Suit Sierra Club

Follow Marin Events

• HomeUpOneBayAreaGrant $382 millionPlan_Bay_Area-OverviewPBA Workshops$20 BILLION on Bay Area TransportationSolution to Overdevelopment19th Ave Freeway TunnelLawsuit against "Plan Bay Area"CIVIC CENTER PDA Q&ALA Transit Orientated DevelopmentBay/cox to mtc detailed comments 20130514.pdfBay/Randal O'Toole comment letter.pdfSF Transit Hub or 19th Ave Tunnel?Marin Regional Planning InitiativesRemoving a PDASuit Sierra Club •
• Sierra_ClubEarth_Justice sPlanBayAreaPleadings(8-19-13)2.htmSierra_ClubEarth_Justice sPlanBayAreaPleadings(8-19-13)2.htm •

Cars and light trucks remain the single largest source of greenhouse gas emissions in the State of California, and in the Bay Area, these
sources are responsible for nearly 40% of greenhouse gas emissions in the region.

Over the past 30 years, there has been an increase in the number of vehicle miles travelled (?VMTs?),
and associated greenhouse gas emissions. The Plan does nothing to alter that
trajectory, and continues to increase the amount of VMTs. The agencies‘ failure to shift
transportation patterns in the Plan is a continuation of their long-standing pattern and practice—
public transportation ridership has remained relatively flat over the past 20 years, despite regional
population increases.

The overall movement of goods nationwide and in the region is expected to increase.
The 2009 MTC study forecast an increase in goods movement through airports, seaports and
railways of 109% between 2006 and 2009.
The Federal Highway Administration projects a
nationwide increase of

  • 80% in freight tonnage hauled by trucks and a
  • 73% increase in rail tonnage;
  • air cargo tonnage is expected to quadruple.
  • Activity in California ports is expected to increase by
    250% between the present and 2020.
  • Due to shifting land use patterns, trucks transiting through the
    Bay Area are expected to increase the distances travelled to deliver their cargoes. The need for
    industrial lands is also expected to increase, as more manufacturing and warehouse space will be
    needed, to accommodate expected increases in goods movement through airports, highways,
    seaports and rail.

The Plan continues to expand highways, and agency projections show that
daily vehicle trips and miles travelled will increase under the Plan.

The Plan includes some 194 projects that increase freeway lane-miles, at a cost of approximately $5.4 billion.
Among the roadway capacity increases proposed under the Plan is the Regional Express Lanes Network,
 which builds new high-occupancy/toll (HOT) lanes on many of the region‘s most congested freeway corridors.

DEIR at 2.1-25. Highway widening projects are responsible for the remainder of the freeway
capacity increases. Under the Plan, daily vehicle trips are expected to increase by 22%. Daily
vehicle miles travelled are expected to increase by 20%.
The EIR shows that under the Plan, through 2040, there will be an increase in
5,571,000 metric tons of greenhouse gas emissions from the transportation sector. This represents a
21% increase from present conditions. Yet the EIR improperly asserts that there will be a decrease
in emissions from passenger vehicles over time. It does so by crediting emissions reductions from
separate state emissions reduction programs. The EIR factors in emissions reductions from
Assembly Bill 1493 (?Pavley?) clean car standards, which set progressive greenhouse gas emissions
caps for passenger vehicles and light trucks. The EIR also factors in emissions from Executive
Order S-01-07, which established a low-carbon fuel standard (?LCFS?) which set goals to reduce the
carbon intensity of transportation fuels.

The EIR also shows that under the Plan, through 2040, there will be an increase in
6,769,000 metric tons of greenhouse gas emissions from various land uses (i.e., residential use, and
commercial, office and industrial uses). This represents a 28% increase from present conditions.
Only by applying emissions reductions from the Air Resources Board (?ARB?) Climate Change
Scoping Plan (?Scoping Plan?) implementing the California Global Warming Solutions Act (?AB
32?), are the agencies able to account for reductions as claimed in the EIR. The ARB Scoping Plan
measures included in the DEIR‘s calculations are: energy efficiency programs (utility energy
efficiency programs, building and appliance standards, efficiency and conservation programs), heat
and combined power use programs, renewables portfolio standards, solar roof programs, solar water
heating and landfill methane control.

