Dear Commissioners and Board,

Thank youfor the opportunity to comment on the Circulation Element. We provide comments below on specificlanguage in the chapter, but are concerned about the overall approach.

Background

We haveprovided comments on other chapters of the General Plan Update, mostly to pointout that balancing our transportation system will do much to achieve the goalsset in many of these chapters. In manycases, balancing the transportation system will do much more than anythingactually in those chapters, such as in the Energy, and Noise and Safetyelements.

With regardto energy, transportation accounts for 45% of greenhouse gas emissions inArcata, and likely a similar proportion in the rest of the county. Our electricity comes from a variety ofsources, biomass, natural gas and solar, but our transportation system isalmost entirely dependent on oil-based fuels. This will become a problem as oil prices continue to rapidly increase.

Motorvehicle collisions are the number one killer of Californians age 1-35. For a city of its size, Eureka nearly leads the state in per capitamotor-vehicle related injuries and deaths (http://eurekareporter.com/node/90194). This carnage can be reduced by reducingdriving and shifting travel to safer modes, such as transit, which is 10 timessafer per passenger mile.

We estimatethat roughly 13% of HumboldtCounty’s GDP is lost toimported fuel and vehicles. Acombination of reducing transportation expenditures through smart land use andnon-motorized infrastructure, and shifting to more transit use couldsubstantially benefit the economy as such policies have in Portland, Oregon,where per capita vehicle miles traveled have successfully been reduced and theeconomy has benefited from reduced transportation expenditures (Dylan Rivera,2007, Less driving is more cash for Portland. The Oregonian (http://www.oregonlive.com/news/oregonian/index.ssf?/base/news/1187576751202450.xml&coll=7).

Because itworks better with compact urban land use, balanced transportation dovetailswell with the goals of preserving agricultural and timber working lands whichprovide for the long-term health of the economy. The resultant reduced urban footprint canhelp reduce flooding and polluted runoff as well.

Flawed Perspective

Ifachieving balanced transportation will help us achieve many of our goals, doesthis Circulation Element strive to balance our transportation system? The first goal C-G1 has all the right buzzwords: “…well coordinated, balanced, circulation system that is safe, efficientand provides good access…” but the element is suffused throughout with thepresumption that this can be achieved while focusing primarily perpetuatingautomobile dependence throughout the county.

Mostemblematic is the statement: “With existing and likely available futurefunding, it does not appear financially feasible to provide transit servicethat can compete with the automobile.” This statement belies the inherent auto-centric viewpoint from whichthis Circulation Element was written.

Let’s startwith funding. Current limitations ontransit funding have been caused by local decisions and priorities, notsomething outside our control. WhileMendocino, Trinity and Del Norte Counties spend all of their TransportationDevelopment Act funds on transit operations with the exception of a smallpercentage going to bicycle and pedestrian improvements. HumboldtCounty does NOT spend allits TDA money on transit operations, and in fact annually puts about $7-800,000into county road maintenance which is struggling with a $100 millionmaintenance backlog. Because we don’tspend all of our TDA money on transit, in 2002 we were not eligible foradditional transit assistance from Wesley Chesbro’s SB 739 Rural Transit SystemGrant Program. We need a set of policiesto unify our transit system and empower it to use all TDA funds available tooperate transit.

Many of theimprovements needed to make transit more competitive have more to do withcapital improvements than with operating costs. These are expenditures that we have a great deal of local control over,for example STIP funding which is dispensed by HCAOG can be used to develop BusRapid Transit strategies along 101 in Eureka and along Central Avenue inMcKinleyville, as well as to construct park-and-ride lots and other amenitieswhere appropriate..

The secondhalf of the statement relates to whether transit service can “compete with theautomobile.” The assumption is made thatanyone riding transit has “no alternative means of transportation available.” This is somewhat insulting to those who areeconomically struggling, because it implies we don’t need to make transit moreconvenient for them. It was nice enoughof us to even offer the charity. Thesuggestion that transit cannot compete is also incorrect. According the 2006 Transit Development Planfor Redwood Transit Service, only about 50% of riders are “ride dependent” andover 20% chose transit for its convenience or to avoid parking hassles.

