RTP Guidelines Update 10 26 2009 document Comment Table Please note all page numbers are those of the 10 26 09 released draft unless otherwise specified Page No Section Name

Document Sample
RTP Guidelines Update 10 26 2009 document Comment Table Please note all page numbers are those of the 10 26 09 released draft unless otherwise specified Page No Section Name Powered By Docstoc
					RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name        Agency     Comment                                                                        Response
                                                     Requested new sub-section in 4.41 to address Resource Areas and Farmland       A new section was created under SCS Contents for
                                                     in the SCS, provided language for that subsection and for best management      Resource Areas and Farmland. Language provided by TNC
                                                     practices to address natural resources and farmland through development of a   was paraphrased and combined with other comments to
            Section 4.41
                              Suneil                 regional Greenprint.                                                           focus on statutory requirements of SB 375. Best practices
  113      Contents of the                  TNC
                             Thomas                                                                                                 information was incorporated into Section 4.37 since best
               SCS
                                                                                                                                    practice level of detail is not provided in the SCS Contents
                                                                                                                                    Section, please note this section is still under construction.

            Section 4.37                             Provided language for Regional Advanced Mitigation Planning (RAMP) and         Incorporated greenprinting language as a best practice
                Key                                  greenprinting as a best practice for inclusion in Section 4.37.                recommendation in Section 4.37. Included reference to
           Environmental      Suneil                                                                                                RAMP as a best practice in Section 4.35 also including
  105                                       TNC
           Considerations    Thomas                                                                                                 comments and language received by USEPA, please note
              for Best                                                                                                              that these sections are still under construction.
              Practices
             Section 1.2                             Third paragraph should mention AB 32 as the purpose for the adoption of the    Comment incorporated.
            Background        Bruce                  May 2008 RTP Guidelines Addendum.
  13                                     Kings CAG
           and Purpose of    Abanathie
              the RTP
             Section 1.4                             Second Paragraph #2 - "compact development" should be replaced with "land      Comment incorporated.
                              Bruce
  17       Purpose of the                Kings CAG   use strategies that will reduce regional greenhouse gas emissions"
                             Abanathie
                RTP
                                                     The SCS and APS should be addressed separately throughout the document         Section 1.8 is currently under construction. Throughout the
                                                     and emphasis should be placed on the SCS. Additionally project exemption       document staff tried to emphasize SCS as the main focus
                              Bruce
  21         Section 1.8                 Kings CAG   should directly reference legislative language.                                with (APS, if applicable) noted. Government Code Section
                             Abanathie
                                                                                                                                    65080 (b)(2)(K) language is used in Section 4.26 to explain
                                                                                                                                    project exemption.
            Section 4.1                              Best practices links on this page are outdated and not relevant.               Links were removed, staff is working to test all links in the
           Policy, Action,                                                                                                          document and replace those that are outdated.
                              Bruce
  63         Financial                   Kings CAG
                             Abanathie
           Elements and
                SCS
            Section 4.11                             Title 23 CFR 450.316(a)(1)(iii) does not require MPOs to maintain Draft RTPs   Removed both from the sentence. Staff is currently
               Public         Bruce                  in publication or hard copy available to the public after the Final RTP is     researching statute to clarify this requirement and will revise
  76                                     Kings CAG
            Participation    Abanathie               adopted. Please separate the requirements for the Public Participation Plan,   the sentence in the next draft.
                Plan                                 Draft RTP and Final RTP.
            Section 4.14                             Paragraph 3 of this section should be re-written to incorporate the last       Comment incorporated, paragraph re-written.
             Input and                               paragraph and more clearly convey the meeting requirements.
            Consultation      Bruce
  81                                     Kings CAG
            During SCS       Abanathie
             and APS
           Development
            Section 4.29                             Remove "See Above" from the Best Practices. Move Performance Measures          Comment incorporated.
                              Bruce
  97       Performance                   Kings CAG   for Rural Transportation Systems Guidebook reference to the Best Practices
                             Abanathie
             Measures                                section.


       9496f356-58e1-4fec-a264-f201c6444e28.xls                                              Page 1                                                                                    11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name           Agency      Comment                                                                          Response
                                                         The discussion of Pricing Strategies and Transportation Planning and             Comment incorporated. Section 4.43 and Appendix J were
            Section 4.32
                                                         Investment Strategies only applies to select MPOs. Strategies for all types of   created to accommodate discussion of land use and
            Congestion        Bruce
  100                                      Kings CAG     MPOs should be included. Recommend an Appendix dedicated to strategies,          transportation strategies to reduce GHG emissions that are
            Management       Abanathie
                                                         how they work, how they are implemented, who they would work for etc.            useful for all types of MPOs.
              Process
            Section 2.2                                  "Page 14 of this document stated that "Transportation is California's largest    This sentence was removed from the Guidelines.
           Background on                                 source of Carbon Dioxide (emitting 58%)" this language should be revised.
              Climate
                              Bruce
  26        Change and                     Kings CAG
                             Abanathie
             Regional
             Blueprint
             Planning
                                                      "The SCS or Alternative Planning Strategy (APS) is the key long range           Reference to APS removed from this sentence.
            Section 4.41                              planning tool to be used by MPOs and local government to help provide an
                            Bruce
  113      Contents of the              Kings CAG outline of how and where future development should occur in the region" The
                           Abanathie
               SCS                                    SCS and APS should not be referenced together in this format, the SCS should
                                                      be the focus of this section.
                                          Senate      Second Paragraph #1 - may need to remove reference to "other than those         Removed reference to exempted projects from this
            Section 1.4
                                        Housing and specifically exempted"                                                            sentence.
  17       Purpose of the Mark Stivers
                                       Transportation
                RTP
                                         Committee
            Section 2.2                               Remove reference to "current or projected local general plans" in strategy #6   This section is under construction. Land Use Strategies will
           Background on                              since we don't want an SCS necessarily to reflect general plans.                be discussed in Section 4.43, strategy #6 is being rewritten.
                                          Senate
              Climate
                                        Housing and
  26        Change and Mark Stivers
                                       Transportation
              Regional
                                         Committee
              Blueprint
              Planning
            Section 4.26                              On page 91, I assume others are rewriting the exemption section to explain that Section 2.6 is currently being re-written to clarify exemption
                                          Senate
           Transportation                             exempted projects should be in an SCS and be modeled (because they are          provisions.
                                        Housing and
  93          Projects    Mark Stivers                likely to happen) but are exempt from the internal consistency requirement. In
                                       Transportation
           Exempted from                              other words, these projects can go forward even if they are inconsistent with
                                         Committee
               SB 375                                 other policies or efforts to reduce GHG.
            Section 4.43                              On pages 100-101 we discussed moving the sections on Pricing Strategies and The sections on Pricing Strategies and Transportation
           Land Use and                               Transportation Planning and Investment Strategies to a new section on Non-      Planning and Investment Strategies will be incorporated into
           Transportation                 Senate      Land Use Strategies Within an SCS.                                              Section 4.43 and Appendix J of the Guidelines. This section
            Strategies to               Housing and                                                                                   and appendix will serve as a source of information for MPOs
  122                     Mark Stivers
              Address                  Transportation                                                                                 for land use and transportation strategies that could be
           Regional GHG                  Committee                                                                                    incorporated into the SCS or APS.
            Emissions in
              the RTP




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                                   Page 2                                                                                   11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name          Agency     Comment                                                                               Response
                                                       Change the title to "Required Contents of an SCS" and amend #2 to read:               Required and Suggested Contents of the SCS were both
                                                       Regional housing needs: The SCS shall identify areas within the region                included in this section. Statutory derived language was
                                                       sufficient to house all the population of the region, including all economic          included in the Required Contents paragraph of #2. "The
                                                       segments, over the course of the planning period of the Regional                      MPO shall also seek to eliminate the need for interregional
                                                       Transportation Plan. In projecting future housing needs, the MPO shall take           commuting" was removed as that language is not a statutory
                                           Senate      into account net migration into the region, population growth, household              requirement.
            Section 4.41
                                         Housing and formation, and employment growth. The MPO shall also seek to eliminate the
  114      Contents of the Mark Stivers
                                        Transportation need for interregional commuting. Pursuant to Government Code section
               SCS
                                          Committee 65584, the SCS shall identify areas within the MPO boundary sufficient to
                                                       house an eight-year projection of the regional housing needs assessment
                                                       (RHNA) as identified by the California Department of Housing and Community
                                                       Development (HCD). State housing goals as specified in Government Code
                                                       sections 65580 and 65581 will have to be considered in the SCS.
                                                         Provided the following suggested language. ―All economic segments‖ shall            This language was included in the Suggested Contents
                                                         mean the very low, low, moderate, and above moderate income categories, as          paragraph of #2 and was modified to reflect that it is
                                                         those categories are defined and used for purposes of the region‘s Regional         recommended rather than required per statute.
                                           Senate
            Section 4.41                                 Housing Need Assessment pursuant to Section 65584 of the Government
                                         Housing and
  114      Contents of the Mark Stivers                  Code. ―Areas sufficient to house‖ shall mean an aggregate number of acres of
                                        Transportation
               SCS                                       vacant or redevelopable land designated for housing development with an
                                          Committee
                                                         aggregate number of acres designated at densities consistent with Section
                                                         65583.2(c)(3)(B) of the Government Code to accommodate the housing needs
                                                         of very low and low income households.
                                                         Provided the following suggested language for this section:In order to satisfy      This language was included in the Suggested Contents
                                                         these requirements, an SCS should present information in the following format:      paragraphs #1 - #4
                                                         1) A map of current land uses, including residential densities and other building
                                                         intensities.
                                                         2) A map or series of maps illustrating the forecasted development pattern for
                                                         the region, highlighting changes from current land uses, changes in residential
                                                         densities and building intensities, and farmland and resource areas protected
                                           Senate
            Section 4.41                                 or worthy of protection.
                                         Housing and
  114      Contents of the Mark Stivers                  3) A map of the transportation network envisions in the RTP.
                                        Transportation
               SCS                                       4) A narrative description of how the forecasted development pattern (A)
                                          Committee
                                                         accommodates 8-year and long-term housing needs for all economic segments
                                                         of the population, (B) incorporates the best practically available scientific
                                                         information on resource areas and farmlands, (C) reduces GHG, and (D) allows
                                                         the RTP to conform with the Clean Air Act.
                                                         5) A narrative description of how the forecasted development pattern and the
                                                         transportation network are consistent with each other.




     9496f356-58e1-4fec-a264-f201c6444e28.xls                                                     Page 3                                                                                     11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section          Name          Agency    Comment                                                                           Response
                                                       On page 114 after the section on ―[Required] SCS Contents‖, insert a Section      Required and Suggested Contents of the SCS were both
                                                       on ―Optional Contents of an SCS‖ and include examples of other initiatives,       addressed in Section 4.41.The sections on Pricing
                                           Senate      such as pricing and transportation demand management, an MPO may want to          Strategies and Transportation Planning and Investment
            Section 4.41
                                         Housing and consider as part of its strategy to meet its GHG target. Some of this language      Strategies will be incorporated into Section 4.43 and
  116      Contents of the Mark Stivers
                                        Transportation will be moved from Section 4.32. SCAG offered to provide language as well.        Appendix J of the Guidelines. This section and appendix will
               SCS
                                          Committee                                                                                      serve as a source of information for MPOs for land use and
                                                                                                                                         transportation strategies that could be incorporated into the
                                                                                                                                         RTP/SCS, APS etc.
                                                       On page 117 delete the current section titled "Role of Cities and Counties in the The first part of this language was directly incorporated. The
                                                       Development of the SCS" and replace with the follwoing language:         Role of last two sentences were paraphrased and combined with
                                                       Existing General Plans and Spheres of Influence                                   language provided by USEPA.
                                                       In developing an SCS, an MPO shall consult with cities and counties about
                                                       their existing general plans and foreseeable changes to their general plans over
                                                       the period covered by the RTP. An MPO shall also consult with relevant
                                           Senate
            Section 4.41                               LAFCOs about current sphere of influence and municipal service review
                                         Housing and
  117      Contents of the Mark Stivers                boundaries and foreseeable changes to these boundaries over the period
                                        Transportation
               SCS                                     covered by the RTP. While an MPO shall take this information into account, an
                                          Committee
                                                       SCS, however, need not be constrained by this information. To the extent they
                                                       are reasonable and consistent with federal requirements, an MPO may base an
                                                       SCS on alternative planning assumptions that differ from and/or go beyond
                                                       existing plans and boundaries and/or foreseeable future decisions of cities,
                                                       counties, and LAFCOs.

                                                       Insert the following language in the Role of Existing General Plans and Spheres Staff is waiting to incorporate these examples pending their
                                                       of Influence section:                                                       As a     consideration by the Land Use and Housing Workgroup
                                                       non-exclusive list of examples, an MPO may use alternative planning                  meeting scheduled for November 10th
                                                       assumptions because:
                                           Senate      1) Existing or foreseeable plans and boundaries will not allow and MPO to meet
            Section 4.41
                                         Housing and its GHG target.
  117      Contents of the Mark Stivers
                                        Transportation 2) Existing or foreseeable plans and boundaries may not accommodate short-
               SCS
                                          Committee term or long-term housing needs.
                                                       3) Existing plans reflect ordinances, policies, voter-approved measures, or
                                                       other standards that directly or indirectly limit the number of residential building
                                                       permits.

                                           Senate         I would suggest deleting the section entitled ―Identifying Land Uses in the SCS‖ On p.117, this section was removed and replaced with new
            Section 4.41
                                         Housing and      (In the October 1st Draft) I don‘t believe it adds any value.                    language provided by MTC, with the incorporation of some
  117      Contents of the Mark Stivers
                                        Transportation                                                                                     language from the League of California Cities, CSAC, and
               SCS
                                          Committee                                                                                        APA.
                                           Senate         In the Housing Section I would suggest deleting as unnecessary paragraphs 1 Suggested deletions were made, this section was completely
            Section 4.41
                                         Housing and      (―In addition‖), 4 (―MPO coordination‖), 5 (―Required housing components‖), and re-written and is still under construction.
  118      Contents of the Mark Stivers
                                        Transportation    8 (―Housing elements shall identify‖)
               SCS
                                          Committee




     9496f356-58e1-4fec-a264-f201c6444e28.xls                                                     Page 4                                                                                    11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name         Agency    Comment                                                                             Response
                                                     Add a new section with the following title and language:                            Suggested section and language were added as Section
                                                     Reasons to Adopt an APS                                                             4.44 Reasons to Adopt an APS. Additional statutory
                                                     The goal of SB 375 is for an MPO to adopt an SCS that would achieve its             language was added to this section as was an "other
                                                     greenhouse gas emission reduction target. It may be necessary for an MPO to         circumstances" provision provided by the League of CA
                                         Senate
            Section 4.44                             adopt an Alternative Planning Strategy (APS) if an SCS cannot achieve its           Cities, CSAC, and APA. This section is still under
                                       Housing and
  123       Reasons to   Mark Stivers                greenhouse gas emission reduction target without:                                   construction.
                                      Transportation
           Adopt an APS                              1. Including improvements to the transportation network that fall outside of
                                        Committee
                                                     current financial constraints.
                                                     2. Using land use planning assumptions that exceed reasonable assumptions
                                                     allowed under federal guidelines.

