23 June 2008

Dear HCAOG Board,

Thank you for the opportunity to comment on the draft 2008 Regional Transportation Plan.

We face emerging challenges that are different from the ones we have addressed in RTPs over the years. Now that oil prices are increasing rapidly, automobile dependence is becoming an even more substantial burden on our economy. The problem of transportation inequity will grow with fuel prices as well. More insidious health and safety problems, have become more apparent, like the rate of carnage on Eureka streets, and the rate of diabetes and other chronic diseases related to inactivity. Our overbuilt road system is now a struggle to maintain because of a decline in available funds.

This RTP represents an opportunity to begin to face some of the tough decisions about how to provide access to jobs, goods and services for Humboldt County residents into a changing future.

We were initially concerned about the separation of chapters by mode. This particularly becomes a problem when an assessed need in the Highways and Roadways Element is congestion. If the need is to relieve traffic congestion in a particular location, transit, non-motorized facilities and land use improvements may be a more effective way of addressing the problem, but because the need is stated in the Highway and Roadway Element, it makes it unlikely that a full suite of strategies will be considered to solve the problem. Waterfront Drive Extension is a classic example of this. The plan can still work written in this format, but care must be taken to avoid this trap by using the right measures of performance for safety and delay.

We see two major holes in the RTP: a failure to address the worsening $150 million maintenance backlog on county roads, and the lack of planning for substantial growth in transit ridership such as using Express Bus, Rapid Bus or Bus Rapid Transit strategies and market research to identify the next transit gorwth opportunities.

We are heartened to see strong language with regard to land use in this document, and hope that is results in strong regulatory land use planning documents for HCAOG entities. Land use has the potential to create the proximity that will make a smarter transportation system possible. The bicycle and pedestrian element is also relatively strong.

We hope the specific comments below in crafting a plan that succeeds in addressing the problems outlined above.

Sincerely,

Chris Rall - Executive Director

Green Wheels

Specific Comments

Executive Summary

Page ES-3

Redwood Coast Transit is missing from the list of transit services.

 

Page ES-4

While county residents express the need for service to Orick, it is actually already provided by Redwood Coast Transit although some may like schedule changes or enhancements that could be brought by changes in Redwood Coast Transit's schedule, extension of RTS to Orick, or the addition of a Humboldt County service connecting Orick with RTS.

 

Introduction

Page I-5

We hope the language regarding the impacts of land use decisions on transportation impacts and costs remains strong in the final document, in particular the language concerning low density development and single-use development.

 

Page. I-14

Regarding the figures displaying projected and future fuel usage and automobile travel, it should be noted that the projections show increases in VMT far steeper than historical increases. This seems higly unlikely given current high fuel costs. Furthermore, the Federal Energy Information Administration has consistently underestimated its fuel price predictions for the last five years. The Federal Highway Administration has reported that Americans are driving less in response to high gas prices (http://www.fhwa.dot.gov/pressroom/fhwa0811.htm).

 

Page I-15

The county's share of total housing need is determined by a Housing Needs Allocation process, the results of which are not yet complete. Given the high costs of developing transportation infrastructure in the unincorporated areas of the county, the purveyors of this process should draft criteria which emphasize development in existing urban areas. Since HCAOG is the body overseeing both the RTP and the Housing Needs Allocation, there ought to be consistency between the two. Given the goals set by the regional transportation plan and previous ones, it is inappropriate for the unincorporated areas of the county to absorb 54% of the growth. The incorporated areas have more capability to provide housing with greater access to transit, and to services via non-motorized transportation.

 

Page I-19

"This RTP will emphasize multimodal opportunities as a way to minimize any increase of vehicle miles traveled within the region."

Please change to read: "...as a way to decrease or minimize any increase of vehicle miles traveled..."

If we don't set appropriate goals, we have little to work for, and little success in addressing our energy problems.

 

Page I-20

"The NCRA will continue to strive to restore rail service."

The fact that this is all we can assume with regard to rail service in Humboldt County illustrates the need to have secondary plans for publicly-owned rights-of-way, and a mechanism for the NCRA to move on from infeasible plans to ones that are realistic and achievable.

 

Page I-21

"As a fundamental element for achieving its goal, the RTP supports an overall balance between transportation modes, and between preserving existing systems while developing new roadway systems."

