By Gary Halbert, Section Director of the San Diego Section of the APA, and Corinne Lytle Bonine, President of the San Diego Chapter of the AEP
How will our region look and feel in 2050? How many more of us will there be? How will we travel around? What will be the key environmental issues of the day? What will our greenhouse gas emissions be?
Earlier this summer, the local chapters of the American Planning Association and the Association of Environmental Professionals hosted a membership appreciation event highlighting San Diego Association of Government’s (SANDAG) most recent draft regional plan – called “San Diego Forward: The Regional Plan.” The event also focused on summarizing the main points from the plan’s draft Environmental Impact Report (EIR), as well as quantifying greenhouse gas emission trends and examining alternative greenhouse gas (GHG) projections. Councilmember Todd Gloria from the City of San Diego facilitated the panel, with SANDAG’s Coleen Clementson and Rob Rundle, as well as the University of San Diego, Energy Policy Initiative Center’s (EPIC’s) Nilmini Silva-Send, as the primary presenters.
As planning and environmental professionals, it’s important for us to understand what is included in the draft Plan and the contents of the draft EIR. SANDAG will be accepting comments on both of these documents until July 15th and is expected to adopt the final plan this fall. APA and AEP members are encouraged to read the draft plan – or at least review the Executive Summary, and delve into the draft EIR. Why is this important? Because the Regional Plan (which combines the Regional Transportation Plan, the Regional Comprehensive Plan, and the Sustainable Communities Strategy into one big plan) provides the framework for updates to local general plans and policies, and serves as the basis for the construction and implementation of $200 billion in major transportation investments, all of which result in the need for environmental review. The Regional Plan also provides a basis for habitat conservation, smart growth planning, enhanced public health, economic development, emerging transportation technologies, and social equity in our region. As leaders in our profession, we should be familiar with our region’s demographic trends, the major planning concepts included in this latest Regional Plan (which by law, gets updated every four years), and the potential interrelationships with our day-to-day projects.
Pulling from SANDAG materials, here’s a quick guide to these efforts.
On April 24th, SANDAG released the draft of “San Diego Forward: The Regional Plan” for review and public comment. The Draft Plan proposes a strategy for a more sustainable future for the San Diego region, which expects to see a million new residents, half a million new jobs, and approximately 330,000 new housing units by 2050. San Diego Forward includes investments in transportation projects that will provide people more travel choices, protect natural resources, help create healthy communities, and stimulate a vibrant economy.
The Draft Plan calls for extensive expansion of transit services in the most urbanized areas of the region – where the region will see the highest increments of growth. These transit services include enhancements in service on the Trolley, SPRINTER, and COASTER lines, new “Rapid” bus services, streetcars, and expanded local bus services. The Plan also calls for improvements on all major freeways, an increased role for active transportation (biking and walking), projects that support smart growth, protections for important natural areas, and incorporating new technologies that help people use the transportation system more efficiently. SANDAG anticipates that, collectively, these investments will result in quicker travel and more travel choices. The plan invests more than 50 percent of the projected available funding toward transit expenditures – more than any of the region’s previous plans.
Economically, SANDAG estimates the Draft Plan will provide almost $2 in benefits for every $1 spent. And over the next 35 years, the region expects to see an average of over 50,000 additional jobs and $13 billion in increased gross regional product annually versus a “no build” scenario, as local businesses take advantage of increased transportation capacity to generate jobs and output.
On May 21st, SANDAG released the draft EIR for a 55-day public review and comment period to inform the SANDAG Board and the public about the significant environmental impacts of the Plan, and to identify mitigation measures and alternatives to avoid or reduce those significant impacts.
The Draft EIR is a program-level document that analyzes the impacts of the entire Regional Plan – both its planned investments in transportation network improvements and programs, as well as the region’s forecasted growth and land use pattern. The impact analysis uses the best available information to project future environmental conditions under Regional Plan implementation out to the year 2050, and then compares them to existing environmental conditions in the year 2012, the starting point for preparation of the Regional Plan and EIR.
In addition to the year 2050, the impact analysis looks at the years 2020 and 2035. Where the analysis shows that the Regional Plan would cause significant impacts, the Draft EIR identifies mitigation measures that, if adopted, would avoid or substantially lessen the significant impact. In addition, a separate Draft EIR chapter identifies and evaluates alternative transportation and land use assumptions that would avoid or substantially lessen the significant impacts of implementing the Regional Plan, while still meeting most of the Plan’s basic objectives.
