segment is estimated to achieve 18,300 daily boardings by reducing Vehicle Miles 

Traveled (VMT) by 111,000 and reduce emission burden levels resulting in beneficial effect 

on CO, TOG, Nox, PM10 and PM 2.5 levels. The current forecast in the Draft RTP/SCS of 

completing the Foothill Gold Line in 2040 is too late and should be amended to complete 

this vitally needed project as soon as possible. No other rail project in Los Angeles County is 

as ready as this one. The project will be ready in 2017 to break ground and SCAG should 

find ways to include innovative sources to fully fund the $1,216 M project sooner as they 

are doing with other unfunded rail projects in Los Angeles.

The funding identified in the Draft 2016 RTP/SCS for the Foothill Gold Line Extension Phase 

2B is based upon innovative strategies that are not expected to be available in the near 

term. The earliest completion date for this project would be 2035 and the RTP/SCS has 

been adjusted accordingly. Should this project be advanced by Metro as it updates its Long 

Range Transportation Plan, the completion date can be adjusted through a future 2016 

RTP/SCS amendment at the request of Metro.

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Submitted by Move L.A. Submittal 16349 Related Documents

16349.01 So, the investments in transit, the investments in active transportation- very happy to see 

active transportation spending moved up to earlier years in the plan as compared to the 

last RTP/SCS. What I wanted to talk about the most, though, is the EJ analysis. Really, a very 

impressive document. It's really a quantum leap from the last EJ analysis. It is very 

thorough, covers a lot of different topics and it is giving us both maps and charts to really 

understand what the impact of investments are and where we are moving to. And one of 

the things that -- one of the findings in the EJ analysis is that in some areas nothing is ever 

true for the entire region; right, but in some areas we are seeing these investments lead to 

displacement of low income people. So, transit investments resulting in increased property 

values and increased rents and pushing away the people who use transit. And this is a really 

thorny thorny problem. And I really want to call on SCAG to work with us to work with local 

jurisdictions. We stand ready to work with you to get the tools and the resources that you 

need that is really a local government issue, it's about land use control, it's about, you 

know, where you build, what you tear down, what are the income levels, how much 

affordable housing is being built. All of those issues are really local land use and I know 

SCAG and we respect the land use authority as local jurisdictions, but we think together we 

can work to convince the legislature to take off some of the restrictions on local 

government around controlling demolitions, restrictions on rent control like the Ellis Act as 

well as resources housing resources. And the state is talking about, hopefully, it will couple 

to pass, but just this week or just last week they introduced, what, a 2 Billion dollar plan for 

affordable housing in local jurisdictions. So that needs to work its way through the 

legislature and through the budget process, but I think this is the first time since 

redevelopment was dissolved that we're seeing this kind of response from the State. At 

Move L.A., of course, we work to increase local resources in L.A. County, excuse me, for 

transportations, but we're also very very concerned that we don't have those local 

resources for housing as well because subsidy is a very key part.

SCAG will consider emerging and persistent regional issues, including suggestions from the 

comment process, and will work with stakeholders to encourage different strategies for 

building affordable housing at the jurisdictional level. SCAG is also exploring ways to 

address social equity issues, including gentrification and displacement, beyond the 

RTP/SCS process, and will continue to work with stakeholders to discuss challenges and 

potential strategies for the SCAG region.

Submitted by National Trust for Historic Preservation Submittal 16298 Related Documents Link

16298.01 We commend SCAG for its focus on constructive, sustainable, regional transportation 

improvements, and for not explicitly including the State Route 710 Tunnel Alternative (SR710 Tunnel) in the list of constrained projects. However, some ambiguity about the status 

of the SR-710 Tunnel project remains as a result of references to the SR-710 North project 

in the Draft PEIR. We urge SCAG to clarify references to the SR-710 North project in the 

Final 2016 RTP/SCS and PEIR, and confirm that the SR-710 Tunnel Alternative is not 

included in the RTP list of constrained projects.

Comment noted. The project with RTP ID 1M0101 was submitted by Los Angeles County 

Metro with the following project description, "SR-710 North Project Study Alternatives 

(Alignment TBD)." Requests to modify projects included within the RTP/SCS must come 

directly from the County Transportation Commissions, in this case, Metro. SCAG modeled 

the SR-710 North Project Study as four toll lanes in each direction since it is the most 

conservative scenario with respect to environmental impacts. This does not express 

SCAG's preference for this alternative. SCAG also included the following footnote to 

describe the current status of the project, "This project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete, the 2016 RTP/SCS will be updated to reflect the Locally 

Preferred Alternative (LPA) as identified in the final environmental document.

156
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Submitted by National Trust for Historic Preservation Submittal 16298 Related Documents Link

16298.02 Since a Locally Preferred Alternative has not yet been identified by Caltrans for the SR- 710 

North Project, SCAG should remove all references or inferences that the project will be the 

SR-710 Tunnel Alternative. Specifically, RTP ID 1M0101 should be moved from the 

Constrained Plan to the Strategic Plan, and the language should be clarified to ensure the 

project description is alternative-neutral, for the following reasons: I. An SR-710 Tunnel 

Alternative Is Inconsistent with the Majority of SCAG’s Regional Goals Expressed in the 

Draft 2016 RTP/SCS. Inclusion of a freeway Tunnel Alternative in the Final RTP/SCS and PEIR 

would be in direct opposition to the many valid, forward-thinking, and sustainable 

initiatives established by the Draft 2016 RTP/SCS: • Preserving the Transportation System 

We Already Have (Fixing it First) • Expanding Our Regional Transit System to Give People 

More Alternatives to Driving Alone • Expanding Passenger Rail • Managing Demand on the 

Transportation System • Promoting Walking, Biking and Other Forms of Active 

Transportation • Focusing New Growth Around Transit II. Including a Tunnel Alternative 

Would Be Inconsistent with Recent California State Legislation. An SR -710 Tunnel 

Alternative is in opposition to the principles and goals of Assembly Bill 32 (AB 32) and 

Senate Bill 375 (SB 375) because the resulting project would induce demand, increase 

vehicle miles traveled (VMT), and increase greenhouse gas (GHG) emissions. As the 

Metropolitan Planning Organization for the region, SCAG should promote and implement 

policies that will improve regional air quality and support projects that will reduce regional 

VMT and GHG emissions. III. References to "SR-710 North Extension (Alignment TBD)" 

should be revised. We remain concerned with SCAG’s assertion in Appendix B of the draft 

PEIR that the alignment is "to be determined.” Comments within the draft RTP/SCS and 

PEIR suggests that the project proposed by SCAG remains the SR-710 Tunnel and that it is 

not alternative-neutral.

Comment noted. The SR-710 project as currently described serves as a place holder until 

Metro decides on a locally preferred alternative. (LPA). SCAG recognizes that the project is 

currently pending environmental review. As with other projects included within the 

Project List, when the SR-710 North Study EIR/EIS process is complete and a locally 

preferred alternative (LPA) is identified in the final environmental document, SCAG will 

work with Metro to amend the RTP/SCS as necessary to update the project description and 

associated modeling analysis.

16298.03 IV. The SR-710 Tunnel Alternative Should Be Removed from the Constrained Projects List. 

Inclusion of the SR-710 Tunnel Alternative fails to meet the federal requirement that any 

project listed as fiscally constrained must establish that funds for the project are 

"committed, available, or reasonably available." (23 C.F.R. §450.104.) The $5.6 billion in 

projected project costs for the dual-bore SR-710 Tunnel Alternative are not at all 

“committed, available, or reasonably available.”

Comment noted. RTP ID 1M0101 includes the following project description, "SR-710 North 

Project Study Alternatives (Alignment TBD)" and includes the following footnote, "This 

project is currently pending environmental review. As with other projects included within 

the Project List, when the SR-710 North Study EIR/EIS process is complete, the 2016 

RTP/SCS will be updated to reflect the Locally Preferred Alternative (LPA) as identified in 

the final environmental document." SCAG’s analysis and documentation of reasonably 

available sources demonstrates consistency with federal requirements. The full text of the 

federal requirements can be found in 23 CFR 450.322. The applicable federal regulations 

clearly indicate an RTP meets the financial constraint requirement by including “sufficient 

financial information for demonstrating that projects” in the plan “can be implemented 

using committed, available, or reasonably available revenue sources, with reasonable 

assurance that the federally supported transportation system is being adequately 

operated and maintained.”

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Submitted by National Trust for Historic Preservation Submittal 16298 Related Documents Link

16298.04 SCAG should remove the Tunnel Alternative from its constrained list in the Final RTP/SCS 

and PEIR, and invest the region's limited financial resources in transportation projects that 

are in alignment with the regional goals and priorities set forth in the RTP/SCS. The 

previous error of including the SR-710 Tunnel in the 2012 Constrained Plan should be 

corrected in the 2016 RTP/SCS by moving the project to the Strategic Plan to accurately 

reflect the lack of available funding.

Comment noted. RTP ID 1M0101 includes the following project description, "SR-710 North 

Project Study Alternatives (Alignment TBD)" and includes the following footnote, "This 

project is currently pending environmental review. As with other projects included within 

the Project List, when the SR-710 North Study EIR/EIS process is complete, the 2016 

RTP/SCS will be updated to reflect the Locally Preferred Alternative (LPA) as identified in 

the final environmental document." SCAG’s analysis and documentation of reasonably 

available sources demonstrates consistency with federal requirements. The full text of the 

federal requirements can be found in 23 CFR 450.322. The applicable federal regulations 

clearly indicate an RTP meets the financial constraint requirement by including “sufficient 

financial information for demonstrating that projects” in the plan “can be implemented 

using committed, available, or reasonably available revenue sources, with reasonable 

assurance that the federally supported transportation system is being adequately 

operated and maintained.”

Submitted by Naturalist For You Submittal 16278 Related Documents Link

16278.01 The 2012 RTP/SCS provided an important stepping stone for the 2016 Plan. In previous 

Plans, natural lands and farmlands were handled under the banner of “land use.” In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn’t be overlooked. We 

believe the opportunity before you isn’t to “plan for” the future of open space in the 

region—as that’s what you’ve been doing since the 2012 Plan. Instead, we believe SCAG 

can now start “implementing” a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. We and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16278.02 Maps contained within the PEIR, RTP, SCS and Appendix should be internally consistent and 

they are not. For example, each map that shows “open space” or “protected lands” should 

be using the same base dataset but they do not. The 2012 Plan resulted in the creation of 

SCAG’s very own geographic information systems (GIS) dataset: the Natural Resource 

Inventory. It is more accurate than what is in the document now and it has been vetted by 

numerous organizations. That’s why it is surprising to see that so few of SCAG’s own GIS 

layers were actually used in the documents’ maps. We urge SCAG to honor its own work 

and that of its partner organizations by using this dataset as the basis for natural and 

farmland mapping. Let’s move forward with the same baseline information.

Each of the maps identified in the comment serve a distinct purpose and as such may 

reference a different data set to fully address its purpose. The various data sets each have 

their own set of constraints, not limited to richness of data and scale, which primarily 

explains the differences in mapping between PEIR and the RTP/SCS. Maps have been 

clarified to properly identify the purpose of the map and the specific data source.

158
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Submitted by Naturalist For You Submittal 16278 Related Documents Link

16278.03 Our organization supports the idea that as new growth occurs it should focus on the 

existing infill areas. This is consistent with the finding in the SCAG surveys where 

respondents preferred to see existing urban areas built upon before greenfields are 

targeted for development, especially those at the Wildland-Urban Interface. When 

developments are built in infill areas, it likely relieves pressure from the fringe. However, 

the Plan fails to outline exactly how (or with what mechanism) these fringe lands (or any 

lands) will actually be protected. Just because the pressure is relieved doesn’t mean the 

land then automatically becomes protected. Numerous organizations, ours included, focus 

their work on preservation of important habitat lands. A lot of time, energy, political will, 

strategy and other efforts combine to create a successful conservation transaction that 

leads to permanently conserved lands. SCAG must identify the mechanism, process or plan 

on how the greenfield lands will be protected.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16278.04 SCAG focused many sections of the document on formal conservation plans, in the form of 

Natural Community Conservation Plans and Habitat Conservation Plans (NCCP/HCP), as the 

conservation method most identified by the agency. It is important to note that NCCP/HCP 

programs are only one conservation mechanism and they have limitations. For example, 

they are voluntary, property owner driven and generally only apply to larger land 

ownerships. Efforts underway by local, regional, state and federal agencies outside of these 

formal plans should not be discounted and must be included. Furthermore, many 

conservation organizations help facilitate, coordinate and find funding for land 

conservation transactions. We believe the conservation approach promoted by SCAG 

should include all of the ways land is protected, including those less regulated methods of 

conservation outside of NCCP/HCP programs.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation. Suggestions for strategies 

beyond HCPs and NCCPs will be encouraged and appreciated. Your group is encouraged to 

participate in the effort.

16278.05.1 The Plan outlines that the region anticipates an additional 3.8 million people by 2040 

providing increased pressure on our existing parkland. Studies document that many 

communities in the Southern California region already do not have enough parkland as 

outlined by the Quimby Act (three acres per 1,000 residents). Throughout the document, 

the Plan promotes providing more access to these existing parks as infill projects are built, 

but nowhere does it state how additional parks will be created. The mechanism is missing.

Parks which are easily accessible are an integral part of sustainable communities as it 

improves public health, air quality, and quality of life. Providing parks within infill areas has 

a different set of challenges that varies by jurisdiction. SCAG encourages jurisdictions to 

look at funding sources, such as the California Department of Housing and Community 

Development (HCD) Housing-related Parks program, to help build and maintain local parks. 

The Housing-related Parks program awards money to build and maintain parks based on 

the number of affordable housing units a jurisdiction has built, which can help increase 

park accessibility in traditionally underserved areas. SCAG will continue to provide 

jurisdictions information regarding funding opportunities and encourage jurisdictions to 

provide parks as part of their long-range plans.

16278.05.2 More importantly, these city parks are fundamentally different than habitat-focused parks. 

Usually city and regional parks include high intensity recreation oriented activities, like 

soccer and baseball fields, and are turfed. The types of land acquired as mitigation or 

through local conservation efforts typically are focused on preservation of natural habitat 

and less intensive uses (birding, hiking, etc.). In fact, many of these mitigation lands have 

limited or managed public access. Providing “more” access to either high or low intensity 

parks and/or habitat lands may have significant consequences for the land manager. The 

document needs to address the impacts to local parks with increased access from 

expanding populations. The document also needs to address how additional lands will be 

protected, i.e., what mechanism will be used?

Comment noted. The term "Natural Lands" is used intentionally to differentiate between 

potentially sensitive habitat areas and urban/suburban parks that provide open space and 

active recreation. Specifically, "Natural Lands" refers to biologically diverse areas and 

landscapes that may provide ecosystem services, such as grasslands, wetlands, deserts, 

forests, shrublands, riparian areas, and other types of habitat lands. Natural Lands is not 

intended to include agricultural croplands, grazing/rangeland, other working lands, or 

municipal parks serving primarily recreational purposes. In the coming years, SCAG will be 

working with local entities to assist in the cross-jurisdictional coordination of habitat 

conservation strategies. Your coalition is encouraged to participate in the effort.

159
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Submitted by Naturalist For You Submittal 16278 Related Documents Link

16278.06 The current federal transportation bill, FAST Act, supports understanding transportation 

impacts on natural resources. The previous bill, MAP-21, supported restoring and 

maintaining environmental functions (i.e., wildlife corridors) affected by the infrastructure 

projects in the RTP. SCAG has even supported efforts in Los Angeles County to create a 

wildlife corridor over the 101 Freeway. Many efforts are underway across the region to 

connect landscapes to one another. This is very important to the region and its biodiversity. 

Wildlife corridors allow species to migrate and forage and expand genetic diversity. These 

corridors also allow ecosystems to maintain ecological functions, act as sources for 

repopulation after natural disasters such as fire, flood or landslide, and improve the 

resiliency in the face of climate change impacts. The Plan would be stronger if it supported 

the enhancement of and/or protection of documented and regionally significant wildlife 

corridors, especially those that are impacted by infrastructure projects.

Comment noted. The RTP/SCS describes (in Chapter 5) next steps for further developing a 

habitat conservation strategy. Included in the steps is the recommendation to provide 

“incentives for jurisdictions to cooperate across county lines to protect and restore natural 

habitat corridors, especially where corridors cross county boundaries.” The Natural/Farm 

Lands Appendix further supports wildlife corridors in its recommended policies, with the 

specific recommendation to “Encourage and facilitate research, programs and policies to 

identify, protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Additionally, continue support for preserving wildlife corridors and 

wildlife crossings to minimize the impact of transportation projects on wildlife species and 

habitat fragmentation.”

Submitted by No 710 Action Committee Submittal 16301 Related Documents Link

16301.01 The stated cost of the $5.6 billion for the SR 710 Tunnels at Appendix B, page 149 is a false 

cost estimate. This cost estimate is grossly underestimated by 1/2. I assume this number 

was adopted from Caltrans/Metro's DEIR for the 710 North which is drawn from Metro's 

LRTP. This number is for construction only and does not include the total cost of the project 

besides being purposely low to deceive the public, decision makers in an attempt to attract 

and gain support from tunnel contractors. One needs only to look no further for an 

accurate cost estimate than SCAG's final compilation of all matrices used during the 2008 

RTP workshops between September and October of 2007 (attached) for a more realistic 

estimate. The SCAG staff got it right in 2007. Additionally, SCAG could have looked at the 

bid costs for Seattle's tunnel project which is the most comparable project in the US at this 

time. That estimate, based on Seattle's numbers, would be close to SCAG's $11.8 billion. 

There has been a long history of attempts to estimate the tunnel costs dating back to 1992 

with a $4 billion cost estimate. From that time to date, the cost estimates for the SR 710 

Freeway Toll Tunnels have been so wildly variable as to be invalid (see attached). SCAG is 

the region’s MPO. One would hope you would act responsibly and try to build confidence 

with your constituents and not try to fool the public by using a number in 2016 this is 1/2 

the number you used eight years before.

Comment noted. RTP ID 1M0101 includes the following project description, "SR-710 North 

Project Study Alternatives (Alignment TBD)" and includes the following footnote, "This 

project is currently pending environmental review. As with other projects included within 

the Project List, when the SR-710 North Study EIR/EIS process is complete, the 2016 

RTP/SCS will be updated to reflect the Locally Preferred Alternative (LPA) as identified in 

the final environmental document."

160
holdID Comment Response 

Submitted by Ontario Chamber of Commerce Submittal 16355 Related Documents

16355.01 Now, as the President and CEO of the Ontario Chamber of Commerce I have the distinction 

of saying that I am a representative of a business community that has the worst air quality 

in the Nation. There was the September 9th, 2015 L.A. Times Article Tony Barboza reported 

with the blazing headlines that people living near the 60 Freeway in Ontario breathe the 

worst air in our Nation. The studious distinction is not one to be proud of. California needs 

to improve our quality and health of our communities. As noted in the L.A. Times Article 

and other resources the transportation sector is the leading air polluter accounting for 80 

percent of the region's smog for emitting emissions and over 40 percent of the region's 

greenhouse emissions. Heavy duty trucks account for the largest source of the region's air 

pollution. According to the Environmental Protection Agency's Air Quality Industry Report 

retrieved on October 14th of 2015, residents in the Riverside, San Bernardino, Ontario 

Metropolitan area only have the luxury of 7.5 percent of good air quality days per year. 

Again, leading the nation with the worst air quality following closely by 8.8 percent of good 

days in the L.A., Long Beach, Santa Ana Region. This means that our residents in the Ontario 

area only experience good air quality one out of every 12 days. This pollution contributes to 

health risks such as asthma, cancer and premature death. Those likely to be the most 

impacted are the disadvantaged communities near and around transportation quarters and 

ports. Poor quality also puts us at risk for failing to meet the stringent state federal air 

quality standards that Kenneth alluded to. California state is at critical need for the 

reduction of critical pollutants and greenhouse emissions in an effort to curtail smog, 

climate change, address first the effects of these critical health issues, if not the particular 

part pollution reduces reduction addresses real human needs that need to be met now.

Comment noted. Jointly prepared by the South Coast Air Quality Management District 

(SCAQMD), the California Air Resources Board (ARB), and SCAG, the upcoming 2016 South 

Coast Air Quality Management Plan will include additional and more stringent control 

measures to demonstrate attainment of all applicable health-based ozone and PM2.5 

national ambient air quality standards by their respective statutory deadlines.

16355.02 Technologies like ultra low NOx, heavy duty engines are a viable solution in addressing 

California's air pollution and climate change goals. Alternate fueled vehicles can help 

reduce harmful emissions. But in order to put more clean vehicles on the road we need the 

fueling infrastructure to support them. In the Inland Empire we have less than a dozen CNG 

locations and of those several require keypads to access. In Aurora, Colorado Majestic 

Realty Company in cooperation with the City of Aurora opened a major Compressed 

Natural Gas fueling station at the Majestic Industrial Park in late 2014. Interestingly, this is 

just outside Colorado Springs which is in the top eight for cities in the Nation with the best 

air quality where its residents experience 86.7 percent of clean air days per year. This public 

private partnership is open 24/7 to all users commercial and private at a much lower price 

than gas or diesel. CNG can offer up to 25 percent reduction in greenhouse emissions and 

20 to 45 percent reduction in NOx. SCAG should support all new alternative fueling 

infrastructure and the development of intermodal fueling strategies. Please take advantage 

of the existing infrastructure and strive to avoid these strategy offsets.

Comment noted. SCAG’s policies are technology neutral with regard to supporting zero 

and/or near-zero emissions vehicles. SCAG will continue to support natural gas fleet 

vehicles by hosting and administering the Southern California Clean Cities Coalition. The 

SCAG Clean Cities Coalition works with local jurisdictions and industry partners to 

encourage more access to alternative fueling stations, including CNG and LNG stations.

161
holdID Comment Response 

Submitted by Orange County Bicycle Coalition Submittal 16022 Related Documents Link

16022.01 Page 3. I am very disappointed that you've chosen to use Geller's very divisive descriptions 

of Bicyclists by Comfort Level as a foundation for promoting bicycling. His "Strong and 

Fearless" label is resented by all the competent bicyclists I know-- it is deliberately 

dismissive of often the largest group of loyal bicyclists in a given market. It plays to the 

ignorance of the general public and marginalizes behaviors that are often safer, more 

tested and reliable than that of Californians at large. Dividing the public into factions and 

playing one off against the other will NOT win the financial and political support we need in 

the long run. Promoting the very real benefits of bicycling for the individual will. We must 

not stereotype bicyclists to make them understandable by the non-bicycling majority, 

PLEASE focus on Behaviors. Behaviors cross Geller's stereotypical "boxes," and are easily 

relatable for non- or occasional bicyclists.

Comment noted. Language inserted noting that no bicyclist fits neatly into any one 

Comfort Level category. However, Evidence from Vancouver and Toronto indicate that 

installing designated bikeways and separated bikeways increases safety by 50% and 90% 

respectively, This increase in safety, both real and perceived changes behavior increasing 

the number of bicyclists as well.

Submitted by Orange County Business Council Submittal 16297 Related Documents Link

16297.01 The RTP/SCS should not mandate technologies or use transit agencies as technology 

incubators. Instead, it should allow for any and all technologies (i.e. near-zero emission 

technologies) that can meet SCAG's performance goals {focus on performance metrics vs 

technology mandates). Near-zero emission technologies will help achieve regional air 

quality and climate goals, at a fraction of the cost and with more flexibility/choice for 

agencies.

Comment noted. SCAG’s policies are technology neutral with regard to supporting zero 

and/or near-zero emissions vehicles. SCAG will continue to support natural gas fleet 

vehicles by hosting and administering the Southern California Clean Cities Coalition. In 

addition, SCAG communicates with Hydrogen Fuel Cell industry partners to exchange 

information and knowledge. Plug-in Electric vehicles are specifically analyzed in the 

RTP/SCS due to the transportation/land use policy nexus regard station siting, and the role 

that MPOs will play in meeting the State's Greenhouse Gas Reduction targets.

16297.02 SCAG should take advantage of the best of what innovation can deliver, and shouldn't limit 

options, but instead welcome technology advancements that moves us towards our goals 

by: a) Maximizing opportunities to improve air quality and reduce GHG emissions through 

"near-zero" technologies. b) Emphasis Life Cycle emission analysis as opposed to simply tail 

pipe emissions. c) Supporting technology neutral policies

Comment noted. SCAG’s policies are technology neutral with regard to supporting zero 

and/or near-zero emissions vehicles. SCAG will continue to support natural gas fleet 

vehicles by hosting and administering the Southern California Clean Cities Coalition. In 

addition, SCAG communicates with Hydrogen Fuel Cell industry partners to exchange 

information and knowledge. Plug-in Electric vehicles are specifically analyzed in the 

RTP/SCS due to the transportation/land use policy nexus regard station siting, and the role 

that MPOs will play in meeting the State's Greenhouse Gas Reduction targets.

16297.03 OCBC does not support the growth forecast utilized in the development of the Intensified 

Land Use Alternative (Alternative 3) in the draft PEIR. The Intensified Land Use (ILU) 

Alternative does not reflect entitlements, development agreements, open space donations, 

projects recently completed and projects under construction (which are properly reflected 

in The Plan). OCBC requests that the growth forecast in the 2016 RTP/SCS and ALL 

alternatives be based on the technically corrected growth forecast submitted to SCAG by 

Orange County Council of Governments (OCCOG) in August 2015.

Comment noted. The following response is to clarify the purpose of the alternatives 

analysis in the Draft PEIR for the 2016 RTP/SCS. The Draft PEIR considered a range of 

reasonable alternatives to the Draft 2016 RTP/SCS. A range of reasonable alternatives 

includes those alternatives that would feasibly attain most of the basic objectives of the 

Draft 2016 RTP/SCS but would avoid or substantially lessen any of the significant 

environmental effects of the Draft 2016 RTP/SCS. Each of the alternatives in the Draft PEIR 

would achieve the basic objectives in relation to the goals of the Plan. Section 15126.6 of 

the CEQA Guidelines requires that an “environmentally superior” alternative be selected 

among the alternatives that were evaluated in the PEIR. The Draft PEIR found that the 

Intensified Land Use Alternative would be the environmentally superior alternative 

because of the three alternatives it has the lowest number of adverse impacts by Draft 

PEIR resource category. However, the environmentally superior finding is not a feasibility 

finding. The feasibility finding will be considered by SCAG’s Regional Council at the time of 

proposed certification of the Final PEIR and the adoption of the 2016 RTP/SCS. Please note 

that the OCBC comments are also included in the matrix of the Draft PEIR comments.

162
holdID Comment Response 

Submitted by Orange County Business Council Submittal 16297 Related Documents Link

16297.04 OCBC concurs with the comments identified by OCTA in its letter of January 11,2016. OCTA 

has identified policy and technical issues related to the draft 2016 RTP/SCS and PEIR that 

are of concern to Orange County. These are focused on the regional strategies that go 

above and beyond the projects submitted by the county transportation commissions (CTC).

Comment noted.

16297.05 Recently the California Transportation Commission (CTC) moved to deprogram nearly $1 

Billion in transportation projects. How will the State's continued funding shortfall factor 

into the assumptions in the 2016 RTP/SCS.

The financial plan for the 2016 RTP/SCS employs a long-range view of available funding yet 

reflects recent actions to the extent that projects may be delayed or re-scoped based on 

the recent CTC action to reduce the estimate of projected funding available for the State 

Transportation Improvement Program (STIP). Each project or project phase included in the 

Federal Transportation Improvement Program (FTIP)—including STIP-funded 

projects—must be consistent with the approved RTP/SCS. Changes to FTIP projects that 

would be inconsistent with the approved RTP/SCS necessitate an amendment to the 

RTP/SCS. The Plan notes that funding for transportation improvements is currently not 

sustainable, given the projected needs. Projected revenues from the gas tax, the historic 

source of transportation funding, will not meet transportation investment needs – and gas 

tax revenues, in real terms, are actually in decline as tax rates (both state and federal) 

have not been adjusted in more than two decades while the number of more fuel efficient 

and alternative powered vehicles continues to grow. It’s vital that we find new ways to 

make transportation funding more sustainable in the long-term, and efforts are underway 

to explore how we can transition from our current system based on fuel taxes to a more 

direct system based on user fees. Recent action by the state Legislature to launch the 

California Road Charge Pilot Program is a critical step in this transition.

16297.06 OCBC applauds SCAG's emphasis on managed lane strategies as not only a funding source, 

but as a means to enhance mobility.

Comment noted.

163
holdID Comment Response 

Submitted by Orange County Council of Governments Submittal 16296 Related Documents Link

16296.01 Overall, the OCCOG supports the 2016-2040 RTP/SCS growth forecast and the adoption of 

the growth forecast at a geographic level no lower than the jurisdictional level. The OCCOG 

supports The Plan since the growth forecast accurately reflects Orange County’s Projections 

dataset. The Plan growth forecast reflects entitlements, development agreements, and 

projects recently completed or under construction in Orange County. OCCOG appreciates 

the ongoing coordination between SCAG and the Center for Demographic Research (CDR) 

at California State University Fullerton on behalf of all Orange County jurisdictions. The 

Orange County Projections have been used by the Orange County Transportation Authority 

(OCTA) in the development of its Orange County Long-Range Transportation Plan 

demonstrating that Orange County has integrated transportation and land use planning for 

decades. OCCOG representatives on the Regional Council and SCAG Policy Committees 

repeatedly requested that the growth forecasts in the 2016 RTP/SCS and all PEIR 

alternatives be based on the technically corrected growth forecast submitted to SCAG in 

August 2015 by the CDR on behalf of all Orange County jurisdictions. Because the draft 

PEIR’s Intensified Land Use Alternative (Alternative 3) does not include the technically 

corrected growth forecast for Orange County, the OCCOG would not support consideration 

of this Alternative as the preferred alternative. Growth Forecast Recommendations: OCCOG 

supports the adoption of the 2016 RTP/SCS growth forecast at the jurisdictional level. 

OCCOG does not support the use of Alternative 3 for any purposes.

Comment noted.

16296.02 Language throughout the draft 2016 RTP/SCS and the associated appendices has a 

tendency to be leading and dramatic in its emphasis of certain key issues such as active 

transportation and public health. While these issues are important, it is recommended that 

the document utilize a more unbiased, objective tone. For example, OCCOG recommends 

the removal of “Our Vision” and “Our Overarching Strategy” from the Executive Summary 

of the document. These two sections are highly speculative and are not necessary to the 

document. “Our Vision” and “Our Overarching Strategy” go above and beyond the 

requirements of the RTP. Additional examples of overly emphatic language are outlined in 

Attachment 1.

Comment noted. We believe this section is important in providing the necessary 

background and context for the development of the rest of the Plan.

16296.03 The OCCOG concurs with the comments identified by OCTA in its letter of January 11, 2016. 

OCTA has identified policy and technical issues related to the draft 2016 RTP/SCS and PEIR 

that are of concern to Orange County. These are focused on the regional strategies that go 

above and beyond the projects submitted by the county transportation commissions (CTC). 

The OCTA comment letter is included for reference as Attachment 2.

Comment noted.

164
holdID Comment Response 

Submitted by Orange County Council of Governments Submittal 16296 Related Documents Link

16296.04 The Draft RTP assumes that almost no new growth will occur within 500 feet of a freeway 

or busy transportation corridor. The Draft RTP states that a “buffer” is consistent with the 

California Air Resources Board’s 2005 advisory guidance that housing be discouraged within 

500 feet of high volume roadways such as freeways. It is important to note that CARB’s 

guidance is not a prohibition of development near high-volume roadways; nevertheless, 

SCAG’s “buffer” strategy eradicates growth in these areas that are otherwise rich in 

connections to jobs, retail and housing accessible by many transportation modes. 

Furthermore, the proposed “buffer” does not reflect the availability of mitigation measures 

to address near-roadway emissions that remain despite a dramatic reduction of diesel 

emissions in the last decade. At best, this strategy is a short-term response and problematic 

because it prevents the kind of density and proximity between land uses that actually 

reduce trips and associated VMT. As vehicle engines and fuels become cleaner, the “buffer” 

strategy will become obsolete yet will leave behind a legacy of inefficient land use patterns. 

Moreover, throughout the SCAG Region, the prevailing existing land use patterns include 

residential and sensitive receptor uses within 500 feet of a major transportation corridor. In 

many cases, these areas demonstrate compact development form and serve as affordable 

housing. Removing this substantial portion of developable land from availability for use is 

premature and counter to the overarching principles of SB375 to locate housing near job 

centers and previously urbanized areas.

Comment noted. The Draft RTP/SCS does not assume new growth will be prohibited within 

500 feet of a freeway or busy roadway. Region-wide, projected growth within 500 feet of a 

freeway or busy roadway reflects local input data. The Draft RTP/SCS encourages local 

jurisdictions to establish their own policies to direct growth outside these areas based on 

factors covered in the Appendix: Environmental Justice. The use of the word “buffer” has 

been omitted from the Plan. However, SCAG will continue to utilize the advisory 

recommendation from ARB’s 2005 Air Quality and Land Use Manual to avoid siting new 

sensitive land uses within 500 feet of a freeway or urban roads with 100,000 vehicles per 

day.

16296.05 There needs to be consistency throughout all the documents regarding the 500 foot 

“buffer.” To that end, OCCOG offers the following recommendations and requests for 

additional clarification: • The word “buffer” should not be used. • Use consistent 

radius/demarcation throughout the documents • Clarify where distance is measured from 

(e.g. centerline, edge of roadway, edge of right of way) • Clearly articulate the types of 

transportation corridors being identified (e.g. freeways, high quality transit corridors, high 

volume corridors, rail etc.) • Emphasis should be on mitigation not prohibition of 

development. o Resolve the conflict with discouraging development within 500 feet of 

transportation corridors now and future reductions in emissions and fleet changes over 

time which will negate the need to utilize this mitigation measure, so that the mitigation 

approach allows for flexibility with the changing fleet mix in the future.

• Comment noted. The use of the word “buffer” has been omitted from the Plan. 

However, SCAG will continue to utilize the advisory recommendation from ARB’s 2005 Air 

Quality and Land Use Manual to avoid siting new sensitive land uses within 500 feet of a 

freeway or urban roads with 100,000 vehicles per day. • Comment noted. Changes have 

been made where appropriate. • Comment noted. The distance measured is edge of 

roadway. •Comment noted. The transportation corridor being identified is a freeway. • 

Comment noted. The RTP/SCS does not contain a policy that prohibits development within 

these areas. It encourages local jurisdictions to establish their own policies to limit growth 

in these areas based on factors covered in the Appendix: Environmental Justice – the 

emphasis is on mitigation.

16296.06 Throughout the 2016 RTP/SCS, PEIR, and associated appendices, there are references to 

“cities”. Since the SCAG region also includes counties, it is recommended that references to 

“city” or “cities” are changed to “jurisdiction” or “jurisdictions” where appropriate. 

Recommendation: Change references to “city” or “cities” to “jurisdiction” or “jurisdictions” 

where appropriate.

Comment noted. Appropriate edits have been incorporated in the Final 2016 RTP/SCS.

165
holdID Comment Response 

Submitted by Orange County Council of Governments Submittal 16296 Related Documents Link

16296.07 Throughout the documents, there are specific examples of technology identified. It is not 

SCAG’s purview to pick winner and losers in technology; the marketplace will determine 

dominant technologies. Therefore, it should be noted that these are only examples and 

that future technologies should not be ignored or excluded from meeting the goals of the 

RTP/SCS. This will allow the document, including mitigation measures, to be more flexible.

Comment noted.SCAG’s policies are technology neutral with regard to supporting zero 

and/or near-zero emissions vehicles. SCAG will continue to support natural gas fleet 

vehicles by hosting and administering the Southern California Clean Cities Coalition. In 

addition, SCAG communicates with Hydrogen Fuel Cell industry partners to exchange 

information and knowledge. Plug-in Electric vehicles are specifically analyzed in the 

RTP/SCS due to the transportation/land use policy nexus regarding charging station siting. 

Regarding mobility innovations such as carsharing, and ridesourcing, SCAG does not view 

these as specific technologies, but rather as emerging transportation modes. In the 

Mobility Innovations appendix, various new technologies are identified that show promise 

in meeting the goals of the RTP/SCS, and will continue to support any and all mobility 

innovations.

16296.08 Several mitigation measures indicate that local jurisdictions or other entities should 

implement new fees or propose taxes to pay for a variety of programs or for acquisition of 

land for preservation. Increases to fees or taxes are issues that could require voter 

approval, and therefore it should not be assumed that they will be approved. Fees and 

Taxes Recommendations: a) Reword measures to indicate that a new or increased fee, new 

tax, or other increase is only an option as a way to implement the mitigation. b) Clarify 

whether it was assumed that these additional fees were considered feasible and if the new 

fees that are suggested were considered in the financial plan or economic analysis of the 

RTP.

Comment noted. The financial plan for the 2016 RTP/SCS does not assume any revenue 

from new fees included as mitigation measures. Details on all revenue sources included in 

the financial plan can be found in the Transportation Finance Appendix. Also, the project 

level mitigation measures that include fees and taxes in the PEIR are a list of example 

mitigation measures that SCAG does not have jurisdiction or authority to implement. They 

are included in the PEIR to fulfill SCAG’s responsibility as lead agency for the RTP/SCS 

under CEQA and to facilitate the Findings that are required at the time that SCAG’s 

Regional Council considers the adoption of the Plan. For a complete discussion on the 

performance standards-based mitigation measures, please refer to Master Response No. 4 

in the Final PEIR.

16296.09 The OCCOG recognizes the immense efforts SCAG undertook to prepare the 2016-2040 

RTP/SCS documents. They represent incredibly complex technical work and have important 

and far-reaching policy impacts for our region. However, because of this importance and 

complexity, we would like to express concern about the timing of the release of the 

documents, and our desire that the preparation of future RTP/SCS documents in future 

RTP/SCS cycles will take into account the need to accommodate adequate review, 

discussion and revision time for all of the documents. The current timeline of document 

releases, public comment period, and time allowed for the response to comments results 

makes it challenging to have credible discussion regarding possible changes, because the 

timeline does not allow for recirculation or full discussion of requested changes. While 

OCCOG is appreciative of the extended public comment period through February 1, 2016, 

there remains concern that only a few weeks remain for SCAG 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 7, 2016. With that, 

we look forward to working with SCAG collaboratively to achieve the schedule.

Comment noted.

166
holdID Comment Response 

Submitted by Orange County Health Care Agency Submittal 16251 Related Documents Link

16251.01 p.1, column 1 Existing text: “Public health is increasingly an area of emphasis for 

Metropolitan Planning Organizations (MPOs) and Departments of Transportation (DOTs) 

across the country, have an opportunity to impact due to the prevalence of chronic 

diseases such as obesity, hypertension, asthma and heart disease through transportation 

planning which promotes increased physical activity.” Modify text to read: “Metropolitan 

Planning Organizations (MPOs) and Departments of Transportation (DOTs) across the 

country, have an opportunity to impact the prevalence of chronic diseases such as obesity, 

hypertension, asthma and heart disease through transportation planning which promotes 

increased physical activity.”

Comment Noted. The proposed changes do not reflect the full extent to which land use 

and transportation affect health outcomes. The Public Health Appendix outlines seven 

focus areas, one of which is physical activity. Changes have been made to the Plan to 

clarify text.

16251.02 p.2, column 1 Introduction- first paragraph sentence beginning with “Public health 

outcomes are the product of Social Determinants of Health.....” consider adding “and other 

factors. p.2, Figure 1 Please have arrows go both ways.

Comment noted. Changes have been made to the Plan.

16251.03 p.3, column 1, paragraph 2 Existing text: “Evidence shows that healthier lifestyles and 

improved air quality can improve outcomes, and built environment factors can play a role 

in supporting healthy behaviors.” Modify text to read: “Evidence shows that healthier 

lifestyles and improved air quality can improve outcomes, and built environment factors 

and related conditions can play a role in supporting healthy behaviors.”

Comment noted. Changes have been made to the Plan.

16251.04 p.3, column 2, paragraph 3 Existing text: “Access to healthy food environments such as 

grocery stores, farmers’ markets and community gardens decreases food insecurity and 

obesity.” Modify text to read: “Access to healthy food environments such as grocery stores, 

farmers’ markets and community gardens can play an important role in food insecurity and 

obesity.”

Comment noted. Changes have been made to the Plan.

16251.05 p.7, column 2, paragraph 3 Existing text: “...Creating infrastructure and facilities that 

encourage active transportation such as biking and walking provide opportunities for 

residents to increase their daily physical activity.” Modify text to read: “...Creating 

infrastructure policies and community conditions and facilities that encourage active 

transportation such as biking and walking provide opportunities for residents to increase 

their daily physical activity.”

Comment noted. Changes have been made to the Plan.

16251.06 p.8, paragraph 3 Consider adding the recommendations for children which has a higher 

standard of one hour per day. This is valuable as jurisdictions look at health co-benefits of 

safe routes to school infrastructure changes and related programming.

Comment noted. Changes have been made in the Plan.

16251.07 p.9, all figures Recommend using the more current 2014 data. Also, it might be helpful to 

look at these metrics on a smaller level of geography and/or by poverty and/or by 

race/ethnicity. Especially since there are often funding set asides to reach disadvantaged 

communities, it might be interesting to see what each of these indicators looks like at a 

more refined level. The need is not equally distributed throughout any jurisdiction.

Comments noted. SCAG plans to expand its analysis of public health data over the coming 

years and will incorporate these suggestions. However, SCAG believes additional outreach 

is necessary to identify any concerns local jurisdictions might have regarding the 

incorporation of smaller geographic analysis into the Plan. SCAG will incorporate newer 

data into the 2020 RTP/SCS, however, SCAG will continue to use the 2011 CHIS data for the 

2016 RTP/SCS to be as consistent as possible in reporting base year statistics.

16251.08 p.9 Add table with data for walking. Comment noted. Changes have been made to the Plan.

16251.09 p.10, column 2 Consider including funding as both a challenge and an opportunity. Comment noted.

167
holdID Comment Response 

Submitted by Orange County Health Care Agency Submittal 16251 Related Documents Link

16251.10 p.10, column 2, paragraph 4 Existing text: “With more than 18 million people, 191 cities, six 

counties and hundreds of local and regional agencies, Southern California is one of the 

most complex regions on earth. Within the region, health outcomes vary widely based on... 

Modify text to read: “With more than 18 million people, 191 cities, six counties and 

hundreds of local and regional agencies, Southern California is a diverse region. Within the 

region, health outcomes vary widely based on many factors.

Comment noted. Changes have been made to the Plan.

16251.11 p. 22-29 Are these all “best practices” or are they local examples of promising practices? 

Since some of these are in process, are the results are there to show that this particular 

practice has proven efficacy over another? These may have the potential to be best 

practices. If the project is based upon a best practice, it is recommended to link to the best 

practice so other jurisdictional leaders could consider for replication. If it is not already a 

proven practice, suggest calling it something different such as “local promising practices”. 

Add the Complete Streets Guidelines that are being developed in Orange County (which 

integrates in best practices.)

Comment noted. The "best practices" term in the Plan has been changed as 

recommended. The Complete Streets Guidelines were not available at time of plan 

development, but will be noted as a resource on the "living" list of local practices that 

SCAG provides on its public health webpage.

Submitted by Orange County League of Conservation Voters Submittal 16169 Related Documents Link

16169.01 The 2012 RTP/SCS provided an important stepping stone for the 2016 Plan. In previous 

Plans, natural lands and farmlands were handled under the banner of "land use." In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn't be overlooked. We 

believe the opportunity before you isn't to "plan for" the future of open space in the 

region—as that's what you've been doing since the 2012 Plan. Instead, we believe SCAG 

can now start "implementing" a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. We and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation programs. Your coalition is 

encouraged to participate in the effort.

16169.02 SCAG focused many sections of the document on formal conservation plans, in the form of 

Natural Community Conservation Plans and Habitat Conservation Plans (NCCP/HCP), as the 

conservation method most identified by the agency. It is important to note that NCCP/HCP 

programs are only one conservation mechanism and they have limitations. For example, 

they are voluntary, property owner driven and generally only apply to larger land 

ownerships. Efforts underway by local, regional, state and federal agencies outside of these 

formal plans should not be discounted and must be included. Furthermore, many 

conservation organizations help facilitate, coordinate and find funding for land 

conservation transactions. We believe the conservation approach promoted by SCAG 

should include all of the ways land is protected, including those less regulated methods of 

conservation outside of NCCP/HCP programs.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation programs. Your group is 

encouraged to participate in the effort.

168
holdID Comment Response 

Submitted by Orange County Public Works Submittal 16299 Related Documents Link

16299.01 Throughout the Draft 2016 RTP/SCS, PEIR, and associated appendices, there are references 

to "cities." Since the SCAG region also includes counties, it is recommended that references 

to "city" or "cities" are changed to "jurisdiction" or "jurisdictions" where appropriate. 

Recommendation: Change references to "city" or "cities" to "jurisdiction" or "jurisdictions" 

where appropriate.

Comment noted. Appropriate edits have been incorporated in the Final 2016 RTP/SCS.

16299.02 Undevelopable/Protected Land Labeled as Vacant This continues to be an ongoing issue 

with data and maps produced by SCAG for use in its various projects. The County is 

especially concerned about this issue due to the effort its staff has expended over the last 

several years to ensure that protected, and therefore undevelopable, land in the 

unincorporated area is not depicted on any land use maps as "vacant" and therefore 

available for development. During the outreach process for the Draft 2016 RTP/SCS, the 

County received a "SCAG Data/Map Book" from SCAG which included several maps for 

review and comment. In this Map Book, SCAG had included its list of General Plan Land Use 

Categories which included the category "8888 Undevelopable." County staff applied this 

category to all areas that are protected open space and submitted this data and maps to 

SCAG for use in the RTP/SCS and PEIR. A review of the various figures (i.e., exhibits or maps) 

contained throughout the Draft 2016 RTP/SCS and PEIR has revealed the "8888 

Undevelopable" category was not applied consistently to protected open space in the 

unincorporated area. For example, in the RTP/SCS Appendix titled "SCS Background 

Document," Exhibits 23 and 24 correctly identify the protected open space areas in the 

unincorporated area including the Cleveland National Forest (CNF). However, in the PEIR, 

Figure 3.11.2- 2 "Existing Land Uses" and Figure 3.11.2-5 "General Plan Land Use 

Designations" both identify CNF as open space instead of undevelopable. Just a few pages 

later in the PEIR, Figure 3.11.2- 7 "SCAG Region Open Space, Recreation, and Agricultural 

Land Uses" labels the CNF as "vacant." The CNF is not vacant land, it is protected open 

space and therefore undevelopable. Recommendation: Revise all figures, exhibits and maps 

to correctly identify protected open space in the unincorporated area as undevelopable. No 

undevelopable areas should be depicted as vacant, which has a connotation that it is 

available for future development.

Comment noted. With respect to the comment on the figures in the PEIR, it is important to 

note that each of the figures in the PEIR serves a distinct purpose and as such, may 

reference a ifferent data set to fully address its purpose. The various data sets each have 

their own set of constraints, not limited to richness of data and scale, which primarily 

explains the differences in mapping between PEIR and the RTP/SCS. To the extent 

appropriate, SCAG has clarified the source of data in the legend for the PEIR figures and 

has made edits as described in the Clarifications and Revisions section of the Final PEIR.

169
holdID Comment Response 

Submitted by Orange County Public Works Submittal 16299 Related Documents Link

16299.03 Consistent Use of 500 Foot Buffer Reference Throughout the Draft 2016 RTP/SCS and PEIR 

there are references to a possible 500, or even 1,000, foot buffer. The terminology "buffer" 

implies that there is a negative condition that needs to be addressed and that development 

is prohibited within this area. There is currently no requirement from the California Air 

Resources Board (CARB) or the South Coast Air Quality Management District (SCAQMD) 

that prohibit development near high quality transit areas or major transportation corridors. 

There are numerous references to prohibiting certain uses (including residential and mixed 

use) within 500 feet of a major transportation corridor (like a freeway). This language 

should be eliminated or at least made more flexible and it should be indicated that 

additional study is pending by air quality agencies and SCAG. It should be made clear that is 

measure from the edge of travel lands and not the right-of-way. Precluding development 

within 500 feet takes a massive amount of land out of play where often times the greatest 

need for affordable housing exists. Furthermore, precluding development in these areas is 

directly contrary to the primary objectives of SB 375 to locate housing near job centers 

within previously urbanized areas. Recommendation: Define the word "buffer" and use it 

consistently throughout all documents and clarity that development is not currently 

prohibited adjacent to transportation corridors.

Comment noted. The Draft RTP/SCS does not assume new growth will be prohibited within 

500 feet of a freeway or busy roadway. Region-wide, projected growth within 500 feet of a 

freeway or busy roadway reflects local input data. The Draft RTP/SCS encourages local 

jurisdictions to establish their own policies to direct growth outside these areas based on 

factors covered in the Appendix: Environmental Justice. The use of the word “buffer” has 

been omitted from the Plan. However, SCAG will continue to utilize the advisory 

recommendation from ARB’s 2005 Air Quality and Land Use Manual to avoid siting new 

sensitive land uses within 500 feet of a freeway or urban roads with 100,000 vehicles per 

day.

16299.04 Overall, the County supports the Draft 2016-2040 RTP/SCS ("The Plan") growth forecast and 

the adoption of the growth forecast at a geographic level no lower than the jurisdictional 

level. The County supports The Plan since the growth forecast accurately reflects Orange 

County's Projections dataset. The Plan growth forecast reflects all entitlements, 

development agreements, and projects recently completed or under construction in the 

unincorporated area. The County appreciates the ongoing coordination between SCAG and 

the Center for Demographic Research (CDR) at California State University Fullerton on 

behalf of all Orange County jurisdictions. The Orange County Projections has been used by 

OCTA in the development of its Orange County Long-Range Transportation Plan 

demonstrating that Orange County has integrated transportation and land use planning for 

decades. On behalf of all Orange County jurisdictions, OCCOG representatives on the 

Regional Council and SCAG Policy Committees repeatedly requested that the growth 

forecast in the Draft 2016 RTP/SCS and all PEIR alternatives be based on the technically 

corrected growth forecast submitted to SCAG in August 2015 by the CDR. Use of any other 

growth forecast could result in unrealistic land use proposals such as depicted in 

Attachment 2, the proposed increase in the numbers of population, dwelling units and 

employment in long-established single-family residential areas such as Midway City and 

decrease in these numbers for newly built planned communities protected by development 

agreements.

Comment noted, this comment is to support the Policy Growth Forecast.

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holdID Comment Response 

Submitted by Orange County Public Works Submittal 16299 Related Documents Link

16299.05 The PEIR itself makes the following statements as to why Alternative 3 should not be 

supported: • "Alternative 3 would result in a greater chance for there to be conflicts with 

existing plans or regulations including local general plans as a result of the policies 

encouraging a much more compact land use development pattern in urbanized areas such 

as HQTAs." • "Additionally, there would be a greater chance for there to be conflicts with 

an existing plan or regulation including local general plans because of the much more 

compact and aggressive land use development pattern in urbanize areas such as HQTAs." • 

"Alternative 3 would result in somewhat more adverse impacts as The Plan from the 

potential to displace substantial amounts of existing housing...Alternative 3 would result in 

greater impacts as The Plan from the potential to displace substantial numbers of people..." 

• "However, Alternative 3 would have much more severe impacts on the built 

environment." Because the draft PEIR's Intensified Land Use Alternative (Alternative 3) 

does not include the technically corrected growth forecast for Orange County, the County 

would not support consideration of this Alternative as the preferred alternative. 

Recommendation: The County supports the adoption of the Draft 2016 RTP/SCS 'The Plan” 

growth forecast at the jurisdictional level.

