Incentives for Healthy Communities: the Indirect Source Rule for the San Joaquin Valley, Environmental Defense Fund

Incentives for Healthy Communities

THE INDIRECT SOURCE RULE FOR THE SAN JOAQUIN VALLEY AND ITS PROMISE OF CLEANER AIR

Incentives for Healthy Communities

THE INDIRECT SOURCE RULE FOR THE SAN JOAQUIN VALLEY AND ITS PROMISE OF CLEANER AIR

AUTHORS Michael A. Repogle Kathryn Phillips Cover image: Photo by Environmental Defense

Our mission Environmental Defense is dedicated to protecting the environmental rights of all people, including the right to clean air, clean water, healthy food and flourishing ecosystems. Guided by science, we work to create practical solutions that win last- ing political, economic and social support because they are nonpartisan, cost- effective and fair.

The complete report is available online at www.environmentaldefense.org. Contents

Executive summary iv

Introduction 1

CHAPTER 1 A brief history of indirect source rules 4

CHAPTER 2 The impetus for a San Joaquin Valley Indirect Source Rule 5

CHAPTER 3 Progress towards a San Joaquin Indirect Source Rule 7

CHAPTER 4 An extraordinary opportunity 8

CHAPTER 5 Winning the greatest benefits 10

CHAPTER 6 Improving the San Joaquin Valley proposal 12

Conclusion 19

APPENDIX A Traffic reduction success stories 20

APPENDIX B Four key benefits of an ISR 28

Notes 29

iii Executive summary

The San Joaquin Valley is currently behind such goals. Fortunately, a new air enjoying a population and economic pollution control strategy, known as an boom. But these developments could indirect source rule (ISR), can help. ISRs be compromised by the congestion and work by limiting the indirect emissions pollution that an increase in people and from new developments. Indirect traffic brings. Recent history provides a emissions include air pollution from hint of what is to come. In just 20 years, automobile traffic attracted to the new from 1980 to 2000, the region’s popula- development; energy demand from new tion increased by 60% and daily vehicle homes and businesses; and pollution miles traveled (VMT) in the region from construction equipment. grew by 150%.1 By 2040, the region’s Such a rule first estimates how much population is expected to double to indirect emissions will increase over about 7 million.2 This would amount time. This estimate is typically expressed to dropping ten new Fresnos into the in terms of tons of new pollution. The Valley. The lack of any clear policy for rule encourages reducing this new pollu- addressing this growth threatens to tion at the development itself by pro- turn the San Joaquin Valley into another moting measures, such as double-paned San Fernando Valley disorganized, windows or a solar water heater, that congested sprawl where any gains in air will cut energy demand. To offset the quality are threatened by new growth remaining emissions that the developer and traffic. either cannot or does not want to But this need not be the Valley’s future. address on site, the rule applies well- Proper planning using sensible market calibrated impact fees that will pay for incentives can manage growth in ways offsite pollution reductions. that create more travel choices, save Several air districts in California are money, build healthier communities and exploring ISRs to cut air pollution while boost the economy. But this can happen still meeting housing and job needs. The only if civic and business leaders unite San Joaquin Valley Air Pollution Con- ENVIRONMENTAL DEFENSE ENVIRONMENTAL

iv trol District is among these. It released developments have variations in emis- a legislatively mandated ISR proposal sions over their lives, include that vari- in June called DESIGN (Decreasing ation in emissions modeling, and review Emissions’ Significant Impact from actual emissions periodically. Growth and New development). Un- fortunately, the proposed rule falls short. 3. Ensure that mitigation measures,

It seeks to reduce NOx pollution by just especially off-site mitigation measures, 4.1 tons per day, even though vehicle provide permanent reductions in pollu-

NOx emissions are expected to increase tion. In some cases, it may be necessary by 25 tons per day by 2010. to sequence shorter-term measures with If the San Joaquin Valley air district’s other shorter- or longer-term measures ISR is to be effective, its goal should to ensure permanent mitigation. be full mitigation of the air pollution associated with new development. This 4. Develop longer-term measures, in- is an achievable objective for which cluding those improving transportation there is legal authority. choices, with mitigation funds. In con- The air district’s proposed rule can be sidering the best uses of the mitigation improved. If well designed, such a rule funds, the district should engage the will provide means for low-cost compli- public, local government and other ance and generate substantial long-term agencies. Ensure proper oversight and health benefits, travel time reductions, and transparency. The ISR will only work energy cost savings for consumers, home if the public has confidence that it is buyers and residents, while boosting the being administered effectively. Building economic vitality of the San Joaquin that confidence requires that there be Valley. To achieve the greatest benefit, timely public access to the information we recommend that the district’s proposed used to calculate emissions or mitigation rule be redrafted to do the following: or fees. Additionally, decisions about how fees are used must include the 1. Fully mitigate the most health- public, and accounting of those fees threatening indirect source pollutants. must be easily available. This means including oxides of nitrogen, particulate matter (PM10 and PM2.5), and 5. Reveal the benefits of the program reactive organic gases (ROG), in the rule. by revealing the health and other costs air pollution creates in the San Joaquin 2. Extend the mitigation to 30 years Valley. Socioeconomic analyses must in- to more faithfully reflect the life of the clude the economic impacts poor air has development project. Recognize that on the Valley’s businesses and residents.

Introduction

One of the greatest barriers to healthy robust growth could be managed in air quality in the San Joaquin Valley is ways that would give people more and rapid growth and the vehicle pollution better choices, save money, create that growth creates. Recent history healthier communities and boost the provides a hint of what is to come. In economy. However, this can happen just 20 years, from 1980 to 2000, the only if civic and business leaders unite region’s population increased by 60% behind such goals and support measures and daily vehicle miles traveled (VMT) that will help ensure that future growth in the region grew by 150%.3 The in- reinforces, rather than undermines, crease in miles driven offsets the pollu- those goals. tion reductions gained from the shift to Residents of the San Joaquin Valley cleaner motor vehicles and fuels. In are clearly aware of these challenges. 2003, for example, although the average In a 2004 Central Valley survey, the new car sold in California was 75% less Public Policy Institute of California polluting than 1994 models, mobile determined that: sources still accounted for 69% of nitro-

gen oxide (NOx) emissions in the San Since 1999, concern over traffic congestion Joaquin Air District.4 And miles driven has nearly doubled from 23% to 44%. Air continue to soar, increasing 9% between pollution—viewed as the Valley’s most 1999 and 2002, with an additional 27% important issue—is now considered a big increase expected by 2010.5 problem by 45% of the population, up from By 2040, the region’s population is 28% in 1999. Furthermore, residents expected to double to about 7 million.6 express increasing dissatisfaction with the This would amount to dropping ten lack of affordable housing: Positive ratings new Fresnos into the Valley. If current have fallen from 37% to 19% since 1999. planning trends continue-with no clear policy addressing growth-induced From among traditional planning pollution and traffic increases—then agencies and government organizations the San Joaquin Valley will become no clear leadership has emerged to another San Fernando Valley: dis- respond effectively to the public’s organized, congested sprawl where any concerns. However, a new air pollution gains in air quality are threatened by control strategy shows the promise of new growth and traffic. In addition, delivering the kind of leadership and this could drive the cost of living in the creative thinking needed to ensure a Valley up while driving the quality of more responsible growth pattern. This life down. As in other parts of Cali- strategy, if properly developed and fornia, as housing starts increase, the enthusiastically embraced, would: amount of broadly affordable housing • preserve farmland and open space; could decrease, adding to an already • encourage revitalization of existing strong disparity between the haves and communities; have-nots in a region long suffering from double-digit unemployment. • reduce vehicle miles traveled and But this need not be the Valley’s future. traffic congestion; With the adoption of sensible market • improve opportunities for affordable incentives, planning and accountability, housing;

