December 10, 2016

Will regional planning stumble on climate change?

Cleaning up greenhouse-gas emissions should be a major priority for any transportation plan. 580 and I80 Traffic Jam.

Cleaning up greenhouse-gas emissions should be a major priority for any transportation plan. 580 and I80 Traffic Jam. Photo: Flickr / Walter Parenteau (cc)

The Metropolitan Transportation Commission (MTC) is on the verge of once more releasing a transportation plan that probably won’t take seriously the challenge of tackling climate change.

Every four years MTC revises its long-term Regional Transportation Plan (RTP) for the Bay Area, and the soon-to-be-released revision is supposed to be the first to have climate change as a focus. Under SB 375, the Sustainable Communities and Climate Protection Act of 2008, California has introduced a new requirement for transportation planning agencies to develop a Sustainable Communities Strategy (SCS) to make sure that RTPs really incorporate the goals for reducing greenhouse gases.

The Bay Area’s combined RTP/SCS will be the blueprint for spending $256 billion through 2040. If it really does address climate change, it could lead to big changes.

Although the draft RTP is not scheduled for release until March 22, previews show no sign that the plan will deal adequately with the climate threat. San Diego’s SANDAG was the first big transportation planning agency in the state to issue an RTP/SCS, which was thrown out in Superior Court for not effectively addressing greenhouse gases. (The case is now on appeal.) MTC’s 2013 RTP risks a similar fate.

SB 375 also requires the Association of Bay Area Governments (ABAG) to mesh its eight-year Regional Housing Needs Assessment (RHNA, pronounced REE–nah) with the SCS. According to ABAG, “The consistency of the housing allocation with a development pattern that promotes reductions in greenhouse gases is likely to emphasize compact, mixed-use commercial and residential development with access to transit. Plans for housing must also include sufficient affordable units so that people don’t have to commute from homes outside the Bay Area to jobs within the region. The goal is more livable communities, offering more housing and transportation choices, a higher quality of life and a vibrant economy.” This is fine language, but here too the housing plan as currently drafted may not produce the needed greenhouse-gas reductions.

The biggest problem with the RTP is also the simplest to state: MTC plans to build 300 miles of new freeway lanes. Since 41% of the Bay Area’s greenhouse-gas emissions come from transportation, it will be a remarkable trick if the EIR shows that the freeway lanes might help cut carbon or support the goals of the Sustainable Communities Strategy.

Priority Development Areas

Other problems are more complex to state.

In the Bay Area, the SCS is organized around Priority Development Areas (PDAs). According to an informative memo by planners at ABAG, the PDAs are intended to “accommodate the majority of the region’s population and employment growth.” The 92 PDAs planned when the memo was written will accommodate 32% of the housing growth and 37% of the forecast job growth on “a little over one percent of the land area of the Bay Area”.

But successful PDAs require a supportive transit system. Unfortunately, MTC does not have a good record of getting more people to take transit. There were more transit passengers 30 years ago than today, even as Bay Area population has increased from five to seven million. During the life of the next RTP/SCS, the population is expected to grow by another two million. What can be done to improve MTC’s transit decisions? There already is a shortfall in funding (about $15 billion over the life of the RTP/SCS) to replace existing vehicles and rehabilitate facilities. So far, documents do not indicate that the RTP contains a plan or estimate of the funds needed for transit improvements to make the PDAs work. For example, some of the San Francisco PDAs are in areas where Muni service is already overwhelmed. More money needs to be found and invested wisely. Successful PDAs will also require upgrades to other infrastructure; ABAG planners’ preliminary assessment of this additional financial need is over $14 billion.

Where will the money come from? Should San Francisco and Oakland, which have volunteered to take on tens of thousands of new residents, have to pay to upgrade their sewers and transit systems to handle the population growth, or should all Bay Area cities and counties, including Novato (with no PDAs) and Pleasanton (with a very small one), be financially responsible?

Unfair housing allocations

The PDAs are voluntary, and that leads to troubling housing issues. For instance, Novato will have two SMART rail stations by 2016, but has not volunteered to have any PDAs. According to a letter from the Public Interest Law Project to ABAG, Novato’s RHNA requires only 413 new housing units in the eight-year cycle from 2014 – 2022, despite the city having 15,000 in-commuters each day. In contrast, 24 cities (e.g. Oakland) have volunteered to take on large increases in housing units and population. San Francisco, according to its planning director, is going to allow more than 90,000 new housing units, and its population will grow from 812,000 to more than 960,000 by 2035. The Public Interest Law Project (PILP) notes that “over 80 percent of [the PDA] growth . . . is confined to just 24 jurisdictions, with only 20 percent allotted to the other 54 jurisdictions with PDAs.”