Comment Noted SCAG appreciates that the County supports the Plan and growth forecast 

at the jurisdictional level and that does not support that the Intensified Land Use 

Alternative as the preferred alternative for the Plan. This information will be presented to 

SCAG’s Regional Council at the time it considers the certification of the Final PEIR and the 

adoption of a preferred alternative for the 2016 RTP/SCS.

16299.06 Language throughout the Draft 2016 RTP/SCS and the associated appendices is leading and 

dramatic to emphasis certain key issues such as active transportation and public health. It is 

recommended that the document utilize an unbiased, objective tone. For example, the 

County recommends the removal of "Our Vision" and "Our Overarching Strategy" from the 

Executive Summary of the document. These two sections are highly speculative and are not 

necessary to the document. "Our Vision" and "Our Overarching Strategy" go above and 

beyond the requirements of the RTP/SCS when the focus of the document should be on the 

challenges we face and how the SCAG region can address those challenges through the 

adoption of the Draft 2016 RTP/SCS. Recommendation: The Draft 2016 RTP/SCS should only 

contain unbiased and objective language throughout the document and associated 

appendices.

Comment noted.

16299.07 Several mitigation measures indicated that local jurisdictions or other entities should 

implement new fees of propose taxes to pay for a variety of programs or for acquisition of 

land for preservation. Increases to fees or taxes are issues that could require voter 

approval, and thus not be approved. They also represent prescriptive means to accomplish 

the mitigation. Recommendations: a) Reword measures to indicate that a new or increased 

fee, new tax, or other increase is only an option as a way to implement the mitigation, b) 

Clarify whether it was assumed that these additional fees were considered feasible and if 

the new fees that are suggested were considered in the financial plan or economic analysis 

of the RTP.

Comment noted. The financial plan for the 2016 RTP/SCS does not assume any revenue 

from new fees included as mitigation measures. Details on all revenue sources included in 

the financial plan can be found in the Transportation Finance Appendix. Also, the project 

level mitigation measures that include fees and taxes in the PEIR are a list of example 

mitigation measures that SCAG does not have jurisdiction or authority to implement. They 

are included in the PEIR to fulfill SCAG’s responsibility as lead agency for the RTP/SCS 

under CEQA and to facilitate the Findings that are required at the time that SCAG’s 

Regional Council considers the adoption of the Plan. For a complete discussion on the 

performance standards-based mitigation measures, please refer to Master Response No. 4 

in the Final PEIR.

171
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Submitted by Orange County Public Works Submittal 16299 Related Documents Link

16299.08 The County recognizes the amount of work put into preparing these documents. They 

represent incredibly complex technical work and have important and far-reaching policy 

impacts for our region. However, because of this importance and complexity, the County 

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 

current 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. While the County is appreciative of the extended public comment 

period through February 1, 2016, there remains concern that 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 7, 2016.

Comment noted.

Submitted by Orange County Transportation Authority Submittal 16059 Related Documents Link

16059.01 The draft RTP/SCS suggests that $130.8 billion of the approximately $200.4 billion regional 

shortfall can be addressed through actions at either the state or federal level. The 

innovative financing strategy, included in the RTP/SCS, assumes that a $0.10 gas tax 

increase will be implemented by 2020. Additionally, by 2025, it assumes that the state or 

federal government would either replace the gas tax with an indexed mileage-based user 

fee of $0.04 per mile, 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 for discussion. When considering 

support for any kind of a new user-based fee program, the region should place an emphasis 

on the need for return-to-source criteria that guarantee funds generated within a county 

are reinvested in that county’s transportation system. Moreover, any user-based fees 

should be indexed appropriately to provide a justifiable and sustainable source of funding. 

Finally, throughout the development of any new funding mechanisms, opportunities should 

be sought to accelerate project delivery and reduce costs, consistent with OCTA’s Breaking 

Down Barriers initiative. While these comments are generally consistent with SCAG’s 

guiding principles for identifying reasonably available funding in the RTP/SCS, OCTA would 

like to reinforce these principles, particularly in consideration of the mileage-based user fee.

The projected revenue from the mileage-based user fee and adjustments to state and 

federal gas excises taxes are equivalent to the what existing state and federal excise taxes 

would generate had they been indexed for inflation when last adjusted more than two 

decades ago. An analysis of the economic impacts of the Plan is provided in Chapter 7 and 

the Economic and Job Creation Analysis Appendix. Additionally, a comprehensive analysis 

of the California Road Charge Pilot Program will be available no later than June 30, 2018 in 

accordance with SB 1077. The 2016 RTP/SCS does not assume revenue from a mileagebased user fee prior to 2025. As noted, the Plan used the following guiding principles for 

identifying reasonably available revenues: establish a user fee based system that better 

reflects the true cost of transportation, provides firewall protection for new and existing 

transportation funds and ensures an equitable distribution of costs and benefits; promote 

national and state programs that include return-to-source guarantees, while maintaining 

flexibility to reward regions that continue to commit substantial local resources; leverage 

locally available funding with innovative financing tools (e.g., tax credits and expansion of 

the Transportation Infrastructure Finance and Innovation Act [TIFIA]) to attract private 

capital and accelerate project delivery; and promote funding strategies that strengthen the 

federal commitment to the nation’s goods movement system, recognizing the pivotal role 

that our region plays in domestic and international trade.

172
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Submitted by Orange County Transportation Authority Submittal 16059 Related Documents Link

16059.02 The draft RTP/SCS 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 draft RTP/SCS, the project includes completing the first 

section through the San Joaquin Valley by 2018, extending to Palmdale and the Burbank 

Bob Hope Airport by 2022, connecting to San Jose/San Francisco by 2026, and finally 

reaching Los Angeles Union Station (Union Station) by 2028. This also assumes upgraded 

commuter rail connections between Union Station and the Anaheim Regional 

Transportation Intermodal Center along the Los Angeles-San Diego-San Louis Obispo 

corridor. This upgraded service will be achieved through a $1 billion program of projects 

identified in a memorandum of understanding (MOU) between the CHSRA and nine 

Southern California agencies. This investment is part of a phased delivery, known as the 

“blended approach”, which OCTA supports through the adopted Resolution 2012-020. 

OCTA recommends that SCAG continue to 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. These updates 

should focus particularly on the status of the MOU.

Comment noted. SCAG Transit/Rail staff has provided, and will continue to provide, regular 

updates to the SCAG Transportation Committee and Regional Council on regional rail 

issues and developments, including the CA HST project and MOU.

16059.03 The draft RTP/SCS includes implementation of a regional express lane network. This 

network proposes to increase occupancy requirements from 2+ to 3+ persons per vehicle 

on select existing and planned high-occupancy vehicle (HOV) lanes throughout the region. 

Pricing for single-occupancy and dual-occupancy vehicles will then be used to increase the 

throughput of the corridor and reduce emissions from congestion. As a result, this concept 

would generate additional revenues. When combined with tolls from a new east-west 

freight corridor in Los Angeles County, the projected revenues would total $23.5 billion. 

These funds are assumed to contribute toward the $200.4 billion regional shortfall. The 

proposed Regional Express Lane Network focuses on converting specific existing and 

planned HOV facilities to express lanes. However, the segment of State Route 55 (SR-55), 

between Interstate 405 (I-405) and State Route 91 (SR-91), is noted as a potential single or 

dual express lane facility. The potential for a dual lane facility is inconsistent with the 

projects submitted by OCTA in December 2014. The submittal identifies general purpose 

lane additions on SR-55, between I-405 and Interstate 5 (I-5), as well as between I-5 and 

State Route 22 (SR-22). OCTA did not submit any new capacity enhancements on SR-55 

north of SR-22. If new capacity is proposed, over and above the OCTA LRTP, new funding 

would be required that is likely dependent on state and federal legislative action. The 2016-

2040 RTP/SCS should consistently recognize the capacity enhancements along SR-55, 

between I-405 and I-5, and between I-5 and SR-22, as general purpose lanes. This is 

consistent with how these projects are characterized in OCTA’s LRTP, OCTA’s 2006 programlevel environmental document, and the current 2012-2035 RTP/SCS. Furthermore, the 

2016-2040 RTP/SCS should clearly recognize that the proposed express lane network is 

subject to further study to evaluate right-of-way impacts, community issues, and overall 

feasibility before any final decisions on implementation can be made.

References to State Route 55 operating as a dual express lane facility have been removed 

from the Plan. The constrained express lane segments in Orange County may be adjusted 

or changed to reflect the new findings and recommendations from SCAG’s Express Travel 

Choices Study and Caltrans District 12’s Managed Lane Network Study in subsequent 

amendments to the Plan. Both studies are expected to be completed in the summer of 

2016.

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Submitted by Orange County Transportation Authority Submittal 16059 Related Documents Link

16059.04 OCTA recognizes that it is within SCAG’s purview to plan for regional strategies that 

enhance transportation; however, it should be noted that OCTA is committed to delivering 

the projects within the LRTP. The 2016-2040 RTP/SCS should clearly state that the regional 

strategies suggest improvements beyond the projects submitted by OCTA, and that the 

implementation of the strategies is subject to availability of new revenue sources and the 

necessary project development and review processes by the implementing agencies. OCTA 

will only consider additional investments after new revenues are realized and identified to 

account for these additional improvements.

Comment noted. Descriptions for projects in the Project List Appendix have been revised 

to provide more clarity as applicable.

Submitted by Port of Hueneme Submittal 16180 Related Documents Link

16180.01 Page 4 of Executive Summary- the Goods Movement section –Port of Hueneme is not 

mentioned as Environmental Steward, its Green Initiatives are: • The Port, and every port 

tenant, is proactive about reducing emissions by using cleaner burning fuels in the vessels 

and equipment used to move cargo • Clean energy at The Port includes using energy 

efficient utilities and alternative fuels • Replacing conventional diesel with low emission 

propane-fueled trucks, and electrifying cargo handling equipment to reduce on-dock 

emissions • The Port actively monitors water quality to mitigate impacts to marine life and 

provides shoreside power for vessels and air quality improvement (over the 30 year life of 

the project) o 92% reduction in Particulate Matter o 55% reduction in Greenhouse Gases o 

98% reduction in NOx • In 2010, the Port developed a Non-compliant Truck Reporting 

System (NCTRS) to document and report all trucks not in compliance with the California Air 

Resources Board (CARB) drayage truck regulation • In 2009, the Port voluntarily prepared 

an Air Emissions Inventory (EI) to quantify the air quality impacts associated with maritime 

operations • Implementing Phase I of a Stormwater Improvement Plan • LED Lighting 

Project to reduce energy consumption • In 2015 Port of Hueneme became the First 

California Port to join Green Marine • Partnered with the US Navy and U.S. Army Corps of 

Engineers (USACE) to construct and monitor a Confined Aquatic Disposal Cell to dispose of 

contaminated sediment Please find more information on Port of Hueneme’s Green 

Program in case you would like to reference them as an example: 

http://www.portofhueneme.org/community/environment/ 

http://www.greenport.com/news101/Projects-and-Initiatives/hueneme-joins-greenmarine 

http://yosemite.epa.gov/opa/admpress.nsf/6424ac1caa800aab85257359003f5337/95d492f

5d48c36a985257cb400541364!OpenDocument

SCAG recognizes the substantial efforts made by the Port of Hueneme as an 

environmentally conscious port. Given that this is an executive summary, a full list of 

information would not be consistent with the abbreviated verbiage called for in this 

section. Moreover, this section is intended to highlight major accomplishments since the 

2012-2035 RTP/SCS. However, SCAG has updated the existing section on the Port of 

Hueneme in the Goods Movement Appendix to discuss the port's green initiatives.

16180.02 Page 7 of Executive Summary- Strengthening the Regional Transpiration Network for Goods 

movement-Ventura County projects are not added and there are several of them, please 

see link to the VCTC 2035 plan. http://www.goventura.org/?q=final-comprehensivetransportation-plan-ctp

Please note that this list is not an exhaustive list of all goods movement projects in the 

region. It is simply a snapshot of some of those projects. The entire list of goods 

movement projects is included in the 2016-2040 RTP/SCS Goods Movement Appendix and 

includes the Ventura County projects referenced.

16180.03 In Section-Our Progress Since 2012, Goods Movement Section- the Port of Hueneme Shore 

Side Power Clean Air Project that was done since then is not listed.

Our Progress Since 2012 lists mobility projects that are realized since 2012. Since the Port 

of Hueneme Shore Side Power Clean Air Project is not a mobility project, it will not be 

included in this graphic. However, SCAG added a discussion of this project in the goods 

movement appendix under Port of Hueneme section.

174
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Submitted by Port of Hueneme Submittal 16180 Related Documents Link

16180.04 In Section-Challenges in a Changing Region- the Draft Plan is missing a section on Seaports, 

perhaps right before Rail, there is segment on Seaports, the increase of cargo volumes 

since 2012 and how that affects the rest of the infrastructure-rail, highway, and intermodal 

corridors. If possible, please include reference to the Port of Hueneme 2020 Strategic Plan 

in the Draft Plan for RTPSCS. Here is the link to the plan. Thank you. 

http://www.portofhueneme.org/2020-strategic-business-plan/

We added a reference to Port of Hueneme in "Continued Growth in International Trade" 

as a growing port for specialized cargo. Further, the Goods Movement Appendix of 

the 2016 RTP/SCS includes a section focused on the Port of Hueneme's work, including 

the 2020 Strategic Business Plan.

Submitted by Port of Los Angeles Submittal 16164 Related Documents Link

16164.01.1 ACTIVE TRANSPORTATION APPENDIX Page 48: “Assist the Cities of Los Angeles and Long 

Beach in providing a continuous pedestrian and bicycle access across the replacements for 

the Vincent Thomas Bridge and Gerald Desmond Bridge linking San Pedro to Long Beach." - 

Consistent with the final City of Los Angeles 2015 Mobility Plan, remove Seaside Avenue on 

Terminal Island as part of the active transportation plan related to the California Coastal 

Trail. > Seaside Avenue is a high-speed (45 mph posted) expressway by function. It is also a 

major truck route and a federally designated National Highway System Intermodal 

Connector route, Countywide Strategic Truck Arterial Network (METRO CSTAN), and the 

Strategic Goods Movement Arterial Plan. Truck volumes will increase substantially over 

time. When the Gerald Desmond Bridge replacement is completed, the entire segment of 

Ocean Boulevard/Seaside Avenue between the I-710 and the State owned Vincent Thomas 

Bridge will be relinquished to Caltrans, and not suitable for bike lanes. > The Harbor 

Department has plans to eventually remove the last signal on Seaside Avenue, which will 

thus result in higher prevailing speeds on this major expressway, and not safe for bikes. > 

This area is an isolated segment in which there are not existing, planned, or proposed bike 

lanes easterly and westerly thereof. > Placing bike access through this area is not in line 

with the RTP goals and objectives for “Connectivity (pg. 48),” "Integrity (pg. 48),” and 

“Support and seek opportunities to promote safety” (pg. 73). • Add the following two 

projects: - Alameda Corridor Terminus/California Coastal Trail Extension Grade Separation 

(Pedestrian/Class I Bicycle Path bridge) - Consistent with the final City of Los Angeles 2015 

Mobility Plan: California Coastal Trail Ports O' Call Promenade (30-foot wide public 

promenade/Class I bike path) • Alameda Corridor Terminus/California Coastal Trail 

Extension Grade Separation (Pedestrian/Class I Bicycle Path bridge): $15 million (assume 

POLA funds for RTP purposes; POLA will be seeking State and possibly METRO ATP funds) • 

California Coastal Trail Ports O' Call Promenade (30-foot wide public promenade/Class I 

bike path) (assume POLA funds for RTP purposes; POLA will be seeking State and possibly 

METRO ATP funds)

The plan assumes a physically separated bicycle/pedestrian path across the Vincent 

Thomas Bridge replacement connecting to the planned Mark Bixby Bike Path (which is part 

of the Gerald Desmond Bridge replacement). Wording in the appendix has been updated 

to reflect separation. Alameda Corridor Terminus added. California Coastal Trail Ports o" 

Call Promenade added.

175
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Submitted by Port of Los Angeles Submittal 16164 Related Documents Link

16164.02 GOODS MOVEMENT APPENDIX Rail Infrastructure Outside Marine Terminals • Add: “Port of 

Los Angeles Rail Efficiency Program (Alameda Corridor - West Basin Area Gap Closures): $20 

million (assume included in total POLA cost for rail per Table 20.F in Goods Movement 

Appendix)” - This project will eliminate two short gaps in trackage between the West Basin 

area of the Port of Los Angeles and the Alameda Corridor (increasing the number of tracks 

from one to two in this area). This doesn’t change any on-dock railyard capacity 

assumptions, and thus doesn’t change any projections of train or truck volumes in the RTP. 

The project however does reduce train delays and idling. San Pedro Bay Ports Access 

Projects • SR 47/V. Thomas Bridge/Front St. Harbor Boulevard Interchange: Add to the 

description, “The Project also includes realigned eastbound and westbound SR 47 onramps.”

Comment noted. This project has been added to the list of projects under Rail 

Infrastructure Outside Marine Terminals section for Port of Los Angeles, and the project 

description for SR 47/V. Thomas Bridge project has been added.

Submitted by PTS Staffing Solutions Submittal 16067 Related Documents Link

16067.01 Comments on the RTP SCS draft. To continue our efforts to minimize the world’s 

greenhouse gases, we need to work with the Oil Infrastructure that serves the 38 million on 

the California’s “energy island”. The unintended consequences of CARB’s over regulations 

on the oil infrastructure industry are that when other states or countries opt to make the 

California boutique fuels, we would have an option to import our crude oil, transportation 

fuels, and jet fuels from other states or countries that have significantly less environmental 

controls. Thus, Imports would increase, not decrease, the world’s greenhouse gas 

emissions, and further raise the costs to deliver our transportation fuels from afar. The 

report should reference the 2016 ASCE Infrastructure Report Card that is due for 

publication around April 2016.

Comment noted. The California Air Resources Board and local air districts have jurisdiction 

over the oil infrastructure industry.

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Submitted by Public Health Alliance of Southern California Submittal 16230 Related Documents Link

16230.01 The 2016-2040 DRAFT RTP/SCS and the plan scenario point our region in the right direction, 

and represent important progress for considering the public’s health when planning for our 

region’s future. We are pleased that the plan does the following: • Puts the region on 

target to meet our AB 32 Greenhouse Gas Reduction goals of 8% by 2020. Climate change is 

a threat to public health in our region, our Alliance strongly supports the climate change 

mitigation actions included in this plan. • Includes increased investment in transit and more 

active modes of transportation, particularly in Los Angeles County. Transportation and built 

environment structures that support increased physical activity will significantly improve 

our region’s health. • Includes performance measures that will help us understand the 

health impacts of the plan, and measure our progress toward implementation. • Includes a 

more robust Environmental Justice analysis than prior plans, setting the stage for increased 

commitment to equity in our region. • Includes a framework for operationalizing the 

ongoing consideration of health in our regional planning, as detailed by the Public Health 

Work Program in the Public Health Appendix. • Is supported by data efforts, including the 

REVISION tool and the Urban Footprint Scenario Planning Module, which will allow us to 

project and understand trends in our region and plan impacts at a more granular level. • 

Includes targeted land use strategies to help meet plan goals, including intensification of 

land use in high quality transit areas, complete streets strategies, and the livable corridor 

strategies. We encourage SCAG members to work to implement these strategies within 

their local plans.

Comment noted.

16230.02.1 Recommendations for the Project List and Performance-Based Planning • Consider a 

performance-based cost/benefit analysis of the largest projects as a way of building 

authentic public engagement around funding decisions included in plan.

Comment noted. For clarification, a performance-based systems level cost/benefit analysis 

is conducted and reported.

16230.02.1 • Consider setting aside a portion of funding for a public discussion/ referendum on the 

types of projects to be included in the plan as a way of building public engagement. At this 

time there is no clear mechanism for public input on the project list.

Comment noted. SCAG has conducted an extensive public outreach effort soliciting public 

input before and after the release of the Draft RTP including the Project List.

16230.02.2 • Performance measures in general, and the public health and environmental justice 

measures in particular should include numeric targets rather than a simple directional 

goal/presentation of data. • Include a performance monitoring measure in the RTP/SCS 

tracking the number of very low, low, and moderate income housing units available and 

constructed as a way of gauging progress towards the 2013 Regional Housing Needs 

Assessment by 2021. • Maintain an updated public data porthole that allows the public to 

measure the implementation of the plan based on the performance measures used for plan 

selection.

Comment noted. The majority of the 2016 RTP/SCS performance measures include a 

target of providing a measurable improvement over the no-project Baseline result. The 

targets for the air quality performance measures are defined by Federal and/or State 

requirements. Criteria pollutant emissions must meet Federal Transportation Conformity 

mandates and greenhouse gas emission levels must meet State defined reduction targets. 

Similarly, targets for the Environmental Justice performance measures are defined by 

Federal requirements in that there should be no unaddressed disproportionately high and 

adverse effects for low income or minority communities. Regarding the tracking of the 

availability of low and moderate income housing units, this is a performance area that 

SCAG recognizes as critical to the future of our region. We will continue to work with our 

state, regional, and local partners to identify a reliable and meaningful methodology for 

evaluating progress toward housing affordability improvement in in our region. In 

response to the recommendation for a public data porthole, SCAG has been working on 

the development of a web-based application that will be accessible to the public for 

evaluating implementation of sustainable communities strategies at the local level. This 

online planning tool, known as 'REVISION', is expected to be online by Spring, 2016.

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Submitted by Public Health Alliance of Southern California Submittal 16230 Related Documents Link

16230.02.2 • In the PEIR, clarify which (if any) of the Strategic Projects are being modeled in the plan 

scenario. It is not clear from the existing documentation which projects were included at 

which stage in the modeling process.

Comment noted. As stated in Section 2.0, Project Description, of the PEIR, this PEIR for the 

2016 RTP/SCS does not analyze strategic projects because their lack of funding indicates 

that implementation is speculative at this point. If these projects become reasonably 

foreseeable, they will be included in the future RTP/SCS updates, and their impacts will be 

addressed in the PEIRs for future Plans. The documentation of RTP projects is the 2016 

RTP/SCS Project List. It is these project that are included for the technical and modeling 

process for the Plan and associated environmental analysis in the PEIR.

16230.03 • Consider a performance-based cost/benefit analysis of the largest projects as a way of 

building authentic public engagement around funding decisions included in plan

Comment noted. Please refer to the performance measure section of the Plan for a 

systems level cost/benefit analysis.

16230.04 • We applaud the inclusion of Safety and Health measures in the overall Plan Performance 

measures, particularly the “Daily amount of walking and biking related to work and nonwork trips” and the “Collision rates by severity and mode.” We encourage SCAG members 

to collaborate with SCAG, Public Safety, Caltrans, and Public Health Departments to 

improve the collection of data to track these metrics over time at a granular level. Data 

collection will be particularly important in tracking the impacts/ benefits of the plan to 

Environmental Justice communities where greater numbers of residents are reliant on 

active transportation modes. • We also encourage SCAG to update the data analysis and 

performance measures included in the public health appendix, where possible, provide this 

data at a granular level through the REVISION tool and other public data portals. This will 

facilitate the development of strategies and projects to advance public health supportive 

built environments while making it easier for member jurisdictions to incorporate public 

health analyses in their plans.

Comment noted. SCAG will take these suggestions into consideration when implementing 

the Plan.

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holdID Comment Response 

Submitted by Public Health Alliance of Southern California Submittal 16230 Related Documents Link

16230.05 • We commend the integration of Public Health into the development of the 2016-2040 

RTP/SCS. In particular, we strongly support the new Public Health Appendix to the plan, and 

appreciate the hard work that went into the creation of this document. • SCAG’s Public 

Health Working Group has created a forum for public health professionals to engage with 

the plan and to advance work on the RTP, and the broader goals of the Public Health Work 

Program. SCAG’s staff participation on the Alliance’s Healthy Transportation Working Group 

has further built constructive engagement between transportation planning and public 

health and we commend and look forward to this continued participation. • The Public 

Health appendix provides a primer explaining the Social Determinants of Health pathways 

through which planning and the RTP impact public health. We encourage SCAG to maintain 

the appendix as a living document and to include it in future RTP/SCSs to ensure future 

members and users understand these links. • We applaud the inclusion of Safety and 

Health measures in the overall Plan Performance measures, particularly the “Daily amount 

of walking and biking related to work and non-work trips” and the “Collision rates by 

severity and mode.” We encourage SCAG members to collaborate with SCAG, Public Safety, 

Caltrans, and Public Health Departments to improve the collection of data to track these 

metrics over time at a granular level. Data collection will be particularly important in 

tracking the impacts/ benefits of the plan to Environmental Justice communities where 

greater numbers of residents are reliant on active transportation modes. • We appreciate 

the inclusion of healthy food access on page 4 of the Public Health Appendix. Given the 

importance of this topic to health, we recommend integration of healthy food systems 

discussions into the broader RTP/SCS. An example would be to consider the impact of the 

food system on goods movement; i.e., how can preservation of local agriculture and 

development of urban agriculture in the region reduce the greenhouse gas emissions from 

that sector?

Comment noted.

16230.06 • We appreciate the effort on the part of the Strategic Growth Council, SCAG and others to 

develop the Urban Footprint Scenario Planning Model (SPM) Public Health Module as a tool 

for helping evaluate the health impacts of proposed scenarios. • While there is room for 

the refinement of this tool both in terms of including a risk exposure pathway and in 

addressing member’s concerns related to the land use codes, we think the Urban Footprint 

SPM Health Module is useful in providing a ballpark assessment of some of the health 

benefits that may come from the plan. • We are encouraged by the estimated health 

benefits of the plan scenario, which projects a 2.5% decrease in the regional obesity rate, 

3% reduction in share of population with high blood pressure and a 13% reduction in total 

annual health costs for respiratory disease. • We encourage SCAG and its member agencies 

to capture the value of our investments in active transportation by purchasing bicycle and 

pedestrian counters, and investing in National Household Transportation Survey (NHTS) 

oversample for active modes for the entire region. Detailed tracking of the physical activity 

increases resulting from the plan are key to understanding health impacts as well as how 

injury rates are related to exposure. • In future years as data investments such as 

automated counters improves the granularity of our bike and walk mode share and trip 

length data, we encourage SCAG to analyze health co-benefits by using a relative risk 

assessment tool such as the ITHIM model.

Comment noted. SCAG will continue to refine its modeling processes around these issues 

and will consider using new tools when appropriate.

179
holdID Comment Response 

Submitted by Public Health Alliance of Southern California Submittal 16230 Related Documents Link

16230.07 • We are encouraged by the estimated health benefits of the plan scenario, which projects 

a 2.5% decrease in the regional obesity rate, 3% reduction in share of population with high 

blood pressure and a 13% reduction in total annual health costs for respiratory disease. • 

We encourage SCAG and its member agencies to capture the value of our investments in 

active transportation by purchasing bicycle and pedestrian counters, and investing in 

National Household Transportation Survey (NHTS) oversample for active modes for the 

entire region. Detailed tracking of the physical activity increases resulting from the plan are 

key to understanding health impacts as well as how injury rates are related to exposure. • 

In future years as data investments such as automated counters improves the granularity 

of our bike and walk mode share and trip length data, we encourage SCAG to analyze 

health co-benefits by using a relative risk assessment tool such as the Integrated 

Transportation Health Impact Model (ITHIM).

Comment noted. Added action step under Plan Implementation (Page 70) to encourage 

local jurisdictions to purchase automated counters as part of infrastructure development. 

Health benefits of the plan from physical activity are currently measured using the Public 

Health Module of the UrbanFootprint Scenario Planning Model. SCAG will improve upon 

modeling processes for active transportation in future years. SCAG plans to improve data 

collection through the expansion of the current Bicycle Data Clearinghouse into an Active 

Transportation Database and partnerships with county and local jurisdictions.

16230.08 • The Environmental Justice (EJ) outreach process and analysis is significantly more robust 

in this 2016-2040 RTP/SCS than in prior years. Thank you for incorporating the feedback we 

provided through the workshops and focus groups, and including the “Active 

Transportation Hazard” and “Climate Vulnerability” measures. • Displacement and 

gentrification are particularly important areas for action in the coming years. We appreciate 

the analysis of this issue in the EJ appendix, and its brief treatment in the Environmental 

Justice toolbox, however given the enormous affordable housing deficit in our region, and 

the trend of the displacement of transit-captive populations from the most transitaccessible urban core, more action on displacement will be necessary in order to realize the 

VMT-reductions promised by our transit investments. We encourage SCAG members to 

convene a task force specifically dedicated to this issue. Because transit investment is a 

proven driver of displacement, this task force should seek to develop a fiscal structure for 

ensuring that the added land value of transit investment is captured for the development 

of affordable housing, with the minimum goal of achieving a ‘no net loss’ of affordable 

units within High Quality Transit Areas. • The 2015 County of Riverside Community Health 

Assessment, which involved community forums and surveys, both homelessness and 

housing affordability surfaced as high priorities for residents. The fear of displacement is 

also a concern for residents of San Bernardino County. Strategies to address housing 

affordability should take the entire region into account.

SCAG will consider emerging and persistent regional issues, including suggestions from the 

comment process, and may propose new task forces/sub-committees as needed. SCAG is 

also exploring ways to address social equity issues, including gentrification and 

displacement, beyond the RTP/SCS process, and will continue to work with stakeholders to 

discuss challenges and potential strategies for the SCAG region. SCAG acknowledges that 

progress on affordable housing has been insufficient in meeting the needs of the region. 

The language of the draft 2016 RTP/SCS has been edited to draw more attention to the 

dire need of affordable housing in the region. As a regional planning agency, SCAG 

encourages jurisdictions to consider different strategies to utilize at the local level to 

promote the development of affordable housing, and SCAG has included an affordable 

housing strategy toolbox for jurisdictions as part of the affordable housing section in 

chapter 3. We are committed to working with our local jurisdictions to ensure that their 

housing elements are in compliance with State housing law and offer technical assistance 

for affordable housing grant programs such as the Affordable Housing & Sustainable 

Communities (AHSC) program, California Department of Housing and Community 

Development Transit-Oriented Development (TOD) grant, and establishing community 

revitalization and investment agency or enhanced infrastructure financing districts.

16230.09 • The EJ analysis should explicitly align the discussion with the Social Determinants of 

Health and the Public Health appendix, as there is no mention of the concept throughout. 

Consider using the California Planning Roundtable’s Social Determinants of Health paper as 

a resource to explain the connection between these two appendices for newcomers to the 

field. • Given the pressing nature of inequity, displacement, and poverty in our region, we 

recommend greater integration of the performance measures and mitigation actions 

included in the Environmental Justice appendix within the main body of the RTP/SCS.

Comment noted. SCAG will enhance our analysis by integrating the Public Health Alliance's 

California Health Disadvantage Index in the coming years, which will increase the linkage 

between the Environmental Justice and Public Health programs as this dataset touches 

specifically on the "Social Determinates of Health" approach. As part of its Environmental 

Justice Appendix, SCAG also put together an Environmental Justice Toolbox of possible 

mitigation measures to address potential impacts to Environmental Justice communities. 

On page 195 of the appendix, there is a list specifically for potential resources and 

strategies related to public health, along with gentrification and displacement. Because 

many of these strategies concern local land use decisions, the toolbox strategies are 

voluntary but SCAG encourages communities to consider them as part of the local decision 

making process. Chapter 3 of the final RTP/SCS also includes a reference to the EJ 

Appendix.

180
holdID Comment Response 

Submitted by Public Health Alliance of Southern California Submittal 16230 Related Documents Link

16230.10 • The Environmental Justice (EJ) outreach process and analysis is significantly more robust 

in this 2016-2040 RTP/SCS than in prior years. Thank you for incorporating the feedback we 

provided through the workshops and focus groups, and including the “Active 

Transportation Hazard” and “Climate Vulnerability” measures. • We particularly appreciate 

SCAG’s inclusion of multiple methods of identifying EJ communities. Due to the complex 

and localized nature of the issues EJ communities face, we would encourage SCAG to 

provide the detailed community-level analysis that is presented in aggregated form in the 

EJ appendix through a public data portal for use by individual communities. • The Public 

Health Alliance has developed the “California Health Disadvantage Index” as a tool for 

identifying community disadvantage from a ‘Social Determinants of Health’ perspective. 

We encourage SCAG to consider the use of this tool for future EJ analysis, and as a layer for 

inclusion in future publicly available datasets on this topic.

Comment noted. SCAG will continue to enhance our environmental justice efforts in the 

region and will evaluate the potential of providing localized analysis through a web portal.

16230.11 • Page 5 and page 39: Please update this sentence: In Riverside County, the Healthy 

Riverside County Initiative is working to have healthy cities resolutions adopted by a 

minimum of 15 cities. To read: In Riverside County, the Healthy Riverside County Initiative 

has formed a Healthy City Network to continue to successfully work with the county’s 28 

cities to enact Healthy City Resolutions and Health Elements into their General Plans. • 

Page 16, #2: Collaborating with Member Agencies, Jurisdictions and Stakeholders: Please 

explicitly mention public health departments as one of the key stakeholders, modifying the 

fifth sentence in that section to read: The Agency will also have to work with key 

stakeholders including local public health departments to ensure... • Page 20, Categorizing 

Land Use: Rural development, which is neither suburban nor natural lands, does not fall 

into any of the listed categories. We would appreciate either a clarification of which of the 

categories rural land uses fall under, or a new, separate category addressing rural 

development.

p.5 and 39 Comment noted. Changes made to Plan. p.16 Comment noted. Changes made 

to Plan. p.20 Comment noted. As noted on page 20, 35 “Place Types” were utilized in the 

urban setting design tool (Urban Footprint Scenario Planning Model (SPM). It is the Place 

Types that factor into the modeling analyses. LDCs are utilized in order to describe general 

conditions within areas of the SCAG region and do not play a role in the modeling analyses. 

The 35 Place Types were then sorted into the three Land Development Categories (LDCs). 

Place Types that have a “rural” category are included in the Standard LDC and have a 

distinct travel behavior and housing and commercial mix.

Submitted by Puente-Chino Hills Task Force of the Sierra Club Submittal 16168 Related Documents Link

16168.01 The 2012 RTP/SCS provided an important stepping stone for the 2016 Plan. In previous 

Plans, natural lands and farmlands were handled under the banner of “land use.” In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn’t be overlooked. We 

believe the opportunity before you isn’t to “plan for” the future of open space in the 

region—as that’s what you’ve been doing since the 2012 Plan. Instead, we believe SCAG 

can now start “implementing” a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. We and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation programs. Your coalition is 

encouraged to participate in the effort.

181
holdID Comment Response 

Submitted by Puente-Chino Hills Task Force of the Sierra Club Submittal 16168 Related Documents Link

16168.02 We have reviewed the RTP/SCS and PEIR and offer the following comments and 

suggestions for inclusion in the Plan with the intent to clarify/strengthen the language, as 

well as link the goals of the RTP and SCAG’s mission with the Natural and Farmland policies. 

Identify a Conservation Mechanism for the Natural and Farmlands Preservation Our 

organization supports the idea that as new growth occurs it should focus on the existing 

infill areas. This is consistent with the finding in the SCAG surveys where respondents 

preferred to see existing urban areas built upon before greenfields are targeted for 

development, especially those at the Wildland-Urban Interface. When developments are 

built in infill areas, it likely relieves pressure from the fringe. However, the Plan fails to 

outline exactly how (or with what mechanism) these fringe lands (or any lands) will actually 

be protected. Just because the pressure is relieved doesn’t mean the land then 

automatically becomes protected. Numerous organizations, ours included, focus their work 

on preservation of important habitat lands. A lot of time, energy, political will, strategy and 

other efforts combine to create a successful conservation transaction that leads to 

permanently conserved lands. SCAG must identify the mechanism, process or plan on how 

the greenfield lands will be protected.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16168.03 SCAG’s Support of Regional Wildlife Corridors The current federal transportation bill, FAST 

Act, supports understanding transportation impacts on natural resources. The previous bill, 

MAP-21, supported restoring and maintaining environmental functions (i.e., wildlife 

corridors) affected by the infrastructure projects in the RTP. SCAG has even supported 

efforts in Los Angeles County to create a wildlife corridor over the 101 Freeway. Many 

efforts are underway across the region to connect landscapes to one another. This is very 

important to the region and its biodiversity. Wildlife corridors allow species to migrate and 

forage and expand genetic diversity. These corridors also allow ecosystems to maintain 

ecological functions, act as sources for repopulation after natural disasters such as fire, 

flood or landslide, and improve the resiliency in the face of climate change impacts. The 

Plan would be stronger if it supported the enhancement of and/or protection of 

documented and regionally significant wildlife corridors, especially those that are impacted 

by infrastructure projects.

Comment noted. The RTP/SCS describes (in Chapter 5) next steps for further developing a 

habitat conservation strategy. Included in the steps is the recommendation to provide 

“incentives for jurisdictions to cooperate across county lines to protect and restore natural 

habitat corridors, especially where corridors cross county boundaries.” The Natural/Farm 

Lands Appendix further supports wildlife corridors in its recommended policies, with the 

specific recommendation to “Encourage and facilitate research, programs and policies to 

identify, protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Additionally, continue support for preserving wildlife corridors and 

wildlife crossings to minimize the impact of transportation projects on wildlife species and 

habitat fragmentation.”

Submitted by Redlands Tea Party Patriots Submittal 16055 Related Documents

16055.01 Can we solve these problems in ways that increase freedom rather than decrease freedom? Comment noted. We believe the plan enables greater freedom through expanded mobility 

choices that meets the needs of all segments of our society. There is nothing in the plan 

that takes away anyone's ability to choose where they live, work, and how they choose to 

move around.

182
holdID Comment Response 

Submitted by Riverside County Transportation Commission Submittal 16244 Related Documents Link

16244.01 The effort SCAG undertook in developing the regional demographic forecast to reflect 

general plans and local input allows the jurisdictions and agencies to uphold established 

goals and policies at the local level and maintain consistency with regional goals and 

policies. We are also pleased that the document indicates capacity projects are supported 

in the SCAG region. Given the 40 percent population growth expected in Riverside County 

over the life of the plan, it is essential that we continue increasing capacity for all modes, 

including lane additions, new corridors, and increased transit options.

Comment noted.

16244.02 The draft 2016 RTP/SCS states that the shortfall in funding over the life of the plan can be 

filled through actions at the state and/or federal levels. We agree with this notion and urge 

SCAG to advocate for such actions, including the need to require federal participation in 

reducing criteria pollutants that are outside the region's control (e.g. regulating ships, 

trains, and planes). It is imperative that all emissions sources are addressed by the 

responsible entity in order to maximize emissions reductions.

Comment noted.

16244.03 We are requesting that the actions and strategies for additional funding and regional 

projects, such as the Regional Bikeway Network and Regional Express Lane Network, be 

clearly delineated as to which projects are planned and included in county long range plans, 

and which projects are part of SCAG's strategic plan and are not included in county long 

range plans. The draft 2016 RTP/SCS should clearly distinguish the costs associated with 

these regional networks and that these networks are above and beyond what is identified 

in current county transportation plans.

RTP ID 7120004 and 7120013 identify the cost of additional active transportation and 

regional express lane network investments, respectively, that are beyond what was 

submitted by the county transportation commissions. The description for RTP ID 7120013 

in the Project List Appendix has been revised to provide more clarity.

16244.04 Existing text: Pg. 4 – Under “Passenger Rail”, revise 2nd sentence “Metrolink is nearing 

completion on the Perris Valley Line;” Modify text to read: Under “Passenger Rail”, revise 

2nd sentence “Riverside County Transportation Commission is nearing completion on the 

Metrolink Perris Valley Line;” The above change also needs to occur in Chapter 2 – Where 

We Are Today, Under “Passenger Rail”

This comment has been incorporated into the Passenger Rail Appendix and Chapter 2.

16244.05 Existing text: Pg. 4 – Under “Highways”, Revise last sentence “...and the Interstate 215 BiCounty project in Riverside and San Bernardino Counties,..” Modify text to read: Pg. 4 – 

Under “Highways”, Revise last sentence “...and the Interstate 215 Bi-County HOV project in 

Riverside and San Bernardino Counties,..” In addition, the 215 Bi-County HOV project 

should be included in the following section – “Regional High-Occupancy Vehicle (HOV) and 

Express Lane Network”. The above changes should also be reflected in Chapter 2 – Where 

We Are Today, Under “Highways” and “Regional HOV and Express Lane Network” sections.

Comment noted. Appropriate edits have been made to incorporate this comment.

16244.06 Pg. 4 - Under “Regional HOV and Express Lane Network”, revise 2nd sentence to include SR91 HOV lanes. The 91 project added HOV lanes from the 60/91/215 Interchange to Adams 

Street, which is nearly complete and should be reflected as such in this section.

Comment noted. The text has been revised to reflect State Route 91 HOV lanes.

16244.07 Pgs. 40 & 41, Under “Our Progress Since 2012 – Mobility Projects in the SCAG Region”, the 

map and project listing should include the SR-91 HOV project, from the 60/91/215 

interchange to Adams Street, which will be open to traffic early 2016.

Comment noted. Appropriate edits have been made to incorporate this comment.

16244.08 Pg. 60 – Under Goals and Guiding Polices section, recommend adding “FAST ACT” federal 

transportation bill recently approved.

Comment noted. Appropriate edit has been incorporated in the Final 2016 RTP/SCS.

183
holdID Comment Response 

Submitted by Riverside County Transportation Commission Submittal 16244 Related Documents Link

16244.09 Pg. 62 – Existing text: Under “Our County Transportation Commissions” 1st paragraph, 1st 

sentence, “...allocating locally-generated transportation revenues, and, in some cases,...” 

Modify text to read: Under “Our County Transportation Commissions” 1st paragraph, 1st 

sentence, “...allocating locally-generated transportation revenues, state and federal 

funding, and, in some cases,...” Pg. 62 – Existing text: Under “Our County Transportation 

Commissions” 1st paragraph, 3rd sentence, “...to receive (or already receiving) federal 

funds.” Modify text to read: Under “Our County Transportation Commissions” 1st 

paragraph, 3rd sentence, “...to receive (or already receiving) federal and state funds.”

Comment noted. Appropriate edit has been incorporated in the Final 2016 RTP/SCS.

16244.10 Pg. 97 – Under Freeway to Freeway HOV Connectors, the SR-91/71 Interchange 

improvement will construct a freeway to freeway connector, however, it does not include 

HOV lanes. This project should be removed from this listing.

Comment noted. Appropriate edits have been made to incorporate this comment.

16244.11 Pg. 109 – Throughout this page and other pages MAP-21 is mentioned, which should be 

updated to reflect FAST ACT.

Comment noted. Appropriate edit has been incorporated in the Final 2016 RTP/SCS.

16244.12 Pg. 111 – Under Conservation Planning Policy, Riverside County has had in place a MultiSpecies Habitat Conservation Plan (MSHCP) in Western Riverside County and a separate 

plan that covers Coachella Valley. Therefore, these plans could be mentioned in this section 

to inform the public of the plans that currently exist in the SCAG region. Pg. 116 – Under 

Mineral Resources, editing comment on 1st sentence, remove repeated words “as well as 

well”.

Comment noted. Page 1 of the Natural/Farm Lands Appendix recognizes and references 

the Coachella Valley and Western Riverside Multiple Species Habitat Plans (MSHCPs). The 

sentence on page 116 has been edited to reflect this comment.

16244.13 It isn’t clearly delineated what areas of the plan are funded with Core Revenues, 

Reasonably Available Revenues, and New Revenue Sources and Innovative Financing 

Strategies. For example, do all of the Strategic Plan projects or strategies require New 

Revenue Sources and Innovative Financing Strategies? As an example, since the Active 

Transportation Program’s Regional Greenway Networks are identified in the Strategic Plan, 

it could be construed that the majority of this strategy is unfunded and would require a 

new revenue fund source and/or an innovative financing strategy. The Plan states $356.1 

billion is from Core Revenues and $556.5 billion equates to the revenue and expenditures 

of the Plan. How much of each project category (highways, transit, ATP, etc.) is considered 

Core Revenues and Reasonably Available Revenues versus New Revenue Sources and 

Innovative Financing Strategies? The Plan should clearly address what areas are “unfunded”

 requiring New Revenue Sources and Innovative Financing Strategies.

Each expenditure category in the Plan is subject to funding shortfalls that cannot be fully 

met with core revenue sources. System preservation needs—maintaining and preserving 

our roads, highways, bridges, transit and bicycle and pedestrian facilities—in particular, 

require a considerable additional reasonably available new sources of transportation 

funding over the next 25 years to reach a state of good repair. The Strategic Plan is 

unconstrained and no funding assumptions have been made for the projects and programs 

identified therein. The Plan includes an estimated $2.6 billion for the Regional Greenway 

Network as part of the financially constrained Plan. The Active Transportation Appendix 

Table 12 has been modified to reflect it as part of a constrained plan. The discussion of the 

Expanded Regional Greenway Network in the Strategic Plan is considered to be beyond the 

Regional Greenway Network included in the financially constrained Plan. In accordance 

with state and federal requirements, the 2016 RTP/SCS financial plan estimates how much 

funding will be needed to implement transportation investment needs, as well as operate 

and maintain the transportation system as a whole over the life of the Plan. The Plan 

demonstrates that there is a balance between the estimated costs of the projects and 

programs described in the Plan and revenue sources reasonably expected to be available 

for transportation investments.

184
holdID Comment Response 

Submitted by Riverside County Transportation Commission Submittal 16244 Related Documents Link

16244.14 Pg. 147 – Under Vehicle Miles Traveled (VMT) Per Capita – this section should mention that 

VMT is a significant metric, however, with the increased usage of electric or alternative 

fueled vehicles reducing VMT will become less significant in achieve greenhouse gas 

emissions reductions. Pg. 160 – Under SB 375 and Greenhouse Gas Emission Reductions, 

this section should reflect the importance of requiring other emissions sources, specifically 

from freight locomotives and rail yards and airplanes, to take on its fair share of GHG 

reduction measures. Pg. 165 – Under Performance Measure 15: Rail-related Impacts, last 

sentence, suggest adding “...and examines environmental justice concerns that may 

potentially be alleviated by grade separation projects

Comments noted. The VMT per capita performance measure is included in the 2016 

RTP/SCS in recognition of the urgency for monitoring progress toward reduction of 

greenhouse gas emissions in the SCAG region to meet State emissions reduction targets in 

a timely manner. While it is understood that a growing market share over time for electric 

and alternative fueled vehicles will eventually impact the influence that VMT has on 

greenhouse gas emissions, for the timeframe of the 2016 RTP/SCS it is recognized that the 

per capita VMT metric is a very useful tool for measuring progress toward meeting 

greenhouse gas reduction goals in the SCAG region. The proliferation of alternative fueled 

vehicles is itself a very valuable strategy in combatting greenhouse gas emissions, and 

SCAG will continue working with our state, regional, and local partners toward identifying 

a reliable and meaningful performance measure for evaluating the impact of electric and 

alternative fueled vehicles for possible future use to supplement the current VMT per 

capita measure. It is acknowledged that greenhouse gas emissions from railroad and 

aviation sources need to be addressed as part of an integrated transportation segment 

strategy toward achieving our regional greenhouse gas reduction targets. However, the 

context of the referenced section of the Performance Measures chapter is confined to the 

contribution made by automobiles and light duty trucks to regional greenhouse gas 

emissions. These transportation modes are estimated to account for 50 percent of air 

pollution in the state and 70 percent of statewide petroleum consumption. The suggested 

text edit under the Rail Related Impacts Environmental Justice performance measure has 

been incorporated into the document.

16244.15 Pg. 24 – Under “4. Encourage development of local plans” – include Riverside Transit 

Agency is developing a first/last mile study. Pg. 28 – Table 12 does not indicate whether the 

strategies are constrained or unconstrained. In addition, the footnote indicates all projects 

were provided by County Transportation Commissions and local active transportation 

plans. However, the strategies are not reflective of CTC submittals, at least in the case with 

Riverside County, and include above and beyond what RCTC submitted. Please distinguish 

SCAG’s Regional Trip Strategies are above and beyond what the CTCs have submitted. Pg. 

29 – Under Regional Trip Strategies, the 1st sentence states that the ATP invests $2.8 billion 

in the Regional Trip Strategy. Is the Regional Trip Strategy Constrained or Unconstrained or 

both? If both, how much is Constrained and Unconstrained/Strategic Plan? Pg. 62 – Exhibit 

28 Riverside County, is the network considered in the Unconstrained/Strategic Plan? Should 

be a footnote explaining this. Pg. 69 – Under “Plan Implementation” – Include a bullet 

indicating that SCAG will advocate for state and federal funds to implement the SCAG 

Regional Bikeway Network and Regional Greenway Network.

Page 24 - Added reference to Riverside Transit Agency Page 28 - Constrained. Reference 

has been added to the table. Page 28 - Footnote changed to "Includes all projects provided 

by County Transportation Commissions, Local Active Transportation Plans and Regional 

Strategies." Page 29 - Constrained. Reference added to table. Page 62 - Constrained. 

Reference added. Page 69 - Comment noted. Existing bullet states "SCAG will support 

regulatory and legislative solutions that can increase funding for active transportation 

safety, infrastructure and education" which applies to all portions of the active 

transportation component of the 2016 RTP/SCS.

16244.16 Pg. 31 – Under “Ground Access Projects Currently Under Construction (or in Design)” – The 

I-215 North HOV project has not started design and should be removed from this listing, or 

indicate that it is a “future planned” project. Pg. 32 – “Under 2016 RTP Ground Access 

Projects” – are these projects in the constrained plan? It should clearly highlight whether 

they are constrained or not.

Comment noted. Staff have made appropriate adjustments to address this comment.

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holdID Comment Response 

Submitted by Riverside County Transportation Commission Submittal 16244 Related Documents Link

16244.17 Pg. 2 – Under “County Congestion Management Programs”, 1st sentence states that “Under

 California Law, urbanized areas must prepare a Congestion Management Program”. Under 

Section 65088.3 of the Govt code allows counties to opt out of adopting a CMP. Therefore, 

this sentence needs to be revised to reflect Section 65088.3. It is our understanding that if 

a county opts out of the State CMP requirements that federal Congestion Management 

Process must be adhered to. Pg. 3 – Under “Roles and Responsibilities of Partner Agencies”, 

1st sentence, suggest revising: “Currently, five of the six counties in the SCAG region (all but 

Imperial County) have adopted CMP’s that generally fall under the state congestion 

management requirements...” Also, last sentence in this paragraph misspelled “SCAG”. Pg. 

7 – Under “Roadways”, 2nd sentence, add word: “...-defined roadway network that is 

monitored for LOS approximately every two years.” Pg. 10 – Under “County Congestion 

Management Program Trends”, 3rd paragraph, last sentence, revise wording “...in RCTC’s 

Capital Improvement Program (CIP) where were and are expected to improve the LOS to E 

or better”. Pg. 27 – Under “According to GlowbalWorkplaceAnalysitcs.com:”, 3rd bullet, 

minor edit: “...the size of the overall the (delete preceding "the") non-self-employed 

workforce” Pg. 28 – Under “Bike Share”, paragraph should emphasize that Bike Share 

programs are successful in certain areas (e.g. HQTAs,) with biking infrastructure planned or 

in place. Pg. 29 – Under “Short Trip Strategies”, 3rd paragraph, revise sentence to: “The 

SCAG Region is investing $12.9 billion in active transportation projects...” Pg. 29 – Under 

“Regional Bikeway Network”, add bullet stating that SCAG will advocate for additional 

federal and state funding sources for Active Transportation projects. Also, it would be 

helpful if SCAG could identify which bullets are short versus long term goals. Pg. 31 – Under 

“The Federal Transportation Improvement Program (FTIP) – Single Occupancy Vehicle (SOV) 

Capacity-Enhancing Projects”, 1st paragraph, last sentence, “Under federal law, the FTIP 

must be updated every two years for funding”. I could not find this reference in the federal 

Congestion Management Process Guidebook. It does not mention a timeframe only 

recommends when planning documents are updated such as the RTP. Therefore, I suggest 

removing this sentence unless staff finds the specific reference.