1 • create more transportation and and a nearby shopping mall, a housing housing choice; and ultimately developer might fund an electric shuttle • produce permanent solutions to air service between the development and pollution. the mall. Finally, for the new development, The strategy is an indirect source rule the ISR applies well-calibrated impact (ISR) that mitigates indirect emissions fees to offset the remaining emissions from new developments. Indirect emis- that the developer either cannot or sions typically include air pollution cre- does not want to mitigate on site. A ated by truck and car traffic attracted well-functioning ISR ensures that the to a new development; the energy fees are reasonable, and will pay for a demanded by new homes and businesses portfolio of offsite pollution cleanup for electricity, heating and cooling; and measures that will last at least as long construction equipment used to build as the development generating the the new development. Ideally, an ISR indirect source pollution. completes three different tasks for each Several air districts in California are new development. exploring ways to use an ISR approach First, the rule considers the likely to cut air pollution while still meeting change in indirect emissions over time housing and job needs. The San Joaquin for a land parcel proposed for develop- Valley Air Pollution Control District is ment. That is, the rule uses reasonable among these. and generally accepted methods, includ- Under legislative mandate to create ing computer modeling, to estimate how such a rule, on June 15, 2005, the much new car and truck traffic, new San Joaquin Valley Air Pollution energy demand, and new construction Control District released a draft a development will generate and how proposal for an ISR which it calls the much pollution all of these indirect DESIGN (Decreasing Emissions’ sources will create. This estimate is Significant Impact from Growth and typically expressed in terms of new New development) Program. As the tons of pollution. Air District’s Extreme Ozone Attainment Next, the rule encourages maximum Plan for the San Joaquin Valley noted onsite mitigation of the new pollution in October 2004: from the indirect sources. Normally, that means a developer is encouraged to do Although tailpipe emissions per vehicle are things on the development site that will declining, growth in travel related to new reduce the amount of pollution from the development is projected to cause an addi- homes or businesses themselves (the tional 25 tons/day of NOx emissions that direct sources) and from the indirect would not be emitted if the growth did not sources attracted to those homes or occur. This means that the mobile source businesses. For instance, to reduce the program is inadequate to do the job by the amount of pollution a new home mandated 2010 attainment date and that generates, a developer might install additional reductions are needed. The in- double-paned windows or a solar- direct source program can provide some of powered water heater to cut the home’s the emissions reductions to offset growth.7 energy demand. Or, in another example, to reduce the number of pollution- The draft ISR proposed by the Air generating car trips that residents make District in June 2005 falls far short of between a new housing development fully offsetting the 25 tons per day of

2 tion. In some cases, it may be necessary to sequence shorter-term measures with other shorter- or longer-term measures to ensure permanent mitigation.

4. Develop longer-term measures, including those improving transportation choices, with mitigation funds. In considering the best uses of the mitigation funds, the district should engage the public, local government and other agencies. Ensure proper oversight and transparency. The ISR will only work

MICHAEL REPOGLE if the public has confidence that it is Bicycle parking and pedestrian-friendly sdewalks help reduce air being administered effectively. Building pollution. that confidence requires that there be timely public access to the information

NOx emissions—seeking to reduce these used to calculate emissions or mitigation by only 4.1 tons per day, or by less than or fees. Additionally, decisions about 20%. Nevertheless, the draft establishes a how fees are used must include the valuable framework that can be enhanced public, and accounting of those fees as the ISR moves towards adoption. must be easily available. To achieve the greatest benefit, we recommend that the district’s proposed 5. Reveal the benefits of the program by rule be redrafted to do the following: revealing the health and other costs air pollution creates in the San Joaquin Val- 1. Fully mitigate the most health- ley. Socioeconomic analyses must include threatening indirect source pollutants. the economic impacts that poor air has This means including oxides of nitro- on the Valley’s businesses and residents.

gen, particulate matter (PM10 and

PM2.5), and reactive organic gases If the San Joaquin Valley air district’s (ROG), in the rule. ISR is to be fully effective, its main goal should be full mitigation of the air 2. Extend the mitigation to 30 years pollution associated with new develop- to more faithfully reflect the life of the ment. This is an achievable objective development project. Recognize that for which there is legal authority. If well developments have variations in emis- designed, such a rule will provide means sions over their lives, include that vari- for low-cost compliance for the devel- ation in emissions modeling, and review opment industry and generate substan- actual emissions periodically. tial long-term health benefits, travel time reductions, and energy cost savings 3. Ensure that mitigation measures, for consumers, home buyers and resi- especially off-site mitigation measures, dents, while boosting the economic provide permanent reductions in pollu- vitality of the San Joaquin Valley.

3 CHAPTER 1 A brief history of indirect source rules

Experience with indirect source rules California Environmental Quality Act goes back to the early 1970s, when (CEQA) to establish conditions for initial efforts were made at the federal, approval of developments that will have state and local level to link air quality, significant effects on the environment. transportation and land development Under CEQA, public agencies shall not decisions. In the early 1970s, the approve a project unless feasible alterna- United States Environmental Pro- tives are considered and mitigation tection Agency (EPA) sought to in- measures incorporated that would sub- clude ISRs as a common required stantially lessen any significant effects element in federally mandated air on the environment. First-generation quality control plans, but resistance ISRs in several air districts arose from from the building industry led Congress intersection of this CEQA mandate and in 1975 to rescind EPA authority to the California Clean Air Act. require such rules in Clean Air Act These first-generation ISRs, mostly implementation plans, as the industry in rural areas, focused on mid-size and saw them as a federal intrusion on local larger developments and sought to land use powers. generate impact fee revenue but not to Nonetheless, some states and local mitigate fully emissions impacts. For jurisdictions voluntarily adopted ISRs as example, the Feather River Air Quality a tool to manage air pollution and traffic Management District rule, issued in congestion and help fund local air pol- 1998, exempts projects producing less

lution reduction programs, including than 25 pounds per day of NOx or Oregon, Vermont, New York State and reactive organic gases (ROG) emissions. Wisconsin. These first-generation ISRs This is approximately two tons per year

varied in scope, often focusing only on of each pollutant, equivalent to the NOx large developments within areas that and ROG emissions of about 100 to 120 were in non-attainment of various air homes, respectively. pollution standards and on simple im- The challenges of achieving and pact fee structures not well tied to actual sustaining healthful air quality in the pollution emissions. San Joaquin Valley demand a more The California Clean Air Act of effective and comprehensive approach 1988 set stricter air quality standards than these first-generation approaches. than the federal act and required non- A second-generation indirect source attainment areas to adopt all reasonably rule—that creates strong market in- available transportation control measures centives that enable developers to avoid to reach its goals. From the 1990s on, or fully mitigate the indirect air pollu- this led various California air districts tion from new developments—is both to focus on identifying and mitigating achievable and necessary to support indirect air pollution associated with sustainable long-term economic growth larger-scale land development. Air and community development that districts also have authority under the protects public health in the Valley.

4 CHAPTER 2 The impetus for a San Joaquin Valley Indirect Source Rule

As Figures 1 and 2 show, development emissions are forecast to grow by 17.3 has a major impact on emissions of tons/day, according to the San Joaquin 8 particulate matter (PM10, or particles Air District.

between 2.5 and 10 micrometers) and NOx is a key ingredient of ground-level

NOx in the eight-county San Joaquin ozone. Ozone is known to reduce lung Valley Air Pollution Control District. function and cause or exacerbate a range

Between 2006 and 2010, PM10 emis- of heart and lung ailments, including sions are forecast to grow 51.7 tons/day asthma. Particulate matter is also known

due to new development, while NOx to cause or exacerbate heart and lung

FIGURE 1 9 PM10 emissions from growth and development in San Joaquin Air District

50 Paved road dust Construction 40 Motor vehicle exhaust

emissions (tpd) emissions 30 10

PM 20

0 2006 2010 2015

FIGURE 2

Difference in NOx emissions from all vehicles, San Joaquin Air District

200

150

100 Tons Growth No growth 50

0 2006 2010 2015

5 also contained commitments to reduce

indirect source NOx pollution by 4.0 tons/day.12 By 2007 the District must prepare a plan to attain the new more stringent federal eight-hour ozone standard and this will require additional deep pollution reductions. More reductions will be needed to plan for attain-

ment of the standard for PM2.5 (particles below 2.5 micrometers). Under the California Clean Air Act’s severe non- attainment classification for the state ozone standard, the District is required

LYNN BETTS/USDA NATURAL RESOURCES CONSERVATION SERVICE RESOURCES CONSERVATION NATURAL BETTS/USDA LYNN to include “reasonably available trans- A strong ISR allows new construction and mitigates new pollution. portation control measures sufficient to substantially reduce the rate of increase ailments and is estimated to be responsible in passenger vehicle trips and miles for thousands of premature deaths in traveled per trip...” in its state air quality California each year.10 The San Joaquin plans.13 Section 40910 of the California Valley is currently noted for having the Health and Safety Code (CH&SC) worst air quality in the country and is in requires air pollution control districts in extreme non-attainment of federal ambi- the state to achieve and maintain state ent air quality standards for ozone, and ambient air quality standards for ozone,

serious non-attainment for PM10. carbon monoxide, sulfur dioxide and Public health concerns alone would nitrogen dioxide at the earliest prac- suggest that the San Joaquin Valley ticable date.14 Air Pollution Control District would be Another legal mandate for this ISR anxious to use an innovative tool like comes from the California Legislature an ISR to reduce air pollution. But there through its adoption of Senate Bill 709, are other compelling reasons. One is authored by Senator Dean Florez, on that the Air District has a legal mandate September 22, 2003. This bill includes a to adopt a strong second-generation requirement that the San Joaquin Valley ISR to meet state and federal air quality Air Quality Control District adopt “a requirements. schedule of fees to be assessed on area-

In its 2003 PM10 air pollution control wide or indirect sources of emissions plan, the San Joaquin Valley Air Pollu- that are regulated, but for which permits tion Control District (APCD) com- are not issued, by the district to recover mitted to adopt an ISR by 2004 to the costs of district programs related to

reduce 1.3 tons/day PM10 in 2005, 4.0 those sources.” The law also says that tons/day in 2008, and 6.2 tons/day in the fee schedule shall be designed to 2010 in order to meet federal air quality yield a sum not exceeding the estimated standards.11 The Air District’s Extreme cost of the administering the programs Ozone Attainment Demonstration Plan and the cost of “mitigation of emissions.”