Does "developing new roadway systems" mean building new roads, using roads in different ways, or something else? Our interest is in seeing roadways used differently, with more road space dedicated to transit and non-motorized modes. As it is the County is overburdened by maintaining its current road infrastructure.

 

Highways and Roadways

Page HR-5

Top of page.

While increasing the non-motorized and transit mode-shares can help to alleviate congestion, land use planning which places services, jobs, recreation and housing in close proximity is an important strategy in encouraging use of transit and non-motorized facilities. Also, while transit ridership helps reduce congestion, it will be difficult to encourage people to use transit instead of driving in congested conditions unless buses can bypass the congestion.

 

Page HR-8

"Goal: Build, maintain a safe and efficient highways, roadways, and streets system that will

accommodate and balance multiple modes of transportation."

The meaning of the word balance is unclear here. We suggest the Victoria Transportation Policy Institute definition be used explicitly:

A balanced transportation system is one in which consumers have a variety of transport options, and incentives to use each for what it does best. (http://www.vtpi.org/tdm/tdm100.htm)

 

Policy HR-4 concerns safety improvements, yet the objective that follows mentions traffic congestion before safety improvements. For the objective to be consistent with the policy, it need not mention congestion at all. In some cases congestion is a safety concern, but certainly not in all cases. Some roadway projects may address congestion as a way of addressing safety, but before an objective is set to address congestion, there would have to be a policy for reducing congestion. If this policy were to be oriented toward roadway expansion (adding lanes for single occupant vehicles) it would be inconsistent with the overall goal of providing a balanced transportation system, because it would involve spending limited transportation funding on additional car lanes, when bike lanes, sidewalks and transit services are missing in so many places.

Page HR-9

Policy HR-6 concerning solutions for 101 congestion in Eureka is well written.

 

Policies HR-10 and HR-11 discuss congestion reduction in a way that ignores the phenomenon of induced traffic. When roadway capacity is expanded, more people are encouraged to drive, increasing traffic volume and congestion at other sites in the artery where the expansion was made, and partially negating the congestion relief at the expansion site. One only needs to look at the Los Angeles Basin to see what capacity expansion leads to: lots of capacity and lots of congestion.

With regard to policy HR-11, the inclusion of LOS measures for bicycling and walking is encouraging, but we would like to see transit also included, and see this overall strategy specifically mentioned in the policy, not just in the objectives. An approach which emphasizes the overall performance of roads (not just LOS for automobiles) has been presented to some members of the Humboldt County community by Jeremy Nelson from Nelson Nygaard Associates at a Policy Charrette organized by the Humboldt Patnership for Active Living. The approach entails classifying roads in terms of their level of priority for each mode, and setting "Quality Of Service" (QOS) goals for each mode based on the level of priority for that mode on each road. Projects are then oriented toward balancing the QOS for each mode on a roadway according the level of priority for each mode. Transit QOS is scored on bus frequency, travel speed, hours of service, loading and reliability.

 

Resources on Measuring QOS in a balanced manner:

Seattle System: http://www.seattle.gov/transportation/docs/TSPprintfinal102505_ch3.pdf

a layperson's explanation is available at:

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

A more detailed explanation for how it works is available at:

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

 

Page HR-10:

Policy HR-13 is good policy

 

 

Comments on Specific Roadway Projects

 

Two short-term roadway projects are of specific concern to us: the 101 Eureka Arcata Corridor Improvement Project, and the Waterfront Drive Extension.

101 Eureka Arcata Corridor

As proposed in the draft Environmental Impact Report in 2007, the 101 Eureka Arcata Corridor Improvement Project had costs out of proportion to the safety problems it was meant to address, and proposed little by way of improvements for non-motorized or transit users of the corridor. While there has been discussion of a new alternative, we have not had the opportunity to review it, but if the STIP money programmed to the project is any indication, costs have been reduced substantially from $25 million in the 2006 RTP to $5.1 million in this RTP. The addition of programmed STIP funding for round-abouts at the Arcata 101 / 255 interchange, facilitating connectivity of bike lanes and sidewalks across 101, a project that emerged as a priority through the EIR process for the Eureka Arcata Corridor project, is another positive development. This project will substantially improve access for bicyclists and pedestrians traveling between Sunny Brae the south side of Arcata.

