| Name (Last, First) | Agency | Page(s) | Heading | Subheading | Figure | Table | Comment | Response | Status | Working Group | ||||
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| 1 |
| California Air Resources Board | Other Heading | Other Subheading | California Air Resources Board (CARB) staff appreciate the opportunity to review and engage with the California Department of Transportation (Caltrans) and the California Transportation Commission (CTC) staff on the update to the 2023 Regional Transportation Plan Guidelines. CARB staff will be providing in line edits, comments, and recommendations on the following topics: Climate Change: * Sustainable Communities Strategy * GHG Emissions * Environmental Analysis * Climate Adaptation and Resilience Housing: * Housing Coordination Plans * RHNA/ SCS Coordination * AFFH Revenue Assumptions/Investments: * Pricing * Sales Tax Measures * Other Revenue * Investment Reporting Performance Metrics: * Metrics * Analysis Monitoring/Implementation: * Tracking and data reporting * Implementation Modeling: * Exogenous variables * Inputs * Induced demand * Interregional trips * Emerging areas (e.g. telecommuting, Avs, TNCs, micromobility) * Model validation and calibration Equity/ Public Participation: * Metrics * Outreach methods Examples Based on Guidance and Reports: * Scoping Plan * SB 150 Report * SCS Guidelines/ SCS Evaluations * CAPTI * AB 285 Report We look forward to working together on the RTP Guidelines update. 1. Strengthen connection to transportation, land use planning, and VMT/ GHG reduction actions in the Scoping Plan. The RTP Guidelines describe bills and reports around transportation planning and climate change but does not explicitly mention the Scoping Plan. One of the goals of the RTP Guidelines includes promoting a comprehensive and cooperative transportation planning process to maintain public health and environmental quality. As the Scoping Plan lays out the vision for carbon neutrality in the State and improves air quality, it is vital to mention it and encourage alignment within the RTP Guidelines. 2. Clarify and strengthen how the SB 375 program works, consistent with SB 375 Statute, the SCS Guidelines, SB 150 Report, and current planning practice. The RTP Guidelines describe the SB 375 program as well as the planning process, but it often lacks details. Clarifications should be made to the RTP Guidelines to assist MPOs as they develop their RTP/SCSs in alignment with existing processes. 3. Encourage consistent methodology for reporting project investments and revenue assumptions (including pricing strategies) and encourage reimagining the project selection process. The RTP Guidelines describe how revenue and transportation costs are forecasted. The AB 285 Report includes a recommendation for standardizing data and reporting of investments. This recommendation and potential actions to address it should be included in the Guidelines to be able to fully understand assumptions and investments and to be able to leverage them. Additionally, the RTP Guidelines describes considerations for including projects in the RTP project list. One of the goals of the RTP Guidelines includes promoting an integrated, statewide, regional transportation planning process and effective transportation investments. Several reports including the CAPTI, AB 285 Report, Scoping Plan, and SB 150 Report include recommendations around reimagining transportation projects in alignment with State goals, so this message should be included in the RTP Guidelines to support effective transportation investments. 4. Clarify and encourage improved modeling, including input data, modeling processes, model validation and calibration. The RTP Guidelines describe how the MPOs should utilize data and modeling, however, the Guidelines lack details such as around new SCS strategies (such as telework, pricing, etc.), how to analyze induced demand, etc. Additional details can help the MPOs to better improve their data collection and modeling process, which can result in more accurate analysis to support regional transportation planning and decision making. 5. Support and advance equity and engagement. The RTP Guidelines describe the public p | Thank you for providing specific comments. We have incorporated edits throughout to clarify language and update references. Higher-level policy feedback will be considered for inclusion in the second draft and will be discussed in the work groups. | Complete | None | ||||||
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| Coalition for Clean Air | 25 | Chapter 2 RTP Process | 2.3 Promoting Public Health and Health Equity | We ask that the RTP Guidelines include strong protections for communities located next to highways or freight routes against air pollution created by the transportation sector. Communities located next to freight routes suffer from increased exposure to air pollution as diesel trucks are the largest mobile source of air pollutant emissions. These communities tend to be predominantly people of color or low income. Air pollution can cause a number of respiratory and cardiovascular diseases such as lung cancer, asthma, and heart attacks. Other impacts of the transportation system include noise, light pollution, and displacement, with more than 200,000 people nationwide over the last 30 years having been displaced due to federal road projects. Minimizing air pollutants is also important from a funding perspective. Currently, there are about 40 counties in California in nonattainment under the Federal Clean Air Act. For those counties, continuing to fail to attain air quality standards could result in federal sanctions and the loss of federal funding for transportation projects, which would heavily impact local and regional agencies due to their lower funding availability. To help avoid this outcome and improve overall public health, we strongly urge that new and existing RTP projects work to minimize air pollutant emissions and adverse impacts on local communities. Thank you. | Thank you for your comment. | Complete | Freight & Economic Development | |||||
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| SCAG | 143, 144 | Chapter 6 RTP Contents | 6.12 Goods Movement (Maritime/Rail/Trucking/Aviation) | I have two comments below. 1. Typo on page 143 as below, Title 23 CFR Part 450.324(f)(1) states that the RTP shall include the €§§§projected transportation demand of persons and goods... 2. Mileage of NHFN inconsistency Mileage numbers of 'PHFS' and 'Other Interstate portions not on the PHFS' are not consistent with FHWA's website numbers (unless the draft document included recent CUFC, and CRFC designation mileage from MPOs and DOT branch offices). Please refer to the below link to the FHWA website. https://ops.fhwa.dot.gov/Freight/infrastructure/nfn/index.htm | Thank you for your comment. We look forward to discussing the inconsistency of mileage numbers at the Freight & Economic Development work group and addressing it in the second draft of the Guidelines. | Complete | Freight & Economic Development | |||||