Further, the cities that have not agreed to PDAs, or only to limited ones, tend to be those with smaller minority populations. According to PILP, cities without PDAs average 64% white, versus 41% for places with PDAs; e.g. Novato, 76% white; and Pleasanton, 67% white; in contrast with Oakland, 34% white (numbers from 2010 census). Housing allocations based on PDAs could lead to increased segregation of housing and transportation.

ABAG’s voluntary approach to PDA housing growth has raised concerns at the state and federal levels. According to the California Department of Housing and Community Development, ABAG adjusted the housing-growth figures “to ensure that no county or city’s proposed growth substantially deviates from local plans.” HCD notes it is “the statutory objective for each local government to share responsibility for addressing regional housing needs in an equitable manner.” Further, “a council of governments [here, ABAG] may not limit its consideration of suitable housing sites or land suitable for urban development based on localities’ existing zoning ordinances and land use restrictions.”

The U.S. Department of Housing and Urban Development (HUD) states in a letter, “If ABAG adopts a housing allocation which is largely contingent on the voluntary PDA designation, efforts should be made to ensure that all jurisdictions with transit-oriented neighborhoods are allocated housing in a manner consistent with fair housing choice.”

PDAs are a key to the RTP/SCS, and there are still a lot of questions ABAG and MTC need to address to make sure that the PDAs help with climate change and that all Bay Area residents are treated fairly. The Sierra Club is working closely with a variety of other organizations including Urban Habitat, Public Advocates, and Greenbelt Alliance to make sure that these questions are addressed.

ABAG and MTC are scheduled to release the Draft Bay Area Plan on March 22, and the companion EIR on March 29. The public-comment period on both will extend until May 16. In accordance with Club “one voice” policy, representatives from the San Francisco Bay, Redwood, and Loma Prieta chapters have been working to provide coordinated comments on both documents.

Matt Williams, co-chair, Sierra Club Bay Chapter Transportation Committee


The Sustainable Communities Strategy

The Metropolitan Transportation Commission

SB 375

The Association of Bay Area Governments

Regional Housing Needs Allocation—RHNA

Governor Schwarzenegger’s Executive Order S–3–05

Filing of the California Attorney General in the SANDAG case

Ruling in SANDAG case (Sierra Club California)

UC Berkeley Professor Andrew Guzman’s Feb. 25 lecture on Climate Change

Bay Chapter list of objectives for the 2013 Regional Transportation Plan

Memo by ABAG staff on PDAs

SMART (Sonoma–Marin Area Rail Transit)

Letter from the Public Interest Law Project on RHNA and PDAs

Letter from state Department of Housing and Community Development to ABAG

Letter from U.S. Department of Housing and Urban Development to ABAG

2010 Census information by city

Article on San Francisco population increase through 2035

Urban Habitat

Public Advocates

Greenbelt Alliance


  1. Tom James says:

    The estimate of 15,000 in bound commuters a day driving into Novato is ludicrous. If you live in Novatom and work in Novato as I did, the number makes no sense. The only way it could be right is if you include all the shoppers headed to Costco, Target, Ross, and Marshalls. For there to be 15,000 in bound commuters there would have to be 15,000 jobs and if there are 3,000, I’d be surprised. I co-founded a company that had about eighty local employees and as we grew we were forced to relocate to Petaluma because there were no facilities in Novato large enough to accommodate our needs. So 15,000 jobs is way out in left field. I wonder who made up that number? And our housing requirements should be based on fallacious estimates like that?

  2. Matt Williams says:

    Dear Mr James:

    Thank you for your note. The correct number of in–commuters to Novato is 15,393. Here is where you can see this figure for yourself:

    Go to and type in Novato in the search box on the left side of the page. Under PLACES will be Novato in bold; click on that.

    Click on PERFORM ANALYSIS ON SELECTION AREA; 2010 should be checked. I used primary jobs to get the figure above. If you select all jobs, the number increases to 16,858.

    Also, hit the button for Inflow/Outflow and you should get 15,393. Primary jobs in Novato total 19,231.

  3. Tom James says:


    Thanks for the response. What you gave me was the source of the number, not how it was determined? Actually when I followed your instructions the estimate of commuters commuting to primary jobs was 19,231. That estimate is even more ridiculous. That’s more than one in-bound commuter for every household in Novato. Just because the number comes from the government doesn’t make it correct. I worked for a very large consulting firm and a large retailer and was involved in data analysis a large part of my career. One should always question the validity of numbers. Does the number make any sense should always be your first question. How in the world would the government have any idea how many people commute into Novato. As I mentioned.

    I was a primary owner of a company headquartered in Novato. Never did the government question us or our employees where they lived. And we were one of the larger employers in Novato and moved because we couldn’t find a facility large enough for our needs. We employed ninety people. So how many larger employers are there in Novato?

    The estimate of in-bound commuters is ludicrous.

    Tom James

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