Page 2. Comment noted. This comment has been incorporated into the Congestion 

Management Appendix. Page 3. Comment noted. The typo has been corrected. Page 7. 

Comment noted. This comment has been incorporated into the Congestion Management 

Appendix. Page 10. Comment noted. This comment has been incorporated into the 

Congestion Management Appendix. Page 27. Comment noted. This comment has been 

incorporated into the Congestion Management Appendix. Page 28. Comment noted. As 

bike share is a new concept for Southern California, and at the time of writing, local plans 

were still in development, an overview of the bike share concept was included as well as 

levels of success from similar sized bike share programs. Existing language reflects benefits 

that are attributed to the similar programs and not to any specific bike share plan or 

project in Southern California. Inserted references in the Active Transportation Appendix 

to established roll outs in Santa Monica, planned roll outs by Los Angeles County Metro 

and Long Beach, indicating that growth of bike share would likely expand beyond their 

initial plans. Page 29. Short-Trip Strategies. Comment noted. This comment has been 

incorporated into the Congestion Management Appendix. Page 29. Regional Bikeway 

Network. Comment noted. In the Active Transportation Appendix, SCAG includes an action 

"SCAG will support regulatory and legislative solutions that can increase funding for 

active transportation safety, infrastructure and education" which applies to all portions of 

the active transportation component of the 2016 RTP/SCS. Page 31. FTIP. Comment 

noted. This sentence has been deleted from the paragraph.

16244.18 Pg. 31- Under “Monitoring Projects for Compliance With the CMP”, 2nd bullet under 4, 

minor edit: “Environmental Impact Statement/Environmental Impact Statement Report 

(EIS/EIR)” Pg. 32 – Under “Congestion Management Under MAP-21”, should be updated to 

reflect FAST ACT.

Page 31. Comment noted. This comment has been incorporated into the Congestion 

Management Appendix. Page 32. Comment noted. Text in this section has been updated 

to reflect adoption of the FAST ACT.

16244.19 Pgs. 122-130, the maps don’t cover the DACs/Areas of Concern in the Eastern Coachella 

Valley. Although the cities are listed further in the appendix it would be helpful if SCAG 

could widen the map to include this area.

Maps included on pages 122-130 of the draft Environmental Justice Appendix include an 

inset for the Eastern Coachella Valley and Imperial County.

186
holdID Comment Response 

Submitted by Riverside County Transportation Commission Submittal 16244 Related Documents Link

16244.20 Pg. 2 – Under “Primary Freight Network”, 1st sentence, spell check “...for Progress in the 

21st Century...” Pg. 6 – Table 2, Adding up the columns for “All Goods Movement 

Dependent Industries” it shows that it is off by one. May be due to rounding. Pg. 7 – Table 

3, when you add “Percent of Total” column, you get 99%. May be due to rounding. Pg. 8 – 

Under “Retail Supply Chains”, 2nd paragraph, 3rd sentence states: “...GDP contribution was 

$106.87 billion for manufacturing and $53.66 billion for retail (Table 4)”. However, these 

amounts cannot be found in the referenced Table 4. Pg. 12 – paragraph above “Technology 

and Consumer Behavior Impacting Goods Movement”, last sentence “...a combined $545 

billion to regional GDP by 2040 (FIGURE 4)”. Can’t relate or find the $545 billion in Figure 4. 

Pg. 21 – Under “Benefits of the East-West Freight Corridor”, 5th bullet, “Reduction of TruckInvolved Accidents” – East-West Freight Corridor is referred to as EWFC many times in prior 

bullets on this page. Suggest referencing it as EWFC to be consistent. Pg. 22 – 7th 

paragraph, last sentence: missing “to”, “...issues are anticipated to be monitored...” Pg. 22 – 

bullets, suggest removing “Interstate”, “State Route” after colons. For example: Interstate 

5: At 210, between 2 and 710, South of 605, between 22 and 55. Pg. 22 – Last paragraph, 

2nd sentence “...the Corridor System Management Plan (CSMP)..” The abbreviation is 

already included in the 1st paragraph of this page, therefore, continue referencing CSMP in 

the last paragraph as well. Pg. 25 – Table 9, missing “-“ in front of 215, 57, and 23 should 

read “I-15/I-215”, etc. Pg. 25 – Table 9, “SR-91 Fast Forward” project is located in what 

county? Description does not indicate location. Pg. 31 – Under “On-Dock/Near-Dock Rail 

Capacity Enhancements”, 1st paragraph, 1st sentence, “...36.6 percent of the Ports’...” - For 

consistency, the full name of the ports have been referenced. Pg. 52 – Table 18, correct the 

Auto Center Dr grade separation and show as “Complete”. Pg. 53 – Table 18, correct the 

Riverside Ave grade separation and show as “Complete”. Pg. 53 – Table 18, correct the 

Avenue 52 grade separation and show as “Complete”.

We have corrected the spelling error in the first sentence as noted. This is a rounding 

error. The percentage of other goods movement is less than 1 percent. The Percent of 

Total in Table 3 is also a rounding error. The GDP reference should be to Figure 4. The 

$545 billion is an estimate for the regional GDP of the manufacturing, construction, and 

retail industries in 2040, but there is no corresponding graphic. The wording has been 

fixed. Bullet has been updated to EWFC. The word "to" has been inserted on page 22. The 

use of "Interstate" and "State Route" is correct within the APA style guide used for the 

2016-2040 RTP/SCS. CSMPs has already been referenced and text has been revised. Table 

9 has been changed. Update made to San Pedro Bay Ports. Tables updated to show Auto 

Center Drive, Riverside Ave., and Avenue 52 as complete. 

187
holdID Comment Response 

Submitted by Riverside County Transportation Commission Submittal 16245 Related Documents Link

16245.01 Pg. 4 – Under “Riverside County”, recommend revising to: “In Riverside County, fixed route 

bus service is primarily operated by RTA and SunLine Transit. RTA’s service area is the 

western portion of Riverside County and SunLine’s service area is the Coachella Valley. 

RTA’s jurisdiction is among the largest transit systems in the nation, and SunLine has led 

the industry by being the first public agency to convert all of its vehicles to CNG. RCTC funds 

the county’s participation in the regional commuter rail service via Metrolink, and the cities 

of Riverside and Corona operate demand response and local circular service. The cities of 

Banning and Beaumont also provide service via the Pass Transit service brand, and Desert 

Roadrunner service is provided by the Palo Verde Valley Transit Agency covering the City of 

Blythe and unincorporated eastern Riverside County. Rural transit service in southwestern 

Riverside County is provided by the Reservation Transportation Authority, a collaborative of 

18 federally recognized tribal groups.” Pg. 12 – Under “Transit and Mobility in the SCAG 

Region”, 1st paragraph, 1st sentence - revise to “in addition to 388 route miles of rail...”. 

(delete miles) Pg. 33 – Under “Historical Investments”, 2nd paragraph, 1st sentence - revise 

to “ ...for fixed route bus service,. Nearly 6 percent...”. (add the period after service and 

take out comma) Pg. 45 – last paragraph, 2nd sentence, delete extra period at the end of 

the sentence. Pg. 64 – Under “Riverside County”, 2nd part of first paragraph, first sentence, 

“..local Measure I” should be “local Measure A”. Pg. 66 – 4th paragraph, 2nd sentence, “This

 list includes bur...”, change bur to bus. Pg. 85 – 2nd complete sentence found on the page, 

“...in the last years twenty often...” revise to “...in the last twenty years often...” Pg. 89 – 3rd 

paragraph, last sentence, “...funding shortfalls in the due to these...” remove “in the”. Pg. 

89 – 1st bullet found within the “Volunteer Driver Program” section, “Passengers are 

enabled choose and recruit...” revise to “Passengers are enabled to choose and recruit...”. 

Pg. 90 – under “Growing Older Cohort”, 1st paragraph, 2nd sentence, add “of” before 65. 

Pg. 90 – under “Growing Older Cohort”, 3rd paragraph, 1st sentence, revise “cost effect” to 

“cost effective”. Pg. 91 – 4th paragraph, 2nd sentence, correct spelling of “form” to “from”. 

Pg. 91 – 3rd bullet, “Graduated Driver’s License Regulations” section b – add “with” after 

“associated”.

The text on page 4 of the transit appendix has been revised to read “In Riverside County, 

fixed route bus service is primarily operated by RTA and SunLine Transit. RTA’s service area 

is the western portion of Riverside County and SunLine’s service area is the Coachella 

Valley. RTA’s service area is among the largest transit systems in the nation, and SunLine 

has led the industry by being the first public agency to convert all of its vehicles to CNG. 

RCTC funds the county’s participation in the regional commuter rail service via Metrolink, 

and the cities of Riverside and Corona operate demand response and local circulator 

service. In addition, the cities of Banning and Beaumont also provide service via the Pass 

Transit service brand, and Desert Roadrunner service is provided by the Palo Verde Valley 

Transit Agency covering the City of Blythe and unincorporated eastern Riverside County. 

Rural transit service in southwestern Riverside County is provided by the Reservation 

Transportation Authority, a collaborative of 18 federally recognized tribal groups.” In 

addition, the typographical errors identified have been addressed.

Submitted by Rural Canyons Conservation Fund Submittal 16236 Related Documents Link

16236.01 The 2012 RTP/SCS provided an important stepping stone for the 2016 Plan. In previous 

Plans, natural lands and farmlands were handled under the banner of “land use.” In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn’t be overlooked. We 

believe the opportunity before you isn’t to “plan for” the future of open space in the 

region—as that’s what you’ve been doing since the 2012 Plan. Instead, we believe SCAG 

can now start “implementing” a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. We and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

188
holdID Comment Response 

Submitted by Rural Canyons Conservation Fund Submittal 16236 Related Documents Link

16236.02 We are pleased to see an Appendix devoted directly to natural and farmlands protection in 

the 2016 Plan. We are glad that the Plan contains specific strategies addressing natural land 

and farmlands issues. This is certainly a step in the right direction. The culmination of the 

work from the last RTP/SCS is clearly visible in this Draft Plan. SCAG has demonstrated that 

Metropolitan Planning Organizations can play a vital, thoughtful and science-based role in 

mitigating impacts to our natural environment from transportation, infrastructure and 

other development projects. By incorporating natural and farmlands protection strategies 

into your policy document, we believe the many benefits of this broad-based conservation 

approach will be realized sooner than expected. Thank you for your leadership.

Comment noted.

16236.03 Our organization supports the idea that as new growth occurs it should focus on the 

existing infill areas. This is consistent with the finding in the SCAG surveys where 

respondents preferred to see existing urban areas built upon before greenfields are 

targeted for development, especially those at the Wildland-Urban Interface. When 

developments are built in infill areas, it likely relieves pressure from the fringe. However, 

the Plan fails to outline exactly how (or with what mechanism) these fringe lands (or any 

lands) will actually be protected. Just because the pressure is relieved doesn’t mean the 

land then automatically becomes protected. Numerous organizations, ours included, focus 

their work on preservation of important habitat lands. A lot of time, energy, political will, 

strategy and other efforts combine to create a successful conservation transaction that 

leads to permanently conserved lands. SCAG must identify the mechanism, process or plan 

on how the greenfield lands will be protected.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

Submitted by Saddleback Canyons Conservancy Submittal 16227 Related Documents Link

16227.01 The 2012 RTP/SCS provided an important stepping-stone for the 2016 Plan. In previous 

plans, natural lands and farmlands were handled under the banner of “land use.” In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn't be overlooked. We 

believe the opportunity before you is not to “plan for” the future of open space in the 

region—as that's what you've been doing since the 2012 Plan. Instead, we believe SCAG 

can now start “implementing” a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions, and nonprofits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. We and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

189
holdID Comment Response 

Submitted by Saddleback Canyons Conservancy Submittal 16227 Related Documents Link

16227.02 We are pleased to see an Appendix devoted directly to natural and farmlands protection in 

the 2016 Plan and that the Plan contains specific strategies addressing natural land and 

farmlands issues. This is certainly a step in the right direction. The culmination of the work 

from the last RTP/SCS is clearly visible in this draft Plan. SCAG has demonstrated that 

Metropolitan Planning Organizations can play a vital, thoughtful, and science-based role in 

mitigating impacts to our natural environment from transportation, infrastructure, and 

other development projects. By incorporating natural and farmlands protection strategies 

into your policy document, we believe the many benefits of this broad-based conservation 

approach will be realized sooner than expected. Thank you for your leadership. Our 

organization supports the idea that as new growth occurs it should focus on the existing 

infill areas. This is consistent with the finding in the SCAG surveys where respondents 

preferred to see existing urban areas built upon before greenfields are targeted for 

development, especially those at the wildland-urban interface. When developments are 

built in infill areas, it likely relieves pressure on the fringe lands. However, the Plan does not 

outline exactly how (or with what mechanism) these fringe lands (or any lands) will actually 

be protected. Numerous organizations, including ours, focus their work on preservation of 

important habitat lands. A lot of time, energy, political will, strategy, and other efforts 

combine to create a successful conservation transaction that leads to permanently 

conserved lands. SCAG must identify the mechanism, process, or plan on how the 

greenfield lands will be protected.

Comment noted.

16227.03 SCAG focused many sections of the document on formal conservation plans, in the form of 

Natural Community Conservation Plans and Habitat Conservation Plans (NCCP/HCP), as the 

conservation method most identified by the agency. However, NCCP/HCP programs are 

only one conservation mechanism and they have limitations. For example, they are 

voluntary, property-owner driven, and generally only apply to larger land ownerships. 

Efforts underway by local, regional, state, and federal agencies outside of these formal 

plans should not be discounted and must be included. Furthermore, many conservation 

organizations help facilitate, coordinate, and find funding for land conservation 

transactions. We believe the conservation approach promoted by SCAG should include all 

of the ways land can be protected, including those less regulated methods of conservation 

outside of NCCP/HCP programs.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation. Suggestions for strategies 

beyond HCPs and NCCPs will be encouraged and appreciated. Your group is encouraged to 

participate in the effort.

16227.04 The current federal transportation bill, the FAST Act, supports understanding 

transportation impacts on natural resources. The previous bill, MAP-21, supported 

restoring and maintaining environmental functions (i.e., wildlife corridors) affected by the 

infrastructure projects in the RTP. SCAG has even supported efforts in Los Angeles County 

to create a wildlife corridor over the 101 Freeway. Many efforts are underway across the 

region to connect landscapes to one another. This is very important to the region and its 

biodiversity. Wildlife corridors allow species to migrate and forage and expand genetic 

diversity. These corridors also allow ecosystems to maintain ecological functions, act as 

sources for repopulation after natural disasters such as fire, flood or landslide, and improve 

the resiliency in the face of climate change impacts. The Plan would be stronger if it 

supported the enhancement and/or protection of documented and regionally significant 

wildlife corridors, especially those that are impacted by infrastructure projects.

Comment noted. The RTP/SCS describes (in Chapter 5) next steps for further developing a 

habitat conservation strategy. Included in the steps is the recommendation to provide 

“incentives for jurisdictions to cooperate across county lines to protect and restore natural 

habitat corridors, especially where corridors cross county boundaries.” The Natural/Farm 

Lands Appendix further supports wildlife corridors in its recommended policies, with the 

specific recommendation to “Encourage and facilitate research, programs and policies to 

identify, protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Additionally, continue support for preserving wildlife corridors and 

wildlife crossings to minimize the impact of transportation projects on wildlife species and 

habitat fragmentation.”

190
holdID Comment Response 

Submitted by Safe Routes to School National Partnership Submittal 16321 Related Documents Link

16321.01 Outside of LA County the RTP/SCS is still primarily about funding highways. While transit 

investments in capital, operations and maintenance make up significantly more than 50% 

of the regional plan, most of these investments are happening in LA County and not in the 

other five counties that could really benefit from greater investments in transit service.

The 2016 RTP/SCS includes substantial transit investments outside of Los Angeles County. 

These include twelve major capital investments, three operations and maintenance (O&M) 

line items over $500 Million, and thirteen productive bus corridor service enhancements, 

as displayed in Tables 5.1 and 5.2 of Chapter 5: The Road To Greater Mobility & 

Sustainable Growth, and in exhibit 18 of the Transit Appendix. The plan also includes two 

transit centers in Imperial County, and a multimodal transportation center and the 

implementation of new interagency transit partnerships in Ventura County.

16321.02 Active transportation, while up from last time, still makes up less than 2% of the RTP/SCS 

funding amount, yet almost 20% of trips in the region are by walking and bicycling. Given 

that SCAG is home to 68% of the State of California’s Disadvantaged Communities and that 

by 2040, nearly one in five people in the region will be seniors, we need to ensure that 

these communities are mobile and can participate in everyday life through more 

transportation choices. The region needs a more balanced, multimodal plan to provide 

everyone in the region with more transportation options, as well as to meet the SB 375 

greenhouse gas emission reduction goals and to realize the many co-benefits that the 

RTP/SCS identifies. Moreover, approximately 78% of trips in the region are less than three 

miles but are taken by car. More funding for active transportation can shift many of these 

trips to more sustainable modes, help reduce greenhouse gas emissions and promote 

public health.

Comment noted. The 2016 RTP/SCS is a fiscally constrained multi-modal transportation 

plan. Because of the fiscal constraints, no one mode is funded to meet all of its needs. The 

Plan Implementation section of the Active Transportation Appendix includes actions (See 

page 70) that SCAG will take in collaboration with local, state and federal partners to help 

increase funding for active transportation in the SCAG region.

16321.03 The investment in active transportation is low compared to the need. In LA County alone, 

Metro has estimated unmet needs of between $11 and 29.5 billion according to the soonto-be-released Active Transportation Strategic Plan, and our own estimates for LA County 

calculate approximately $20 billion in unmet needs (Best Practices for Funding Active 

Transportation with County Transportation Sales Taxes). Thus we feel that $12.9 billion for 

the whole region is too low compared to the need for walking and bicycling infrastructure 

in the entire six-county region.

Comment noted. The 2016 RTP/SCS is a fiscally constrained multi-modal transportation 

plan. Because of the fiscal constraints, no one mode is funded to meet all of its needs. The 

Plan Implementation section of the Active Transportation Appendix includes actions (See 

page 70) that SCAG will take in collaboration with local, state and federal partners to help 

increase funding for active transportation in the SCAG region.

16321.04 The active transportation strategies’ goal that half of all jurisdictions in the SCAG region 

would have a Safe Routes to School plan by 2040 is too low. Given that approximately 37% 

of communities have a plan now or are in the processing of creating one, and that the 

Policy B scenario calls for 75% of communities having such a plan by 2040, there seems to 

be a greater opportunity to increase this number over the next twenty-five years.

Comment noted. The 2016 RTP/SCS is a fiscally constrained multi-modal transportation 

plan. A 50% goal for Safe Routes to School is reasonable and achievable within the 

available budget.

16321.05 SCAG does not adequately link RTP/SCS transit and active transportation funding to its 

environmental justice obligations. The lack of transit and active transportation funding 

disproportionately affects immigrant, lower-income and communities of color because 

these neighborhoods have greater barriers to physical activity and transit access, higher 

numbers of busy regional arterials, poor pedestrian and bicycle infrastructure, safety 

concerns, 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)

SCAG has fulfilled its environmental justice obligations by showing that the Plan does not 

result in any unaddressed adverse disproportionately negative impacts to low income and 

minority communities. Improvements in transit and bicycle mileage are broken down by 

area of concern and compared to the region as a whole in the Geographic Distribution of 

Transportation Investments section of the Environmental Justice Appendix. As can be seen 

from Table 31 and Table 32, investments are targeted in areas that have a high 

concentration of low income and minority population.

191
holdID Comment Response 

Submitted by Safe Routes to School National Partnership Submittal 16321 Related Documents Link

16321.06 Accessibility and proximity to many destinations such as schools, jobs and parks does not 

improve for many disadvantaged communities in the region, according to the EJ analysis. 

The RTP/SCS touts the many benefits of tying land use and transportation investments 

together, but the EJ analysis reveals that even with these investments, the region will fall 

short in improving accessibility and proximity to many destinations. This includes jobs and 

schools, two fundamental places that people need safe, convenient access to in order to 

economically succeed in the region.

Accessibility to jobs, schools, and parks improves for all Environmental Justice groups and 

areas of concern as a result of the Plan when considering the impact of transportation 

improvements on travel time and distance. There are some communities that lack high 

quality transit areas, however, that may see a reduction of destinations within close 

proximity due to the concentration of growth in areas well served by transit. This is 

demonstrated in the Environmental Justice and discussed on page 109.

16321.07 There is no sense of scale in the EJ Appendix. Most of the metrics are described as 

“improve” or “does not improve,” so it is hard to quantify the adverse impacts that some of 

the transportation investments in the RTP/SCS will create. This is especially critical for 

metrics where no data are given, just a paragraph description of the potential impacts. 

Often, the appendix reports that both disadvantaged communities and other communities 

would “improve.” Without quantification, readers cannot know whether the plan would 

worsen or shrink the gap between the haves and have-nots.

Table 3 provides a quick summary of Environmental Justice impacts for minority and low 

income population at the regional level as well as for all population in a given area of 

concern. It is meant to be a quick guide, wheras more detailed analysisis, including 

quantitative findings, is included in each performance area's section of the Appendix.

16321.08 The environmental justice analysis, while more robust than the 2012 RTP/SCS, identifies 

gentrification and displacement as major impacts of making the transportation investments 

and land use changes identified in the RTP/SCS. Affordable housing is a major issue in 

Southern California and the RTP/SCS overlooks the magnitude of the challenge this region 

faces. Recommending development in High Quality Transit Areas, Livable Corridors, 

Neighborhood Mobility Areas and other compact development patterns without a strategy 

to provide affordable housing in these areas, will result in higher-income people moving 

into these areas, and research shows that higher-income populations living near transit 

typically drive twice as many miles and own more than twice as many vehicles as extremely 

low-income households living within a 1⁄4 mile of transit (California Housing Partnership 

Corporation & TransForm, 2014). We also fear that gentrification and displacement are 

happening in the region at a rate faster than the data can capture. SCAG is uniquely 

positioned to foster coordination across the six-county region and create frameworks for 

collaboration on issues that impact the region as a whole. SCAG must work diligently to 

provide regional analysis and leadership by better tracking trends in displacement and 

illustrating the repercussions of these trends, as well as connecting the dots between 

compliance with the Regional Housing Needs Allocation (RHNA) and its effect on GHG 

reduction.

SCAG is committed to serving as a leader in research and analysis of regional trends, 

including issues relating to environmental justice and displacement. Because many of our 

regional plans and programs are inter-related, SCAG will review programs such as RHNA to 

look for ways for better integration of policies and goals, along with compliance standards.

192
holdID Comment Response 

Submitted by Safe Routes to School National Partnership Submittal 16321 Related Documents Link

16321.09 The RTP/SCS relies on anticipated revenues from sales taxes, which have a record of 

success in the region, but also on mileage-based user fees and other future sources of 

revenue that have no track record and may not come to fruition during this timeframe, or 

that have equity implications for low-income households if they are implemented. While 

the EJ analysis identifies the equity impacts of anticipated revenues, additional analysis is 

needed to truly understand how major shifts to a mileage-based user fee or other cost 

structure for driving would impact low-income and minority communities in the region. 

With two sales taxes under consideration in the region, and gas and excise taxes under 

consideration by the state, additional analysis would make help clear the extent to which EJ 

populations would be adversely affected

Comment noted. We agree that additional work is needed including but not limited to 

potential phasing, governance, accountability and approaches for protecting privacy as 

well as addressing income and geographic (e.g., urban vs. rural) equity impacts before the 

mileage-based user fee (or road charge) would become effective—which why the Plan 

does not assume revenues from this source before 2025. SCAG, in collaboration with local, 

regional, state and federal stakeholders, will continue to actively participate in efforts to 

make transportation funding more sustainable in the long-run. An EJ analysis was 

conducted for the Plan, including a focused analysis of impacts from funding through a 

mileage-based user fee. The findings of that analysis indicate, "there is no 

disproportionate impact. The proposed mileage-based user fee system is deemed more 

equitable to low income groups than both the gasoline tax and sales tax, which are highly 

regressive. Under the current structure, low income households pay more per mile in 

gasoline tax than their higher earning counterparts due to their lower adoption rates of 

new (more fuel efficient) vehicles. With the mileage-based user fee system, all households 

will pay in proportion to their usage of the transportation system."

16321.10 The selection of the preferred scenario simply meets but does not exceed the targets for 

2020 as it did in the 2012 RTP/SCS. It appears from the PEIR Table 4.3-1 on page 4-4 that 

SCAG has selected a hybrid scenario between local input and Policy A, which meets the 8% 

GHG emissions reduction target required by 2020. However, in 2012, SCAG expected to 

exceed the 2020 target by one percentage point and hit 9%. We need greater reductions to 

both stem the impact of climate change and to meet future targets which are likely to be 

higher. If the region is already slipping behind, it foreshadows trouble meeting future 

targets. If the region is already slipping behind, it foreshadows trouble meeting future 

targets as well.

Comment noted.

16321.11 There is no local accountability to implementing the RTP/SCS. We are concerned that there 

are big disparities between the RTP/SCS and the plans adopted by the SCAG region’s cities 

and counties, and we recommend that local governments reconsider their plans for growth 

and bring them into alignment with the regional plan. Otherwise, its many benefits, 

including more housing and transportation choices, public health benefits and reducing 

greenhouse gases, may never come to life. These land use changes must be approved at 

the local level, and many jurisdictions will need to change their zoning codes, general plans 

and development regulations to facilitate more mixed-use and compact development. 

Without these changes, the benefits of an expanded transit system and more opportunities 

for walking and bicycling will be minimal.

Comment noted.

193
holdID Comment Response 

Submitted by Safe Routes to School National Partnership Submittal 16321 Related Documents Link

16321.12 The RTP/SCS’ Goods Movement Appendix underscores the need to complement SCAG’s 

focus on funding the expansion and maintenance of highways with a concomitant 

commitment to clean vehicles. The Goods Movement Appendix breaks down the total 

miles of freight traveled within the Primary Freight Network by County. Los Angeles and 

San Bernardino account for 60 percent of total miles traveled. The PFN is a component of 

the National Freight Network, and was designed to “assist states in strategically directing 

resources towards the improved system performance for the efficient movement of freight 

on the highway portion of the nation’s freight transportation system.” But without a 

parallel and significant effort to deploy clean truck and rail vehicles the expansion of roads 

and highways to support increased demand by the goods movement industry conflicts with 

our ambitious greenhouse gas emission reduction goals. While the Goods Movement 

Environmental Strategy and Action Plan seeks to advance zero-emission technology, it 

needs targets as well as funding to promote the prioritization and incorporation of 

emerging technologies into daily operations.

Comment noted. Funding is critical to achieving the objectives outlined and as such, the 

2016 RTP/SCS includes $3 billion to facilitate RD&D for zero-emission goods movement 

technologies.

16321.13 The RTP/SCS promotes the idea that supporting vibrant, well-planned, urban developments 

means natural lands are protected simultaneously is inaccurate. Mechanisms and funding 

must be in place at the local and regional level to accommodate natural lands preservation. 

Furthermore, many conservation non-profits and regional/state agencies have identified 

important lands to conserve that aren’t covered by the sweeping generalizations made in 

the RTP/SCS about what lands need to be protected. Finally, no real plan exists for actual 

conservation of lands, it is mentioned as a byproduct of the infill approach.

Comment noted.

16321.14 Invest greater amounts in active transportation. We applaud SCAG and local jurisdictions 

for increasing active transportation investments in recent years, but we should go further. 

With approximately one-fifth of trips in the region by foot or bike, we should match that 

with greater investments in active transportation. Even with a doubling of funding 

compared to the last RTP/SCS, the region still need to do more to meet the needs. As 

mentioned above, in LA County alone, the estimated need for active transportation 

investments is close to $20 billion. Moreover, many of the traditional sources of funding for 

active transportation are oversubscribed. The state’s Active Transportation Program 

received over $1 billion in requests for funding in each of the last two cycles, with only 

$120 million per year available. The region needs to identify not only new sources, but also 

shift around existing funding, to invest in pedestrian and bicycle infrastructure that makes 

it safer and more convenient for people to get around using these modes.

Comment noted. The 2016 RTP/SCS is a fiscally constrained multi-modal transportation 

plan. Because of the fiscal constraints, no one mode is funded to meet all of its needs. The 

Plan Implementation section of the Active Transportation Appendix includes (see page 70) 

action steps SCAG will take in collaboration with local, state and federal partners to help 

increase funding for active transportation.

16321.15 It is critical to find a way to expand public transportation in all of the counties in the SCAG 

region and not just LA County -- where according to the Transit Appendix 21% of all 

residents have access to frequent transit service compared to 5% in Orange County and 

only 2.5% in San Bernardino and Riverside counties. Public transit as well as first-last mile 

connections to transit are essential to achieving state goals for reductions in VMT, GHGs 

and petroleum use.

The 2016 RTP/SCS includes substantial transit investments outside of Los Angeles County. 

These include twelve major capital investments, three operations and maintenance (O&M) 

line items over $500 Million, and thirteen productive bus corridor service enhancements, 

as displayed in Tables 5.1 and 5.2 of Chapter 5: The Road To Greater Mobility & 

Sustainable Growth, and in exhibit 18 of the Transit Appendix. The plan also includes two 

transit centers in Imperial County, and a multimodal transportation center and the 

implementation of new interagency transit partnerships in Ventura County.

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16321.16 Include a target goal for complete streets components of highway projects. The Active 

Transportation element of the RTP/SCS identifies complete streets as a strategy to 

incorporate more pedestrian and bicycle improvements into transportation projects, and 

while it identifies about one-third or $4.8 billion of active transportation improvements on 

regionally significant local streets, we feel that this is not enough on its own to guarantee 

that money is spent on walking and bicycling infrastructure. We recommend setting a goal 

for a percentage of projects that will have complete streets components, much like the 

percentage goal for communities having a Safe Routes to School plan.

Comment noted. The Plan Implementation section of the Active Transportation Appendix 

includes six actions for Complete Streets. SCAG is committed to working work with local, 

state and federal partners in implementing the Active Transportation component of the 

2016 RTP/SCS with a focus on Complete Streets.

16321.17 Include a target goal for integrating active transportation into transit projects through a 

first/last mile strategy. Much like the above recommendation, we urge SCAG to set a goal 

for the number of transit projects that include active transportation components. The 

majority of people taking transit do not own cars, and thus are walking and/or biking to the 

station. Providing them a safe, convenient route is critical and should be done as part of 

transit planning projects.

Comment noted. One of the performance goals for the 2016 RTP/SCS is to increase the 

share of regional commuters traveling by transit. We agree that first/last mile connectivity 

improvements are essential to increasing the transit mode share in the SCAG region. In 

addition, these same kinds of connectivity improvements will serve our goal of increasing 

the active transportation mode share. We will continue to work with our state, regional, 

and local partners to evaluate improved methodologies, as they become available, for 

monitoring the implementation of first/last mile transit connectivity improvements.

16321.18 Commit to completing active transportation planning efforts before the 2020 RTP/SCS. 

During the 2012 RTP/SCS cycle, the National Partnership advocated for creating several 

regional active transportation plans: an Active Transportation Finance Strategic Plan, 

Regional Complete Streets Plan and Regional Safe Routes to School Plan. We commend the 

work that has been done since 2012 to increase staff devoted to active transportation and 

strengthen its place in the 2016 RTP/SCS. Yet investments in active transportation still 

comprise a paltry percentage of the RTP/SCS, partly because many communities do not 

have active transportation plans that would make them eligible for ATP funding. SCAG 

could play a key role in creating a regional plan and providing a guidebook for local 

jurisdictions to create their own plans at a low cost. A good example is the Orange County 

Council of Governments’ (OCCOG) Complete Streets Guidebook, which will identify 

complete streets templates, sample language and typologies for each jurisdiction in the 

county to incorporate a complete streets policy into their general plan. SCAG could do 

something similar at a regional level for complete streets, Safe Routes to School and active 

transportation in general. We recommend having these plans in place before Cycle 4 of the 

ATP, which is expected in early 2018.

Comment noted. Beginning on page 69 of the Active Transportation Appendix, the Plan 

Implementation section delineates steps SCAG will take, in collaboration with local, state 

and federal partners, to implement key strategies in the 2016 RTP/SCS Active 

Transportation Appendix.

16321.19 Bolster the Safe Routes to School Goal to 75%. The RTP/SCS states a goal of 50% of 

communities having a Safe Routes to School plan by 2040. Given that 37% of communities 

currently have one or are planning to create one, we recommend going with the Policy B 

recommendation of 75% by 2040. This can be more easily achieved by completing the 

Regional Safe Routes to School Plan identified above.

The 2016 RTP/SCS is a fiscally constrained multi-modal transportation plan. Because of the 

fiscal constraints, the 50% goal is a realistic achievable goal within the constraints of the 

plan.

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16321.20 Identify policies, strategies and investments to increase access to transit and active 

transportation in less urban areas. SCAG should identify strategies, best practices and 

policy guidance that support increased opportunities for active transportation, access to 

transit (such as first mile / last mile strategies expanded service, vanpools and ridesourcing) 

that improve resident connectivity to education, employment, healthcare and other basic 

goods and services throughout this diverse region. We appreciate SCAG’s commitment to 

increasing access to transit and active transportation but don’t see policies in the SCS that 

will benefit much of the region, such as the more rural and suburban areas of Imperial, San 

Bernardino and Riverside.

SCAG's existing goals/policies related to active transportation are delineated on pages 24 

and 25 of the Active Transportation Appendix, as well as how SCAG is carrying 

out/implementing these policies. Included in this is SCAG developing sustainability joint 

work programs with each of the six counties that include active transportation throughout 

the region (urban, suburban, rural).

Submitted by Safe Routes to School National Partnership Submittal 16322 Related Documents Link

16322.01 Disaggregate transportation mode choice at smaller geographies. Mode choice varies 

considerably by neighborhood and depends on multiple factors. SCAG should explore doing 

a deeper analysis of transportation mode choice, which would help identify gaps in the 

regional system and prioritize projects, plans and investments by addressing limited usage 

of modes of transportation such as transit and active travel.

Comment noted. The 2016-2040 RTP/SCS did analyze mode usage by geographic areas, 

and addressed and place appropriate transit and active transportation investments where 

projects and land use yields the most benefits to the region.

16322.02 Commit to creating a Regional Gentrification and Displacement Strategy. While SCAG does 

not have local land use control to regulate the location of affordable housing, it can 

conduct a regional study of gentrification and displacement pressures that face particular 

parts of the region, including areas that are most vulnerable, as well as where people go 

when they are displaced. Much like the planned Regional Complete Streets and Safe Routes 

to School Plans, SCAG has an important role to play in creating a regional vision and 

strategy to address displacement proactively, and provide local communities the tools they 

need to combat the impacts of it. We also encourage SCAG to convene a task force 

specifically dedicated to this issue.

SCAG will consider emerging and persistent regional issues, including suggestions from the 

comment process, and may propose new task forces/sub-committees as needed. SCAG is 

also exploring ways to address social equity issues, including gentrification and 

displacement, beyond the RTP/SCS process, and will continue to work with stakeholders to 

discuss challenges and potential strategies for the SCAG region.

16322.03 Create a standing Environmental Justice/Disadvantaged Communities Working Group. 

Given some of the unavoidable impacts of the plan on Environmental Justice Communities, 

we encourage SCAG to establish an ongoing process for elucidating and addressing these 

challenges in the region. A standing Environmental Justice/Disadvantaged Community 

workgroup could provide guidance for the integration of environmental 

justice/disadvantaged community prioritization processes in county and city-level 

transportation planning, ensuring that the project lists included in future RTP/SCSs have 

been developed with an eye toward more equitable transportation investment. Greater 

investment in environmental justice/disadvantaged communities’ readiness will have the 

added benefit of increasing the competitiveness of the SCAG region in state funding 

competitions subject to SB 535 requirements.

SCAG will consider emerging and persistent regional issues, including suggestions from the 

comment process, and may propose new committees as needed. SCAG is also exploring 

ways to address social equity issues, including gentrification and displacement, beyond the 

RTP/SCS process, and will continue to work with stakeholders to discuss challenges and 

potential strategies for the SCAG region.

16322.04 Target Sustainability Planning Grants to Disadvantaged Communities. Many small urban 

and rural communities lack comprehensive multi-modal transportation plans. Without 

plans in place, systematic improvements to active transportation infrastructure, improved 

first mile/last mile access and improved transit will be incomplete and ineffective. We 

recommend SCAG target Sustainability Planning Grants to disadvantaged communities, and 

especially rural, disadvantaged communities that lack plans, models and programs 

designed to secure and promote sustainable development.

Comment Noted. The past two Sustainability Grant Program calls for projects (2010 and 

2013) have included "need for assistance" as one scoring criterion. Additionally, SCAG 

intentionally keeps the application process simple and streamlined to encourage 

jurisdictions with constrained capabilities to apply. Finally, the program is designed to 

provide direct technical assistance. This allows the jurisdictions to focus their sometimes 

limited resources on managing the work, and not administering the grant.

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16322.05 Include target industry goals and include non-industry stakeholders into the Goods 

Movement Environmental Strategy and Action Plan. The Goods Movement Environmental 

Strategy and Action Plan is comprised of four phases as a means to incorporate 

technological solutions. However, phases of the action plan do not include goals of how the 

plan can assist industries nor does the plan incorporate non-industry stakeholders into the 

process. Phase two of the plan includes the creation of a Logistics Working Group with 

many geographic representations. We recommend that the Working Group be expanded to 

include public health advocates from all regions, so this process has a larger perspective to 

address public health concerns. Although energy security, energy cost security, climate 

protection and green-sector job development are identified as important roles for the 

convening to address, public health is not. An important role for these partners should also 

be the consideration of health inequities from environmental justice communities as a 

result of emissions. Furthermore, Phase three and four address deployment and 

operational demonstration but it is unclear how industries will participate in development 

and deployment efforts since there are no industry goals attached to the plan.

The SCAG Goods Movement Environmental Strategy and Action Plan offers a framework 

for the eventual deployment of clean technologies going forward. The Plan may be 

updated as appropriate.

16322.06 Track implementation of the RTP/SCS between update cycles. ClimatePlan has a new report 

that monitors the implementation of the 2012 RTP/SCS, and the region is falling short. 

SCAG should continually monitor how the region’s land use and transportation investments 

are complying with the RTP/SCS. We need tools to better understand where investments 

from cap-and-trade, ATP and disadvantaged communities are going. We especially urge 

SCAG to track the efforts of CTCs to update their long-range transportation plans to align 

with the RTP/SCS, as ultimately it is at the local and county level that transportation 

projects are approved and then sent up to SCAG for inclusion in the RTP/SCS. Only by 

continually monitoring local efforts will SCAG be able to identify where our region is 

succeeding and even exceeding the SB 375 goals, and where it is falling short in meeting 

the SB 375 goals and where it needs to make changes to land use and transportation 

investments. We recognize SCAG is already doing this with the new REVISION tool, and 

hopefully that will help address some of these implementation challenges.

Comments noted. SCAG recognizes the critical need to continually monitor 

implementation of the 2016 RTP/SCS at the local level throughout our region. The 

Performance Measures chapter and appendix of the 2016 RTP/SCS feature two separate 

sets of performance indicators. The first evaluates the performance of the Plan relative to 

how the region would fare under various alternative planning scenarios, including the 

continuation of current trends without intervention (no Plan). The second set includes a 

list of performance indicators to be used for on-going regional monitoring. These 

measures will be used to support our continuous monitoring of implementation of the 

regional Sustainable Communities Strategy (SCS) throughout the Plan period. We agree 

with your assessment that continuous regional performance monitoring is crucial to 

ensuring the success of the Plan and for achieving our greenhouse gas reduction targets. 

We also agree that close coordination and on-going communication with each of our 

County Transportation Commissions is an important element of the performance 

monitoring effort. The web-based 'REVISION' application, which will be released later this 

year, will provide a significant new tool for planners and decision-makers at all levels of 

government in our region to both track progress toward achieving local and regional 

sustainability objectives, and inform the planning decision-making process itself.

Submitted by Safe Routes to School National Partnership Submittal 16356 Related Documents

16356.01 According to some estimates L.A. -- the City of L.A. or its L.A. Metro has the second highest 

bus ridership in the country so there is not an insignificant amount of people that are taking 

transit and many of these people are disadvantaged communities which as a previous 

speaker mentioned we have about two-thirds of the states, so making investments in 

transit is a good idea for the region.

Comment noted.

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16356.02 We do, you know, have some concerns that the funding is primarily still about roads and 

highways and we recognize that most of the region still drives. But we do think with a 

significant amount of people that walk, bike and take transit that we could do even more to 

link our investments within ways that people actually get around and, especially, make it 

safer for people to get to their schools, their jobs and parks around the region.

Comment Noted.

Submitted by Safe Routes to School National Partnership Submittal 16359 Related Documents

16359.01 Today, I would like to highlight two specific recommendations that I think could strengthen 

the RTPSCS: First, in bolster the safe routes to school goal to 75 percent. The RTPSCS states 

a goal of 50 percent of communities having a safe route to school plan by 2040. Given that 

30 percent of communities currently have one or plan to create one we recommend going 

with Policy B recommendation of 75 percent by 2040. And this could be easily achieved by 

completing the Regional Safe Back to School Plan.

Comment noted. The 2016 RTP/SCS is a fiscally constrained multi-modal plan. The 50% 

goal for Safe Routes to School represents a realistic goal of what can be achieved with the 

limited budget available.

16359.02 Second, we recommend creating an environmental justice disadvantaged communities 

working group. As a standing environmental justice and disadvantaged community work 

group we could provide guidance for integration in EJ and disadvantaged community per 

our presentation process and County and City level Transportation Planning. We can also 

ensure that the project list included in the future RTPSCS's have been developed with an 

eye towards equitable transportation investment. Greater investment in EJ and 

disadvantage community readiness will have the added benefit of increasing the 

competitiveness of the SCAG region in other statewide funding competitions that are 

subject to SB535 requirements. Furthermore, as a Riverside native I'm particularly 

concerned about Riverside and San Bernardino disadvantaged communities and the impact 

of carbon emissions from the goods movement.

SCAG will consider emerging and persistent regional issues, including suggestions from the 

comment process, and may propose new task forces/sub-committees as needed. SCAG is 

also exploring ways to address social equity issues, including gentrification and 

displacement, beyond the RTP/SCS process, and will continue to work with stakeholders to 

discuss challenges and potential strategies for the SCAG region.

16359.03 Furthermore, as a Riverside native I'm particularly concerned about Riverside and San 

Bernardino disadvantaged communities and the impact of carbon emissions from the 

goods movement.

Please refer to the Environmental Justice Appendix (page 177), which looks at the 

breakdown of population by income group and race for residents who live in close 

proximity to rail roads and planned grade separations in the SCAG Region.

16359.04 The RTPSCS is still primarily about funding highways and we want to look toward 

transportation. While doubled this last year, it still makes up less than two percent of 

RTPSCS's funding amount, yet, 20 percent of trips in the region are by walking and biking 

and 78 percent of trips are under three miles driven. Overall, the draft of the RTPSCS 

envisions a region where people have more transportation choices they can walk, bike, 

take transit and, of course, drive. It has been said by SCAG's executive director that people 

aren't going to stop driving but they will drive differently. By investing in active 

transportation and transit as well as bringing in new shared use systems and technologies 

we give everyone in this region a variety of options to get around safely, efficiently and 

sustainably.

Comment noted. More than 50% of total funding in the 2016 RTP/SCS is dedicated to 

transit and active transportation.

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16181.01 SANBAG recently completed its Countywide Transportation Plan (CTP) and provided it to 

SCAG as background and input to the RTP/SCS. The CTP analyzed two future scenarios: a 

“baseline scenario” that assumed traditional revenue sources (generally consistent with 

what the RTP/SCS defines as “core revenues”) and an “aggressive scenario” (generally 

consistent with RTP/SCS “Plan” revenues, including the innovative sources identified in the 

Plan). The projects and programs in the aggressive scenario of SANBAG’s CTP are consistent 

with the lists in SCAG’s 2016 RTP/SCS. In addition, the jurisdiction-level growth forecasts for 

the CTP are consistent with the jurisdiction-level growth forecasts for the RTP/SCS. SANBAG 

has provided SCAG with technical corrections to the San Bernardino County portion of the 

RTP/SCS project list in a separate communication so that the changes can be incorporated 

into the modeling for the final RTP/SCS. It should be noted that agreement was reached in 

2015 for the Los Angeles World Airports to transfer control of Ontario International Airport 

(ONT) to the Ontario International Airport Authority (OIAA). SANBAG and our partner 

agencies appreciate the regional support that has been provided by SCAG and other 

agencies around the region. We look forward to continuing local and regional efforts to 

make ONT a truly regional asset.

Comment noted.

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16181.02 Although the SCAG innovative revenue sources are projections of “reasonably available” 

revenue under the federal definition, much is unknown about how these will play out in the 

long run. In terms of project implementation, SANBAG bases its programs and budgets on 

the core revenues, but will be working with SCAG, the State, and federal agencies on 

options to 1) derive the most benefit from the funds that have been entrusted to us by the 

public, 2) seek additional State and federal funding for projects that are of statewide and 

national significance (e.g. expansion of highway facilities that serve international goods 

movement), and 3) work with policy makers to determine if and when additional funding is 

needed and ways to provide that funding so as to minimize taxpayer burdens and fairly 

distribute project funding. Transportation infrastructure is fundamental to our 

competitiveness as a county and as a region. Infrastructure represents an asset that needs 

to be protected and invested in to sustain our economy, a significant portion of which is 

logistics-based. At the same time, it must be acknowledged that support for the overall 

RTP/SCS financial plan does not imply support for any individual piece of legislation related 

to the funding of transportation projects. Fixing America’s Surface Transportation Act (FAST 

Act) recently passed by Congress is an opportunity to continue to upgrade our 

transportation infrastructure, as it provides a stable source of federal revenue and includes 

a revenue stream for freight projects that are critical to San Bernardino County’s economy. 

We believe that the regional freight collaboration that has worked so well for our regional 

project funding through the State’s Trade Corridor Improvement Fund (TCIF) program 

should be re-invigorated to craft a program of projects that can be most competitive for 

these new federal freight program funds. As highlighted in the RTP/SCS, a future funding 

mechanism based on vehicle miles of travel (VMT) is viewed to be one of the most 

significant innovative funding sources for the future. SANBAG has provided comments to 

the California Transportation Commission related to the SB 1077 “Road Charge” pilot 

program. One of our comments was that, depending on the results of the pilot, the State 

should consider phasing in this program, beginning with alternative fuel vehicles. We 

recognize that the State has accelerated the schedule for the Road Charge pilot, but it 

should not be at the expense of taking shortcuts or skipping steps that are important to 

designing an ultimate program that has a high probability of success. This is potentially a 

very complex program, and it is more important to do it right than to do it fast. SCAG can 

play an important role in suggesting ways to make this transition successful and acceptable 

to the public if, in fact, the pilot program concludes that replacement of the gas tax with a 

road charge is a viable path forward.

Comment noted. We agree that additional work is needed including but not limited to 

potential phasing, governance, accountability and approaches for protecting privacy as 

well as addressing income and geographic (e.g., urban vs. rural) equity impacts before the 

mileage-based user fee (or road charge) would become effective—which is why the Plan 

does not assume revenues from this source before 2025. SCAG, in collaboration with local, 

regional, state and federal stakeholders, will continue to actively participate in efforts to 

make transportation funding more sustainable in the long-run.

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16181.03 As highlighted in Attachment 1, SANBAG and our partner agencies are investing heavily in 

passenger rail and premium bus services. Capital investments for premium transit, 

including rail and bus rapid transit (BRT) projects in the San Bernardino Valley will exceed 

$600 million in the decade beginning in 2012. This will enable the planning and 

implementation of more transit- oriented development in the Valley subarea of the County. 

This is a bold step for San Bernardino County, and we look forward to partnering with SCAG 

to encourage the State to invest in the suburban portions of the transit system, not just the 

more urban portions. San Bernardino County jurisdictions are supportive of TOD, but need 

additional flexibility from the State if we are to be able to compete for funding under the 

Affordable Housing/Sustainable Communities (AHSC) program and related cap-and-trade 

programs. SANBAG and the County of San Bernardino have been involved in commenting 

on the AHSC grant guidelines which, unfortunately, are not friendly to TOD in suburban 

areas such as the Inland Empire, even though densities are increasing. Transit headways 

and density requirements for the TOD portion of the AHSC program are still too stringent 

for the Inland Empire market, even around passenger rail stations. That said, several of our 

local jurisdictions have built and are pursuing TOD projects around Valley transit stations at 

densities the market can support. Our jurisdictions also need enabling tools to lay further 

groundwork for TOD, in light of the dissolution of redevelopment agencies (RDAs) several 

years ago. In summary, we are highly supportive of transit/TOD development, but need 

additional help if our local jurisdictions are to be successful.

Comment noted. SCAG will continue to work with the local jurisdictions that show interest 

in implementing the RTP/SCS land use policies, including TOD, by providing information 

and resources to support local planning activities, such as the Sustainability Program and 

the Active Transportation Program. As the AHSC program and related cap-and-trade 

programs continue to grow, SCAG will continue to offer assistance and advocate for the 

local jurisdictions in the SCAG region to ensure all jurisdictions can compete for funding.

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16181.04 The 2016 RTP/SCS demonstrates that the SB 375 GHG reduction targets for the region are 

met for 2020 and 2035. SANBAG has been aggressively working on greenhouse gas 

reduction strategies and implementation within San Bernardino County through our 

Regional Greenhouse Gas Reduction Plan (now being implemented through individual city 

climate action plans), the Home Energy Renovation Opportunity (HERO) program, truck 

retrofit programs, and other energy/GHG-related initiatives. As highlighted in Attachment 

1, we are being very proactive on sustainability and GHG reduction initiatives. At the same 

time, it is important to recognize that we need a robust highway network to remain 

competitive from a logistics standpoint. A strong economy is required for both the private 

and public sectors to afford the technology needed to meet air quality standards and 

achieve the requisite GHG reductions. It should also be understood that a thriving economy 

in a growing county like San Bernardino can result in an increase in vehicle miles of travel 

(VMT). While we understand that reductions in VMT can be helpful to GHG reduction, it 

should be noted that VMT has steadily increased in southern California at the same time 

that air quality has been dramatically improved over the last several decades. The same 

thing could be true with our GHG reduction strategy if we do it right. We can achieve both 

GHG reduction and mobility/economic development goals, even if VMT should increase in 

some of the faster growing areas of the State like San Bernardino County. The GHG analysis 

in the draft 2040 California Transportation Plan demonstrated that vehicle and fuels 

technology will be the primary way in which GHG reduction goals will need to be met. VMT 

reduction is an appropriate goal, but technology will be the principal path to long term GHG 

reduction. See SANBAG’s comments on the draft 2040 California Transportation Plan, 

previously provided to SCAG. We make this point because individual transportation 

projects may increase VMT, but these projects are very necessary from a mobility 

standpoint. In terms of GHG reduction, it is the net result at the regional and statewide 

level that is most important, not the effect of an individual project. In other words, because 

SB 375 GHG reduction is evaluated at the regional level, individual transportation projects 

should not be held to a GHG reduction or VMT reduction standard. We request that SCAG 

keep that in mind in ongoing discussions with the air districts, the California Air Resources 

Board, and other state agencies. SANBAG strongly supports initiatives to advance vehicle 

and fuels technology and to see that technology penetrating into the fleets of light duty 

and heavy duty vehicles. This is the path to success in GHG reduction for mobile sources.

Comment noted. SB 375 GHG reduction is evaluated at the regional level, and individual 

transportation projects are not be held to a GHG reduction or VMT reduction standard. 