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| Caltrans | 4.5 Private Sector Involvement | the private sector does not really interact with regional agencies, and they are the ones leading in innovation. How can we make it easier for them to consult with us? Maybe have a strategy to capture participation. Maybe send out surveys. We need to make it easy for them to strategize with us. | Thank you for your comment. We will look forward to further discussing this in the Freight & Economic Development work group. | Complete | Freight & Economic Development | |||||||
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| Caltrans | 6.12 Goods Movement (Maritime/Rail/Trucking/Aviation) | Maybe I missed it, but I did not see any mention of consideration for climate resilience. We should be considering current and future climate impacts on our goods movement facilities. We have federal req travel time reliability, is it appropriate to include that in here? We have not been preforming well in this area. | The RTP section discussing goods movement can be strengthened or we can reword the language where we mention GHG. This ties to PM 3, this will be included in that section. This has been a finding from FTA/FHWA, we can work on incorporating this throughout the document. | Complete | Freight & Economic Development | |||||||
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| Coalition for Clean Air | 6.12 Goods Movement (Maritime/Rail/Trucking/Aviation) | is there language that focuses on impacts that freight projects can have on communities? (Air pollution, noise pollution, displacement) | Yes, we worked with the coalition during the last update, this will be a consideration. | Complete | Freight & Economic Development | |||||||
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| KernCOG | 4.5 Private Sector Involvement | regarding issues with class one railroads in the private sector, MPOs don’t have time to interact with all the state agencies every 4 year. Recommend incorporating input from state freight planning agencies. When there is more involvement from class one railroads and local goods movement interest, that’s a good way to get their input into these plans/guidelines. | Thank you for your comment. | Complete | Freight & Economic Development | |||||||
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| KernCOG | 6.12 Goods Movement (Maritime/Rail/Trucking/Aviation) | #9 could be expanded to include inland trade ports and connectivity network for those ports. (last mile connectors. Truck parking or ZEV implementation considerations are kind of related to #11, it can be added there. RTP guidelines do a good job of talking about rural versus urban areas. A lot of CTC documents are skewed to urban areas. Rural communities are resource areas; providing truck passing lanes to get products to market. These communities need the resources provided – CTC to be aware that capacity projects in rural area can help a community whereas it may not in an urban area. Shipping by rail is more efficient than shipping by truck; trade port allows goods from rail to market. The guidelines may not be the mechanism to communicate this. | Thank you for your comment. | Complete | Freight & Economic Development | |||||||
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| SANDAG | 4.5 Private Sector Involvement | Recommend conversation about who makes up the private sector is important to note. Do we understand the vertical integration? (Different business sizes and how they are impacted). Suggestion to add language to strengthen who makes up private sector and importance of engaging them. The examples of modes provided can be more specific. | Thank you for your comment. | Complete | Freight & Economic Development | |||||||
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| SCAG | 4.5 Private Sector Involvement | Those who engage tend to be a biased, or asymmetrical representation, of the very wide range of entities constituting "private sector." Just sharing a bit of our experience/challenge, generally. | Thank you for your comment. | Complete | Freight & Economic Development | |||||||
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| SRTA | 6.12 Goods Movement (Maritime/Rail/Trucking/Aviation) | Seems like continuing to expand freight trucking (as opposed to rail) poses challenges to achieving state goals regarding climate, sustainability, VMT, and street safety, but addressing the issue really more in the state's realm rather than regional issues. Are we capturing the latest and greatest with ZEV, truck parking? | Thank you for your comment. | Complete | Freight & Economic Development | |||||||
| 12 | HCD | 40 - 41 | Chapter 2 RTP Process | 2.9 IIJA Housing Coordination Plan | Describe the similarities/differences of the suggested content of a Housing Coordination Plan with current RTP requirements. If there are similarities, could describe how to package them into a Housing Coordination Plan to incorporate in an RTP. Describe benefits/incentives, e.g. additional funding opportunities, of including a Housing Coordination Plan in the RTP. Define “should”. For example, in the description of a Housing Coordination Plan it states “MPOs may develop a housing coordination plan . . .”(Emphasis added). Could describe if a Housing Coordination Plan is an option, recommendation, or requirement to include in an RTP. | Thank you for your comment. | Complete | Housing | ||||||
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| Nor Cal Carpenters Union | 167 | Chapter 6 RTP Contents | 6.24 Contents of the Sustainable Communities Strategy (SCS) | “The enactment of the Affordable Housing and High Road Jobs Act of 2022 (AB 2011, Chapter 4.1 of Division 1 of Title 7 of the Government Code) may impact forecasted development plans. To account for increased infrastructure demand to support new housing development, the forecasted development pattern in the SCS should consider the impact of this state housing policy, and potential subsequent transportation expansion, on regional CARB targets.” | Thank you for your comment. | Complete | Housing | |||||
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| Caltrans HQ | NA | Other Heading | Other Subheading | In the OWP guidance, please update this to allow for flexibility in funding for use in housing coordination activities. As advised by Antonio Johnson (FHWA) funding eligibility changes necessary; need to bring FTA and FHWA in on this - FHWA Metropolitan Planning Grant (PL), FTA Metropolitan Planning Grant (5303), FHWA State Planning and Research 1 (SPR1), and FTA State Planning and Research 1 (5304). | Thank you for your comment. We advise this note is best incorporated through changes to OWP guidance. | Complete | Housing | |||||
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| Caltrans | NA | Other Heading | Other Subheading | Usually zoning matters is not covered in Caltrans land use and planning documents. There has been discussion that the Biden Administration will want zoning matters incorporated into IIJA funded projects. Can you please provide perspectives into this? >> | Thank you for your comment. This is best considered in LDR guidance rather than RTP guidelines. | Complete | Housing | |||||