                                                       Re: Paragraph 4 on p.13 RTAC recommended a reduction of per capita GHG            Incorporated the phrase "to meet regional greenhouse gas
             Section 1.2
                                                      which will result in a net increase of GHG from autos and light trucks, because    emissions targets specified by the California Air Resources
            Background
  13                      Clint Daniels    SANDAG     increases in population will offset reductions in per capita emissions. Consider   Board"
           and Purpose of
                                                      changing wording to ―strive to meet regional GHG emission targets established
              the RTP
                                                      by ARB‖
                                                      Insert #3 on the second list on page 17:                                    #3     Comment Incorporated.
                                                      The MPO must prepare an Alternative Planning Strategy (APS) if the SCS is
            Section 1.4
                                                      unable to reduce greenhouse gas emissions to achieve the greenhouse gas
  17       Purpose of the Clint Daniels    SANDAG
                                                      emission reduction targets established by the ARB. The APS shall be a
               RTP
                                                      separate document from the regional transportation plan, but it may be adopted
                                                      concurrently with the regional transportation plan.
                                                      In Section 1.8 under the APS description concern was raised regarding the          Comment noted, this section is currently under construction.
                                                      characterization of CEQA relief for the APS. This section states that the APS is   All references to CEQA applicability to the SCS and APS
                                                      exempt from CEQA, in statute the APS is not subject to CEQA, there is a            (and any CEQA relief provisions contained in SB 375) will
  21         Section 1.8   Rob Rundle      SANDAG
                                                      difference.                                                                        use direct statutory language and will be incorporated within
                                                                                                                                         the CEQA Appendix and/or the APS Appendix, as
                                                                                                                                         appropriate.
                                                      In Section 2.2 there are some issues with the Land Use Strategies and              This section is under construction. It is being completely
            Section 2.2
                                                      Performance Indicators identified, for example some are contradictory and          rewritten to clarify the relationship between Blueprint
           Background on
                                                      unclear.                                                                           Planning and SCS development to accommodate the
              Climate
                                                                                                                                         provisions of Climate Change legislation. All Land Use
  34        Change and      Elisa Arias    SANDAG
                                                                                                                                         strategies in this section are being revised and will be
             Regional
                                                                                                                                         incorporated into Section 4.43 and Appendix J which were
             Blueprint
                                                                                                                                         created to accommodate discussion of land use and
             Planning
                                                                                                                                         transportation strategies to reduce GHG emissions.
            Section 2.5                               In Section 2.5 the first sentence reads: "It is very important that the RTP be     The consistency recommendations in this section should be
            Consistency                               consistent with other plans prepared by local, State, Federal agencies and         applied to the RTP as appropriate.
  29         with Other    Clint Daniels   SANDAG     Native American Tribal Governments." Does this supersede the best case
             Planning                                 scenario or blueprint inclusion?
            Documents




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                                Page 5                                                                                      11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section          Name         Agency   Comment                                                                     Response
            Section 2.5                              The Key Planning Document Produced by MPOs/RTPAs Table on p. 38 lists a Staff is currently coordinating with the Caltrans Division of
            Consistency                              2 year update requirement for the FTIP (MPOs Only). SAFETEA-LU allows for Programmin to address this item.
                             Heather
  29         with Other                     SANDAG   a 4-year update. Since MPOs are considering a different update cycle, there
                             Werdick
             Planning                                should be a footnote that the update cycle is under consideration.
            Documents
            Section 4.1                              The Sustainable Communities Strategy List on p. 63 should reference the APS The APS is introduced on p. 14 and is further explained in
           Policy, Action,                                                                                                       Section 4.44 and Appendix H. Since the APS is not actually
  62         Financial     Clint Daniels    SANDAG                                                                               part of the RTP it is not explained in Section 4.1.
           Elements and
                SCS
                                                     #2 on p. 67 Projected Costs - "Estimate of costs to implement the projects         Staff is currently coordinating with the Caltrans Division of
                                                     identified in the four year FTIP and the RTP must be included." The FTIP years Programmin to address this item.
             Section 4.4
                              Heather                do not necessarily line up with the start of the RTP years. MPOs should be
  67          Financial                     SANDAG
                              Werdick                given flexibility to refer to the FTIP for the early years with the knowledge that
              Overview
                                                     projects being implemented in the FTIP are consistent with the RTP.

                                                     #3 on p. 67 Projected Operation and Maintenance Costs - "The financial plan         Staff is currently coordinating with the Caltrans Division of
                                                     shall contain system level estimates of costs and revenue sources that are          Programmin to address this item.
                                                     reasonable expected to be available to adequately operate and maintain
                                                     Federal-aid higheays and public transportation.Financial plans that support the
             Section 4.4
                              Heather                RTP process must assess capital investment and other measures necessary to
  67          Financial                     SANDAG
                              Werdick                ensure the preservation of: the existing transportation system...Resurfacing,
              Overview
                                                     restoration and rehabilitation of roadways etc." This requirement is in federal
                                                     law, but it is ONLY for FEDERALLY funded projects. This section reads all
                                                     projects and should be changed to clarified that costs for federal funded
                                                     projects are required.
                                                     Top of p. 72: "In relation to the MPOs financial plan, SAFETEA-LU now permits       Staff is currently coordinating with the Caltrans Division of
                                                     the use of aggregate cost ranges or cost bands. ― For the outer years of the        Programmin to address this item.
            Section 4.8
                                                     metropolitan transportation plan (i.e. beyond the first 10 years), the financial
             Estimating
                              Heather                plan may reflect aggregate cost ranges/cost bands, as long as the future
  72           Future                       SANDAG
                              Werdick                funding sources(s) is reasonably expected to be available to support the
           Transportation
                                                     projected cost ranges/cost bands." Since CA FHWA office will not allow the use
               Costs
                                                     of cost bands (i.e. only allow the high end of the band), this paragraph probably
                                                     should be deleted.
            Section 4.11                             p. 76 "The public participation plan and both the draft and adopted RTP shall       Removed both from the sentence. Staff is currently
               Public         Heather                be posted on the World Wide Web, to the maximum extent practicable and for          researching statute to clarify this requirement and will revise
  76                                        SANDAG
            Participation     Werdick                the life of the RTP." Once the RTP is adopted only the adopted RTP should be        the sentence in the next draft.
                Plan                                 required to be posted on the Web site.
            Section 4.14                             p.81 Paragraph 3 of this section should be re-written to incorporate the last       Comment incorporated, paragraph re-written. SB 575
             Input and                               paragraph and more clearly convey the meeting requirements                          language added re: purpose of the meeting(s).
            Consultation
  81                        Clint Daniels   SANDAG
            During SCS
             and APS
            Development


       9496f356-58e1-4fec-a264-f201c6444e28.xls                                               Page 6                                                                                         11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name        Agency   Comment                                                                            Response
            Section 4.15                           Possible inclusion of Caltrans in the coordination process.                        Caltrans added to list of agencies
            Interagency
  81        Coordination Clint Daniels    SANDAG
              on SCS
           Development
            Section 4.17                           Can sections 4.15 and 4.17 be combined?                                            Staff is working on combining these sections.
            Consultation
  83                      Clint Daniels   SANDAG
           with Resource
              Agencies
            Section 4.43                           The Pricing Strategies section should not be limited to only pricing strategies    The pricing strategies listed are being revised and moved to
           Land Use and                            but should include other TDM and TSM strategies.                                   Section 4.43 which will also include other TDM and TSM
           Transportation                                                                                                             strategies. Additionally Appendix J will feature more detailed
            Strategies to   Heather                                                                                                   best practices information.
  122                                     SANDAG
              Address       Werdick
           Regional GHG
            Emissions in
              the RTP
                                                   Pricing Strategy #2 - "Consider utilizing revenues from these pricing strategies Staff is working to update the pricing strategies and is
            Section 4.43
                                                   for projects, such as mass transit, that improve mobility without increasing VMT compiling more recent links and information.
           Land Use and
                                                   or GHG emissions" Have these revenues penciled out for anyone? Or are they
           Transportation
                                                   purely a cost recovery for managing the system? Road pricing paper:
            Strategies to
  122                     Clint Daniels   SANDAG   ―Opportunities to Improve Air Quality through Transportation Pricing Programs‖,
              Address
                                                   U.S. Environmental Protection Agency, September 1997
           Regional GHG
                                                   http://www.epa.gov/oms/market/pricing.pdf is very outdated.
            Emissions in
              the RTP
            Section 4.43                           Strike the following language from Transportation Planning and Investment          Language removed as requested. Transportation Planning
           Land Use and                            Strategy #1 "A market-based approach to transit infrastructure and service         and Investment Strategies are currently being rewritten.
           Transportation                          planning is required to comply with AB 32's requirement of reducing GHG            Reference to GHG reduction will be emphasized.
            Strategies to                          emission, to achieve smart growth, and improve the region's economic
  122                     Clint Daniels   SANDAG
              Address                              competitiveness." Also strategies should refer to GHG reduction as that is the
           Regional GHG                            legislative intent of SB 375.
            Emissions in
              the RTP
                                                   First paragraph contains the sentence "The United States Environmental             Reference to draft language removed and citation revised.
                                                   Protection Agency has draft language to include greenhouse gasses in the           Citation is now located in the new Section 2.2.
            Section 4.40                           environmental protection act" Should references be made to draft language?
            Greenhouse                             Second paragraph included the sentence "The California Environmental
  113      Gas Emissions Clint Daniels    SANDAG   Protection Agency (CalEPA) prepared a briefing package for Assembly Bill
            Targets and                            (AB) 1493 entitled ―Global Warming and Greenhouse Emissions from Motor
            Background                             Vehicles‖; page 14 of this document stated that, ―Transportation is California‘s
                                                   largest source of Carbon Dioxide.‖ This quoted text does not exist in that
                                                   document. Please revise.




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                             Page 7                                                                                      11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section          Name        Agency   Comment                                                                             Response
                                                    Second sentence in the first paragraph in this section "Modifying future land       Sentence was removed to focus the paragraph on the
            Section 4.41
                                                    use practices so as to reduce the growth in vehicular travel is a key element in    contents of the Sustainable Communitites Strategy. The
  113      Contents of the Clint Daniels   SANDAG
                                                    California's strategy to reduce its greenhouse gas emissions" should be             entire Overview/Background section was shortened.
               SCS
                                                    removed.
                                                    The Role of Cities and Counties in the Development of the SCS sub-section           Language removed as requested. This sub-section was
            Section 4.41                            contains the sentence "Over time, cities and counties will need to address land     rewritten to focus on the Role of Existing General Plans and
  117      Contents of the Clint Daniels   SANDAG   use and transportation policies as well as regional transportation system           Spheres of Influence which are defined in statute.
               SCS                                  decisions that will reduce both the number and length of vehicle trips" This is
                                                    not in the legislation.
                                                    The Identifying Land Uses in the SCS sub-section contains the sentence "Each        Language changed as requested.
            Section 4.41                            region continues to grow in its own unique way, but more and various
  117      Contents of the Clint Daniels   SANDAG   transportation choices, and livable communities, can help reduce miles traveled
               SCS                                  in vehicles." Miles traveled in vehicles should be replace with GHG emissions.

                                                    "The housing element shall identify adequate sites for housing, including rental Language removed.
                                                    housing, factory-built housing, mobile homes, and emergency shelters, and
            Section 4.41
                                                    shall make adequate provision for the existing and projected needs of all
  118      Contents of the Clint Daniels   SANDAG
                                                    economic segments of the community. (Government Code 65583)" The HE is
               SCS
                                                    part of the local GP, not part of the RTP. Consider striking language.

                                                    The third bullet under Addressing Regional Transportation Needs in the SCS:         Language changed to read: "Transit investments need
            Section 4.41                            "Transit investments need supporting levels of land use density and intensity       supporting levels of land use density and intensity."
  120      Contents of the   Elisa Arias   SANDAG   plus traffic congestion that creates high demand for reliable travel times" Needs
               SCS                                  clarification, congestion doesn‘t help transit when transit vehicles operate in
                                                    mixed flow lanes.
                                                    The last paragraph in this sub-section reads: Additional methods are available      Language re-written to read: MPOs may also consider other
                                                    to the regions on balancing their transportation needs against the objective to     transportation strategies that reduce GHG emissions. These
                                                    reduce GHG emissions. These include Transportation Demand/Systems                   may include Transportation Demand Management (TDM)
            Section 4.41
                              Heather               Management Strategies, Transportation Investments, and Land Use                     strategies, Transportation Systems Management (TSM)
  120      Contents of the                 SANDAG
                              Werdick               Strategies" This should include all TDM, TSM, Transportation Investments, and       strategies, Transportation Investments, and Land Use
               SCS
                                                    Land Use Strategies.                                                                Strategies. Additional information regarding these strategies
                                                                                                                                        is available in Sections 4.43 and Appendix J.

            Section 4.41                            The SCS Public Participation and Input/Consultation with Local Elected              This sub-section was shortened and includes a reference to
  120      Contents of the Clint Daniels   SANDAG   Officials sub-section contains the same information as Section 4.14                 Sections 4.11 and 4.14.
               SCS
                                                    Re: California Air Resources Board Review of the SCS. How does the timing           Section 2.7 contains a flowchart which illustrates the RTP
                                                    work with federal conformity approval? The federal and state reviews would be       development process including federal conformity review
            Section 4.41
                              Heather               occurring at the same time.                                                         and ARB review. The RTP Sequencing Workgroup will
  120      Contents of the                 SANDAG
                              Werdick                                                                                                   continue to work on this issue and Staff is currently meeting
               SCS
                                                                                                                                        with ARB to further clarify the (ARB review) process.