SCAG applauds SANBAG's efforts/initiatives to address GHG and criteria pollutant 

emissions and appreciates our close collaboration. SCAG is also committed to supporting 

advanced vehicle and fuel technology, and technology-based mobility solution. SCAG looks 

forward to continue working with SANBAG and other transportation and air quality 

partners to attain the health-based federal and state air quality standards, to meet the SB 

375 GHG reduction targets, and other regional goals of the 2016 RTP/SCS.

16181.05 Page 22 - It would be useful to provide the definition that SCAG uses to distinguish single 

family vs. multi-family

Clarification has been provided with the revised figure 2.1 to define single family and multifamily.

16181.06 Page 23, Exhibit 2.1 - Putting county boundaries on the map would be helpful for 

geographic perspective

Comment noted. County lines have been added to the map.

16181.07 Page 40 - Legend - The blue dot may be better labeled “Transit Centers” Comment noted. Within the map legend, transit centers are classified under "transit 

capital improvements."

16181.08.1 Page 41 - For I-10 widening, add the word “westbound” to the description; Comment noted. Edits have been made to incorporate this comment.

16181.08.2 for Downtown San Bernardino Transit Center, add “and Metrolink extension” since the text 

mentions the extension.

Comment noted. The text will be added.

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16181.08.3 Also, under Omnitrans E Street sbX state: “A 16-mile bus rapid transit project ...” The text has been changed to read: "Omnitrans E Street sbX: A 16-mile bus rapid transit 

project including 6-miles of dedicated bus lanes on E Street, providing service between 

California State University San Bernardino and the City of Loma Linda."

16181.09 Page 43, grant no. 50 - add “and Safe Routes to School Study” to the description. Comment noted. Project title has been revised.

16181.10 Page 48 - it would be helpful to add definitions of “distressed,” “failed condition,” 

“functionally obsolete,” and “structurally deficient” in the text or on the graphic.

Comment noted. Distressed lane miles reflect multiple types of pavement distress (i.e. 

minor distress, major distress, and poor ride). Similarly, structurally deficient bridges can 

reflect a number of conditions related to bridge decks, superstructure, substructure or 

culvert deficiencies or waterway adequacy. Therefore, single definitions for these terms 

are not commonly used.

16181.11 7. Page 50 - Preserving our Transportation System - SANBAG agrees with stressing the 

importance of system preservation. The statement on Page 50 says: “Moving forward, the 

region needs to continue to make “fixing it first ” a top priority - that is, focusing its funds 

on preserving the existing transportation network prior to investing in system expansions. 

Failing to adequately invest in the preservation of Southern California’s roads, highways, 

bridges, railways, bicycle and pedestrian facilities and transit infrastructure will only lead to 

further deterioration, which has the potential to worsen our congestion challenges.” Page 

79 further references the consideration of life-cycle costs beyond construction. However, it 

should be noted that “prior to investing in system expansions” does not mean that capital 

projects can be put on hold while maintenance funding catches up to a defined state of 

good repair. Both need to proceed in parallel. A possible re-phrasing could be: “focusing 

the necessary funds on preserving the existing transportation network while strategic 

investments are made in system expansions’’

Comment noted. Appropriate edits have been made to incorporate this comment.

16181.12 In addition, identification of a regional need for system preservation funding does not imply 

that a regional or sub-regional entity will be responsible for raising the funds needed for 

system preservation. Responsibility for system preservation funding will still need to rest 

with the facility owner except in cases where maintenance/operations costs are explicitly 

identified in agreements between the owner and a third party (e.g. an operator of express 

toll lanes). Caltrans needs to remain responsible for the funding of maintenance and 

operation of state highways, and local jurisdictions need to remain responsible for local 

roads. It is suggested that this clarification be added to the text.

Comment noted. Appropriate edits have been made to incorporate this comment.

16181.13 Page 50 - Logistics Epicenter - The last paragraph on the page states that 750 million of the 

1.2 billion square feet of industrial space is occupied. This seems like a low percentage of 

occupied square feet. Please clarify.

Comment noted. 750 million square feet of occupied space was limited to facilities larger 

than 50,000 square feet, whereas 1.2 billion total facility space is in reference to all 

facilities combined. To make it consistent, we have updated that section to clarify that 

nearly 1.1 billion square feet out of 1.2 billion was occupied.

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Submitted by San Bernardino Associated Governments Submittal 16181 Related Documents Link

16181.14 9. Page 95 - The first paragraph under Highways and Arterials states: “Active transportation 

has grown in recent years, but the majority of trips in our region today is still made on our 

region’s highways and arterials. Yet, the expansion of our highways and arterials has 

slowed down over the last decade. Revenue from traditional sources to fund transportation 

improvements is declining and costly expansions to address congestion are no longer 

financially feasible. However, given that critical gaps and congestion chokepoints still exist 

within the network, improvements beyond TSM and TDM strategies need to be considered. 

Closing these gaps to complete the system will allow residents and visitors alike to enjoy 

improved access to opportunities such as jobs, education, recreation and healthcare.” 

Please change “are no longer financially feasible” to “may not always be financially 

feasible” or similar language. Many transportation improvements are costly, but they are 

also important to regional mobility and the economy and are also financially feasible.

Comment noted. Appropriate edits have been incorporated in the Final 2016 RTP/SCS.

16181.15 10. Page 95 near the bottom of the page states: - “The 2016 RTP/SCS highways and local 

arterials framework and guiding principles are summarized here: a. Focus on achieving 

maximum productivity through strategic investments in system management and demand 

management. b. Focus on adding capacity primarily (but not exclusively) to: i. Close gaps in 

the system; and ii. Improve access where needed. c. Support policies and system 

improvements that will encourage the seamless operation of our roadway network from a 

user perspective. d. Any new roadway capacity project must be developed with 

consideration and incorporation of congestion management strategies, including demand 

management measures, operational improvements, transit and ITS, where feasible. Focus 

on addressing non-recurring congestion with new technology. e. Support complete streets 

opportunities where feasible and practical.” SANBAG concurs with this language. While we 

are aggressively pursuing sustainability initiatives, as described earlier, highway capacity 

improvements are also needed particularly to support the mobility improvements required 

to sustain economic growth. This is particularly important for the movement of freight, as 

the logistics sector supports about one third of San Bernardino County’s economy.

Comment noted.

Submitted by San Gabriel Valley Council of Governments Submittal 16232 Related Documents Link

16232.01 (1) The Plan intentionally does not pre-suppose the adoption of proposed 1/2 cent 

transportation sales tax measure being considered for the Los Angeles County ballot in 

November 2016. If such a sales tax measure is put to the voters and adopted, the funding 

and implementation outlook for transportation projects in Los Angeles County and our subregion will significantly improve. We anticipate working with SCAG staff on a subsequent 

Plan Amendment that will reopen project lists and incorporate and/or revise the schedules 

for the priority transportation projects and programs in the San Gabriel Valley identified in 

the ballot measure expenditure plan and other projects identified in the Subregional 

Mobility Matrix for the San Gabriel Valley prepared in 2015 for Los Angeles County Metro.

Comment noted. The Plan does not assume funding from a potential additional sales tax 

measure or an extension of Measure R within Los Angeles County. If such an additional 

sales tax measure is approved by Los Angeles County voters, it can be incorporated into 

the Plan through subsequent amendments.

16232.02 (2) A transit accomplishment important to the San Gabriel Valley is the latest extension of 

the Foothill Gold Line Phase 2A to Azusa which completed construction in late 2015 and is 

being prepared for passenger traffic this spring. This significant accomplishment warrants 

inclusion in the sections of the Plan discussing transit projects progress on page 4 and page 

38.

The Metro Foothill Gold Line Extension Phase 2a (RTP ID LA29212XY-LA0G558) was not in 

revenue service at the time of the Draft RTP/SCS release. It has been included in the Final 

RTP/SCS on the map of completed projects on page 38.

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Submitted by San Gabriel Valley Council of Governments Submittal 16232 Related Documents Link

16232.03 (3) The ''Fixing America's Surface Transportation Act'' or FAST Act signed into law in 

December 2015 authorizes federal transportation project and program funding for the next 

five fiscal years, including two new freight programs that will provide significant funding. 

Discussion of the FAST Act should be included in the federal transportation initiatives 

section on page 60.

Comment noted. Appropriate edit has been incorporated in the Final 2016 RTP/SCS.

16232.04 (4) The current and projected 2040 train volumes identified for regional rail segments on 

page 53 shows a decline in future passenger train volumes and insignificant growth in 

future freight train volumes on the Union Pacific Railroad (UPRR) Los Angeles & Alhambra 

Subdivisions in the San Gabriel Valley. The modest growth in freight trains is contrary to our 

understanding and UPRR’s plans to double-track the Alhambra Subdivision, which is noted 

elsewhere in the Plan, and to expand the capacity of the LA Subdivision. Regarding future 

passenger train volumes, we have not been informed of any planned future reductions of 

Metrolink or Amtrak service on these subdivisions. We request that the basis for these 

projections be re-examined in light of this information and adjusted accordingly.

Comment noted. The graphic on page 53 has been updated to correct misrepresentations 

of the train volumes for both passenger and freight.

16232.05 (5) SGVCOG continues to have concerns about the designation by SCAG of State Route 60 

as part of a proposed network of truck-only lanes due to the potential for obstructing the 

alignment of the proposed SR 60 light rail extension and potential displacement of future 

long-haul truck traffic by shorter haul on this regional corridor. We are concerned that the 

demand for such a facility has not been conclusively defined. Trucking demands are rapidly 

changing as product delivery to the end user is being redefined by technology and 

consumer demands. For example “Uber” type services are becoming more common to 

deliver goods from local manufacturers and the ports to local and regional distribution 

centers. This may result in a decline of the traditional long haul truck trips along the SR 60 

and will make a truck-only facility less viable along this corridor. We request that SCAG 

work closely with the SGVCOG and the staffs of communities adjacent to the proposed EastWest Corridor to create a truck mobility plan for the SR 60 corridor which takes into 

account the proposed alignment of the SR 60 light rail project and that will address the 

changing needs of the trucking industry.

Comment noted. SCAG acknowledges the need for continuing analyses and dialogue with 

stakeholders. Please note that the inclusion of the East-West Freight Corridor in the 2016 

RTP/SCS allows for further analyses to be conducted. Specific costs, refined user demand, 

accessibility concerns, designs, and alternative alignments would be identified through a 

project level Environmental Impact Report (EIR) . Further discussion of project mitigation 

concerns would also be addressed through upcoming processes.

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Submitted by Sea and Sage Audubon Society Submittal 16225 Related Documents Link

16225.01 The 2012 RTP/SCS provided an important stepping stone for the 2016 Plan. In previous 

Plans, natural lands and farmlands were handled under the banner of “land use.” In this 

new Plan, however, they are their own category. This is a great milestone in conservation 

planning for the region and SCAG. Additionally, the creation of a Natural and Farmlands 

Appendix provides important opportunities for SCAG that shouldn’t be overlooked. We 

believe the opportunity before you isn’t to “plan for” the future of open space in the 

region—as that’s what you’ve been doing since the 2012 Plan. Instead, we believe SCAG 

can now start “implementing” a regional conservation program. We strongly urge SCAG to 

take a more serious leadership role by actively seeking funding to implement conservation 

efforts by partnering with agencies, transportation commissions and non-profits to see that 

the Plan created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant 

Program in Northern California is a program that we believe can be replicated in Southern 

California. We and other coalition members would gladly assist with this implementation 

effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16225.02 We are pleased to see an Appendix devoted directly to natural and farmlands protection in 

the 2016 Plan. We are glad that the Plan contains specific strategies addressing natural land 

and farmlands issues. This is certainly a step in the right direction. The culmination of the 

work from the last RTP/SCS is clearly visible in this Draft Plan. SCAG has demonstrated that 

Metropolitan Planning Organizations can play a vital, thoughtful and science-based role in 

mitigating impacts to our natural environment from transportation, infrastructure and 

other development projects. By incorporating natural and farmlands protection strategies 

into your policy document, we believe the many benefits of this broad-based conservation 

approach will be realized sooner than expected. Thank you for your leadership.

Comment noted.

16225.03 Identify a Conservation Mechanism for the Natural and Farmlands Preservation Our 

organization supports the idea that as new growth occurs it should focus on the existing 

infill areas, where it is appropriate and sustainable. This is consistent with the finding in the 

SCAG surveys where respondents preferred to see existing urban areas built upon before 

greenfields are targeted for development, especially those at the Wildland-Urban Interface. 

When developments are built in infill areas, it has the possibility to relieve pressure from 

the fringe. However, the Plan fails to outline exactly how (or with what mechanism) these 

fringe lands (or any lands) will actually be protected. Just because the pressure is relieved 

doesn’t mean the land then automatically becomes protected. Numerous organizations, 

ours included, focus their work on preservation of important habitat lands. A lot of time, 

energy, political will, strategy and other efforts combine to create a successful conservation 

transaction that leads to permanently conserved lands. SCAG must identify the mechanism, 

process or plan on how the greenfield lands will be protected.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

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Submitted by Sequoyah School Submittal 16268 Related Documents

16268.01 On behalf of Sequoyah School, which is situated within the SR 710 corridor, I commend 

SCAG for its focus on constructive, sustainable, regional transportation improvements, and 

for not explicitly including the State Route 710 Tunnel Alternative (SR-710 Tunnel) in the list 

of constrained projects. However, I urge SCAG to clarify references to the SR-710 North 

project in the Final 2016 RTP/SCS and PEIR, and confirm that the SR-710 Tunnel Alternative 

is not included in the RTP list of constrained projects. Since a Locally Preferred Alternative 

has not yet been identified by Caltrans for the SR-710 North Project, and environmental 

review is incomplete, SCAG should remove all references or inferences that the project will 

be the SR-710 Tunnel Alternative. The Draft 2016 RTP/SCS and DRAFT PEIR should remain 

alternative neutral. Leaving these references in the documents presupposes, and 

promotes, the selection of the freeway tunnel alternative in advance of the conclusion of 

the public process. That process has so far raised serious issues with the quality of the 

environmental analysis. As a steward of the public’s interest in sustainable transportation 

improvements, SCAG should wait to consider whether the selected alternative aligns with 

its own goals and priorities.

Comment Noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description and associated modeling analysis.

Submitted by Sherman Oaks Homeowners Association Submittal 16160 Related Documents Link

16160.01 Sherman Oaks Homeowners Association Comment 1 – The Sepulveda Pass Corridor is the 

greatest rapid transit challenge facing Southern California). The corridor connects the San 

Fernando Valley to Los Angeles’ Westside, coastal areas, LAX, and new LA Rams stadium 

complex. There is essentially zero rapid transit through the corridor. More appallingly, 

current transportation plans for the corridor project completion dates in the 2030-2040 

timeframe. This is ludicrous, especially because rapid transit in the corridor is the critical 

missing link in an otherwise fairly well integrated transit network. The SCAG Draft 2016 

RTP/SCS and PEIR ignore rapid transit in the Sepulveda Pass Corridor. The RTP/SCS notes 

already completed improvement works in the corridor only twice (RTP page 84, and RTP 

Transit Appendix page 52 in Table 19). These are I-405 freeway improvements and not 

rapid transit improvements. The RTP/SCS lists the Sepulveda Pass Transit Corridor only 

once in the Project List Appendix (page 162 as RTP ID 1160001). This same list entry 

appears in the PEIR (Table 3.17.1-1 on page 3.17-15). The entry identifies a transit project 

through the Sepulveda Pass Corridor, from the Metro Orange Line Van Nuys station (in the 

Valley) to the Metro Expo Line, with a completion date of 2039 and a project cost of 

approximately $2.4 billion. To our knowledge, the noted project is inconsistent with LA 

Metro’s latest transportation planning, first that it is too late and second that the cost is too 

low (we have seen Metro estimates ranging from $8 to $20 billion). The listed project is 

completely inconsistent with the first sentence in the RTP/SCS: “In our vision for the region 

in 2040, many communities are more compact and connected seamlessly by numerous 

public transit options, including expanded bus and rail service.” Rapid Transit in the 

Sepulveda Pass Corridor is the cornerstone of integrated rapid transit in Los Angeles County 

and an absolute near-term necessity, yet the Draft RTP/SCS relegates the project to a single 

listing in a table and no discussion. SOHA recommends that SCAG develop a mandatory 

rapid transit project list that integrates with and fulfills their vision. This list should 

obviously include a near-term rapid transit project through the Sepulveda Pass Corridor, 

probably as the highest-priority entry. The project should be complete in the early 2020 

timeframe and funded at realistic levels consistent with LA Metro’s latest projections.

SCAG works with the county transportation commissions to develop the transportation 

investment strategies in the RTP/SCS. The details for RTP# 1160001, the Sepulveda Pass 

Transit Corridor, were submitted to SCAG by Metro staff in the spring of 2015. The project 

details submitted include project termini, stations locations, project cost assumptions, and 

completion year assumptions. The 2039 completion year and $2.468 billion cost estimate 

are consistent with Metro’s board adopted 2009 Long Range Transportation Plan (LRTP), 

as displayed in Figure N on page 30 of that plan. Should the project details change due to 

voter approval of a new sales tax measure and due to Metro updating its LRTP, then SCAG 

will work with Metro to update the RTP/SCS accordingly.

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Submitted by Sherman Oaks Homeowners Association Submittal 16161 Related Documents Link

16161.01 Sherman Oaks Homeowners Association (SOHA) Comment 2 – The Draft RTP/SCS includes a 

discontinued project in the Sepulveda Pass that should be eliminated, as it is no longer 

needed and not currently being considered by LADOT. The installation of a reversible lane 

on Sepulveda Boulevard through the Mulholland Tunnel was once considered a quick fix to 

traffic alleviation (RTP ID LA996425 from RTP/SCS Project List Appendix Table 2 on page 

124, and also Program Environmental Impact Report Appendix B Table 1 on page 18). 

Sepulveda Boulevard comprises three lanes through the Mulholland Tunnel – two 

southbound lanes and one northbound lane. The project would convert the central 

southbound lane to a reversible lane, thereby providing two lanes in each direction at 

certain times of the day. Because of improvements to the I-405 freeway in this area, 

including addition of the new Skirball on- and off-ramps, recent observations have 

confirmed that there is no longer significant evening rush-hour northbound traffic on 

Sepulveda Boulevard. Two northbound traffic lanes and the reversible lane project are no 

longer necessary.

Comment noted. Since the completion of the improvements on I-405, additional 

improvement needs in this corridor, including Sepulveda Boulevard, are being further 

examined. SCAG will work with Metro and Caltrans to reflect the ultimate improvement 

configuration in this corridor in the future RTP/SCS amendments or updates as appropriate.

Submitted by Skirball Cultural Center Submittal 16172 Related Documents

16172.01 Re: RTP LA996425 Proposed project to create reversible lane in Mulholland Tunnel on 

Sepulveda Blvd. The traffic on the 405 and Sepulveda Blvd. affects our workers and visitors 

to our educational, museum, cultural and other programs. We have a posted crossing guard 

on at the Bergreen/Sepulveda intersection during commuting times. We monitor traffic 

patterns closely so we can advise our visitors. While southbound Sepulveda traffic 

continues to be problematic in the morning - though there are two lanes in the tunnel for 

southbound cars - northbound traffic in the evening has not been a problem. We therefore 

see no potential value to investing further effort into a reversible tunnel lane.

Comment noted. Since the completion of the improvements on I-405, additional 

improvement needs in this corridor, including Sepulveda Boulevard, are being further 

examined. SCAG will work with Metro and Caltrans to reflect the ultimate improvement 

configuration in this corridor in the future RTP/SCS amendments or updates as appropriate.

Submitted by South Bay Cities Council of Governments Submittal 16343 Related Documents Link

16343.01 1. We appreciate that the 2016 RTP/SCS introduced the Neighborhood Mobility Area (NMA) 

concept. Like the land use component of the South Bay’s Sustainable Strategy, NMA's have 

the potential to provide jurisdictions an opportunity to develop without reliance on high 

quality transit areas. (HQTA) We would like to see SCAG further develop the concept with 

criteria and implementation options.

Comment noted. With SB 375, SCAG is tasked with integrating land use and 

transportation. The land use policies listed in Chapter 5, under the “Our Strategies for 

Transportation and Land Use” section, are the foundational policies that guided the 

development of the RTP/SCS land use strategies. In order to encourage “complete 

communities” that integrate land use and transportation, SCAG introduced two new 

concepts called “Livable Corridors” and “Neighborhood Mobility Areas." These concepts 

are introduced to give local jurisdictions ideas for developing sustainably in other contexts 

besides dense urban High Quality Transit Areas (HQTAs). The Livable Corridors concept 

features land use strategies that are appropriate for lower density growth areas that are 

served by HQTA bus corridors. The Neighborhood Mobility Areas concept features low 

impact land use strategies and low-cost transportation solutions to replace vehicle miles 

with low GHG travel modes. SCAG’s intention is to assist local jurisdictions by providing a 

framework and allowing maximum flexibility in creating “complete communities”. SCAG 

will continue to work with the local jurisdictions that show interest in implementing the 

RTP/SCS land use policies by providing information and resources to support local planning 

activities, such as the Sustainability Planning Grant Program and the Active Transportation 

Program.

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Submitted by South Bay Cities Council of Governments Submittal 16343 Related Documents Link

16343.02 2. Carrying Capacity: The policy of increasing density in the built-out counties and 

preserving open space in the outer counties doesn’t appear to consider the carrying 

capacity of the already built-out areas. The idea of preserving green fields as a strategy to 

avoid building costly infrastructure on the edge does not take into account the potential to 

exacerbate infrastructure issues in the core. For example, landfills, sewers and utility 

infrastructure in many built-out jurisdictions are overloaded and in need of repair; open 

space per capita has been declining, roads and sidewalks are in disrepair, and so forth. We 

believe that such an analysis should be undertaken so that the true cost of the infill density. 

Transit Oriented Development (TOD) and HQTA strategy is understood.

Comment noted. The Urban Footprint Scenario Planning Model utilized for the 2016 

RTP/SCS is routinely refined and further developed to enhance its capabilities to reflect 

capacity concerns and costs. The Plan encourages jurisdictions to explore and implement 

innovative and emerging financing options such as Enhanced Infrastructure Finance 

Districts (EIFDs) to address capacity issues.

16343.03 3. Vehicle Miles Traveled (VMT): Reducing VMT is the key metric of success in the draft 

2016 RTP/SCS and may be consistent with state requirements; however, it is too coarse a 

measure to actually guide carbon reduction in the region. Going forward, SCAG should 

distinguish between electric VMT and carbon VMT. Focusing only on total VMT binds the 

plan to transit, cycling and walking which will have very minimal impacts on either total 

VMT or zero emission VMT.

Comment noted. Reduction of VMT per capita is a major component in our strategy to 

reduce regional greenhouse gas emissions and promote a more sustainable growth 

pattern in Southern California. Clearly the growing market share of electrically powered 

vehicles will contribute to total VMT, while not producing carbon emissions. SCAG will 

continue to work with our state, regional, and local partners to evaluate strategies, as they 

become available, to refine methodologies for monitoring and reducing greenhouse gas 

emissions in our region.

16343.04 4. Alternate Vehicles: Page 7 of the RTP states that SCAG has focused on Plug-In Hybrid 

Electric Vehicles. With the market getting larger for PEVs with more range, this plan should 

not focus just on hybrids. This document should be a realistic vision of how the region can 

meet state goals as well as regional needs. Since it takes 15 to 25 years to turnover a fleet, 

it is vitally important to increase the number of all Plug-in Electric Vehicles on the road each 

year.

Comment noted. SCAG, through its Plug-in Electric Vehicle (PEV) Readiness Planning 

support all types of zero emissions passenger vehicles. The Regional Electric Charging 

Station Rebate program will greatly benefit all plug-in electric vehicles. However, for the 

purposes of achieving mandated Greenhouse Gas (GHG) Reduction targets, the proposed 

strategy measures only the increased use of electric drive by Plug-in Electric Hybrids 

(PHEVs).

16343.05 5. The SBCCOG is concerned that there are policies and strategies proposed in the 

Appendices that are not included in the main body of the RTP/SCS or are included in a 

general way. All of the recommendations for specific actions should be in the main 

document or in one place in an Action Document. It is possible that some of the strategies 

and policies have already been adopted by SCAG but the document doesn't say that is the 

case. If they have already been approved, that should be stated. If they have not, does 

voting for this plan constitute agreement with all of the recommendations going forward? 

Please see the following appendices: o Mobility Innovation - pages 2 - 5 of the Appendix 

include Policy Recommendations. Page 106 of the main document does state: “These 

mobility innovations are discussed further in the Mobility Innovations Appendix”. At a 

minimum, this sentence should be revised to state that the appendix contains policy 

recommendations,

Sentence has been changed from "These mobility innovations are discussed further in the 

Mobility Innovations Appendix" to "Please see the Mobility Innovations Appendix for 

policy recommendations and additional information."

16343.06 o Natural and Farm Lands - pages 6 and 7 of the Appendix have Strategies and Next Step 

Recommendations. Page 111 of the main document states: “Please see the Natural and 

Farm Lands Appendix for additional detail”. At a minimum, this sentence should be revised 

to state that the appendix contains policy recommendations

Sentence has been changed from "Please see the Natural and Farm Lands Appendix for 

additional detail" to "Please see the Natural/Farm Lands Appendix for policy 

recommendations and additional information."

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Submitted by South Bay Cities Council of Governments Submittal 16343 Related Documents Link

16343.07 o Public Health - Page 19 of the Appendix contains the Public Health Work Program. It is not 

clear from the text whether the SCAG Board has adopted this work program already or 

whether it is being adopted with the passage of the RTP/SCS.

Comment noted. In 2013, the SCAG Regional Council adopted the recommendations of the 

Public Health Subcommittee to "Provide robust public health data and information, as 

feasible, to better inform regional policy, the development of the 2016-2040 RTP/SCS, and 

support public health stakeholder participation," and to "Promote and seek ongoing 

partnerships with regional partners, local public health departments and other 

stakeholders." The strategies and actions in the Public Health Appendix incorporate the 

Subcommittee recommendations and will be adopted as part of the Plan. The title of this 

section has been changed to Plan Implementation to align with other Plan components.

16343.08 o Transportation Safety and Security - Page 33 of the Appendix has Policies and 

Recommendations which are more detailed than the main document. At a minimum, the 

main document should include a sentence which states that there are more specific 

recommendations in the Appendix.

Comment noted. The Draft 2016 RTP/SCS has been updated to include a specific reference 

to the additional safety and security policies detailed within the Transportation Safety and 

Security Appendix.

Submitted by Southern California Gas Company Submittal 16295 Related Documents Link

16295.01 As a preliminary matter, SoCalGas appreciates SCAG’s ongoing focus on public health and 

air pollution, specifically the challenges of ozone reduction for Southern California, which is 

reflected in the RTP/SCS. At SoCalGas we also remain focused on the end goal - emission 

reduction - whether it be reducing ozone for public health or reducing greenhouse gas 

(“GHG”) emissions for global health. At the same time, we believe SCAG should take 

advantage of the best of what innovation can deliver, and welcome technology 

advancements that move us toward our collective goals.

Comment noted. SCAG’s policies are technology neutral with regard to supporting zero 

and/or near-zero emissions vehicles. SCAG will continue to support natural gas fleet 

vehicles by hosting and administering the Southern California Clean Cities Coalition.

16295.02 SoCalGas emphasizes the importance of natural gas to the California environment and 

economic health. We continue to work with our customers and technology developers to 

identify clean technology solutions through energy efficiency programs, customer 

education and outreach initiatives, and by supporting near-term and long-term technology 

development that can reduce both GHG and criteria pollutant emissions and better meet 

our customers’ changing energy needs. SoCalGas seeks to meet a range of customer needs, 

including serving traditional and new uses such as heating, power generation and 

transportation fueling, as well as continuing to leverage natural gas resources to deploy 

industry leading energy efficiency, conservation and emerging technology programs.

SCAG’s policies are technology neutral with regard to supporting zero and/or near-zero 

emissions vehicles. SCAG will continue to support natural gas fleet vehicles by hosting and 

administering the Southern California Clean Cities Coalition.

16295.03 Diversity in the State’s energy portfolio is also important for prudent risk management to 

support resiliency in the energy infrastructure as a climate adaptation strategy and should 

be a factor in the overall analysis of future pathways. As weather becomes more extreme 

from droughts, wildfires, hurricanes and El Nino events, there are risks to overreliance on 

one source of energy. Hurricane Sandy provided an example where every system 

dependent on electricity was jeopardized, from the refueling pumps at gasoline stations to 

the water pumps for putting out fires. Developing micro-grids supported by natural gas 

distributed technologies can operate for a limited timeframe separate from the grid; they 

can create more diversity in the electric grid since the natural gas system is mostly 

underground and relatively immune to extreme weather events.

Comment noted.

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Submitted by Southern California Gas Company Submittal 16295 Related Documents Link

16295.04 Further, the natural gas energy sector continues to create jobs and grow our economy. In 

California, the existing natural gas energy industry supports (directly and indirectly) more 

than 250,000 jobs and adds over $36 billion to the State’s economy. Future natural gas 

infrastructure improvement projects offer significant job opportunities and contribute to 

the local and State economy. Additionally, the manufacturing, industrial, and building 

sectors rely on natural gas as a low-cost energy source to run profitable operations. 

SoCalGas alone employs more than 8,000 Southern Californians and, in 2014, spent $571.4 

million with diverse suppliers encompassing 48.4 percent of SoCalGas’ procurement. 

SoCalGas’ natural gas energy efficiency programs have created approximately 8,000 jobs in 

California.

Comment noted. Promoting natural gas and biomethane projects would seemingly be 

more appropriate for an economic development strategy. The Economic & Job Creation 

Analysis of the 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy 

examines the impact that the Plan will have on the region's economy.

16295.05 We appreciate that the RTP/SCS includes a clear, recognized role for near-zero emission 

natural gas vehicles in both the near term and long term, especially in the goods movement 

sector. The RTP/SCS allocates $74.8 billion in goods movement strategies, which include 

“reducing environmental impacts by supporting the deployment of commercially available 

low-emission trucks and locomotives; and in the longer term advancing technologies to 

implement a zero- and near-zero emission freight system” (page 7). Supporting the 

deployment of commercially ready technologies that significantly reduce criteria pollutants 

and greenhouse gas emissions is critical to meet SCAG’s regional goals. With the recent 

California Air Resources Board (“CARB”) certification of the Cummins Westport Innovations 

(“CWI”) near-zero emissions engine, California has the opportunity to reduce NOx 

emissions by 90% from heavy duty trucks. The RTP/SCS should include a discussion on this 

near-zero emission CWI engine, which was certified recently with lower NOx and methane 

emissions. CARB established an Optional Low NOx Standard to incent engine development 

of trucks with emissions in the range of 0.02 to 0.1 grams of NOx per brakehorse power 

(“g/bhp”). The SCAQMD refers to 0.02 g/bhp as power plant equivalent emissions because 

electric vehicles may have zero tailpipe emissions but if full life cycle emissions are 

considered they are not zero emission. The near-zero CWI engine actually certified to 

emissions of 0.01 g/bhp, which means a natural gas truck or bus would have lower overall 

emissions than an equivalent battery electric truck.

SCAG will further review opportunities for integrating discussion of recent certification 

actions as may be appropriate.

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Submitted by Southern California Gas Company Submittal 16295 Related Documents Link

16295.06 The commercialization of this game changing technology for heavy-duty trucks and buses is 

a vital step in meeting our air quality goals and improving health in disadvantaged 

communities along Southern California’s transportation corridors. CWI’s first near-zero 8.9L 

engine can be utilized by transit fleets, waste haulers and some regional goods movement 

trucks. This provides an opportunity for transit and waste hauling fleets in Southern 

California to continue using compressed natural gas (“CNG”) buses with even greater 

environmental benefits- achieving emission levels below electric buses and trucks. 

Commercialization of this technology also provides opportunities for transit districts in the 

northern and eastern portions of SCAG’s region to transition to cleaner fleets today, as 

many of Southern California transit agencies have already done. All of these fleets can 

move to near-zero levels with the acquisition of the new CWI engine. Further, with the use 

of increasing volumes of renewable natural gas (RNG), the transit sector has the potential 

to drive the carbon intensity of its emissions below electric buses. We can do this in the 

next several years and not wait 20 years - a generation - before we begin to realize these 

emission reductions. In addition, CARB has included deployment of low emission, lowcarbon fueled trucks, such as low NOx, RNG fueled trucks as part of their 2014 Scoping Plan 

Update on how to meet the AB32 2020 GHG reduction goals. The 2016 RTP/SCS should 

clearly articulate this pathway. In addition to the certified 8.9L engine, CWI is also working 

on applying the same technologies to a larger engine, which can be commercialized for the 

goods movement sector in the next twelve to eighteen months. Goods movement is an 

important economic driver in Southern California. Maintaining cost effective solutions for 

long-haul drayage truckers will help the region remain competitive and meet stringent 

emissions goals. The Goods Movement Environmental Strategy quotes, “the regional 

strategy supports the deployment of commercially available low emission trucks and 

locomotives while centering on continued investments into improved system efficiencies. 

For example, the region envisions increased market penetration of technologies already in 

use, such as heavy-duty hybrid trucks and natural gas trucks.” (pg. 101). We look forward to 

partnering with SCAG and membership organizations to making this a reality.

Comment noted. SCAG looks forward to continuing opportunities to work with the 

Southern California Gas Company.

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Submitted by Southern California Gas Company Submittal 16295 Related Documents Link

16295.07 SoCalGas supports that the RTP/SCS recognizes the role of natural gas in locomotive sector. 

The Long- Term Emission-Reduction Strategies for Rail quotes, “Opportunities for near-zero 

emissions include incorporating liquid natural gas tender cars and after treatment systems. 

Tier 4 engines and earlier engine types can be retrofitted to operate with natural gas.” (pg. 

170). The Goods Movement Appendix quotes, “Liquid natural gas has also been considered 

as a fuel for rail locomotives. It is estimated that use of LNG with a Tier 4 locomotive would 

lead to NOx and PM reductions of 70 percent beyond the Tier 4 locomotive”. Beyond heavyduty truck engines, LNG is an ideal choice to replace diesel and bunker fuel for the goods 

movement industry, especially for marine and rail operators. Using LNG to reduce GHG and 

criteria pollutant emissions has been discussed by the rail and marine industries as well as 

the ports. This is not required through regulation- it is being driven by the fuel price 

differential between natural gas and diesel. Nationally and internationally, we have seen an 

increase in the number of LNG-fueled vessels in the marine sector, as well as LNG-fueled 

engine pilot programs by railroads. SoCalGas has had discussions with the Ports of Long 

Beach and Los Angeles about the possibility of utilizing LNG as a multi-sector transportation 

fuel, and natural gas as an energy source, at the ports. The Port of Long Beach identified 

this as a potential strategy in their Energy Island proposal. This opportunity is only 

marginally addressed in the RTP/SCS and we request that the plan should more clearly 

include a focus on reducing NOx emissions by investing in natural gas transportation 

technologies and fueling infrastructure at the ports.

SCAG will further review opportunities for integrating discussion as appropriate.

16295.08 SCAG’s goods movement strategies should also consider the advantages that switching 

from diesel to natural gas can have in the off-road and marine sectors will have for 

improvement of cancer risk in nearby communities affected by goods movement-related 

emissions. The Office of Environmental Health Hazard Assessment (OEHHA) Air Toxics Hot 

Spots Program Risk Assessment Guidelines Version 8.0 published in March 2015, shows 

natural gas has a significant advantage over diesel. SoCalGas calculated two examples of 

the difference between cancer risk from just switching from diesel to natural gas. In the 

case of a marine engine transiting near a port terminal, the calculation of the change in 

absolute residential cancer risk from just fuel switching (diesel to natural gas) shows that 

the diesel risk is 314 times the natural gas risk. In the case of locomotives, using an example 

of arrival and departure trains (ltrain/day; 4 hours/train at 50% load), the calculation of the 

change in absolute residential cancer risk from fuel switching (diesel to natural gas) shows 

that the diesel risk is 107 times the natural gas risk. We wish to point out that no specific 

facility was examined in our sample calculations, and no inference about actual risk at a 

specific facility can be derived from just this tier 2 screening level analysis information.

Comment noted.

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Submitted by Southern California Gas Company Submittal 16295 Related Documents Link

16295.09 SoCalGas supports SCAG’s inclusion of renewable natural gas (“RNG”) as an alternative 

transportation fuel in the Goods Movement Appendix. Reducing emissions and petroleum 

use within the transportation sector is critical to meeting both air quality and climate 

change policy goals for California. We believe supporting the development and deployment 

of RNG in the transportation sector should be included as a key strategy to achieve 

emission reduction goals. Meeting the federal ozone and particulate matter standards in 

Southern and Central California are the most significant air quality challenges for the state. 

Natural gas vehicles (“NGVs”) that can meet the optional low-NOx standard and run on 

renewable fuels can help California meet its GHG reduction and petroleum displacement 

goals, and should be included as a key pathway, especially in the heavy-duty vehicles 

sector. The transportation sector can also be an important catalyst for building an RNG 

market and encouraging the utilization of methane resources. CARB’s Low Carbon Fuel 

Standard identifies RNG from existing organic sources, such as dairy waste, landfills, and 

waste water treatment as the lowest carbon intensity standard pathway available, even 

lower than the current electricity mix and hydrogen. Today, due largely to this policy, RNG 

is already being used in California’s transportation sector. For example, Waste 

Management, Inc., uses RNG produced at its Altamont Landfill and Resource recovery 

Facility to fuel its waste hauling fleet in that region. Clean Energy Fuels Corporation offers 

RNG at their CNG and LNG stations throughout California. A review of the CARB’s Low 

Carbon Fuel Standard reporting tool shows that RNG, as a percentage of total natural gas 

used in the transportation sector, has increased from approximately 10% to 40-60% in the 

past year. SCAG needs to look at policies and incentives to promote more development of 

RNG in the region. Support for heavy-duty natural gas vehicles is a key to this development. 

The transportation sector can be an important catalyst for building the renewable natural 

gas market.

SCAG acknowledges different technology paths that have the potential for broad 

commercial deployment in the region for goods movement activities.

16295.10 In addition, renewable natural gas creates jobs. The Renewable Natural Gas Coalition 

estimates that biomethane projects in California have resulted in the creation of more jobs 

per year average (11.5) than any other renewable energy technology. According to 

Renewable Natural Gas Coalition’s California Biofuels Cap and Trade Initiative, developing 

biomethane projects at 200 candidate sites throughout the state (located at landfills, waste 

water recovery facilities, and agricultural sites) would create more than 20,000 direct and 

indirect jobs in 42 California counties. Also, as many as 100 temporary construction jobs 

could be created as a result of each project (page 8).

Comment noted. Promoting natural gas and biomethane projects would seemingly be 

more appropriate for an economic development strategy. The Economic & Job Creation 

Analysis of the 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy 

examines the impact that the Plan will have on the region's economy.

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Submitted by Southern California Gas Company Submittal 16295 Related Documents Link

16295.11 In the long term, and as transportation options evolve, more RNG can be injected into the 

pipeline and redirected to traditional natural gas end-uses, like cooking, space and water 

heating, achieving our Governor’s goal announces in this year’s State of the State speech to 

“clean our heating fuels.” We need to re-think methane. Capture and management of 

methane emissions (primarily from agriculture, dairies, landfills, etc.) will have a 

proportionately greater impact than efforts to control C02 emissions because of the higher 

global warming potential of methane. Combustion of methane, i.e. conversion to C02, 

reduces its global warming potential by a factor of greater than 20 times. Other 

management techniques, e.g. sequestration, are untested and still have significant issues to 

resolve, e.g. the ability to sequester the methane for long periods without leakage. 

Therefore, combustion of captured and recovered methane emissions will play an 

important role in current and future plans to reduce global warming.

SCAG acknowledges different technology paths that have the potential for broad 

commercial deployment in the region for goods movement activities.

16295.12 Conclusion We applaud SCAG’s effort in creating a technology neutral, performance-based 

RTP/SCS that looks to take advantage of the best that technology can offer. SoCalGas looks 

forward to working with SCAG and membership communities over the coming years to 

develop clear and actionable strategies to take advantage of and invest in opportunities to 

utilize natural gas’ potential as a clean energy solution. Decisions today are defining the 

course of our clean energy future in all sectors of our economy. Simply put, Southern 

California has the unique challenges and opportunities presented by its comprehensive 

environmental targets that cannot be met by staying on the current course. There will 

always be ongoing regulatory initiatives that are being undertaken by various agencies in 

the state, but this should not deter SCAG from taking the lead in affirming natural gas’ role 

in the long-term energy mix as a clean and affordable way to reduce smog and greenhouse 

gas emissions and improve the health of all Californians.

SCAG acknowledges different technology paths that have the potential for broad 

commercial deployment in the region for goods movement activities.

16295.13 SoCalGas supports expanded research, development and deployment agendas for natural 

gas technologies. We are pleased SoCalGas’ progress was noted in the Goods Movement 

Appendix, “Southern California Gas Company (SoCalGas) has also been involved in several 

technology development projects and has worked with Original Equipment Manufacturers 

to develop and test several engines and vehicles. These projects have been funded by 

partners including the CEC, DOE, SCAQMD, in addition to funding invested by SoCalGas” 

(page 48). We believe the next step will be to prioritize these research opportunities and 

identify specific action plans to advance strategies for realizing the benefits of natural gas. 

We appreciate the opportunity to provide comments and input on the 2016 Regional 

Transportation Plan/Sustainable Communities Strategy. Southern California is our home 

and we share SCAG’s goals to strive at the highest levels to preserve and take care of it. We 

embrace a big picture view and shall continue to work diligently to provide safe, clean, 

reliable and affordable service to 21 million people. We believe natural gas offers an 

affordable, clean and practical way to meet California’s goals and look forward to 

continuing to work together to develop action plans to align state and regional policies and 

identify funding resources to advance cleaner natural gas technologies to meet the state’s 

environmental goals, improve the health of our local communities through NOx, particulate 

matter and ozone emissions reductions, as well as global health through GHG reductions.

SCAG acknowledges different technology paths that have the potential for broad 

commercial deployment in the region for goods movement activities.

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Submitted by Southern California Leadership Council Submittal 16290 Related Documents Link

16290.01 Our group is particularly focused on assuring that the RTP/SCS will provide positive 

economic impacts and job creation. With that in mind, we applaud SCAG’s commitment to 

providing thorough economic analysis, including an evaluation of the plan’s impact on jobs 

and job creation. The economist’s analysis of the plan has produced some very positive 

data, projecting that the benefits of the RTP/SCS, in terms of job creation and economic 

growth in the region, will exceed the costs of the plan. Our group is encouraged by this 

analysis and will continue to work with SCAG and other stakeholders to assure that these 

projected benefits are brought to fruition through the plan’s effective implementation.

Comment noted.

16290.02 In a very few instances, the proposed SCS was analyzed using population and development 

forecasts that are below both the densities included in existing General Plan designations 

and the densities forecasted by the respective local jurisdictions. Fortunately, these 

deviations are relatively small in number and extent. However, in order to abide by the 

planning principles that were expressly adopted prefatory to the draft documents, these 

should be corrected.

Comment noted. SCAG cannot accommodate request for corrections. TAZs showing 

densities below existing General Plan designations are consistent with base year 

conditions and projections provided by local jurisdictions.

Submitted by SR 60 Coalition Submittal 16288 Related Documents Link

16288.01 The SR60 Coalition Cities have been advocating for the SR60 Light Rail Alternative since 

2007. Our coali¬tion has been successful in having the SR60 Light Rail Alternative selected 

as one of the two alternatives selected for further study. In November of 2014, the Metro 

Board voted to move our alternative to the next phase of technical study and analysis.

The 2016 RTP/SCS recognizes that a final alignment decision on the Metro Eastside Transit 

Corridor Phase 2 (RTP ID 1TR0704) is yet to be made, and does not preclude any final 

decision to be made by the Metro Board of Directors.

16288.02 Our Coalition is very concerned about the proposed dedicated truck lanes on the SR60 

Highway as proposed in the 2016 RTP/SCS . We have stated that SR60 Highway can not be 

the solution to all the transportation needs in the region. There are plans for the highway 

expansion and possible HOV lanes. The SR60 Coalition is concerned that many of these 

proposals, especially the dedicated truck lanes will be in direct conflict with the SR60 Light 

Rail Project. We ask that further discussion on transportation proposals on the SR60 State 

Highway be addressed with our SR60 Coalition and San Gabriel Valley Council of 

Governments.

Comment noted. SCAG acknowledges the need for continuing analyses and dialogue with 

stakeholders. Please note that the inclusion of the East-West Freight Corridor in the 2016 

RTP/SCS allows for further analyses to be conducted. Specific costs, refined user demand, 

accessibility concerns, designs, and alternative alignments would be identified through a 

project level Environmental Impact Report (EIR) . Further discussion of project mitigation 

concerns would also be addressed through upcoming processes.

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Submitted by Transportation Corridor Agencies Submittal 16187 Related Documents Link

16187.01 Pp 57, Table 1: FTIP Projects, Project 111207 We wish to clarify that project 111207 is a 

distinct and separate project from any other TCA project included within the FTIP. The SR 

241/91 connector project has always had its own project description, schedule, budget and 

unique ID number. This project was first introduced in the 2008 RTP as 2T01135. The 

project ID was updated to ORA084403 when the project was added to the 2008 FTIP in 

August 2010. The project ID was updated to ORA111207 when the project was included in 

the 2011 FTIP. The project has since been carried over into all subsequent FTIPs as project 

111207. Copies of these FTIP listings are attached to this letter as documentation of the 

project’s separate identity. Page 174, Table 2, Financially-Constrained RTP Projects 

Consistent with our comment above on the FTIP listing for 111207, we request that the 

reference to “parent project ORA050” be struck from the project description. The SR 

241/91 connector project is not part of ORA050. This will have no effect on the project 

content, schedule or budget. As noted in the previous comment for 111207 in Table 1, the 

SR 241/91 connector project has always had its own unique project description, schedule, 

budget, and project ID and has never been part of ORA050. Therefore, we request that the 

reference to “parent project ORA050” be struck from the project description, as the SR 

241/91 connector is not part of ORA050. This clarification will have no effect on the project 

content, schedule or budget.

Comment noted. We have addressed all modification requests to the Project List as 

submitted by county transportation commissions through the standard RTP long-range 

project list modification and FTIP database update processes. As part of that process, 

modifications to FTIP ID #111207 has been addressed.

16187.02 Pp. 173 and 174, Table 2: Financially-Constrained RTP Projects TCA’s four main toll road 

project descriptions are correctly listed in this table for project numbers, 10254, ORA050, 

ORA051 and ORA052. However, Table 2 also lists specific components of the toll road 

projects as “projects” with unique RTP ID numbers. For example, in addition to 10254 

(Route 73/ San Joaquin Hills Transportation Corridor), the Glenwood Drive/Pacific Park 

Drive on/off ramps are listed as a separate TCA project (RTP ID 2M0726). There is no 

reference to the ramps being a subset of 10254, and the project actually precedes the San 

Joaquin Hills Transportation Corridor listing. Similarly, a series of SR 241 interchanges and 

improvements are called out on page 174, with no reference that they are subsets of a 

larger toll road project that is also included in Table 2. Further, the opening dates for these 

pieces of the four main toll road projects should be 2020, consistent with the main project 

listings. TCA requests that SCAG work with our agency to remove any duplication or 

inconsistencies among the TCA project listings in Table 2, and that all completion dates be 

updated as needed to reflect the correct completion dates identified in the FTIP project 

descriptions.

Comment noted. We have addressed all modification requests to the Project List as 

submitted by county transportation commissions through the standard RTP long-range 

project list modification and FTIP database update processes. As part of that process, 

modifications to RTP ID# 2M0726, 2120003, 2160002, 2160003, 2160004, 2160005, and 

2160006 have been made.

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Submitted by United States Environmental Protection Agency Submittal 16285 Related Documents Link

16285.01 The 2016 RTP/SCS contains a strong focus on the long-term goal of a zero emission goods 

movement system where technically feasible and economically viable, while also 

integrating near-zero emissions technologies that serve as bridging options to continue to 

reduce emissions. EPA strongly supports these efforts to move towards zero emission 

goods movement, and is available to assist SCAG in meeting this goal. Well-planned and 

executed zero-emission freight corridors will contribute to improved air quality and reduce 

public health impacts for the already heavily burdened, low income and minority 

communities along these corridors and throughout the Southern California Air Basin. The 

Draft RTP/SCS uses the term clean trucks. For example, page 99 states “The East-West 

Freight Corridor would carry between 58,000 and 78,000 clean trucks per day that would 

be removed from adjacent general-purpose lanes and local arterial roads.” There are also 

several references to the San Pedro Bay Ports Clean Truck Program. However, there is no 

definition provided for “clean trucks”. Recommendation: EPA suggests defining the term 

“clean truck” in relation to current vehicle emissions standards. One possible criteria for 

defining “clean truck” could consist of meeting the EPA exhaust emission standards for 

model year 2010 and newer heavy-duty on-highway engines, or the CARB optional low NOx 

emission standards for on-road heavy-duty engines.

Comment noted. SCAG uses the term "clean trucks" to capture potentially new 

technologies that may emerge and contribute tremendously to reducing vehicle emissions 

in the future as our plan is long-range in scope. At the same time, we recognize the benefit 

of developing a plan to get to the zero-emission future and include Goods Movement 

Environmental Strategy And Action Plan in the Goods Movement Appendix. Further, SCAG 

recognizes a need for a collaborative relationship with our partner agencies at the 

regional, state, and Federal level in defining these terms and looks forward to the 

opportunity to work with the EPA on further defining them.

16285.02 The Environmental Justice Appendix to the Draft RTP/SCS provides a thorough 

Environmental Justice Analysis which includes five different geographies (Environmental 

Justice Areas, SB 535 Disadvantaged Communities, Communities of Concern, Urban Areas, 

and Rural Areas) and eighteen different performance areas. The analysis of impacts along 

freeways and highly traveled corridors is an especially important performance criteria 

because vulnerable populations (such as older adults, children, and those with pre-existing 

cardiovascular and respiratory conditions), and people with “low socioeconomic status” are 

particularly susceptible to PM2.5-related health impacts. EPA supports the 

recommendation in the Environmental Justice Toolbox (RTP/SCS Environmental Justice 

Appendix, page 194) to conduct corridor-level near roadway environmental justice analyses 

for proposed projects in areas where air quality impacts may be concentrated among 

Environmental Justice communities. Please consider the following recommendations in 

order to facilitate effective analysis and mitigation of the impacts that communities with 

Environmental Justice concerns may experience from the proposed plan and future 

projects. Recommendations: Please consider making the underlying Environmental Justice 

Toolbox data and analyses accessible for project proponents to use as a starting point for 

corridor and project level analyses. In addition, please consider which of the other 17 

performance areas would be useful for a corridor or project level analysis, include those as 

recommendations in the Environmental Justice Toolbox, and make the data easily 

accessible. Please consider highlighting the use of the recently published EPA-guidance 

document titled “Best Practices for Mitigating Near Roadway Pollution at Schools 

(November 2015)” which could serve as a useful resource for mitigating Environmental 

Justice Impacts. EPA strongly supports the following advanced technology deployment 

measures included in this section and recommends SCAG discuss strategies to incentivize 

their implementation: 1) zero emission heavy-duty trucks; 2) Tier 4 marine engine repowers 

and replacements; and 3) Tier 4 and zero emission railyard equipment.

SCAG has amended the Environmental Justice Toolbox to highlight potential strategies to 

reduce corridor and project specific impacts for EJ groups (including the EPA-guidance 

document, "Best Practices for Mitigating Near Roadway Pollution at Schools"). SCAG will 

also work to make available to project proponents the underlying Environmental Justice 

Toolbox data and analyses.