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| AMBAG | 2.9 IIJA Housing Coordination Plan | It would be good to add to guidelines example of good housing example near transit etc. | Thank you for your comment. We will consider this feedback in the second draft of the RTP Guidelines for MPOs. | Complete | Housing | |||||||
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| Caltrans | Do the guidelines have feedback loop requirements to meet the objectives? How do we know if we are moving in the right direction? In other words, taking baby steps to achieving the State's goals. The goal should be to get input from all stakeholders. While having working groups is great, what steps are we taking to get sufficient and adequate representation? | Yes, it is an inclusive, iterative process with feedback built in. The plans themselves have explicit feedback loops and objective requirements. | Complete | Housing | ||||||||
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| Equity Transit | 2.9 IIJA Housing Coordination Plan | In reviewing IIJA housing coordination in plan, the RTP SCS already does some of this work. Does this have to be a separate plan? How we design TODs and any development should ensure integrated housing so that within a development there are all ages, economic levels, including workforce housing. And a person who is blind or vision impaired may have very different concerns that someone who is wheelchair dependent. We also advocate for development designs that connect people in community rather than cold disconnected building - there must be a street level or ground level vibrancy. Just shooting out points to think about. I recommend please reaching out to org leaders of underrepresented org – NAACP, Disability representation, etc. Ensuring as we do these guidelines, we have affordable housing to allow people to live where they work | Yes, it need needs to be separate; we will work to avoid duplication. Thank you for your comment, it is a challenging topic. We may consider incorporating equity metrics in this section. We will keep this feedback in mind for the second draft of the RTP Guidelines for MPOs. | Complete | Housing | |||||||
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| MTC | 2.9 IIJA Housing Coordination Plan | Some of the content is duplicative of SCS. It would be helpful to highlight what is additive to the section: is it an addition or is overlap? | Thank you for the suggestion. We will work with HCD to identify overlap and avoid duplication. | Complete | Housing | |||||||
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| HCD | 40, 41, 80, 87, 306, 307, 308, 309, 314, 316 | Chapter 2 RTP Process | 2.9 IIJA Housing Coordination Plan | *These comments are for both the housing and equity-identified update sections. Please see attached file for clarity. *HCD will also be submitting additional comments by the end of the week. Pages 40-41: Describe the similarities/differences of the suggested content of a Housing Coordination Plan with current SCS/RTP requirements. If there are similarities, could describe how to package them into a Housing Coordination Plan to incorporate in an RTP. Describe benefits/incentives, e.g. additional funding opportunities, of including a Housing Coordination Plan in the RTP. Define “should”. For example, in the description of a Housing Coordination Plan it states “MPOs may develop a housing coordination plan . . .”(Emphasis added). Could describe if a Housing Coordination Plan is an option, recommendation, or requirement to include in an RTP. Another strategy could be promoting walkable neighborhoods/Location Efficient Communities. Emphasize afordable housing, low-income, and disadvantaged communities. Page 80: Change "appropriate" to "affordable." Page 87: Edit to "with limited/no internet access such as those in rural communities." Page 306: Consider also mentioning that not sitting in a car for hours can have physical health benefits. Page 307: Consider adding language about the urban heat island effect in this paragraph or under "climate change." Page 308: Consider using "people with disabilities" instead. Page 309: Is HiAP known now as State of Equity? Page 314: Add a period after "agencies." Page 316: What is considered over age? 18 years old? | Thank you for your comments, we incorporated many of these edits into the first draft. | Complete | Climate Change & Environment Equity, Engagement, & Health Housing | |||||
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| OCTA | Chapter 2 RTP Process | 3.2 Requirements for RTP Analysis | How does NCST Tool fit in here? I don’t see it included. | The NCST calculator is specific to induced VMT estimates based on adding lane miles, so it doesn’t encompass all the elements that need to be included in the TDM and RTP requirements. It is specific for VMT and not inclusive for RTP modeling. | Complete | Modeling | ||||||
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| AMBAG | Chapter 3 RTP Analysis and Modeling | I don’t think there is anything needed to be added to this section. There is a reference to GHG reduction and SB 375 requirements in in the climate change section of the RTP guidelines. Specific way of how its modeled in the SCS requirements is governed and outlined in the SCS documentation the CARB produces. | Thank you for your comment. | Complete | Modeling | |||||||
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| California Air Resources Board | 48-60 | Chapter 3 RTP Analysis and Modeling | 3.3 TDM Quality Control and Consistency | The travel demand modeling tools and assumptions are critical for developing the Sustainable Communities Strategy (SCS) and demonstrating the GHG emission reduction targets. Currently, MPOs use the requirements and recommendations specified in the RTP guidelines. Under SB 375 statute, CARB must review MPOs’ technical methodology for forecasting GHG emission reductions for 2020 and 2035. CARB would like to suggest improving the current modeling techniques and practices based on the information and insights gained over the years of reviewing SCSs. This would include developing a consistent methodology for critical input variables such as auto operating cost, socioeconomic forecasts, and network characteristics. In addition, we suggest an expanded discussion of model validation, calibration criteria, and thresholds. Some key topics that we’d like to discuss are interregional trip estimates, induced demand effects of land use & transportation projects, telecommuting and new mobility, and automated vehicles. Finally, we recommend checking the reasonableness of model outputs. | Thank you for your comment. We look forward to discussing these topics in the Modeling work group. | Complete | Modeling | |||||
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| CARB | Chapter 3 RTP Analysis and Modeling | 3.4 RTP Modeling Improvement Program (MIP) / Planning Practice Examples | Page 54 & 55 of the draft, is it true to assume that these pages will not discuss more than what is on here? | Feedback to discuss the latest technology in modeling, beyond what is in the RTP guidelines, is solicited during CARB forums; if there are any other modeling suggestions that fall out of the scope of the guidelines, we can address them elsewhere via another avenue. | Complete | Modeling | ||||||