54. The same programs (Pavley, LCFS, and AB 32 Scoping Measures) are taken into
consideration when analyzing whether the Plan meets the goals of Executive Order S-3-05 (June 1,
2005) and Executive Order B-16-2012 (March 23, 2012). Executive Order S-3-05 recognized the
need to reduce greenhouse gas emissions to combat the effects of climate change, and set the
following targets for emissions reductions: ?by 2010, reduce GHG emissions to 2000 levels; by
2020, reduce GHG emissions to 1990 levels; by 2050 to 80 percent below 1990 levels.? Executive
Order B-16-2012 recognized the importance of encouraging the development and adoption of zero
emissions vehicles, and sets a ?California target for 2050 a reduction of greenhouse gas emissions
from the transportation sector equaling 80 percent less than 1990 levels.? Without reductions from
Pavley, LCFS and AB 32, land use and transportation emissions in the region are expected to
increase, and the Plan does not meet the targets set forth in these executive orders. Furthermore,
even with these reductions being taken into account, the Plan will fail to adequately contribute to
meeting the executive order targets.

57. The Plan also creates the risk of displacement of low-income communities.
According to the Equity Analysis conducted by MTC and ABAG, the Plan would increase the risk
of displacement to overburdened renters by 36%. A number of the areas identified for development
as PDAs – such as Chinatown, Bayview/Hunters Point, the Mission District, and areas identified for
development in Richmond and along major corridors in East Oakland – have historically housed
renters, and have been home to long-standing, low-income communities of color. The Plan does not
ensure that affordable housing will remain accessible to these communities, thereby creating the risk
that members of these communities will be displaced to suburban areas which are further from
robust public transportation systems. When they do not have ready access to transit, the low-income
members of these communities tend to depend on older vehicles, with greater levels of emissions,
for their daily transportation needs. This movement will necessarily have environmental impacts.

58. There is very little consideration of goods movement in the Plan or EIR, despite
MTC‘s 2004 and 2009 studies providing extensive information about projected increases in goods
movement through the region, the negative health effects of goods movement, and the need for
mitigations for the effects of goods movement. This is in marked contrast to the regional plan
created by the Southern California Association of Governments, which includes a detailed
description of goods movement in the project description, a detailed analysis of goods movement
through the region, and proposes a variety of mitigation measures to address the environmental and
health effects of goods movement.

59. The alternative proposals considered by the agencies perform better than the Plan in a
variety of ways. For example, the EIR identifies Alternative 5, the Environment, Equity and Jobs
alternative as the environmentally superior alternative due in large part to its ?overall GHG
emissions reductions and estimated reduction in criteria and TAC [toxic air contaminants] emissions.
. . .? DEIR at ES-11, 3.1-148.

  • Alternative 3, the ?Transit Priority Focus? Alternative, and
  • Alternative 5, both have lower levels of vehicle miles travelled than the Proposed Plan.

Alternative 5 has the lowest amount of vehicle miles travelled, at 2 percent lower than the proposed Plan.
Alternative 5 also has the greatest transportation ridership than any other plan, 6 percent more than
the proposed Plan. Alternative 5 is also expected to reduce more transportation and land use
greenhouse gases than the proposed Plan – under Alternative 5, GHG emissions are expected to
decline by 14 percent between 2010 and 2040, which is a two percent greater decline than the
proposed Plan.

60. Adopting the Environment, Equity and Jobs alternative would dramatically increase
transit service levels, and will result in a number of tangible benefits, including: 83,500 fewer cars
on the road; 3.5 million fewer miles of auto travel per day; 165,000 more people riding public transit
per day; and 1,900 fewer tons of carbon dioxide emissions per day and 568,000 fewer tons of
greenhouse gas emissions per year.2