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Submitted by United States Environmental Protection Agency Submittal 16285 Related Documents Link

16285.03 In the Climate Vulnerability Chapter, include a discussion about how global warming affects 

ozone formation. Please also include a discussion about the possible health threats from 

dust storms related to extended drought conditions, which could be a concern for 

vulnerable populations at risk for Valley Fever. Please update Exhibit 39 to describe areas at 

risk from inland flooding, in addition to the information describing coastal areas at risk for 

sea level rise in 2100. This information is available from national flood maps, and would 

more holistically communicate potential flood risks to Environmental Justice communities. 

Please provide a reference for the statement in Table 94 that states, “Increased greening 

may increase gentrification/ housing cost pressures.”

SCAG has expended the Climate Vulnerability section of the Environmental Justice 

Appendix to account for ozone impacts from climate change, potential dust storms related 

to extended droughts, and potential impacts from inland flooding. Table 95 looks at the 

possible impacts from certain climate adaptation policies on low income and minority 

groups. Infrastructure investments, such as shade trees, may increase the overall 

attractiveness of a neighborhood and could impact housing prices, as discussed in recent 

studies from WRCOG and the City of Chula Vista and noted in the table.

Submitted by United States Environmental Protection Agency Submittal 16371 Related Documents Link

16371.01 The U.S. Environmental Protection Agency (EPA) appreciates the opportunity to provide 

feedback on the 20 16-2040 Draft Regional Transportation Plan/Sustainable Communities 

Strategy (RTP/SCS) and the Draft Program Environmental Impact Report (PEIR). EPA 

supports the Southern California Association of Government (SCAG) goal of incorporating 

environmental and community considerations in the regional transportation planning 

process. Early integration of comments from regulatory and resource agencies results in 

greater opportunities to avoid sensitive resources and receptors and minimize impacts 

associated with future transportation projects. We note that Title 23 USC 134 states that a 

long-range transportation plan “shall 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 affected by the plan” and that the discussion of mitigation “shall 

be developed in consultation with Federal, State, and tribal wildlife, land management, and 

regulatory agencies.” EPA is available to coordinate with SCAG as the development of the 

RTP and SCS continues in order to provide feedback on mitigation activities and assist in 

meeting consultation requirements. EPA provides the following comments following our 

limited review of plan elements related to Environmental Justice, Air Quality, and Climate 

Change.

Comment noted.

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Submitted by Ventura County Submittal 16235 Related Documents Link

16235.01 In September 2015, the Ventura County Board of Supervisors adopted a comprehensive 

update to the Saticoy Area Plan. The Saticoy community is defined as a "severely 

economically disadvantaged community”. The Saticoy Area Plan has a 20-year time horizon 

that extends from 2015 to 2035. Within the Saticoy Area Plan, project objectives are called 

"guiding principles” that must be used when evaluating future Area Plan amendments. The 

four guiding principles developed for the Saticoy Area Plan update 1) sustainable 

development that supports a healthy community, 2) economic revitalization, 3) improved 

housing opportunities and, 4) improved infrastructure systems. The Area Plan update was 

primarily funded through a combination of Compass Blueprint Program Grant and the 

Strategic Growth Council Sustainable Communities Planning Grant Program. Significant 

planning efforts were focused on reducing vehicle miles travelled. One of the unavoidable, 

significant impacts that was identified in the Saticoy Area Plan Program EIR, includes traffic 

impacts on State Route 118 (SR118) in the Saticoy Community. One potential mitigation 

measure that was identified includes the widening/re-striping of SR118 in the Saticoy 

community (e.g., generally between Vineyard Avenue to Darling Road). Although the Board 

of Supervisors adopted a statement of overriding considerations for this impact, the 

following implementation program (highlight added) was included in the Area Plan to help 

mitigate the impact in the future. (SEE ATTACHED LETTER) As indicated in the adopted 

Saticoy Area Plan program, it is critical for implementation of the recently adopted Saticoy 

Area Plan and future development in the Saticoy community that the re-striping project be 

included as a prioritized project in the 2016 RTP/SCS (FTlP Projects). The Saticoy Area Plan 

guiding principles are consistent with the RTP/SCS overarching strategy that calls for "more 

compact communities in existing urban areas”. The Saticoy Area Plan includes a land use 

plan with more compact development and improved mobility in an existing urban area. 

Peak-hour traffic impacts are already significant in this area and will impede future 

revitalization of this disadvantaged community if improvements to SR118 are not 

constructed. As such, we respectfully request that the re-striping and any other critical 

intersection improvements in the Saticoy area be included in the RTP/SCS or FTIP Projects 

list as necessary, to make this a priority project

Comment noted. Widening improvements to SR-118 within the Saticoy area are included 

in the Project List under RTP ID# 5160008. Any additional improvement projects that are 

identified in the Saticoy Area Plan, but not included in the 2016 RTP/SCS at present, may 

be submitted to SCAG via VCTC for future consideration for inclusion in the RTP/SCS 

through an amendment or update to the Plan.

Submitted by Ventura County 350 HUB Submittal 16274 Related Documents

16274.01 The Ventura County 350 Climate Hub, a coalition of organizations with an interest in 

climate change mitigation, transition from fossil fuels to renewable energy, and community 

resilience, just learned of the opportunity to comment on the SCAG 2016 RTP-SCS (Regional 

Transportation Plan - Sustainable Communities Strategy). Based on quick study, our 

comment at this time focuses on a desire for higher targets for reductions in Greenhouse 

Gas (GHG) emissions, along with more clear assurance of efforts to stop burning fossil fuels 

near predominately low income people of color. We also want a relevant Climate Action 

Plan for Ventura County which is informed by, and is used to inform, the Regional 

Transportation Plan (RTP).

There is a continuing emphasis on reducing greenhouse gas emissions, even after the 

adoption of SB 375. On April 29, 2015, Governor Brown issued Executive Order B-30-15, 

which establishes a California greenhouse gas reduction target of 40 percent (below 1990 

levels) by 2030. Because the transportation sector is the largest contributor to California’s 

greenhouse gas emissions (more than 36 percent), SCAG anticipates updated and more 

stringent regional emissions reduction targets. SCAG encompasses six counties and 191 

cities, and the RTP/SCS policies and strategies reflect the diversity in the region. It is not in 

SCAG’s mission to plan for specific areas/jurisdictions in the region – any plans to specific 

areas/jurisdictions will and should come from the respective jurisdiction(s).

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Submitted by Ventura County 350 HUB Submittal 16274 Related Documents

16274.02 More Public Input and Engagement is Crucial to Success of Timely Emissions Reductions 

We would like to request an extension of 45 days so that we can learn and study more and 

engage more of our members and partner organizations studying the plan. We did not hear 

about the workshop in Camarillo last summer. It appears no NGOs whose primary concern 

is climate change were sufficiently engaged with SCAG to receive notice of the 60 day 

comment period. That 60 day period spanned the holidays, during which time we were 

paying attention to COP21 and other critical climate-related issues, such as the 

consequences of the massive gas leak at Porter Ranch. The Ventura County Transportation 

Commission has no money, no sales tax revenue. It is considering a ballot measure this year 

to add a half cent sales tax. Such a measure has failed twice because there is not a 

perceived traffic congestion problem here. There is skepticism about it getting a 2⁄3 vote. 

Regional plans that support greater awareness and engagement about reducing our carbon 

footprint are urgently needed. When the problem of climate change is presented with 

concrete, workable, high-tech, fun solutions that significantly boost the local economy, 

using real life examples and case studies, people can overcome what is otherwise a 

potentially hopeless view of the future that leads to denial. A community with concrete 

options is alert and empowered. Your Fundamental Assumptions Need to be Based on 

Fully Meeting State and Federal Policy Goals Rather Than Guided First and Foremost by the 

Consumer Choice Model The RTP seems to take pride in being consumer driven, which may 

explain why targets are not high or explicit enough. A comment was submitted by SCE 

Docket # 15-IEPR-10 on December 8, 2015. It suggests that Transportation Energy planning 

should model two scenarios for on-road / train and off-road segments: (1) a mid-case 

scenario incorporating all regulations and incentives, and (2) a high-case scenario based on 

achievement of all “federal air quality requirements under a variety of fuel and technology 

mixes, including a high-electrification case in most market segments.” This comment is 

relevant for SCAG’s plan, exemplifying the bold leadership to plan and act in the 

community’s best short and long-term interest. There is no time left to allow public input to 

be dominated, particularly in Ventura County, by those more engaged consumers, labor, 

and Chamber leaders misled by oil industry propaganda.

Comment noted. SCAG provided a 60 day public review and comment period beginning 

December 4, 2015, and concluding on February 1, 2016, for the Draft 2016 RTP/SCS and 

the PEIR. SCAG provided advance notice of elected official workshops and public hearings 

on the Draft 2016 RTP/SCS including publication in newspapers throughout the region such 

as the Ventura County Star to give as many interested parties as possible the opportunity 

to attend and provide input. There are additional opportunities to provide comment, 

including speaking at upcoming meetings of the Regional Council and Policy Committees or 

speaking with your Regional Council representative. To find your SCAG board 

representative, please visit SCAG's website, www.scag.ca.gov

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Submitted by Ventura County 350 HUB Submittal 16274 Related Documents

16274.03 GHG Emissions Reduction Goals and Targets Transportation Plans Should Parallel Climate 

Action Plans Developed with Public Input The recently published draft Climate on the 

Move (concerning Ventura County’s carbon footprint and vision for GHG reductions) 

documents the amount of GHG pollution from mobile sources as 53% (p. 14-21). It says 

that half of that is due to vehicles emitting GHGs on state highways, (e.g. 101, 118, 23 and 

126). In comparison, for the SCAG region, mobile sources contribute only 37%. Therefore, 

our first concern is that Ventura County should be strongly encouraged by SCAG to adopt a 

more ambitious set of targets than are reflected in the transportation plan targets currently 

specified in the SCAG RTF. There is little county by county breakdown; the projects and 

resources in the SCAG plan seem less applicable to Ventura County. The VC Transportation 

Commission needs you to model more ambition to help it create a sense of urgency for 

revenue generation. Ventura County's carbon footprint is 53% transportation, 36% energy 

and 11% "other" (mostly wastewater and landfill). SCAG's carbon footprint, by contrast, is 

37% transportation (per the RTP). An overall GHG emissions inventory from SCAG would be 

helpful for context. Statewide, the emissions from transportation are reported in the 2015 

EIPR as 37%, from the industrial sector including oil refineries 27%, residential and 

commercial sectors 26%, and agriculture 9%. Consistency among agencies in making 

emissions source pie charts and a detailed breakdown by county would be helpful to 

inform county Climate Action Plans and, hence, county transportation plans. We can only 

assume that the carbon footprint for SCAG is similar to that for the state. Assuming that LA 

County's soon-to-launch Community Choice Energy (CCE or CCA) will boost early reductions 

in the energy sector (i.e. hopefully 50-70% below 1990 emissions by 2030), maybe higher 

targets in the energy sector and “other” sources make up for the low target in the 

transportation sector. Considering the potential for CCE to speed electrification of the 

transportation system with energy from 70+% preferred resources, this parallel 

development seems like a glaring omission that would support significantly higher targets 

for the transportation sector.

Comment noted. Pursuant to SB 375, the 2020 and 2035 regional GHG reduction targets 

apply to the entire SCAG region and there are no county specific targets.

16274.04 GHG Emissions Reduction Goals and Targets - Part 2 SCAG Does Not Appear to Align with 

US Pledges to the UN Climate Agreement The US has pledged to reduce emissions 24-31% 

below 2005 levels by 2025 and 32% below 2005 levels by 2030. Those goals are uncertain 

and do not assure that the US can do its minimum fair share. The larger economies of 

Europe have goals of 40% below 1990 levels by 2030 and analysts say more ambition than 

that is required to prevent warming above 1.5 degrees Celsius. SCAG’s 2016 RTP-SCS 

targets are only 8% below 2005 levels by 2020, 18% by 2035 and 22% by 2040! If SCAG aims 

to do its part in the family of nations, the 2016 RTP-SCS would likely need to at least double 

these targets. We therefore demand a target of 28-35% (not 14%) below 2005 levels by 

2030. The first five years of the plan are crucial to help slow climate feedbacks. We further 

request a timetable of project choices by lead time and emissions ROI (target intensity) by 

stated completion times. Our national pledge is a moral imperative that must be a 

minimum operational guide right now for every state, regional, and local government. With 

a federal price on carbon (in the form of a revenue-neutral Carbon Fee and Dividend, which 

also includes a border fee adjustment), the world’s largest economy will trigger a global 

gradually rising price on carbon to speed achievement of adequate local targets.

Comment noted. SCAG's regional targets require a reduction in greenhouse gas emissions 

(GHG) per capita from automobiles and light trucks, while the US Pledges apply to total 

GHG reductions from all GHG emission sources. In other words, the GHG reduction 

percentages are not directly comparable.

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16274.05 GHG Emissions Reduction Goals and Targets - Part 3 SCAG Also Does Not Appear to Meet 

Governor Brown’s Executive Orders If SCAG prefers to be guided strictly by state laws and 

regulations as opposed to international norms, then the RTP-SCS targets as proposed would 

be inadequate: proposed targets would achieve only a third of the reductions that are 

specified in CARB regulations. Executive Order S-03-05 sets the statewide target at 80% 

below 1990 levels by 2050. Executive Order B-30-15 of last year then requires interim 40% 

GHG reductions below 1990 levels by 2030 to ensure the 2050 target. Using this 1990 

target, SCAG would only achieve 32% reductions below 1990 levels by 2040. Again, by any 

standard, this seems “too little, too late”. Attorney General Kamala Harris submitted 

comment on September 16, 2011 on the Draft EIR for the SANDAG 2016 RTP-SCS, 

concerning the San Diego Association of Governments (SANDAG) failure to mitigate climate 

change impacts, air pollution impacts, and impacts to public health and communities 

already impacted by air pollution (see attachment). SANDAG is being sued for lack of 

ambition and lack of priority concerning clean emission public transit in urban centers, 

among other issues. SANDAG’s defense that the Executive Orders are not legally binding is 

legally suspect and ethically unconscionable. We urge SCAG to respect CARB’s and 

Governor Brown’s reasonable and useful rules for regional GHG reductions. At the very 

least, SCAG needs to revisit its goals and targets to ensure compliance with AB32.

Comment noted. The Executive Order calls for all the relevant sectors to contribute to its 

fair share. The Draft 2016 RTP/SCS meets and exceeds its regional GHG emission reduction 

targets which demonstrates SCAG's overachievement in fulfilling its responsibility. SCAG 

staff has been working with ARB staff in setting the next round of regional GHG emission 

targets. We are committed to setting and meeting ambitious and achievable regional GHG 

reduction targets pursuant to SB 375. As the Draft 2016 RTP/SCS meets and exceeds its 

regional GHG emission reduction targets required for light and medium duty vehicles, if 

other sectors also meet their share of GHG reduction, the SCAG region will also meet or 

exceed the goals set by AB 32 and the Executive Orders.

16274.06.1 SCAG’s Vision Needs Concreteness for Transparency and Public Engagement - Part 1 It is 

difficult to locate and discern the scope and comparative impact of proposed projects in 

this report. We see that the descriptions of plans trail off toward 2040 in vague 'scenarios'. 

Details are needed to enable the public to comprehend the SCAG vision.

SCAG first generated four preliminary scenarios for our region’s future – each one 

representing a different vision for land use and transportation in 2040. These four 

preliminary scenarios are described and analyzed in full detail in the Appendix: SCS 

Background Documentation. More specifically, each scenario was designed to explore and 

convey the impact of where the region would grow, to what extent the growth would be 

focused within existing cities and towns, and how it would grow — in other words, the 

shape and style of the neighborhoods and transportation systems that would shape 

growth over the period. SCAG’s ‘Preferred Scenario’ is described in full detail in Chapter 4: 

Creating a Plan for Our Future (page 65).

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16274.06.2 Descriptions of innovative projects that would engage people. The CA Energy Commission 

(CEC) 2014 IEPR (Integrated Energy Policy Report) Chapter 3 in its description, for example, 

of statewide EV rollout refers to SCAG’s EV readiness plan and atlas for 200 cities to meet 

demand for EV charging, including removing barriers to installing chargers at multi-unit 

dwellings (MUDS) and parking facilities and completion of the West Coast Green Highway 

with DC fast chargers. CEC’s 2014 Fact Sheet Advancing Statewide Plug-In Electric Vehicle 

Infrastructure details goals, incentives, barriers, and opportunities with a focus on home 

charging as “the greatest opportunity for growth in the next few years.” These are just 

some of the exciting projects reported by the CEC that we would also like to see featured as 

phase one projects in the RTP-SCS! Governor Brown’s ZEV (Zero Emission Vehicle) Action 

Plan. Chapter 4 of 2014 IEPR covers next generation alternate renewable fuel / electric 

vehicles and hybrids and how to win acceptance. In particular, it states “hydrogen fuel 

vehicles will play a key role in fulfilling the Governor’s ZEV Action Plan goals of 1.5 million 

zero-emission vehicles in 2025 [nine years from now!]....They can travel...300 miles on a 

tank of hydrogen and can be refilled in 5 to 10 minutes....Fuel cell electric drivetrains can 

be scaled up and used in larger sedans, vans, SUVs, and light trucks, which will create 

more...options than...with battery-electric vehicles.” We read that California is doing a 

demonstration infrastructure for hydrogen fuel cell vehicles in Irvine. The Mayor of 

Camarillo recently reported from the dais of the Ventura County AQCD Board meeting that 

state transportation planners expect hydrogen fuel cells to far outpace solar electric within 

a rapid ZEV mobilization. Projected costs are not more than 35% higher than comparable 

vehicles run by other forms of energy. A rising price of carbon will nullify the higher 

purchase price.

Comment noted. The RTP/SCS includes the regional electric vehicle charging station rebate 

program, which is a proposed strategy to increase access for plug-in electric vehicles to 

level 1 and level 2 charging. In addition, SCAG is active in encouraging the deployment of 

hydrogen fuel cell vehicles.

16274.07.1 SCAG’s Vision Needs Concreteness for Transparency and Public Engagement - Part 2 Also, 

we read that SCE was awarded funding to build out EV fast chargers around Los Angeles 

with an apparent prioritization of EV charging stations at businesses and multi-family 

dwellings. We would also like to see in the RTP-SCS about progress reported in 2015-IEPR01 for EV-smart grid integration, such as the two million dollar demonstration completed 

by UCLA.

Comment noted. SCAG partners with Southern California Edison on planning for the 

deployment of electric vehicle charging stations throughout the region.

16274.07.2 SCAG’s 2016 RTP-SCS mentions an ambitious goal for emissions reductions in 

transportation of goods but no specifics. It appears aligned with developments reported in 

2015-IEPR for medium and heavy-duty alternate fuel vehicles. Examples will reassure and 

inspire businesses.

The 2016-2040 RTP/SCS identifies numerous strategies in reducing emissions from goods 

movement sources as outlined in the Goods Movement Environmental Strategy and 

Action Plan section of the Goods Movement Appendix.

16274.07.3 Below are some further examples of innovations that might be listed: electric buses, trucks 

and delivery vans, government fleets, and plug-in electric and battery garbage trucks 

charged by solar panels at fleet yards. We are particularly interested in seeing a current 

inventory of buses and a plan for transitioning to electric, hydrogen, or renewable fuel 

hybrids (methane captured from the garbage). Such ideas jump-start discussion of how to 

speed up the greening of the transportation system.

Comment noted. SCAG, through its Clean Cities Coalition, encourages local jurisdictions in 

replacing existing fleet vehicles with zero and near-zero emissions vehicles.

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16274.08 Unwise to plan fleets that run on natural gas The SCAQMD reportedly plans to transition to 

natural gas fuels for heavy-duty trucks. We suggest that you request economic forecasting 

based upon an inevitable rise in the price of carbon. SCAQMD seems to be planning for 

short-term savings and fails to anticipate the inevitable upstream tax on fossil fuel carbon 

that will obviously shift the economics of natural gas fuels. Even CEC (in IEPR 2015) still 

does not make plans based on a scenario in which society finally compels producers to fully 

internalize all the social and environmental costs of fossil fuels, such as the climate 

destabilization costs associated with the massive release methane currently occurring due 

to the blown-out gas storage well in Aliso Canyon. Governments and industries that 

anticipate a rapidly rising price on carbon will be more secure and successful within a few 

years. They will be competitive leaders and will help speed the transition to a renewable, 

low carbon (and perhaps, carbon-free economy) when they invest in EV, hydrogen, and 

alternate fuel Hybrid EV heavy-duty vehicles, buses, and trucks. The risks from natural gas 

extraction and storage are no longer justifiable. Potential natural gas-related catastrophe 

threatens both our atmosphere and those who live nearby. Well-documented devastation 

of communities and water supplies at fracking sites only adds to the long-term 

unsustainability of a natural gas dependent economy that we do not want to support. 

Major corporations, including oil companies like Shell, use a shadow price around $40 per 

ton of CO2 equivalent. An additional tax must be put on release of unburnt methane that 

takes into account its short-lived but intense atmospheric heat-trapping effect. Climate 

activists are lobbying for legislation to put an appropriate price on leaking methane and a 

gradually-rising price on fossil fuels, up to $100 per ton CO2 equivalent within ten years. 

We urge you to join us and plan for this new, more ecologically-sustainable regulatory 

environment of the near future.

Comment noted. The Plan does not assume funding from a carbon tax. However, the Plan 

notes that funding for transportation improvements is currently not sustainable, given the 

projected needs. Projected revenues from the gas tax, the historic source of transportation 

funding, will not meet transportation investment needs – and gas tax revenues, in real 

terms, are actually in decline as tax rates (both state and federal) have not been adjusted 

in more than two decades while the number of more fuel efficient and alternative 

powered vehicles continues to grow. It’s vital that we find new ways to make 

transportation funding more sustainable in the long-term, and efforts are underway to 

explore how we can transition from our current system based on fuel taxes to a more 

direct system based on user fees. Recent action by the state Legislature to launch the 

California Road Charge Pilot Program is a critical step in this transition.

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16274.09 GOVERNOR BROWN'S EXECUTIVE ORDER B-30-15 PART 1 WHEREAS climate change poses 

an ever-growing threat to the well-being, public health, natural resources, economy, and 

the environment of California, including loss of snowpack, drought, sea level rise, more 

frequent and intense wildfires, heat waves, more severe smog, and harm to natural and 

working lands, and these effects are already being felt in the state; and WHEREAS the 

Intergovernmental Panel on Climate Change concluded in its Fifth Assessment Report, 

issued in 2014, that "warming of the climate system is unequivocal, and since the 1950s, 

many of the observed changes are unprecedented over decades to millennia" and that 

"continued emission of greenhouse gases will cause further warming and long-lasting 

changes in all components of the climate system, increasing the likelihood of severe, 

pervasive and irreversible impacts for people and ecosystems;" and WHEREAS projections 

of climate change show that, even under the best-case scenario for global emission 

reductions, additional climate change impacts are inevitable, and these impacts pose 

tremendous risks to the state's people, agriculture, economy, infrastructure and the 

environment; and WHEREAS climate change will disproportionately affect the state's most 

vulnerable citizens; and WHEREAS building on decades of successful actions to reduce 

pollution and increase energy efficiency the California Global Warming Solutions Act of 

2006 placed California at the forefront of global and national efforts to reduce the threat of 

climate change; and WHEREAS the Intergovernmental Panel on Climate Change has 

identified limiting global warming to 2 degrees Celsius or less by 2050 as necessary to avoid 

potentially catastrophic climate change impacts, and remaining below this threshold 

requires accelerated reductions of greenhouse gas emissions; and WHEREAS California has 

established greenhouse gas emission reduction targets to reduce greenhouse gas emissions 

to 1990 levels by 2020 and further reduce such emissions to 80 percent below 1990 levels 

by 2050; and WHEREAS setting an interim target of emission reductions for 2030 is 

necessary to guide regulatory policy and investments in California in the midterm, and put 

California on the most cost-effective path for long term emission reductions; and

Comment noted.

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16274.10 GOVERNOR BROWN'S EXECUTIVE ORDER B-30-15 - PART 2 WHEREAS all agencies with 

jurisdiction over sources of greenhouse gas emissions will need to continue to develop and 

implement emissions reduction programs to reach the state's 2050 target and attain a level 

of emissions necessary to avoid dangerous climate change; and WHEREAS taking climate 

change into account in planning and decision making will help the state make more 

informed decisions and avoid high costs in the future. NOW, THEREFORE, I, EDMUND G. 

BROWN JR., Governor of the State of California, in accordance with the authority vested in 

me by the Constitution and statutes of the State of California, in particular Government 

Code sections 8567 and 8571 of the California Government Code, do hereby issue this 

Executive Order, effective immediately IT IS HEREBY ORDERED THAT: 1.A new interim 

statewide greenhouse gas emission reduction target to reduce greenhouse gas emissions 

to 40 percent below 1990 levels by 2030 is established in order to ensure California meets 

its target of reducing greenhouse gas emissions to 80 percent below 1990 levels by 2050. 

2.All state agencies with jurisdiction over sources of greenhouse gas emissions shall 

implement measures, pursuant to statutory authority, to achieve reductions of greenhouse 

gas emissions to meet the 2030 and 2050 greenhouse gas emissions reductions targets. 

3.The California Air Resources Board shall update the Climate Change Scoping Plan to 

express the 2030 target in terms of million metric tons of carbon dioxide equivalent. 4.The 

California Natural Resources Agency shall update every three years the state's climate 

adaptation strategy, Safeguarding California, and ensure that its provisions are fully 

implemented. The Safeguarding California plan will: -Identify vulnerabilities to climate 

change by sector and regions, including, at a minimum, the following sectors: water, 

energy, transportation, public health, agriculture, emergency services, forestry, biodiversity 

and habitat, and ocean and coastal resources; -Outline primary risks to residents, property, 

communities and natural systems from these vulnerabilities, and identify priority actions 

needed to reduce these risks; and -Identify a lead agency or group of agencies to lead 

adaptation efforts in each sector.

Comment noted.

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16274.11 GOVERNOR BROWN'S EXECUTIVE ORDER B-30-15 - PART 3 5.Each sector lead will be 

responsible to: -Prepare an implementation plan by September 2015 to outline the actions 

that will be taken as identified in Safeguarding California, and -Report back to the California 

Natural Resources Agency by June 2016 on actions taken. 6.State agencies shall take 

climate change into account in their planning and investment decisions, and employ full lifecycle cost accounting to evaluate and compare infrastructure investments and alternatives. 

7.State agencies' planning and investment shall be guided by the following principles -

Priority should be given to actions that both build climate preparedness and reduce 

greenhouse gas emissions; -Where possible, flexible and adaptive approaches should be 

taken to prepare for uncertain climate impacts; -Actions should protect the state's most 

vulnerable populations; and -Natural infrastructure solutions should be prioritized. 8.The 

state's Five-Year Infrastructure Plan will take current and future climate change impacts 

into account in all infrastructure projects 9.The Governor's Office of Planning and Research 

will establish a technical, advisory group to help state agencies incorporate climate change 

impacts into planning and investment decisions. 10.The state will continue its rigorous 

climate change research program focused on understanding the impacts of climate change 

and how best to prepare and adapt to such impacts. This Executive Order is not intended to 

create, and does not, create any rights or benefits, whether substantive or procedural, 

enforceable at law or in equity, against the State of California, its agencies, departments, 

entities, officers, employees, or any other person. I FURTHER DIRECT that as soon as 

hereafter possible, this Order be filed in the Office of the Secretary of State and that 

widespread publicity and notice be given to this Order. IN WITNESS WHEREOF I have 

hereunto set my hand and caused the Great Seal of the State of California to be affixed this 

29th day of April 2015. ______________________________ EDMUND G. BROWN JR. 

Governor of California

Comment noted.

16274.12 The well documented and serious deficiency in the SANDAG RTP-SCS may inform what we 

need to see addressed by SCAG's plan. To that end we refer you to: 

https://oag.ca.gov/news/press-releases/attorney-general-kamala-d-harris-filed-motionintervene-lawsuit-seeking http://www.climateplan.org/wpcontent/uploads/2011/05/CA_AG_comments-to-SANDAG.pdf

Comment noted. SCAG has been monitoring the litigation related to the challenge of 

SANDAG's 2011 RTP/SCS and related PEIR since its inception. SCAG has taken into account 

the issues raised in the SANDAG litigation in developing the mitigation strategies in the 

2016 RTP/SCS and PEIR.

Submitted by Ventura County Air Pollution Control District Submittal 16257 Related Documents

16257.01 Table 1 FTIP Projects-Ventura County: The following Projects appear to be TCMs but are not 

on the Transportation Conformity Analysis Table 81 Ventura County TCMS Subject To 

Timely Implementation: VEN120403 Sidewalks longer than 1⁄4 mile, VEN141201 Bike lanes 

longer than 1 mile, VEN140804 Sidewalks longer than 1⁄4 mile, VEN140805 Bike lane 1 mile 

long, VEN130401 Bike lanes longer than 1 mile, VEN93017 Regional Rideshare Projects 

should be considered TCMs, VEN131001 Purchase more than 5 CNG Buses,

Comment noted. Project-specific responses are as follows: VEN120403 is not a committed 

TCM because no right-of-way or construction fund programmed in the first two years of 

the 2015 FTIP; VEN141201 is not a committed TCM because no right-of-way or 

construction fund programmed in the first two years of the 2015 FTIP; VEN140804 is 

included in the Table 81 (page 77); VEN140805 is not a committed TCM because no rightof-way or construction fund programmed in the first two years of the 2015 FTIP; 

VEN130401 is a Class III bike lane project and thus not a committed TCM per Final 2015 

FTIP Guidelines; VEN93017 is included in the Table 81 (page 77); and VEN131001 is a bus 

replacement project and thus not a committed TCM per Final 2015 FTIP Guidelines.

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16257.02 Summary of Regional Emissions Analysis for SCCAB Table 21: It is important to note that the 

RTP emission forecasts shown for both ROG and NOx are significantly lower than the motor 

vehicle emission (MVE) budgets from the February 27, 2008 Air Resources Board Early 

Progress Plans (EPP) submitted for the Ventura County portion of the South Central Coast 

Air Basin (SCCAB). The SCCAB EPP MVE budgets for 2009, found adequate by EPA on May 

20, 2008, for conformity purposes, were based on the older EMFAC 2007 model and 2008 

January SCAG motor vehicle activity. U.S. EPA did not take action on the Ventura County 

2007 State Implementation Plan (SIP) because of issues related to Reasonable Further 

Progress regulations. Thus, MVE budgets for milestone years in the 2007 SIP, could not be 

used for conformity purposes. The Ventura County Air Pollution Control District (District) is 

currently updating its Air Quality Management Plan that will include updated MVE budgets 

to adopt and submit to ARB for transmittal to U.S. EPA as the Ventura County portion of 

SCCAB SIP. We anticipate a narrower gap between the MVE Budgets and the RTP/SCS 

emission forecasts once the new MVE budgets are approved or found adequate for 

conformity purposes.

Comment noted.

16257.04 Transit and mobility in the SCAG Region: Table 4 shows a low percentage of transit trips, 

however, it is good to know that the bike trips, in terms of percentage of total trips, is the 

highest in the region. Transit buses with bike racks or bike storage are an important 

amenity to keep this positive trend in bike use growing in Ventura County. Table 5 shows 

that the journey to work in Ventura County by carpools, walking, transit buses, and bicycles 

were a bit better than the other counties, while working at home was above average. The 

District is committed to increasing or, at the very least, maintaining the use of alternative 

transportation modes other than solo driving during peak work-commute hours by 

continuing Rule 211-Transportation Outreach Program and supporting the efforts of the 

Ventura County Transportation Commission’s Rideshare Program.

Comment noted.

16257.05 2012 RTP/SCS Implementation and Developments between 2012-2016: We support the 

ongoing planning processes and efforts among the transit agencies and other stakeholders 

to more effectively deliver efficient transit services throughout Ventura County with the 

goal of increasing transit trips and reducing drive alone trips.

Comment noted.

Submitted by Ventura County Public Works Submittal 16369 Related Documents Link

16369.01 The intersection improvement project at Pleasant Valley Road and Fifth Street in Table 1 on 

Page 95 (VEN 130104) has a Total Project Cost (TPC) of $2.96 million (not $1.76 million).

Comment noted. The FTIP projects included within the RTP/SCS Project List incorporates 

the adopted 2015 FTIP and Amendments 1 – 7, and 12. Regarding FTIP ID# VEN130104, the 

project costs have been updated to $2.96 million through a subsequent amendment and 

will be reflected in the 2017 FTIP list of projects.

16369.02 lt is our understanding that bicycle lane and pedestrian improvement projects that are not 

specifically listed in the tables would be grouped in the Call for Projects listings in Table 2 

on Page 136 (RTP lDs 101007 and 101008). lf this is not true, then the following two (2) 

CMAQ and locally funded pedestrian/safe-routes-to school improvement projects in 

Camarillo Heights and El Rio should be added to the appropriate table. i. Camarillo Heights 

Elementary School Pedestrian lmprovements - TPC of $452,000. ii. Rio Real Elementary 

School Pedestrian lmprovements - TPC of $365,000.

The referenced call for project listings (RTP IDs 1O1007 and 1O1008) in Table 2 on Page 

136 of the Project List Appendix are not applicable for the Camarillo Heights Elementary 

School Pedestrian Improvements or the Rio Real Elementary School Pedestrian 

Improvements projects as these lump sums are specific to Los Angeles County. However, 

RTP ID 5O0703 (Page 320) may be applicable if confirmed by the Ventura County 

Transportation Commission. Additionally, RTP ID 7120004 would be applicable as it covers 

the entire SCAG region.

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16369.03 The following two (2) HSIP and locally funded road/bicycle improvement projects in Casitas 

Springs should be added to the appropriate table. i. Santa Ana Road Pavement Widening 

and Bike Lanes (MP 0.05 to MP 1.7) - TPC of $980,000. ii. Santa Ana Road Pavement 

Widening and Bike Lanes (MP 3.81 to MP 5.81) - TPC of $1.3 million.

Comment Noted. Most of the projects featured in the Plan's Project List Appendix were 

provided by the six County Transportation Commissions (CTCs), in which decisions to add 

projects must come through the CTCs in this case VCTC. Therefore, we suggest you work 

with VCTC towards incorporating the projects in a future RTP and/or RTP amendment.

16369.04 The following two (2) unfunded road improvement projects in the Oxnard Plain and Oxnard 

Beach Areas should be added to the appropriate table. i. Hueneme Road Widening Project - 

Rice Road to Las Posas Road - TPC of $22.34 million. ii. Harbor Boulevard Widening ProjectOxnard City Limits to Ventura City Limits - TPC of $58.7 million.

Comment Noted. Most of the projects featured in the Plan's Project List Appendix were 

provided by the six County Transportation Commissions (CTCs), in which decisions to add 

projects must come through the CTCs in this case VCTC. Therefore, we suggest you work 

with VCTC towards incorporating the projects in a future RTP and/or RTP amendment.

16369.05 The following two (2) projects are listed in two tables in Appendix B (Table l, Page 95; Table 

2,Page 319): i. Hueneme Road (VEN 011202 for $6.953 million ii. Pleasant Valley Road at 

Fifth Street (RTP lD 5A0709 / VEN 130104) for $1.76 million.

Comment Noted. Regarding VEN011202 and VEN130104, the reason the projects are listed 

within both the FTIP and financially constrained RTP portion of the Project List is because it 

is not fully programmed in the FTIP.

Submitted by Ventura Hillsides Conservancy Submittal 16344 Related Documents Link

16344.01 The 2012 RTP/SCS was an important stepping stone for the 2016 Plan. In previous Plans, 

natural lands and farmlands were handled under the banner of “land use.” In this new Plan, 

they are their own category. This is a great milestone in conservation planning for the 

region and SCAG. Additionally, the creation of a Natural and Farmlands Appendix provides 

important opportunities for SCAG that shouldn’t be overlooked. We believe the 

opportunity before you isn’t to “plan for” the future of open space in the region—as that’s 

what you’ve been doing since the 2012 Plan. Instead, we believe SCAG can now start 

“implementing” a regional conservation program. We strongly urge SCAG to take a more 

serious leadership role by actively seeking funding to implement conservation efforts by 

partnering with agencies, transportation commissions and non-profits to see that the Plan 

created in 2012 comes to fruition through the 2016 Plan. The One Bay Area Grant Program 

in Northern California is a program that we believe can be replicated in Southern California. 

We and other coalition members would gladly assist with this implementation effort.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16344.02 The current federal transportation bill, FAST Act, supports understanding transportation 

impacts on natural resources. The previous bill, MAP-21, supported restoring and 

maintaining environmental functions (i.e., wildlife corridors) affected by the infrastructure 

projects in the RTP. SCAG has even supported efforts in Los Angeles County to create a 

wildlife corridor over the 101 Freeway. Many efforts are underway across the region to 

connect landscapes to one another. This is very important to the region and its biodiversity. 

Wildlife corridors allow species to migrate and forage and expand genetic diversity. These 

corridors also allow ecosystems to maintain ecological functions, act as sources for 

repopulation after natural disasters such as fire, flood or landslide, and improve the 

resiliency in the face of climate change impacts. The Plan would be stronger if it supported 

the enhancement of and/or protection of documented and regionally significant wildlife 

corridors, especially those that are impacted by infrastructure projects.

Comment noted. The RTP/SCS describes (in Chapter 5) next steps for further developing a 

habitat conservation strategy. Included in the steps is the recommendation to provide 

“incentives for jurisdictions to cooperate across county lines to protect and restore natural 

habitat corridors, especially where corridors cross county boundaries.” The Natural/Farm 

Lands Appendix further supports wildlife corridors in its recommended policies, with the 

specific recommendation to “Encourage and facilitate research, programs and policies to 

identify, protect and restore natural habitat corridors, especially where corridors cross 

county boundaries. Additionally, continue support for preserving wildlife corridors and 

wildlife crossings to minimize the impact of transportation projects on wildlife species and 

habitat fragmentation.”

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Submitted by Ventura Hillsides Conservancy Submittal 16344 Related Documents Link

16344.03 SCAG focused many sections of the document on formal conservation plans, in the form of 

Natural Community Conservation Plans and Habitat Conservation Plans (NCCP/HCP), as the 

conservation method most identified by the agency. It is important to note that NCCP/HCP 

programs are only one conservation mechanism and they have limitations. For example, 

they are voluntary, property owner driven and generally only apply to larger land 

ownerships. Efforts underway by local, regional, state and federal agencies outside of these 

formal plans should not be discounted and must be included. Furthermore, many 

conservation organizations help facilitate, coordinate and find funding for land 

conservation transactions. We believe the conservation approach promoted by SCAG 

should include all of the ways land is protected, including those less regulated methods of 

conservation outside of NCCP/HCP programs.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation. Suggestions for strategies 

beyond HCPs and NCCPs will be encouraged and appreciated. Your group is encouraged to 

participate in the effort.

16344.04 Our organization supports the idea that as new growth occurs it should focus on the 

existing infill areas. This is consistent with the finding in the SCAG surveys where 

respondents preferred to see existing urban areas built upon before greenfields are 

targeted for development, especially those at the Wildland-Urban Interface. When 

developments are built in infill areas, it likely relieves pressure from the fringe. However, 

the Plan fails to outline exactly how (or with what mechanism) these fringe lands (or any 

lands) will actually be protected. Just because the pressure is relieved doesn’t mean the 

land then automatically becomes protected. Numerous organizations, ours included, focus 

their work on preservation of important habitat lands. A lot of time, energy, political will, 

strategy and other efforts combine to create a successful conservation transaction that 

leads to permanently conserved lands. SCAG must identify the mechanism, process or plan 

on how the greenfield lands will be protected.

Comment noted. In the coming years, SCAG will be working with local entities to assist in 

the cross-jurisdictional coordination of habitat conservation strategies. Your coalition is 

encouraged to participate in the effort.

16344.05 The Plan outlines that the region anticipates an additional 3.8 million people by 2040 

providing increased pressure on our existing parkland. Studies document that many 

communities in the Southern California region already do not have enough parkland as 

outlined by the Quimby Act (three acres per 1,000 residents). Throughout the document, 

the Plan promotes providing more access to these existing parks as infill projects are built, 

but nowhere does it state how additional parks will be created. The mechanism is missing. 

More importantly, these city parks are fundamentally different than habitat-focused parks. 

Usually city and regional parks include high intensity recreation oriented activities, like 

soccer and baseball fields, and are turfed. The types of land acquired as mitigation or 

through local conservation efforts typically are focused on preservation of natural habitat 

and less intensive uses (birding, hiking, etc.). In fact, many of these mitigation lands have 

limited or managed public access. Providing “more” access to either high or low intensity 

parks and/or habitat lands may have significant consequences for the land manager. The 

document needs to address the impacts to local parks with increased access from 

expanding populations. The document also needs to address how additional lands will be 

protected, i.e., what mechanism will be used?

Park accessibility is an integral part of sustainable communities as it improves public 

health, air quality, and quality of life. Providing parks within infill areas has a different set 

of challenges that varies by jurisdiction. SCAG encourages jurisdictions to look at funding 

sources, such as the California Department of Housing and Community Development 

(HCD) Housing-related Parks program, to help build and maintain local parks. The Housingrelated Parks program awards money to build and maintain parks based on the number of 

affordable housing units a jurisdiction has built, which can help increase park accessibility 

in traditionally underserved areas. SCAG will continue to provide jurisdictions information 

regarding funding opportunities and encourage jurisdictions to provide parks as part of 

their long-range plans. The term "Natural Lands" is used intentionally to differentiate 

between potentially sensitive habitat areas and urban/suburban parks that provide open 

space and active recreation. Specifically, "Natural Lands" refers to biologically diverse 

areas and landscapes that may provide ecosystem services, such as grasslands, wetlands, 

deserts, forests, shrublands, riparian areas, and other types of habitat lands. Natural Lands 

is not intended to include agricultural croplands, grazing/rangeland, other working lands, 

or municipal parks serving primarily recreational purposes.

231
holdID Comment Response 

Submitted by Ventura Hillsides Conservancy Submittal 16344 Related Documents Link

16344.06 Maps contained within the PEIR, RTP, SCS and Appendix should be internally consistent and 

they are not. For example, each map that shows “open space” or “protected lands” should 

be using the same base dataset but they do not. The 2012 Plan resulted in the creation of 

SCAG’s very own geographic information systems (GIS) dataset: the Natural Resource 

Inventory. It is more accurate than what is in the document now and it has been vetted by 

numerous organizations. That’s why it is surprising to see that so few of SCAG’s own GIS 

layers were actually used in the documents’ maps. We urge SCAG to honor its own work 

and that of its partner organizations by using this dataset as the basis for natural and 

farmland mapping. Let’s move forward with the same baseline information.

Commented noted. Each of the maps identified in the comment serve a distinct purpose 

and as such may reference a different data set to fully address its purpose. The various 

data sets each have their own set of constraints, not limited to richness of data and scale, 

which primarily explains the differences in mapping between PEIR and the RTP/SCS. Maps 

have been clarified to properly identify the purpose of the map and the specific data 

source.

Submitted by Western Riverside Council of Governments Submittal 16324 Related Documents Link

16324.01 WRCOG has two requests of SCAG pertaining to the Draft 2016 RTP/SCS which are intended 

to help maximize the impact of the final document and the resources that went into 

preparing the document. First, WRCOG asks that SCAG compile a distinct listing of all 

commitments explicitly made of SCAG and/or others in the document that could affect 

WRCOG and/or our member agencies. Several examples of these occurrences are listed 

below: (Page 70) The 2012 RTP/SCS discussed strategies to combat gentrification and 

displacement, a continuing challenge that we discussed in Chapter 3. Jurisdictions in the 

SCAG region should continue to be sensitive to the possibility of gentrification and work to 

employ strategies to mitigate its potential negative community impacts. WRCOG asks that 

commitments such as these be called out in a separate document and that SCAG denote an 

action plan to fulfill such commitments.

As part of its Environmental Justice Appendix, SCAG has put together an Environmental 

Justice Toolbox of possible mitigation measures to address potential impacts to 

Environmental Justice communities. On page 196 of the appendix, there is a list specifically 

for potential resources and strategies related to gentrification and displacement. Because 

many of these strategies concern local land use decisions, the toolbox strategies are 

voluntary but SCAG encourages communities to consider them as part of the local 

decisionmaking process.

16324.02 (text that follows copied/pasted for clarity) First, WRCOG asks that SCAG compile a distinct 

listing of all commitments explicitly made of SCAG and/or others in the document that 

could affect WRCOG and/or our member agencies. Several examples of these occurrences 

are listed below: (Page 88) To accommodate the growth in walking, biking and other forms 

of active transportation regionally, the 2016 Active Transportation Plan also considers new 

strategies and approaches beyond those proposed in 2012. Among them: • Better align 

active transportation investments with land use and transportation strategies to reduce 

costs and maximize mobility benefits: • Expand regional understanding of the role that 

short trips play in achieving RTP/SCS goals and performance objectives and provide a 

strategic framework to support local planning and project development geared toward 

serving these trips; and • Expand understanding and consideration of public health in the 

development of local plans and projects.  WRCOG asks that commitments such as these 

be called out in a separate document and that SCAG denote an action plan to fulfill such 

commitments.

The Plan Implementation section of the Active Transportation Appendix (Page 69) 

delineates actions or commitments SCAG will take in collaboration with local, subregional, 

state and federal partners to help implement the Active Transportation component of the 

2016 RTP/SCS. The Appendix also encourages local jurisdictions to incorporate active 

transportation into new road construction as well as maintenance. However, final 

implementation decisions are made by the local jurisdictions.

232
holdID Comment Response 

Submitted by Western Riverside Council of Governments Submittal 16324 Related Documents Link

16324.03 (text that follows copied/pasted for clarity) First, WRCOG asks that SCAG compile a distinct 

listing of all commitments explicitly made of SCAG and/or others in the document that 

could affect WRCOG and/or our member agencies. Several examples of these occurrences 

are listed below: (Page 111) Consistent with the provisions of Section 15091 of the State 

CEQA Guidelines and review of county and city general plans and Caltrans designated 

scenic vistas, aesthetics performance standards-based mitigation measures may include, 

but are not limited to: • Design landscaping along highway corridors to add significant 

natural elements and visual interest to soften the hard-edged, linear transportation 

corridors. • Remove blight or nuisances that compromise visual character or visual quality 

of project areas including graffiti abatement, trash removal, landscape management, 

maintenance of signage and billboards in good condition, and replacing compromised 

native vegetation and landscape. WRCOG asks that commitments such as these be called 

out in a separate document and that SCAG denote an action plan to fulfill such 

commitments.

Comment noted. The request that SCAG compile a distinct list of all commitments made of 

SCAG and/or others in the document that could affect WRCOG, such as MM-AES-3(b), in a 

separate document is fulfilled by the Mitigation Monitoring and Reporting Program 

(MMRP) in the Final PEIR. The MMRP providing a table that lists each impact, mitigation 

measure, the implementing agency, and the implementing date. West Riverside Council of 

Governments and/or its member agencies are identified as “Lead Agency” in the 

“Implementing Agency” column of the table for project-level mitigation measures, as SCAG 

has authority only for SCAG’s mitigation measures. For a complete discussion on the 

performance standards-based mitigation measures, please see Master Response No. 4 of 

the Responses to Comments in the Final PEIR.

16324.04 Second, in recognition of the extensive research and data collection efforts of SCAG to 

prepare the document, WRCOG requests that all data be made publicly accessible. Further, 

WRCOG requests that SCAG widely promote the availability of the data, particularly among 

jurisdictions within the region, to ensure the information’s use and ongoing benefit to the 

region.

Comment noted. Data will be made available to local jurisdictions upon request. Data at 

the smaller geographic levels below the local jurisdiction level is only advisory - the 

RTP/SCS will be adopted utilizing local jurisdiction level data.

Submitted by XpressWest Submittal 16320 Related Documents Link

16320.01 Although XpressWest is included as a Strategic Plan project, request adding a discussion of 

the XpressWest project in the passenger rail section of the RTP since it is a federally 

licensed interstate passenger railroad that will be interoperable with the California High 

Speed Rail system and interface with Metrolink at Palmdale.

Comment noted. Strategic Plan projects are discussed in Chapter 9 of the RTP/SCS 

document. The XpressWest project is also discussed in detail in the Unserved Markets and 

Strategic Plan sections of the Passenger Rail appendix. The High-Speed Rail sections in the 

RTP/SCS and Passenger Rail appendix focus on the CA HST Phase One project which is a 

fiscally constrained project of the 2016 RTP/SCS.

233
holdID Comment Response 

Submitted by XpressWest Submittal 16320 Related Documents Link

16320.02 Existing text: In addition to the California High-Speed Train system, our region has other 

important high-speed rail projects in development. XpressWest is a high-speed rail service 

that will connect Victorville and Las Vegas along the I-15 corridor and connect via the High 

Desert Corridor to Palmdale and California High-Speed Train Phase One. It will use “steel 

wheel on steel rail” technology, with electrical propulsion to speeds of up to 150 miles per 

hour (mph). That would result in a trip between Victorville and Las Vegas lasting only 80 

minutes. XpressWest has secured federal environmental reviews and in September 2015, 

China Railway International and XpressWest entered into a $100 million agreement to 

implement the project. XpressWest continues to seek additional funding and required 

regulatory approvals. Modify to read: In addition to the California High-Speed Train system, 

our region has other important high-speed rail projects in development. XpressWest is a 

high-speed rail service that will connect Victorville and Las Vegas along the I-15 corridor 

and connect via the High Desert Corridor to Palmdale and California High-Speed Train 

Phase One. It will use “steel wheel on steel rail” electric multiple unit train technology, at 

speeds of up to 150 miles per hour (mph). That would result in a trip between Victorville 

and Las Vegas lasting only 80 minutes. XpressWest has secured federal environmental 

Records of Decision and authorization to construct and operate. In November 2015, 

XpressWest was awarded the franchise to construct and operate high speed rail service 

between Southern California and Las Vegas by the Nevada High Speed Rail Authority.

Comment noted. This comment has been incorporated into the Passenger Rail Appendix.

16320.03 Request adding a discussion of XpressWest in the High Speed Rail section. Comment noted. The XpressWest project is discussed in detail in the Unserved Markets 

and Strategic Plan sections of the Passenger Rail appendix. The High-Speed Rail section of 

the appendix focuses on the CA HST Phase One project which is a financially constrained 

project of the 2016 RTP/SCS.

234
holdID Comment Response 

Submitted by XpressWest Submittal 16320 Related Documents Link

16320.04 Existing text: "Passenger service was last provided between Los Angeles and Las Vegas by 

Amtrak on its Desert Wind interstate service that ceased operations in 1997. Currently, 

XpressWest is a high-speed rail service under development connecting Victorville and Las 

Vegas along the current I-15 corridor. It will use steel wheel on steel rail technology with 

electrical propulsion operating at speeds of up to 150 mph to make the trip between 

Victorville and Las Vegas in 80 minutes. The tracks will largely be within I-15’s ROW. It will 

run daily, with peak departures up to every 20 minutes. XpressWest estimates 5 million 

passengers during its first year of operation with one-way fares of $50.00 and round-trip 

fares of $89.00. XpressWest has been completely permitted since 2011. XpressWest had 

applied for a $5.5 billion loan through FRA’s Railroad Rehabilitation & Improvement 

Financing program, however the loan was indefinitely suspended in July 2013 due to the 

failure of the application to meet the federal “Buy America” policy. It is estimated to cost 

$6.9 billion, with $1.4 billion coming from private investors." Modify to read: "Passenger 

service was last provided between Los Angeles and Las Vegas by Amtrak on its Desert Wind 

interstate service that ceased operations in 1997. Currently, XpressWest is a high-speed rail 

service under development connecting Victorville and Las Vegas along the current I-15 

corridor. It will use steel wheel on steel rail electric multiple unit train technology operating 

at speeds of up to 150 mph to make the trip between Victorville and Las Vegas in 80 

minutes. The tracks will largely be within the I-15 ROW. It will run daily, with peak 

departures up to every 20 minutes. XpressWest has been completely permitted since 2012. 