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| Friends of the Rail & Trail | the requirements for reducing GHG, do not state that GHG reduction has to come from transportation. Can we add more clarity? Regarding the requirement to include in the planning and analysis to switch to electric vehicles, a study done by a State agency that stated we would not make that switch in the next 15 years. Is that consideration factored into these models? | We will look into requirements for both transportation GHG and GHG in general. For a Statewide model we are required to incorporate EO N-79-20. We must forecast for EVs by 2035 and 2045 for freight vehicles. We will take into consideration these two forecast years. Different scenarios will need to be analyzed; we will work with the climate change group. | Complete | Modeling | ||||||||
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| Caltrans | Chapter 7 Transportation Performance Management | California needs to strengthen our relationship between the RTP’s and TPM outcomes. California did not make progress as required by federal regulations on about 1/3 of the TPM metrics. The guidelines should include a requirement to demonstrate that the Proposed RTP will make progress in the future. | That is tied to FSTIP findings and MPOs need to be cognizant of. We need to be able to showcase how MPOs are meeting our goals and they need to more language for us to know how to report for the regions and for the state. | Complete | Transportation Performance Management | |||||||
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| Caltrans | Chapter 7 Transportation Performance Management | can we strengthen the language for performance-based plans such as TAMP, CFMP, System performance plans, etc.? Chapter 7 focuses on Federal, will state be found in this chapter? | We are trying to be proactive on our CTP, Freight plans and articulate what we need and what targets we are setting to meet the federal requirements. Once we update the actual text and content, the guidelines will reorganized to better flow and be useful. They most likely will be separate. It will stay as is for input and then changed throughout the process. | Complete | Transportation Performance Management | |||||||
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| SANDAG | Chapter 7 Transportation Performance Management | This draft has good info, covers all bases. One of the challenges we have is institutional knowledge. So few people at the agencies have the technical expertise. Would recommend having a calendar on the frequency of updates (on all the PMs). Also, don’t see a lot of info on the FTA safety rule. | Thank you. A calendar is a great idea, will work on incorporating that. It is a lot to manage all PM target timelines. | Complete | Transportation Performance Management | |||||||
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| SANDAG | Chapter 7 Transportation Performance Management | Do the CMAQ measures in PM 3 now apply to all MPO? If not, adding clarification on applicability would be helpful. Attainment statuses may change so may be better not to list out areas specifically. But rather clarify. | CMAQ measures only apply to non-attainment areas. Thank you for your suggestion. Referencing the applicability table that are referenced on the FHWA website would be helpful; we can include it as a link in the Guidelines. | Complete | Transportation Performance Management | |||||||
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| SANDAG | Chapter 7 Transportation Performance Management | 7.4 Performance Monitoring | Section 7.4 for SANDAG is outdated; is there something more recent that the 2011 performance monitoring indicators? | We will include more recent examples and best practices in the second draft of the RTP Guidelines for MPOs. | Complete | Transportation Performance Management | ||||||
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| Coalition for Clean Air | 87 | Chapter 4 RTP Consultation and Coordination | 4.3 Social Equity Factors | We applaud the RTP Guidelines' strong considerations for equity and engagement in the development of the plans. In particular, we are thankful for the suggestions that local agencies should hold public meetings after working hours and provide adequate translation to allow more stakeholders to engage in the RTP process. We ask that the RTP Guidelines continue to prioritize creating a robust stakeholder engagement process that listens to and addresses the concerns of the community by encouraging MPOs and RTPAs to address attendance barriers when holding public comment hearings. For example, the agency could help cover the costs of transportation and childcare to ensure that members from low-income communities are able to participate. We would also like for the final RTP to include a section that lists the concerns and comments that were brought up by the community and how the agency addressed them to help improve the transparency of the engagement process. Thank you. | Thank you for your comment. | Complete | Equity, Engagement, & Health | |||||
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| Coalition for Clean Air | Chapter 4 RTP Consultation and Coordination | we would love continued emphasis on air pollution as it affects communities of colors. It is a funding issue as some areas are in non-attainment. Would liketo see stronger language on air pollution. Suggest adding to Equity list how local agencies address low-income attendance reimbursement for transportation to public meetings. Would like to see a sections in RTPs that lists concerns of communities and how the Agency addresses them. | Thank you for your comment. | Complete | Equity, Engagement, & Health | |||||||
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| Equity Transit | Chapter 4 RTP Consultation and Coordination | Recommend bring in representatives from all communities (races, abilities, disabilities) How we design TODs and any development should ensure integrated housing so that within a development there are all ages, economic levels, including workforce housing. Looking at representatives from difference groups helps to gain perspective; vision impaired individuals may have very different concerns than someone who is wheelchair dependent. We also advocate for development designs that connect people in community rather than cold disconnected building - there must be a street level or ground level vibrancy. Just shooting out points to think about to ensure we are developing access for our most vulnerable. | Thank you for your comment. | Complete | Equity, Engagement, & Health | |||||||