6 CHAPTER 3 Progress towards a San Joaquin Indirect Source Rule

The Air District issued a preliminary under CEQA in recent years resulted draft staff report for an indirect source in settlements that included substantial rule in October 2003 in the face of emissions impact mitigation fees. After significant opposition, including Build- being approached by two major devel- ing Industry Association threats of opers who were anxious to avoid a simi- legal challenges in court should a rule lar challenge and project delay, the San be adopted. The District proceeded Joaquin Valley Air District in April to update technical tools and conduct 2005 adopted controversial emissions other analyses, which slowed the rule reduction contract agreements with the development. On June 15, 2005, the two developers. The agreements involve District posted a new draft staff report payment to the District of emissions and proposed ISR. It held a public impact fees. These contracts were workshop on the draft on June 30, and adopted with little opportunity for after more revisions, will hold another public review and comment and without workshop in September. release of the technical assumptions Sierra Club challenges to various underlying the calculation of the emis- major developments in Kern County sions or related impact fees.

7 CHAPTER 4 An extraordinary opportunity

The indirect source rule process pro- bus rapid transit lines to boost transit vides an extraordinary opportunity to use and focus new development. help the San Joaquin Valley change It could work with the eight separate course. With involvement and en- metropolitan planning organizations couragement by the general public and and dozens of local jurisdictions to help other stakeholders, the rule could help fund a region-wide transportation plan- shape development patterns and deci- ning coordinator to help identify cost- sions in ways that clean the air and, at effective economic development and the same time, provide other benefits— investment opportunities to support job from better housing to less time in and housing growth with less traffic. traffic. If the Valley takes advantage of Public-private partnerships focused on this opportunity, it could lead the way transportation and emissions manage- for other air districts across the state to ment could enable small and large follow and adopt the Air District’s developers alike to cooperate in identi- model rule. fying and marketing least-cost emissions The San Joaquin rule could include reduction strategies. short- and mid-term emissions strategies The San Joaquin Valley has repeat- such as: replacing dirty diesel engines with edly failed to meet federal deadlines and cleaner ones, cleanup of dirty construction locally adopted goals for attaining equipment, improved transit in the city healthful air quality for area residents. core and rural vanpool services. It could As Figure 3 shows, smog pollution include investment in emissions reduc- remains as big a challenge today for tion strategies that produce sustained public health in the Valley as it did in long-term benefits, such as incentives 1990. If the District adopts a weak ISR to expand affordable infill housing that falls short of full emissions miti- developments close to job centers and gation for new development, such

FIGURE 3 San Joaquin Air District’s smog pollution remains as big a problem today as in 1990

140

120

100

SJVAB days above state ozone standard state days above SJVAB 0 1990 1991 1992 19931994 1995 1996 1997 1998 1999 2000 2001 2002

8 failure is likely to be repeated to the the affordability of housing close to jobs. detriment of public health, especially for It could also serve as the first step in vulnerable populations such as children a region-wide public planning process, and the elderly. A weak rule will set similar to those that have succeeded back efforts to attract high-paying jobs elsewhere in the country, including that will support sustainable and Salt Lake City, Utah and Sacramento attractive community development. County. The San Joaquin Valley is A well-crafted, strong ISR that fully clearly ripe for such an effort, especially offsets new emissions would cut the in Fresno County, where community very substantial health and business leaders grapple with designing a local costs imposed on the Valley by air pollu- transportation funding measure that can tion while expanding travel choices, cut- win broad public support to pay for new ting traffic congestion, and enhancing transportation investments.

9 CHAPTER 5 Winning the greatest benefits

For the San Joaquin Valley ISR to pro- because as more residents move in and vide more and better choices, save money, grow their families, and as commercial create healthier children, families and and industrial developments attract and communities and boost the economy, it expand their markets and activities, is important that the rule be based on traffic increases and emissions grow. several key principles: Similarly, the effectiveness of most emissions mitigation strategies cannot 1. Full emissions mitigation. The rule be treated as a constant. Effectiveness should require full mitigation of emis- varies over time. Some strategies, such sions from new development to support as replacing a dirty diesel agricultural the timely meeting of air quality stan- pump with a new clean pump, produce dards and public health protection. The a big initial benefit that will disappear District should not undermine already at some point in the future. Other strat- adopted federal and state emissions egies, such as developing a new bus reduction rules, such as more stringent rapid transit line to attract new transit motor vehicle emissions and fuel stan- riders and spur less car-dependent com- dards, by allowing the real estate devel- munity development, produce only opment industry to cancel out these modest emissions reduction benefits already planned and credited emissions in their early years but can accrue ever- reductions. This would be the effect growing emissions reduction benefits of indirect source emissions accounting over a long period of time. that implicitly gives developers credit for such reductions. 4. Timely public oversight of analysis. Emissions accounting should be 2. Use of best analysis tools and transparent and available for timely assumptions. Emissions calculations independent oversight and public should be based on best available anal- comment to ensure the integrity of the ysis tools and assumptions, such as the ISR and confidence of the public and URBEMIS model developed by the Air development community in the admin- Resources Board and other air districts, istration of emissions accounting and complemented with analysis assump- mitigation funding. Documentation of tions drawn from and consistent with how emissions have been estimated for regional travel models and recent local any development should be sufficiently studies. clear that any competent outside independent auditor could understand the 3. Use of time-sensitive development assumptions and methods well enough lifecycle emissions analysis. Emissions to replicate the analysis. accounting should take note that emissions from developments will vary con- 5. Encouragement for regional and siderably over time. Although cars and community-based traffic and emissions trucks are getting cleaner each year as management public-private partner- older vehicles are replaced with newer, ships. Many opportunities for the most cleaner ones, first-year indirect source cost-effective long-term emissions emissions will still often increase sig- avoidance can be found only through nificantly a few years later. This is better regional business and government

10 cooperation to explore smart growth ISR. Smaller projects should be exempt and transportation management from more detailed analysis required for strategies, as is being done through the larger developments, but should still be Sacramento Regional Blueprint process. required to incorporate all feasible on- The emissions analysis techniques of the site mitigation strategies identified in ISR could be applied to evaluate the checklists tailored to the type of devel- general plans of cities and counties and opment and its location, and to make a to identify benefits in emissions contribution to offsite mitigation, with avoidance that could result from better credits available for exemplary onsite balancing job and housing growth at mitigation and participation in trans- different income and affordability levels portation management district agree- and fostering increased travel choices. ments, where available.16 Urban infill Such regional travel model sensitivity projects below the full ISR thresholds analysis should be used to produce small that contribute to meeting affordable area-specific adjustment factors to the housing needs close to job-rich areas or URBEMIS model where opportunities that contribute to employment creation for extra emissions reduction crediting in low-income, high-unemployment may be appropriate, such as for urban neighborhoods might be exempted infill housing in areas with too little from further ISR emissions mitigation housing near a major job center. requirements. Other opportunities lie at the community level in mechanisms like transporta- 7. Fully account for costs and benefits tion management associations that help in developing and administering the employers expand commuting options for rule. Dirty air and few or no trans- their employees, manage parking supply portation choices carry large hidden and prices, improve conditions for pedes- costs to public health, the environment, trians and cyclists, sponsor improved natural resources and communities. A transit and vanpool services, and foster sound ISR will take these costs into market-incentive and marketing based account and help make them explicit. It approaches to reducing traffic growth.15 will not consider only the development The ISR should help support widespread industry’s direct costs of compliance availability of these approaches and pro- with the rule but also the fiscal, eco- vide a framework to enable small devel- nomic and societal benefits of changes opers to gain technical assistance and brought about by the rule. These participate in these initiatives to mitigate changes could include more compact small project development emissions with mixed-use development; an improved minimum administrative cost and hassle. local job-housing balance that increases the availability of affordable housing 6. Support emissions mitigation from near job centers; reduced transportation small developments with simplified costs for residents with more travel community-based compliance programs. choices and less need to travel long A simplified and flexible approach distances daily; and reduced travel time, should apply to all projects smaller than which means higher productivity and the exemption thresholds for the full more time with family and friends.