XpressWest had applied for a loan through FRA’s Railroad Rehabilitation & Improvement 

Financing program, however the loan was indefinitely suspended in July 2013 due to the 

failure of the application to meet the federal “Buy America” policy. In November, 2015, 

XpressWest was awarded the franchise to construct and operate high speed rail service 

between Southern California and Las Vegas by the Nevada High Speed Rail Authority."

Comment noted. This comment has been incorporated into the Passenger Rail Appendix.

16320.05 Suggest inserting the map from the FRA Southwest Multi-State Planning Study that 

identifies the Core Express Service corridors.

Comment noted. The Core Express Service corridors in the SCAG region are discussed on p. 

20 of the Passenger Rail appendix.

235
holdID Comment Response 

Submitted by XpressWest Submittal 16320 Related Documents Link

16320.06 Existing text: "The XpressWest would connect Las Vegas to Victorville using steel wheel on 

steel rail technology with a top speed of 150 mph. There are no intermediate stops 

between Victorville and Las Vegas and the running time is estimated to be approximately 

80 minutes. The project has completed the environmental process and the FRA issued a 

record of decision (ROD) on July 8, 2011. XpressWest Enterprises had applied to the FRA’s 

Railroad Rehabilitation Improvement Financing (RRIF) program for a loan to start and 

complete construction of the project however the loan application was denied in 2013 due 

to the application not meeting Buy America requirements. In addition to the RRIF loan, 

private debt and equity are expected be included in the project financing. In September 

2015, China Railway International and XpressWest entered in to a $100 million agreement 

to begin construction on the project. Phase Two of this project would connect Victorville to 

Palmdale along the High-Desert Corridor, thereby providing a connection with the CA HSR 

system and the Metrolink Antelope Valley Line. Phase Two was not included in 

XpressWest’s environmental process, nor was it part of their FRA loan application." Modify 

to read: “The XpressWest would connect Las Vegas to Victorville using steel wheel on steel 

rail technology with a top speed of 150 mph. There are no intermediate stops between 

Victorville and Las Vegas and the running time is estimated to be approximately 80 

minutes. The project has completed the environmental process with the Records of 

Decision from the Federal Railroad Administration, Bureau of Land Management, Federal 

Highway Administration, and Certificate of Public Convenience and Necessity issued by the 

Surface Transportation Board. XpressWest had applied to the FRA’s Railroad Rehabilitation 

Improvement Financing (RRIF) program for a loan to start and complete construction of the 

project however the loan application was suspended in 2013 due to the application not 

meeting Buy America requirements. Phase Two of this project would connect Victorville to 

Palmdale along the High-Desert Corridor, thereby providing a connection with the CA HSR 

system and the Metrolink Antelope Valley Line. Phase Two was not included in 

XpressWest’s environmental process, nor was it part of their FRA loan application. In 

November, 2015, XpressWest was awarded the franchise to construct and operate high 

speed rail service between Southern California and Las Vegas by the Nevada High Speed 

Rail Authority.”

Comment noted. This comment has been incorporated into the Passenger Rail Appendix.

Submitted by 5-Cities Alliance Submittal 16339 Related Documents Link

16339.01 Because the SR-710 North Project is flawed and unnecessary and because the RTP/SCS PEIR 

fails to adequately disclose or mitigate the environmental impacts from this Project, the 5-

Cities Alliance respectfully requests that SCAG eliminate the Project from the 2016 RTP/SCS 

(including the transportation model and project list).

Comment Noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description and associated modeling analysis.

236
holdID Comment Response 

Submitted by 5-Cities Alliance Submittal 16339 Related Documents Link

16339.02 In any event, SCAG should eliminate the SR-710 North Project from the RTP/SCS. Comment noted. The 710 project is included in the voter-approved Measure R sales tax 

measure and in Metro's Long Range Transportation Plan, as well as in previous SCAG RTPs. 

SCAG understands that a project specific environmental analysis is underway by the lead 

agency, which will consider project impacts including environmental and traffic and 

mobility impacts, and identify mitigation measures as required. Upon the completion of 

this effort and selection of a preferred alternative by Metro, SCAG will work with Metro to 

amend the RTP as necessary to update the project description and associated modeling 

analysis.

16339.03 The Freeway Tunnel Alternative would further impede the RTP/SCS’s goals for sustainability 

because it would increase highway capacity, vehicle miles traveled (“VMT”) and induce 

travel. According to Nelson Nygaard, the reduction of VMT per capita is the most important 

metric for sustainability because it identifies a shift from dependence on personal vehicles 

and a reduction of stress on the region’s congested arterial and highway networks. See 

Nelson Nygaard Report at 2. Conversely, any increase in highway capacity, such as that 

which would occur with the Freeway Tunnel Alternative, will increase VMT because it 

would induce travel.

Comment noted.

16339.04 In the event that SCAG does not eliminate the SR-710 North Project from the RTP/SCS 

altogether, as the 5-Cities Alliance recommends, it must revise the RTP/SCS (and the PEIR’s 

Project Description) to give equal weight to each SR-710 North Project alternative.

Comment noted. The 710 project is included in the voter-approved Measure R sales tax 

measure and in Metro's Long Range Transportation Plan, as well as in previous SCAG RTPs. 

SCAG understands that a project specific environmental analysis is underway by the lead 

agency, which will consider project impacts including environmental and traffic and 

mobility impacts, and identify mitigation measures as required. Upon the completion of 

this effort and selection of a preferred alternative by Metro, SCAG will work with Metro to 

amend the RTP as necessary to update the project description and associated modeling 

analysis.

16339.05 In summary, the 5-Cities Alliance respectfully requests that SCAG eliminate the SR-710 

North Project from the 2016 RTP/SCS. First, the Freeway Tunnel Alternative is flawed and 

unnecessary, failing to provide a real solution to the region’s transportation needs. Second, 

the Freeway Tunnel would be inconsistent with the RTP/SCS’s goal that transportation 

projects be sustainable and environmentally protective. Third, there are viable alternatives 

to the Freeway Tunnel that improve mobility and expand transportation options while 

limiting dependence on personal vehicles.

Comment noted. The 710 project is included in the voter-approved Measure R sales tax 

measure and in Metro's Long Range Transportation Plan, as well as in previous SCAG RTPs. 

SCAG understands that a project specific environmental analysis is underway by the lead 

agency, which will consider project impacts including environmental and traffic and 

mobility impacts, and identify mitigation measures as required. Upon the completion of 

this effort and selection of a preferred alternative by Metro, SCAG will work with Metro to 

amend the RTP as necessary to update the project description and associated modeling 

analysis.

237
holdID Comment Response 

Submitted by Assael, Margarita Submittal 16056 Related Documents

16056.01 Why are you so excited to change this country to a COMMUNIST country?????? I am an 

AMERICAN and no one is going to get me out of MY CAR!!!!!!!!!!!!! I live in a FREE country 

and I cannot believe that this is your agenda: To push us into COMMUNES; make me give 

up my car; track where and how much I drive. I am NOT going to RIDE a BIKE or take the 

BUS!!!! Leave us alone!!!!!!!!!! You are not in CHARGE of us!!!!!!!!!!!!!!!!!!!!

Comment noted. The 2016 RTP/SCS will not change how everyone chooses to get around 

the region, but the Plan is designed to offer residents more choices so that we can 

experience regionwide benefits, such as improved air quality. The Plan will provide people 

with more options for transportation and mobility, offering numerous alternatives to 

driving alone. This will be accomplished by enhancing public transit capacity and increasing 

its viability by making it more accessible; completing critical road connections; providing 

greater opportunities for biking and walking, particularly for short trips; exploring how 

people might use alternative fuel vehicles within their neighborhoods and beyond; 

incentivizing telecommuting and flexible work schedules; encouraging new mobility 

innovations; and improving safety. In addition, Transportation Demand Management 

(TDM) strategies will help us better manage the demand we place on the roadway 

network by reducing the number of people who drive alone and encouraging them to use 

alternative modes of travel. At the same time there is nothing in the plan that will take 

away anyone's right to drive their private vehicles.

Submitted by Ayala, Enrique Submittal 16050 Related Documents

16050.01 Metrolink is a better service than Amtrak cause Amtrak is way to expensive Comment noted. Metrolink operates commuter rail service involving relatively shorter trip 

distances than Amtrak and more frequent riders. Amtrak operates interstate and 

interregional services involving longer trip distances than commuter rail, thus having 

higher operating costs and higher fares to cover those costs. Therefore, when both Amtrak 

and Metrolink operate between the same stations, Amtrak's fare is required to be higher 

than Metrolink.

Submitted by Bautista, Fabricio Submittal 16209 Related Documents

16209.01 I wonder What is the possibility of a creating of an on/off ramp on the I-10, between Sierra 

Avenue and Alder Ave. There is a 2 mile gap in between both exits and the traffic on both is 

heavy at peak times. Specially on Alder Avenue, since the bridge has not been 

reconditioned.

Comment noted. A proposed interchange on I-10 at Alder Avenue is included within the 

Project List appendix please refer to RTP ID# 4120200.

238
holdID Comment Response 

Submitted by Boddula, Keshav Submittal 16141 Related Documents Link

16141.01 There are different tendencies, or natures, of people including tendencies to control Nature 

more. This nature seems to have lead to mechanistic processes toward the best, quality 

products, which is then reproduced and made efficient; then strategically scaled and 

streamlined in an economic growth sense. This dominant activity has then been implicitly 

understood as akin to the following for various people (for examples): value (businessmen), 

“success” or how to improve our G.D.P./“Economy” (politicians), desirable activity or goals 

(the majority of the population who unsalmonly take the path of least resistance to make a 

living and survive). Perhaps in a similar way to SCAGs' acknowledgment that “compact 

communities are not for everyone”, also it may be balancingly helpful to consider the 

following unconventional2 hypothesis: natural flows of our environment's “basic” elements 

(earth, water, fire, air) more undesirably flow (i.e. the phenomena of “climate change”) in 

accord with the amount of “impact” of human-produced machines/computers have in that 

environment. Generally, I see this greater impact machines/computers have on humans 

and our thinking about our environment and our relationship to it in a longer context of 

History/Time, and thus more as an ephemeral fad that will wean in the generally near 

future from the currently greater emphasis on static, human/machine-controlled processes 

of life, to more dynamic, natural flows of life. This insight may be helpful in considering “a 

growing population with shifting priorities and desires”. Rather than being “prepared to 

confront and cope with the inevitable consequences of climate change (more 

downstream)”, let's shift more upstream by recognizing symptoms and causes of our 

degraded environment to then prevent the imbalanced impacts of unnatural, machine-like 

processes to begin with (similar to that traditional, more downstream “biomedical” 

approach vs. a smarter, more upstream “human systems” approach to health and 

wellness.) After a “deeper understanding of all contextual elements beginning with 

watershed and ending with architectural detail,” developmend with Nature/ecologically.

Comment noted. The SCAG 2016 RTP/SCS supports a balance between "upstream" and 

"downstream" strategies as you have referred to them. Upstream strategies include 

policies such as encouraging sustainable land use patterns that reduce resource 

consumption, and integrating transportation, energy, and water infrastructure. 

Downstream strategies include facilitating climate adaptation studies, and efforts to 

incentivize short to mid-term locational and transportation behavior choices. As noted it is 

important to remember that SCAG values local control and works with all of its member 

jurisdictions as well as public and private partners to achieve a long term vision of a 

sustainable region.

Submitted by Butler, Lana Submittal 16125 Related Documents

16125.01 You are aN UNELECTED, hughly funded organiization trying to mandate us out of our cars. I 

oppose your views and all your tactics to do this.

Comment noted. SCAG’s is governed by an 86-member Regional Council, which is 

comprised of duly elected Mayors, City Council Members and County Supervisors from 

jurisdictions throughout the SCAG region. These elected officials meet monthly as 

members of SCAG’s Regional Council and Policy Committees, and they have discussed the 

proposed Draft 2016 RTP/SCS at regular and special meetings and will consider the Final 

Plan for adoption at their April 7, 2016 meeting. The roster of Regional Council members 

can be found on SCAG's website at http://scag.ca.gov. The 2016 RTP/SCS will not change 

how everyone chooses to get around the region, but the Plan is designed to offer residents 

more choices so that we can experience regionwide benefits, such as improved air quality. 

The Plan will provide people with more options for transportation and mobility, such as 

transit, walking, and bicycling.

239
holdID Comment Response 

Submitted by Cahn, Michael Submittal 16021 Related Documents Link

16021.01 on table 12 d2016RTPSCS_ActiveTransportation.pdf some additions and % look a bit odd: 

Education and Encouragement Strategy $1.1 Billion 2% I think the total would be more like 

8 % and also, the 8 million for education campaigns looks oddly low on page 50 under LA 

County #5 talk is about "Extend the pedestrian/bicycle path from Washington Street to the 

north jetty of Marina Del Rey and support the seasonal ferry service for pedestrians and 

cyclists across the channel to Playa del Rey." apart from a little lack of logic of del / Del 

capitalization, I think the road is properly called Washington Blvd, not Street BTW the same 

error occurs in http://www.wearemdr.com/bm~doc/marina-del-rey_major-lipamendment.pdf under # 22.46.1050, but it has been corrected on page 25 of that 

document. Anyhow, where is all these billions coming from? and how does it compare with 

money for motor infrastructure?

The referenced Table 12 has been corrected. $8 million is for education campaigns as 

explained in the text. Safe Routes to School which includes both education and 

engineering totals $280 million. Combined, the Education and Encouragement Strategy 

totals $288 million. On Page 50, Washington Street has been changed to Washington Blvd. 

The county transportation commissions in the SCAG region submitted approximately $1.7 

billion worth of capital costs for active transportation investments (exclusively—not 

accounting for portions of larger multi-modal projects that include active transportation 

elements). The Plan includes approximately $6.4 billion in capital costs, which includes the 

State Active Transportation Program which funds Safe Routes to School and capital active 

transportation projects. In addition, the Plan notes that $4.8 billion in Regionally 

Significant Local Streets and Roads Operations and Maintenance is associated with active 

transportation expenditures, such as sidewalk repair. These expenditures are funded in 

the plan through short-term gas tax increase and long-term transition to mileage-based 

user fees. Combined, these expenditures total $12.9 billion for active transportation 

investments. This represents 2.3% of the plan.

Submitted by Capps, Tressy Submittal 16303 Related Documents Link

16303.01 As a member of TOLL Free IE in San Bernardino County I can tell you that the public 

outreach for the TOLL lane project is just as bogus as SCAG's public outreach for this plan. 

The public is clueless and that is by design. The way SANBAG votes on the project without 

each member city getting input from the other council members or the community is 

fraudulent and criminal in nature. The way SCAG has conducted the public outreach on the 

plan is scandalous and demands an investigation. I attended all 4 public hearings and there 

was no real engagement. At one of the public hearings, the Riverside office did not even 

attend. What happened there and how do you plan on correcting that situation?

Comment noted. SCAG has provided significant opportunities for input to the Draft 2016 

RTP/SCS. This included, but was not limited to, the SCAG RTP/SCS website, policy 

committee meetings, a series of twenty-three open houses held during Summer 2015, and 

nineteen additional workshops and public hearings held following the release of the Draft 

2016 RTP/SCS. As required by law, SCAG provided advance notice of public hearings on the 

Draft 2016 RTP/SCS, including publication in newspapers throughout the region, to give as 

many interested parties as possible the opportunity to attend and provide input. These 

hearings and workshops were held in every county in the region to solicit input from 

various interests such as residents, elected officials, representatives of public agencies, 

community organizations, and environmental, housing and business stakeholders. To 

provide greater time accommodations, SCAG held public hearings in the evenings, 

weekend, as well as weekdays. In reference to the public hearing at the Riverside office on 

Tuesday, Jan. 12, SCAG is required to hold three (3) public hearings on the Draft 2016 

RTP/SCS. In order to ensure many additional opportunities to participate, SCAG hosted 

four (4) public hearings, three (3) of which were video-conferenced to satellite locations. In 

total, this strategy provided 17 opportunities for the public to participate at the Public 

Hearings, significantly exceeding our statutory requirements. At the January 12, 2016 

Public Hearing, the Riverside County office hosting the video-conference opened 30 

minutes after the scheduled start time. It was confirmed that one person attempted to 

participate during this time frame. This person participated at the subsequent January 13, 

2016 Elected Officials’ Briefing and provided testimony.

16303.02 Shame on all for you for the way you are top down conducting this process all the while 

engaging in your bogus outreach that only the stakeholders participate in.

Comment noted. SCAG will consider this comment in assessing its outreach activities.

240
holdID Comment Response 

Submitted by Capps, Tressy Submittal 16303 Related Documents Link

16303.03 Regional government is unconstitutional and SCAG needs to be abolished. 50 years and the 

public is weary of these schemes that serve only to line the pockets of your stakeholders 

and does very little to actually facilitate traffic movement. Hasan Ikhrata may have been a 

planner in the Soviet Union but his methods are not welcome here in the United States. 

Americans do not need to be coordinated. Hasan needs to stop running around Southern 

California using false statistics and population data in an effort to deceive the public and 

swindle taxpayers.

Comment noted.

16303.04 I testified regarding the plan at 3 of the 4 public hearings and want a transcript of my 

statements to ensure they are part of the report.

Comment noted. Any verbal comments made at public hearings were recorded by a court 

reporter and submitted as formal comments. Your comments have been reflected in the 

final summary of comments.

Submitted by Capps, Tressy Submittal 16350 Related Documents

16350.01 I think that plan -- I don't like the plan. I think what you are attempting to do is to transform 

the West Coast into the East Coast and, I think, it would be a lot easier if people want to 

live like that back and pack and bikes and buses, if people want to live like that they could 

just move to the East Coast or they can move to Europe. But to try to transform the West 

Coast and to try to get people out of their cars is an exercise in futility and you're wasting a 

half a trillion tax dollars doing things that people don't want. And I have an article right 

here from the Wall Street Journal, "Car sales still have room to grow" this is the January 

4th, "Cars are selling like crazy." The West Coast people love their cars. But you've done 

this whole plan and it is based on a fantasy that people will somehow leave their cars and 

share bikes and take a train. And a good example of the whole train concept not working is 

ARTIC in Anaheim that place is deserted and, now, Anaheim the City of Anaheim is going to 

be left holding the bag on that. So, you know, I realize you guys have these ideas, but they 

are concepts that aren't based on reality.

Comment noted.

16350.02 And so, instead of for tax payers because as you can see from this meeting there is nobody 

from the public here it's just SCAG's staff and stakeholders and myself and there is a few 

people who have figured out what is going on with the vehicle mileage tax and toll lanes. 

What you are going to do is you're trying to price people out of their cars so the only choice 

they have is to use public transit because they are not going to be able to afford driving 

their cars which is what they like to do now.

Comment noted. All formal comments received have been responded to and will be 

presented to SCAG policymakers to be considered as part of the final RTP/SCS. The 

projected revenue from the mileage-based user fee and adjustments to state and federal 

gas excises taxes are equivalent to the what existing state and federal excise taxes would 

generate had they been indexed for inflation when last adjusted more than two decades 

ago. An analysis of the economic impacts of the Plan is provided in Chapter 7 and the 

Economic and Job Creation Analysis Appendix. Additionally, a comprehensive analysis of 

the California Road Charge Pilot Program will be available no later than June 30, 2018 in 

accordance with SB 1077. The 2016 RTP/SCS does not assume revenue from a mileagebased user fee prior to 2025. Regarding the mileage-based user fee, we agree that 

additional work is needed including but not limited to potential phasing, governance, 

accountability and approaches for protecting privacy as well as addressing income and 

geographic (e.g., urban vs. rural) equity impacts before the mileage-based user fee (or 

road charge) would become effective—which why the Plan does not assume revenues 

from this source before 2025. SCAG, in collaboration with local, regional, state and federal 

stakeholders, will continue to actively participate in efforts to make transportation funding 

more sustainable in the long run.

241
holdID Comment Response 

Submitted by Capps, Tressy Submittal 16350 Related Documents

16350.03 And you have Hasan Ikhrata running around saying that millennials do not want to drive 

cars that they do not want to get their driver's licenses and that is just a flat out lie.

Comment noted.

16350.04 Now, this thing the Constitution of The United States, perhaps, you guys should brush up 

on it because what SCAG is is regional government, it's shadow government and this is 

not -- when the Founding Fathers established our Nation Regional Government is not what 

they had in mind. And this is how you people -- you should all be ashamed of yourself what 

you're participating in. You are all a bunch of traitors and I can't even understand why this 

is allowed to go on.

Comment noted. SCAG’s is governed by an 86-member Regional Council, which is 

comprised of duly elected Mayors, City Council Members and County Supervisors from 

jurisdictions throughout the SCAG region. These elected officials meet monthly as 

members of SCAG’s Regional Council and Policy Committees, and they have discussed the 

proposed Draft 2016 RTP/SCS at regular and special meetings and will consider the Final 

Plan for adoption at their April 7, 2016 meeting. The roster of Regional Council members 

can be found on SCAG's website at http://scag.ca.gov.

16350.05 And as far as the review period for this plan that is so big to have it be two months of time, 

you did it in December and January so right in the holidays. There is no way that the public 

can – even knows about this plan much less can review all of those pages. I doubt any of 

you have even read that whole thing so to -- minimally, you need to give -- you need to do 

real outreach.

Comment noted. SCAG has provided significant opportunities for input to the Draft 2016 

RTP/SCS. This included, but was not limited to, the SCAG RTP/SCS website, policy 

committee meetings, a series of twenty-three open houses held during Summer 2015, and 

nineteen additional workshops and public hearings held following the release of the Draft 

2016 RTP/SCS. Details on the outreach performed, including presentations at 

organizational meetings, email campaigns, community events and flyer distributions and 

media outreach, are highlighted in the Public Participation and Consultation Appendix.

16350.06 You know, if people really knew what you were planning with vehicle mileage tax and toll 

lanes they'd be protesting in the streets. But they don't have a clue because this outreach 

that you are doing is completely bogus and, again, you should all be completely ashamed of 

yourself.

Comment noted. All formal comments received have been responded to and will be 

presented to SCAG policymakers to be considered as part of the final RTP/SCS. The 

projected revenue from the mileage-based user fee and adjustments to state and federal 

gas excises taxes are equivalent to the what existing state and federal excise taxes would 

generate had they been indexed for inflation when last adjusted more than two decades 

ago. An analysis of the economic impacts of the Plan is provided in Chapter 7 and the 

Economic and Job Creation Analysis Appendix. Additionally, a comprehensive analysis of 

the California Road Charge Pilot Program will be available no later than June 30, 2018 in 

accordance with SB 1077. The 2016 RTP/SCS does not assume revenue from a mileagebased user fee prior to 2025. Regarding the mileage-based user fee, we agree that 

additional work is needed including but not limited to potential phasing, governance, 

accountability and approaches for protecting privacy as well as addressing income and 

geographic (e.g., urban vs. rural) equity impacts before the mileage-based user fee (or 

road charge) would become effective—which why the Plan does not assume revenues 

from this source before 2025. SCAG, in collaboration with local, regional, state and federal 

stakeholders, will continue to actively participate in efforts to make transportation funding 

more sustainable in the long run.

242
holdID Comment Response 

Submitted by Capps, Tressy Submittal 16353 Related Documents

16353.01 I do agree with things that were said today about natural gas. I, actually, drive a natural gas 

vehicle and I've been. So, I know that here at SANBAG we're developing this Redlands Rail 

and I don't think those are natural gas. I don't think that train is going to be natural gas. 

Anyways, I think that natural gas is a good technology and it is clean so I would fully 

support anything like that that would actually be a solution versus some of the things that 

are in this plan that are somewhat ridiculous and so I'll go through some my thoughts 

about that.

Comment noted. Locomotive propulsion systems decisions are the responsibility of 

Amtrak, Metrolink and the freight railroads in our region. Notably, Metrolink is moving to 

an all Tier 4 locomotive fleet in the next few years. These locomotives are over 85% 

cleaner than Metrolink's oldest locomotives that are still in operation. SCAG is cognizant of 

the need to incorporate evolving technologies with plans for new infrastructure. These 

include technologies to fuel vehicles, as well as to charge batteries and provide power. 

Chapter 5 of the RTP/SCS discusses a regional strategy for deployment of commercially 

available low-emission locomotives while advancing technologies toward phased 

implementation of zero- and near-zero emission systems.

16353.03 I have an article here that just was in the paper yesterday. It was written by Thomas Elias 

and it's entitled -- the Commentary it's entitled Worst Bottleneck Stalled Traffic In Spite of 

Nearby Transit Lines. And it's a very well written commentary and it makes the point that 

"One lesson here, then, is that mass transit doesn't solve all congestion." Just look at the 10 

between Downtown Los Angeles and the City of West Side where commuters sit and wait 

while trains dis-unmolested [sic] along the almost parallel mostly completed Metro Express 

Line. So, I think, the problem I have with this plan is that it is an exercise in a fantasy. SCAG 

is assuming, assuming, that people are going to abandon their cars and they're going to 

take public transit, and it's just not going to happen, like I spoke about before.

Public transportation is an important part of a suite of mobility solutions. It provides an 

important alternative to driving, and is a necessary lifeline for those who cannot provide 

their own mobility. The 2016 RTP/SCS contains a wide variety of strategies, tailored to 

meet the needs of a variety of communities, jurisdictions, subregions, and the region as a 

whole. Public transportation is one of those solutions.

16353.04 And so, now, I've got -- I've been examining the plan, I have some specific comments about 

that. First of all, you start out the plan with this picture here, as you can see there is no 

cars. So, clearly, the gist of this plan is to get people out of their cars for their health or, 

however, you want to justify it. The next big picture that I wanted to show is this picture of 

this bus tying up traffic in Los Angeles and I've, actually, videotaped down by the SCAG 

office this exact same area. So, what is going on is a bunch of empty buses are running 

around Downtown L.A. an they're actually I don't think those buses are solving much of 

anything other than creating traffic. Some buses are necessary but a lot of the lines are 

empty and we've documented that on videotape. Okay, my next comment is about trains. 

So, here you've got the train and all these happy people, that's nice that works in some 

places the East Coast, perhaps. It is not going to work here on the West Coast and my 

example for that is ARTIC and that was a SCAG boom-dawdle that cost a bunch of money 

and Anaheim will be paying for that for a very long time. And if anyone wants to go check 

that out that big snow globe on the side of the 57 Freeway, no one is using and it is a 

complete failure and that was SCAG's bright idea. Good job at bombing.

Public transportation is an important part of a suite of mobility solutions. It provides an 

important alternative to driving, and is a necessary lifeline for those who cannot provide 

their own mobility. The 2016 RTP/SCS contains a wide variety of strategies, tailored to 

meet the needs of a variety of communities, jurisdictions, subregions, and the region as a 

whole. Public transportation is one of those solutions. Transit vehicles operate at a variety 

of passenger loads throughout the region, and throughout the day. In FY2011-12, 

residents of the region took 710 million transit trips, during 19 million hours of transit 

service. The project sponsor and implementing agency for the Anaheim Regional 

Transportation Intermodal Center was the City of Anaheim. SCAG does not engage in 

capital construction. And, while ARTIC may not be operating at capacity today, it was built 

partly to accommodate the future, which includes full operation of the California High 

Speed Train by 2029.

16353.05 So SCAG imagines that everybody is going to get on a bike and Hasan claims that 

millennials, I brought my little Minion here millennials, that they like to travel in packs on 

bikes to the movies. Now, I have never witnessed this phenomena anywhere so, maybe, if I 

saw a video of it, you know, I mean here in the Inland Empire my niece goes to Etiwanda 

High School and I see all the young kids driving their cars to school or their parents are 

driving them to school or they come on the bus. But I do not see a lot of people on bikes, 

there is a lot of traffic, it would be very dangerous and they'd probably end up at Stanley if 

they were to take a bike so.

Comment Noted. Active transportation is part of a multi-modal transportation plan

243
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Submitted by Capps, Tressy Submittal 16353 Related Documents

16353.06 So, anyways, so again natural gas sounds like a good solution, I don't know if that is 

somewhere here in the plan, but the parts of the plan that I have seen involve, like I said, 

pricing people out of their cars and so they plan on using -- doing that through a series of 

things. Toll lanes is one of the ways that SCAG wants to price people out of their cars. 

Another way that SCAG plans to do that is vehicle mileage tax and that is just going to be 

tea bagging the people in California. I'm not sure if you guys have noticed but in other 

states gas is like 80 cents a gallon but here in California we're still paying 2-something a 

gallon, I don't know because I drive a natural gas car, but I know it's not anywhere close to 

80 cents a gallon. So, here you just want to tax, tax, tax us so -- or SCAG does, so that we 

have -- Hasan will tell you it's so we have choices. But I will tell you, my opinion, it is to 

make sure that people are priced out of their cars and forced to these choices and, I think, 

that that is wrong. So, let see what else.

Gas tax revenues, in real terms, are actually in decline as tax rates (both state and federal) 

have not been adjusted in more than two decades while the number of more fuel efficient 

and alternative powered vehicles continue to grow. The Plan identifies several new 

funding sources that are reasonably expected to be available and are included in the 

financially constrained plan. These sources include adjustments to existing state and 

federal gas tax rates and a long-term replacement of state and federal gas taxes with a 

mileage-based user fee to maintain the historical purchasing power of the gas tax.

16353.07 So, again, it is a fantasy to envision that people are going to be biking around. It sounds like 

a third world country not anywhere I want to live and so, I think, this plan is awful, I think 

the outreach is completely bogus and fake.

Comment noted.

16353.08 At the last public hearing Riverside didn't even show up so I don't know how you are going 

to address that, but I would say that that last public hearing you had is invalidated [sic] 

because the Riverside County Office wasn't even participating so you better do that public 

hearing over again is my suggestion.

SCAG is required to hold three (3) public hearings on the Draft 2016 RTP/SCS. In order to 

ensure many additional opportunities to participate, SCAG hosted four (4) public hearings, 

three (3) of which were video-conferenced to satellite locations. In total, this strategy 

provided 17 opportunities for the public to participate at the Public Hearings, significantly 

exceeding our statutory requirements. At the January 12, 2016 Public Hearing, the 

Riverside County office hosting the video-conference opened 30 minutes after the 

scheduled start time. It was confirmed that one person attempted to participate during 

this time frame. This person participated at the subsequent January 13, 2016 Elected 

Officials’ Briefing and provided testimony.

Submitted by Capps, Tressy Submittal 16361 Related Documents

16361.01 This entire plan is based on climate change which is, in fact, a false religion and so the 

whole plan is based on something that is not even real. So, of course, I don't agree with the 

plan.

Comment noted.

16361.02 And I'll give you an example with our Toll lanes flight why this regional thing is such a bad 

setup for We the People. So in San Bernardino County the Toll lane process has been going 

on since December of 2013, the public is largely clueless and that's by design.

Comment noted. San Bernardino Associated Governments (SANBAG) initiated study of 

potential Interstate 10 improvements in 2007. In 2011, SANBAG started a study of express 

lanes. In 2012, SANBAG began final technical studies and extensive public outreach, 

including public scoping meetings, for the I-10 Project and began preliminary technical 

studies and public outreach for the I-15 Project. In 2014, the SANBAG Board selected 

express lanes as the locally preferred alternative for the I-10 Project and SANBAG started 

final technical studies for the I-15 Project. Final environmental approval for the I-10 Project 

is anticipated for late 2017 and early 2018 for the I-15 Project. A regional network of 

express lanes was included in the adopted 2012 RTP/SCS. The network was refined over 

the last four years through various efforts, including the I-10 and I-15 Projects described 

above. The segments of the regional express lane network in San Bernardino County 

included in the 2016 RTP/SCS are consistent with those in being considered by SANBAG.

244
holdID Comment Response 

Submitted by Culp, Bruce Submittal 16252 Related Documents

16252.01 i believe as you look into the future on how citizens are going to move around, there should 

be thought on how to assist autonomous vehicles. There will be a revolution in vehicles. 

Today's kids are now used to Uber and being driven around. those companies will partner 

(they already have) with auto manufacturers to create fleets of autonomous vehicles that 

people will pay a monthly subscription to be driven everywhere. Insurance companies will 

make it cost prohibitive to own a vehicle, since human driven vehicles will be the most 

dangerous form of transportation. With that in mind, future infrastructure should revolve 

around centrally located "hubs" for these vehicles to park and recharge themselves. 

Overall, there will be less vehicles on the road, however, there will need to be locations 

where these vehicles can centrally locate in order to maximize their efficiency in picking up 

and dropping off people and then re-charge.

Comment noted. SCAG is aware that automated and connected vehicles will be available 

within the timeframe of this RTP/SCS. However there is still significant uncertainty 

regarding the timeframe for deployment, and the ownership model for these vehicles. 

Automakers plan their vehicles years ahead of deployment, and existing vehicles will 

remain in operation for decades. Therefore the challenge facing SCAG and other MPOs will 

be to forecast a mixed vehicle fleet for the next plan and into the future. The RTP/SCS 

section on mobility innovations does not endorse any single technology, or business 

model, however the plan recommends that regional leaders advocate for policies to 

encourage that future automated vehicles rely on zero or near zero emissions drivetrains.

Submitted by Culp, Bruce Submittal 16260 Related Documents

16260.01 the Montclair transit center is one of only a few unique transit centers that services several 

types of transit options (i.e., bus, rail, class 1 bike path and soon, light rail (gold line)). In 

addition, it is located near both the higher populated southwest corner of San Bernardino 

county and Los Angeles county. It also serves bus lines from 3 different counties. There are 

also two major freeways within a mile of the transit center. The pacific electric trail also 

connects to the north end of the transit center. Lastly, Montclair plaza is located within 

walking distance. With all of these features, the Montclair Transit Center, in my opinion, is 

one of the most valuable transit centers in the entire region. Serving 3 counties, with 

multiple transit options, located to major freeways, and next to major colleges and 

shopping, i believe that this transit center deserves top priority funding for any transit 

related projects. the city of Montclair itself is investing in TOD. Please consider priority 

funding for this important transit center when looking at future plans and funding.

Comment Noted. The 2016-2040 RTP/SCS includes rail and bus service improvements to 

and from Montclair Transit Center, including the Foothill Gold Line light rail transit 

extension to Montclair (RTP ID 4120222).

Submitted by Dhahbi, Sally Submittal 16062 Related Documents

16062.01 Please, give us groceries stores and building supplies stores close to wood road and jahalco 

r9oad. we are far from perris and riverside and population has been increasing since 1999 

and no commercial buildings close to home.

Comment noted. The actions and strategies contained in Chapter 5 of the 2016 RTP/SCS 

do encourage various components of "livable streets" (Livable Corridors and 

Neighborhood Mobility Areas). Working with local jurisdictions, SCAG's land use and 

transportation strategies support expanding choices including better bicycling and 

pedestrian infrastructure, compact neighborhoods, and transit access. While the SCS is 

intended to provide a regional strategy that local governments may consider if they so 

choose, local jurisdictions maintain local land use authority.

245
holdID Comment Response 

Submitted by Dillard, Joyce Submittal 16312 Related Documents Link

16312.01 The DRAFT POLICY GROWTH FORECAST does not match amongst the POPULATION, 

HOUSEHOLDS and EMPLOYMENT. LOS ANGELES COUNTY has a POPULATION growth for 

cities/unincorporated of 10% and more at 1,226,100 or 10.65% of the total. That is 77.01% 

growth in 10 cities. Cities/unincorporated with the largest expected growth comprise of 

12.10% of the total with a population increase of 1,393,000. LOS ANGELES COUNTY 

HOUSEHOLD increase is at 17.46%. LOS ANGELES COUNTY EMPLOYMENT is at 18.73%. As 

with the other counties, we see no consistency in the model used, and therefore, no reality 

of real growth.

Comment noted. SCAG staff is unable to confirm accuracy of cited growth figures for the 

Los Angeles County. According to SCAG date, Los Angeles County growth forecasts of 

population, household and employment between 2012 and 2040 are as follows: 

Population: 1,591,000, or 16% Household: 689,000, or 21% Employment: 980,000, or 23%

16312.02 You have no substantiation for the following statements: Like the 2012 RTP/SCS, the 

proposed land use strategies included in the 2016 RTP/SCS continue to focus new growth in 

HQTAs, existing suburban town centers, and more walkable, mixed-use communities: • 

Identify regional strategic areas for infill and investment; • Structure the plan on a threetiered system of centers development;11 • Develop “Complete Communities”; • Develop 

nodes on a corridor; • Plan for additional housing and jobs near transit; • Plan for changing 

demand in types of housing; • Continue to protect stable, existing single-family areas; • 

Ensure adequate access to open space and preservation of habitat; and • Incorporate local 

input and feedback on future growth.

Comment noted. SCAG staff utilized these established land use policies in developing the 

2016 RTP/SCS. With SB 375, SCAG is tasked with integrating land use and transportation. 

The SCS and SB 375 do not require a jurisdiction’s land use policies and regulations be 

consistent with the SCS. While the SCS is intended to provide a regional policy foundation 

that local governments may build upon if they so choose, it is clear that local jurisdictions 

maintain local land use authority.

16312.03 You have no substantiation for the following statements: In support of the foundation 

policies and guiding principles, the RTP/SCS includes six proposed land use strategies: • 

High Quality Transit Areas (HQTA) • Livable Corridors • Neighborhood Mobility Area • ZeroEmission Vehicles and Electric Vehicle Charging Stations • Natural Lands Preservation • 

Balancing Growth Distribution between 500 Feet of Freeways and HQTAs

Comment noted. SCAG's Regional Council approved utilizing these land use strategies in 

developing the 2016 RTP/SCS. With SB 375, SCAG is tasked with integrating land use and 

transportation. The SCS and SB 375 do not require a jurisdiction’s land use policies and 

regulations be consistent with the SCS. While the SCS is intended to provide a regional 

policy foundation that local governments may build upon if they so choose, it is clear that 

local jurisdictions maintain local land use authority.

16312.04 Infrastructure needs to be analyzed. All Elements of all Cities/Unincorporated should be 

analyzed for General Plan consistency.

Comment noted. With SB 375, SCAG is tasked with integrating land use and 

transportation. SCAG’s SCS is based on general plans from local jurisdictions, and other 

local input from communities, cities and other local jurisdictions across the SCAG region. 

The SCS and SB 375 does not require a jurisdiction’s land use policies and regulations be 

consistent with the SCS. While the SCS is intended to provide a regional policy foundation 

that local governments may build upon if they so choose, it is clear that local jurisdictions 

maintain local land use authority. Regarding transportation infrastructure, the County 

Transportation Commission (CTCs) provided input regarding the list of projects to be 

included as part of the RTP/SCS. Through a bottom-up approach, the CTCs solicited input 

from their respective sub regions regarding local transportation priorities. Such priorities 

are in turn reflected within Project List appendix. Therefore, infrastructure improvements 

within the RTP/SCC should be consistent with local General Plans.

16312.05 Material presented at the Southern California Economic Summit are not consistent with the 

DRAFT POLICY GROWTH FORECAST.

Comment noted. Recent figures indicate the region and its counties have regained all the 

lost jobs during the Great Recession by December 2015, which are consistent with the 

assumptions and trends under the 2016-2040 RTP/SCS policy growth forecast.

246
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Submitted by Fung, Hank Submittal 16020 Related Documents

16020.01 Remove SR-241 extension from Cow Camp Road to I-5 from the RTP baseline and remove 

SR-241 Tesoro extension as a Transportation Control Measure for 2021 conformity. This 

project is extremely controversial and the Regional Water Quality Control Board rejected 

providing permits for the Tesoro extension. While it may be reasonable to overcome this 

objection for the Tesoro extension prior to the 2040 baseline year, I do not believe the 

project sponsor, Foothill/Eastern Transportation Corridor Agency, can overcome objections 

to completion by 2040, given that the United States Marine Corps and California State 

Parks oppose the project, and the project was not approved by either the California Coastal 

Commission or National Oceanic and Atmospheric Adminstration. F/ETCA should comply 

with the NOAA ruling and implement one of the other alternatives in the EIR, with proper 

mitigation to the residents affected by the project, rather than spoiling one of the last 

remaining sections of wilderness in Southern California.

Comment noted. SCAG recognizes that SR-241 Extension no longer meets the timely 

implementation requirements of a Transportation Control Measure (TCM) under the 

Conformity rules pursuant to the Clean Air Act. As a result, TCM substitution has been 

initiated to rescind the committed TCM designation of the SR-241 project. However, 

removal of the TCM designation does not automatically result in the deletion of the 

project from the RTP/SCS. The decision to change, replace or remove a project submitted 

to SCAG by the implementing agency (TCA) via a county transportation commission (OCTA) 

lies with the submitting agencies.

Submitted by Fung, Hank Submittal 16238 Related Documents

16238.01.1 FTIP project list, ORA052: The TCA has had the project disallowed by the State Coastal 

Commission and the Federal NOAA between Cow Camp Road and I-5. Is it realistic that this 

project would be delivered by 2021, and that the section from Oso Parkway to Cow Camp 

Road would be delivered (or even started) by 2017 given that the Transportation Corrdior 

Agencies has re-initiated the environmental analysis project from scratch? RTP project list, 

ORA052 - Same. There are hurdles with state and federal permitting agencies not to 

mention environmental groups. This project, by enabling longer distance, regional trips, 

would not reduce climate change nor meet the goals of SB 375 nor AB 32. This project 

should not be used for air quality conformity purposes and should be removed from the 

financially constrained plan. NOAA indicated that other options should be studied for a 

connection to I-5 which would reduce impacts to sensitive resources. RTP project list, 

1M0101 - Support the inclusion of SR-710 as a mode-neutral corridor, consistent with the 

alternatives identified in the draft EIR.

Comment noted. Regarding ORA052) SCAG recognizes that SR-241 Extension no longer 

meets the timely implementation requirements of a Transportation Control Measure 

(TCM) under the Conformity rules pursuant to the Clean Air Act. As a result, TCM 

substitution has been initiated to rescind the committed TCM designation of the SR-241 

project. However, removal of the TCM designation does not automatically result in the 

deletion of the project from the RTP/SCS. The decision to change, replace or remove a 

project submitted to SCAG by the implementing agency (TCA) via a county transportation 

commission (OCTA) lies with the submitting agencies. Regarding 1M0101) SCAG recognizes 

that the project is currently pending environmental review. As with other projects 

included within the Project List, when the SR-710 North Study EIR/EIS process is complete 

and a locally preferred alternative (LPA) is identified in the final environmental document, 

SCAG will work with Metro to amend the RTP/SCS as necessary to update the project 

description and associated modeling analysis.

16238.01.2 Overall - indicate as a disclaimer that these RTP projects may be subject to individual 

environmental review and the programmatic EIR is not a substitute for project level 

environmental analysis.

Commented noted. Both the 2016 RTP/SCS and the PEIR make clear that RTP projects 

require project or site-specific environmental analysis to assess impacts at the project level 

and the consideration of appropriate mitigation measures. See Master Response No. 2 in 

the Response to Comments in the Final PEIR.

16238.02 One of the challenges that SCAG has is managing regional challenges in a way that is 

sensitive to local communities, while still meeting the state and federal mandates regarding 

climate change, air quality, and transportation conformity. I would like to see SCAG take a 

more robust role in coordinating between counties and, if necessary, imposing policies on 

recalcitrant agencies in order to preserve our region's conformity with these state and 

federal laws and regulations. SCAG is doing so with projects such as the West Santa Ana 

Branch study and Express Lane Choices study, but I would like to see a greater role in this 

regard, and an acknowledgment that although different counties have different priorities, 

as expressed through their county transportation plans and self help sales tax measure 

breakdowns (when available), that the region is required as a whole to meet these laws and 

regulations, and we all share in the costs much like we do the benefits.

Comment noted.

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Submitted by Fung, Hank Submittal 16238 Related Documents

16238.03 Chapter 2, Chapter 5 - Acknowledge the adoption of "Vision Zero" in the City of Los Angeles 

and other jurisdictions, and that other agencies in the SCAG region are considering it. Vision 

Zero "is a road safety policy that promotes smart behaviors and roadway design that 

anticipates mistakes so that collisions do not result in severe injury or death." (City of Los 

Angeles Vision Zero subsite) The City of Los Angeles's goal is to achieve Vision Zero by 2025, 

well within the time frame of this plan. Many of the pedestrian and bicycle improvements 

proposed in the plan are for safety purposes and should be highlighted in the plan.

Comment noted. SCAG has incorporated information regarding the local Vision Zero 

initiatives into the Plan.

16238.04 TSM/TDM - Although SCAG, as noted, is not an implementing agency, they can and should 

use their funding powers to help the region standardize on a single fare card system - the 

TAP card used in Los Angeles County. It is my understanding that Metro staff have 

presented this card system to other county transit agencies. Ventura County has also 

discontinued their previous obsolete smart card system. SCAG should not submit for 

Federal funding separate smart card projects that compete with the TAP card, as we need 

to facilitate regional cooperation. Mobile ticketing options are currently being developed 

by multiple agencies with multiple vendors, which has the potential of creating confusion 

between riders traveling through the region, if Metrolink, LADOT, and OCTA have different 

providers each with different apps. I regularly bring up the specter of the Inland Empire 

counties having a different 511 system than Los Angeles, Orange, and Ventura counties, but 

it is instructive, since people cross county lines regularly to go to work, school, social, or 

recreational activities, and have to deal with separate systems when they cross county 

lines. As a regional body, SCAG should monitor the development of these projects and 

ensure that, at some point, that a regional solution is adopted to avoid confusion for transit 

riders, which could hurt usage of transit and the emissions reductions planned for in the 

RTP.

The 2016 RTP/SCS calls for implementing inter-jurisdictional fare agreements and media to 

make transit and rail more attractive and accessible to users. While SCAG encourages 

interagency collaboration, the selection of vendors and other procurement issues are 

ultimately the responsibility of the lead agency for any particular project. SCAG recognizes 

that local agencies should have the ability to respond to their own particular needs in any 

given ITS procurement.

16238.05 Unfortunately, agencies such as OCTA are reducing the footprint of fixed route service, as 

with the OC Bus 360 plan, due to fiscal constraints. While fixed route service is expensive to 

operate, it also is likely to generate more spontaneous trips and support seniors and the 

disabled compared to alternatives such as taxis or app-based ride services. In many of 

these suburban areas which are seeing transit service reduced, such as in South Orange 

County, seniors and the disabled will also no longer have dial-a-ride/Access service. This 

has tremendous impacts for public health for those individuals who previously were able to 

take local bus service, albeit infrequently, and are now isolated. In addition, SCAG notes 

correctly that the population is aging, and seniors aging in place without adequate 

transportation is an issue that needs to be addressed. SCAG should acknowledge the 

reduction of the area of its region served by public transit, and implement policies to 

support development of services which may be better able to meet the needs of seniors 

and the disabled. The South Bay COG has advocated Neighborhood Electric Vehicles as one 

way to address this concern. It is mentioned as a greenhouse gas emission solution, but 

also should be mentioned as a means to improve first mile/last mile to stations and transit.

The decision to add or cut fixed route service is ultimately the responsibility of the 

operating agency. In this case, that is the Orange County Transportation Authority (OCTA). 

The impacts of the Recession of 2008-09, and the subsequent period of slow growth, are 

still being felt by local providers of public transportation, and it may be some time before 

service levels stabilize. Specific strategies to identify and meet mobility needs of older 

adults, persons with disabilities, and persons of low income were produced in the 2015 

update to the Coordinated Public Transit – Human Services Transportation Plan for Orange 

County. This plan outlines strategies to address specialized mobility needs including 

innovative mobility management programs, expanding specialty and beyond the ADA 

transportation services including door-through-door service, regulating access to taxis, 

promoting senior and disabled friendly complete streets, and providing online and travel 

training resources to mobility challenged communities.

248
holdID Comment Response 

Submitted by Fung, Hank Submittal 16238 Related Documents

16238.06 MAP-21 calls for "reliability" as a measurement. In addition to traditional highway system 

reliability (i.e. travel time), transit reliability is important. Metrolink on time performance is 

dropping. LACMTA's on time performance goal for buses is 80% and is usually not met. 

Reliability is especially important for low wage workers who have shift-based schedules 

that require showing up on time to help customers or manufacture products. Poor 

reliability impacts people shifting trips to transit, since they perceive that a car trip is more 

reliable, especially if transfers are involved. Policies such as dedicated bus lanes, smart 

cards, and off board fare payment can improve reliability.

Comment noted. First, the MAP-21 performance measures rule-making is still in progress 

by the US DOT. Transportation system reliability is included in the 2016 RTP/SCS as one of 

the outcomes to be used for on-going regional performance monitoring. The importance 

of transit system reliability is recognized in the 2016 RTP/SCS, and one of the sustainability 

goals of the Plan is to increase the mode share for transit. Staff will work with our transit 

partner agencies to explore the transit reliability measures. It is very important to make 

commuting by transit a more attractive option than driving alone in an automobile. 

Reliability, mobility, transfer, and first/last mile improvements are all critical ingredients 

toward achieving the goal of greater transit mode share in our region.

16238.07 SCAG should also acknowledge the San Joaquin train service, managed by the San Joaquin 

Joint Powers Authority. Although the rail corridor is outside of the SCAG region, many 

riders transfer in Bakersfield for bus service to destinations throughout all counties in the 

SCAG area (except Imperial). The bus between Los Angeles Union Station and Bakersfield 

regularly fills multiple buses daily. It is a key route serving passengers to destinations in 

Central and Northern California. While it may be replaced by high speed rail during the 

duration of this plan, it is a key route today used by thousands of passengers annually.

Comment noted. This comment has been incorporated into the Passenger Rail Appendix.

16238.08 Although not an "innovation" per se, electric bicycles and similar devices have a potential of 

increasing first mile/last mile options, especially in hilly areas poorly served by transit. They 

can be carried on buses and trains similar to pedal-powered bicycles and also help increase 

the range of riders to go longer distances, especially in hot weather. Similarly, self balancing 

electric scooters, i.e. "hoverboards", are currently seen as a toy and are dangerous due to 

their poor construction. However, over the course of the RTP, they are a potential first 

mile/last mile option which should be monitored for possible inclusion in future RTPs.

Comment noted. Electric bicycles are discussed in the mobility innovations appendix. 

Hoverboards, as well as electric skateboards, are anticipated as first/last mile 

transportation options.

16238.09 Model reliability among different ethnic groups, including transit reliability. The expansion 

of rail will enable transit riders to have a more reliable commute, but this impact might be 

distributed inequitably. Also, although this is outside of SCAG's control, different transit 

agencies in the region have different reliability standards, such as permissible percentage 

of buses early/late. How does that impact environmental justice?

Transit reliability was not included in the analysis for the 2016 RTP/SCS due to lack of data 

tools, but can be evaluated for future efforts.

Submitted by Fung, Hank Submittal 16348 Related Documents

16348.01 But in terms of the process, I think, it is great that SCAG is doing the regional process with 

all the different regional offices, although, I do see that very few people seem to be at the 

outlying offices, but certainly, having the times available on evenings and on Saturday for a 

hearing is much better than the process when we were collecting public input where the 

City of Los Angeles was omitted as a location and, also, when the majority of the meetings 

were held during the daytime with the only evening meeting in the Los Angeles Basin at the 

Gateway City's Hall which I was disappointed at. They later did add more meetings but only 

when I complained to the member of my regional council, my Regional Council Member 

Sam Pedroza. So, I do compliment SCAG on that.

Comment noted. SCAG will consider these comments in its assessment of outreach 

activities. Thank you.

249
holdID Comment Response 

Submitted by Fung, Hank Submittal 16348 Related Documents

16348.02 In relationship to the plan itself, generally, I think that SCAG needs to be taking a much 

more robust role regionally. For example, in the presentation just one items they 

mentioned was the Tap Card and we need to see that not just in L.A. County but we need 

to see that regionally.

