from Campaign for Sustainable Transportation by Rick Longinotti

Co-chair Rick@sustainabletransportationSC.org

Santa Cruz County Regional Transportation Commission

Re. Item 22: Adoption of the Regional Transportation Improvement Program

December 2, 2019

Dear Commissioners,

There are two projects in the Regional Transportation Improvement Program (RTIP) that fail to meet the state’s goals for reducing greenhouse gas emissions. The first project proposes to use State Transportation Improvement Program funding, but is not in alignment with the STIP Guidelines (updated Aug 14, 2019). Failure to align the RTIP with the STIP Guidelines is considered grounds for rejection of the RTIP by the California Transportation Commission.  The two projects are:

  1. auxiliary lanes on Highway 1 between Soquel Ave. and State Park Dr.
  2. expansion of the intersection of Highway 1 and Highway 9 (River St.)

A.   Hwy 1 Auxiliary Lanes fails to meet STIP Guidelines

1)     The Auxiliary Lanes Project does not take climate change into account.

The STIP Guidelines state,

Governor Brown issued Executive Order B-30-15 on April 29, 2015, related to climate change and ordering that a new interim statewide greenhouse gas emission reduction target to reduce greenhouse gas emissions to 40 percent below 1990 levels by 2030… Executive Order B-30-15 must be considered by the Department and Regional Agencies when proposing new programming for the 2020 STIP…

According to the Caltrans EIR on Highway 1 projects, there would be a 25% increase in greenhouse gases resulting from the TSM Alternative relative to the No Build Alternative at year 2035.[1] The TSM Alternative includes auxiliary lanes and ramp metering on most segments of Hwy 1 from Soquel Ave to Freedom Blvd.

2)    The analysis of full life-cycle costs is lacking

The STIP Guidelines further note:

For projects with total cost of $50 million or greater, or STIP programming for right-of-way and/or construction of $15 million or more, a project specific benefit evaluation will be performed to estimate its benefit to the regional system from changes to the built environment. Consistent with Executive Order B-30-15, the project specific benefit evaluation must include a full life-cycle cost evaluation and take climate change impacts into account.

The EIR that analyzed the TSM Alternative, of which the Auxiliary Lane Project is a part, did not analyze full life-cycle costs.

3)  The Auxiliary Lanes Project does not perform well on criteria of safety or congestion relief.

The STIP Guidelines section 19 states that the California Transportation Commission will evaluate each RTIP based on performance. Criteria for evaluating performance include:

  • congestion relief
  • fatalities and serious injuries
  • vehicle miles traveled per capita
  • commute mode share

 According to Caltran’s EIR, the TSM Alternative, of which the Auxiliary Lanes Project are a part, performs poorly on these criteria:

  • Building the TSM Alternative “would result in a very slight improvement in traffic congestion when compared to the No Build Alternative”.[2] 
  • The EIR predicts “severe breakdown of State Route 1 by year 2035” following completion of the TSM Alternative.[3]
  • “The Tier I Corridor TSM Alternative would not achieve sufficient congestion relief to attract any substantial number of vehicles that had diverted to the local street system back to the freeway.”[4] 
  • “The total accident rates overall and by segment in 2035 under the Tier I  Corridor TSM Alternative would be the same as the accident rates for the No Build Alternative.”[5]
  • The EIR does not evaluate vehicle miles traveled per capita. However it reports that total vehicle miles traveled would increase by 44% (morning peak hour) and 24% (afternoon peak hour) relative to the No Build Alternative in year 2035.[6]
  • The EIR does not evaluate commute mode share.

4)    Bus-On-Shoulder without auxiliary lanes should be analyzed for cost-effectiveness

The STIP Guidelines section 19 states that the California Transportation Commission will evaluate each RTIP based on cost effectiveness.

The EIR on Highway 1 projects, certified in January, 2019, failed to analyze bus-on-shoulder as an alternative to auxiliary lanes and the TSM Alternative. The EIR should have studied this alternative because the state legislature expressed early support by when it passed AB 946 in 2013, authorizing the Monterey-Salinas Transit District and the Santa Cruz Metropolitan Transit District to conduct a transit bus-only program using the shoulders of Highway 1. MST and METRO collaborated on a Bus-on-Shoulder Feasibility Study published in June 2018.  