     9496f356-58e1-4fec-a264-f201c6444e28.xls                                                Page 8                                                                                       11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section          Name        Agency    Comment                                                                             Response
                                                     Last paragraph of the California Air Resources Board Review of the SCS              Paragraph modified to read: "When reviewing the SCS,
                                                     states: "When reviewing the SCS, FHWA will consider only those projects that        FHWA will consider only those projects that are incorporated
                                                     are incorporated within an SCS that is financially constrained and eligible to be   within an SCS that is financially constrained and eligible to
            Section 4.41
                              Heather                federally funded. Projects within an APS are not considered financially             be federally funded. Projects that are only included within an
  120      Contents of the                 SANDAG
                              Werdick                constrained, and FHWA will not fund projects within an APS document." This          APS are not considered financially constrained, and FHWA
               SCS
                                                     should be clarified that projects that are ONLY in an APS will not be funded by     will not fund projects within an APS document if they are not
                                                     FHWA. However, many projects may be in both a SCS and APS so there will             included in the SCS."
                                                     be overlap.
                                                     On page 13, the guidelines state ―SB 375 was only directed towards MPOs and         Language incorporated for review and comment by the
                                                     essentially requires them to include land use/housing issues and strive to          subcommittee and full workgroup.
                                                     reduce regional greenhouse gas emissions by achieving a regional greenhouse
                                                     gas emission target specified by the ARB.‖ Clarify that this language means
                                                     the new requirements are for MPOs and not RTPAs. The current language
             Section 1.2                             implies that for regions‘ affected by SB375, stakeholders besides the MPO
            Background                     MTC and   (e.g. local municipalities) are not affected by the process. Consider language
  13                         Liz Brisson
           and Purpose of                   ABAG     such as: ―The 2010 update was prepared to incorporate new planning
              the RTP                                requirements mandated by SB 375. SB 375 requires the 18 MPOs in the State
                                                     to identify a land use pattern and transportation network that will meet a
                                                     greenhouse gas reduction target specified by the ARB through their RTP
                                                     planning process. These requirements pertain only to the State‘s 18 MPOs, but
                                                     not to the RTPAs that also prepare RTPs.‖

                                                     On page 18, the guidelines state that one new requirement of RTPs as a result Language incorporated for review and comment by the
                                                     of SB 375 is that ―Other than those specifically exempted, transportation          subcommittee and full workgroup.
                                                     projects identified in the RTP must be modeled to determine their impacts on
            Section 1.4                              the regional GHG emissions.‖ We believe that even those projects that are
                                           MTC and
  17       Purpose of the    Liz Brisson             exempt will need to be modeled for GHG emission reduction (see pages 4-5 of
                                            ABAG
               RTP                                   this letter for more discussion on this topic). Consider re-wording this to remove
                                                     the reference to exempt projects: ―Transportation projects identified in the RTP
                                                     must be modeled to determine their impacts on the regional GHG emissions.‖




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                               Page 9                                                                                       11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section        Name         Agency    Comment                                                                        Response
                                                    On page 24, under Sustainable Communities Strategy (SCS), #1, the 2nd          This section is currently under construction and is being re-
                                                    sentence states: ―It should also use the most recent local general plans and   written, language will be incorporated.
                                                    other land use assumptions.‖ This meaning is slightly different than the
                                                    statutory language. Consider using the statutory language instead: ―It should
                                                    also use the most recent planning assumptions considering local general plans
                                                    and other factors.‖ On page 25, under Sustainable Communities Strategy
                                                    (SCS), #7, it should be noted here that these provisions only apply to the
                                          MTC and
  21         Section 1.8   Liz Brisson              SCAG region. On page 26, under Alternative Planning Strategy (APS), #3, E),
                                           ABAG
                                                    the current language implies that the APS will not identify specific projects.
                                                    Also, the description of CEQA exemption could be misleading as development
                                                    projects consistent with an APS may be subject to CEQA-relief provisions of
                                                    SB 375. Consider replacing it with the following language:―E) Unlike the RTP,
                                                    projects listed in the APS will not be used to program projects in the MPO‘s
                                                    TIP, F) CEQA does not require MPOs to prepare an EIR for an APS.‖

                                                    On page 26, under Programmed Projects, the language here does not convey          This section is currently under construction and is being re-
                                                    the same meaning of the statute. Consider replacing with the following: ―Any      written. Programmed projects are addressed in Section 4.26
                                                    transportation projects programmed for funding by December 31, 2011 and are       and the statutory language provided will be incorporated into
                                                    either a) contained in the 2007 or 2009 FSTIP, b) are funded from Proposition     that section.
                                          MTC and   1B, or c) were specifically listed in a sales tax measure prior to December 31,
  21         Section 1.8   Liz Brisson
                                           ABAG     2008 are exempt from the Sustainable Communities Strategy requirements. In
                                                    addition, sales tax authorities cannot be required to change voter approved
                                                    funding allocations for categories of transportation projects in sales tax
                                                    measures adopted prior to December 31, 2010.

                                                    Section 4.41 on page 113 of the guidelines discuss blueprint plans as a        Section 2.2 is currently under construction and is being re-
                                                    precursor to SB 375 and state that those regions that have participated in a   written in an attempt to clarify the relationship between the
                                                    blueprint planning effort have a head start in implementing SB 375. We concur Blueprint, the SCS and the RTP as requested.
            Section 2.2
                                                    with this characterization of the blueprint planning effort. However, the
           Background on
                                                    discussion of blueprint planning as a part of the recommended land use
              Climate
                                          MTC and   strategies on pp. 32-34 seems in conflict, referring to consistency between
  26        Change and     Liz Brisson
                                           ABAG     blueprint plans, the SCS, and the RTP. We believe the blueprint work
             Regional
                                                    completed in the Bay Area (FOCUS) will be the starting point for the SCS, but
             Blueprint
                                                    will not necessarily be consistent with it. Moreover, the RTP and the SCS must
             Planning
                                                    by definition be consistent as the SCS is a part of the RTP, which must be
                                                    internally consistent. We suggest clarifying the relationship between the
                                                    blueprint plan, the SCS, and the RTP.




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                            Page 10                                                                                     11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name        Agency    Comment                                                                          Response
                                                    The addition to Section 4.1 encourages MPOs to add to the Policy Element of These best practices and links will be incorporated in
                                                    the RTP policies that support Smart Growth Land Use principles. MTC has 2        Section 4.43.
                                                    examples that may be helpful to cite here: MTC's T2035 Plan called for
                                                    modifying our Transportation for Livable Communities (TLC) program to
            Section 4.43
                                                    support Priority Development Areas which were identifed as a part of FOCUS,
           Land Use and
                                                    the Bay Area's bluepprint planning process. The TLC program offers capital
           Transportation
                                                    grants to cities, counties, and transit agencies to connstruct projects that
            Strategies to                 MTC and
  122                       Liz Brisson             support compact development near transit. MTC's Resolution 3434 TOD Policy
              Address                      ABAG
                                                    ties regional discretionary funds for new transit extension projects (funded via
           Regional GHG
                                                    Resolution 3434) to supportive land uses. This policy establishes targets for
            Emissions in
                                                    new housing units in each transit corridor and calls for station area plans and
              the RTP
                                                    corridor working groups to help achieve targets. Station area plans to meet the
                                                    housing targets must be adopted by local municipalities prior to receiving MTC
                                                    discretionary funding for construction of Resolution 3434 funds.

                                                    Page 81, the third paragraph states: ―The purpose of these meetings will be to    Language has been changed to reflect the new statutory
                                                    present a draft SCS and gather input and comments.‖ SB 575 includes               language of SB 575.
            Section 4.14
                                                    language that changes this requirement as follows: ―This bill would instead
             Input and
                                                    provide that the purpose of the meeting or meetings is to discuss the
            Consultation                  MTC and
  81                        Liz Brisson             sustainable communities strategy and alternative planning strategy, if any,
            During SCS                     ABAG
                                                    including the key land use and planning assumptions, with the members of the
             and APS
                                                    board of supervisors and the city council members in that county and to solicit
            Development
                                                    and consider their input and recommendations.‖ This section should be
                                                    updated once SB 575 is signed.
            Section 4.14                            Page 81, the fourth paragraph restates the same consultation principles listed    The repetition of consultation principles was deleted and a
             Input and                              in Section 4.10 (on page 75). Perhaps these only needed to be stated in this      reference to Section 4.10 was inserted.
            Consultation                  MTC and   introductory section instead of repeated.
  81                        Liz Brisson
            During SCS                     ABAG
             and APS
            Development
            Section 4.14                            The last paragraph in this section (page 81) seems to repeat the same             Paragraph deleted. Third paragraph of this section re-written.
             Input and                              information as the third paragraph.
            Consultation                  MTC and
  81                        Liz Brisson
            During SCS                     ABAG
             and APS
            Development
                                                    This section describes consultation that should occur between the MPO and      Section has been re-titled Interagency Coordination so as to
                                                    federal agencies, HCD, and the ARB. While we concur that consultation with all not be confused with the Consultation required during the
            Section 4.15
                                                    these agencies is important as a part of development of the RTP, we suggest Federal Conformity Determination process.
            Interagency
                                          MTC and   re-working this section so as not to confuse interagency consultation for
  81        Coordination    Liz Brisson
                                           ABAG     transportation air quality conformity, which is a very focused process to meet
              on SCS
                                                    Clean Air Act requirements, with other types of consultation. We concur with
            Development
                                                    the suggestion made at the 10/8/09 meeting that this section be re-titled.




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                            Page 11                                                                                      11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section          Name        Agency    Comment                                                                          Response
            Section 4.26                             We believe this section, as written, does not convey the same meaning as the This Section has been re-written and statewide MPO input
           Transportation                            law and that additional guidance is needed in this section. MTC is still working on the proposed language will be sought.
                                           MTC and
  93          Projects       Liz Brisson             on new proposed language for this section which we will submit early the week
                                            ABAG
           Exempted from                             of October 19th.
              SB 375
                                                     The 2010 Guidelines add the discussion from the 2007 RTP Guidelines             These strategies will be addressed in Section 4.43 which is
                                                     Addendum on Pricing and Transportation Planning and Investment Strategies       in the Greenhouse Gas Emissions Requirements and
                                                     to the congestion management section of guidelines. While these strategies      Considerations chapter of the RTP Guidelines.
            Section 4.32                             certainly impact congestion management, this section might not be the best
            Congestion                     MTC and   location within the guidelines because a) not all MPOs are subject to the
  100                        Liz Brisson
            Management                      ABAG     congestion management process, and b) this section was originally added to
              Process                                the addendum specifically to provide strategies to reduce greenhouse gas
                                                     emissions via RTPs. Consider re-locating this section to the ―Greenhouse Gas
                                                     Emissions Requirements and Considerations in the RTP‖ part of the
                                                     Guidelines.
            Section 4.43                             Under Transportation Planning and Investment Strategies, #1, the last           This language has been removed.
           Land Use and                              sentence is unclear. ―A market-based approach to transit infrastructure and
           Transportation                            service planning is required to comply with AB 32‘s requirement of reducing
            Strategies to                  MTC and   GHG emissions, to achieve smart growth, and improve the region‘s economic
  122                        Liz Brisson
              Address                       ABAG     competitiveness.‖ We request additional guidance regarding what this strategy
           Regional GHG                              means.
            Emissions in
              the RTP
                                                     On page 114, under SCS Contents, #3, the last sentence states that ―The         This section has been re-written and the language in
                                                     system should also meet regional and statewide mobility standards, address      question has been removed.
                                                     multi-modal regional blueprint performance measures as well as meet regional
                                                     air quality conformity and regional GHG emissions targets.‖ It is unclear what
            Section 4.41
                                           MTC and   ―address multi-modal regional blueprint performance measures‖ means, nor
  114      Contents of the   Liz Brisson
                                            ABAG     does the Transportation section on pp. 117-118 expand on this requirement.
               SCS
                                                     We agree that it is important to evaluate how transportation investments impact
                                                     a set of performance measures, but it is unclear what these performance
                                                     measures are and how they relate to those discussed in Section 4.29.

                                                     On page 116, also under SCS Contents, the last 2 sentences define ―internally Language incorporated for review and comment by the
                                                     consistent‖. Because the SCS primarily adds a land use component to the        subcommittee and full workgroup.
                                                     RTP, we believe the requirement of ―internal consistency‖ described in SB 375
                                                     does not merely require financial constraint, which is already a federal
                                                     requirement of RTPs. We recommend expanding the definition of internally
            Section 4.41
                                           MTC and   consistent to also include that the land use and transportation components
  116      Contents of the   Liz Brisson
                                            ABAG     should be consistent as follows: ―The SCS must be ‗internally consistent‘ with
               SCS
                                                     the other sections of the RTP. This means that the contents of the Policy,
                                                     Action and Financial elements must be consistent with the Sustainable
                                                     Communities Strategy. Transportation investments should be consistent with or
                                                     supportive of the land use pattern contained in the SCS.‖


       9496f356-58e1-4fec-a264-f201c6444e28.xls                                             Page 12                                                                                   11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section          Name        Agency    Comment                                                                              Response
                                                     At the 10/18/2009 subcommittee meeting, we discussed completely re-writing           Language incorporated with some paraphrasing to
                                                     the Identifying Land Uses in the SCS section. We propose the following               emphasize greenhouse gas emissions reduction and to
                                                     language to be included in this section. ―MPOs and local jurisdictions are           accommodate comments submitted by the League of CA
                                                     challenged to jointly develop a land use plan for the region that, when              Cities, CSAC, and APA.
                                                     integrated with the regional transportation network, decreases regional vehicle
                                                     trips and vehicle miles travelled. In preparing the land use strategy, empirical
            Section 4.41                             relationships between land use and the built environment should be
                                           MTC and
  117      Contents of the   Liz Brisson             considered, including the following characteristics of areas that have relatively
                                            ABAG
               SCS                                   lower levels of VMT and vehicle trips: Increased levels of density, Greater
                                                     mixes of uses, Streetscape designs that accommodate pedestrians, bicycles,
                                                     and transit, Close proximity to regional destinations, Close proximity to frequent
                                                     transit service In developing the land use plan, local context should also be
                                                     considered. MPOs , local jurisdictions, and other stakeholders should strive to
                                                     create an SCS that will assist local jurisdictions in future general plan updates.

                                                     Under Housing Issues in the SCS, the third paragraph begins, ―MPO                 Language removed from this section. The Addressing
                                                     coordination with local jurisdictions and HCD is necessary to integrate the most Housing Needs in the SCS Section is currently under
                                                     recent planning assumptions and other factors such as sites requiring zoning      construction and is being re-written.
            Section 4.41
                                           MTC and   changes to meet housing need into the SCS.‖ We believe identifying individual
  118      Contents of the   Liz Brisson
                                            ABAG     sites requiring zoning changes to be beyond the scope of what is required of
               SCS
                                                     the SCS. Local jurisdictions identify sites requiring zoning changes as a part of
                                                     their Housing Element update process. Please consider striking this.

                                                     On page 120, the last two sentences in the Addressing Regional Transportation        Language re-written to read: MPOs may also consider other
                                                     Needs in the SCS subsection seem to be referring to other sections of the RTP        transportation strategies that reduce GHG emissions. These
                                                     Guidelines. Consider replacing these sentences with language that makes this         may include Transportation Demand Management (TDM)
            Section 4.41                             reference clearer such as: ―MPOs may consider transportation strategies that         strategies, Transportation Systems Management (TSM)
                                           MTC and
  120      Contents of the   Liz Brisson             reduce GHG emissions such as those described in Section X.X‖ (currently              strategies, Transportation Investments, and Land Use
                                            ABAG
               SCS                                   these are in Section 4.32, but we suggest moving them to a new section under         Strategies. Additional information regarding these strategies
                                                     Greenhouse Gas Emissions Requirements and Considerations in the RTP 4.4X             is available in Sections 4.43 and Appendix J.
                                                     as described previously).

            Section 4.46                             On page 123, the 3rd full paragraph discusses AB 32 and SB 375. Because              Language regarding AB 32 and SB 375 has been moved to
             Addressing                              these laws are aimed at climate change mitigation rather than climate change         Section 2.2.
              Climate                                adaptation , they appear misplaced in this section. While there is already
              Change                       MTC and   discussion of SB 375 and AB 32 in Section 4.40, we suggest moving the non-
  123                        Liz Brisson
           Adaptation to                    ABAG     duplicative parts of this paragraph to this section.
            the Regional
           Transportation
               System




     9496f356-58e1-4fec-a264-f201c6444e28.xls                                                 Page 13                                                                                      11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name        Agency    Comment                                                                             Response
                                                    On page 124, the guidelines leave a placeholder for climate change adaptation Best practice information and link have been incorporated.
                                                    best practices. In the San Francisco Bay Area, the Bay Conservation and
            Section 4.46                            Development Commission (BCDC) has taken a lead role in adaptation planning
             Addressing                             for the Bay Area. BCDC prepared a report, Living with a Rising Bay that
              Climate                               provides information on the region‘s vulnerability to sea level rise and strategies
              Change                      MTC and   for adaptation. BCDC has also proposed a series of findings and policies to be
  124                       Liz Brisson
           Adaptation to                   ABAG     amended into the Bay Plan which regulates development within the 100-year
            the Regional                            floodplain of the Bay. One proposed policy is to develop a regional strategy to
           Transportation                           identify areas where development should be protected and areas where
               System                               development should be removed and the Bay should be allowed to migrate
                                                    inland. This work may be helpful to identify as a best practice.