The 2016 RTP/SCS calls for implementing inter-jurisdictional fare agreements and media to 

make transit and rail more attractive and accessible to users. While SCAG encourages 

interagency collaboration, the selection of vendors and other procurement issues are 

ultimately the responsibility of the lead agency for any particular project. SCAG recognizes 

that local agencies should have the ability to respond to their own particular needs in any 

given ITS procurement.

16348.03 We need to see the Greenhouse Gas Emission reductions which the plan proposes. So, we 

need to see more of these active transportation project out in the San Bernardino, 

Riverside and the Inland areas so that they are also pulling their fair share of greenhouse 

gas reductions, as it is mandated by SB375 that we reduce our greenhouse gas emissions 

and the voters voted for that when they turned down the oil companies' attempt to delay 

implementation. So, the voters have spoken, we want greenhouse gas emission reductions 

and we want these projects throughout the region.

Comment noted. Final analysis of Greenhouse Gas Emissions have been provided in the 

Transportation Conformity Analysis Appendix. Active Transportation projects in Riverside 

and San Bernardino Counties are taken from local and county active transportation plans 

and gap closures. Active Transportation is but one part of a comprehensive multi-modal 

strategy in the Regional Transportation Plan/Sustainable Communities Strategy to help 

reduce Vehicle Miles Traveled and Greenhouse Gas Emissions.

16348.04 L.A. County is doing a great job with Measure R and with the different tax measures in the 

past, but I'd like to see some of the other counties do the same as well with their tax 

measures as they move forward so that's all.

Comment noted. Imperial, Los Angeles, Orange, Riverside and San Bernardino counties 

currently have sales tax measures dedicated to transportation expenditures. Ventura 

County is the only county in the region without an existing dedicated sales tax for 

transportation. However, Ventura County is in the process of seeking voter approval on a 

half-cent sales tax, which is reflected as part of the reasonably available revenues.

Submitted by Gar, Victor Submittal 16126 Related Documents

16126.01 We cannot allow you to make driving so expensive that we have to walk an bike places like 

in a third world country. You cannot tax us per mile! Would like to walk or bike to work 

when is raining or when it is a 110 degrees in summer time? How about when its 60 mph 

winds in fontana? These ideas are are not right, I live in redlands,ca an as a construction 

worker I have different job locations every day. one day i will be in Los angeles the next in 

temecula an the next in burbank, i carry with me a lunch box and many heavy tools. It is 

impossible for me to commute in mass transit. we paid for the carpool lanes to be built an 

now we are getting charged to use them. Now you want to use them for your own financial 

gain. That is theft an me and my family and neighbors are against this metropolis you want 

to build at the cost of our freedoms and tax dollars.

Comment noted. It should be clarified that gas tax revenues, in real terms, are actually in 

decline as tax rates (both state and federal) have not been adjusted in more than two 

decades. At the same time, the number of more fuel efficient and alternative powered 

vehicles continue to grow. The Plan identifies several new funding sources that are 

reasonably expected to be available. These sources include adjustments to existing state 

and federal gas tax rates and a long-term replacement of state and federal gas taxes with a 

mileage-based user fee to maintain the historical purchasing power of the gas tax.

Submitted by Garcia, John Paul Submittal 16360 Related Documents

16360.01 I do echo with what Vivian Romero who just came up to say, I would also like to request 

that the SR60 corridor in the Montebello area be considered in the RTP. I believe, that an 

HOV or a carpool lane be considered on the SR60 from the 710 to the 605.

Comment noted. Upon review of the Project List Appendix, financially constrained RTP 

projects as related to SR-60 between I-710 and SR-605 were not identified. However, as 

part of the strategic portion of the Project List, specifically RTP ID# S1120044 proposes an 

HOV lane on SR-60 between I-710 and US-101. As funding becomes available in the future, 

it is possible that this project could move to constrained list through future update or 

amendment to the RTP/SCS.

250
holdID Comment Response 

Submitted by Garg, Om Submittal 16346 Related Documents Link

16346.01 Please inform the requirements for getting a new Interchange on I-15 in SB County 

included in RTP. Thanks!

Comment noted. We believe your first step in identifying potential improvement projects 

on I-15 should be to understand what projects are already recommended in this corridor 

in the applicable planning and programming documents, including the Project List 

Appendix of the 2016 RTP/SCS, Transportation Concept Report (TCR) prepared by Caltrans 

etc. Based on your initial research if you still feel strongly that the corridor needs are not 

adequately addressed, we suggest you contact your county transportation commission 

with your suggestions and ideas for their consideration in their future plans and programs.

Submitted by Giba, Jeffrey Submittal 16347 Related Documents

16347.01 1. The RTPSCS on pages 6 and 14 define both major initiatives as well as major themes. In 

both as well as the Ex Summary the higher/highest priority is given to "Preserving and 

Protecting our existing trans infrastructure" or Fixing It First yet in Riverside County there is 

no mention in the RTP for completing and fixing the E/W 60 freeway between the 15 and 

10. Instead there is a focus on going around and building a new corridor to the South. If we 

are to Fix it First then we should Fix it First.

Comment noted.

16347.02 Good Economic Opportunities - The approval of a logistics plan in East Moreno Valley of 

40.6 mil ft squared is off the 60 freeway corridor. Again, a reason to be included to repair 

and preserve.

Comment noted.

16347.03 3. One way to decrease time on the roads is to reserve transportation to jobs from East to 

West instead from the West to the East and shorter distance to jobs. The Moreno Valley 

majority council considered this by approving the 40.6 mil ft squared WLC in East Moval 

potentially creating 20,000 jobs. Keeping jobs closer to home and reducing average daily 

vehicle miles, reducing pollutants and improve Air Quality while creating greater economic 

opportunities. This is not in the RTP.

Comment noted. SCAG’s SCS is built upon local input from local jurisdictions including the 

City of Moreno Valley, so the approved projects are included in the data utilized in the SCS. 

The "Forecasted Regional Development Types" maps have been developed for the 

purpose of modeling performance. SB 375 legislation does not require that a jurisdiction’s 

land use policies and regulations, including its general plan, be consistent with the SCS. 

The goal of SB 375 is to integrate transportation and land use by reducing average vehicle 

miles traveled, reducing pollutants and improve air quality.

Submitted by Gilbert, Whitley Submittal 16053 Related Documents

16053.01 I am a 24 year old full time college student who was born and raised in the region. I would 

like to make it clear that I am a broke college student! I do not own a car and have student 

debt and credit card debt and am unable to buy a car at the moment. I attend school in the 

San Francisco bay area where I can easily access public transportation. I can take a bus to 

the Emeryville BART station where I can then catch the AMTRAK and ride with ease all the 

way to Sacramento. Public transportation in Northern California makes living so much 

easier for the broke car-less college student like myself. Here at home, it is not that easy. I 

live in Perris, Ca and have been trying to visit a friend in Rancho Cucamonga for the last 4 

days. Niether of us own a car and the lack of public transit options make it impossible to 

meet up. This is in sharp contrast from the systems of the bay area. I should not have to 

move out of my home region to be able to live a lifestyle that is a reality for me as a broke 

car-less college student.

Comment noted. The 2016 RTP/SCS includes a significant expansion of rail and transit 

services across the region through 2040. Notably, Metrolink is opening its new Perris 

Valley Line in 2016, which will provide a connection between Perris and Rancho 

Cucamonga on high-quality rail service.

251
holdID Comment Response 

Submitted by Goller, Terry Submittal 16224 Related Documents Link

16224.01 This Federal Reginal SCAG plan would be a grandiose state endeavor to further burden the 

taxpayer and their individual rights. With a $556 billion expenditure and a $275 billion 

operating and maintenance cost, there would be a $200 billion difference resulting in tax 

increases. Allowing the state and cities to solve their own transportation problems and 

working with Cal Trans is a more feasible solution. Even curtailing the rail plans would be a 

monetary benefit as there are existing construction impossibilities. This would free up 

funds to improve California needs and not federal mandates and more taxes.

In accordance with state and federal requirements, the 2016 RTP/SCS includes a financial 

plan that estimates how much funding will be needed to implement transportation 

investment needs, as well as operate and maintain the transportation system as a whole 

over the life of the Plan. The Plan must demonstrate that there is a balance between the 

estimated costs of the projects and programs described in the Plan and revenue sources 

reasonably expected to be available for transportation investments.

16224.02 Yes, we have transportation issues. This can be solved with more park and ride-share 

incentives along with rewards for car-pooling and using bus services that are not utilized.

Comment noted. The 2016 RTP/SCS includes a wide variety of transportation strategies 

and investments, recognizing that improvements to all transportation modes are 

necessary in order to reduce congestion and improve the transportation system in the 

SCAG region. These include transportation demand management, transportation systems 

management, active transportation investments, land use strategies and multi-modal 

capital and operating improvements.

16224.03 The DMV should be made more aware of enforcing legal valid drivers with more stringent 

retail auto sales verifications.

Comment noted. Improper licensing continues to be a critical issue within California. SCAG 

supports efforts that the State of California is taking to improve driver licensing, 

including: - Assess and improve policies for managing unlicensed drivers, negligent 

operators and suspended/revoked drivers. - Improve data systems, including quality 

control measures, for driver and vehicle records, citations issued, court adjudication 

reporting and DMV license actions. - Improve training of law enforcement and related local 

agencies regarding licensing, DMV license actions and DMV data systems. - Create a public 

awareness campaign addressing the consequences of driving without a valid license. - 

Examine the reasons why some individuals choose to drive without a proper license rather 

than reinstate licensing privileges when eligible and based on this information, propose 

ways to increase the reinstatement rate.

16224.04 When the state mandates housing to live near transportation, this differs from the 

American Way. Such regional living borders on the sci-fi “Hunger Games” mentality. Living 

near railroad stations with increased walking and biking to work with untold restrictions are 

not a priority.

Comment noted.

16224.05 Like the Obama Plan, this has too many mandates and loop-holes with the benefits siding 

with the provider companies. This tact can be seen as a forcible way to eliminate the 

American “know-how” of entrepreneurship. I commend the designers of this document as 

it contains all legal-binding, freedoms and taxes that would restrict the California citizen. If 

the draft is predominately from an environment persuasion, then it is not reflecting a 

balanced voice. Since SCAG is a voluntary association, I recommend that Southern 

California does not participate in this Federal plan. Our state should not accept assistance 

with regional housing, energy, transportation or the environment. Voting for 86 more 

government officials to implement this would restrict California from making their own 

decisions. Please do not accept this draft.

Comment noted.

252
holdID Comment Response 

Submitted by Gutierrez, Ezequiel Submittal 16314 Related Documents Link

16314.01 As a result, redraft of the document is compelled with greater efforts at inclusion of the 

several HD communities than evident. Without engaging in extensive review of the DRAFT 

which is substantially if not completely exclusive of the HD communities and environment, 

two regional maps in Chapter 5 of the DRAFT startling reveal the omission.

Comment noted. Please refer to SCAG's Environmental Justice Appendix for a detailed 

breakdown of the Plan's impacts on disadvantaged communities, urban areas, rural areas, 

and communities of concern.

16314.02 Exhibit 5.2, 2040 Transit Network Planned and Existing, reveals the absence of the HD in 

any transit future for the SCAN region. It is indeed a picture worth a 1000 words, only 

Palmdale/Lancaster are included.

Exhibit 5.2 depicts local and express bus service in the Antelope Valley, the Victor Valley, 

the City of Barstow, and in the Morongo Basin.

16314.03 Similarly, Exhibit 5.4, Major Highway Projects, does not show an adequate highway scheme 

for the HD. The only significant infrastructure represented is the High Desert Corridor (HDC) 

which after considerable planning forums has been admitted not to include any on and off 

points between Highway 14 in the Antelope Valley and Highway 15 to the east of the 

Adelanto/Victorville communities. As such, it will not serve nor is it planned to serve HD 

communities. Its only apparent purpose is to drain dollars away from the SCAG region (and 

California, generally) to Vegas. It will be a toll road so any benefit to HD communities will 

have to be purchased.

Comment noted. Exhibit 5.4 is intended for illustrative purposes only. Please refer to the 

Project List Appendix for a complete list of projects. Regarding the HDC project, the 

proposed build alternatives carried forth as part of the Draft HDC EIR/EIS includes a total 

of 18 interchanges between SR-14 and SR-15. The following website provides a map of the 

proposed interchange locations along the HDC corridor: 

https://d1akjheu06qp1r.cloudfront.net/projects_studies/hdc/images/map_corridor_hdc_r

amps_eng.pdf

16314.04 The High Desert has enormous potential to accomplish any of the objectives of the DRAFT. 

Its relatively undeveloped areas represents, in essence, a blank slate in which to plan and 

develop nodal transit oriented communities (the High Quality Transit Areas (HQTA's) of the 

DRAFT.

Comment noted. HQTAs in the 2016 RTP/SCS are designated based on existing and 

planned transit service. The transit service input is from the local County Transportation 

Commission (CTC) - any desired transit service not included in the 2016 RTP/SCS needs to 

be requested by the local CTC.

16314.05 As with the coming METROLINK Perris Valley Line reviewed in the DRAFT, a similar 

METROLINK line can be developed eastward from its Palmdale station toward Hesperia, 

using and expanding the existing right of way freight line of the Union Pacific railroad.

The 2016 RTP/SCS includes the High-Desert Corridor connecting the Antelope Valley to the 

Victor Valley in the financially constrained plan. This transportation facility includes a 

highway/tollway, bike lanes and high-speed rail.

16314.06 Such a commuter transit line could be developed with periodic HQTA nodes, creating the 

type of living environments for people envisioned in the DRAFT while protecting the natural 

environment of the HD. It would help link HD commuters with employment opportunities 

"down the hill," thus, mitigating the growing traffic load in the Cajon Pass and its adverse 

environmental impacts.

Comment noted. HQTAs in the 2016 RTP/SCS are designated based on existing and 

planned transit service. The transit service input is from the local County Transportation 

Commission (CTC) - any desired transit service not included in the 2016 RTP/SCS needs to 

be requested by the local CTC.

16314.07 Such a METROLINK line would serve to economically integrate the HD to the greater 

economy of the region, as a whole. It would serve to channel and direct population growth 

into new HQTA's along the new METROLINK line, away from the haphazard pattern which 

based on current building would otherwise develop.

The 2016 RTP/SCS includes the High-Desert Corridor connecting the Antelope Valley to the 

Victor Valley in the financially constrained plan. This transportation facility includes a 

highway/tollway, bike lanes and high-speed rail.

16314.08 Further review and planning of the DRAFT document is requested to create a truly inclusive 

and integrated SCAG region.

Comment noted.

253
holdID Comment Response 

Submitted by Harris, Eileen Submittal 16216 Related Documents

16216.01 I am highly concerned with regard to the proposal for re-zoning the Armstrong Nursery 

Property (17552 Goldenwest) to RH Zoning. We have had so many apartments built in the 

city already that the traffic in the streets as well as crime has increased tremendously. 

Wouldn’t it make logical sense to build something that can benefit the community as a 

whole? This location would be perfect for seniors who want to eat or shop near the new 

community center or possibly a YMCA for kids who want to use the park. Huntington Beach 

already has numerous high-density apartment complexes. The safety of our neighborhood, 

parks and the seniors are pertinent. Studies have shown that bringing in a low-income 

facility destroys communities and schools. I strongly oppose this proposition. Eileen Harris, 

Esq. - 6901 Rook Dr., Huntington Beach, CA

Comment noted. SCAG’s SCS is built upon local input from local jurisdictions and SB 375 

legislation does not require a jurisdiction’s land use policies and regulations, including its 

general plan, be consistent with the SCS. For the purposes of SB 375, and reducing 

Greenhouse Gas (GHG) emissions and Vehicle Miles Traveled (VMT), SCAG, in some cases, 

altered small area land use assumptions to better reflect recent trends occurring in many 

transit-rich areas of the region. The "Forecasted Regional Development Types" maps have 

been developed for the purpose of modeling performance. While the SCS is intended to 

provide a regional policy foundation that local governments may build upon if they so 

choose, local jurisdictions maintain local land use authority.

Submitted by Hearst, Patricia Bell Submittal 16228 Related Documents Link

16228.01 As a resident of Brentwood, I travel through the Sepulveda Pass - using Sepulveda 

Boulevard to conduct business in the San Fernando Valley and points north. For 15 years I 

have reviewed studies, reports and opinions amounting to 10 file boxes regarding the 1-

405 Sepulveda Pass Improvement Project. After reviewing the Draft 2016-RTP/SCS 

regarding a Reversible Lane (LA-RTP-996425) through the Mulholland Tunnel, please be 

advised that: - There are no studies or evidence to support the need for a reversible lane 

within the Mulholland Tunnel. - The 1-405 Sepulveda Pass Improvement Project provided 

an additional North Bound Lane from the new Skirball Ramps on Sepulveda - to the new 

Skirball Center Bridge. - This new North Bound lane provides greet ease in North Bound 

traffic movement during peak hours of traffic, thereby eliminating any need of a reversible 

lane in the Mulholland Tunnel

Comment noted. Since the completion of the improvements on I-405, additional 

improvement needs in this corridor, including Sepulveda Boulevard, are being further 

examined. SCAG will work with Metro and Caltrans to reflect the ultimate improvement 

configuration in this corridor in the future RTP/SCS amendments or updates as appropriate.

Submitted by Helgeson, Richard Submittal 16326 Related Documents Link

16326.01 I join with a growing number of people, organizations and public entities in requesting that 

SCAG act responsibly in the preparation of the 2015-2040 Regional Transportation 

Plan/Sustainable Communities Strategies (RTP/SCS) and remove all references which could 

be construed to support inclusion of the SR-710 Freeway Tunnel Project from that 

instrument. Even though the 710 North Project alternatives are undergoing environmental 

review and no alternative should have yet been selected pursuant to the current EIR 

process it is obvious that SCAG has already "pre-determined" the SR-710 Tunnel 

alternative. This patently illegal action by SCAG unfortunately opens the door to the very 

type of "post hoc rationalization" under the California Environmental Quality Act which 

California appellate courts have uniformly condemned. (See for example Laurel Heights 

Improvement Association v. Regents of the University of California (1988) 47 Cal. 3rd 376). 

A number of references which point solely to the tunnel still remain in the in the RTP/SCS.

Comment Noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document, SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description and associated modeling analysis.

254
holdID Comment Response 

Submitted by Helgeson, Richard Submittal 16326 Related Documents Link

16326.02 Given the circumstances of the Seattle SR 99 Alaskan Way Viaduct project in the State of 

Washington, any attempt to carry forth the SR-710 North Freeway Tunnel would represent 

the very height of local governmental irresponsibility. As I will demonstrate subsequently, 

the Washington Alaskan Way Viaduct Project is the only other project in the world in which 

the proposed tunnel boring technology which is contemplated for the SR-710 Freeway 

Tunnel has ever been attempted. The catastrophic consequences which have followed 

from that project provide every reason for concluding that the SR-710 Tunnel Project 

should never be seriously considered or pursued. The State of Washington, of course, rues 

the day it ever gave thought to attempting to construct the Alaskan Way Viaduct tunnel.

Comment noted. A project specific environmental analysis is underway by the lead agency, 

which will consider project impacts including construction-related impacts, and identify 

mitigation measures as required. Upon the completion of this effort and selection of a 

preferred alternative by Metro, SCAG will work with Metro to amend the RTP as necessary 

to update the project description and associated modeling analysis.

16326.03 Given all of this and given the current status of the CalTrans SR-710 North EIR/EIS process, 

the only reasonable transportation solution now posed for the SCAG RTP/STS is to reject all 

710 tunnel alternatives. Any further transportation matters associated with this illconceived and controversial tunnel project should be carried forth by examining the 

community based alternatives which have been submitted within the currently pending 

CalTrans EIR/ EIS process which seek to address transportation issues in the West San 

Gabriel Valley without the tunnel.

Comment noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document, SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description and associated modeling analysis.

16326.04 The 710 North tunnel has a dark and tumultuous history which has been fueled in no small 

part by the pressures of special interests. As a preliminary matter I would ask that SCAG 

bear in mind the loud public outcry and the fierce public opposition which has 

characterized the 710 North project for more than fifty years, as well as the bitter enmity 

which this project has often evoked in Southern California in the past. This opposition has 

occurred in no small part because of the devastating environmental degradation which this 

project would have wreaked upon a significant geographic area of Los Angeles County. I am 

hopeful that, with appropriate reflection, SCAG will have the vision to free itself from the 

irrational tunnel vision, which over and over creates more congestion on this region's 

freeway systems and that SCAG, as a more progressively responsible organization, will 

instead work to help develop a responsible transportation paradigm which can better serve 

the region in the generations to come.

Comment noted. SCAG understands that a project specific environmental analysis is 

underway by the lead agency, which will consider project impacts including environmental 

and traffic and mobility impacts, and identify mitigation measures as required. Upon the 

completion of this effort and selection of a preferred alternative by Metro, SCAG will work 

with Metro to amend the RTP as necessary to update the project description and 

associated modeling analysis.

16326.05 While the ballot initiative contained some references to freeway traffic flow improvements 

which might have been directed at improvements in off-ramps and on-ramps, and in 

freeway flow and freeway interchanges, it was not understood by the average voter to 

contemplate construction of a whole new freeway. Measure R's purpose, in the mind of the 

average voter, was to improve mass transit. To the average voter it was intended to free us 

of the irrational over-congestion of the region's freeway systems and to develop a 

responsible mass transit paradigm which would serve Los Angeles for generations to come. 

It's passage represented the hope and the vision of the electorate to free our children and 

our children's children from the obstructive gridlock and air pollution of congested 

freeways. SCAG, however, needs to take irresponsible projects such as the SR 710 North 

tunnel off the table altogether if this hope and this vision is ever to become a reality.

Comment noted. The 710 North project was included in the voter-approved Measure R 

sales tax measure and in Metro's Long Range Transportation Plan, as well as in previous 

SCAG RTPs. A project specific environmental analysis is underway by the lead agency, 

which will consider project impacts including environmental and traffic and mobility 

impacts, and identify mitigation measures as required. Upon the completion of this effort 

and selection of a preferred alternative by Metro, SCAG will work with Metro to amend 

the RTP as necessary to update the project description and associated modeling analysis.

255
holdID Comment Response 

Submitted by Helgeson, Richard Submittal 16326 Related Documents Link

16326.06 In 2011 the Second Appellate District of the California Court of Appeal handed down a 

decision which explained that Measure R did not necessarily commit Metro to those items 

listed as “potential projects” in Attachment A of the Metro ordinance passed in advance of 

Measure R. (See City of South Pasadena et. al. et al., Plaintiffs and Appellants, v. Los 

Angeles County Metropolitan Transportation Authority, Defendant and Respondent; 

California Department of Transportation, Real Party in Interest. California Court of Appeals, 

Second District, Division Six, 2d Civil No. B221118 (2011). In light of this SCAG should be 

guided by the reality that construction of a 710 tunnel through the West San Gabriel Valley 

would represent a project fraught with substantial uncertainty and danger, and that there 

are wiser and more compelling transportation solutions to which our limited resources 

should appropriately be devoted.

Comment noted. A project specific environmental analysis is underway by the lead agency, 

which will consider project impacts including environmental and traffic and mobility 

impacts, and identify mitigation measures as required. Upon the completion of this effort 

and selection of a preferred alternative by Metro, SCAG will work with Metro to amend 

the RTP as necessary to update the project description and associated modeling analysis.

16326.07 The numerous traffic studies compiled by Susan Handy and Marion Boarnet illustrate that 

little will be accomplished in terms of reducing induced demand or traffic congestion by the 

proposed expansion of the 710 Freeway through the SR-710 Tunnel Project. And if one 

seriously considers the enormous environmental and financial risks this project poses, 

there are far better solutions to traffic congestion in Los Angeles County which are 

represented in extensions of the Gold Line, the Purple Line, the Crenshaw Line and other 

mass transit projects that would better serve our twenty-first century transportation needs, 

than to burrow a freeway tunnel through the bowels of the West San Gabriel Valley. Given 

the environmental consequences of the SR-710 Freeway Tunnel our limited transportation 

resources should be better used for worthwhile twenty-first century Los Angeles County 

transportation projects and not the SR-710 Freeway Tunnel.

Comment noted. The 710 North project was included in the voter-approved Measure R 

sales tax measure and in Metro's Long Range Transportation Plan, as well as in previous 

SCAG RTPs. SCAG understands that a project specific environmental analysis is underway 

by the lead agency, which will consider project impacts including environmental and traffic 

and mobility impacts, and identify mitigation measures as required. Upon the completion 

of this effort and selection of a preferred alternative by Metro, SCAG will work with Metro 

to amend the RTP as necessary to update the project description and associated modeling 

analysis.

Submitted by Hvidston, Robin Submittal 16222 Related Documents

16222.01 I strongly oppose this plan! It is overreaching and TAKES THE MONEY FROM THE PEOPLE 

without transparency and oversight. This is an outrage!!!

Comment noted.

256
holdID Comment Response 

Submitted by Jaiswal, Anna Submittal 16128 Related Documents

16128.01 The vast majority of the projects listed for San Bernardino County are highway widening / 

capacity expansion projects. Since it's been well-documented in the research that capacity 

expansion has a long-term effect of increasing traffic because of the induced demand 

principle, I do not understand why we are still adding highway capacity in San Bernardino 

County. It additionally doesn't make sense because, according to the CMP appendix of the 

document, San Bernardino County has relatively low levels of traffic congestion (only one 

of the top 100 congested intersections in the SCAG area); so even if I believed that highway 

capacity expansion would relieve congestion, it wouldn't make sense to invest billions of 

dollars toward it in San Bernardino County. Furthermore, this draft document has a 

resounding theme and goals of providing transportation options in the SCAG region, and 

puts a lot of emphasis on Active Transportation, complete streets, and transit. That is 

commendable, but yet the sheer amount of highway widening projects in the Project List 

does not fit the goals of the overall plan. Besides the issue of the widening itself, I am also 

very disappointed in the fact that the project descriptions for most of these projects do not 

mention anything about whether complete streets considerations will be made in the 

design of these projects. So I assume most likely they will not. It typically is near impossible 

to track down the status of these projects or find an avenue to give input on the design 

until the engineers say it is "too late to accept input to change the design." So I am still at a 

loss as to how to ensure that complete streets consideration will be given to highway 

projects as they're designed. This should be the role of regional agencies such as SCAG and 

SANBAG - to facilitate a conversation and an input process to ensure that all road users are 

considered in the design of these projects before it's too late.

Comment noted. The six county SCAG region is a vast and diverse region, geographically as 

well as demographically. Accordingly, the 2016 RTP/SCS recognizes that a "one size fits all" 

approach will not work for our region. So, the plan is multi-modal and aims to address 

transportation needs of all segments of our society across our expansive region by 

expanding and enhancing travel choices. The plan creates opportunities to engage in a 

healthy and active lifestyle through a significant increase in investment in Active 

Transportation modes. At the same time, the plan also recognizes that over 90% of the 

trips will continue to rely on our roadways, particularly in places like Riverside and San 

Bernardino counties. So, strategic improvements to our roadways to improve safety and 

congestion must be a part of any sensible long term plan. In addition, investments to our 

roadways also serve to benefit other modes including transit and active transportation. 

Furthermore, with the renewal of Deputy Directive 64-R2, Complete Streets - Integrating 

the Transportation System, Caltrans has placed an even greater emphasis towards the 

consideration of pedestrians and bicyclists throughout all phases of a project. Therefore, it 

is only a matter of time before complete street ideals are fully integrated as part of the 

capital improvement projects. It should also be noted that many of these roadway 

improvement projects are part of the commitment made by the counties to their residents 

in passing the local option sales tax measures that fund many of these projects. In 

addition, active transportation plans from local jurisdictions are included as part of the 

Plan and are beyond the project listings provided by the CTCs. These include the Imperial 

County Bicycle Plan, Western Riverside County Non-Motorized Transportation Plan, 

Coachella Valley Non-Motorized Transportation Plan, CVLink, and the San Bernardino 

County Non Motorized Transportation Plan.

Submitted by Jatich, Thomas Submittal 16127 Related Documents

16127.01 I do not approve the Mileage-Based User Fee to provide additional funding. This will result 

in additional infrastructure cost to determine the distances traveled by each motor vehicle. 

It is much cheaper to just raise the gasoline tax. The amount of gasoline/diesel fuel used is 

directly proportional to the amount of wear and tear caused to our roads. Heavy vehicles 

use more fuel and should pay their fair share. Taxing by miles subsidizes these inefficient 

vehicles. Raise the gas tax and adjust it for inflation.

Given the potential complexities associated with a transition from gas taxes to a mileagebased user fee, the 2016 RTP/SCS does not assume revenue from a mileage-based user fee 

prior to 2025. The Plan also does not assume a specific mileage recording method. A 

number of mileage recording method alternatives were recommended by the California 

Road User Charge Technical Advisory Committee (TAC) for consideration as part of the 

Road Charge Pilot Program. Additionally, the TAC recommended that the pilot evaluate the 

cost of administration and fee collection. The TAC adopted goals for the pilot evaluation 

addressing equity and fairness, noting: "All Californians should pay their fair share for 

using the transportation system – just like they pay their fair share of use for water or 

electricity. A fair system may account for vehicle type and size (e.g., fuel efficiency and 

weight) and consider incentives for lower income and disadvantaged Californians." Solely 

raising the gas tax does not address the long term revenue challenges. Current corporate 

average fuel economy (CAFE) standards call for a increase from 29 miles per gallon to 54.5 

miles per gallon by model year 2025. This will approximately double vehicle fuel efficiency 

and cut gas tax revenues in half. In order to meet California greenhouse gas emission 

reduction goals, the California Air Resources Board indicates that the new vehicle fleet will 

need to be primarily composed of advanced technology vehicles such as such as electric 

and fuel cell vehicles by 2035 in order to have nearly an entire advanced technology fleet – 

that is, both new and used vehicles – by 2050.

257
holdID Comment Response 

Submitted by Jatich, Thomas Submittal 16127 Related Documents

16127.02 The OCTA is violating the intent of Measure M2 by constructing the high-occupancy toll 

(HOT) lanes on the 405 and using the toll revenue as a never-ending source of funding. 

When the voters approved Measure M2 in 2006, they were told that the funding would add 

one addition general-purpose lane in each direction on the 405. Nothing was said about 

building a toll road. There was no mention in the ballot language of “toll lanes” as an 

eligible project to receive funding. In fact, while “toll lane” language was once considered 

to be included, it was removed for fear that Measure M2 would not pass. The OCTA knew 

that the voters would not approve a toll road. They intentionally hid this information from 

the voters because they knew that Measure M2 would not pass if it were included. The 

OCTA claims that Caltrans is forcing them to build the toll road, but this is not true. In 

October 2013, the OCTA recommended Alternative 3 that would add one general-purpose 

lane and convert the existing one-lane car pool to a two-lane toll road. After the uproar 

from the citizens of Orange County and the mayors of Costa Mesa, Fountain Valley, 

Huntington Beach, Westminster, Los Alamitos, and Seal Beach, the OCTA changed their 

recommendation in December 2013 to Alternative 1 that would add one general-purpose 

lane. Subsequently Caltrans granted the OCTA’s original recommendation by approving the 

toll road in Alternative 3. On April 27, 2015 the OCTA Board of Directors voted to take the 

lead on implementing both the general-purpose lane and the HOT lanes. Instead of funding 

from Caltrans, the additional cost for the HOT lanes will be financed by the tolls. Carpools 

of two or more will only remain free for three years. By building the toll road, the OCTA will 

be collecting tolls forever. After the toll road cost is covered, the OCTA will be using this 

revenue for other purposes. Maybe this was the OCTA’s plan all along? When the voters 

approved Measure M2, they did not approve a never-ending source of funding for the 

OCTA. Per the Renewed Measure M Transportation Investment Plan, “voter approval [is 

required] for any major changes to the Plan.” Constructing a toll road and creating this new 

source of revenue for the OCTA is a violation of Measure M2.

Comment noted. A recent OCTA Board report dated October 12, 2015 indicates that 

Measure M2 funds will be used for the mixed-flow lanes additions, that both OCTA and 

Caltrans will seek additional state and federal discretionary grant funding for the tolled 

portion of the project, and that Caltrans will provide $82 million toward the construction 

of the project. The report also indicates that net excess toll revenues (after payment of 

operations and maintenance on the express lanes including toll collection costs, debt 

service for obligations payable from tolls, funding of debt and project reserves, and 

required repayment of TIFIA loan) will be used in accordance with an expenditure plan 

developed by Caltrans and OCTA. In addition to other stipulations, the expenditure plan 

terms include restricting the use of net excess revenues for projects that maintain or 

improve the safety, operation, or travel reliability of any transportation mode in the 

corridor, or provide for improved travel options in the corridor.

Submitted by Jolles, Mark Submittal 16199 Related Documents

16199.01 I am concerned that the verbiage in the RTP document has almost a "spin" tone to it, 

oftentimes sugarcoating what are some very serious issues. It is my understanding that the 

document is supposed to provide an objective perspective without such a heavy 

promotional bias. It is not supposed to be a sales document but rather an objective 

analysis. I suggest that the SCAG staff review the text for language that may not be 

construed as objective and edit it for a less bias tone. Specifically, if one surveys those that 

pay for and use the regional transportation system, SCAG may find their viewpoints quite 

different and far more critical than what is presented in the RTP text.

Comment noted.

258
holdID Comment Response 

Submitted by Jolles, Mark Submittal 16200 Related Documents

16200.01 Some illustrations in the SCAG document portray one third of street capacity used for 

vehicle storage (parked cars) while high capacity transit vehicles are stuck in mixed traffic. 

This may not be a good model to provide as an example of smart streets or improved 

mobility.

Comment noted. The RTP/SCS encourages our partner County Transportation 

Commissions to pursue Bus Rapid Transit (BRT), BRT Lite, and designated bus only lanes 

where appropriate. The images that you refer to, accompany the Livable Corridors 

Concept. This is a concept that is meant to support High Quality Transit Areas served 

primarily by bus transit. These corridors cross large portions of the region, many of which 

still rely heavily on passenger cars. The strategies are meant to leverage improved bus 

service, increased active transportation investment, and more sustainable land uses.

16200.02 Some illustrations in the SCAG document portray one third of street capacity used for 

vehicle storage (parked cars) while high capacity transit vehicles are stuck in mixed traffic. 

This may not be a good model to provide as an example of smart streets or improved 

mobility.

Comment noted. This comment pertains to the visuals displayed in Chapter 5, which, 

accompany the Livable Corridors Concept. This is a concept that is meant to support High 

Quality Transit Areas served primarily by bus transit. These corridors cross large portions 

of the region, many of which still rely heavily on passenger cars. The strategies are meant 

to leverage improved bus service, increased active transportation investment, and more 

sustainable land uses.

Submitted by Jolles, Mark Submittal 16201 Related Documents Link

16201.01 The SCAG discussion about BRT (Bus Rapid Transit Technology) and LRV (Light Rail Vehicle 

Technology) is not accurate. Light rail technology was developed prior to pavement and 

rubber tires, only steel on steel was an existing option. Since the implementation of 

efficient paving methods, development of rubber tires, development of the internal 

combustion engine, and increases in vehicle ownership, LRV lost much of its benefit and 

became obsolete. "True" BRT is a technology that replaces LRV at about one third the cost. 

It is faster, safer, more nimble, higher capacity, with less noise and vibration, and avoids the 

costly maintenance of rail and catenary systems. Please include along with my comment, 

the attached photos with examples of "true" BRT as a competitive replacement to LRV at 

about 1/3 the cost. Please also include the following links to provide accurate information 

about BRT (Bus Rapid Transit) Technology - Social Environmental Economic Impacts, People 

Oriented Sustainable Urban Mobility, Best Practices. WHAT IS BRT? - INSTITUTE FOR 

TRANSPORTATION & DEVELOPMENT POLICY https://www.itdp.org/library/standards-andguides/the-bus-rapid-transit-standard/what-is-brt/ NATURAL RESOURCES DEFENSE 

COUNCIL - SWITCHBOARD 

http://switchboard.nrdc.org/blogs/kbenfield/how_bus_rapid_transit_is_clean.html WORLD 

RESOURCES INSTITUTE - ROSS CENTER - http://www.wricities.org/media/video/bus-rapidtransit-social-environmental-and-economic-impacts

Comment noted. Chapter 1 does not discuss the relative cost effectiveness of transit 

capital investment strategies, technologies, or propulsion systems. Final alignments, 

station stop locations, propulsion systems, and/or technologies employed in any major 

transit capital investment are ultimately the responsibility of the individual project sponsor 

and determined through a project-specific planning and environmental analysis process.

259
holdID Comment Response 

Submitted by Jolles, Mark Submittal 16201 Related Documents Link

16201.02 The SCAG discussion about BRT (Bus Rapid Transit Technology) and LRV (Light Rail Vehicle 

Technology) is not accurate. Light rail technology was developed prior to pavement and 

rubber tires, only steel on steel was an existing option. Since the implementation of 

efficient paving methods, development of rubber tires, development of the internal 

combustion engine, and increases in vehicle ownership, LRV lost much of its benefit and is 

considered obsolete. "True" BRT is a technology that replaces LRV at about one third the 

cost. It is faster, safer, more nimble, higher capacity, with less noise and vibration, and 

avoids the costly maintenance of rail and catenary systems. Please include along with my 

comment, the attached photos with examples of "true" BRT as a competitive replacement 

to LRV at about 1/3 the cost. Please also include the following links to provide accurate 

information about BRT (Bus Rapid Transit) Technology - Social Environmental Economic 

Impacts, People Oriented Sustainable Urban Mobility, Best Practices. WHAT IS BRT? - 

INSTITUTE FOR TRANSPORTATION & DEVELOPMENT POLICY 

https://www.itdp.org/library/standards-and-guides/the-bus-rapid-transit-standard/what-isbrt/ NATURAL RESOURCES DEFENSE COUNCIL - SWITCHBOARD 

http://switchboard.nrdc.org/blogs/kbenfield/how_bus_rapid_transit_is_clean.html WORLD 

RESOURCES INSTITUTE - ROSS CENTER - http://www.wricities.org/media/video/bus-rapidtransit-social-environmental-and-economic-impacts

Comment noted. Chapter 2 does not discuss the relative cost effectiveness of transit 

capital investment strategies, technologies, or propulsion systems. Final alignments, 

station stop locations, propulsion systems, and/or technologies employed in any major 

transit capital investment are ultimately the responsibility of the individual project sponsor 

and determined through a project-specific planning and environmental analysis process. A 

brief discussion of the economic benefits of investing in public transportation occurs on 

page 26, but the discussion does not analyze these benefits by propulsion technology or 

mode.

Submitted by Jolles, Mark Submittal 16202 Related Documents Link

16202.01 The SCAG discussion about BRT (Bus Rapid Transit Technology) and LRV (Light Rail Vehicle 

Technology) is not accurate. Light rail technology was developed prior to pavement and 

rubber tires, only steel on steel was a viable option. Since the implementation of efficient 

paving methods, development of rubber tires, development of the internal combustion 

engine, and increases in vehicle ownership, LRV lost much of its benefit and became 

obsolete. "True" BRT is a technology that replaces LRV at about one third the cost. It is 

faster, safer, more nimble, higher capacity, with less noise and vibration, and avoids the 

costly maintenance of rail and catenary systems. Please include along with my comment, 

the attached photos with examples of "true" BRT as a competitive replacement to LRV at 

about 1/3 the cost. Please also include the following links to provide accurate information 

about BRT (Bus Rapid Transit) Technology - Social Environmental Economic Impacts, People 

Oriented Sustainable Urban Mobility, Best Practices. WHAT IS BRT? - INSTITUTE FOR 

TRANSPORTATION & DEVELOPMENT POLICY https://www.itdp.org/library/standards-andguides/the-bus-rapid-transit-standard/what-is-brt/ NATURAL RESOURCES DEFENSE 

COUNCIL - SWITCHBOARD 

http://switchboard.nrdc.org/blogs/kbenfield/how_bus_rapid_transit_is_clean.html WORLD 

RESOURCES INSTITUTE - ROSS CENTER - http://www.wricities.org/media/video/bus-rapidtransit-social-environmental-and-economic-impacts

Comment noted. Chapter 3 does not discuss the relative cost effectiveness of transit 

capital investment strategies, technologies, or propulsion systems. Final alignments, 

station stop locations, propulsion systems, and/or technologies employed in any major 

transit capital investment are ultimately the responsibility of the individual project sponsor 

and determined through a project-specific planning and environmental analysis process.

260
holdID Comment Response 

Submitted by Jolles, Mark Submittal 16203 Related Documents Link

16203.01 LRV COST BENEFIT ANALYSIS Regarding the LRV systems that SCAG discusses in the RTP, I 

am concerned that these systems are incurring cost without a comparative benefit. The 

"benefit", as described in the attached FTA and FHWA documents is what attracts ridership 

(primarily discretionary) and additional associated economic development to 

transportation facilities. Without this "benefit", the LRV discussed in the SCAG document 

imposes investment and operational costs on the public without a mobility or economic 

advantage. Specifically with the Expo Line LRV discussed in the attachments, the local 

agency, METRO, turned down a $2.5 billion %50 federal match and developed the project 

without a "benefit". The ridership of existing LRV lines without this "benefit", is equal to 

what prior bus service provided. I suggest that future transportation improvement projects 

provide a verifiable calculated "benefit", as is the industry standard, in order to obtain and 

leverage significant federal matching funds and meet economic development goals. As an 

additional note, "true" BRT (Bus Rapid Transit Technology) developed correctly, provides a 

higher mobility "benefit" than LRV (Light Rail Vehicle Technology) at one third the cost. It is 

my understanding that a benefit is a "calculated" improvement in travel time, cost, and 

convenience, as compared to alternatives.

User benefit, as referenced in the correspondences attached to this comment, was a 

project level SAFETEA-LU era performance measure used as a project selection criteria by 

the Federal Transit Administration (FTA) as part of applications for grant funds awarded 

per 49 U.S.C. 5309 (b), the New Starts program. This program funds major capital 

investments for public transportation. The measure was one of about 12 used during this 

period, and consisted of projected travel time savings divided by projected passenger 

miles travelled on the corridor in question. A further cost effectiveness measure consisted 

of the proposed project cost divided by the quotient of the above measure. These 

measures were employed throughout the SAFETEA-LU era. After the passage of MAP-21, 

the FTA began a rulemaking process, culminating with the changes to 49 C.F.R. Part 611, 

effective April 9, 2013. The newly adopted project level performance measures include 

mobility improvements, environmental benefits, congestion relief, economic 

development, land use, and cost effectiveness. These measures each account for 

approximately 8.33% of the quantitative scoring of a New Starts grant application. The cost 

effectiveness measure used for rating grant applications per the new FTA rulemaking no 

longer employs the previous user benefits model; instead capital and operating and 

maintenance costs are divided by annual linked trips. The mobility measure also no longer 

employs user benefits, instead employing a weighted measure of projected total linked 

trips by discretionary and dependent passengers. The previous user benefit measures are 

no longer applicable to project development, as part of the grant application process. 

Additionally, as is discussed in the correspondence from FTA’s Dwayne Meeks attached by 

the commenter, dated January 23, 2007, the SAFETEA-LU era performance measures used 

in the New Starts process were intended to measure the benefits of interventions to a 

particular corridor, usually by means of a particular fixed guideway project. When offcorridor feeder bus network service changes were implemented in the cited forecast, they 

interfered with the ability of the forecasters to determine the independent benefits of the 

project in question. The 2016 RTP/SCS is an integrated, system level package of strategies 

and investments, so it is not possible to use these kinds of corridor level measures to 

ascertain the performance of any particular project or strategy in the plan. Similar to the 

earlier findings of Mr. Meeks, it would be impossible to discern the impacts of one project 

or strategy from a neighboring project or strategy. Furthermore, final alignments, station 

stop locations, propulsion systems, and/or technologies employed in any major transit 

capital investment are ultimately the responsibility of the individual project sponsor.

261
holdID Comment Response 

Submitted by Jolles, Mark Submittal 16204 Related Documents Link

16204.01 LRV COST BENEFIT ANALYSIS Regarding the LRV systems that SCAG discusses in the RTP, I 

am concerned that these systems are incurring cost without a comparative benefit. The 

"benefit", as described in the attached FTA and FHWA documents is what attracts ridership 

(primarily discretionary) and additional associated economic development to 

transportation facilities. Without this "benefit", the LRV discussed in the SCAG document 

imposes investment and operational costs on the public without a mobility or economic 

advantage. Specifically with the Expo Line LRV discussed in the attachments, the local 

agency, METRO, turned down a $2.5 billion 50% federal match and developed the project 

without a measured "benefit". The ridership of existing LRV lines without this "benefit", is 

equal to what prior bus service provided. I suggest that future transportation improvement 

projects provide a verifiable calculated "benefit", as is the industry standard, in order to 

obtain and leverage significant federal matching funds and meet economic development 

goals. As an additional note, "true" BRT (Bus Rapid Transit Technology) developed correctly, 

provides a higher mobility "benefit" than LRV (Light Rail Vehicle Technology) at one third 

the cost. It is my understanding that a benefit is a "calculated" improvement in travel time, 

cost, and convenience, as compared to alternatives.

User benefit, as referenced in the correspondences attached to this comment, was a 

project level SAFETEA-LU era performance measure used as a project selection criteria by 

the Federal Transit Administration (FTA) as part of applications for grant funds awarded 

per 49 U.S.C. 5309 (b), the New Starts program. This program funds major capital 

investments for public transportation. The measure was one of about 12 used during this 

period, and consisted of projected travel time savings divided by projected passenger 

miles travelled on the corridor in question. A further cost effectiveness measure consisted 

of the proposed project cost divided by the quotient of the above measure. These 

measures were employed throughout the SAFETEA-LU era. After the passage of MAP-21, 

the FTA began a rulemaking process, culminating with the changes to 49 C.F.R. Part 611, 

effective April 9, 2013. The newly adopted project level performance measures include 

mobility improvements, environmental benefits, congestion relief, economic 

development, land use, and cost effectiveness. These measures each account for 

approximately 8.33% of the quantitative scoring of a New Starts grant application. The cost 

effectiveness measure used for rating grant applications per the new FTA rulemaking no 

longer employs the previous user benefits model; instead capital and operating and 

maintenance costs are divided by annual linked trips. The mobility measure also no longer 

employs user benefits, instead employing a weighted measure of projected total linked 

trips by discretionary and dependent passengers. The previous user benefit measures are 

no longer applicable to project development, as part of the grant application process. 

Additionally, as is discussed in the correspondence from FTA’s Dwayne Meeks attached by 

the commenter, dated January 23, 2007, the SAFETEA-LU era performance measures used 

in the New Starts process were intended to measure the benefits of interventions to a 

particular corridor, usually by means of a particular fixed guideway project. When offcorridor feeder bus network service changes were implemented in the cited forecast, they 

interfered with the ability of the forecasters to determine the independent benefits of the 

project in question. The 2016 RTP/SCS is an integrated, system level package of strategies 

and investments, so it is not possible to use these kinds of corridor level measures to 

ascertain the performance of any particular project or strategy in the plan. Similar to the 

earlier findings of Mr. Meeks, it would be impossible to discern the impacts of one project 

or strategy from a neighboring project or strategy. Furthermore, final alignments, station 

stop locations, propulsion systems, and/or technologies employed in any major transit 

capital investment are ultimately the responsibility of the individual project sponsor.

262
holdID Comment Response 

Submitted by Jolles, Mark Submittal 16205 Related Documents Link

16205.01 FORECAST CONCERNS. I think that the SCAG RTP uses constrained forecasts that are 

obscuring a significant amount of forecasted regional travel demand. This seems to be most 

apparent as a capacity shortage in the region's core. The result I think is congestion being 

pushed outward toward suburban communities and economic development going 

elsewhere. While it may be a bit embarrassing, I strongly urge the SCAG staff to provide 

local decisionmakers both constrained and unconstrained forecasts in the RTP. In the 

planning performed by other MPO's the two forecasts are often compared. This makes it 

possible for decisionmakers to measure the effectiveness of varying constrained plans to 

meet long range need. Moreover, this approach provides local governments the ability to 

strategically capture more economic growth and the resultant tax base benefits region 

wide can be significant.

Comment noted. SCAG will consider providing constrained and unconstrained forecasts in 

future RTP/SCSs.

Submitted by Jolles, Mark Submittal 16207 Related Documents Link

16207.01 FINANCIAL CONSTRAINTS & CARPOOL LANES The continued regional investment in 

additional carpool lane capacity is of concern. Firstly, this program diverts huge resources 

from competitive alternatives. Second, it is adding to the number of single vehicle (SOV) 

trips being taken. When carpoolers shift to additional lanes, this increases the capacity for 

single occupancy vehicles (SOV) in the main lanes. These lanes quickly fill. When the system 

overall exceeds capacity, as in the SCAG region, these additional single occupancy vehicles 

overload connecting roads. Congestion is simply moved and increases system wide. It 

appears to be relieved in one area only to migrate to adjoining streets. Relieving one 

bottleneck simply moves it down the road to the next bottleneck. A thorough "system" 

analysis of road capacity changes reveals this. A more effective objective is to improve 

mobility on the highway system without adding traffic or congestion elsewhere. I suggest 

using existing lanes for carpool lanes rather than adding new lanes and redirecting the 

saved resources to develop competitive transit alternatives. Also, I suggest referring local 

agencies to the Victoria Transport Policy Institute, http://www.vtpi.org/ for resources to 

facilitate modeshift from SOV to other alternatives. The average pedestrian on transit 

utilizes three square meters of public space. The average SOV vehicle occupies 115 square 

meters of public space. This is forty times more space for the same trip. Imposing this extra 

infrastructure cost on the taxbase and local business makes the region uncompetitive 

against other regions where the percentage of SOV trips is much less. The best example of 

resources ill spent on carpool lanes may be the $4.2 billion I-405 widening from I-105 to 

Highway 101. The multi-project 12 year traffic delay from the construction was several 

times the benefit calculated. The delay is greater now than before the project and traffic is 

increased on connecting surface streets. Overall mobility in the corridor has declined. The 

$4.2 billion would have been better spent making higher capacity improvements. An 

extensive "true" BRT (Bus Rapid Transit) system is one example.

The 2016 RTP/SCS directs approximately $15.5 billion (out of a total $556.5 billion) 

towards improvements in the region's managed lane system, which includes carpool lanes 

and high-occupancy toll (HOT) lanes. Managed lanes are a key part of the Plan's overall 

system management approach to manage congestion and optimize the performance of 

the transportation system. Managed lanes support transit, ridesharing, and other 

transportation demand management strategies, with the goal of reducing singleoccupancy vehicle (SOV) trips. A study released by Metro on May 26, 2015, identified 

improvements in safety, traffic congestion, vehicle and person throughput, and travel time 

on the 405 corridor after the addition of carpool lanes through the Sepulveda Pass.

Submitted by Jolles, Mark Submittal 16263 Related Documents Link

16263.01 INACCESSIBLE INFORMATION The document is too Verbose. This makes it difficult to read. 

Important facts and figures are buried in lengthy compound and run-on sentences. The 

meaning of the text is unclear to the reader. Hopefully this is not intentional. The 19 million 

citizens paying for the $560 billion plan deserve more clarity.

Comment noted.

263
holdID Comment Response 

Submitted by Jolles, Mark Submittal 16263 Related Documents Link

16263.02 FACTS & FIGURES Facts and figures buried in the text are better presented in graphic 

format. Important points are more readable in bullet or outline format. Clarity and brevity 

attracts more readers. Simple objective language instills confidence that issues and facts 

are not handpicked or manipulated

Comment noted.