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| Friends of the Rail & Trail | Chapter 4 RTP Consultation and Coordination | 4.2 Title VI and Environmental Justice Considerations in the RTP | Would like to see more references to the Clean Water Act. The Clean Air Act and newer research on brake pads and particulate show that they are affecting communities. Not sure if this is in the act or if we can add it. Page 84 references increased traffic congestion, while more measures reference VMT. Is there a reason we don’t measure ‘disparate impacts’ on disabled and low-income instead of just race/nationality? Page 84 only lists race/ethnicity. Is it written that way in the law? | We will look at how this is reflected in the guidelines and revise references as appropriate. For location-based projects, it is difficult to measure disability in communities but we will consider this feedback. It's also based on Title VI and EJ Executive Orders, which protects based on "race, color, and national origin" and "low-income and minority populations." | Complete | Equity, Engagement, & Health | ||||||
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| SCCRTC | Chapter 4 RTP Consultation and Coordination | It would be great to get overview from agencies that have done a great job integrating equity into their RTPs at a future meeting | Thank you for your comment. | Complete | Equity, Engagement, & Health | |||||||
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| SJCOG | Chapter 4 RTP Consultation and Coordination | I believe I put a comment in Social equity considerations - 2 come to mind - the needs of communities that speak languages other than English, for interpretation/translation. Also, use of alternate methods to engage folks who are not literate in English or their own language (videos, infographics, etc). consider differing AMI levels in counties in determining EJ/AB 535 communities, because the AMI is lower in San Joaquin County (and other SJ Valley counties) vs areas where AMI is higher (Bay Area, So Cal | Thank you for your comment. | Complete | Equity, Engagement, & Health | |||||||
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| TAMC | Chapter 4 RTP Consultation and Coordination | would like to address language barriers. Would like to recommend leading meetings in the preferred language of the community in which these meetings are and provide interpretation if needed. A database of these strategies for agencies to tell citizens what they’re doing and what is working would be helpful. | Thank you for your comment. | Complete | Equity, Engagement, & Health | |||||||
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| CDPH | Multiple | Appendix K: Promoting Health and Health Equity in MPO RTPS | Other Subheading | Please find the CDPH Climate Change and Health Equity Section preliminary recommendations for updates to the Regional Transportation Plan Guidelines attached. Please note, we look forward to participating throughout the update process, and would be happy to provide support in drafting language updates for the public health and health equity section or related sections as needed. Feel free to reach out to our team if you would like further support, or to discuss our feedback in more detail. | Thank you for your comment. We will consider this feedback in the second draft of the RTP Guidelines for MPOs. | Complete | Climate Change & Environment Equity, Engagement, & Health | |||||
| 39 |
| MTC | 6.29 Adaptation of the Regional Transportation System to Climate Change | In reference to sea level rise and adaptation planning (is there a resilience improvement program?) Will these be included in the RTP guidelines? | Yes, there are resilience improvement programs and alignment with the RTP is called out in those programs. We will consider including these programs into the first draft. We look forward for more comments for the second draft of the Guidelines. | Complete | Climate Adaptation | |||||||
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| SRTA | 6.29 Adaptation of the Regional Transportation System to Climate Change | not sure if this is appropriate but will there be mention of maladaptation? | We will work to address that and include language to avoid maladaptation in the second draft of the Guidelines. We are being cognizant of how we are phrasing these recommendations; the Adaptation Planning Guide is a key document for this section. | Complete | Climate Adaptation | |||||||
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| Coalition for Clean Air | 6.29 Adaptation of the Regional Transportation System to Climate Change | we would like to see RTP guidelines include CAPTI considerations. RTP guidelines emphasize need to limit VMT inducing project to, reducing VMT has a lot of public health benefits, collisions, congestion. Would like to see RTP include VMT reduction mitigation. | Thank you for your comment. | Complete | GHG/SCS | |||||||
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| Equity Transit | 6.29 Adaptation of the Regional Transportation System to Climate Change | the Clean Air Act is now a part of the guidelines, but we want Clean Water Act to be included. Put an emphasis on when we focus on TOCs, moving away from road widening allows robust access and address VMT too. | Thank you for your comment. | Complete | GHG/SCS | |||||||
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| NRDC | 6.29 Adaptation of the Regional Transportation System to Climate Change | How does Caltrans consider cumulative pollution burdens, especially with respect to criteria pollutants in environmental justice communities, in the RTP process? | Thank you for your question. We look forward to addressing this is the GHG/SCS work group. | Complete | GHG/SCS | |||||||
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| Coalition for Clean Air | 120 | Chapter 5 RTP Environmental Considerations | 5.7 Analysis of GHGs and Achievement of SB 375 GHG Targets | We kindly request that the Regional Transportation Plan Guidelines include a requirement to comply with the Climate Action Plan for Transportation Infrastructure (CAPTI). CAPTI lists the transportation strategies that will allow California to get closer to meeting our climate change and air quality mandates set by the Legislature, Governor Newsom, and CARB’s Scoping Plan. By making sure that all projects in California help advance the same goals, we can make progress in achieving those goals. Additionally, the recently released California Transportation Plan Guidelines also state that the updated plan needs to align with CAPTI. We believe this requirement should extend to the RTP Guidelines as well. We also ask that the RTP Guidelines emphasize the need to limit the number of VMT-increasing projects proposed and constructed by MPOs and RTPAs. Projects that reduce vehicle miles traveled (VMT) have been shown to reduce GHG emissions and air pollution, and improve public health. Aside from environmental benefits, VMT reduction can also reduce the number of car crashes, congestion, and road deterioration. We ask that the RTP Guidelines require the final RTP to list the total VMT impact of the projects included in the plan and explain how the plan will contribute to the 25% VMT reduction goal set by CARB’s Scoping Plan. For projects that would result in an increase in VMT, we ask that the local agencies consider all VMT mitigation alternatives. These additions would help provide information on how each region is contributing to the VMT reduction goal and would encourage local agencies to consider all alternatives before approving a VMT-increasing project. We ask that the RTP Guidelines promote VMT reduction to help us reach our climate goals and to create a sustainable transportation system that is accessible to all. Thank you. | Thank you for your comment. | Complete | Climate Change & Environment | |||||