In anycase, the suggestion of people having “no other transportation available” isalso a gross oversimplification. For some,affording a car (or the ability to drive one) might be out of thequestion. For others, there is aweighting of the costs and benefits of car ownership. Many people use a combination oftransportation strategies including a combination of walking, biking andtransit. Every household makes decisionsabout how many vehicles it needs, and having transportation options affectsthose decisions. Since our goal is tohave a balanced transportation system, we ought to strive to provide thoseoptions.

Additionally,the suggestion that transit can’t compete is incorrect on several levels. Transit captures a small share of trips. If it couldn’t compete, it wouldn’t captureany. That share is growing quickly aswell. Arcata & Mad River TransitSystem has seen a 20% increase in ridership over the last three fiscal yearsmeasured, and about a 10% increase in the last year to date. Redwood Transit System ridership has grown 24%in three years leading up to this year (based on annual ridership). Growth is now accelerating, with about 30%growth on RTS the last year alone (Oct. ‘06 compared with Oct. ‘07). Willow Creek Bus ridership has grown 244% infour years. Redwood Coast Transit Route20, providing service from Del Norte County through northern Humboldt Countyto Arcata, is on track to double its ridership since its inception in2005. Meanwhile, vehicle miles traveled inHumboldt County only increased 3% between 2000and 2006 (the last year for which there is data). While still a small proportion of totaltravel demand, transit use is competing effectively for a greater market share.

How to Proceed?

We providesome general and specific comments below, but we believe the draft needs to essentiallybe rewritten. Because of the economicand environmental consequences of automobile dependence perpetuated by thecurrent draft plan, we recommend hiring a consulting firm with extensiveexperience in multimodal transportation demand management to assist with this,and the writing of urban land use goals, policies and implementationmeasures. While hiring a good consultantwill add to the cost of the plan, the consequential costs of not getting thisplan right are many times greater.

Respectfully submitted,

Chris Rall

Green Wheels – Executive Director

Complete Picture

Meeting thestated goal of creating a “well coordinated, balanced, circulation system thatis safe, efficient and provides good access” will require a coordinatedapproach in the Land Use, Circulation and Community Design Elements. At this time, the Land Use Element lacksurban land use goals and policies, and therefore does little to move us towarda goal that it must play a key role in achieving. The Community Design Element has not beenavailable for review yet at the time of this writing. The Circulation Element is currentlyunbalanced, in that it assumes continued emphasis on automobile dependencewhile accommodating minor improvements for bicyclists and pedestrians, andvirtually no improvements for transit.

Asuccessful balanced transportation strategy will require balancing theperformance standards for all modes, creating safe bicycle connections betweenall communities, encouraging compact mixed use development, pedestrian-friendlystreetscapes and market-based parking policies. So far, it is not clear to us that any of these components of thestrategy are in place.

Roadway Standards

The set ofstandards classifying roads in a hierarchy as major and minor arterials, majorand minor collectors and local roads is overly simplistic, and if adhered totoo strictly, can result in a hierarchical road system with poor connectivity.

We suggestusing the system adopted in Seattle(http://www.seattle.gov/transportation/docs/TSPprintfinal102505_ch3.pdf). This system defines roads based on theirimportance for each mode. Thenimprovements to each road can bring the quality of service on each road intoline with what is needed for each mode. A lay-person’s explanation of this system is available at:

http://www.nrsrcaa.org/humpal/jeremynelsonpresentation.pdfp.22-40

A more detailed explanation for how it works is availableat:

http://www.ci.glendale.ca.us/planning/pdf_files%5CMobilityPlan/GLENDALE_PerfMeasures_StreetsRPT.pdf

Level of Service

The balancedapproach above requires level-of-service (LOS) or quality of service (QOS)standards for all modes rather than just for private automobiles. LOS standards have been developed for transit(see previous link), and road segments for bicycling (http://ntl.bts.gov/DOCS/98095/index.html)and pedestrians (http://www.dot.state.fl.us/Planning/systems/sm/los/pdfs/pedlos.pdf,note: this standard is not as well developed), but have not been developed forintersections for bicyclists and pedestrians.