Waterfront Drive

The Waterfront Drive Extension Project which the City of Eureka continues to pursue is, in our view, a misguided strategy for dealing with congestion on Broadway. The Coastal Commission has little interest in seeing the PalCo Marsh be impacted by new road construction. There is little indication that they will permit the project. Even if they were to allow it, this project is projected to only temporarily alleviate congestion on Broadway. Lastly, this route along the waterfront from the Wharfinger Building to the Elk River is an incredible opportunity to create a Class I non-motorized trail that would be a great asset to Eureka and the wider community. Which is a better use of the waterfront: a non-motorized facility that will contribute to citizens' health and enjoyment of beautiful Humboldt Bay for years to come, or a bypass that will have limited and short-term effectiveness in alleviating congestion?

We support substantial investment in Eureka to deal with the safety and congestion problems there. Eureka is plagued by high motor-vehicle-related injury and death rates per capita and suffers the worst congestion in the County. A combination of land use and transit improvement strategies is the best hope for long-term alleviation of congestion and safety issues on Broadway. We support land use strategies such as investment in Eureka's multiple neighborhood centers, along with non-motorized facilities improvements, and traffic calming. It is disconcerting to not see projects of this type listed in the roadway section. Only 2 short term, and one long term projects were listed for Eureka in the RTP. This city has some of the biggest safety problems in California, and we need to invest to solve it.

 

New Roads in the County

One other note of concern in the list of projects is the number of new road projects planned for the unincorporated county. If the County indeed has a maintenance backlog of $150 million, a backlog that grew by $50 million in 8 years, is it wise for the county to build several new roads in the South Eureka Area without a clear plan for maintaining all of its roads? Humboldt County should be working to reduce the burden of road miles it carries, not increase it.

 

Page HR-31

An assumption is made that $3 million of the $4.5 million in TDA funds the County and Cities receive will be spent on streets and roadways. This would seem to contradict the statement: "In recent years, little LTF remains available for streets and roads at the end of the allocation process." on page HR-29. Are two thirds of Humboldt County's TDA funds spent on roads?

This is money is intended primarily for transit and for non-motorized facilities. Mendocino, Trinity and Del Norte Counties all spend close to 100% of their TDA funds on transit, with the remainder going to non-motorized facilities. Were our county to unify our transit system under one authority and do this, we could have an excellent transit system.

 

Page HR-33

Performance Measures

We would like to see a few changes in the measures of safety.

1) Please use the term "collision" rather than "accident."

2) Collision rates are counted per vehicle mile traveled. This is a flawed measurement because it masks the increase in collisions caused by increasing VMT. The goal needs to be improved safety for people. With transit providing a form of travel that is 10 times safer per passenger mile than single-occupant vehicles, it represents a real opportunity to improve safety, but our current flawed way of measuring safety would not detect gains in safety through that strategy. We would like to see a switch to counting collisions per passenger mile when measuring safety of a roadway of a particular length, and per person (passenger or pedestrian) for intersections.

3) Additionally, safety for pedestrians and bicyclists needs to be measured separately, per the number of pedestrians or bicyclists respectively passing through an intersection, or per bicycle-mile if relevant to a roadway segment. Measuring bicycle collisions per motor-vehicle traffic volume does not capture the risk to bicyclists on a given road. Using the motor-vehicle traffic volume metric would also make an increasing bicycle mode share appear to increase the danger to bicyclists when in fact the opposite tends to be true.

4) The most fundamental measure of collisions is per capita population. This should be included, and might spur HCAOG to redouble efforts to invest in safety improvements for Eureka which is one of the most dangerous cities in California for vehicle related injuries. Policies that place housing, services, recreation and jobs in close proximity will reduce the need to travel and therefore increase safety. Measuring injuries and fatalities per capita will detect these improvements, whereas measuring safety with respect to VMT will not.

5) We appreciate the inclusion of a measure of collision reduction per money invested.

We would like to see the following changes in the Mobility/ Accessibility performance measures and indicators:

1) See above for our discussion of LOS/QOS for multiple modes of travel. Most of the problems in this section could be cleared up by having a balance of performance standards for all modes.

2) It might be helpful to define "nonvehicle modes." We take this to mean land use strategies that reduce travel demand, and perhaps Travel System Management strategies.

3) There are several more measures of quality of service for transit that should be used (see above).