When the Highway 1 Draft EIR was published in November, 2015, our organization submitted a comment on the Draft asking that the EIR analyze bus-on-shoulder and other transit strategies as an alternative to the Project.

The Regional Transportation Commission has indicated support for bus-on-shoulder as an addition to the Auxiliary Lane Project. However, Auxiliary Lanes are not needed in order for a bus-only lane to be constructed on the shoulder of Highway 1. The Bus on Shoulder Feasibility Study (2018) indicated that options exist for bus-only lanes in the median of Hwy 1 as well as the right shoulder. The Study indicated that for $12 million a bus-on-shoulder lane could be implemented in the Southbound direction on 4.2 miles of the 7.5 mile distance from Santa Cruz to Freedom Blvd.  In contrast, the 4 mile Auxiliary Lane Project would cost over $100 million, not counting bus-on-shoulder infrastructure added to the Project. Monterey County bus-on-shoulder project is listed in the Association of Monterey Bay Area Governments (AMBAG) Metropolitan Transportation Plan (MTP). However, bus-on-shoulder in Santa Cruz County is not listed in the MTP because funding for this project is not constrained (identified).

The failure to analyze and compare the cost effectiveness of bus-on-shoulder with and without auxiliary lanes does not meet the STIP mandate to analyze cost effectiveness.

B.     Expansion of the intersection of Highway 1 and Highway 9 (River St.)

  • undermines achievement of state climate change goals by increasing vehicle miles traveled and greenhouse gases
  • expends funds that could be spent on achieving safer streets for bicyclists and pedestrians
  • is inconsistent with the City’s General Plan

A project that increases auto capacity tends to result in an increase in vehicle miles traveled. Caltrans’ Mitigated Negative Declaration (2015) on this project states:

“Annual 2030 carbon dioxide emissions equivalents are expected to increase with implementation of the project relative to the 2030 no-project condition.” [Table 2-15 indicates a 10% increase]

The cost of the intersection expansion project would come at the expense of other projects that would reduce auto dependency and vehicle miles traveled. The RTIP requests $2 million in RSTPX funds and transfer and additional $188,000 in already programmed RSTPX funds to this project. These are funds that could be used on projects that make streets safer in the City of Santa Cruz. The State Office of Traffic Safety has rated Santa Cruz #1 in rate of injuries to bicyclists in each of the years 2013-2016 out of 104 cities of similar size and an average of #11 over those years in rate of injuries to pedestrians. Moreover, this project plans to use over $4 million in local Traffic Impact Fees, an amount that approximates the total fund balance. These are funds that won’t be spent on reducing the unacceptable rate of injuries on our streets.

This project is inconsistent with the City of Santa Cruz General Plan’s measures, including:

  • “Seek ways to reduce vehicle trip demand and reduce the number of peak hour vehicle trips.”
  •  “Accept a lower level of service and higher congestion at major regional intersections if necessary improvements would be prohibitively costly or result in significant, unacceptable environmental impacts.”

Faced with public opposition, in June, 2019 the City Council referred this project to the City’s Transportation and Public Works Commission. The Commission has yet to review the project.

Both Projects Require Mitigation

The EIR for AMBAG’s Metropolitan Transportation Plan/Sustainable Communities Strategy requires the following mitigation measure:

T-5 Project-Level VMT Analysis and Reduction

Transportation project sponsor agencies shall evaluate transportation projects that involve increasing roadway capacity for their potential to increase VMT. Where project-level increases are found to be potentially significant, implementing agencies shall identify and implement measures that reduce VMT. Examples of measures that reduce the VMT associated with increases in roadway capacity include tolling new lanes to encourage carpools and fund transit improvements; converting existing general purpose lanes to high occupancy vehicle lanes; and implementing or funding off-site travel demand management.

Neither the Auxiliary Lanes Project nor the Hwy 1 & Hwy 9 Intersection Project have developed measures to reduce VMT, as required by this EIR.

Both Projects Are Inconsistent  with Governor Newsom’s Executive Order issued on September 20, 2019 to “Align the state’s climate goals with transportation spending.”

Conclusion

Please remove these projects from the Regional Transportation Improvement Plan in order to align our spending with our goals for climate and safety.

Thank you,

[1] Table 3-2, page 3-14

[2] page 2.1.5-16

[3] page 2.1.5-14

[4] page 2.1.5-17

[5] page 2.1.5-17

[6] Table 2.1.5-7