Transit LOSstandards developed by Nelson / Nygaard go beyond measuring cost efficiencyfrom the operator’s perspective, although this is still important. Transit LOS standards measure quality ofservice for the rider: frequency, hours of service, reliability, loading, andtravel speed. A primary transit route shouldmeet the following standards:

• Frequency 15 minutes or better
• Hours of Service 6am to 10pm
• Reliability <10% probability of delay > 0.5 of headway
• Loading maximum of 86-100% capacity
• Travel Speed 0.3 of speed limit or better

There are less stringent standards for secondary transitroutes. None of our transit routes comeclose to the primary transit standard, but we have an opportunity with acombination of land use, circulation and community design policies, to identifya primary route in the micropolitan core of our county and work towards meetingthe standard over the next 20 years. Such a route would likely include McKinleyville’s Central Avenue, Spruce Point and Field’sLanding, as well as the three major cities and College of the Redwoods. This strategy would give the people of Humboldt County the option to live in an areawell-served by transit. Imagine a seriesof healthy, pedestrian-friendly communities at the core of our string of urbanareas, places designed primarily for people rather than primarily for thepassage of automobiles. A primarytransit route would help make this possible.

The BicycleCompatibility Index created by the federal DOT has developed, and LOS standardsfor pedestrians from Florida’sDOT are based on bicyclist and pedestrian perception of safety. They use traffic volumes, lane widths andbuffers to ascertain how safe a roadway will appear to a bicyclist orpedestrian. These standards should beused to balance LOS for all modes in all road improvement projects.

We suggestusing LOS standards that are available, and adopting more complete standardswhen they do become available either from the U.S. DOT or from Caltrans.

Bicycle Infrastructure

Thissection needs to be more inclusive of the long term goal of providing a networkof Class I multi-use paths between all major population and employment centersin the Humboldt Bay Area: McKinleyville, BlueLake, Arcata, Manila,Eureka, College of the Redwoods, Fortuna, RioDell and Scotia. This is ambitious, but we are supposed to beplanning for twenty years out, and depending on what happens with the railroad,this is entirely within the realm of possibilities.

Transit

There are twobasic goals to strive for with transit. One is to try to provide service to the transportation disadvantaged,which is essentially addressed with CIM-11. Service to the North and East has largely been accomplished, but serviceto southern Humboldt is needed.

The secondgoal is to capitalize on places where transit has shown itself to be effective,and support those hi-performing transit services so they can meet transitdemand and encourage transit-oriented development. Opportunities for improving the bus ways onRTS between McKinleyville and Fortuna could provide an alternative solution(and in the long term a more effective one than what has been proposed) fortraffic congestion in Eurekaand on Central Avenuein McKinleyville, both of which continue to deteriorate.

The twentyyear timeline of this plan makes it appropriate to plan for the option ofdeveloping RTS into a Bus Rapid Transit system with dedicated lanes and streetsas well as queue jumps strategically located to provide speedy passage forbuses through the most congested parts of Eureka and McKinleyville, withimprovements in other sections to improve passenger amenities, speed travel andattract passengers. Identifying aprimary transit route and working towards meeting minimum performance standardsoutlined above could guide this process.

Road Capacity and Land Use

Studieshave shown that building road capacity may relieve congestion in a location butit paradoxically generates additional traffic which can impact other locations(http://www.vtpi.org/tdm/tdm96.htm). A combination of transportation demand management(TDM) strategies can more effectively at reduce congestion over the long termthan increased roadway capacity.

Ifsubstantial development is allowed or encouraged in areas where residents willhave little option other than drive the narrow roads serving that area to getdowntown for their employment and services, there will be substantial increasesin congestion as a result. Even if thecongestion is somehow mitigated in the outlying areas, congestion will increasein the areas where services and employment are concentrated, especially Eureka.

Ifdevelopment occurs in such a way as to provide citizens a choice of modes, the systemwill have more resilience when it comes to mitigating traffic congestion orcontending with changing energy prices even if the vast majority of peoplecontinue to drive in the near term. Policies focused on developing walkable, transit-oriented communitiesseem to be missing entirely from the Land-use Element. These policies will need to address parkingpolicy, encouraging mixed use development in commercial zones and nodes ofhigher density focused around transit hubs. The few toothless land-use policies in the Circulation Element will notsuffice.