11 CHAPTER 6 Improving the San Joaquin Valley proposal

The draft ISR released for comment by The developer would be required to the San Joaquin Air District in late June do onsite or offsite mitigation or pur- 2005 lays an important framework for chase mitigation credits only sufficient future action. The proposal is a good to offset pollution represented by the foundation for crafting a stronger rule light area, representing one-third of the that better incorporates the principles first ten years of total indirect source discussed above. emissions. The indirect source emissions represented by the dark colored area consti- Create full emissions mitigation tute two-thirds of the unmitigated The June 2005 draft rule takes a sound project indirect source emissions that

approach to mitigation of PM10 con- would be produced over the first ten struction-related emissions—that years and that would not be subject to should be applied more broadly: 100% emissions reduction or mitigation mitigation. But in several other key requirements. The project’s indirect respects, the proposed rule would fall far source emissions after the tenth year short of full emissions mitigation. The would not be subject to any accounting proposed rule seeks to exempt from or mitigation whatsoever. The exemp- mitigation requirements two-thirds of tion of these emissions from the rule

total project indirect source NOx emis- appears to be arbitrary and capricious.

sions, half of PM10 emissions, and all The discussion of this discounting in indirect source emissions after the tenth the June 2005 draft ISR fails to justify year of a development project. properly the exemption of these emis- The proposal exempts from mitiga- sions. All that the staff draft says is: tion requirements two-thirds of total

project NOx emissions during the first Since the majority of the NOx emissions ten years, as illustrated in Figure 4. associated with a project are due to motor

FIGURE 4

NOx project emissions and reductions compared to 50% of first-year emissions

3.5

3.0 Baseline project emissions in excess of 50% of first year 2.5 50% of first year

2.0

1.5

Emissions (tons) Emissions 1.0

0.5

0 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

12 vehicles, there is a decline in NOx emissions for full mitigation of construction over time due to ARB’s tailpipe controls. emissions is the right approach and

The primary concept for the NOx mitiga- should be applied to all indirect source tion fee is that annual NOx emissions from emissions for the lifetime of a project. motor vehicles declines 50% over ten years. To assume that a new development Thus the rule requires mitigation of the generates just half the trips it actually cumulative NOx emissions in excess of 50% does would result in new air pollution of the projects first-year baseline emissions that could be avoided. That would result until the project’s baseline emissions reaches in allowing air pollution that adds to the half of the project’s first-year baseline emis- local pollution health risk. If there is sions, which is approximately 10 years.17 going to be discounting—say, to take account of double counting for trips that This justification implicitly gives might be attracted to a new neighbor- credit to developers in advance for the hood shopping center developed in the cleaner fuel and vehicle programs same timeframe as the new residential mandated under already-adopted state subdivision—it should be based on the and federal rules as these take effect and particulars of the area and not presumed older, dirtier motor vehicles wear out without justification. and are replaced by newer, cleaner The proposed ISR also ignores one vehicles. It argues that, because newer of the key criteria pollutants emitted by cars are cleaner, after ten years their indirect sources: reactive organic gases emissions should not matter. However, (ROG). This pollutant should be in- after ten years the project’s indirect cluded among those that must be miti- source emissions will continue at half gated at new developments. the level of ten years earlier, contribut- A well-crafted strong ISR would seek ing to the challenge of attainment and avoidance or mitigation of all indirect maintenance of national and state air emissions from new developments. It quality standards, which today by far would do so for the life of a project. remain unmet. Moreover, motor vehicle That life is far beyond a ten-year plan- fleet turnover assumptions may not be ning horizon, and should run for 30 realized if consumers and businesses years or more, roughly the time until the hold onto older, dirtier vehicles longer deadline for attainment plus the dura- than anticipated in the emissions model- tion of two ten-year maintenance plans ing—a problem that has contributed to beyond that, as required by the federal past failures of air quality control plans. Clean Air Act. The proposed San Joaquin Valley ISR Low-cost near-term emissions reduc- also requires mitigation of only half of the tion strategies are available to support first-year operational PM10 emissions full mitigation in the early years. These from a project for the first ten years of can be found through more effective the project, plus full mitigation of con- application of incentives for onsite miti- struction-related PM10 emissions. It thus gation, accelerated investment in diesel exempts developers from any mitigation retrofits throughout the Valley, employer requirement for half the first year of oper- based commuting incentive programs ational PM10 emissions and any increment and other initiatives. Low-cost emis- of PM10 emissions in years two through sions reduction and avoidance strategies ten that are higher than the first-year to fully offset emissions in 2015 and emissions, as well as all emissions of PM10 beyond are also available. They can be after year ten. The draft rule’s requirement obtained through both regional and

13 community-based transportation, land emissions related to raw material delivery use and emissions management and to construction sites or quarrying activi- planning; incentives for smart growth ties. URBEMIS now pulls emissions and infill affordable housing close to factors from the statewide EMFAC jobs; and incentive-based transportation emissions model but could be refined by operations, such as time-of-day tolls, toll drawing on air district-specific and site- truck lanes and parking management. specific mix of factors, where appropriate.

Use of best available analysis Tracking emissions variations tools and assumptions over time URBEMIS is an “Urban Emissions With new developments come periods Model” developed by the Air Resources of construction-related emissions. This Board to help local agencies estimate often involves highly polluting diesel the air quality impacts of land use equipment used for delivery of material, projects for CEQA analysis. It has been hauling of debris and various onsite complemented by further upgrades activities. Once a new residential devel- funded by the San Joaquin Valley Air opment is populated, there is typically Pollution Control District and has significant variability in the amount and undergone extensive review by various character of local motor vehicle traffic experts and stakeholders. It appears over time. As has been noted in travel to be the best available analysis tool behavior research in Montgomery to support the San Joaquin ISR. County, Maryland, and elsewhere, a “more How the tool is applied, however, elderly population in the more urban remains critical. Many assumptions areas of the county results in different must be made in developing inputs for trip generation than do young families the model that appropriately character- starting out in the newer suburbs. As ize a given project. When possible, it is areas age, their trip-making character- important to ensure the use of appropri- istics can be expected to change.”18 ate local trip rates or other factors for a The variation in trip generation project to capture the difference in trip rates by age of head of household for length distributions between, for exam- residents of single and multi-family ple, an urban infill project, an inner or housing units in Montgomery County outer suburban area project or an iso- was used to develop a trip generation lated rural development. Some of these model that better matched observed are readily available from metropolitan- data. In the typical lifecycle of new level or county-level travel models residential neighborhoods, peak trip maintained by several of the eight generation rates and population often metropolitan planning organizations occur 5–15 years after the completion in the San Joaquin Valley. A printout of the neighborhood, as more house- checklist of changes from URBEMIS holds are filled with driving-age teen- default values should be routinely agers and young adults. Trip generation made available as part of the standard rates and population often fall off in documentation of any application of later years as aging empty-nesters con- URBEMIS to support ISR evaluations. tinue to occupy the same structures There are several areas where the that once provided a home for more URBEMIS model can benefit from people during child-rearing years. Trip further refinement, such as including rates fall after people reach their 50s,

14 profile derived from the study of the lifecycle of new developments. A sound analysis will require estima- tion of emissions in the first, fifth, tenth, twentieth, and thirtieth years of the project and seek to mitigate these as much as possible onsite, then look to offsite mitigation and mitigation fees to offset the remaining emissions for each of these points in time.