            Section 1.4                             Paragraph 1: delete sentence three but move reference that is at the end of the Comment incorporated.
                             Michael
  16       Purpose of the                 SBCAG     sentence to sentence two.
                             Powers
               RTP
                                                    Paragraph 2 on this page is not clear. Suggested replacement langugae as           Based on comments received, the language in this section
                                                    follows: 1. Develop and adopt a Sustainable Communities Strategy (SCS) as          was re-written to focus on the statutory language of SB 375.
                                                    part of the RTP with the goal of achieving GHG reduction targets set by the
            Section 1.4
                             Michael                ARB 2. Include within the SCS a land use allocation that reflects a number of
  17       Purpose of the                 SBCAG
                             Powers                 different econimc, housing, resource, and environmental factors 3. Develop and
               RTP
                                                    approve the SCS with enhanced public participation 4. Integrate the Regional
                                                    Housing Needs Assessment into the RTP and synchronize the update of the
                                                    RTP with the RHNA
                                                    Re: Land Use Strategies. This section is vague and seems like it is                This section is being completely re-written, comments wll be
            Section 4.43
                                                    overreaching beyond the scope of the RTP Guidelines. Replace language such         incorporated into the new Section 4.43 and specific
           Land Use and
                                                    as "can be incorporated" with "should be considered in the development of the      information and recommendations will be included in
           Transportation
                                                    RTP." And delete "to meet the following environmental and social goals." The       Appendix J so as to not overreach the scope of the RTP
            Strategies to    Michael
  122                                     SBCAG     use of encourage is too vague for this purpose. Measure #3 makes no sense          Guidelines.
              Address        Powers
                                                    and #4 needs further clarification. Blueprint references will soon be superceded
           Regional GHG
                                                    by the SCS. Other measures also need work to improve clarity. The focus
            Emissions in
                                                    should be on the connection between lnd use and transportation.
              the RTP




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                            Page 14                                                                                      11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section        Name         Agency   Comment                                                                             Response
                                                   On p. 33 (of the 10-1-09 draft) the Land Use Assumptions section is                 Comment noted, and Land Use Assumptions language
                                                   misdirected. I disagree that land use assumptions are the dirver, rather,           removed as requested.
                                                   demographic changes can happen independent of land use changes e.g. aging
                                                   of the population, changes in birth rates. Land uses are one part of
            Section 4.43
                                                   assumptions about future grouwth. Likewise, changes in the structure of the
           Land Use and
                                                   economy can change the nature of land use without changes in the outward
           Transportation
                                                   physical structure of land use. Witness the intensification of industrial uses with
            Strategies to   Michael
  122                                     SBCAG    the transition to information age technologies or how increasing land values are
              Address       Powers
                                                   increasing employee density. The RTP must look at all these factors and they
           Regional GHG
                                                   are no subsets of land use. For example, the aging of the population will have a
            Emissions in
                                                   significant impact on paratransit and transit over the next 30 yeras but does not
              the RTP
                                                   arise out of land use. While the SCS paradigm will influence how the RTP looks
                                                   and incorporates land use, letting land use be the driver puts us on the wrong
                                                   track to addressing the overall transporatation system.

            Section 2.6                            The Complete Streets concept has less applicability for rural and semi-rural      This section was shortened in an attempt to make it clearer
            Coordination                           areas. Be more specific in the application of the concept. For example,           and all language is recommendation based only. Language
                            Michael
  30         with Other                   SBCAG    sidewalks might be required to address the "complete street" but may be           was added to emphasize phrases such as "to the exent
                            Powers
              Planning                             inappropriate for many areas.                                                     practicable, to the extent feasible" etc. to allow for flexibility
             Processes                                                                                                               in implementation.
            Section 4.43                           On page 60 (of the 10-1-09 draft) regarding land use strategy #1, here MPOs       These strategies are being re-written based on comments
           Land Use and                            are encouraged to support local jurisdictions which makke land use decisions      received and will be addressed as recommendations in
           Transportation                          that implement the SCS. If the SCS must use local general plans, won't local      Section 4.43 and Appendix J.
            Strategies to   Michael                jurisdictions following their own general plans make decisions that support the
  122                                     SBCAG
              Address       Powers                 SCS by default? Land use strategy #2 needs to be reworded.
           Regional GHG
            Emissions in
              the RTP
            Section 4.11                           Delete reference to the ongoing posing of the draft RTP on the web.               Removed both from the sentence. Staff is currently
               Public       Michael                                                                                                  researching statute to clarify this requirement and will revise
  76                                      SBCAG
            Participation   Powers                                                                                                   the sentence in the next draft.
                Plan
            Section 4.14                           The last paragraph in this section (page 81) seems to repeat the same             Paragraph deleted. Third paragraph of this section re-written.
             Input and                             information as the third paragraph.
            Consultation    Michael
  81                                      SBCAG
            During SCS      Powers
              and APS
           Development
                                                   SBCAG believes, based on the emergence of High Speed Rail and segregation The Guidelines are worded as such due to the fact that state
                            Michael                of funding and oversight programs for rail vs. transit, that rail deserves to be statute identifies rail and transit together. If an MPO or RTPA
  87        Section 4.20                  SBCAG
                            Powers                 treated separately from transit.                                                 so chooses, they may address rail and transit in the manner
                                                                                                                                    most appropriate for their region.




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                            Page 15                                                                                          11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name        Agency    Comment                                                                          Response
            Section 4.43                            Pricing Strategies should not be singled out. Pricing has limited relevance to   Transportation Planning and Investment strategies identified
           Land Use and                             most MPOs/RTPAs when many communities don't currently charge for parking.        in the previous draft (10-1-09) are being re-written based on
           Transportation                           Transportation Planning and Investment Strategies #2 should be deleted as        comments received and will be addressed as
            Strategies to    Michael                most MPOs/RTPAs do not have funds to provide local agencies so they can          recommendations only in Section 4.43 and Appendix J.
  122                                     SBCAG
              Address        Powers                 develop and implement the Blueprint/SCS
           Regional GHG
            Emissions in
              the RTP
            Section 4.41                            The SCS Overview/Background subsection seems repetetive from prior               The SCS Overview/Background section has been
                             Michael
  113      Contents of the                SBCAG     sections, focus on GHG.                                                          condensed.
                             Powers
                SCS
                                                    Suggested the following language: A regional Blueprint Preferred Growth        This section is currently under construction and is being re-
                                                    Scenario (PGS) may be used by the MPO/RTPA to help determine if their SCS written based on comments received.
                                                    is ambitious and achievable. The ambitious and achievable test is discussed in
                                                    the final RTAC report. If the MPO/RTPA had a successful public involvement
                                                    process for their Blueprint, that resulted in a change in land use density and
            Section 2.2
                                                    distribution from Business As Usual (BAU), the MPO/RTPA may choose to use
           Background on
                                                    the Blueprint PGS as a guide for how far the SCS should go to reduce
              Climate
                                                    greenhouse gas emissions in light of local public input. For example, in the
  26        Change and       Rob Ball    Kern COG
                                                    blueprint modeling or sketch planning tool analysis, a region may have a BAU
             Regional
                                                    scenario showing an average of 5 dwelling units (DUs) per acre for new
             Blueprint
                                                    housing built by 2050. The PGS may show 7 DUs per acre. An SCS that
             Planning
                                                    matches or exceeds the Blueprint PGS density could be submitted to CARB for
                                                    consideration as an SCS if all the other requirements are met, including the
                                                    RTAC recommendation for a significant change over BAU. CARB has final say
                                                    on if the SCS is sufficient, or an APS is required.

            Section 4.43                            Under Land Use Strategies, rename "Performance Indicators" to avoid              This section is currently under construction, any referenced
           Land Use and                             confusion with Performance Measures.                                             to Performance Indicators will be removed to prevent
           Transportation                                                                                                            confusion.
            Strategies to
  122                        Rob Ball    Kern COG
              Address
           Regional GHG
            Emissions in
              the RTP




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                            Page 16                                                                                     11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name        Agency    Comment                                                                           Response
                                                    Add a paragraph to the end of this section called Consistency Checks on           Language incorporated for review and comment by the
                                                    Amendments: Planning documents are rarely synchronized in their adoption          subcommittee and full workgroup.
                                                    timeframes. Consistency requirements are to be reviewed with each complete
            Section 2.5                             update of the RTP every 4-5 years depending on attainment status of the
            Consistency                             MPO/RTPA. An amendment to an RTP does not require a consistency check
  30         with Other      Rob Ball    Kern COG   or finding to the documents listed in this section with the exception of SIPs. An
             Planning                               MPO is not required to implement an SCS related consistency requirement
            Documents                               until the first complete RTP update with an SCS is adopted after the
                                                    greenhouse gas targets are available for the MPO.‖


                                                    Add a paragraph to the end of this section called Consistency Betweeen the  Language incorporated for review and comment by the
                                                    RTP and FTIP: To promote better consistency between the RTP and the FTIP, subcommittee and full workgroup.
            Section 2.5
                                                    at the MPO/RTPAs discretion, an RTP project listing may omit the first 5-10
            Consistency
                                                    years of projects and replace them with a reference to the most recent
  30         with Other      Rob Ball    Kern COG
                                                    amended FTIP. The FTIP would need to show all missing years in the RTP
             Planning
                                                    including those years not in the 5-year planning band of the FTIP, but that
            Documents
                                                    would show up in the next 2-year cycle of the FTIP. Those extra years could
                                                    be tracked as RTP projects in the FTIP.
            Section 4.1                             Add the following paragraph called Consistency Between the SCS and the RTP Comment incorporated.
           Policy, Action,                          Policy, Financial, and Action Elements: To promote consistency between the
  63         Financial       Rob Ball    Kern COG   SCS and RTP core elements, an MPO may integrate the SCS within these
           Elements and                             elements rather than create a separate, stand-alone SCS element.
                SCS
                                                    Section 2.6 should be deleted. Discussion of Complete Streets and Corridor     Based upon comments received, Section 2.6 was left intact.
                                                    System Management Plans are a Congestion Management issue that deal with Reorganization of the Guidelines is being considered for
            Section 2.6
                                                    how a region addresses level of service. These sections should be incorporated future drafts.
            Coordination
                                                    under the CMP discussion of the RTP. Context Sensitive Solutions is an
  30         with Other      Rob Ball    Kern COG
                                                    Environmental Justice Issue and should be discussed in the EJ Section of the
              Planning
                                                    RTP. The Smart Mobility Framework is a Performance Measure issue and
             Processes
                                                    should be discussed under performance measures.

             Section 4.2                            Add the following paragraph called Amendments Prior to an Approved SCS           Language incorporated for review and comment by the
             Adoption -                             (Grace Period): An MPO is not required to implement an SCS or other              subcommittee and full workgroup.
  64       Update Cycles     Rob Ball    Kern COG   consistency requirements until the first 4 or 5 year complete RTP update after
                and                                 the greenhouse gas targets are available for their region.
            Amendments
            Section 4.24                            TSMs can be discussed under the CMP as a federal component.                      Comment noted.
  91       Transportation    Rob Ball    Kern COG
              Systems
           Operations and
            Section 4.28                            ITS can be discussed under the CMP as a federal component.                       Comment noted.
  94        Regional ITS     Rob Ball    Kern COG
            Architecture



       9496f356-58e1-4fec-a264-f201c6444e28.xls                                            Page 17                                                                                 11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name        Agency    Comment                                                                              Response
                                                    This section should be renamed Progress Tracking Performance Indicators.             Section 4.29 is currently under construction pending input
            Section 4.29
                                                    The third listing of measures for cost effectiveness requiring future year           from the RTAC Coordination Workgroup.
  95        Performance      Rob Ball    Kern COG
                                                    modeling should be included in the Section 3.0 Modeling Performance
             Measures
                                                    Measures
                                                    Insert the following paragraph entitled Role of the SCS in the Environmental            This language was modified to correct the fact that RTPAs
                                                    Document Alternatives Analysis: the MPO/RTPA may choose to address the                  are not statutorily required to prepare an SCS and removed
                                                    SCS as part of the alternatives analysis for the environmental document to the          the last sentence to avoid overly prescriptive language. The
                                                    RTP. This may provide an added level of consistency between the                         language now reads: "MPOs may choose to address the
            Section 4.34
                                                    enviornmental document and the SCS. Other Alternatives that may be                      SCS (and APS, if applicable) as part of the alternatives
  103      Environmental     Rob Ball    Kern COG
                                                    considered include the APS, the Business as Usual (BAU), and the No-Build.              analysis for the environmental document to the RTP. This
           Documentation
                                                                                                                                            may provide an added level of consistency between the
                                                                                                                                            environmental document and the SCS (and APS, if
                                                                                                                                            applicable). This language may also be moved to the SCS
                                                                                                                                            Chapter of the Guidelines.
            Section 4.42                            Insert the following paragraph to the Regional GHG Reduction Targets                    Language not incorporated. The RTP Guidelines do not have
            Sustainable                             subsection entitled Strategic Employment Centers Exemptions for GHG                     statutory authority to grant exemptions from consideration for
            Communities                             Analysis: Regions with rural employment centers that are not conducive to infill vehicle and light truck related GHG analysis. This issue must
  120         Strategy       Rob Ball    Kern COG   should be granted an exemption from consideration for vehicle and light truck           be addressed by ARB.
             Process,                               related GHG analysis. Strategic land uses in these areas include: wind farms,
            Review, and                             solar farms, bio fuels, military, farming, forestry, mining, oil, distribution centers,
            Acceptance                              prisons, recreation/tourism, land fills, etc.
                                                    Add a new paragraph to the Addressing Housing Needs in the SCS subsection This section is under construction. Language not
                                                    entitled Housing Forecasts and DOF: Housing Element law now requires that               incorporated pending statutory verification of these
                                                    growth forecasts used in the housing element be with in 3% of the Department requirements and consideration of this language by the Land
                                                    of Finance (DOF) forecast for the horizon year of the RTP. Differences in               Use and Housing Workgroup at the November 10th meeting.
            Section 4.41
                                                    forecasts may be negotiated in consultation with DOF. To resolve the issue,
  118      Contents of the   Rob Ball    Kern COG
                                                    the state or neighboring regions should develop and maintain an economic
               SCS
                                                    model that predicts based on a balance of employment wages and housing
                                                    costs, when a household chooses to migrate to a neighboring region. Lacking
                                                    such a model, the State shall use the MPOs estimate for net migration of
                                                    households.
                                                    Add a new paragraph to the Addressing Housing Needs in the SCS subsection This section is under construction. Language not
                                                    entitled Housing Data Book as part of RHNA: To streamline development of                incorporated pending consideration of this language by the
                                                    Housing Elements by local governments, the MPO should consider the                      Land Use and Housing Workgroup at the November 10th
            Section 4.41                            development of a Housing databook broken out by jurisdiction, with all the              meeting.
  119      Contents of the   Rob Ball    Kern COG   reporting requirements for the housing element and federal comprehensive
               SCS                                  housing plans. The databook could include a combined regional housing
                                                    conditions report based on sampled data and extrapolated to the region using
                                                    Geographic Information Systems (GIS) and other techniques.