Parking Policy

Therequirement of providing over-abundant parking in all new development drives upthe price of housing, goods and services for everyone. Free on-street parking is a substantialgovernment subsidy of $240 to $3600 annually per space depending on land valuesand whether they are included in the calculation (2003 Regional Parking NeedsStudy, http://hcaog.net/docs/Regional_Parking.pdf). Off-street parking requirements represent asubsidy of parking coming from higher prices we all pay for housing, goods andservices (Donald Shoup, The High Cost ofFree Parking). These subsidiescreate further incentive for people to use the already overemphasized mode thatis responsible for so much congestion, emissions and threat to public safety. We will provide more detailed comments onmoving towards a more market-based parking policy once we have reviewed theCommunity Design Element.

Comments on Specificsin the Plan

8.2 Description ofTransportation Facilities

RoadwayInfrastructure

The unstated goal of perpetuating automobile dependency isapparent in this section.

“….are among the eight (8) road segments already operatingat above capacity¹.” p.8-2

While weunderstand this is a technical description of a road with certain characteristicsand traffic volumes, it reveals some of the absurdity of LOS forautomobiles. How can a road operateabove capacity? What does “at capacity”really mean if a road can continue to operate above it? If a road can operate “above capacity,” thenperhaps capacity needs to be better defined than the somewhat arbitrary numberattached to a given type of roadway.

“Roadway capacity is also affected by limited right-of waywidth and the need to provide for vehicle travel lanes and facilities for othertransportation modes, including public transit, bicycles and walking.” p.8-2

This impliesthat public transit, bicycling and walking are not valid modes for addingcapacity. It is possible to achievehigher passenger capacity per right-of-way width using Public transit andbicycling than using single occupancy vehicles.

“Simply put, areas with development potential need to beadequately served by roads with sufficient capacity to accommodate the newdevelopment.” p.8-3

This seemsto imply that the county must expand roads wherever there is developable land. Another way to put it would be: “Simply put,areas do not have development potential if they are not adequately served byroads with sufficient capacity to accommodate new development.”

“…and the preferred alternative involves construction of anoverpass at the intersection of

Indianola Cutoff and U.S. Highway 101.” p.8-4

A “LeastEnvironmentally Damaging Preferred Alternative” has not yet been selected forthis project.

Public Transportation

“The following fixed route systems serve the County’s publictransit needs: Redwood Transit System, Eureka Transit System, Southern Humboldt Rural Transit System,Arcata & Mad River Transit System, Klamath/Trinity Non EmergencyTransportation (K/T Net), and Blue Lake Rancheria.” p.8-4

SouthernHumboldt Rural Transit System, more commonly known as the Quail, would be betterdescribed as paratransit, rather than “fixed-route,” since it is only availableto seniors and the disabled, and not the rest of the general public.

“1 hour weekday interval or less as the appropriate level ofservice for the urban areas of Eureka and Arcata, and an interval of 1.5 hoursfor the U.S. Highway 101 corridor between Trinidad and Scotia. This Element carriesforward those public transit goals, policies and implementation measures applicableto the unincorporated areas of the County.” p.8-5

Thisstatement inserts inherent bias in the Circulation Element before goals andpolicies are discussed. While an LOS ofF for road capacity (which might represent a delay on the order of 1 minute) isdeemed non-satisfactory, and indicates the roadway is operating “abovecapacity,” a wait of 1 to 1.5 hours for the next bus is considered“appropriate.” Goals for transit servicein and between urban areas need to be defined in a manner that is more comparablewith LOS for other modes.

Non-motorized

“Major new non-motorized facilities are possible along theAnnie and Mary Rail Line from Arcata to Blue Lake, and along the NorthwesternPacific Railroad between Arcata and Eureka.” p.8-5

Re-write toread: “Major non-motorized transportation facilities are possible such asextending the existing Hammond Trail to Arcata, and trails on all former Northwest Pacific Railroad rights of way depending onthe near-term viability of the railroad. The most immediate projects include the Annie and Mary Rail Trailbetween Blue Lake and Arcata, and the Eureka ArcataHumboldt Bay Trail.” Otherwise the planmakes extremely limited statements of what is possible in the next 20 years.