Emissions avoidance and

LYNN BETTS/USDA NATURAL RESOURCES CONSERVATION SERVICE RESOURCES CONSERVATION NATURAL BETTS/USDA LYNN mitigation strategies: evaluating Emissions produced by indirect sources change as neighborhoods age. variation over time Similarly, emissions mitigation strategy and more sharply in even later years. accounting should account for the life- Eventually, a new generation of young cycle of equipment replacement, retrofit families will come to occupy neighbor- programs and other initiatives. The Carl hoods that were built up 25 to 40 years Moyer Program has been a very cost- before, starting the cycle over, usually effective and worthwhile emissions with a less pronounced lumpiness in reduction program. But a dirty diesel age distributions. agricultural irrigation pump dating from A well-crafted strong ISR would seek 1980 or 1985 that is subject to acceler- to mitigate both short- and long-term ated replacement in 2005 may have emissions from new development and worn out and been replaced with a new take into account this lifecycle by adjust- pump in 2015, one that would be even ing the long-term URBEMIS forecasts cleaner than today’s Tier II diesel-fueled for emissions mitigation planning. How- agricultural pump, in the absence of a ever, the June 2005 proposed ISR from Carl Moyer Program grant today. The the Air District fails to look at anything Moyer program provides grants for other than construction emissions and retrofitting, replacing or repowering

first-year project NOx emissions. It high-polluting diesel engines to reduce ignores the evidence that, for many emissions. In this case, the emissions projects, first-year emissions will be benefits of a Moyer grant today would lower than the emissions in the third, be quite positive between 2005 and

fifth, or later years, especially PM10 emis- 2015, but somewhat negative for years sions, which increase proportionately after 2015, when the Tier II pump with growth in vehicle miles traveled. would continue in use for many more This shortcoming of the District’s years instead of being replaced in 2015 proposed rule creates a framework that by a cleaner “Tier III” or “Tier IV” pump biases the rule towards overinvestment likely to become available by 2015. in short-term emissions reduction strat- The San Joaquin Air District con- egies, such as diesel agricultural pump siders such Moyer Program investments replacement. It neglects the need to in- to be permanent emissions reductions. vest in longer-term emissions avoidance However, as the above example illustrates, strategies that match the significant such a Moyer Program investment long-term indirect source emissions should not be viewed as a “permanent”

15 emissions reduction benefit. Rather, it is cies took action against wood burning, a time-dependent emissions reduction, but particulate pollution remained well good perhaps for seven years. in excess of federal standards. In the 1990s transportation and air quality officials replaced street sanding with Longer-term emissions chemical deicers and widespread road reduction strategies sweeping, causing particulate levels While some longer-term reduction to drop by half. Conformity spurred strategies may sometimes appear to be officials to build into regional plans costly at first, they can have the largest enough maintenance plan measures to cumulative emissions avoidance bene- meet long-term health standards fits, making them very cost effective in through 2015 and provided an incentive the long run. For example, investment for developing light rail as a long-term in a bus rapid transit line in Fresno— pollution control measure, as well as bus priority lanes, dedicated bus stations, a commitment by metro area govern- stops facilitating rapid boarding and ments to limit growth to a 730-square alighting, high service frequencies mile area, with transportation alterna- throughout the day—could create the tives to support this goal. Travel momentum for substantial infill transit- demand management strategies in oriented development along the route, the Denver long-range plan promote reducing traffic growth and car depen- ridesharing and telework and are dence in this corridor. Investment in used as a safety margin in meeting incentive programs to encourage urban the 2025 emissions budget. By 2001, redevelopment in the core of communi- Denver was one of only a few large ties like Fresno and Modesto, close to metro areas that had attained every jobs and public transportation, in walk- national air quality standard. able neighborhoods, could cut regional But investments in expanding travel vehicle miles of travel and related air options need not be urban or metro- pollution.19 Just as cities like Portland, politan in focus to be effective in cutting Oregon; Denver; Salt Lake City; Sacra- emissions while supporting job and mento; Charlotte; and Chattanooga economic development. The San have reduced long-term traffic growth Joaquin Valley’s Kings County Rural through rapid transit investment. Transit Agency in the past four years In Charlotte in the mid-1990s, in has built a 150-van vanpool fleet response to excessive air pollution emis- operating in five counties and largely sions from traffic under a 20-year trans- serving 800 farm and prison workers. portation plan, planners and officials This takes traffic off the highway and adopted a revised plan emphasizing better boosts access to jobs for low-income transit and smarter growth. This enabled workers while cutting pollution. them to trim forecast traffic growth and Unfortunately, the air district’s plans pollution by almost a quarter. They won for investing the mitigation funds that voter approval for the plan for a sales tax are generated appear to be limited to to pay for a regional bus rapid transit, replacing or retrofitting engines and light rail and commuter rail system, and reducing dust from dirt roads in the began revising local land use plans to region. While each of these mitigation support this new vision. measures provides quick fixes to NOx Denver was faced with terrible winter and dust problems, they don’t provide particulate pollution in the 1980s. Agen- the kind of long-term solutions needed.

16 Given this, it would be appropriate for the consider a new vision of how trans- air district to put greater consideration portation investment could support into the best uses of the mitigation funds. more effective growth patterns with This consideration should include oppor- less traffic growth and related air tunities for open discussions with the pub- pollution. Some groundwork has lic and local governments and agencies. already been undertaken with the Getting Smart Growth Response Model and other initiatives. But Identifying cost-effective and business, civic, and political leadership available regional emissions will be needed to establish goals and a avoidance strategies framework for action, avoiding more The Sacramento region, through its paper planning studies. council of governments, has done much to develop effective frameworks to evaluate transportation and land use scenarios A portfolio-based indirect that can produce longer-term perma- source rule nent travel reductions embedded in land Just as sound investment portfolio use, infrastructure and reform-of-pricing planning seeks to include a mix of structures. Similar opportunities can be short- and longer-term investment created in the San Joaquin Valley, through strategies that are hedged against risk the ISR process, to help identify cost- by including a diverse array of invest- effective long-term emissions avoidance ment types, so too a sound emissions strategies. This is especially true if the mitigation portfolio will include a mix ISR recognizes the need to address not of strategies that address different just first-year emissions, but thirty-year aspects of the pollution challenges emissions from new developments in confronting the Valley over time. An order to protect public health and to ISR should focus on ensuring a match trim the hidden long-term costs of between short and longer-term forecast economic development. indirect source emissions and related Timely regional travel model sensitivity mitigation strategies. analysis should be undertaken to identify The rule proposed by the Air District locations where job or housing growth in June 2005 fails to look beyond year in potential transit-oriented centers might one and fails to consider longer-term reduce rather than increase regional indirect source emissions problems asso- vehicle miles of travel. This could pro- ciated with new development, focusing vide critical evidence for adjustment to only on generating fees for short-term URBEMIS analyses by developers in emissions reduction programs and the relation to proposed developments at costs to the Air District for administer- these locations. This might help identify ing these. A model rule can and should areas that would be subject to much be crafted to address these missing easier emissions mitigation requirements, elements in the proposal. and opportunities for emissions fees to be invested as additional development incentives for long-term pollution Ensuring transparency and avoidance through smart growth. independent oversight for The upcoming debate in the Fresno accounting area over Measure C transportation The proposed June 2005 ISR fails to funding provides an opportunity to require that the information used to

17 calculate emissions or mitigation or if the ISR is to have credibility with fees be made public in a timely manner the public. for independent oversight of the accounting. Greater transparency is crucial and should be required as part Ensuring accounting for benefits of the ISR. and avoided costs The public has already witnessed The proposed June 2005 ISR does not serious shortcomings in the process for yet include a socioeconomic impact releasing information to the public analysis, but this should take into full about air pollution mitigation contracts account the long-term hidden costs to with Tejon Ranch and Castle and the region’s residents and businesses of Cooke projects, which came before the rising levels of car dependence, unequal Air District for approval in April 2005. and often poor access on the part of low In those contracts, the Air District income residents to jobs and public made what appear to be questionable facilities, and the health and other im- assumptions about emissions reductions pacts of unhealthful levels of air pollu- and responsibility for indirect source tion. According to the Federal Highway emissions. But even after an open Administration, adverse health effects of records request, the Air District has motor vehicle pollution cost Americans failed to provide sufficient information over $40 billion/year.20 And this figure to the public to show how it arrived at does not even include the adverse im- its estimates of impact fees. This situa- pacts of mobile source air toxics, which tion must be remedied and not repeated recent research suggests are considerable.21

18 Conclusion

The San Joaquin ISR process is an transportation choices, save money, extraordinary opportunity, but the create healthier children, families and proposed rule needs to be strength- communities, and boost the economy. ened to ensure that it fosters sensible But this will happen only if civic and market incentives, planning and business leaders unite behind these accountability. A well-crafted strong healthy community goals and support rule will support robust growth in the adoption of an ISR to ensure that future San Joaquin Valley in ways that give growth reinforces, rather than under- people more and better housing and mines, these goals.