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                               Page 18                                                                                        11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section        Name         Agency   Comment                                                                             Response
                                                   EPA suggests revising the language in bullets 3 and 6 (note that we are not         This section is currently under construction. Land Use
                                                   proposing any changes to bullets #4 and #5) by combining the two bullets with       strategies identified in the previous draft (10-1-09) have been
                                                   the replacement language below which is consistent with federal                     moved to Section 4.43 and are being re-written to
                                                   recommendations for land use that is not consistent with historical trends:         incorporate comments received. EPA provided language has
            Section 2.2                            Where areas include strategies that result in land use changes different than       been incorporated into Section 4.41 Contents of the SCS
           Background on                           historical trends, federal, state and local agencies should be consulted to reach   under the Role of Existing General Plans and Spheres of
              Climate                              agreement that the land use assumptions are reasonable, best available, and         Influence subsection and will also be incorporated into
                             Karina
  26        Change and                    USEPA    consistent with the transportation system planned to meet federal guidance on       Section 4.43 which is currently under construction.
                            O'Connor
             Regional                              land use. Additional best practice language for Section 4.43 is provided as
             Blueprint                             follows: When land use assumptions are radically different from historical, the
             Planning                              consultation process should be used to determine why these assumptions are
                                                   appropriate. The RTP should explain why the assumptions are appropriate. In
                                                   subsequent conformity determinations, land use assumptions should be
                                                   reevaluated through the interagency consultation process.

                                                   On page 37 EPA recommends som changes to the text to clarify the scope and Language incorporated for review and comment by the
                                                   regulatory references for the Transportation Conformity regulations. Replace      subcommittee and full workgroup.
                                                   language in the third paragraph with the following: Section 176(c) of the Clean
                                                   Air Act (CAA), as amended (42 U.S.C. 7401 et seq. ), and the related
                                                   requirements of 23 U.S.C. 109(j), ―transportation conformity‖ requirement
                                                   ensures that Federal funding and approval are given to transportation plans,
                                                   programs and projects that are consistent with the air quality goals established
             Section 2.3
                             Karina                by a State Implementation Plan (SIP). For MPO nonattainment regions, the
  27          Federal                     USEPA
                            O'Connor               MPO and FHWA are responsible for making the RTP conformity determination.
            Requirements
                                                   Both the MPO and FHWA must be able to determine that any new
                                                   transportation projects will not cause or contribute to any new air quality
                                                   violations, worsen existing violations or delay timely attainment of the National
                                                   Ambient Air Quality Standards or interim milestones. The transportation
                                                   conformity rule (40 CFR Part 93) sets forth policy, criteria, and procedures for
                                                   demonstrating and assuring conformity of transportation activities. Change the
                                                   Federal Requirements citiation to read: Title 23 CFR part 450 and Title 40 CFR
                                                   part 93




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                            Page 19                                                                                        11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section        Name         Agency   Comment                                                                                  Response
                                                   USEPA recommends the following clarifications to the discussion of                       Language incorporated for review and comment by the
                                                   interagency consultation. The fourth paragraph of this section should be                 subcommittee and full workgroup.
                                                   modified to read: MPOs/RTPAs participate in air quality planning by providing
                                                   vehicle counts for emissions inventories. They also develop methods to reduce
                                                   transportation related emissions. This participation helps lay the groundwork
                                                   for development of air quality plans and future conformity determinations to the
            Section 4.10                           plans. All MPOs/RTPAs in nonattainment and maintenance areas must
            Consultation     Karina                coordinate the development of their RTPs with the Air Quality Management
  74                                      USEPA
                and         O'Connor               District(s) located within the MPOs region, the California Air Resources Board,
            Coordination                           Caltrans, local transportation agencies, EPA, and DOT in order to ensure
                                                   conformity with the SIP. The federal Clean Air Act Amendments of 1990
                                                   requires SIP development to be coordinated with the transportation planning
                                                   process (Title 42, Section 7504(b)). Detailed requirements may also be found
                                                   in 40 CFR 51 and 93 (Transportation Conformity rules). Federal Requirements
                                                   citation should be amended to read: Transportation Conformity regulations of
                                                   40 CFR 93.105
                                                   USEPA recommends revisions to this section in order to more clearly identify             Language incorporated for review and comment by the
                                                   what SAFETEA-LU required. The Federal Requirements citiation section                     subcommittee and full workgroup.
                                                   should be amended to read: Title 23 CFR part 450.322(g)(1) & (g)(2) requires
                                                   that the MPO shall consult, as appropriate, with State and local agencies
                                                   responsible for land use management, natural resources, environmental
            Section 4.17                           protection, conservation, and historic preservation concerning the development
            Consultation     Karina                of the transportation plan. The consultation shall involve, as appropriate: (1)
  84                                      USEPA
           with Resource    O'Connor               Comparison of transportation plans with State conservation plans or maps, if
              Agencies                             available; or (2) Comparison of transportation plans to inventories of natural or
                                                   historic resources, if available. In addition, the discussion of mitigation activities
                                                   required by SAFETEA-LU section 450.322(f)(7) (and described more fully in
                                                   Section 4.35 below) shall be developed in consultation with Federal, State, and
                                                   Tribal land management, wildlife, and regulatory agencies.




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                              Page 20                                                                                      11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.     Section        Name        Agency   Comment                                                                          Response
                                                 USEPA recommends revisions to this section in order to clearly identify what     Language incorporated for review and comment by the
                                                 SAFETEA-LU requires regarding identification of mitigation activities through    subcommittee and full workgroup.
                                                 the Regional Transportation Planning process. Section 4.35 summarizes the
                                                 requirements, yet doesn‘t include all important elements of the requirements.
                                                 The proposed revisions identify the ―shalls‖ identified in SAFETEA-LU and
                                                 provide greater consistency. In addition, Page 107 of Section 4.37 states that
            Section 4.35                         ―Title 23 CFR part 450.306(a)(5) requires that the metropolitan planning
           SAFETEA-LU       Karina               process addresses protection and enhancement of the environment, among
  104                                   USEPA
           Environmental   O'Connor              other planning factors”. Yet this statement is included in a section titled ―Key
           Requirements                          environmental considerations for best practices” (Section 4.37 – page 105).
                                                 This is also followed up by a sentence in the ―Best Practices‖ section that
                                                 states, ―Voluntarily addressing all of the applicable topics noted above during
                                                 the preparation of the RTP would be considered as a best practice.” Because it
                                                 is a requirement to address protection and enhancement of the environment,
                                                 we are recommending Title 23 CFR part 450.306(a)(5) be identified as a ―shall"

                                                 USEPA recommends replacing the Federal Requirements citation with the               Language incorporated for review and comment by the
                                                 following statutory language: SAFETEA-LU section 450.322(f)(7) requires that subcommittee and full workgroup.
                                                 the RTP 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 metropolitan transportation plan. The
                                                 discussion shall be developed in consultation with Federal, State, and Tribal
                                                 land management, wildlife, and regulatory agencies.
                                                 SAFETEA-LU section 450.322(g)(1) and (2) requires that the MPO shall
                                                 consult, as appropriate, with State and local agencies responsible for land use
            Section 4.35                         management, natural resources, environmental protection, conservation, and
           SAFETEA-LU       Karina               historic preservation concerning the development of the transportation plan.
  104                                   USEPA    The consultation shall involve, as appropriate: (1) Comparison of transportation
           Environmental   O'Connor
           Requirements                          plans with State conservation plans or maps, if available; or (2) Comparison of
                                                 transportation plans to inventories of natural or historic resources, if available.
                                                 SAFETEA-LU section 450.306(a)(5) requires that the metropolitan
                                                 transportation planning process shall be continuous, cooperative, and
                                                 comprehensive, and provide for consideration and implementation of projects,
                                                 strategies, and services that will address the following factors…Protect and
                                                 enhance the environment, promote energy conservation, improve the quality of
                                                 life, and promote consistency between transportation improvements and State
                                                 and local planned growth and economic development patterns. See Section
                                                 4.37 and below for key environmental considerations for best practices.




     9496f356-58e1-4fec-a264-f201c6444e28.xls                                           Page 21                                                                                   11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name      Agency   Comment                                                                           Response
                                                 USEPA recommends the following best practices information: Advanced               Best practice information and links have been incorporated.
                                                 mitigation planning to identify areas for mitigation prior to project-by-project
            Section 4.35
                                                 discussion is a best practice. Elkhorn Slough Early Mitigation Project and
           SAFETEA-LU         Karina
  104                                   USEPA    Regional Advanced Mitigation Planning (RAMP) are important examples of
           Environmental     O'Connor
                                                 such efforts. Coordinating early with agencies responsible for project-level
           Requirements
                                                 permitting can lead to identification of regional priority conservation areas and
                                                 can lead to more effective mitigation.
                                                 On October 8, 2009, EPA designated issued final designations for the final        Map updated.
            Section 4.39
                                                 particulate standard (PM2.5), which was revised in 2006 to a level of 35 ug/m3.
           Air Quality and    Karina
  108                                   USEPA    This action designated one new county, Yuba as nonattainment. Please add
           Transportation    O'Connor
                                                 this area as nonattainment to the map on page 110.
             Conformity
                                                 Under the SIP Conformity Requirement please insert the following language:       Language incorporated for review and comment by the
            Section 4.39
                                                 Once a non-attainment area meets the NAAQs, if the area develops a               subcommittee and full workgroup.
           Air Quality and    Karina
  111                                   USEPA    maintenance plan and submits a redesignation request, the U.S. EPA can
           Transportation    O'Connor
                                                 change or redesignate the area as a ―maintenance‖ area.
             Conformity
                                                 Under the RTP Conformity subsection please insert the following language:        Language incorporated for review and comment by the
                                                 Transportation conformity requirements apply to all U.S.EPA designated non- subcommittee and full workgroup.
                                                 attainment and maintenance areas. When areas are designated as non-
            Section 4.39                         attainment for the first time, a conformity determination must be made within
           Air Quality and    Karina             one year of the effective date of the determination. RTP and FTIP
  111                                   USEPA
           Transportation    O'Connor            amendments, Federal project approvals and Federal funding are all contingent
             Conformity                          upon the conformity determination that shows how the total emissions
                                                 projected in the RTP and FTIP do not increase emissions beyond baseline
                                                 emissions or are within the emission limits or ‗budgets‘ established in the SIP.

                                                 On p.111 the Federal Requirements citation should be amended to read: 40        Language incorporated for review and comment by the
                                                 CFR 93.104(b)(3) and (c)(3) changes the required frequency of transportation subcommittee and full workgroup.
                                                 conformity determinations for RTPs and FTIPs from three years to four years;
                                                 176(c)(2)(E) and 40 CFR 93.104(e) provide two years to determine conformity
            Section 4.39                         after new SIP motor vehicle emissions budgets are either found adequate,
           Air Quality and    Karina             approved or promulgated; 176(c)(9) and 40 CFR 94.104(b)(3) adds a one-year
  111                                   USEPA
           Transportation    O'Connor            grace period before the consequences of a conformity lapse apply; 176(c)(4)(E)
             Conformity                          and 40CFR 93.105 provides streamlining requirements for conformity SIPs;
                                                 and, 176(c)(8) and EPA‘s policy January 2009 guidance (EPA420-B-09-002)
                                                 identifies procedures for areas to use in substituting or adding transportation
                                                 control measures (TCMs) to approved SIPs.




     9496f356-58e1-4fec-a264-f201c6444e28.xls                                           Page 22                                                                                    11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name      Agency   Comment                                                                             Response
                                                 On page 112 the guidelines contains a reference to greenhouse gas related           The greenhouse gas language in this section has been
                                                 language in an environmental protection act. This is incorrect and EPA              condensed and the Climate Change legislation discussion
                                                 suggests the following replacement language: Currently, the federal                 has been moved to Section 2.2 which focuses on state level
            Section 4.40                         government has several domestic and international voluntary programs                climate change legislation. At the time proposed federal
            Greenhouse                           designed to reduce greenhouse gas emissions. These programs do not contain          climate change legislation for the consideration of
                              Karina
  113      Gas Emissions                USEPA    regulatory programs the development of RTPs at this time, however there is          greenhouse gas emissions in RTPs is passed, this
                             O'Connor
            Targets and                          proposed climate change legislation that could require consideration of             information will be incorporated into future RTP Guidelines
            Background                           greenhouse gas emissions into RTPs under federal regulations. United States         updates as needed.
                                                 Environmental Protection Agency will submit revisions to the guidelines if and
                                                 when new federal regulations are developed.

                                                 Page 113 states that ―The intent of the regional blueprint program is to identify   Comment noted and considered in the development of the
                                                 land use, transportation, and environmental connections‖ and ―The SCS is a          Resource Areas and Farmland subsection withint SCS
                                                 continuation of this regional blueprint process which started in 2003‖.             Contents.
            Section 4.41                         Consideration of the environment is a key component to the three ―E‘s‖ within
                              Karina
  113      Contents of the              USEPA    the regional blueprint process (Environment, Equity, Economy). Yet a challenge
                             O'Connor
               SCS                               exists with a ―sustainable community strategy‖ potentially being developed for
                                                 multiple regions with extensive efforts to reduce greenhouse gas emissions and
                                                 without due consideration to other environmental issues that are integral to
                                                 creating sustainable communities.
                                                 US EPA proposes revisions within the text of Section 4.41, as well as another       Comments noted, this information was considered in the
                                                 SubSection within Section 4.41, to reflect the intent of the Blueprint program in   development of the Resources Areas and Farmland
                                                 integrating environmental considerations into Regional Blueprints, and              subsection of the SCS Contents section, and in Section 2.2.
                                                 ultimately into the SCS, beyond measures to reduce greenhouse gases. This is
                                                 important if the SCS is considered a ―continuation of the blueprint process‖ as
                                                 identified on page 113. The revisions are provided with an understanding that
                                                 the scope and definitions as provided for in CA Government Code Section
            Section 4.41
                              Karina             65080 cannot be changed. Rather, they are proposed in order to create a link
  115      Contents of the              USEPA
                             O'Connor            between new SCS requirements and existing SAFETEA-LU requirements and
               SCS
                                                 to provide recommendations to avoid potential project-level resource/regulatory
                                                 disputes at such time that Federal regulatory requirements, including Clean
                                                 Water Act and Endangered Species Act, may affect what a region has
                                                 identified as a ―Sustainable Community Strategy‖. For example, a
                                                 recommended transportation/housing scenario that would affect sensitive
                                                 resources may need to be altered in the future if such a scenario is not
                                                 permittable under federal regulation.