8.3 Goals andPolicies

“C-G1 Roadway Safetyand Functionality. To develop, operate and maintain a well coordinated, balanced,circulation system that is safe, efficient and provides good access to allcities, communities, neighborhoods, recreational facilities and adjoiningregions [FRWK].” p.8-9

The Titleof this goal should be changed to “Circulation System Safety and Functionality”especially if you wish to use the word “balanced” to describe thetransportation system. Otherwise, thegoal immediately implies that altering roads (i.e. expanding their capacity) isthe only way to improve safety and functionality, when altering the way theroads are used (i.e. slowing speeds and balancing the mode-share) can alsoserve to improve safety and functionality.

It wouldalso be helpful to define access. Doesthis mean human access, or is an automobile required to have good access?

Is the word“efficient” meant to be with regard to user cost, government cost, both or withregard to fuel consumption?

“C-G2 Multi-ModalTransportation. To provide a balanced multi-modal transportation system thataccommodates motorized vehicles, public transit, bicycles, and pedestrians.”p.8-9

Does simplyaccommodating each mode qualify a transportation system as balanced? I don’t think most transportation plannerswould agree with this definition. Itneeds to be defined here so we know what the goal is. A balanced system could be defined as one inwhich roughly an equal number of trips are made by each mode, as is done in Fraiburg, Germany. This might be a good long term goal. In the shorter term you could use theVictoria Transportation Policy Institute definition: a transportation system in which consumershave a variety of transport options, and incentives to use each for what itdoes best.

“C-G3 InteragencyCooperation. To coordinate planning among state/county/city roadway systemservice providers and HCAOG for improved system design, development, operationsand maintenance.” p. 8-9

Re-write toread: “To coordinate planning among state/county/city transportation system service providers, and HCAOG for improvedsystem design, development, operations and maintenance.” Otherwise it is implied that transitproviders are not included in coordination.

“C-P2. RoadwayFunctional Classifications. Adopt and apply consistent roadway

functional classifications that reflecturban/rural/community distinctions and that

maximize right-of-way use for multi-modal safety andfunctionality.” p.8-9

This policyfalls short of the Seattlesystem mentioned in earlier comments. Distinctions in the priority each mode places on a roadway should bepart of the classification system.

From C-P6:

“A. Using minor collector roads to provide access to higherdensity residential areas, local commercial facilities, neighborhood parks andschools.” p.8-10

This policyhas the tendency to create major collectors and arterials that are unpleasantto walk on and have increased potential for crime if executed poorly. This is often due to privacy fences that wallthe sidewalks along an arterial off from the development, and poor pedestrianconnectivity. Here is our suggestedrewrite: “Using minor collector roads to provide access to higher densityresidential areas, local commercial facilities, neighborhood parks and schools,while maintaining maximum bicycle and pedestrian connectivity and access. New fences and walls fronting any sidewalk ormulti-use path shall be limited to 3 feet in height to provide a safeenvironment for pedestrians.”

FromC-P20:

“C.Multi-family housing, public uses such as libraries, schools and community centers,and commercial uses should be encouraged in areas serviced by public transitwhere consistent with other sections of the plan. [FRWK]” p.8-12

Change “should” to “shall.” Theopposite should also apply. That is:“Development and public uses shall be discouraged in areas not serviced bypublic transit.”

Thereshould be a section on urban lands in the Land-use Element to draft acollection of policies like this, but for some reason there is no such section.

“C-P21. RoadwayCapacity Expansion and Non-Vehicle Modes. Enhance the Level of

Service for non-vehicle modes when expanding roadwaycapacity for vehicle circulation.” p.8-12

Change“non-vehicle” to “non-motorized” in heading and text. Apply to other alternatives as well. A bicycle is a vehicle and the intent of thisPolicy was surely to include bicycles.

“C-P24. Right-of-WayMulti-Modal Level of Service Standards. Right of Way Multimodal Level ofService (LOS) Standards should be used for maximizing the multi-modalsuitability of County roads and intersections.” p.8-12

Replace“should be used” with “shall be adopted and used.” There is absolutely no justification forhaving standards only for automobiles in a balanced transportation system.

