Comment Log Display

Here are some ideas that were stimulated by the LUSCAT process,
that didn't make it into the Draft Scoping Plan.  They deserve
full consideration in the Final Scoping Plan:

High Speed Rail
High-Speed Rail could serve as the future armature tying together
the State’s far-flung regions.  Its routing serves as a de facto
land use plan of where the State will grow in the future.  As
such, the High-Speed Rail project needs State-enacted land use
controls, to make sure that development in future High-Speed Rail
station areas helps the state achieve its goals for compact
growth.  Otherwise, the tremendous expense of the project will
provide less than optimal benefits in shaping future growth.  The
needed controls would impose minimum density zoning guidelines as
a requirement for station siting, to catalyze a densification of
future growth around station areas, and a development focus on
urban cores.  These controls are needed because the High-Speed
Rail FEIRs did not impose meaningful mitigations for growth
inducement, or for the sprawl contained in current land use
plans.

CEQA
The CEQA Guidelines need to identify what constitutes a
significant impact.  We suggest that emissions of additional GHGs
be considered a significant impact.  Add the following to the Air
Quality section of the Checklist:  “Result in greenhouse gas
emissions that delay the attainment of AB 32 targets?”  

We believe the ARB will need to create an extensive CEQA
Mitigation Bank, which will enable small projects to pay a
mitigation fee to be able to receive a Mitigated Negative
Declaration.  Such an approach would avoid CAPCOA’s CEQA meltdown
scenario, in which no projects would be able to get through CEQA
without an EIR.  

We see fees received from small land use projects being invested
in renewable energy projects, solar generation plants, energy
efficiency projects, and public transit capital projects.  Both
the fee itself, as well as the modelling process to determine the
level of mitigation needed, as well as the investments of the
mitigation bank itself will need to be carefully written into
regulation, so as to achieve reliable GHG reductions.  We see a
Mitigation Bank possibly functioning as part of a future Cap and
Trade program.

Funding for Urban and Infill Schools  
A major impediment to Smart Growth is the perception of poor
quality urban schools.  Attracting families into cities will
require good schools.  Part of the solution will be additional
funding from the State.  Please note:  The Education Code
requirements for playing fields tend to prevent new schools from
being sited in infill locations, and push them instead to
greenfield locations far from students’ neighborhoods.  This needs
to be fixed.

Market-Priced Parking
We need to stop using public funds to subsidize parking. 
Requiring parking to pay its own way will have a VMT reduction
effect, and will result in more economic use of scarce land
resources.  

LAFCOs and Infill Determination of Need
LAFCOs need to be instruments of State policy, restricting the
annexation of vacant lands so as to push development into infill
locations.