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.
Guest Post by Paul Schoellhamer
Railbanking is a real thing, but some of the claims being made about it here in Santa Cruz County have no basis in reality.
Railbanking was a legal sleight-of-hand (and I mean that in a good way) that was created by Congress in 1983 to solve a very specific problem: flaws in some railroad land deeds were making it difficult for some of those properties to be converted by local governments into recreational trails.
In that purpose, Congress’s 1983 railbanking provision has mostly been a success: a lot of abandoned rail rights-of-way have been turned into recreational trails. Across the U.S. railbanking has, in 37 years and over 300 specific projects, facilitated the conversion of roughly 6000 miles of rail right-of-way. And those have been all kinds of conversions: trails adjacent to tracks and trails in place of tracks, trails that were paved or not paved but improved or that offered no improvements at all. (In a few cases the rail-right-of-way was just left as a place to cross-country ski in winter – snowfall being the only improvement.) We have a lot of real world experience with railbanking.
Greenway now argues that railbanking can do something very specific here in Santa Cruz County: we can with railbanking remove the rail line entirely and pave it over with asphalt or concrete and then at some point in the future we can reverse course, tear up all that pavement, rebuild the rail line, and offer some type of electric light rail transit service. The question before us is: Is that a realistic possibility we would be leaving for our kids and grandkids? Or are we being misled into a dead-end?
We could have a theoretical debate about what could or could not happen in a distant future, but we don’t need to. We have 37 years and roughly 6000 miles of real world experience with railbanking. That real world experience tells us volumes about what railbanking realistically can and cannot do.
And here is what all that real world experience is telling us: as much as railbanking has accomplished over all those years and all those miles, it has NEVER done what Greenway says it can do here in Santa Cruz County. To be specific, Greenway claims that railbanking would make it a realistic possibility that we could remove the rail line entirely and pave it over with asphalt or concrete, and then many years later decide to rip it all up and rebuild the rail line -- and that has NEVER happened in the entire history of railbanking.
The point is simply this: Greenway should be honest with the public. Greenway can advocate tearing up the tracks if they want to, but they should stop holding out to the public the unrealistic claim that under their proposal throwing around the word “railbanking” has any realistic chance of bringing back rail service in the future. Tear it up and pave it over and it very likely is gone forever -- that’s what honesty looks like.
That being the case, the question becomes: Should we sitting here in 2022 be making a decision for 10 or 20 or 30 years from now, when we have (let’s face it) very limited ability to predict what that world will look like then? Or should we in fairness leave that decision to be made by those living in that world, including our kids and grandkids?
Paul Schoellhamer worked for many years as legislative staff in the US House of Representatives, focusing on transportation issues. He now lives in South County.
Modern transportation experts agree on a few things:
Adding passenger rail transit to our bus system will increase county-wide use of public transit from 13,700 trips to 34,200 trips every single day according to the RTC’s recent Transit Corridor Alternatives Analysis (TCAA). That is a 150% increase in public transit ridership county wide. The data is in, and as a result, the county Regional Transportation Commission has selected electric passenger rail as the Locally Preferred Alternative for adding public transit to the rail corridor.
To support this 150% increase in public transit ridership, local funds will be needed to match available state and federal funding. The RTC’s draft TCAA Business Plan states that besides a traditional sales tax, other sources of local funds include “funds from vehicle levy or registration fees, local fuel tax, property tax, income tax, transient occupancy tax, student fees, vehicle miles traveled charges, and parking fees.” What the Business Plan doesn’t say is how to move forward.
Proactive communities are leading the way in finding the equitable “how” to fund expansions of public transit. One of the most successful strategies is the “collaborative” model utilized by the City of Portland in its Pricing Options for Equitable Mobility (POEM) project, grounded in a commitment to Transportation Justice.
One of the most amazing things about Portland's community-wide effort is that its final report outlines seven near-term and three long-term funding strategies and of these strategies, none involves a sales tax. It should come as no surprise; the final report was unanimously adopted by the Portland City Council with direction to staff to implement the recommendations.
The benefits of improving our public transportation system are so numerous, it is short-sighted and unjust to delay finding the funding to transform our transportation system into the more equitable, sustainable and economically just system we want and need. Let’s take advantage of the tremendously creative energy in our community and go to work on a “POEM” project of our own.
Friends of the Rail and Trail is excited today to be announcing the launch of Coast Connect, a new campaign to transform the County's transportation system for the future. The Coast Connect vision is committed to the principles of People, Planet, and Prosperity.
The vision starts with a modern rail service connecting the City of Watsonville to the City of Santa Cruz and points between and beyond. At each stop, synchronized bus connections provide access to various county destinations. Alongside the tracks, the wide, paved, multi-use Coastal Rail Trail runs the full 32 mile length of the rail corridor from Watsonville to Davenport. A network of trails, paths, and complete streets that serve all members of the community is connected to the corridor. Wheelchair users, skateboarders, cyclists, pedestrians and rideshares can all access the system safely and easily.
The combination of active transportation routes, rail service, and synchronized bus connections will provide our community with a modern, robust transportation system that benefits people, the planet and our shared prosperity.
A transformed transportation system will make Santa Cruz County more equitable. Convenient, reliable and accessible transportation options will allow all workers, families, students and visitors to travel freely across the county and to access opportunities for work, education, and recreation without needing a car.
A transformed transportation system will help fight climate change by giving us attractive, convenient alternatives to car travel that will help our community reduce greenhouse gas emissions, cut air pollution, and reduce our dependence on fossil fuels.
A transformed transportation system will give both employees and customers improved access to local businesses, make Santa Cruz County accessible to rail and bicycle tourists through the rail connection at Watsonville/Pajaro junction and the coastal trail, and enable residents to forego car expenses.
Coast Connect is about how quality transportation can create a better, more connected future for the people of Santa Cruz County. We believe implementing the Coast Connect vision can transform our county for the benefit of generations to come.
We’re excited to share this launch with you today. With the Coast Connect vision, we hope to inspire everyone to see how we can transform transportation together and build a better future for our County. To join us in our advocacy efforts, please visit us at CoastConnect.org and add your name today.