“C-P37. Use of theNWP Railroad Right of Way for Bicycles and Pedestrians. The County shallencourage of the NWP right of way between Arcata and Eureka as a Class 1 bike/pedestrian trailprovided those uses do not compromise future use of the right of way for railtransportation.” p.8-13

Add: “Shouldrailroad development become infeasible within the timeframe of the generalplan, the county shall encourage a rail-banking strategy to create multi-usetrails on all NWP rights of way creating intercity bicycle connectivity andpreserving rights-of-way in case of changes that make rail transportationfeasible in the distant future.

“C-P41. Joint Use ofthe Greater EurekaArea Travel Model. Integrate roadway maintenance and improvement datathrough use of the Greater Eureka Area Travel Model (GEATM). Supportcoordination with other agencies to resolve discrepancies in the list of roadsegments with capacity problems between the GEATM model and estimates made byHCOAG based on CalTrans data.” p.8-13 and 8-14

Before adoptionof policy advocating the reliance on a specific travel model (the GEATM), theassumptions, inputs and methods associated with that model must be understoodby the public and those who choose to adopt this policy. The information recently released on theGEATM and the Humboldt County Travel Demand Forecasting Model which it grewfrom indicates the following shortcomings of both models with regard tobalanced transportation:

• Trip generation estimates appear to be based on square footage and type of development. The correlation between trip generation and square footage is weak to non-existent in many cases.
• The model measures auto trips only and assumes a set per-unit trip-rate based on whether it is multifamily or single family housing. This may be a useful simplification if the goal is to prioritize accommodation of the automobile, but does not make sense in the context of the stated Circulation Element goals.
• There is no mode-choice component of the model “given the purpose of the model and the limited transit use in the county.” Transit is only one of four mode choices, and if the purpose of the model is not consistent with the stated goals of the circulation element, its use should be qualified.
• It would appear that changes in route selection because of congestion are accounted for, but not changes in trip time, or trip reduction. As congestion worsens individuals will make decisions to combine trip purposes or travel at off-peak times. This in combination with competitive alternative modes and land use that places at least some services closer to residents, could act to mitigate congestion in a way the model would be incapable of estimating.

These travel demand models may be useful, but until they aredeveloped in a way to serve the goals of the circulation element, they shouldbe used with caution and “a grain of salt.”

The policyshould have additional language to direct model developers to incorporatetravel demand management and multimodal inputs into travel demand models sothat these strategies can be effectively employed to help solve congestionproblems.

“C-P53. On-StreetParking. On street parking shall be prohibited discouraged in commercialareas and shall be prohibited discouraged where bicycle routes are plannedadjacent to public street’s travel lanes unless parking lanes are provided.(MCCP)” p.8-15

We willprovide more complete suggestions on parking policy once the Community DesignElement becomes available, but policies C-P53 and C-P68 needed to be addressedimmediately.

This policyhas two problems. First, it discourageson-street parking in commercial areas. This must be a mistake. In theabsence of public parking lots, on-street parking is the only parking thatenables motorists to park once and walk to various businesses to do theirshopping in a commercial district. Thusit works in concert with making a downtown walkable while still allowingautomobile access. If there is a concernwith having adequate right-of-way width, it should be written as a separatepolicy allowing for acquisition of additional right-of-way as a condition ofdevelopment or providing incentives to facilitate such an exchange.

It seemsthat the second purpose of this policy is to facilitate the creation of bikelanes in planned areas where they have not yet been built or designated. Perhaps wording stating that on-streetparking is of secondary importance to providing bike lanes where they areconsistent with the county bike plan might be clearer.

Anadditional issue brought up by this policy is that of car-dooring. Using existing design standards of a 7 footparking lane and 5 foot bike lane renders most of a bike lane hazardous becauseof the potential of being car-doored. A7 foot wide vehicle (not uncommon in our county) parked 18 inches from the curbleaves 3.5 feet of bike lane. Becausethe car-door zone extends 3 feet from the side of the vehicle, that leaves 6inches of usable bike lane.

Here’s asuggested rewrite: “On street parking isof secondary importance to providing bike lanes where they are consistent withthe county bicycle plan. On streetparking shall be prohibited in bike lanes. Designation of on street parking adjacent to bike lands should bediscouraged except where bike lanes and on street parking can be accommodatedwith a minimum parking lane width of 8ft, and minimum bike lane width of 6ft.”