| 45 |
| Caltrans | Other Subheading | Consider Taking out FAST Act and replacing with IIJA. We should take out all reference to reauthorization. Keep the USC and it will automatically update. | Thank you for your comment, we will make the necessary updates. | Complete | ||||||||
| 46 |
| OPR | Adaptation Chapter | Chapter 6 RTP Contents | 6.29 Adaptation of the Regional Transportation System to Climate Change | Possible MPO case studies for adaptation section: MTC https://resilientca.org/case-studies/Accelerating-Implementation-Local-and-Regional/ https://resilientca.org/case-studies/Dumbarton-Bridge-Communities-Resilience-Study/ SANDAG https://resilientca.org/case-studies/regional-collaboration-transportation-system/ SCAG https://resilientca.org/case-studies/southern-california-regional-climate-adaptation/ SACOG https://resilientca.org/case-studies/transportation-project-level-climate-adaptation/ AMBAG https://resilientca.org/case-studies/central-coast-highway-1-climate-resiliency/ FCOG https://resilientca.org/case-studies/Fresno-County-Regional-Transportation-Network/ SBCAG https://resilientca.org/case-studies/santa-barbara-county-multi-modal-transportation/ https://resilientca.org/case-studies/Ventura-County-Transportation-Commission-and-San/ HCAOG https://resilientca.org/case-studies/Sea-Level-Rise-Adaptation-Plan-for-Humboldt-Bay/ https://resilientca.org/case-studies/battery-electric-fleet-feasibility-assessment/ | Thank you. We have included some of these case studies as planning practice examples. | Complete | Climate Adaptation | |||||
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| Caltrans | 112 | Chapter 5 RTP Environmental Considerations | 5.4 Key Resource Areas for Avoidance and Mitigation | Please look at link and fix if need. I can't get it to work. | Thank you. The link will be updated. | Complete | Environmental | |||||
| 48 |
| Caltrans | 113 | Chapter 5 RTP Environmental Considerations | 5.4 Key Resource Areas for Avoidance and Mitigation | It would be helpful to provide a link to the coastal commission under the following text: "For RTPs in the coastal zone, the environmental analysis conducted during the planning process for projects should also include an evaluation of consistency with the California Coastal Act and applicable certified Local Coastal Programs." https://www.coastal.ca.gov/maps/lcp/ --- or something that lets them who they may need to contact. | Thank you. The link will be considered for this section. | Complete | Environmental | |||||
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| Santa Cruz County Regional Transportation Commission | 29 | Chapter 2 RTP Process | 2.3 Promoting Public Health and Health Equity | 1. General comment for section 2.3: since in other sections the guidelines reference social equity, consider having this section also cover both health equity and social equity. 2. Include CBOs in the fourth sentence of the first paragraph. 3. Please consider including in Appendix E not only a summary of what’s been in past RTPs, but also best practices of implementation (since a lot of equity work has taken place in some jurisdictions since the last RTP came out). | 1. Section 2.3 Promoting Public Health and Health Equity relates to California legislative mandates set forth by AB 441. Since there is no legislation for social equity at this time, the topic is discussed in other sections. 2. "CBOs" have been added. 3. In Progress. Additional examples of best practices are welcome. | Complete | Equity, Engagement, & Health | |||||
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| Santa Cruz County Regional Transportation Commission | 45 | Chapter 2 RTP Process | 2.9 IIJA Housing Coordination Plan | 1. Housing Planning section general comment: Incentivize TOD in the Housing Coordination Plan, and include an equity metrics section when identifying goals 2. Recommendations (Should) section: Clarify the "should" when some of the IIJA housing coordination already is included in the RTP SCS to avoid overlap/duplication. When determining if an MPO "should" conduct a housing coordination plan, what are some of the factors to consider when making this decision? | This comment will be considered by the Housing workgroup. | Complete | Housing | |||||
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| Santa Cruz County Regional Transportation Commission | 81 | Chapter 4 RTP Consultation and Coordination | 4.1 Consultation and Coordination | Consider including CBOs in the first sentence of the third paragraph. | Thank you. CBOs will be included. | Complete | Housing | |||||
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| Santa Cruz County Regional Transportation Commission | 167 | Chapter 6 RTP Contents | 6.25 SCS Development | 1. Considering Social Equity in the SCS section: It would be helpful to see examples of visioning tools that enable the public and policy makers to clearly understand social equity impacts of scenarios. 2. Considering Social Equity in the SCS section: Add “but are not limited to” to the 5th sentence. | This comment will be considered by the Equity workgroup. | Complete | Equity, Engagement, & Health | |||||
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| Caltrans | 99 | Chapter 4 RTP Consultation and Coordination | 4.9 Native American Tribal Government Consultation and Coordination | It would be good to possibly add within Section 4.9, Page 99 under State Requirements a Director’s Policy (Director's Policy – 19: Working with Native American Communities) https://dot.ca.gov/-/media/dot-media/programs/environmental-analysis/documents/env/ex-3-6-dp-19-a11y.pdf | Thank you for your comment. Director's Policies do not apply to MPOs. | Complete | Equity, Engagement, & Health | |||||
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| AMBAG | General Comment | AMBAG appreciates the opportunity to participate in the RTP subgroups, however the release of the various drafts/versions of proposed changes and the timing of the public review period has been confusing and staff intensive. AMBAG requests that the 2023 Second Draft California MPO RTP Guidelines scheduled for release in October 2023 include a version that includes ALL edits and proposed changes to the RTP Guidelines in tracked changes. This will allow AMBAG staff to review all changes to the approved 2017 MPO RTP Guidelines. | Thank you. Changes to the existing RTP Guidelines are reflected in purple text. | Complete | ||||||||
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| AMBAG | General Comment | New sections/additions to the RTP Guidelines should be included in a way that makes it clear to MPOs how it should be incorporated into their RTPs. For example, Section 2.9 Housing Coordination Plan, provides information, direction, and the statute reference. However, Section 6.29 Climate Adaptation and Resilience Policy Landscape, provides good background information but it does not reflect how this should be incorporated into the RTP. | This comment will be considered by the Climate Adaptation workgroup. | Complete | Climate Adaptation | |||||||