     9496f356-58e1-4fec-a264-f201c6444e28.xls                                            Page 23                                                                                     11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name      Agency   Comment                                                                              Response
                                                 USEPA proposed addition to Section 4.41 - Resource Areas, Open Space, and            A new section was created under SCS Contents for
                                                 Environmental Protection: California Government Code Section 65080 requires          Resource Areas and Farmland. Language provided by
                                                 that the SCS shall identify regional land uses, including resource areas and         USEPA was paraphrased and combined with other
                                                 open space. Based on reasonable land use assumptions, the SCS shall set              comments to focus on statutory requirements of SB 375.
                                                 forth the forecasted development pattern within the region. As a complement to       Best practices information was incorporated into Section
                                                 forecasting the development pattern, through the RTP, MPOs can also identify         4.37 since best practice level of detail is not provided in the
                                                 a proposed resource area and open space pattern as well. As previously               SCS Contents Section, please note this section is still under
                                                 discussed in Section 4.35, SAFETEA-LU section 450.322(f)(7) requires that the        construction.
                                                 RTP 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 metropolitan transportation plan. In addition,
                                                 SAFETEA-LU section 450.322(g)(1) and (2) requires that the MPO shall
                                                 consult, as appropriate, with State and local agencies responsible for land use
            Section 4.41                         management, natural resources, environmental protection, conservation, and
                              Karina
  115      Contents of the              USEPA    historic preservation concerning the development of the transportation plan,
                             O'Connor
               SCS                               including a comparison of transportation plans with State conservation plans or
                                                 maps, if available, or comparison of transportation plans to inventories of
                                                 natural or historic resources, if available. In order to both comply with the
                                                 requirements of CA Government Code Section 65080(b)(2)(b) as well as
                                                 SAFETEA-LU sections 450.322(f)(7), 450.322(g)(1) and (2), MPOs may
                                                 develop a Regional Open Space and Conservation Area Framework, or
                                                 ―Greenprint‖ which identifies existing resource areas such as parkland, forests,
                                                 and designated conservation areas, as well as those targeted for existing or
                                                 future protection due to presence of sensitive resources, high value aquatic
                                                 resources, vernal pools, sensitive habitat, wildlife movement corridors,
                                                 floodplains, etc. This would support the SAFETEA-LU requirements to ―include
                                                 a discussion of types of potential environmental mitigation activities and
                                                 potential areas to carry out these activities‖ as well as supporting sustainable,
                                                 livable communities.
                                                 In the Identifying Land Uses in the SCS subsection language should be                This sentence was removed from this section based upon
            Section 4.41
                              Karina             modified to read: MPOs are challenged, through development of the SCS, to            comments received from the 10-8-09 joint subcommittee
  115      Contents of the              USEPA
                             O'Connor            encourage local jurisdictions to balance housing jobs, services, education,          meeting indicating that it was too vague and that the use of
               SCS
                                                 recreation, and environmental protection                                             the word balance was hard to define.
                                                 The following language should be incorporated into Section 4.41: The SCS             This language was incorporated into the suggested contents
                                                 should contain a map or series of maps that will provide a visual reference of       of the SCS. Best practice level of detail was not incorporated
                                                 the various land uses within the region. Maps should show a balance between          into the SCS Contents section and all references to the
            Section 4.41                         land use, housing, transportation, and environmental resources. Maps may             balancing of land uses was removed based upon comments
                              Karina
  115      Contents of the              USEPA    display types of land use, including vacant developable land, potential              received.
                             O'Connor
               SCS                               development densities, and location of transit facilities as well as amenities and
                                                 safe access to the transportation network for pedestrians and bicyclists. Maps
                                                 may also display farmland, open space and resource areas, as well as land
                                                 proposed for future conservation or mitigation.



     9496f356-58e1-4fec-a264-f201c6444e28.xls                                             Page 24                                                                                        11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name           Agency        Comment                                                                             Response
                                                           Suggest the first paragraph be modified to read: Transportation planning and        Language incorporated for review and comment by the
            Section 1.1                                    land use planning has become more closely linked. Following the passage of          subcommittee and full workgroup.
           Why Conduct                     League of CA    SB 375, the reduction of greenhouse gases has become one of the key
  11        Long-Range      Bill Higgins   Cities, CSAC,   priorities in the transportation planning in addition to improving transportation
           Transportation                     and APA      mobility, addressing federal air quality criteria pollutants and ensuring the
              Planning                                     statewide transportation system addresses local, regional and statewide
                                                           economic and mobility needs.
            Section 1.1                                    In the fourth paragraph the original sentence referenced land use and housing.      Sentence was modified to reference the forecasted
           Why Conduct                     League of CA    Any such reference should reference should reference 65080(b)(2)(B)(vii),           development pattern, transporation network, and other
  13        Long-Range      Bill Higgins   Cities, CSAC,   which includes a forecasted development pattern, transportation network, and        transportation measures and policies to meet the target.
           Transportation                     and APA      other transportation measures and policies, that will achieve the target.
              Planning
                                                           Modified the second bullet in the secon paragraph to read: The RTP must             Language incorporated for review and comment by the
                                                           include a sustainable communities strategy (SCS) that includes a forecasted         subcommittee and full workgroup.
                                                           development patter for the region, which, when integrated with the
            Section 1.4                    League of CA    transportation network, and other transportation measures and policies, will
  17       Purpose of the   Bill Higgins   Cities, CSAC,   reduce the greenhouse gas emissions from automobiles and light trucks to
               RTP                            and APA      achieve, if feasible, the greenhouse gas emission reduction target approved for
                                                           the region by the state Air Resources Board. The MPO will need to increase its
                                                           coordination with cities and counties within the region to work towards
                                                           strategies that will reduce regional GHG emissions.
                                                           Do we really need this section? Doesn‘t it repeat what is included in the rest of   Comment noted, this section is currently under construction.
                                           League of CA
                                                           the document? This information should not be held in a SB 375 only section –
  21         Section 1.8    Bill Higgins   Cities, CSAC,
                                                           SB 375 has to be fully integrated into the RTP. As such, this entire Section 1.8
                                              and APA
                                                           is not helpful.
                                                           Suggested the following language for inclusion in this section: Regional land       This section is currently under construction and being re-
            Section 2.2                                    use projections that underlie RTPs have typically assumed existing growth           written.
           Background on                                   trends will continue in the future, based on general plans that are prepared by
              Climate                      League of CA    cities and counties. Beginning in 2004, 17 of the 18 MPOs have undertaken
  26        Change and      Bill Higgins   Cities, CSAC,   regional visioning or ―blueprint‖ processes to look at how regions can grow
             Regional                         and APA      more efficiently and meet more environmental and social goals. Some MPOs
             Blueprint                                     have been able to use the Blueprint process to change the projection of
             Planning                                      existing growth trends in a way that improves the quality of the built out
                                                           communities.




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                                    Page 25                                                                                       11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section          Name           Agency      Comment                                                                             Response
                                                          The Land Use strategies identified on p.32 and 33 of the previous draft (10-1-      This section is currently under construction and land use
                                                          09) have been re-written to include: 1. Encourage cities and counties to            strategies are being modified to remove confusing or
                                                          consider the regional blueprint plan and the SCS for the region when they are       contradictory references to general plans, blueprints and the
                                                          updating their general plan, 2. Assure that there is a reasonable basis for the     SCS.
            Section 4.43                                  forecasted development pattern included in the RTP and the SCS, 3. Build land
           Land Use and                                   use changes within city and county general plans into the forecasted
           Transportation                                 development pattern projections in the base case for modeling purposes, 4. To
                                            League of CA
            Strategies to                                 the extent feasible, where there is a regional blueprint and an SCS, encourage
  122                        Bill Higgins   Cities, CSAC,
              Address                                     that, the forecasted development pattern for the Regional Transportation Plan
                                               and APA
           Regional GHG                                   is consistent with that regional agency‘s blueprint and the SCS, 5. To the extent
            Emissions in                                  feasible, encourage that the forecasted development pattern for the regional
              the RTP                                     blueprint and the SCS are consistent with federal regulations and current or
                                                          projected local general plans



            Section 2.2                                   The Land Use Assumptions paragraph on p. 33 of the previous draft (10-1-09)         The land use assumptions section was removed based upon
           Background on                                  should be re-titled: Forecasted Developmment Patterns - forecasted                  comments received.
              Climate                       League of CA development patterns are based on assumptions relating to, population,
  26        Change and       Bill Higgins   Cities, CSAC, economics and land use.
             Regional                          and APA
             Blueprint
             Planning
                                                          Inserted the following language into the Complete Streets subsection: However, Comment noted. Subsection was revised to be less
                                                          it is recognized that the local system is significantly underfunded with an     directive.
            Section 2.6
                                                          identified statewide shortfall of $71 billion over the next decade just to
            Coordination                    League of CA
                                                          accommodate preservation of the existing system. Further, it is acknowledged
  30         with Other      Bill Higgins   Cities, CSAC,
                                                          that Complete Streets‘ requirements will require additional funding to fully
              Planning                         and APA
                                                          implement. Also suggested adding the following phrases: "identify the financial
             Processes
                                                          resouces necessary to accomodate such policies" and "to the extent
                                                          practicable"
            Section 4.1                                   Added "local streets and roads" to first paragraph of p. 61, 62, and "regional  Comment incorporated.
           Policy, Action,                  League of CA and local" transportation system to bullet #1 under Financial Element on p.62.
  61         Financial       Bill Higgins   Cities, CSAC,
           Elements and                        and APA
                SCS
                                                          Modified the land use strategies listed under the Policy Element section to         Land Use strategies are being re-written and incorporated
                                                          read: 1. Develop investments and programs that support local jurisdictions that     into section 4.43 since best practice level of detail is not
            Section 4.1                                   make land use decisions that implement, as appropriate, the SCS, regional           contained in the general overview section of the RTP
           Policy, Action,                  League of CA blueprints and other strategies that will help reduce greenhouse gas emissions       Guidelines.
  61         Financial       Bill Higgins   Cities, CSAC, and improve the quality of mobility throughout the region. 2. Emphasize
           Elements and                        and APA    transportation investments in areas where forecasted development patterns
                SCS                                       indicate may result in reduced vehicle miles traveled (VMT) or achieve some
                                                          other desired policy outcome.


       9496f356-58e1-4fec-a264-f201c6444e28.xls                                                    Page 26                                                                                       11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section          Name           Agency      Comment                                                                            Response
            Section 4.1                                   The Sustainable Communities Strategy List on p. 62 and 63 repeats Section          Section 1.8 is currently under construction.
           Policy, Action,                  League of CA 1.8
  62         Financial       Bill Higgins   Cities, CSAC,
           Elements and                        and APA
                SCS
                                                          Suggested the following language be included at the bottom of p. 77: For          A paraphrased version of this language was incorporated,
                                                          MPOs only, SB 375 increased the minimum level of public participation             the reference to ARB review of GHG technical methodology
                                                          required in the regional transportation planning process in so far as there are   was removed as it is duplicated in Section 4.42.
                                                          specific requirements for an SCS. But these requirements can be incorporated
                                                          into the existing plan. Prior to the Public Participation Process for development
                                                          and review of the SCS (as identified in Government Code 65080), the MPO will
            Section 4.11
                                            League of CA need to provide the ARB with the technical methodology it intends to use to
               Public
  77                         Bill Higgins   Cities, CSAC, estimate the GHG emissions from its SCS, and if appropriate, the APS. The
            Participation
                                               and APA    ARB and the MPO should work collaboratively to ensure the ARB is able to
                Plan
                                                          conclude the technical methodology identified by the MPO operates accurately.
                                                          Public Participation and Consultation for the development of an RTP remains
                                                          essential. Mapping and visualization tools should be used to the extent that
                                                          they lead to open and efficient consideration of proposed scenarios and can
                                                          lead to a well-informed public selection of an SCS.

                                                            Suggest inserting a cross-reference to Section 4.35.                             The following language was inserted on p.84: "Additional
            Section 4.17
                                            League of CA                                                                                     guidance regarding federally required consulation with
            Consultation
  83                         Bill Higgins   Cities, CSAC,                                                                                    resource agencies during the RTP development process is
           with Resource
                                               and APA                                                                                       available in Section 4.35 SAFETEA-LU Environmental
              Agencies
                                                                                                                                             Requirements.
                                                          We do not have time to provide language, but we believe that this section          Comment noted, the environmental sections are still under
                                                          should include a discussion of the CEQA incentives relating to an SCS and          construction and there will be a CEQA appendix.
            Section 4.34                    League of CA
                                                          APS in addition to Transportation Priority Projects? At least as a best practice,
  102      Environmental     Bill Higgins   Cities, CSAC,
                                                          it would seem a good idea to encourage MPOs to think about these in the
           Documentation                       and APA
                                                          design of their environmental documents to help local agencies to take
                                                          advantage of this streamlining.
            Section 4.35                                  Cross reference this section to Section 4.17 - should they be combined?           Comment noted, the environmental sections are still under
                                            League of CA
           SAFETEA-LU                                                                                                                       construction.
  104                        Bill Higgins   Cities, CSAC,
           Environmental
                                               and APA
           Requirements
                                                          For the reasons commented on below, this section does not add anything             Based on the comments received this section (and the SCS
            Section 4.40
                                                          specifically relating to what needs to be done in an RTP. It should be stricken.   Overview and Background section) was shortened
            Greenhouse                      League of CA
                                                          Federal government has nothing to do with GhG ―Targets‖ which is the title of      considerably. Climate Change legislation discussion can
  113      Gas Emissions     Bill Higgins   Cities, CSAC,
                                                          this subhead. What do the six GHGs have to do with the RTP? You could say          now be found in Section 2.2.
            Targets and                        and APA
                                                          that Transportation is 37 percent of the state‘s CO2 and leave at that.
            Background
            Section 4.41                    League of CA Regional Land Uses subsection of SCS Contents should read: "Identification of Language incorporated for review and comment by the
  114      Contents of the   Bill Higgins   Cities, CSAC, general land uses, residential densities, and building intensities within the subcommittee and full workgroup.
               SCS                             and APA    region.


       9496f356-58e1-4fec-a264-f201c6444e28.xls                                                    Page 27                                                                                  11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section          Name           Agency        Comment                                                                              Response
                                                            Regarding the Regional Housing Needs subsection: Disagree with Stivers               The Contents of the SCS section was restructured to feature
                                                            recommendation for this paragraph. This language tracks what is in 65080.            required and suggested SCS contents. Requirements are
                                                            Economic Segments is defined via statute, and the proposed language for              tied directly to statute. Suggested contents feature language
                                                            ―areas sufficient to house‖ may not be the only way to do it. The ―shall‖ in         such as could, should, and may. The "Areas Sufficient to
                                                            Mark‘s comments is too strong. The Areas Sufficient to House part should be          House" language will be considered by the Land Use and
            Section 4.41                    League of CA    edited out because it only represents one method—a very onerous one—in               Housing Workgroup at the November 10th meeting.
  114      Contents of the   Bill Higgins   Cities, CSAC,   which this could be demonstrated. I think its saying a lot for the MPOs to be
               SCS                             and APA      casting probably densities 20 years in advance – they simply will not know
                                                            many of the sites that will be available yet (infill sites rarely become available
                                                            20 years in advance). The net effect will lead to sprawl. As an alternative, an
                                                            MPO may make reasonable assumptions about infill opportunities and the
                                                            availability of housing opportunities within such areas without getting as
                                                            detailed as what is suggested in the stricken language.
            Section 4.41                    League of CA    Suggested the incorporation of statutory language requiring the consideration        Statutory language inserted.
  115      Contents of the   Bill Higgins   Cities, CSAC,   of Resouce Areas and Farmland.
                SCS                            and APA
            Section 4.41                    League of CA The Social Equity and Environmental Justice subsection just repeats what was            Comment noted, this section is under construction and is
  121      Contents of the   Bill Higgins   Cities, CSAC, said in housing – maybe use this section to highlight other social equity issues       being considered by the RTAC Coordination workgroup.
                SCS                            and APA    – such as transportation cost, job housing fit, etc.
            Section 4.46                                  This section could be rewritten into one or two paragraphs. Basically, the             This section is being condensed and re-written based upon
             Addressing                                   recommendation is that MPOs should consider Adaption in their plans and                comments received.
              Climate                                     consult the CAS. Why do we need so many words?
                                            League of CA
              Change
  123                        Bill Higgins   Cities, CSAC,
            Adaptation to
                                               and APA
            the Regional
           Transportation
               System
                                                            The following language should be incorporated into Section 4.1 on p. 63 under        Statute does not specify that the consistency requirement is
            Section 4.1
                                                            the subheading Consistency Between the SCS and the RTP Policy, Financial             met based upon achievement of GHG reduction.
           Policy, Action,
                              Naresh                        and Action Elements: "The RTP and all its transportation investments are
  63         Financial                         SCAG
                              Amatya                        deemed to be internally consistent if the RTP is determined to achieve the
           Elements and
                                                            required GHG reduction through the SCS or APS"
                SCS
                                                            The description of the SCS seems to focus solely on the land use portion. The        Given the wide variety of resources and regional differences
                                                            Guidelines should include a description which comprehensively captures what          between MPOs across the state and the request for
                                                            an SCS will be comprised of. Elements of an SCS include 1. Growth                    flexibility, language in this section was focused closely on
            Section 4.41
                              Naresh                        distribution and land use strategies, 2. transporation network to complement         statute.
  114      Contents of the                     SCAG
                              Amatya                        the land use strategies, 3. transportation policies (i.e. TDM and TSM policies)
               SCS
                                                            and 4. other economic development strategies aligning economic development
                                                            with the land use and transportation invesment strategies.