The following is a summary of topics addressed in the EIR that have been the subject of the majority of the discussion by the public.
The Draft EIR identifies five significance criteria to cover various issues related to air quality. Of particular note are significance criteria AQ-2 and AQ-4, which address the health impacts of exposure to particulate emissions and toxic air contaminant emissions, respectively. Both AQ-2 and AQ-4 account for emissions generated by the Regional Plan’s transportation network improvements and programs, and also where people within the land use patterns in the Regional Plan would be exposed to substantial pollutant concentrations.
Health Impacts from Exposure to Particulate Emissions
In AQ-2, the Draft EIR identifies the areas along the San Diego region’s freeways and highways where, under Regional Plan implementation, localized concentrations of particulate matter (called PM10 and PM2.5) would exceed air quality standards. The Draft EIR estimates the number of residents, housing units, and schools in these areas, and describes the health impacts associated with short-term and long-term exposure to PM10 and PM2.5, including aggravated asthma, chronic bronchitis, and decreased lung function The Draft EIR concludes that impacts for AQ-2 would be significant. Mitigation measures are recommended to reduce the impact, but the impacts would, nevertheless, remain significant.
Cancer Risk and Noncancer Health Impacts from Exposure to Toxic Air Contaminants
In AQ-4, the Draft EIR identifies locations where the Regional Plan is expected to expose people to substantial concentrations of toxic air contaminants (TACs), the resulting cancer risks, and noncancer health impacts. To conduct this analysis, SANDAG asked the following three questions, which are used in EIRs prepared by agencies throughout California:
- Does the Regional Plan increase cancer risk by more than 10 chances in 1 million compared to the total risk in 2012?
- Does the Regional Plan expose sensitive receptors to total cancer risks above 100 in 1 million?
- Does the Regional Plan increase noncancer health impacts as measured by a total hazard index above 1.0?
The cancer risk of a given area is a measure of any one person’s likelihood of contracting cancer; it is not a measure of how many people will contract cancer. For example, for an area with an increase in cancer risk of 10 in 1 million, any one person’s likelihood of contracting cancer would increase by 10 chances in 1 million (i.e., increased likelihood of contracting cancer would increase by 0.001 percent); for an area with a total cancer risk of 100 in 1 million, any one person’s likelihood of contracting cancer is 100 in 1 million, or 0.01 percent. In estimating any one person’s cancer risk, the analysis assumes, in accordance with State of California guidelines, that person would stay in the same place for 30 years, 7 days a week, 24 hours a day, 350 days a year. The analysis follows the most recent state guidance and utilizes conservative assumptions to calculate exposure to TACs. Accordingly, it is designed to provide a conservative estimate of cancer risk and likely overestimates actual impacts that would occur.
Similar to AQ-2, the Draft EIR concludes that impacts to AQ-4 would be significant. The Draft EIR recommends mitigation measures to reduce the impact, but the impacts would, nevertheless, remain significant
Greenhouse Gas Emissions
The Draft EIR identifies four significance criteria to address GHG emissions impacts, including GHG-2 and GHG-3, in which the analysis concludes the Regional Plan would not conflict with Assembly Bill 32 (Pavley, 2002) or Senate Bill 375 (Steinberg, 2008). Of particular note is significance criterion GHG-4, which examines whether the Regional Plan is inconsistent with the goals of two Executive Orders: one which calls for reduction of California’s GHG emissions to 40 percent below 1990 levels by 2030, and the other for 80 percent reduction below 1990 levels by 2050 (EO-B-30-15 and EO S-3-05). While noting that there is no requirement that the San Diego region’s emissions be reduced by the same percentages (“equal share”) called for in the Executive Orders’ statewide goals for all emission sectors, the analysis identifies 2035 and 2050 emissions reduction reference points for the region using the Executive Orders’ statewide reduction goals. It concludes that while total regional emissions in 2035 and 2050 would be about 28 percent and 27 percent lower, respectively, than the 2012 emissions level, total GHG emissions would be higher than the region’s “equal share” of statewide emissions reduction goals expressed in the Executive Orders. Therefore, the region’s total GHG emissions levels are considered significant impacts in 2035 and 2050 under GHG-4.