16263.03 SPIN AND OBJECTIVITY The tone of the document has too much spin. It is not supposed to 

be a sales document but rather an objective analysis. If SCAG surveys those that pay for 

and use the regional transportation system, they may find viewpoints quite different and 

far more critical than what is presented in the RTP text. Language that may not be 

construed as objective should be edited out.

Comment noted.

16263.04 ILLUSTRATION EXAMPLES - SMART STREETS Some illustrations in the SCAG document 

portray one third of street capacity used for vehicle storage (parked cars) while high 

capacity transit vehicles are stuck in mixed traffic. This may not be a good model to provide 

as an example of smart streets or improved mobility.

Comment noted. This comment pertains to the visuals displayed in Chapter 5. The RTP/SCS 

encourages our partner County Transportation Commissions to pursue Bus Rapid Transit 

(BRT), BRT Lite, and designated bus only lanes where appropriate. The images that you 

refer to, accompany the Livable Corridors Concept. This is a concept that is meant to 

support High Quality Transit Areas served primarily by bus transit. These corridors cross 

large portions of the region, many of which still rely heavily on passenger cars. The 

strategies are meant to leverage improved bus service, increased active transportation 

investment, and more sustainable land uses.

16263.05 LRV TECHNOLOGY The SCAG discussion about BRT (Bus Rapid Transit Technology) and LRV 

(Light Rail Vehicle Technology) is not accurate. Light rail technology was developed prior to 

pavement and rubber tires, only steel on steel existed as an option. Since the development 

of paving systems, rubber tires, the internal combustion engine, and increases in vehicle 

ownership, LRV has lost much of its benefit and is obsolete against newer technologies.

Final alignments, station stop locations, propulsion systems, and/or technologies 

employed in any major transit capital investment are ultimately the responsibility of the 

individual project sponsor and determined through a project-specific planning and 

environmental analysis process.

16263.06 "TRUE" BRT "True" BRT is a technology that replaces LRV at about one third the cost. It is 

faster, safer, more nimble, higher capacity, with less noise and vibration, and avoids 

construction and maintenance of rail and catenary systems. Please include with my 

comment, the attached photos and links with examples of "true" BRT as a competitive 

replacement to LRV at about 1/3 the cost. WHAT IS "TRUE" BRT? - INSTITUTE FOR 

TRANSPORTATION & DEVELOPMENT POLICY https://www.itdp.org/library/standards-andguides/the-bus-rapid-transit-standard/what-is-brt/ NATURAL RESOURCES DEFENSE 

COUNCIL - SWITCHBOARD 

http://switchboard.nrdc.org/blogs/kbenfield/how_bus_rapid_transit_is_clean.html WORLD 

RESOURCES INSTITUTE - ROSS CENTER - http://www.wricities.org/media/video/bus-rapidtransit-social-environmental-and-economic-impacts

Comment noted. Final alignments, station stop locations, propulsion systems, and/or 

technologies employed in any major transit capital investment are ultimately the 

responsibility of the individual project sponsor.

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Submitted by Jolles, Mark Submittal 16263 Related Documents Link

16263.07 BENEFIT ANALYSIS STANDARDS Regarding LRV systems that SCAG discusses in the RTP, I am 

concerned that these systems are incurring cost without a comparative benefit. The 

"benefit", as described in the attached FTA and FHWA documents is what attracts ridership 

(primarily descretionary) and associated economic development. Without this "benefit", 

the LRV discussed in the SCAG document imposes investment and operational costs on the 

public without a mobility or economic advantage.

User benefit, as referenced in the correspondences attached to this comment, was a 

project level SAFETEA-LU era performance measure used as a project selection criteria by 

the Federal Transit Administration (FTA) as part of applications for grant funds awarded 

per 49 U.S.C. 5309 (b), the New Starts program. This program funds major capital 

investments for public transportation. The measure was one of about 12 used during this 

period, and consisted of projected travel time savings divided by projected passenger 

miles travelled on the corridor in question. A further cost effectiveness measure consisted 

of the proposed project cost divided by the quotient of the above measure. These 

measures were employed throughout the SAFETEA-LU era. After the passage of MAP-21, 

the FTA began a rulemaking process, culminating with the changes to 49 C.F.R. Part 611, 

effective April 9, 2013. The newly adopted project level performance measures include 

mobility improvements, environmental benefits, congestion relief, economic 

development, land use, and cost effectiveness. These measures each account for 

approximately 8.33% of the quantitative scoring of a New Starts grant application. The cost 

effectiveness measure used for rating grant applications per the new FTA rulemaking no 

longer employs the previous user benefits model; instead capital and operating and 

maintenance costs are divided by annual linked trips. The mobility measure also no longer 

employs user benefits, instead employing a weighted measure of projected total linked 

trips by discretionary and dependent passengers. The previous user benefit measures are 

no longer applicable to project development, as part of the grant application process. 

Additionally, as is discussed in the correspondence from FTA’s Dwayne Meeks attached by 

the commenter, dated January 23, 2007, the SAFETEA-LU era performance measures used 

in the New Starts process were intended to measure the benefits of interventions to a 

particular corridor, usually by means of a particular fixed guideway project. When offcorridor feeder bus network service changes were implemented in the cited forecast, they 

interfered with the ability of the forecasters to determine the independent benefits of the 

project in question. The 2016 RTP/SCS is an integrated, system level package of strategies 

and investments, so it is not possible to use these kinds of corridor level measures to 

ascertain the performance of any particular project or strategy in the plan. Similar to the 

earlier findings of Mr. Meeks, it would be impossible to discern the impacts of one project 

or strategy from a neighboring project or strategy. Furthermore, final alignments, station 

stop locations, propulsion systems, and/or technologies employed in any major transit 

capital investment are ultimately the responsibility of the individual project sponsor and 

determined through a project-specific planning and environmental analysis process.

16263.08 FUNDING - MISSED OPPORTUNITIES Specifically with the Expo Line LRV discussed in the 

attachments, the local agency, METRO, turned down a $2.5 billion 50% federal match and 

developed the project without a "benefit". (see attached correspondence) The ridership of 

existing LRV lines without this "benefit", is equal to what prior bus service provided. I 

suggest that future transportation improvement projects provide a verifiable calculated 

"benefit", as is the industry standard, in order to obtain and leverage federal matching 

funds and meet economic development goals.

Comment noted. Final alignments, station stop locations, propulsion systems, and/or 

technologies employed in any major transit capital investment are ultimately the 

responsibility of the individual project sponsor.

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Submitted by Jolles, Mark Submittal 16263 Related Documents Link

16263.09 COMPETITIVE TRANSIT ALTERNATIVES As an additional note, "true" BRT (Bus Rapid Transit 

Technology) developed correctly, provides a higher mobility "benefit" than LRV (Light Rail 

Vehicle Technology) at one third the cost. It is my understanding that a benefit is a 

"calculated" improvement in travel time, cost, and convenience, as compared to 

alternatives.

Comment noted.

16263.10 IMPORTANT FORECASTS EXCLUDED The SCAG RTP uses constrained forecasts that are 

obscuring a significant amount of forecasted regional travel demand. This has manifested 

itself most apparently as unmet demand and a capacity shortage in the region's core. 

Congestion is being forced outward toward suburban communities. Economic development 

is leaving the region due to the shortage and poor mobility.

Comment noted. SCAG will consider providing constrained and unconstrained forecasts in 

future RTP/SCSs.

16263.11 PROVIDE UNCONSTRAINED FORECASTS I urge SCAG staff to provide decisionsmakers both 

constrained and unconstrained forecasts in the RTP. For other MPO RTPs it is standard to 

include both forecasts for comparison. This gives decisionmakers the tools necessary to 

measure the effectiveness of constrained plans against unconstrained need. Local 

governments then have the ability to strategically capture economic growth. Tax base 

benefits and growth regionwide are typically significant.

As part of the Plan develop process, SCAG staff presented decision makers with forecasts 

of the capital costs for transit, state highways, and arterials, as well as operations and 

maintenance costs and debt service payments over the 25-year planning timeframe for a 

projected total investment need of $556.5 billion. Staff also presented how much money is 

reasonably expected to be available to build, operate, and maintain the region’s surface 

transportation system over the 25-year planning timeframe. An initial core revenue 

forecast comprising existing local, state, and federal sources totaled $356.1 billion through 

FY2039-40. The difference between the expenditure forecast total ($556.5 billion) and the 

core revenue forecast total ($356.1 billion) is $200.4 billion. The Draft 2016 RTP/SCS 

proposes to invest $556.5 billion through the forecast horizon year of 2040 to significantly 

improve every component of our multi-modal transportation system, including much 

needed investment for the operation and maintenance of our existing system. The funding 

of the Plan is based on $356.1 billion in core revenue sources and $200.4 billion in new 

revenue sources that are reasonably expected to be available over the plan period. 

Reasonably available revenues include short-term adjustments to state and federal gas 

excise tax rates and the long-term replacement of gas taxes with mileage-based user fees 

(or equivalent fuel tax adjustment). These and other categories of funding sources were 

identified as reasonably available on the basis of their potential for revenue generation, 

historical precedence and the likelihood of their implementation within the time frame of 

the Plan. In accordance with state and federal requirements, the 2016 RTP/SCS financial 

plan estimates how much funding will be needed to implement transportation investment 

needs, as well as operate and maintain the transportation system as a whole over the life 

of the Plan. The Plan demonstrates that there is a balance between the estimated costs of 

the projects and programs described in the Plan and revenue sources reasonably expected 

to be available for transportation investments.

16263.12 CARPOOL LANES - SYSTEM ANALYSIS The continued regional investment in additional 

carpool lane capacity is of concern. Firstly, this program diverts huge resources from 

competitive alternatives. Second, it is adding to the number of single vehicle (SOV) trips 

being taken.

The 2016 RTP/SCS directs approximately $15.5 billion (out of a total $556.5 billion) 

towards improvements in the region's managed lane system, which includes carpool lanes 

and high-occupancy toll (HOT) lanes. Managed lanes are a key part of the Plan's overall 

system management approach to manage congestion and optimize the performance of 

the transportation system. Managed lanes support transit, ridesharing, and other 

transportation demand management strategies, with the goal of reducing singleoccupancy vehicle (SOV) trips.

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Submitted by Jolles, Mark Submittal 16263 Related Documents Link

16263.13 CONGESTION MAKING INCENTIVES When carpoolers shift to additional lanes, this increases 

the capacity for single occupancy vehicles (SOV) in the main lanes. These lanes quickly fill. 

When the system overall exceeds capacity, as in the SCAG region, these additional single 

occupancy vehicles overload connecting roads. Congestion is simply moved and increases 

systemwide. It may appear to be relieved in one area only to migrate to adjoining areas. 

Relieving one bottleneck simply moves it down the road to the next bottleneck. A thorough 

"system" analysis of road capacity changes reveals this.

Comment noted. The 2016 RTP/SCS includes a wide variety of transportation strategies 

and investments, recognizing that improvements to all transportation modes are 

necessary in order to reduce congestion and improve the transportation system in the 

SCAG region. These include transportation demand management, transportation systems 

management, active transportation investments, land use strategies and multi-modal 

capital and operating improvements.

16263.14 CARPOOL LANE ALTERNATIVES A more effective objective is to improve mobility on the 

highway system without adding traffic or congestion overall. I suggest using existing lanes 

for carpool lanes rather than adding new lanes; then redirect the saved resources to 

develop competitive transit alternatives. Also, I suggest referring local agencies to the 

Victoria Transport Policy Institute, http://www.vtpi.org/ for resources to facilitate 

modeshift from SOV to other alternatives.

Comment noted. The 2016 RTP/SCS includes a wide variety of transportation strategies 

and investments, recognizing that improvements to all transportation modes are 

necessary in order to reduce congestion and improve the transportation system in the 

SCAG region. These include transportation demand management, transportation systems 

management, active transportation investments, land use strategies and multi-modal 

capital and operating improvements.

16263.15 REGIONAL COMPETITIVENESS The average pedestrian on transit utilizes three square 

meters of public space. The average SOV vehicle occupies 115 square meters of public 

space. This is forty times more space for the same trip. Imposing this extra infrastructure 

cost on the tax base and on local business makes the region uncompetitive. Many 

competing regions have a percentage of SOV trips that is much less, especially in the core.

Comment noted. The Plan includes a range of investment to increase mobility options.

16263.16 $4.2 BILLION The best example of resources ill spent on carpool lanes may be the $4.2 

billion I-405 widening from I-105 to Highway 101. The 12 year multi-project traffic delays 

from construction exceeded by several times the benefit calculated. The delay is now 

greater than before the project and traffic is increased on connecting surface streets. 

Overall mobility in the corridor has declined. Would the $4.2 billion have been better spent 

making higher capacity improvements. An extensive "true" BRT (Bus Rapid Transit) system 

is one example of a more effective long term investment.

The “I-405 Corridor Evaluation (I-405 Sepulveda Pass Improvement Project Before/After 

Study),” released by Metro on May 26, 2015, identified improvements in safety, traffic 

congestion, vehicle and person throughput, and travel time on the 405 corridor after the 

addition of carpool lanes through the Sepulveda Pass. The full report, along with the Metro 

Board report, can be found at: 

http://boardarchives.metro.net/BoardBox/BB2015/2015_05_May/150526_I_405_Sepulve

da_Pass_Improvements_Project_Evaluation.pdf

Submitted by Leland, Dolly Submittal 16363 Related Documents Link

16363.01 We are here to give unqualified support to this RTP. It is a great job. We are grateful, of 

course, that the 710 North Gap is within the RTP and we're here to present documents that 

we presented to Caltrans in the study currently on-going for the 710 for the funding and 

Caltrans approval.

Comment Noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description and associated modeling analysis.

16363.02 The 710 is critical to these plans because it is not only in the RTP right now, the tunnel, but 

it's also in the Measure R that was passed by the people several years ago and it's actually 

coming to fruition now. There is money, specifically, voted on $780,000,000 by the people 

of this County. We think that is a pretty good mandate to build this tunnel so it's voter 

approved.

Comment Noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description and associated modeling analysis.

Submitted by Newman, Robert Submittal 16300 Related Documents Link

16300.01 With the proposed crowding into the cities, contagious diseased are rapidly transmitted. 

Urban crowding leads to interpersonal conflict in our culture.

Comment noted.

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Submitted by Newman, Robert Submittal 16300 Related Documents Link

16300.02 Do not get in the way of farming and ranching in California. We need food that is 

domestically produced, thus preserving the sovereignty of America.

Comment noted. SCAG is committed to preserving farm and ranch land in Southern 

California. SCAG is engaging numerous stakeholders as it creates a Natural Lands 

Conservation Plan. This strategic and comprehensive approach allows the region to meet 

its housing and transportation needs, while ensuring that important natural lands, 

farmlands and water resources are protected. Please see our Natural/Farm Lands 

Appendix for more information. 

http://scagrtpscs.net/Documents/2016/draft/d2016RTPSCS_NaturalFarmLands.pdf

Submitted by Nig, Pat Submittal 16198 Related Documents

16198.01 Please do not get rid of bus routes 187, 191, 193 I am a senior and live in CVME mobile 

home park San Juan Capistrano

The decision to add or cut fixed route service is ultimately the responsibility of the 

operating agency. In this case, that is the Orange County Transportation Authority (OCTA).

Submitted by Norman, Kirsty Submittal 16139 Related Documents

16139.01 Looking at the proposed projects for Riverside and San Bernardino county projects I'm 

seeing very little transit and ATP improvements. The fact that SoCal is very much relying on 

cars is not something to be proud of. The IE in particular has a great need for more transit 

and ATP facilities, it's a shame that nothing is included in this project.

Comment noted. The six county SCAG region is a vast and diverse region, geographically as 

well as demographically. Accordingly, the 2016 RTP/SCS recognizes that a "one size fits all" 

approach will not work for our region. So, the plan is multi-modal and aims to address 

transportation needs of all segments of our society across our expansive region by 

expanding and enhancing travel choices. The plan creates opportunities to engage in a 

healthy and active lifestyle through a significant increase in investment in Active 

Transportation modes. At the same time, the plan also recognizes that over 90% of the 

trips will continue to rely on our roadways, particularly in places like Riverside and San 

Bernardino counties. So, strategic improvements to our roadways to improve safety and 

congestion must be a part of any sensible long term plan. In addition, investments to our 

roadways also serve to benefit other modes including transit and active transportation. 

Furthermore, it should be noted that many of these roadway improvement projects are 

part of a commitment made by the counties to their residents in the passing of local 

option sales tax measures that fund many of these projects. In addition, active 

transportation plans from local jurisdictions are included as part of the Plan and are 

beyond the project listings provided by the CTCs. These include the Imperial County 

Bicycle Plan, Western Riverside County Non-Motorized Transportation Plan, Coachella 

Valley Non-Motorized Transportation Plan, CVLink, and the San Bernardino County Non 

Motorized Transportation Plan. The 2016 RTP/SCS also includes nine large capital projects 

and seven bus corridor enhancements in Riverside and San Bernardino Counties.

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Submitted by OKeefe, Eva Submittal 16158 Related Documents

16158.01 My biggest issues are the proliferation of unregulated Sober Homes in residential 

neighborhoods bringing more drugs into the community, not helping the addicts 

themselves, not offering any protections to the addicts themselves, changing the 

residential character of the communities, preventing children to grow up in neighborhoods 

with other children but now growing up with communities full of adults and the clustering 

in certain cities. My next issue is the incredible growth of our homeless population and the 

unsanitary conditions that brings to our cities. I frequently witness public urination and 

defecation, which is unsanitary and brings disease into the communities. I believe that 

homeless people should be given housing and that not accepting housing is not a choice 

because their actions affect ALL of us. I am a mother of young children. Every time we go 

out, we see someone passed out, sleeping on the street, defecating and urinating. This is 

not the example I want to set for my children. Our homeless deserve better and they 

deserve housing weather they want it or not.

Zoning housing for specific needs, such as transitional living shelters and group homes, is 

determined by local jurisdictions. SB 375 does not require that a jurisdiction's land use 

policies and regulations, including building codes and design guidelines, need to be 

consistent with the RTP or SCS. While the SCS is intended to provide a regional policy 

foundation that local governments may build upon if they so choose, local jurisdictions 

maintain local land use authority. In regard to homeless populations, there are a number 

of local programs that are looking to develop funding for permanent housing for homeless 

individuals and families. Currently while State law designates homelessness as a mental 

health issue rather than a land use issue, a number of jurisdictions are looking to provide 

permanent housing for certain homeless populations, such as those with disabilities or 

medical issues. As with transitional living shelters and group homes, the SCS is intended to 

provide a regional policy foundation that local governments may build upon if they so 

choose, local jurisdictions maintain local land use authority.

Submitted by Oliver, Bill Submittal 16051 Related Documents

16051.01.1 The plan is good, BUT does anyone think outside the box. What makes you think that you 

can continue to add lanes to the current roads forever. Every plan that has been put 

forward in the last 10 to 20 years has been to widen the freeway and add more HOV/ 

Carpool lanes. It has only created delays during the construction and by the time of 

completion the increase of newer traffic has delays in the same area. ("Orange Crush" 

I5,57,22)

The 2016 RTP/SCS is rooted upon a multi-modal approach towards addressing congestion 

and provides individuals with various options ranging from transit, bicycling, and walking 

as a means towards reducing single occupancy demand (SOV) demand on our highways 

and local arterials. As one of strategies for highways and arterials, the system 

management approach serves to address congestion by reducing demand and increasing 

efficiency without the need for expansion through the use of transportation system 

management (TSM) and transportation demand management (TDM) strategies. Examples 

of TSM/TDM include providing real time traffic information, advanced ramp metering, and 

incentivizing carpooling.

16051.01.2 There is an old military saying. Proper Prior Planning Prevent Poor Performance. For years I 

have asked WHY NO MONO RAIL above THE CENTER OF THE FREEWAYS? How much space 

is required? how many passengers per mile. If you build it, they will use it. We need to 

provide AFFORDABLE MASS TRANSIT to the suburbs to will reduce the pressure on the 

major arteries. The north has BART and it works. We can due a lot better.

The Draft 2016 RTP/SCS includes a significant investment in public transportation across 

the region through 2040, and allocates roughly 22% of capital spending to public 

transportation, and roughly 57% of operations and maintenance spending. The Draft 2016 

RTP/SCS also allocates an additional 15% of capital spending to passenger rail. These 

investments include a wide variety of major capital projects, in a variety of communities, 

and along a wide variety of corridors. Final alignment decisions are the responsibility of 

project sponsors.

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Submitted by Robinson, Betty Submittal 16253 Related Documents

16253.01 I greatly object to a non-elected government entity making decisions on transit and land 

use, among other things, that will negatively impact southern California in so many ways, 

including the addition of a huge financial burden to an already fiscally stressed area. You 

say that you encourage public comment but I dare say but for a very few persistent and 

patriot citizens NO ONE knows about your plans---if the plans were in ballot form, they 

would go down in flames. SCAG and other similar, secretive groups are why the American 

public SO distrusts this Administration. I recommend that SCAG be dissolved and their 

burdensome plans be discarded. Planning should be done on a local basis with 

transparency and consent of the majority of residents.

Comment noted. SCAG’s Regional Council and Policy Committee Members are elected 

Mayors, City Council members and County Supervisors from jurisdictions throughout the 

SCAG region. The cities and counties appoint the elected officials to represent them at 

SCAG’s Regional Council and Policy Committees. SCAG’s Regional Council and Policy 

Committee meetings are open to the public and publicly noticed. SCAG's Regional Council 

meetings are also available via live streaming on SCAG’s website, www.scag.ca.gov, and 

are archived for on-demand viewing online. The names of the Regional Council and Policy 

Committee Members are posted on SCAG’s website. SCAG has provided significant 

opportunities for input to the Draft 2016 RTP/SCS. This included, but was not limited to, 

the SCAG RTP/SCS website, policy committee meetings, a series of twenty-three open 

houses held during Summer 2015, and nineteen additional workshops and public hearings 

held following the release of the Draft 2016 RTP/SCS. As required by law, SCAG provided 

advance notice of public hearings on the Draft 2016 RTP/SCS, including publication in 

newspapers throughout the region, to give as many interested parties as possible the 

opportunity to attend and provide input. These hearings and workshops were held in 

every county in the region to solicit input from various interests such as residents, elected 

officials, representatives of public agencies, community organizations, and environmental, 

housing and business stakeholders.

16253.02 I greatly object to a non-elected government entity making decisions on transit and land 

use, among other things, that will negatively impact southern California in so many ways, 

including the addition of a huge financial burden to an already fiscally stressed area. You 

say that you encourage public comment but I dare say but for a very few persistent and 

patriot citizens NO ONE knows about your plans---if the plans were in ballot form, they 

would go down in flames. SCAG and other similar, secretive groups are why the American 

public SO distrusts this Administration. I recommend that SCAG be dissolved and their 

burdensome plans be discarded. Planning should be done on a local basis with 

transparency and consent of the majority of residents.

Comment noted. SCAG’s is governed by an 86-member Regional Council, which is 

comprised of duly elected Mayors, City Council Members and County Supervisors from 

jurisdictions throughout the SCAG region. These elected officials meet monthly as 

members of SCAG’s Regional Council and Policy Committees, and they have discussed the 

proposed Draft 2016 RTP/SCS at regular and special meetings and will consider the Final 

Plan for adoption at their April 7, 2016 meeting. The roster of Regional Council members 

can be found on SCAG's website at http://scag.ca.gov.

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Submitted by Romero, Vivian Submittal 16362 Related Documents

16362.01 I want to start by addressing some of the concerns about the traffic flow that continues to 

plague residence in my neighborhood. I'm off the SR60 Freeway the Pomona freeway, have 

been for years, my family has been there for years. Actually, my family purchased a home 

in 1964 and the developer never disclosed that the SR60 was even going to be graded in 

the future. Over the years there have been issues with all the residents and there is many 

original homeowners there that had issues with and complaints with flooding, cracked 

foundations, they've had windows that have vibrated, windows that have loosened off 

their frames. Some residents' problems have been exacerbated with heavy rains due to the 

runoff from the freeway lanes, the cracked Arroyo drain canal causes flooding and ground 

water issues to rise over the two-foot broken Arroyo drain cracked wall between the 

freeway and backyards into homes that get submerged leading into people's living rooms 

like it happened back then in, probably, all the residents homes there, and at the bottom of 

our street most recently about, I would say, two and a half -- no, three and a half years ago 

where cars were submerged in water at the bottom of Arroyo and I have photographs of all 

of this. I did submit them to Caltrans as well. They did repair some of the cracked canal and 

they removed some of debris that is there. There is also a cracked sound barrier wall that 

was it's original to the freeway as is the cracked pavement along the SR60 Freeway behind 

the homes. As you may or may not know, there is no irrigation between Veil, Markland and 

Paramount Boulevard which would help with the air quality issues. There is an industrial 

park on the Monterey Park side which is the Edison Sub Basis Station which it has plans 

right now, I believe, for expansion. There is a proposed market place that is supposed to go 

and it has come to some of the residents' hears that Caltrans plans to expand those ramps 

to be in line with the Paramount Bridge expansion -- I'm sorry, with the Ramp Expansion 

Project to align with the new bridge that was compromised during the tanker fire and so 

the freeway is going to come and encroach more upon the homes.

Comment noted. We will share your concerns with Caltrans.

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Submitted by Romero, Vivian Submittal 16362 Related Documents

16362.02 Without that irrigation in that part of the corridor you've got another issue which gets 

exacerbated over there which is constant exhaust and fumes from tailpipes and soot and 

dirt and dust. You know, you have got a poor wall design that was constructed in the early 

1960s. You've got excessive inhalation of tailpipe fumes, you're breathing the soot the gas 

the dust, the particles are going into people's lungs every minute of the day. You've got 

cars that are queuing going westbound in the morning probably starting at 5:30 in the 

morning. I had to go to Sacramento the other day the cars were queuing starting at 5:45 in 

the morning and it doesn't stop until, probably, 9:30. Then going eastbound you've got cars 

queuing starting around 3 p.m. going all the way up until about 6:30 p.m. So, every minute 

of every day people are breathing and having health problems and then you have no trees 

oxygenating your air and you have no irrigation there because I've talked to District 7 and 

I've talked to Mike Miles and Debra Wong and various people at Caltrans and I asked "Why 

don't we have any landscape there? Can we put any landscape there?" And they said, "No, 

we have no irrigation there." You know, how can we mitigate some of the noise? How do 

we help with the fine particulates that everybody is breathing? How are people going to 

have a quality night's rest when you've got your house shaking because of the vibration? 

They've done some noise studies there houses are shaking constantly. You hear the trucks, 

the 18-wheeler trucks, you know, going over the lanes of the cracked payment on the SR60 

which is, again, original payment, and when you have an empty 18-wheeler shaking you've 

got these booms going on. You hear the tire pop and we've signed petitions and we've 

asked, you know, and had formal complaints signed and we get -- we get nothing, you 

know, it falls on deaf ears.

Comment noted. The PEIR for the 2016 RTP/SCS is a programmatic document that that 

provides a region-wide assessment of the potential significant environmental effects of 

implementing goals, policies, strategies, programs, and projects included in the Draft 2016 

RTP/SCS. As a programmatic environmental document for a region-wide, long-range Plan, 

the PEIR is not intended to conduct local impacts or provide information in detail sufficient 

for project or site-specific analyses. Project or site-specific environmental analysis to 

assess impacts at the project level must be separately assessed for each individual project. 

That said, the comments regarding concerns regarding this portion of SR 60 will be 

forwarded to Caltrans, District 7.

16362.03 So, we've got cars and traffic, we've got air quality issues, we've got flooding issues, we've 

got a host of environmental issues here and those are the primary focus of my, you know, 

and my reason for coming to you today. Because there are many concerns about the 

constituents and the people, the residents, like myself, in my neighborhood and -- so I 

looked at your plan, it did not include any kind of a project in our area between the 710 and 

the 605.

Comment noted. Upon review of the Project List Appendix, financially constrained RTP 

projects as related to SR-60 between I-710 and SR-605 were not identified. However, as 

part of the strategic portion of the Project List, specifically RTP ID# S1120044 proposes an 

HOV lane on SR-60 between I-710 and US-101. However the project is financially 

unconstrained in which funding has not been identified for RTP ID# S1120044. We will 

share your comment with Metro and Caltrans for consideration in future needs 

assessment studies.

16362.04 It should be that you look at disadvantaged communities which that area has moderate to 

low income and we're significantly impacted by the movement of freight and goods 

through our corridor through the SR60, you know, all of this movement of freight and 

goods coming through, you know, to eastern parts of the country and through different 

counties is coming through the SR60. And because we're severely impacted by all of these 

air quality issues and human quality issues and environmental injustices, I would ask that 

you please consider the route 60 because it is a very congested corridor. There is not even 

an HOV lane there. There is no -- nothing to remedy some of the issues and the excessive 

traffic, vibration, sound. So, please, in your further studies I would ask that you please 

consider some funding and in the very near future for that corridor. SCAG has a 

responsibility, especially, for disadvantaged communities, to consider those. And I 

anticipate that in the next round that you'd be a little more astute and a little more 

sensitive to these things.

Thank you for your comment. Impacts of the RTP/SCS on disadvantaged communities are 

analyzed in the Environmental Justice Appendix, and show that the Plan results in positive 

outcomes for low income and minority communities as a result of the Plan. Specifically for 

the SR-60 corridor, there are currently multiple transportation improvement proposals 

under consideration, including transit options which do not preclude the potential for an 

East-West Freight Corridor. SCAG recognizes the multiple needs associated with the 

corridor—serving the residential population including addressing environmental justice 

concerns while also serving commercial/industrial activities. Ongoing evaluations of the 

corridor will continue to address these issues.

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Submitted by Sandler, Irene Submittal 16226 Related Documents Link

16226.01 The Sepulveda Reversible Lane and Improvement Project came into existence in 1998 as an 

Los Angeles Dept. of Transportation project. For many years It has been a component of 

the SCAG RTIP's and SCAG RTP'S. LA 996425 can be found in both the SCAG 2016 PEIR and 

the 2016 SCAG RTP/SCS documents. Funding has been set aside for this Project for about 

18 years. The project scope has been modified over time, and it is now substantially 

complete. However, It is still part of both the Draft 2016 PEIR Impact Report and the Draft 

2016 RTP/SCS Plans .The one component that is not completed is the unnecessary 

Sepulveda Reversible Lane in the Mulholland Tunnel on Sepulveda Blvd in CD 5 and 11, and 

Metro District 7. The I-405 Sepulveda Pass Improvement Project, ( funded by Federal, State, 

County, and City governments), added new Skirball ramps to the I-405 and an additional 

northbound lane on Sepulveda Blvd itself, leading from the new I-405 Skirball northbound 

exit ramp northward to the Skirball Bridge. Northbound Sepulveda traffic flows well. 

Northbound traffic going toward/through the Mulholland Tunnel does not present a traffic 

problem. The Reversible Lane Project in the Mulholland Tunnel is not needed.

Comment noted. Since the completion of the improvements on I-405, additional 

improvement needs in this corridor, including Sepulveda Boulevard, are being further 

examined. SCAG will work with Metro and Caltrans to reflect the ultimate improvement 

configuration in this corridor in the future RTP/SCS amendments or updates as appropriate.

Submitted by Segura, Melody Submittal 16054 Related Documents

16054.01.1 I believe the RTP does a good job of addressing the future needs of millenials. Myself and 

my peers are more conscious about the environment and the effects our actions have on 

the environment. Therefore, we are interested in activities that reduce our impact on the 

environment. Specifically, we are more interested in hybrid cars, more efficient public 

transit and living closer to where we work.

Comment noted. The Mobility Innovations appendix provides an overview of how SCAG 

analyzed a wide range of technology innovations that could potentially impact travel 

behavior and locational choices in the region over the next 25 years. In addition, the SCAG 

Clean Cities Coalition works with regional transit operators to improve the fuel efficiency 

of transit vehicles. In addition to new bus and rail transit services such as Metro Rail 

expansion in LA County and rapid bus improvements in Orange, Riverside, and San 

Bernardino Counties, the RTP/SCS recommends operational and accessibility strategies to 

improve the efficiency and effectiveness of transit. This includes transit signal priority, 

inter-county fare agreements (universal transit pass), real-time passenger information 

systems, and first/last mile strategies. One of the 2016 RTP/SCS land use strategies is to 

focus future housing and employment growth in High-Quality Transit Areas (HQTA), which 

moves the region towards more compact, mixed-use development leading to more 

opportunities for walking and biking, more transit use, and shorter auto trips. While the 

SCS is intended to provide a regional strategy that local governments may consider if they 

so choose, local jurisdictions maintain local land use authority.

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Submitted by Segura, Melody Submittal 16054 Related Documents

16054.01.2 In regards to transportation and jobs, I think the plan should include a strategy to attract 

more jobs to areas like the Inland Empire, where several people commute out to other 

areas for jobs. Personally, I think the more jobs that are available for residents near the 

areas where they live, the less they will have to commute long distances for jobs.

Comment noted. The 2016 RTP/SCS in and of itself is a job creation engine and the jobs 

created by the plan would come either directly from investments in transportation 

infrastructure (jobs from construction, operations, and maintenance) or from the 

improvements made to the transportation network (jobs from network efficiencies and 

related increases in regional economic and business competitiveness). SCAG develops the 

RTP/SCS in close collaboration with stakeholder agencies such as the county 

transportation commissions, which are responsible for planning, managing, and prioritizing 

the portfolio of transportation investments in their respective counties, as well as the 

allocation of locally generated transportation revenues. One of the benefits of an 

improved transportation system is the impact on commutes. Chapter 7 of the 2016 

RTP/SCS provides some insight on how transportation improvements increase the region's 

economic competitiveness. Reducing travel time allows firms to hire from a larger 

geographic area. This effectively increases the firm’s labor market – particularly in a large 

urban area like the SCAG region where reductions in commuting time can yield access to 

many more potential employees. Likewise, if the region’s transportation system supports 

more efficient commutes, then employers will be encouraged to draw from larger labor 

market pools, and if that larger employee pool allows firms to hire better employees, 

eventually those firms will move into the region in response to those improved hiring 

prospects.

16054.01.3 Also, the Inland Empire has a large trucking and logistics industry and as a result, there is 

heavy truck traffic in the area. One concern I have is pollution. It would be great if the plan 

could include guidelines or recommendations for these vehicles so their impact on air 

quality is reduced or if companies could reduce the trips they generate in the area.

2016-2040 RTP/SCS Goods Movement Environmental Strategy emphasizes coordinated 

strategies that support state and regional initiatives to reduce harmful pollutants from 

goods movement activities. The Plan continues to focus on the long-term goal of a zeroemission goods movement system where technically feasible and economically viable, 

while also integrating near zero-emissions technologies that serve as bridging options to 

continue to reduce emissions. Broad deployment of zero-and near zero-emission 

transportation technologies in the 2023 to 2040 timeframe is a critical and significant 

undertaking with technological, cost and operational challenges. In recognizing this, the 

2016 RTP/SCS outlines a roadmap for developing and deploying needed technologies, 

along with key action steps for public sector agencies to help move the region to that 

objective.

Submitted by Snyder, Kristi Submittal 16057 Related Documents

16057.01.1 I live in Rancho Cucamonga commute to Orange then husband continues to Long Beach. 

We can not afford to be penalized for commuting a long distance. We already pay our fair 

share in gas taxes for the STATE, LOCAL & FED governments'. People will not want to buy 

real estate in Rancho Cucamonga if they are fined. Our real estate prices will go down.

Gas tax revenues, in real terms, are actually in decline as tax rates (both state and federal) 

have not been adjusted in more than two decades while the number of more fuel efficient 

and alternative powered vehicles continue to grow. The Plan identifies several new 

funding sources that are reasonably expected to be available and are included in the 

financially constrained plan. These sources include adjustments to existing state and 

federal gas tax rates and a long-term replacement of state and federal gas taxes with a 

mileage-based user fee to maintain the historical purchasing power of the gas tax.

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Submitted by Snyder, Kristi Submittal 16057 Related Documents

16057.01.2 Ditch the speed train to Northern California. No one wants it and no one will use it. I see 

trains go by in Orange with only a few people on them. Cancel any train/bus schedules that 

are not profitable.

The 2016 RTP/SCS includes investments in our region's rail network in order to provide 

additional capacity for interregional travel in our state as its population continues to grow. 

This includes investments in existing commuter and passenger rail systems in addition to 

future CA High Speed Train (HST). The CA HST is mandated to operate without a public 

subsidy. Rail ridership in our state and region consistently has increased year over year 

except during the Great Recession.

16057.01.3 Do not spend money you do not have. I have to live within a budget and so should the 

Government. You should be trying to reduce your spending and living within your means. 

Kristi Snyder 14078 San Dimas Lane Rancho Cucamogna, CA 91739 951-966-5044

In accordance with state and federal requirements, the 2016 RTP/SCS includes a financial 

plan that estimates how much funding will be needed to implement transportation 

investment needs, as well as operate and maintain the transportation system as a whole 

over the life of the Plan. The Plan must demonstrate that there is a balance between the 

estimated costs of the projects and programs described in the Plan and revenue sources 

reasonably expected to be available for transportation investments.

Submitted by Swan, Cari Submittal 16269 Related Documents

16269.01 I find this entire plan, all the assumptions and vision to be fundamental WRONG and 

repulsive! This UNELECTED board has far overstepped what should "reasonably" be the role 

of SCAG....although I would argue that there is NO ROLE for SCAG in a representative 

government! I fundamentally disagree with virtually all the assumptions being spewed as 

fact with respect to: 1) "Climate Change" which is nothing more than weather and has been 

scientifically disproven; 2) land use---I have yet to meet the "millennial" who actually 

WANTS to live in a stack-n-pack box (I happen to be the parent of 3 millenials!). There isn't 

anything I read in this document that I can agree with or be even remotely comfortable!! 

The only simple way I can summarize is that if Federal transportation money is tied to 

having these plans (RTP & SCS) then you should go back to the drawing board, and do AS 

LITTLE AS POSSIBLE AND GET THE HECK OUT OF OUR LIVES!!! SCAG is systematically 

destroying the wonderful communities of Southern Calif and attempting to socially 

engineer our lives! What a WASTE of taxpayer money. If SCAG is truly concerned about 

repairing the issues of transportation & infrastructure, how about trying to fix the MASSIVE 

unfunded liabilities caused by excessive employee union commitment throughout the 

state! Take care of this problem and EVERYTHING else will fix itself!

Comment noted.

Submitted by Tarkington, Ann Submittal 16365 Related Documents Link

16365.01 NO MORE HIGH DENSITY!!! I live in Huntington Beach, CA. and it is NOW A NIGHTMARE!!! 

No one really does substantial planning for anything!!! I only found the info for this this 

afternoon. I only have a few hours to respond!! The majority of people have had it with 

HD!! It has to STOP NOW!!

Comment noted. SCAG’s SCS is built upon input from local jurisdictions and SB 375 

legislation does not require a jurisdiction’s land use policies and regulations, including its 

general plan, be consistent with the SCS. For the purposes of SB 375, and reducing 

Greenhouse Gas (GHG) emissions and Vehicle Miles Traveled (VMT), SCAG, in some cases, 

altered small area land use assumptions to better reflect recent trends occurring in many 

transit-rich areas of the region. The "Forecasted Regional Development Types" maps have 

been developed for the purpose of modeling performance. While the SCS is intended to 

provide a regional policy foundation that local governments may build upon if they so 

choose, local jurisdictions maintain local land use authority.

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Submitted by Teutsch, Carol Submittal 16162 Related Documents Link

16162.01 Is Metro going to do the right thing for the people of Los Angeles as they consider the 710 

north tunnel? The preponderance of evidence from scientific sources addresses great 

concern about the significant negative impact of the 710 tunnel on our air quality and 

human health. I highlight health concerns as you continue to deliberate on the future of the 

tunnel proposal. More detailed health comments and scientific literature can be seen in my 

DEIR comments. I wanted to bring to your attention two recent articles authored by leading 

researchers in the field of environmental health. The first is by Dr. Scott Fruin from the 

University of Southern California entitled “LA Metro/CalTran’s 710 tunnel plan will take 

your breath away. Literally.” 

(http://www.wpra.net/files/public/WPRA%20News%20PDFs/WPRA2016winNL.pdf). 

According to the article, the tunnel will result in concentrated pollution for many nearby 

residents, visitors, and sensitive receptors. The author points out valid critiques of the 

model used in the EIR and points to the omission of critical traffic related pollutants in the 

studies done by the transportation agency. According to Civil Engineer Gregory M. 

Rowangould’s analyses, models, and maps, one can see very clearly near roadway pollution 

gradients based on specific transportation pollution sources. These findings, based on 

detailed data, are very relevant to an examination of health impacts. Metro/Caltrans maps 

seem to show overall regional pollution at a much lower resolution and lower specificity 

and predictive models on air quality seem to rely heavily on general pollution reduction 

measures which is a deficit in their model. For transparency and for adequate consideration 

of health effects, a comparison of the data and reconciliation should be performed by 

independent scientists. The second article by Dr. Andrea Hricko, faculty from the 

Environmental Health Department in Preventive Medicine from the University of Southern 

California, reports on her team’s National Institute of Environmental Health Sciences 

research showing the important negative impact of diesel pollution on health.

Comment Noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description and associated modeling analysis.

16162.02 “Two decades of NIEHS-funded research (http://www.ncbi.nlm.nih.gov/pubmed/8179653) 

have clearly linked serious health risks with exposure to elevated levels of fine particulate 

matter and other components of diesel exhaust, especially for those who live close to 

highways and roads (http://www.ncbi.nlm.nih.gov/pubmed/17307103” Importantly, 

children’s lungs improved as pollution dropped. We must think of the health of our 

children, all our region’s children, as we consider this massive infrastructure proposal. 

Metro/Caltrans needs to be transparent about how port traffic would use this 710 north 

tunnel route. Otherwise their impact assessments are wrong and misleading. As citizens, 

we are apalled when we see large corporations and government agencies flagrantly 

disregarding the legally binding agreements, such as the clean port mitigation standards 

and looking to overturn them. ("Port of Los Angeles has failed to meet pollution-cutting 

measures" Los Angeles Times.) Trust in government and transportation agencies 

evaporates with this kind of illegal maneuvering. Increasing scientific evidence is being 

published about increased mortality with noise at certain decibel levels and the physiologic 

impacts of noise on sleep, stress hormones and blood pressure. (The risks of noisy roads LA 

Times Jan 9, 2016) PLEASE RESTORE FAITH IN THE REGION’S TRANSPORTATION DECISION 

MAKING BODIES BY REMOVING THE 710-NORTH TUNNEL FROM ALL PROJECT LISTS 

FOREVER. BUILD US A STRONG MULTIMODAL TRANSIT PLAN THAT WILL BE USED BY ALL TO 

IMPROVE THE ECONOMIC STRENGTH OF THE REGION, AND TRULY IMPROVE OUR AIR 

QUALITY AND PROTECT OUR HEALTH.

Comment Noted. SCAG recognizes that the project is currently pending environmental 

review. As with other projects included within the Project List, when the SR-710 North 

Study EIR/EIS process is complete and a locally preferred alternative (LPA) is identified in 

the final environmental document SCAG will work with Metro to amend the RTP/SCS as 

necessary to update the project description and associated modeling analysis.

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Submitted by Tripoli, Vicki Submittal 16195 Related Documents

16195.01 Single person auto travel is rapidly becoming unsustainable. It would be a waste of scarce 

finances to expand or upgrade this method of transportation. Allowing this option to decay 

encourages the use of more sustainable public transportation in which most of the budget 

should be used.

Comment noted. One of the many goals of the RTP/SCS is provide people with options 

when it comes to travel. We believe, 90 percent of the trips will continue to rely on our 

roadways. Therefore, investments to maintain and strategically add capacity to our 

roadways will continue to be critical to meet the needs of our region.

Submitted by West, Janet Submittal 16229 Related Documents

16229.01 I oppose this plan and SCAG in it's entirety. SCAG is a big government, top down entity that 

most of the public has no knowledge that it even exists. It's activities are tyrannical 

socialism whereby they believe they know what's best for us lesser people. The last thing 

we need is another layer between local and state government. Stop the nonsense.

Comment noted. SCAG’s Regional Council and Policy Committee Members are elected 

Mayors, City Council members and County Supervisors from jurisdictions throughout the 

SCAG region. The cities and counties appoint the elected officials to represent them at 

SCAG’s Regional Council and Policy Committees.

Submitted by Anonymous Submittal 16357 Related Documents

16357.01 Okay. First and foremost, SCAG is a Corporation and because SCAG is a corporation I do not 

consent to any of your mandates, edicts or demands. You need to show me the contract 

that I signed as a willing consenting adult before we can even have this conversations. 

Secondly, SCAG is not constitutional. Nowhere in the Constitution does it talk about JPA it's 

a made-up term to steal government away from people at the local level. There is nothing 

good about Regional Government. When you take 191 cities and put them altogether in 

one body which is what SCAG is, you have created a massive government. There is not one 

big government in history that has ended well for the people. This whole SCAG Regional 

Transportation process proves why Regionalism is terrible for this country. An associate of 

mine who is not here we discussed -- he and I discussed sitting down and reading the 

thousands of page that are in the SCAG RTP/SCS and EIR documents we were going to 

make notes and eventually publish a report refuting the plan.

Comment noted. Founded in 1965, the Southern California Association of Governments 

(SCAG) is an association of local governments and agencies that voluntarily convene as a 

forum to address regional issues. Under federal law, SCAG is designated as a Metropolitan 

Planning Organization (MPO) and under state law as a Regional Transportation Planning 

Agency and a Council of Governments. SCAG’s is governed by an 86-member Regional 

Council, which is comprised of duly elected Mayors, City Council Members and County 

Supervisors from jurisdictions throughout the SCAG region. These elected officials meet 

monthly as members of SCAG’s Regional Council and Policy Committees, and they have 

discussed the proposed Draft 2016 RTP/SCS at regular and special meetings and will 

consider the Final Plan for adoption at their April 7, 2016 meeting. The roster of Regional 

Council members can be found on SCAG's website at http://scag.ca.gov.

16357.02 The whole idea of reading the document that is published in the report is not even possible 

given the time constraints; secondly, even if we were able to get the report complete we 

would then have to go to through 191 elected representatives in 191 different cities and try 

to convince them on a side to vote, that's 191 people and we only have several months to 

do all of this. So, we have to take the localism and local government if the same thing were 

happening in a local city we would only have to convince three people to agree with us on 

the plan. That is three versus 191. That example that I just read is the very reason why this 

regionalism has to stop, it completely shuts we the people out of progress.

Comment noted. SCAG provided a 60 day public review and comment period beginning 

December 4, 2015, and concluding on February 1, 2016, for the Draft 2016 RTP/SCS and 

the PEIR. There are additional opportunities to provide comment, including speaking at 

upcoming meetings of the Regional Council and Policy Committees or speaking with your 

Regional Council representative. To find your SCAG board representative, please visit 

SCAG's website, www.scag.ca.gov SCAG’s Regional Council and Policy Committee members 

are elected Mayors, City Council Members and County Supervisors from jurisdictions 

throughout the SCAG region. The cities and counties appoint the elected official to 

represent them at SCAG’s Regional Council and Policy Committees. SCAG’s Regional 

Council and Policy Committee meetings are open to the public and publicly noticed. SCAG 

Regional Council meetings are also available via live streaming on SCAG’s website, 

www.scag.ca.gov.

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Submitted by Anonymous Submittal 16357 Related Documents

16357.03 Now, let's get into what the plan is based on. The entire plan is based on sustainability. 

Now, when you ask these planners what sustainability is they are likely to say something 

along the lines of making development that fits the current needs while preserving the 

ability for future generations to meet their own needs. What the hell does that even mean? 

Seriously, half the time you ask a planner what sustainability is they usually use the word 

sustainability in their answer which tells me they don't even know what it means. So, I have 

spent four years trying to figure out what sustainability actually is and I have the answer. 

Sustainability is rational. It is being forced to use less of everything. Less water, they've got 

that covered already. Less energy, they are attempting that as renewable. Renewable 

energy is a giant total capital scam where the government takes one of the looters and 

crops up field industries by that trade [sic]. Less food, that's been worked on by the United 

Nations right now.

Comment noted.

16357.04 Less mobility, I cannot believe you guys think we are so stupid that people are actually 

going to believe that going from a car to a bus or a bike is somehow getting around quicker. 

Seriously, that is insane. Less freedom, freedom is choice and you are destroying our 

choices with this plan. And let's talk about those choices. You are acting like you are doing 

us a favor by providing us a bike lane, buses and trains that most people want nothing to 

do with. However, this is all a huge scam.

Comment noted.

16357.05 Last year the state attempted to cut gasoline in half by 50 percent the bill was called SB350. 

The bill passed but the gasoline language was taken out of the bill. We have confirmation 

the state will be trying to pass that again this year in 2016. So yes, the State of California is 

trying to get us out of our cars. We are seeing all of this planning right now because you 

know the main option that everyone wants is going to be to eliminated. So, stop with this 

garbage that you are doing us a favor. This is a surrounded big government that is waging 

war against us. You are not doing anybody any favors.

Comment noted.

16357.06 Lastly, I want to address this lie about the millennials how my generation wants to walk and 

ride bikes everywhere and live in little shoebox apartments. First off, my generation is 

glued to their phones so they are completely disengaged, as a result they are not coming to 

these meetings and demanding what you are saying, they are demanding. I have yet to see 

this ever happening.

Comment noted.

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Submitted by Anonymous Submittal 16357 Related Documents

16357.07 Secondly, we are told the millennials want to spend lots of money with small apartment. 

How is that going to happen? We were screwed by older generations when they told us 

that we must go to college. Not only is a college degree worthless now, but it has put all the 

young people in debt so they're not going to be spending $400,000 on a so-called luxury 

apartment. The truth is every single city is increasing the number of housing units and we 

have a president that has opened up the borders and brings in illegal aliens and refugees in 

the different wars that are going on. Those people need a place to live if they are going to 

be here. That is the real reason why we are seeing all this building. America is being 

transformed into a Third World Country and that is evident by the fact that the American 

dream of a golden card is being destroyed. If you want to know what Obama's fundamental 

transformation looks like this is it. All this planning this Central planning that you are 

engaged in this is communism. Mouths trying to sell Russia in a 5-year, 10-year and 20-year 

planning cycle. I mean, come on, this is such a joke. How is it you are throwing this at our 

faces.

A lack of housing options is one of the contributing factors to the high cost of housing, 

particularly in areas where there are few affordable housing units available. While the 

RTP/SCS is a regional document, local land use decisions are made at the jurisdictional (city 

and county) level. SCAG encourages jurisdictions to look at different strategies to ensure 

that there is sufficient housing for its current and future population, otherwise it will lead 

to a multitude of problems, such as overcrowding and unsafe conditions.

Submitted by Anonymous Submittal 16358 Related Documents

16358.01 But here's the thing so we've got a really hugely growing population. I mean, side to side all 

your feelings about everything else, we have the second worst congestion in the country. 

So, it is taking a long time to get around and that actually does put a burden on people that 

have less money. I mean, I just moved back to California I used to be a homeowner, I can't 

afford like a $2,000 apartment and to have a car and drive around and transition between 

careers. So, being able to jump on something quickly the obligation to not own a car would 

really help me so I could afford a $2,000 apartment and I could get around. So, here is my 

thing, what is the solution, you guys? We have so many people in this environment.

Comment noted. The RTP/SCS begins with a vision for the region that states: "In our vision 

for the region in 2040, many communities are more compact and connected seamlessly by 

numerous public transit options, including expanded bus and rail service. People live closer 

to work, school, shopping and other destinations. Their neighborhoods are more walkable 

and safe for bicyclists. They have more options available besides driving alone, reducing 

the load on roads and highways." The integrated land use and transportation strategies in 

the plan aim to build more transit infrastructure, increase existing service, improve 

housing affordability by strategically increasing supply, and improve congestion through 

innovative market-based strategies.

279