19 APPENDIX A Traffic reduction success stories22

TravelSmart program: communities and the use of smaller Kamloops, British Columbia23 buses that feed into the main system. The TravelSmart program in Kamloops, • Promoting bicycle use: The Kamloops British Columbia, promotes changes in Bicycle Plan identifies $6 million travel behavior and encourages sustain- worth of additional cycle routes and able community development in order initiatives for businesses to provide to minimize demands on the municipal “end-of-trip” facilities to cyclists, such transportation system. Kamloops’ pop- as showers and bike racks. ulation, which is expected to increase from 85,000 to 120,000 by 2020, is • Promotional programs: Transporta- placing increased demands on the city’s tion alternatives, such as carpooling, transportation system and causing biking and walking, are promoted growing concern about quality of life through workshops and seminars in among residents. Launched in January workplaces; the “Safe Routes to 1997, TravelSmart includes these on- School” program in schools; “Go going initiatives: Green” billboards on commuter streets; and door-to-door neighborhood edu- • Land use integration: Recognizing cation by city staff. The plan recognizes the strong links between transporta- the need for an ongoing awareness tion and land use, the city’s official campaign and community involvement plan was revised to minimize the to sustain TravelSmart. demand for car travel by influencing growth patterns. The plan now favors a Total project planning costs $300,000, compact form of development, situ- of which $245,000 was funded by the city ating accommodation close to employ- and $55,000 by the province. The full ment and community services, and program is funded through city’s general increasing density of the central area. revenue, development cost charges, the B.C. Transportation Financing Authority, • Less expensive road structure specific developers and BC Transit. alternatives: To avoid expensive TravelSmart will be updated every five improvements to road networks, the years as one component of “Kamplan,” city has slowed or halted development the city’s growth management strategy. in some areas and identified under- After three years of operation, the utilized arterial corridors for access to program has improved air quality and the downtown core. Rather than build- reduced planned road expenditures by ing bypasses over the busy highway 75%. Economic and environmental that runs through town, the city en- benefits: courages residents to use alternatives to the highway. • Reducing anticipated road expendi- • Improved public transit: A compre- tures from $120 million to $14 million. hensive travel plan was developed to im- • Reducing annual per capita energy con- prove the level of service and provide sumption from 128 to 125 gigajoules. alternatives to the single occupant vehicle. Some improvements include in- • Reducing annual per capita carbon di- creased frequency of service to outlying oxide emissions from 7,200 to 7,000 kg.

20 TABLE 1 Commute Partnership Products, King Co. Metro Product Description

Alternative Work Schedules Compressed or flexible work schedules allowing employees to work longer hours in fewer days. Biking and Walking Alternative commute mode that can be subsidized. Business Use of Vans A program making Metro commuter vans available for use by employees (at that worksite) during the business day. Carsharing A convenient and economical alternative to owning a personal vehicle. Commuter Bonus A non-taxable voucher program that encourages employees to take the bus, a vanpool or a ferry. Commuter Bonus Plus A voucher program to encourage employees to commute by carpool, or walking and biking. Carpools Alternative commute mode that can be subsidized. Custom Bus A special service for areas with limited bus service. Datamatch A computerized ridematching service to encourage employees to “share the ride.” Flex Pass A comprehensive discount pass program that can be customized to include commute incentives. Home Free Guarantee A program that ensures an emergency ride home for employees using alternative commute modes. Parking Cash-out A program for offering employees a choice between a subsidized parking space, and cash. Pass Subsidy A variety of options for businesses interested in pur- chasing employee transit passes. Preferential Parking Program that reserves worksite parking spaces for those employees commuting by carpool and vanpool. Ridematch A computerized ridematching database and mapping service. Rideshare Plus A customized service approach for carpool and vanpool formation that employers can contract for. Tax Laws Some helpful guidelines about commute-related tax issues that provide advantages for both employer and employee. Vanpools A program that supplies vans to groups of employees to share. How to get a Metro Vanpool on the Road

King County METRO Commute each component can be downloaded Partnership Program24 from their web site. METRO also pro- The King County (Seattle area) METRO vides general support and resources to Transit Agency has developed a com- employers to develop commute trip prehensive commute trip reduction reduction programs and integrate these program. The table below lists program efforts with parking, land use and transit components. A detailed description of management activities.

21 TABLE 2 Alameda County Commute Incentive Program Alameda Albany Oakland Pleasanton

Incentive offered $1.50/day $2.50/day $40/mo transit pass $2.00/day Average combined fuel savings $268/year $381/year $407/year $282/year and financial benefit Eligible employees 573 130 400 380 Participants before 12 (3%) 7 (5%) 11 (3%) 147 (40%) Participants after 108 (19%) 30 (23%) 93 (23%) 130 (34%)

Alameda County Congestion a pre-tax commuter program was the Management Program25 most frequent enhancement by far, with The Alameda County (East San Fran- 62% of the respondents asking for it. cisco Bay area, including suburban and We are pleased to offer such a program rural areas) Congestion Management that will make our people’s commute to Program enlisted four employers to work a bit easier.” provide financial incentives to encourage reduced driving. The table below summarizes the results at the CH2M Hill four worksites. The program man- Upon moving into new offices in the agers conclude that financial incentives Seattle suburb of Bellevue, Washington, alone typically reduce automobile the 430 employees of the engineering commute trips by 16–20%, and sig- firm of CH2M Hill were offered $40 nificantly more if combined with other per month if they walked, bicycled, TDM strategies. carpooled or took transit to work, or free parking if they drove alone. The firm’s drive-alone rate declined from 89% to Ernst & Young26 54%, and stayed there, while the per- Since 2001, the accounting and man- centage biking or walking increased agement firm Ernst & Young has from 1% to 17% (see Table 3). With offered pre-tax commuter transporta- parking demand down by 39%, the tion and parking benefits to its employ- firm’s problem of “too many parkers for ees in partnership with WageWorks. too few spaces” disappeared. This ap- This is projected to save employees proach reduced costs for the company 40% of their commuting and work- and reduced traffic and pollution while related parking costs and reduce the increasing tax revenue. firm’s payroll expenses. “Adding commuter benefits to our TABLE 3 innovative benefits offerings is just one Parking cash-out program results more reflection of Ernst & Young’s Before After commitment to make the firm a great place to work,” says vice chairman of Drive alone 89% 54% human resources, James L. Freer. Carpool 9% 12% Bus 1% 17% “When we surveyed a group of employ- Bike, walk 1% 17% ees regarding what benefits they value,

22 Exel: how the logistics campus GTA), there is potential through con- can reduce unnecessary trips solidation to reduce truck movements by and enable the efficient flow of up to 30%. It is important to note that goods to market27 there is additional room to improve Exel Worldwide is an international pro- capacity efficiency because an average vider of logistics services, which has pio- “full truck load” is 40,000 lbs and 2,300 neered the “campus” concept—a collection cube, while the actual capacity is 62,500 of multiple manufacturers focused on lbs and 3,400 cube. consumer products with similar dis- tribution channels. The collection of companies in a single location achieves Campus Transport Management28 critical mass in several key areas. It Stanford University in Palo Alto, allows for the sharing of resources, California plans to expand capacity by freight consolidation and flexibility. A 25%—adding more than 2.3 million campus begins with establishing indi- square feet of research and teaching vidual accounts within a narrow geo- buildings, public facilities and hous- graphic area and grows organically ing—without increasing peak period through new business acquisitions. vehicle traffic. By 2000, 1.7 million There are clear practical benefits and square feet of new buildings had been economic efficiencies to the campus: developed while automobile commute having facilities and resources close to trips were reduced by 500 per day. To customers; being able to share labor accomplish this, the campus transporta- resources among clients and operations; tion management plan includes: improved transit time and reduced order • a 1.5 mile transit mall; cycle time; and reduced inventory velocity and lower freight costs through volume • free transit system with timed transfers leverage. In addition, there are also im- to regional rail; portant environmental efficiencies made • a bicycle network; possible through the campus model. For instance, in the past, if Loblaws • staff parking “cash-out”; requested an order of two truckloads of • a ridesharing program; soup and one truckload of cereal, three trucks would go out. Now, only two trucks • other transportation demand go out because the cereal can sit on top management elements. of the soup. Trips are reduced, and $600 can be saved by providing one less truck. By using this approach the campus The trend towards supply chain integra- was able to add $500 million in new tion allows the linking of inbound goods projects with minimal planning or envi- with outbound goods and materials. The ronmental review required for individual result, made possible by more sophisti- projects. The campus also avoided sig- cated software and breakthroughs in nificant parking and roadway costs. tracking media, allows logistics special- Planners calculate that the University ists to mix inbound materials with out- saves nearly $2,000 annually for every bound products, so that trucks have a commuter shifted out of a car and into higher load factor. In the area of Canadian another mode. This also reduced regional food sales, which amounted to $66.2 agency traffic planning costs. billion in 1998, totaling 662,000 truck- Public benefits included decreased loads (two thirds of which were in the congestion and improved safety on