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                                      Page 28                                                                                      11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name         Agency      Comment                                                                               Response
                                                       We are very pleased to see Complete Streets recognized as an integral                 Language incorporated for review and comment by the
                                                       component of the regional transportation planning process, and we comment             subcommittee and full workgroup.
                                                       Caltrans and CTC for its inclusion in the Guidelines. Complete Streets are a
                                                       key strategy for shifting short auto trips to walking, bicycling, or transit thus
                                                       reducing emissions.We offer the following suggestions: "While AB 1358
                                                       provides no statutory requirement for MPO's and RTPAs, the consideration and
            Section 2.6
                                                       integration of Complete Streets policies is strongly recommended." and "MPOs
            Coordination
                                                       and RTPAs should integrate Complete Streets into their RTPs and should
  30         with Other    Chris Morfas   SMAQMD
                                                       consider accelerating programming for projects that retrofit existing roads to
              Planning
                                                       provide safe and convenient travel by all users." and "MPOs and RTPAs should
             Processes
                                                       encourage all jurisdictions and agencies within the region to ensure that their
                                                       circulation elements and street and road standards including planning, design,
                                                       construction, operations and maintenance procedures, address all users of the
                                                       transportation system." and "Regional planning agencies should also include
                                                       "Complete Streets" improvements in MPO/RTPA funded transportation system
                                                       projects."
                                                       On pages 32 and 33 of the previous draft (10-1-09) Some of these strategies           These strategies are being re-written based on comments
                                                       are now requirements under SB 375, e.g. 1 and 3, while others may contradict          received and will be addressed as recommendations in
            Section 2.2
                                                       each other, e.g. 3 and 5. If working group members believe it‘s important to          Section 4.43 and Appendix J. Additionally, the RTAC
           Background on
                                                       include this section in the guidelines, perhaps it should focus solely on             Coordination Workgroup is providing insight regarding
              Climate
                                                       strategies that go beyond SB 375‘s requirements. Insert RTAC                          performance measures and land use assumptions are being
  26        Change and Julie Snyder       Housing CA
                                                       recommendations/ARB regulations re: performance measures. It should be                addressed in Section 4.41 under the subsection entitled Role
             Regional
                                                       noted that the CTC and Caltrans have convened a Housing and Land Use                  of Existing General Plans and Spheres of Influence, land use
             Blueprint
                                                       Workgroup to address the MPOs‘ land use assumptions, including the                    assumption issues will be discussed at the November 10th
             Planning
                                                       relationship to local general plans.                                                  Land Use and Housing Workgroup meeting.

                                                       Pages 114-118 (SCS Contents, Identifying Land Uses in the SCS and Housing             The SCS Contents section was revised to feature required
                                                       Issues in the SCS) These three sections are vague and seem to provide                 and suggested contents of the SCS. Definitions and more
                                                       minimal guidance to MPOs, especially in defining key terms used in the                specific examples and guidance still need to be considered
                                                       legislation. For example, the terms ―sufficient to house‖ and ―reasonable land        by the Land Use and Housing Workgroup.
                                                       use assumptions‖ are not defined in statute or regulations. Some members of
                                                       the working group have expressed a preference for vagueness. However, that
                                                       approach seems counter to the purpose of the guidelines as reflected in its
            Section 4.41
                                                       other sections. Additionally, while MPO flexibility on policy choices is desirable,
  113      Contents of the Julie Snyder   Housing CA
                                                       key underlying assumptions/definitions should be consistent from MPO to MPO
               SCS
                                                       in order to allow comparison across regions over time. Also, to ensure the
                                                       assumptions are realistic, they should be consistent between the SCS and
                                                       housing elements. One potential approach to provide clearer guidance would
                                                       be inserting a new section after the last paragraph in SCS Contents that
                                                       outlines each required components of the SCS and defines terms. The new
                                                       section could combine portions of Identifying Land Uses in the SCS and
                                                       Housing Issues in the SCS into a single, coherent set of guidelines.




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                                 Page 29                                                                                      11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section         Name         Agency      Comment                                                                              Response
                                                       Housing Issues in the SCS should be re-titled: Addressing Housing Needs in           Section has been re-titled and is currently under
                                                       the SCS. Second paragraph in this section should read: Government Code               construction.
                                                       Section 65584.04 (i) (1) addresses consistency between housing allocation and
            Section 4.41                               regional transportation planning by stating that it is the intent of the legislature
  118      Contents of the Julie Snyder   Housing CA   that housing planning be coordinated and integrated with the RTP. To achieve
               SCS                                     this goal requires the housing allocation plan to allocate housing units within
                                                       the region consistent with the development pattern included in the SCS, as well
                                                       as the allocation factors in Government Code Section 65584.04.

                                                       The Social Equity and Environmental Justice subsection should be                   This section is under construction pending input from the
                                                       substantially expanded to reflect the RTAC recommendations. The second             RTAC Coordination Workgroup. Language for the second
            Section 4.41                               sentence of this subsection should be modified to read: More transportation        sentence was incorporated.
  121      Contents of the Julie Snyder   Housing CA   and mobility choices, such as increased transit, bicycle and pedestrian
               SCS                                     facilities, and housing choices near job centers increase opportunities for all of
                                                       the population within the region (regardless of income)

                                                       We suggest that there is a lack of clarity in the current organization of the       Staff is looking into the suggested reorganization of the
                                                       Guidelines, probably because of its many revisions over the years. We               Guidelines. At this time staff is focusing on the content of the
                                                       suggest taking the opportunity of this revision of the Guidelines to clean up the   RTP Guidelines and therefore did not make any
                                                       structure. There are now many sections of Chapter 4 which relate to RTP             reorganization changes pending input from the entire
                                                       process, rather than content, and so, we believe, these should be moved to          subcommittee on the matter, reorganization of Chapter 4 will
                                                       Chapter 2. To do that sections 4.2, 4.3, 4.9 - 4.18, 4.25, 4.33 - 4.40, and 4.43    be reflected in the next Draft released on 11/23/09.
                                                       should all be moved to Chapter 2. This would have the benefit of making all
                                                       the sections of Chapter 4 pertain to actual RTP contents. (If this suggestion is
              Table of       David
   1                                      TRANSDEF     implemented, please be sure to do a global search and replace for each
              Contents     Schonbrunn
                                                       reference to the moved section numbers. Section 1.7, for example, references
                                                       all the sections added, which would all need to be updated to the new section
                                                       numbers.) If you do reorganize sections, we suggest you provide a table of
                                                       previous and revised section numbers. If you move the sections around with
                                                       Track Changes paused, the moved sections won‘t show up as new text. That
                                                       will make it much easier to review changes made to this draft.


             Section 1.2                               The last sentence in the second paragraph at the top of page 12 should be    Comment incorporated
            Background      David                      changed to read: "Pursuant to SB 375, the RTP Guidelines are to be developed
  12                                      TRANSDEF
           and Purpose of Schonbrunn                   pursuant to California Government Code sections 14522 and 65080 which
              the RTP                                  state:"




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                                 Page 30                                                                                         11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section        Name         Agency   Comment                                                                             Response
                                                   In the third sentence of the fourth paragraph on page 13 "was only directed         Requested deletion made. Paragraph was re-written to read:
                                                   toward MPOs and essentially" should be deleted and the paragraph should be          "SB 375 requires the 18 MPOs in the State to identify a
                                                   modified to read: "SB 375 requires MPOs (not RTPAs) to include land                 forecasted development pattern and transportation network
                                                   use/housing issues and strive to reduce regional greenhouse gas emissions by        that will meet greenhouse gas emission reduction targets
             Section 1.2
                                                   achieving a regional greenhouse gas emissions target specified by ARB"              specified by the California Air Resources Board (ARB)
            Background      David
  14                                    TRANSDEF                                                                                       through their RTP planning processes. These requirements
           and Purpose of Schonbrunn
                                                                                                                                       pertain only to the State‘s 18 MPOs, but not to the RTPAs
              the RTP
                                                                                                                                       that also prepare RTPs." This language was chosen based
                                                                                                                                       on statute and to further clarify that RTPAs are not subject to
                                                                                                                                       the requirements of SB 375.

                                                   Re: Bullet #1 of the second paragraph on p.17 which reads "Other than those         Comment noted. This bullet was re-written to read:
                                                   specifically exempted, transportation projects identified in the RTP must be        "Transportation Projects identified in the RTP must be
                                                   modeled to determine their impact on the regional GHG emissions." We do not         modeled to determine their impacts on regional greenhouse
                                                   think that this is what the language of the exemption means. We would like          gas emissions." Further explanation of project exemption is
            Section 1.4                            someone to explain what ―this paragraph‖ means in the law. We think that            located in Section 4.26 which is still under construction as
                            David
  17       Purpose of the               TRANSDEF   exempt projects are exempt from RTP consistency requirements, not from              exemption issues are being researched and discussed.
                          Schonbrunn
               RTP                                 modelling requirements. That wouldn‘t make any sense--it would make a
                                                   mockery of the process. In any event, this point should not be the first point
                                                   made about SB 375. It is only a refinement of the basic themes now in point
                                                   #2.

                                                   We don‘t think this section needs to be located here. Because the whole             Comment noted. This section is currently under construction
                                                   purpose of these revisions is to integrate the requirements of SB 375 into the      to address comments received and SB 375 statutory
                             David                 Guidelines, a restatement of the law is quite redundant as part of the              language will be located in the appendices.
  21         Section 1.8                TRANSDEF
                           Schonbrunn              Guidelines. Anyone reading the Guidelines would be exposed to each point
                                                   made by this section, within the far more logical organization of the Guidelines.
                                                   It would serve much better as an appendix, instead.
             Section 2.1                           The 5th paragraph on page 25 should not reference Section 1.8 based on our          Comment incorporated.
                             David
  25           State                    TRANSDEF   previous comment, we suggest referencing Section 1.7.
                           Schonbrunn
            Requirements
                                                   This original text (in black) of this section was made obsolete by SB 375.          Comment noted. This section is currently under construction
                                                   Blueprinting, PGS and alternative planning scenarios are now irrelevant. The        to clarify the relationship between regional blueprint planning
            Section 2.2                            section should be deleted, as it would confuse readers. We should phase out         and the development of the SCS. Given the fact that the
           Background on                           the use of the term ―Blueprint planning‖ and consistently use ―SCS‖ throughout      Regional Blueprint Planning program funds both MPO and
              Climate                              this document.                                                                      RTPA planning efforts and the fact that many MPOs are in
                           David
  26        Change and                  TRANSDEF                                                                                       the process of developing blueprint plans that will inform the
                         Schonbrunn
             Regional                                                                                                                  development and implementation of the SCS and APS at the
             Blueprint                                                                                                                 regional and local level, references to Blueprint Planning will
             Planning                                                                                                                  remain in the Guidelines with an emphasis on how they
                                                                                                                                       inform the SCS and APS for MPOs.




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                            Page 31                                                                                        11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section          Name        Agency    Comment                                                                              Response
                                                     Re: the Land Use strategies located on p. 32 of the 10-1-09 Draft: These             Comment noted. Land use strategies are being completely
                                                     strategies, which were developed in the last revision, were apparently revised       re-written to address the concerns raised, performance
                                                     again, with SCS added in on a random basis. Unfortunately, these last                indicators section has been deleted. Land use and
                                                     revisions were badly garbled. They can‘t be allowed to go forward in their           transportation strategies (including pricing) will be located in
            Section 2.2
                                                     current condition, as they are now factually incorrect or inappropriate.             Section 4.43 and Appendix J of the Guidelines.
           Background on
                                                     Everything in red should be deleted. We suggest that there be a collection of
              Climate
                           David                     land use strategies, along with the pricing strategies, in a strategy development
  26        Change and                    TRANSDEF
                         Schonbrunn                  section, to be placed elsewhere in Chapter 2. Please don‘t use anything from
             Regional
                                                     this draft, as it is too confused. Re: Performance Indicators: This section is now
             Blueprint
                                                     obsolete. Someone inappropriately plugged in SCS where Blueprint had
             Planning
                                                     previously been. It is wrong, and needs to be deleted



                                                     Re: the Policy Element recommendations located on p. 60 of the 10-1-09 Draft:        Comment noted. Bullet #3 was deleted. These
                                                     bullet #3 should be deleted and the recommendations should read: And, as             recommendations were removed from this location (best
                                                     MPOs and RTPAs work towards implementing Smart Growth Land Use                       practice level of detail isn't accomodated in this overview
                                                     principles within their regions, both MPOs and RTPAs are highly encouraged to        section) and will be incorporated into Section 4.43 as
            Section 4.1                              include in their Policy Element the following:                                       strategies with examples provided.
           Policy, Action,                           1. Develop investments and programs that support local jurisdictions that
                               David
  61         Financial                    TRANSDEF   make land use decisions that implement, as appropriate, the SCS, regional
                             Schonbrunn
           Elements and                              blueprints and other smart growth strategies, including rural sustainability
                SCS                                  strategies.
                                                     2. Emphasize transportation investments in areas where desired land uses as
                                                     indicated in the SCS may result in vehicle miles traveled (VMT) reduction or
                                                     other lower impact use

                                                     Re: the third paragraph under The Financial Element which reads: "It is very         Comment noted. The paragraph in question provides a
                                                     important that RTPs reflect the transportation needs of the specific region.         flexibility provision for both MPOs and RTPAs regarding how
                                                     There are State statutory content requirements for the Policy, Action and            RTPs may be formatted to meet state requirements. This is
            Section 4.1
                                                     Financial elements of the RTP; however, there is flexibility in choosing a format    an important provision that reinforces the need for flexibility
           Policy, Action,
                               David                 for the presentation of this information. Most MPOs/RTPAs use the categories         to accomodate region-specific characteristics. This flexibility
  62         Financial                    TRANSDEF
                             Schonbrunn              of Policy, Action and Financial to organize their RTP." The first sentence is a      is addressed for the SCS within the RTP in the Consistency
           Elements and
                                                     statement of the obvious. The second is redundant--these should all be               Between the SCS and the RTP Policy, Financial, and Action
                SCS
                                                     indentified in the Guidelines. There is no pattern yet for how the SCS will fit      Elements subsection added to end of Section 4.1.
                                                     into the RTPs. So we suggest this paragraph is unnecessary, and can be
                                                     deleted.




