How sustainable is SANDAG's SCS?

I’ve been spending the last month wrapping up a report on the critical steps that metropolitan planning organizations (MPOs) can take in order to implement Senate Bill 375. The report examines how MPOs can leverage the opportunities presented by SB 375 to effectively create more livable communities, reduce sprawl, provide better alternatives to driving, and lower greenhouse gas (GHG) emissions, and we’ll be posting it on our website soon. Meanwhile, MPOs continue to work on their next regional transportation plans (RTPs), which are required to include a land use plan, the sustainable communities strategy (SCS), that works alongside the transportation improvements in the RTP to reduce GHG emissions by concentrating new housing in areas where people drive less. SANDAG, the MPO for the San Diego metro area, just released their draft RTP, which is the first plan subject to the requirements of SB 375. There’s a lot in SANDAG’s RTP to applaud, including its focus on transit and the fact that it meets ARB’s GHG reduction targets. However, in the process of creating this report we found that complying with SB 375 is a different thing than actually using the opportunities that the bill presents to produce substantive changes in the way our communities look and the way that we get around, and SANDAG’s RTP illustrates this gap. I took a look at the RTP to see how it performs with respect to two of the key recommendations in our report.

The draft RTP is open for public comment through mid-June if you wish to weigh in.

Recommendation #1: MPOs should include clear goals for future land use changes in their SCS.

According to Appendix D, page 33 of SANDAG’s RTP: “The 2050 Regional Growth Forecast is based primarily on local land use plans, many of which have been updated in the past four years, and also includes draft plan updates and more robust redevelopment assumptions within existing plans.” In effect, this is how MPOs have created local land use scenarios for the past several decades, and it’s the approach that gave us the sprawling metro areas that we have today. Local plans don’t adequately consider regional impacts such as congestion or air quality, and are often based more on economic aspirations—more big-box retail that brings big tax revenues and costs less to serve, less housing—than on regional realities. The California Transportation Commission allows that MPOs can deviate from local planning assumptions local plans in order to account for regional economic trends, prior regional “blueprint” land use plans, or for the gap in the time horizon between local plans, which cover 15 to 20 years, and the RTP/SCS, which in SANDAG’s case goes out to 2050.

SANDAG’s draft SCS does not seem to take advantage of many of these opportunities. Though the plan calls for areas that are well-served by current and planned transit, such as San Diego and Chula Vista, take on fair shares of the region’s housing growth between now and 2050—44 and 11 percent respectively—unincorporated areas of San Diego county, which are generally far from transit and low-density, still take on 10 percent of the region’s housing, even during the period between 2035 and 2050, when SANDAG is free to make more assumptions because this period is outside the horizon of the county’s updated general plan. And there are plenty of reasons, from shifting demographics to rising gas prices, to assume that this housing will not be as desirable in the future. Yet SANDAG’s SCS only houses 53 percent of the region’s growth in Smart Growth Opportunity Areas identified in its blueprint plan, while the remaining half goes to the suburbs, much of it in unincorporated areas.

Source: SANDAG, 2050 Draft RTP, page 3-3

According to SANDAG’s projections, the GHG reductions in its RTP start out substantial and then taper off. SANDAG’ explains that this is because “greenhouse gas emission reductions from compact land use, [sic] and alternative transportation modes will be outpaced by regional growth." This doesn’t have to be the case. If the SCS and RTP pursue a land-use strategy that houses most new residents in areas that have progressively better transit service and higher density and mix of uses, GHG reductions should compound over time. This is one of the assumptions upon which ARB’s GHG reduction targets, which get more stringent over time, were created, and an MPO can meet this assumption by creating an SCS that proactively addresses regional land use patterns. SANDAG doesn’t estimate the relative effectiveness of the GHG reduction measures in its RTP, but based on the numbers my guess is that the large initial reductions are due to congestion relief from the new freeway lanes, some of which are managed, that SANDAG is building over the short term, and then they taper off as new cars fill that capacity. If that’s the case, this is not the type of planning that’s going to create more sustainable communities over the long term—it’s greenwashing the status quo.

Recommendation #2: MPOs should review “committed” projects and fast-track those that reduce emissions.

The RTP process allows for a fair amount of flexibility: although an RTP includes a fixed list of projects, it often doesn’t specify the order in which projects will be completed. Same goes for transportation sales taxes such as the San Diego area’s TransNet, which is administered by SANDAG. This means that MPOs have an opportunity to reduce GHG emissions by prioritizing projects that support smart growth, while delaying others until they are amended or omitted in a subsequent version of the RTP or until a sales tax measure allows for amendments. However, many MPOs limit their own flexibility by considering a large number of projects, as well as many funding sources to be “committed,” and not subject to discretionary decisions during the RTP process. 

SANDAG points out that this RTP is much more focused on transit than the previous one, and indeed transit accounts for about 45 percent of the overall plan expenditures, compared to 32 percent for roads and highways. However, this does not present a clear picture of SANDAG’s priorities, because it accounts for dollars spent by local governments and Caltrans, and because many funding sources, particularly those that go toward transit operations, can only be used for one purpose, so they’re not really discretionary. SANDAG’s analysis of different investment scenarios for its RTP (see page 13 of Appendix D) included roughly $43 billion worth of transit and highway projects—the type of projects that SANDAG funds—and $32 million of those are included in TransNet or otherwise committed. Of those committed projects, 63 percent go to highways and 37 percent go to transit. Granted, SANDAG does not have the ability to remove sales tax projects from its expenditure plan, and SB 375 specifically exempts sales tax projects from consideration during the SCS process. However, $10 billion worth of SANDAG’s committed projects are not tax-funded, and even those that are draw in money from other discretionary sources that SANDAG allocates. There is no reason that the agency can’t elect to reconsider committed projects in light of SB 375, particularly those in its Early Action Program, which are the first in line for funding. MTC, the MPO for the Bay Area, just passed a policy narrowing its definition of committed projects and funds, which potentially frees up more money to apply toward meeting its GHG reduction targets. This type of policy can be an important step in taking early and aggressive action to reduce GHGs.