23 surrounding roadways and the regional tion fell and bus companies collected traffic system, reduced air, noise and water enough extra fares to recoup the cost pollution, and improved local transit within three years. options. All of Stanford’s transportation The south Perth trial cost AUS$1.3 services are available to students, em- million—including new bus stops in the ployees and the general public. suburbs, printed material and surveys— and took three months. That compares with the UK government’s ten-year Inside track: How to think people transport plan, published last summer, out of their vehicles29 which promised that in return for 180 When 8,000 Perth households were billion pounds of private and public helped to analyze their journeys, car use money, traffic would rise by 17%. (Ad- fell by 14% with a shift to public trans- mittedly, that is 5% less than what has port and cycling. It sounds like a trans- been forecast without the plan.) At a port dream: a cheap and effective scheme seminar at the Institute for Public Policy that could cut traffic by 10% or more Research in London, Werner Brog, within months. But in Australia it is Socialdata’s founder and managing reality. And the idea is now on trial in director, explained the theory behind 15 European countries. the individualized marketing project. The concept, called “individualized Socialdata found that only 20% marketing,” is simple. Households are of journeys in Perth were by “green contacted and offered advice about the modes”-public transport, walking and journeys they make. If they are inter- cycling. However, in potentially 60% of ested, they can get information and per- journeys, people either did not need cars sonalized timetables by mail, telephone or had an adequate alternative. hotline, or a home visit from a con- Socialdata asked why people did not sultant who analyses the trips they make leave their cars behind more often and and suggests alternatives to the car. found a big gap between perceptions Socialdata, a German-based con- and the reality of public transport, walk- sultancy, claims to have developed the ing and cycling. Typically, people thought idea and spent ten years looking for a their journey would take twice as long as test case before the government of it did and would cost a third more than Western Australia agreed to try it in the actual fare. Half of motorists with a Perth. An initial trial in 1997 of more viable alternative did not know about than 800 households in South Perth the individualized marketing service. showed a 10% drop in car journeys and “There’s an alternative there,” said vehicle miles, with a significant shift to Mr. Brog, pointing outside to buses, cycle public transport and cycling. Surveys a lanes and subway stations, “but not there” year later, and again 18 months after he said, jabbing at his head. “Transport that, showed those gains were sustained. planners want to fix that” he continued, Last year, Western Australia’s Depart- pointing out of the window again “but ment for Planning and Infrastructure we’d say it’s much easier to fix the head.” extended the project to 8,000 house- The success of the Perth project holds in South Perth, with even better persuaded the International Public results. Car journeys and mileage fell Transport Union-UITP—to hold a 14% and walking, cycling and use of series of trials in Europe, although public transport rose again. Use of local only on public transport. 45 results shops and services increased, air pollu- have come in and only one, a project

24 approach is “not Stalinist,” says Mr. Brog. People are not stopped from making journeys; they are never told to stop using their cars, and the project stresses how even tiny changes—say, one journey a week—can make a big difference. “As soon as people hear what I do at a party they start saying ‘Do you know how far I have to travel to work? Do you know I have to make interchange four times?’ and so on,” says Mr. Brog. “I say, if that’s the case, use your car. But let’s look at where else you can use public transport.”

MICHAEL REPOGLE More subtly, another barrier is the Smart uses of mitigation fees can help reduce traffic congestion. long-standing assumption by transport engineers and planners that putting on in Oporto in northern Portugal, failed more services and building new infra- to cut traffic. Some are planning bigger structure is the solution to all prob- schemes—including one in Germany lems—an approach that has often been covering cycling and walking as well as reinforced by the political attraction of public transport. opening new railways and roads. It sounds almost too good to be true, Individualized marketing can be which raises the question of why more complementary to investing in infra- towns, cities and regions are not pursuing structure, says Mr. Brog, and, he be- the idea. As it stands, Western Australia lieves, it is more cost effective. “We can plans to extend the scheme to all 600,000 better them hands down every time,” residents of Perth, while elsewhere in he insists. Linked to this is the reverse the country, Brisbane is running a trial. problem that in some places—large Transport operators in Europe are talk- cities such as London, for example—the ing to Socialdata about city-wide initia- capacity and quality of public transport tives, says Mr. Brog. Socialdata is also are inadequate to cope with a major exploring how individualized marketing increase in use. There is a correlation can be used for energy, water, waste dis- between the quality of transport and the posal and other applications. size of the modal shift but most areas do However, before the transport scheme have the capacity—and the extra fares can spread, deep-rooted cultural and can help to fund improvements. practical barriers will need to be over- Then there is the natural distrust of come in many countries. Perhaps the experimental results. In Perth they have biggest perceived threat, especially tried to overcome this by repeating the among politicians being asked to fund surveys to show that improvements are such projects, is a backlash from motor- sustained. Further successful projects ists who may see the scheme as “anti-car.” would strengthen the case for indi- But in Australia, the Department for vidualized marketing. Doubters should Planning and Infrastructure collected know that Perth—designed for cars and seven files of positive feedback and not a massive 100 km by 80 km in size—was one letter of complaint, insists Bruce a highly testing trial area, says Mr. Brog. James, the department’s executive director “The saying is if it works in Perth it metropolitan. One reason is that the works everywhere in the world,” he says.

25 The Chattanooga story 30 opened in 1992 and which has since Over the last 20 years, Chattanooga, become a trademark for a city that, in Tennessee has turned its once-depressed ten years, transformed itself, becoming downtown into a major commercial and a prime example of sustainable growth tourist center attracting millions of visitors and development. a year. This evolved from three decades A second development that has come of community planning that emphasize to define Chattanooga was also intro- citizen involvement, local environmental duced in 1992, when the Chattanooga quality and strategic investments. Area Regional Transportation Authority Concerned about the impacts that initiated the Electric Shuttle. With free pollution was causing on local economy, five minute service between the Tennessee the Chattanooga Chamber of Com- Aquarium and the Chattanooga Choo merce created an Air Pollution Control Choo hotel, the Electric Shuttle pro- Board in 1967. The board included a vides the transportation link that had diverse group of business leaders and been identified as one of the top goals. citizens. In 1972, it established a dead- As a result of such efforts, Chattanooga line requiring all existing major sources is now deemed one of America’s most of pollution to be in compliance with livable cities. emissions standards, which was met at a cost of $40 million. National and international attention was focused on Portland’s positive experiences a city that in three years had changed in curbing sprawl31 from the most polluted cities in the The Portland metropolitan area is United States into one of the cleanest. thriving with 1.3 million people in a This inspired a new community chal- compact region, about 35 miles across lenge, revitalizing a dying city core. at its widest point. The region has In the early 80s, city officials set the grown by more than 24% over the last goal for Chattanooga of becoming a 20 years but only by 13% in land area. leader in developing solutions to urban Employment in downtown Portland has problems. In 1982, City and county gov- nearly doubled from 63,000 (1970) to ernments appointed a task force to study 108,000 (1995). In addition, the average and determine the best way to develop lot size for residential development has the 22-mile Tennessee River corridor been reduced by 50% over the last 20 around Chattanooga. Thousands of citi- years. This is due to diversification of zens attended hundreds of meetings fo- the housing market with land use initia- cused on the riverfront. The Task Force tives to encourage a compact commu- drafted the Tennessee Riverfront Master nity. The region has adopted a 2040 Plan, which covered 20 years and involved Growth Concept that promotes mini- $750 million in commercial, residential mal expansion of the existing Urban and recreational development. Growth Boundary (UGB), increased This led to creation of the RiverCity densities in centers and along transit Corporation, a private nonprofit organi- corridors, multi-modal accessibility, and zation with a mandate to implement protection of neighborhoods, parks and the Riverfront Master Plan and 40 green spaces. community development goals. Among There are five historical events other achievements, it developed the that help frame the discussion about Tennessee Aquarium, the world’s the Portland region’s experience in largest freshwater aquarium, which curbing sprawl:

26 • 25 years ago, the State of Oregon access to the downtown (including enacted legislation requiring universal parking caps, a bus mall and light rail). land use planning and UGBs, as well • The state also adopted a Transporta- as state goals such as public involve- tion Planning Rule to increase accessi- ment, creating compact communities bility, require pedestrian and bike using UGBs, and preserving farmland, facilities, and require reductions in forest land and water resources. vehicle miles traveled and parking • 25 years ago, the City of Portland first spaces per capita. adopted its Downtown Plan. This • In 1992 the Metro region approved a provided for pedestrian and transit Metro charter with a primary priority amenities, open spaces, public art, being the coordination of transporta- housing and active streets. The plan tion and land use planning for the was instrumental in ensuring that region. A key responsibility for Metro downtown remained vibrant and is the administration of the UGB. continued to redevelop and intensify with both jobs and housing. Portland works because of its collab- • Metro adopted the first regional UGB orative planning approach, supportive 20 years ago. Since then, there has been state laws and engaged people who continued community leadership in pro- care about the environment and the moting the downtown and multi-modal community.