“C-P68. Off-Street Parking. Off-street parkingalong local streets shall be encouraged in the design of new developments. Creative on-street parking arrangements suchas parking pockets or bays on local service roads are encouraged when based onengineering principles.” p.8-17

Encouragingoff-street parking instead of on-street parking in both commercial andresidential developments may increase development costs and decrease housingaffordability without expected benefit tradeoffs. For example, adding a driveway for off-streetparking at a residence takes away curb space from on-street parking whichfrequently is large enough to park another vehicle. Thus, in many circumstances adding off-streetparking may simply lead to greater construction costs and more land paved overwhich could be dedicated to other uses, all while doing little or nothing toincrease overall parking capacity.

“Creativesolutions” should be further clarified and expanded on. Allowed solutions should include methods suchas shared parking with other uses that have different peak travel demand hours,centralized off-site shared parking, and transportation demand management (TDM)or mobility management strategies. Thesestrategies could include universal transit pass programs for residentialneighborhoods or businesses, or designated spaces for subsidized car-sharingprograms, for example.

Theabove-suggested mobility management strategies are most effective when they arecomplemented by parking “unbundling,” so parking costs are not included in thecosts of other goods and services. Thisis best achieved by allowing developers and businesses to decide how much parkingto build rather than instituting minimum parking requirements. Since parking availability is important tomake most business or residential developments viable, they will find itnecessary to build parking, but since it is expensive to build, they willlikely choose a fairer, market-driven approach to providing parking — chargingresidents or business tenants for parking separately from other occupancyfees. Businesses, in turn, to reducetheir costs for parking, may offer employees a parking “cash-out” for notdriving to work.

“C-P70. TrailsImplementation Plan A Trails Implementation Plan shall be prepared…” p.8-18

This is animportant policy. Writing it in theactive voice will clarify who is responsible for making sure this gets done.

Standards

“C-S7 Multi-ModalLevel of Service Standards. Right of Way Multimodal Level of Service

(LOS) Standards should be used for maximizing themulti-modal suitability of County roads and intersections. For bicyclefacilities, LOS standards should be developed for the following types offacilities: …” p.8-21

Change toactive voice and change “should” to “shall.” LOS or “Quality of Service” (QOS) standards need to be adopted forpedestrians and transit as well. See ourcomments above on the Seattlesystem.

ImplementationMeasures

“C-IM6 Transit Infrastructure.Work with regional transit providers (HTA) to situate transit stops and hubs atlocations that are convenient for transit users, and promote increased transitusage through the provision of shelters, benches, and other amenities.” p.8-25

Thisimplementation measure leaves out many transit providers and falls far short ofthe goal of creating a balanced transportation system. It should be rewritten:

“Work with regional transit providers (K-T Net, Blue LakeRancheria Transit, HTA, A&MRTS and Redwood Coast Transit) to situatetransit stops and hubs at locations that are convenient for transit users. Where feasible, develop Bus Rapid Transitstrategies, such as signal prioritization, dedicated lanes and streets, queuejumps and bus stations with pre-board fare payment capabilities and next-busarrival display on congested urban corridors to provide long-term congestionrelief by providing a viable transit alternative”

A&MRTS shouldbe included in the event that it begins to provide service outside Arcata citylimits, such as to Jacoby Creek.

“C-IM9 U.S. Highway 101 Safety Corridor Improvements.Issuance of Coastal Development Permits and other discretionary permits by theCounty for the U.S. Highway 101 Safety Corridor Improvement project shouldsupport a strategy that treats all three main roads between Arcata and Eureka (U.S. Highway 101,State Route 255, and Old ArcataRoad/Myrtle Avenue) as one system. The strategywould develop an overall improvement plan that phases improvements on a prioritizedbasis between the three roads. Potential impacts of the project on coastalresources, including those that were identified in the comments made toCalTrans by the Board of Supervisors September 18, 2007, should be minimized.”p.8-25

Change toread: “…support a multimodalstrategy…”

8.4 Staff Analysisand Alternatives

“LOS D and worse are not generally appropriate designcriteria in rural areas. This provides no room for future growth, and caneasily lead to substantial deterioration in traffic operations which candecrease safety conditions.” p.8-32 and 8-33

Pleaseprovide a citation supporting the assertion that deterioration in trafficoperations can decrease safety conditions. Safety and congestion are separate issues.