The Draft EIR identifies four significance criteria to address transportation issues. Of particular note is significance criterion T-1, which addresses changes in per capita and total Vehicle Miles Traveled (VMT). While noting that average daily VMT per capita decreases under the Regional Plan, from about 25.2 miles per day in 2012 to 23.4 miles per day in 2050, the analysis reports that total VMT would increase under the Regional Plan from about 79 million miles per year in 2012 to just over 95 million miles per year in 2050, an increase of about 20 percent, which is lower than the forecasted population increase of 29 percent by 2050. While population growth is the main cause of the total VMT increase and the amount of driving per person would decrease under the Plan, the analysis nevertheless concludes that the total VMT increases are considered a significant impact.
Mitigation Measures to Reduce Significant Impacts
For each issue area analyzed, a conclusion is made to indicate if the Regional Plan would have a significant impact on the environment. For those issue areas where a significant impact has been identified, mitigation measures or project alternatives are identified to reduce the significant impact. For the issue areas described above (Air Quality, GHG Emissions, and Transportation), many of the mitigation measures outlined in the Draft EIR would relate to all three impact areas due to their interconnected nature. Described in detail in the Draft EIR, some of the mitigation measures include:
- Modify grant criteria to award projects that reduce GHG emissions
- Adopt a Mobility Hub Strategy to reduce GHG emissions
- Fund electric vehicle charging infrastructure
- Adopt Plan for Alternative Transportation Fuels
- Assist local agencies with the preparation of climate action plans
In addition to the measures outlined above, the Draft EIR identifies measures that SANDAG will implement to reduce impacts associated with construction projects. Further, the Draft EIR identifies mitigation measures that local agencies can and should adopt during planning, design, and implementation of the projects they approve. SANDAG has identified these measures, because the Regional Plan addresses impacts of regional growth and transportation, which includes implementation of projects over which SANDAG will not have authority.
The Draft EIR examines alternative transportation and land use assumptions that would avoid or substantially lessen the significant impacts of implementing the Regional Plan, while still meeting the Regional Plan’s basic objectives. In addition to the CEQA-required ‘No Project’ Alternative, the Draft EIR considers seven alternatives. The characteristics of the alternatives are in large part based on major transportation investments and policy options that members of the public and stakeholders suggested would lead to major reductions in VMT and related reductions in GHG emissions and air quality impacts, including but not limited to:
- Advancing public transit (capital and operations) and active transportation investments to 2025 (the first 10 years of the Regional Plan)
- Including investments from the unconstrained transit network (e.g., investments for which available funding was not identified in the Regional Plan)
- Delaying and eliminating general purpose highway and Managed Lane investments
- Converting existing general purpose lanes to Managed Lanes
- Providing more compact land use patterns
- Substantially lowering transit fares
- Substantially increasing the price of parking
- Substantially increasing the cost of driving
Alternative 5D is considered the environmentally superior alternative, and would achieve the greatest reductions in total VMT, GHG emissions, and air pollutant emissions, although total VMT would still increase by about 7.2 million miles per year, or 9 percent, by 2050, compared to an increase of about 15.7 million miles per year, or 20 percent, under the Regional Plan. To be implemented, however, Alternative 5D would require a major state road pricing policy change, and major changes in land use policies, parking policies, and transit funding. The results indicate that total reductions in VMT below the 2012 level are not feasible in light of the forecasted increase of nearly one million more people in the region by 2050.
The public review period for the Draft EIR ends on July 15. At that time, SANDAG will prepare written responses to all comments received regarding the adequacy of the Draft EIR. SANDAG will make any appropriate modifications to the Draft EIR, and along with the public comments and responses, will present the information to the Board of Directors for its consideration prior to making a decision on the adoption of The Regional Plan.
A big thanks to Councilmember Todd Gloria for facilitating an excellent discussion on the draft Regional Plan and its draft EIR. And kudos to Coleen Clementson, Rob Rundle, and Nilmini Silva-Send for explaining the details on the draft Plan, draft EIR, and greenhouse gas inventory in an easy-to-understand way. The SANDAG documents can be found on www.sdforward.com, including live streaming from workshops held earlier this spring. Don’t forget to get involved in this effort and send in your comments – before the July 15th deadline!
Presentations that detail the plan:
 Sensitive receptors include but are not limited to hospitals, schools, daycare facilities, elderly housing, and convalescent facilities. These are areas where the occupants are thought to be more susceptible to the adverse effects of exposure to toxic chemicals, pesticides, and other pollutants.