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| CARB | General Comment | 1. Strengthening the connection to transportation, land use planning, and VMT/ GHG reduction actions in the Scoping Plan. 2. Clarifying and strengthening how the SB 375 program works, consistent with SB 375 Statute, the SCS Guidelines, SB 150 Report, and current planning practice. 3. Encouraging consistent methodology for reporting project investments and revenue assumptions (including pricing strategies) and encourage reimagining the project selection process. 4. Clarifying and encouraging improved modeling, including input data, modeling processes, model validation and calibration. 5. Supporting and advancing equity and engagement | These comments will be considered by the appropriate workgroups. | Complete | ||||||||
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| Coalition for Clean Air | General Comment | We would like to take these public engagement strategies a step further and ask that a strategy be added encouraging MPOs to provide financial compensation. We would also like to suggest a public engagement strategy that asks MPOs to publish a list of comments that were brought up by the community during the public engagement process and a response from the MPOs on how those comments were addressed. For these reasons, we ask that the RTP Guidelines include the following VMT-reducing strategies. 1) Limiting the number of VMT-increasing proposed projects, 2) Listing cumulative VMT impacts for projects proposed in the RTP. We recommend that MPOs identify opportunities to eliminate GHG and air pollutant emissions wherever possible. | These comments will be considered by the appropriate workgroups. | Complete | Equity, Engagement, & Health Freight & Economic Development GHG/SCS | |||||||
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| Disability Right California | General Comment | The RTP Guidelines should include all applicable anti-discrimination laws in its list of state and federal requirements. Where the RTP Guidelines discuss public participation, it should provide specific guidance on inclusion and access for people with disabilities. To maximize public participation in the RTP process, the Guidelines should highlight the importance of accessibility and inclusion in community engagement activities. Where the RTP Guidelines discuss active transportation, the language used should be inclusive of the disability community. | These comments will be considered by the appropriate workgroups. | Complete | ||||||||
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| HCD | Chapter 4 RTP Consultation and Coordination | 4.3 Social Equity Factors | MPOs should leverage the public participation process to identify strategies for promoting social equity factors in the RTP/SCS, including those related to affirmatively furthering fair housing (AFFH). State law requires that all public agencies affirmatively further fair housing by taking meaningful actions to foster inclusive communities free from barriers that restrict access to opportunity based on protected classes (Gov. Code, § 8899.50, subd. (a)(1)). One component of AFFH is promoting the transformation of racially and ethnically concentrated areas of poverty (RECAPs) into areas of opportunity. MPOs should consider how transportation investments can be used to meet the existing needs of low-income residents living in RECAPs. For instance, MPOs may be able to leverage policies that promote transit, bicycling, and walking to transform RECAPs into areas of opportunity. Further, MPOs should also consider how to avoid or mitigate the harmful effects of transportation investments in historically disadvantaged communities, such as air and noise pollution. Additionally, MPOs should consider how transit investments can be used to increase access to existing high resource areas. Lastly, MPOs should consider how to develop accessible transportation options that increase opportunity access for protected classes, including those with disabilities. | Thank you this language has been included. | Complete | Housing | ||||||
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| HCD | Chapter 6 RTP Contents | 6.1 Summary Of RTP Components | I think this is the wrong GC reference. 65584.04(i)(1) discusses the process by which COGs can incorporate HCD's feedback on the allocation methodology. The section of statute that requires consistency is 65584.04(m)(1). (m) (1) It is the intent of the Legislature that housing planning be coordinated and integrated with the regional transportation plan. To achieve this goal, the allocation plan shall allocate housing units within the region consistent with the development pattern included in the sustainable communities strategy. | Thank you. This citation has been updated. | Complete | Housing | ||||||
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| HCD | Chapter 6 RTP Contents | 6.25 SCS Development | In addition to allowing the region to meet its GHG emission reduction targets, the forecasted development pattern should provide consistency with the regional housing allocation and further the five statutory objectives of RHNA listed in GC Section 65584(d). | Thank you this language has been included. | Complete | Housing | ||||||
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| SCAG | 161, 182, 202/210, 213, 220 | Other Heading | Other Subheading | Good afternoon, Here are a handful of additional suggested edits from SCAG staff in advance of the October 6 draft release. Thank you for your consideration. • Page 161 on amending RTPs to include State-sponsored rail projects. Consider adding language encouraging Caltrans and/or other State agencies developing intercity passenger rail and freight rail projects to engage with MPOs to align with applicable RTP adoption and amendment schedules, including deadlines for project submittals for incorporation in transportation conformity analysis. • Pg. 182, amend the text to read: "Planning assumptions must satisfy all applicable requirements of the U.S. EPA’s Transportation Conformity Regulations and Guidance for the Use of Latest Planning Assumptions in Transportation Conformity Determinations, and should be based on local data and should include land use, zoning, RHNA and Housing Element inputs.” • Pages 202 and 210, clarify if references to STIP here should be FSTIP. May also appear in other locations where direct application of federal STIP language was added. • Page 213, recommend change from “MPOs shall provide an analysis to Caltrans that demonstrates how the portfolio of projects proposed to be included in the RTP makes progress on meeting federal and state performance management goals and targets…” to “MPOs should provide an analysis to Caltrans that demonstrates how the portfolio of projects proposed to be included in the RTP makes progress on meeting federal and state performance management goals and targets…” as it is unclear where this suggested new requirement originates and assumes a significant new oversight role by Caltrans. • Page 220 Regional Transportation Plan Contents – consider changing the “Yes/No” to “Yes/No/N/A”. For example, item 7c on page 221 would be not applicable if a MPOs did not voluntarily elect to development multiple scenarios and programming/operations items 3 and 4 on page 225 should recognize that an unconstrained project list is not a required RTP element. | Thank you for your suggested edits, the will be considered in the third draft. | Complete | None | |||||