27 APPENDIX B Four key benefits of an ISR

An ISR’s main purpose is to clean up clean up more dirty air. In addition, the air by mitigating the pollution gen- cleaner air means less money spent on erated by cars, trucks and other indirect health care. sources attached to new developments. Because this rule makes developers and consumers think a little harder about 3. Creates healthier children, how to reduce the air pollution associ- families and communities ated with growth, it also encourages An ISR helps create an overall better creative action and innovation. Ulti- quality of life for people by reducing air mately, the rule carries a range of bene- pollution and, by extension, the number fits. Many of these benefits can be of school days and work days children summarized in four main categories. and adults miss because of lung and heart ailments related to air pollution. A good ISR can help people avoid 1. Gives people more and better traffic congestion by offering alternative choices transportation and encouraging housing The rule can encourage a broader choice closer to jobs. This means more leisure of housing by rewarding developers who time and family time, less time stalled look for ways to put good and affordable in traffic, and generally safer and less housing closer to work sites and reduce stressful travel. And by providing an the need for new infrastructure develop- incentive for building businesses closer ment such as new roads and sewers on to where people live, and houses closer undeveloped land. to where they work, an ISR helps relieve The rule has the potential to spur pressure for building on agricultural new ways of thinking about public lands and green fields. transportation and new funds for transportation planning and development. This can give people more options for 4. Boosts the economy getting to work and school, for shop- When people are able to get to work ping, and to see friends and family. without a stressful commute, they are more productive. When they and their family members are not burdened by 2. Saves money the health impacts of dirty air, they A rule that offers more transportation don’t have to take as much time off opportunities allows people to choose to attend to medical appointments and less expensive and more efficient ways to care for sick family members. And to travel. A rule that encourages build- when a community has more housing ing closer to jobs and existing infra- choices, more transportation choices structure saves public dollars that and clean air—or at least evidence that otherwise go into maintaining roads. it is on the path to cleaner air—it be- All of this adds up to less pollution comes more attractive to new businesses from new developments, which means and new tourism, all of which helps that citizens and public agencies can create more and better jobs and a spend less money figuring out ways to stronger local economy.

28 Notes

1 Bedsworth, Louise Wells. Clearing the Air in Pollution in California. Union of Concerned the San Joaquin Valley: Developing an Action Scientists. Cambridge, MA. 2004. Plan for Regulators, Legislators, and the Public. 11 San Joaquin Valley Unified Air Pollution Union of Concerned Scientists, Cambridge, Control District, 2003 PM10 Plan, Chapter MA. 2004. Available online at: www.ucsusa 4, page 52, June 30, 2005, http://www .org or at www.kirschfoundation.org. .valleyair.org/Workshops/public_workshops 2 Ibid. And State of California, Department _idx.htm (accessed June 17, 2005). of Finance. Population Projections by Race/ 12 San Joaquin Valley Unified Air Pollution Ethnicity, Gender and Age for California and Control District, Extreme Ozone Its Counties 2000-2050. Sacramento, CA. Attain–ment Plan, 2004, Chapter 4, May 2004. page 12, http://www.valleyair.org/Air 3 Bedsworth, Louise Wells. Clearing the Air in _Quality_Plans/AQ_plans_Ozone_Final the San Joaquin Valley: Developing an Action .htm (accessed June 18, 2005). Plan for Regulators, Legislators, and the Public. 13 San Joaquin Valley Unified Air Pollution Union of Concerned Scientists, Cambridge, Control District, Extreme Ozone Attain- MA. 2004. Available online at: www.ucsusa ment Plan, 2004, Appendix G, page 1, .org or at www.kirschfoundation.org. http://www.valleyair.org/Air_Quality_Plans/ 4 San Joaquin Valley Unified Air Pollution AQ_plans_Ozone_Final.htm (accessed Control District, Draft Staff Report: Rules June 18, 2005). 3180 and 9510, June 30, 2005, http://www 14 San Joaquin Valley Unified Air Pollution .valleyair.org/Workshops/public_workshops Control District, Extreme Ozone Attain- _idx.htm (accessed June 17, 2005). ment Plan, 2004, page 8-18, http://www 5 San Joaquin Valley Unified Air Pollution .valleyair.org/Air_Quality_Plans/AQ_plans Control District, 2003 PM10 Plan, _Ozone_Final.htm (accessed June 18, 2005). Appendix B, June 30, 2005, http://www 15 See Appendix A for some examples of .valleyair.org/Workshops/public_workshops successful programs that help cut traffic _idx.htm (accessed June 17, 2005). through such initiatives. 6 Ibid. And State of California, Department 16 There are many successful examples of such of Finance. Population Projections by Race/ trip reduction agreements under various Ethnicity, Gender and Age for California and growth management programs. For example, Its Counties 2000-2050. Sacramento, CA. traffic mitigation requirements imposed May 2004. under Montgomery County, Maryland’s 7 San Joaquin Valley Unified Air Pollution Adequate Public Facilities Ordinance in the Control District, Extreme Ozone Attainment 1980s and 1990s led many developers and Plan, 2004, Appendix H, page 15, http:// employers to create and support Transporta- www.valleyair.org/Air_Quality_Plans/ tion Management Associations, public- AQ_plans_Ozone_Final.htm (accessed private partnerships that facilitate employee June 18, 2005). commuter trip reduction and invest in local 8 San Joaquin Valley Unified Air Pollution shuttle services, manage parking supply and Control District, Draft Staff Report: Rules price, and undertake other initiatives to 3180 and 9510, June 30, 2005, Appendix B, reduce traffic problems. page 6, http://www.valleyair.org/ 17 San Joaquin valley Unified Air Pollution Workshops/public_workshops_idx.htm Control District, Draft Staff Report: Rules (accessed June 17, 2005). 3180 and 9510, June 30, 2005, page 9, 9 San Joaquin valley Unified Air Pollution http://www.valleyair.org/Workshops/public_ Control District, Draft Staff Report: Rules workshops_idx.htm (accessed June 17, 2005). 3180 and 9510, June 30, 2005, page 5, 18 Ajay Kumar and David Levinson, “Specify- http://www.valleyair.org/Workshops/public_ ing, Estimating, and Validating a New Trip workshops_idx.htm (accessed June 17, 2005). Generation Model: Case Study in Mont- 10 Anair, Don and Patricia Monahan. Sick of gomery County, Maryland,” Transportation Soot: Reducing the Health Impacts of Diesel Research Record 1413, (1993) page 111.

29 19 An example of this kind of initiative is the 23 www.city.kamloops.bc.ca/transportation/ Atlantic Steel Transportation Control plans/travelsmart.html. Measure in Atlanta, which was approved by 24 http://transit.metrokc.gov. EPA in 2000, as the region was facing a 25 www.accma.ca.gov. formidable clean air conformity challenge. 26 www.wageworks.com. A transportation management district was 27 formed to ensure that emissions and traffic Moving the Economy reduction goals would be met by this 135 (www.city.toronto.on.ca/mte). A more acre mixed use urban brownfield redevelop- detailed version of this case study is featured ment project near downtown Atlanta, which in Moving Goods in the New Economy: A was shown likely to reduce regional vehicle Primer For Urban Decision Makers, a joint miles of travel despite its accommodation of publication of Moving the Economy and the thousands of new dwelling units and jobs. Canadian Urban Institute, made possible by support from Transport Canada and 20 U.S. Department of Transportation Federal HRDC. Highway Administration. Addendum to the 28 1997 Federal Highway Cost Allocation Stanford University (www.stanford.edu). Study Final Report. http://www.fhwa.dot 29 www.travelsmart.transport.wa.gov.au; .gov/policy/hcas/addendum.htm (accessed www.socialdata.de, Juliette Jowit, Financial 3/14/05). Times; Sep 11, 2001 (http://globalarchive.ft 21 Michael Replogle and John Balbus, M.D., .com/globalarchive/article.html?id=0109110 M.P.H.,“Considering Cancer Risk in Trans- 01424&query=Transport#docAnchor01091 portation Decision-Making,” Environmental 1001424). Manager, June 2005, Vol. 55, pages 10-13. 30 www.chattanooga.gov. 22 These examples are taken from the TDM 31 Elaine Wilkerson, Director, Portland Metro Encyclopedia, http://www.vtpi.org/tdm/ Growth Management Services Department, tdm71.htm. www.trans.ci.portland.or.us

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