 

Page HR-34

The final measure of cost-effectiveness of projects, "Increase in annual passenger, freight and goods miles carried per thousand dollars invested," overemphasizes mobility rather than access. If an investment reduces the need for passengers, freight and goods to travel as far, it is just as worthwhile an investment.

 

Public Transit

Page PT-15

There is discussion of HTA designing and constructing "park-and-ride" facilities. Leasing existing parking lots should also be considered if they are well situated and owners are interested. This may be a more cost-effective solution. Care should be taken to ensure that newly constructed park-and-ride facilities are not sited in such a way that they inhibit transit-oriented land use development where there is potential for it.

The inclusion of language mentioning bike facilities is appreciated.

 

Page PT-24

"Low ridership, statutorily driven performance requirements, lower population density in rural

communities, and the HTA JPA limitations present significant challenges to the expansion of

existing services."

 

This sentence clearly and accurately lays out the challenges of improving transit service in Humboldt County. Interestingly enough, of the four barriers to increasing investment in RTS, three are local decisions, and one of those has already been addressed. Ridership on RTS has increased by around 50% in the last 5 years. With the County General Plan Update process and Regional Housing Needs Allocation, we have the opportunity to increase population density where transit exisits, and the HTA JPA is a local construct that we have the power to change locally. Were we to apply the funding model of Mendocino, Del Norte or Trinity County, rolling our transit systems into one authority which is responsible for meeting all the unmet transit needs of the County, we could increase TDA funding for RTS operations by around 50%. Pursuing these changes to increase transit ridership growth would be consistent with the overall goal of the RTP to develop a "balanced, countywide multimodal transportation system."

 

Page PT-29 and PT-30

The only performance measures here relevant to users of fixed-route and commuter transit are miles between "accidents," on-time departures and service frequency. We recommend adding performance measures for transit speed (or travel time), hours of operation and crowding. We provided resources above in the discussion of LOS. Given that transit represents the smallest mode-share of trips to work according to the 2000 census (1%), and given the overall goal to develop a balanced multimodal transportation system, growth in ridership should probably be a performance measure as well.

 

Pages PT-30 and PT-31

While not a specific project, the most impressive accomplishment for RTS has been its extraordinary growth in ridership.

 

Bicycle and Pedestrian

Page BP-6

Change "Greenwheels" to "Green Wheels"

 

Page BP-20

It's terrific to see the Bicycle Compatibility Index being put forward in policy.

 

Page BP-30

As mentioned in our comments on the performance measures for roads and highways, measuring bicycle collision rates per motor-vehicle traffic volume is not a helpful measure of safety for a bicyclist using a facility, nor is number of incidents. Since there is a goal of increasing ridership, incidents per bicycle volume would provide an accurate measure of cyclist safety.

 

The Bicycle and Pedestrian Element fails to recognize the role traffic reduction plays in encouraging bicycle ridership. High traffic volumes are one of the main impediments to gaining a large bicycle mode-share. Traffic calming and diversions to discourage motorized thru-traffic can be used on connective non-arterial streets thus creating low-traffic streets where bicyclists feel safe. Portland has used this "bicycle boulevard" strategy to create an extensive bicycle network as part of an overall strategy that has driven a 400% increase in cycling there over the last 6 years. The key to its success is traffic reduction.

 

Goods Movement

Page GM-20

Policy GM-13. This policy opens the question of how long something that is not feasible should be supported. It has been a decade since the railroad has been used. The NCRA is being sued by the City of Novato for alleged violations of CEQA, and there is currently no identified funding source for restoring the railroad. As HCAOG policy directs us to "continue to support the restoration" of the railroad, we continue to ask at what point to we put the NCRA right-of-way to use as a trail for which funding from the California Coastal Conservancy has already been identified?

 

Community Input

Page CI-12

The description of workshop participants' rankings of modes is confusing when compared to Tables CI1-CI4. The percentages cited in the text and in bold in each table are the percentages of workshop participants that allotted a particular rank to a particular mode, not ranked that as their favorite or most valued mode. Perhaps noting the rank of each mode when noting the percentages in the body of the plan would make it more clear, i.e. 1.) bicycle and pedestrian facilities (41%), 2.) public transit and paratransit services (37%) etc. This type of clarification seems to be more prevalent in similar situations later in the element.