“Areas with development potential need to be adequatelyserved by roads with sufficient capacity to accommodate the new development inorder to avoid serious operation or economic consequences.” p. 8-35

Thisstatement is backward. Given thecounties struggle to maintain its road network, this would be a better way tothink about it: “If an area is notserved by roads with sufficient capacity, new automobile-dependent developmentmay cause serious operation or economic consequences.” 

p.8-38

The tableabove is out-dated. Eureka offers four routes (not five) onweekdays. Arcata offers three routes (nottwo) on weekdays while HSU is in session. Arcata’s express shuttle runs until 5pm and the red and gold routes rununtil 10pm, not 7pm.

Mostimportantly, Redwood Transit Service average weekday headway is 41 minutes, andheadways are as short as 20 minutes during rush hour. The only weekday two hour headway is betweenthe second to last and last buses in the evening.

“Public transit in Humboldt Countyprimarily serves persons who have no alternative means of transportationavailable. With existing and likely available future funding, it does not appearfinancially feasible to provide transit service that can compete with theautomobile. A competitive transit service would require at least a doubling ofservice from current levels, and greatly extended hours of operation. Buttransit operators are financially stretched to operate at their current levels.”p.8-38

Thisparagraph has a few inaccuracies. First-off, HumboldtState Universityattendees compromise a great deal of the ridership on both A&MRTS andRTS. Many of these riders have othermeans of transportation, but choose the bus in part because of a universal buspass for students and in part due to parking fees that have doubled in the lastthree years, and will further increase to $157.50 per semester in Fall of 2008. Unionized university staff and facultycurrently pay less than $60 per semester now, but their parking fees may comeinto line with student and non-unionized staff fees in the next several years,adding incentives for more potential transit riders.

Withtransit ridership and service growing, and $100 million backlog on county roadmaintenance that gets worse every year, the county road system appears far lessfinancially feasible than transit growth. Competitive transit service is in part based on frequency of service(and RTS service frequency is roughly double what the draft elementassumes). However, transit cannotcompete as an alternative choice to the congestion on roadways if it is stuckin the same congestion that is acts to alleviate.

Bus RapidTransit strategies such as signal prioritization, dedicated lanes or streets,queue jumps and bus stations are not funded through the sometimes tight operatingbudget of the transit agency, because they are a capital improvement. As such, they can be funded with StateTransportation Improvement Project (STIP) dollars that are dispensed throughHCAOG. So it is the discretion of ourregion, whether we wish to fund transit improvements, and less an issue ofoperating budgets.

The issueof transit operators being financially stretched was covered in earliercomments. There is more TDA moneyavailable to HumboldtCounty to improve andexpand transit operations, but it is being spent on our financially infeasiblecounty road system.

Rail

“– especially since rail service was suspended in recentyears.” p.8-41

Replace“recent years” with “1998.”

“Passenger rail service could support efforts to increasetourism and offer an alternative for visitors to the County to Highway 101… passenger rail service can be animportant element of a comprehensive transportation system for the County.” p.8-41

Recent studiesdo not support this statement. The 2003Bay District document, “The Long Term Financial and Economic Feasibility of theNorthwestern Pacific Railroad” states: “Due to the relatively low population density and long travel times onthe NWP corridor, intercity passenger service demand was not found to be sufficientto warrant further analysis” (S-9).

While therewould be many benefits to the restoration of rail, it is unlikely to happen,and we need a “plan b” to ensure the preservation of these public rights-of-way. A network of multi-use trails is the obviouschoice for rights-of-way in the vicinity of BlueLake, Arcata, Manila,Samoa, Eureka, College of the Redwoods, Fortuna,Rio Dell and Scotia. Using a railbanking approach to build thetrails would help preserve the right-of-way and allow for return of rail atsome future date if market and political conditions change. Rail rights-of-way are already under threator lost in the northern part of the county as landowners reclaim railroadeasements on their land. Railbankingwould act to preserve the rights-of-way and prevent this loss of a vital publicasset.