TRANSDEF: County Analysis Fails to Address Greenway Harms
The Transportation Solutions Defense and Education Fund, known as TRANSDEF, is a non-profit environmental organization created by transit activists to advocate for better solutions to transportation, land use and air quality problems in the San Francisco Bay Area. TRANSDEF promotes cost-effective transit, Smart Growth, and market-based pricing as fiscally and environmentally preferable responses to traffic congestion. These strategies represent a major departure from the prevailing policy climate of suburban sprawl, ever-widening highways and overwhelming dependence on the private automobile. TRANSDEF is especially focused on transportation solutions that reduce the emissions of greenhouse gases that cause climate change.
TRANSDEF read the County Staff report analyzing the Greenway ballot measure and found it to be woefully inadequate. Here is their letter to the Board of Supervisors pointing out the flaws and omissions in the staff report, and the serious unrecognized harms that the Greenway ballot initiative would cause for Santa Cruz County.
Transportation Solutions Defense and Education Fund
P.O. Box 151439 San Rafael, CA 94915 415-331-1982
Manu Koenig, Chair
Santa Cruz County Board of Supervisors
701 Ocean Street
Santa Cruz, CA 95060
Re: Election Code 9111 Report Regarding
the Santa Cruz County Greenway Initiative
Dear Chair Koenig,
TRANSDEF, the Transportation Solutions Defense and Education Fund, is an environmental non-profit focused on reducing the growth in Vehicle Miles Travelled (VMT), as the strategy needed to counter the dual challenges of rising GHG emissions from transportation and congested highways. For the past 26 years, we have advocated for public transit and the land use patterns that support transit.
We have reviewed the Election Code 9111 Report Regarding the Santa Cruz County Greenway Initiative (the Report) and find it inadequate in evaluating the impacts of the Greenway Initiative (the Initiative) on the policies of the Santa Cruz County General Plan (the Plan) and the Sustainable Santa Cruz County Plan. In short, we find the Report failed to identify how the Initiative would interfere with the County's efforts to address its highway congestion and housing shortage. In particular, it is shocking that the Report failed to evaluate a transportation initiative's consistency with the Plan's Circulation Element. We request you ask Staff to revise the report to specifically address the following findings:
Consistency with the General Plan
1. The Report fails to acknowledge that the Initiative is fundamentally inconsistent with the General Plan Circulation Element. "The Transportation System Management (TSM) section is the cornerstone of the Circulation Element and Transportation Planning in general." (p. 3-3 of the Plan.)
The Transportation System Management section states:
The Initiative would block the only non-highway high-capacity transit mode available to the County "to reduce automobile trips and congestion." It would also block commuter rail's ability to reduce the impact of weekend beach traffic.
2. The Transportation System Goals include:
The Initiative would reduce mode choice and force more Santa Cruz residents to travel in automobiles. TRANSDEF is unaware of any County documents that demonstrate that the proposed Greenway would attract user volumes equivalent to projected commuter rail ridership, as an alternative to driving.
3. The Report should have indicated that the Initiative will interfere with Plan Objective 3.1: "To limit the increase in Vehicle Miles Traveled (VMT) to achieve as a minimum, compliance with the current Air Quality Management Plan." The Initiative would eliminate the County's only available non-highway high-capacity transit mode option.
4. The Report's evaluation of "Limitations on County Actions Related to Housing" was superficial and conclusory. It focused on land use law, rather than on the fundamental connection between transportation and land use. Higher land use densities are practical if served by rail, because less physical space is taken up by parking and the economic burden of providing parking is lessened.
Envision Utah was a community consensus-building project in a fast-growing area of a conservative state, which had severe geographic constraints preventing further sprawl. The community came to agreement on growing up, not out. Higher density housing would be built, served by a rail network. "Since 2010, over 40 percent of new multifamily housing units have been built within walking distance of a rail station. That means reduced household costs, air emissions, traffic, infrastructure costs, and land consumption." https://envisionutah.org/about
The Report fails to discuss the impact of the Initiative on the County's potential for transit-oriented development, a fundamental strategy for affordable housing, stating only that:
5. The discussion in Point #4 strongly suggests that this Report conclusion is incorrect:
6. The Report should have indicated that the Initiative would interfere with Plan Policy 3.1.1: "Land Use Patterns (Jobs/Housing Balance):
The Initiative would prevent the implementation of this Policy by blocking commuter rail.
7. The Report's conclusion on business retention appears to be deliberately misleading:
Common sense (rather than a detailed analysis) is all that is needed to know that a county with a constantly congested main artery is not attractive to business. It should be obvious that a county investing in commuter rail will be seen by business as more attractive than one investing in a trail.
8. The Report's conclusion regarding the availability of freight service on business retention is similarly misleading:
The temporary unavailability of freight service is not a legitimate reason to not consider the value of rail freight to business. Again, common sense indicates that some businesses would find the availability of freight service attractive.
9. The Report discusses trail and trail with rail as mere amenities, thereby entirely failing to acknowledge the significance of commuter rail to the mobility of the County's residents, who otherwise are stuck in gridlock.
As discussed above, commuter rail would be much more supportive of development and affordable housing. That is not a speculation.
10. The Report's finding on congestion is accurate, but not consistent with the rest of the Report:
11. The Report is in error when it states "Although passenger rail transit is not funded or planned for the SCBRL at this time, it is possible that the construction of an interim trail on the railroad track alignment would postpone implementation of passenger rail transit on the SCBRL." (p. 7 of the Report.) Passenger rail is planned, and it is certain that an interim trail would postpone implementation of passenger rail.
Consistency with the Sustainable Santa Cruz County Plan
TRANSDEF was unable to locate a non-password-protected copy of this Plan. This odd practice of securing a governmentally adopted Plan that should have been publicly available prevented us from analyzing the Initiative's consistency with it.
Consistency with the Draft Update to the General Plan
The Report made no attempt to evaluate the consistency of the Initiative with the draft Access + Mobility Element (the Element) of the Draft General Plan Update. It is clear that high-capacity transit is needed to meet the dual challenges of highway congestion and excessive GHG emissions identified in the Element. It should be equally clear that the Initiative's emphasis on personal transport is quantitatively inadequate to face these challenges. VMT reduction and the transportation-land use connection are stressed in this Element even more strongly than in the current Plan:
Points #1 - #4 above apply even more to the Element than to the current Plan. While the Initiative purports to offer recreational and commuting opportunities, there is no basis upon which to conclude that the proposed trail would meet the County's needs, as identified in the Element.
Misleading Language in the Initiative Itself
Finally, the Report fails to call out the Initiative's misleading use of the word "interim." In the world of rail trails, it is extremely rare for a railbanked line to ever be put back into rail use. Once a line is railbanked, the national experience is that, for all practical purposes, it is forever lost to rail. While the Report should have clarified that fact for voters, all it says is "…there is no time frame given or definition of “interim” within the Initiative on when that future system might occur or how long the “interim” use would remain in place." (p. 5 of the Report.)
TRANSDEF requests the Board to have staff revise the Report, so as to present the voters with an accurate evaluation of the impacts of the Initiative, including its inconsistency with existing plans. Thank you for considering these comments.