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| CA Dept of Public Health | 30-33; 250-255; 267-274; 282 | Appendix K: Promoting Health and Health Equity in MPO RTPS | 2.3 Promoting Public Health and Health Equity | Comments and tracked changes can be found in Section 2.3, Appendix E:Promoting Health and Health Equity in MPO RTPs, and Appendix F in the attached Word document. | Thank you for your comments. Suggested revisions were incorporated throughout the document where appropriate. Notably, the use of "biking" to be more inclusive, updates to the C-PHAM section, and adding CDPH Climate Change and Health Vulnerability Indicators for California (CCHVIs as a resource. | Complete | Equity, Engagement, & Health | |||||
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| MTC/ABAG | 260 | Appendix E: Integration of the Planning and NEPA Processes | Other Subheading | The text about OBAG 2 should be updated to OBAG 3, as follows. “The MTC One Bay Area Grant (OBAG 3) Program provides funding opportunities for jurisdictions in the nine-county Bay Area region to invest in Safe Routes to School (SRTS) projects. The OBAG 3 program prioritizes SRTS projects and non-infrastructure programs, with a minimum regional investment target of $6 million per year. The adopted OBAG 3 program invests more than twice this target amount, with over $14 million directed to SRTS projects and programs per year, on average. It should be noted that this example is unique to a large urbanized MPO with substantial discretionary funding sources. Not all regions have the fiscal resources to undertake this type of program.” | Thank you for your comment. | Complete | None | |||||
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| SBCAG | Chapter 1 Introduction Chapter 2 RTP Process Chapter 6 RTP Contents Chapter 7 Transportation Performance Management | See attached comment letter. | Thank you for your letter. CARB participated in providing comments on Section 2.10. SBCAG has been listed as an MPO & COG region in Section 6.24. We worked to make these guidelines as concise as possible and the 2024 version is ~50 pages shorter than the previous version. | Complete | ||||||||
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| City of Palmdale | See attached comment letter. | Thank you for your letter. | Complete | |||||||||
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| AMBAG | Appendix A: RTP Checklist Chapter 1 Introduction Chapter 2 RTP Process Chapter 3 RTP Analysis and Modeling Chapter 4 RTP Consultation and Coordination Chapter 5 RTP Environmental Considerations Chapter 6 RTP Contents Chapter 7 Transportation Performance Management | See attached comment letter. | Thank you for your letter. We considered each of the specific suggested revisions in our final draft. Namely, we revised sentences and graphics for clarification and to be in line with statutory requirements. The RTP Checklist which is a reporting tool used by Caltrans has been revised to indicate that agencies should utilize the list as applicable to them. | Complete | ||||||||
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| SCAG | See attached comment letter. | Thank you for your comment letter. | Complete | |||||||||
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| SLOCOG | Chapter 1 Introduction Chapter 2 RTP Process Chapter 4 RTP Consultation and Coordination Chapter 6 RTP Contents | See attached comments. | Thank you for your comments. We considered your suggestions and made efforts to update language where possible. | Complete | ||||||||
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| Coalition for Clean Air | Chapter 4 RTP Consultation and Coordination Chapter 5 RTP Environmental Considerations Chapter 6 RTP Contents | See attached comment letter. | Thank you for your comment letter. We have conidered your suggestions for VMT, Public Engagement and Freight. We have included specific language to section 6.12 to align with the CA Freight Mobility Plan. | Complete | ||||||||
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| CALCOG | General Comment | See attached comment letter. | Thank you for your comment letter. We made efforts to add clarifying language regarding RHNA. | Complete | ||||||||
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| OCTA | Appendix A: RTP Checklist Appendix D: Glossary of Transportation Terms Chapter 1 Introduction Chapter 3 RTP Analysis and Modeling Chapter 4 RTP Consultation and Coordination Chapter 5 RTP Environmental Considerations Chapter 6 RTP Contents Chapter 7 Transportation Performance Management | See attached comment letter. | Thank you for your comment letter. Notably, we changed the use of TDM throughout the document to avoid confusion and we implemented your suggestions to Sections 1.1, 5.0, 6.12, and Appendix A & D. | Complete | ||||||||
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| CA Coastal Comission | Appendix F: Climate Adaptation Tools & Resources Chapter 5 RTP Environmental Considerations | See attached comments. | Thank you for your suggestions, these revisions have been incorporated in the final draft. | Complete | ||||||||
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| NCTC | Appendix A: RTP Checklist Appendix B: Air Quality Conformity Checklist Appendix C: RHNA and RTP Development Information Appendix D: Glossary of Transportation Terms Appendix G: Planning Practice Examples Chapter 1 Introduction Chapter 2 RTP Process Chapter 4 RTP Consultation and Coordination Chapter 5 RTP Environmental Considerations Chapter 6 RTP Contents Chapter 7 Transportation Performance Management | See attached comment letter. | Thank you for your comment letter. We have incorporated suggestions throughout the final draft of the RTPA version. We have included NCTC as a planning practice for Emergency Planning. | Complete | ||||||||
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| MTC/ABAG | General Comment | See attached comment letter. | Thank you for your comment letter. The use of “shall” on page 11 has been updated to "should". | Complete | ||||||||
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| SANDAG | Chapter 1 Introduction Chapter 2 RTP Process Chapter 3 RTP Analysis and Modeling Chapter 4 RTP Consultation and Coordination Chapter 5 RTP Environmental Considerations Chapter 6 RTP Contents Chapter 7 Transportation Performance Management | See attached comments. | Thank you for the specific line item comments. Efforts have been made to incorporate suggested revisions and new content where appropriate. | Complete | ||||||||
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