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                               Page 32                                                                                         11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section          Name        Agency    Comment                                                                                Response
                                                     Deleted the following sentence from the Sustainable Communities Strategy               Suggested language for the contents of the SCS was
                                                     (SCS) subsection: "SCS that is part of the RTP utilizing the most recent               incorporated.Statutory language of SB 375 will be included in
                                                     planning assumptions considering local general plans and other factors." This          the Appendix which will prevent the statutory requirments of
                                                     section is duplicative of 1.8. Rather than identify the statutory requirements         the SCS on p. 62 from being redundant. Suggested deletion
                                                     here (that is done elsewhere) it would be far more helpful to list exactly what        was not made based on the statutory requirement of
                                                     the SCS‘s contents are. Note that contents means a listing of nouns and not            Government Code Section 65080(b)(2)(B).
                                                     verbs. I‘ve provided a first draft attempt at this: 1. The general location of uses,
            Section 4.1
                                                     residential densities, and building intensities within the region. The resultant
           Policy, Action,
                               David                 plan shall be sufficient to house an eight-year projection of the regional housing
  62         Financial                    TRANSDEF
                             Schonbrunn              need for the region pursuant to Section 65584 and sufficient to house all the
           Elements and
                                                     population of the region, including all economic segments of the population
                SCS
                                                     over the course of the planning period of the regional transportation plan, taking
                                                     into account net migration into the region, population growth, household
                                                     formation and employment growth.
                                                     2. A transportation network to service the transportation needs of the region.
                                                     3. The best practically available scientific information regarding resource areas
                                                     and farmland in the region as defined in subdivisions (a) and (b) of Section
                                                     65080.01.
            Section 4.6                              The best practices link for the MTC plan should be updated to the 2035 plan.           Comment incorporated.
             Listing of
            Constrained        David
  70                                      TRANSDEF
                and          Schonbrunn
           Unconstrained
             Projects
                                                     The following text within Section 4.11 should be removed: "Prior to the Public Comment incorporated, suggested deletion made.
                                                     Participation Process for development and review of the SCS (as identified in
            Section 4.11                             Government Code 65080), the MPO will need to provide the ARB with the
               Public          David                 technical methodology it intends to use to estimate the GHG emissions from its
  77                                      TRANSDEF
            Participation    Schonbrunn              SCS, and if appropriate, the APS. The ARB and the MPO will also need to work
                Plan                                 collaboratively to ensure the ARB is able to conclude the technical
                                                     methodology identified by the MPO operates accurately"

                                                     Re: The bulleted list of Public Participation Plan components located on p.78:         Comment noted. This section was developed based upon
            Section 4.11
                                                     These requirements need to be integrated into the text of the previous                 SB 375 requirements for Public Participation Plans as well
               Public          David
  78                                      TRANSDEF   Guidelines. They should not remain separate like this. We don‘t have the time          as input from MPOs and the Public Participation Workgroup.
            Participation    Schonbrunn
                                                     to do that work for you.                                                               Based upon comments received for this section the list was
                Plan
                                                                                                                                            not separated.
            Section 4.26                             Need to define precisely what projects are exempted from.                              Comment noted. Staff is currently working on clarifying
           Transportation                                                                                                                   exemption language through consultation with Caltrans
                            David
  93          Projects                    TRANSDEF                                                                                          Division of Programming and Legislative Affairs staff as well
                          Schonbrunn
           Exempted from                                                                                                                    as the MPOs and ARB.
              SB 375




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                               Page 33                                                                                        11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section       Name         Agency    Comment                                                                                         Response
            Section 4.43                           The Pricing, Transportation Planning and Investment Strategies identified on p.                 These strategies will be addressed in Section 4.43 which is
           Land Use and                            99 of the previous draft (10-1-09) are hidden away in a section on congestion                   in the Greenhouse Gas Emissions Requirements and
           Transportation                          management, and will never be found by someone looking for them. They                           Considerations chapter of the RTP Guidelines.
            Strategies to   David                  should be relocated to their own section: Section x , Greenhouse Gas
  122                                   TRANSDEF
              Address     Schonbrunn               Emissions Reduction Strategies, which should be part of Chapter 2 (as it
           Regional GHG                            pertains to the development of the RTP, and not to its actual content
            Emissions in                           requirements).
              the RTP
                                                   Re: the sentence reading "The California Environmental Protection Agency         Comment noted, text deleted as requested.
            Section 4.40                           (CalEPA) prepared a briefing package for Assembly Bill (AB) 1493 entitled
            Greenhouse                             ―Global Warming and Greenhouse Emissions from Motor Vehicles‖; page 14 of
                           David
  113      Gas Emissions                TRANSDEF   this document stated that, ―Transportation is California‘s largest source of
                         Schonbrunn
            Targets and                            Carbon Dioxide.‖ It is unnecessary to provide this level of documentation or put
            Background                             it in quotes. CARB‘s GHG Emissions Inventory clearly shows this.

            Section 4.41                           Include the Overview/Background discussion in the previous section, and start 4.41 with Overview/Background discussion was shortened to provide
                             David                 Contents
  113      Contents of the              TRANSDEF                                                                                           more focus on the contents of the SCS.
                           Schonbrunn
               SCS
                                                   We have been urging from the start of this process that the key guidance needed in              Comment noted. The Role of Existing General Plans and
                                                   developing an SCS is an understanding of how to interpret latest planning assumptions           Spheres of Influence sub-section attempts to clarify how
                                                   for a blueprint-type plan that is no longer moored to local general plans. Since no one         latest planning assumptions factor into the development of
                                                   has proposed one, this is a first draft attempt: "In addition, the SCS is required to use       the SCS. The language used in this sub-section was
                                                   latest planning assumptions. (CFR ,,,) Because local general plans typically result in a
            Section 4.41                                                                                                                           provided by the Senate Transportation and Housing
                             David                 substantial increase in future VMT, it is clear that the SCS will have to modify the location
  117      Contents of the              TRANSDEF   and types of future development if it is to show reduced GHG emissions. Through a               Committee and USEPA and focuses on SB 375
                           Schonbrunn                                                                                                              requirements as well as federal requirements. This section is
               SCS                                 dynamic interchange between the MPO and local jurisdictions, an SCS will emerge that is
                                                   considered reasonable by stakeholders and representative of the latest thinking by              still under construction pending input and discussion by the
                                                   regional and local decisionmakers. This result can then be called the latest planning           Land Use and Housing Workgroup at their next meeting on
                                                   assumptions."                                                                                   November 10th.

                                                   Create a new section in Chapter 2 titled ―SCS Development Process.‖ Start it with this
                                                                                                                                    Staff is looking into the suggested reorganization of the
                                                   Multi-County piece, then Role of Cities, Identifying Land Uses, GHG Targets, Housing
                                                                                                                                    Guidelines. At this time staff is focusing on the content of the
            Section 4.41                           Issues, Addressing Regional Transportation, Social Justice, and CARB approval.   RTP Guidelines and therefore did not make any
                             David
  116      Contents of the              TRANSDEF                                                                                    reorganization changes pending input from the entire
                           Schonbrunn
               SCS                                                                                                                  subcommittee on the matter, reorganization of Chapter 4
                                                                                                                                    and Chapter 2 will be reflected in the next Draft released on
                                                                                                                                    11/23/09.
                                                   In the identifying Land Uses in the SCS subsection: "balancing land uses for all Based on the comments received, this subsection was re-
            Section 4.41
                             David                 residents within a region" - Don‘t know what this means. Is this a reference to written, language was submitted by MTC and has been
  117      Contents of the              TRANSDEF
                           Schonbrunn              housing affordability?                                                           included for review and comment by the workgroup and
               SCS
                                                                                                                                    subcommittee.




     9496f356-58e1-4fec-a264-f201c6444e28.xls                                                    Page 34                                                                                            11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section        Name        Agency    Comment                                                                            Response
                                                   "The SCS should contain a map or series of maps that will provide a visual         Mapping information is provided in Section 4.41 under the
                                                   reference of the various land uses within the region. Maps should show a           SCS contents sub-section.
                                                   balance between land use, housing and transportation. Maps may display types
            Section 4.41
                             David                 of land use, including vacant developable land, potential development
  117      Contents of the              TRANSDEF
                           Schonbrunn              densities, and location of transit facilities as well as amenities and safe access
               SCS
                                                   to the transportation network for pedestrians and bicyclists." Include this
                                                   paragraph in Section 4.41. Don‘t move it with the rest of these paragraphs.

            Section 4.41                           The first sentence of the first paragraph under the Regional GHG Reduction       Comment incorporated, suggested deletion made.
                             David
  120      Contents of the              TRANSDEF   Targets sub-section is redundant and should be deleted.
                           Schonbrunn
               SCS
                                                   Under the Housing sub-section: "The housing element shall identify adequate Comment incorporated, suggested deletion made.
                                                   sites for housing, including rental housing, factory-built housing, mobile homes,
            Section 4.41
                             David                 and emergency shelters, and shall make adequate provision for the existing
  118      Contents of the              TRANSDEF
                           Schonbrunn              and projected needs of all economic segments of the community. (Government
               SCS
                                                   Code 65583)" If this paragraph truly pertains to the housing element, it doesn‘t
                                                   belong in the Guidelines.
            Section 4.41                           Under the SCS Public Participation and Input/Consultation with Elected             Comment incorporated, this sub-section was replaced with a
                             David
  121      Contents of the              TRANSDEF   Officials sub-section: This section is entirely duplicative, and should be deleted reference to Sections 4.11 and 4.14 of the Guidelines.
                           Schonbrunn
               SCS
                                                   In the California Air Resources Board Review of the SCS subsection: the        Comment incorporated, suggested deletion made and text
                                                   language "Prior to starting the public participation process, the MPO provides moved.
                                                   ARB with the technical methodology description estimating the greenhouse gas
            Section 4.41
                             David                 emissions from its SCS, and if appropriate, its APS. The ARB and the MPO
  121      Contents of the              TRANSDEF
                           Schonbrunn              work together until ARB concludes the technical methodology operates
               SCS
                                                   accurately" should be moved to the beginning of the subsection and the MPOs
                                                   Technical Methodology for Estimating the Regional GHG Emissions subsection
                                                   should be removed.
           Section 4.46                            This section should be renamed Adaptation of the Regional Transportation       Comment incorporated.
            Addressing                             System to Climate Change
                             David
  123        Climate                    TRANSDEF
                           Schonbrunn
             Change
           Adaptation to
           Section 4.46                            Much of the text in this section (from the end of the third paragraph through the Comment incorporated. Section 4.46 was condensed based
            Addressing                             fifth) is not relevant to adaptation and is too political.                        on the comments received.
                             David
  123        Climate                    TRANSDEF
                           Schonbrunn
             Change
           Adaptation to




     9496f356-58e1-4fec-a264-f201c6444e28.xls                                              Page 35                                                                                    11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section        Name         Agency   Comment                                                                           Response
                                                   Several sections of the draft include redundant material which could be           Section 1.8 is being re-written to avoid redundant
                                                   consolidated - and can be cross referenced where appropriate: 1. The              information. Staff is also looking into the suggested
                                                   explanation of SB 375 and background material should be in the introductory       reorganization of the Guidelines. Discussion of equity, civil
                                                   chapter; unique information from Section 4.40 and 4.41 for example should be      rights issues etc. will be further expanded in Section 4.41
                                                   removed and need not be repeated, 2. The sections include related material -      pending input from the RTAC Coordination workgroup.
                                                   Section 2.6 and Sections 4.10 - 4.18 on RTP Consultation/Coordination (some
              Table of       Linda
   1                                        HCD    of which also overlaps the SCS), 3. SCS descriptions are in several places i.e.
              Contents      Wheaton
                                                   pgs. 24-25, Section 1.8, Section 4.1, Section 4.41. Also, there should be some
                                                   guidance on RTP provisions addressing equity, civil rights issues,
                                                   environmental justice issues, including consideration of benefits and burdens
                                                   borne by different socio-economic population segments (beyond only item g. of
                                                   the modeling section on page 56)

                                                   Pg. 26: re: Submitting SCS/APS to ARB for review: the description of potential This section is being re-written.
                                                   revision of the SCS should clarify that, since ARB review of an SCS occurs
                                                   after adoption of the RTP, revision of the SCs would require amendment of the
                                                   RTP. The procedural or timing implications of this relative to meeting the RTP
                                                   adoption due date before expiration of its federal conformity findings should be
                             Linda                 noted (e.g., how much additional time would an MPO have to allow at a
  21         Section 1.8                    HCD
                            Wheaton                minimum to allow for amending its newly adopted RTP and yet meet its 4 yr.
                                                   adoption due date)? Is this prospectrealistic?
                                                   Pg. 27 re RTP Update Cycle: It would be useful to include the CFR citation for
                                                   what the trigger date is for the four-year update for non-attainment MPOs so as
                                                   not to have a conformity lapse.
                                                   Pgs. 32-33 re Land Use Strategies: The second par. Should read ―the MPOs to These strategies are being re-written and will be
            Section 4.43                           adopt RTPs or APS‘ which meet targets reducing GHG emissions . . . ― and the incorporated in Section 4.43.
           Land Use and                            itemized list that follows should be revised and clarified . . .i.e., #1 -- should not
           Transportation                          mix statutory requirements such as the housing projections for the RTP
            Strategies to    Linda                 planning horizon with voluntary options such as regional blueprint plans such
  122                                       HCD
              Address       Wheaton                that it is unclear which is required, and which is voluntary; #2 & #6 in particular
           Regional GHG                            are confusing. . . as regional blueprints were to configure more beneficial
            Emissions in                           development patterns that existing development patterns, they are not
              the RTP                              necessarily consistent with current general plans.




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                           Page 36                                                                                       11/3/2009
RTP Guidelines Update (10/26/2009 document) Comment Table
Please note all page numbers are those of the 10-26-09 released draft unless otherwise specified.
Page No.      Section        Name         Agency   Comment                                                                            Response
                                                   Pg. 33: re: Performance Measure #2: This is a potentially problematic              These strategies are being re-written and will be
                                                   recommendation, and needs revision for clarification:                              incorporated in Section 4.43.
            Section 4.43                           a) what is considered to constitute a ―project(s) identified in the RTP‖? -
           Land Use and                            presumably projects limited to transportation investments required to be
           Transportation                          identified or transit priority projects which are to qualify for the CEQA
            Strategies to    Linda                 streamlining benefits?
  122                                       HCD
              Address       Wheaton                b) as written it implies that projects listed in the RTP must be consistent with
           Regional GHG                            existing general plans, while that may not always be the case – particularly for
            Emissions in                           project assumptions that may be attributed to or related to the RTP planning
              the RTP                              horizon extending beyond the planning period covered by most general plans.


            Section 4.43                           Pgs. 33-34 re Land Use Assumptions: This section needs to be rewritten, as it This language has been removed.
           Land Use and                            confuses the relationship of land use assumptions and growth forecasts –
           Transportation                          regional population and economic forecasts should drive modeling assumptions
            Strategies to    Linda                 about land use assumptions, not the reverse. Types of uses (Residential,
  122                                       HCD
              Address       Wheaton                commercial, mixed use, etc) and capacity (e.g. population and employment
           Regional GHG                            density) and their distribution are examples of land use assumptions.
            Emissions in
              the RTP
            Section 2.6                            This section should identify the Regional Housing Needs Allocation Process as The RHNA process is referenced in Section 2.7 and further
            Coordination                           a key process the RTP updates must be coordinated with (proposed language explained in the Housing Needs subsection of Section 4.41
                             Linda
  30         with Other                     HCD    being developed).                                                             and in Appendix L.
                            Wheaton
              Planning
             Processes
            Section 2.7                            Perhaps something similar to the RHNA-RTP process chart developed by HCD Section 2.7 is currently under construction pending
                RTP                                would be appropriate here?                                               additional input from the Sequencing Workgroup.
                             Linda
  34       Development                      HCD
                            Wheaton
            Sequencing
              Process




       9496f356-58e1-4fec-a264-f201c6444e28.xls                                            Page 37                                                                                        11/3/2009

				
DOCUMENT INFO
Description: Federal Question Jurisdiction Flowchart document sample