| Agency | Page Number | Chapter | Section | Comment | Response | Status | |
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| 1 | Coalition for Clean Air, Active San Gabriel Valley, Move LA, Safe Routes Partnership, Climate Plan, and Planning and Conservation League | 37 | General | While we strongly support the public engagement process conducted for this round of CTP Guidelines updates, we would like to see an improved public engagement process during the development of the California Transportation Plan itself. Would be some sort of compensation to attendees to incentivize members of lower income communities to attend workshops without the concern of adding additional financial hardship. We would also like to see a stronger consideration for how transportation investments are advancing equity goals such as Justice40. The CTP Guidelines can be utilized to echo this priority by requiring that state transportation agencies advance Justice40 goals in state transportation investments and disaggregate estimated impacts and outcomes by race, ethnicity, and income. | We agree the CTP will require a more robust engagement effort when compared to the guidelines update. Within the guidelines on page 35 we include the following text “The methods utilized should ensure the ability to engage the public – including: low-income people, people of color, underserved populations, persons with disabilities, youth, and the elderly.” We will further define outreach methods within the Public Participation Plan (PPP). There is also more on Justice40 on page 40. The PPP is our federally mandated plan that defines what successful implementation for the CTP will include Justice40. | Addressed | |
| 2 | Coalition for Clean Air, Active San Gabriel Valley, Move LA, Safe Routes Partnership, Climate Plan, and Planning and Conservation League | 30 | General | We are very thankful for the strong sustainability considerations included in the guidelines update, such as requiring the reduction in GHG emissions and vehicle miles traveled (VMT) to meet the targets outlined in the California Air Resources Board's Scoping Plan and for the requirement to align the plan with the principles stated in the Climate Action Plan for Transportation Infrastructure (CAPTI). And while we appreciate the change to add criteria air pollutants to the list of quantitative metrics for the technical analysis, we would also want to see agencies further consider cumulative pollution burdens in their analysis and planning. Specifically, we would like the guidelines to include a consideration that transportation projects should not lead to an increase in air, water, noise, or light pollution, especially for disadvantaged communities. As transportation funding in California continues to fluctuate, it is more important than ever to ensure that we are funding the right priorities. If we are to achieve the climate targets set by the CARB Scoping Plan and SB 32 (2016), we must begin prioritizing projects that decrease greenhouse gas and air pollutant emissions and disincentive those that contribute to climate change and poor air quality. Thus, we would like to see the CTP Guidelines consider decreasing funding for highway capacity expansions and proportionately increasing funding for transit, bicycling, walking, and zero-emission charging and fueling projects. We also, critically, would like to see more maintenance funding leveraged to support complete street redesigns. Finally, we request that the state makes a concerted effort to align its own performance metrics with similar metrics used to evaluate local governments, MPOs, and transit agencies. While the state has made some progress with the development and implementation of CAPTI, we often see local agencies and districts struggling to follow suit. If we are to ensure that state and regional actions are aligned, it's imperative that all levels of government are coordinated in their efforts. For example, if the state is expecting transit agencies to be working to increase transit ridership, then state and local governments should also be committed to, incentivized to, and evaluated against their ability to do the same. This could be fleshed out in the context of state goals and associated performance metrics in the California Transportation Plan Guidelines and the final CTP. | We agree that future transportation projects should limit (or reduce/mitigate existing) negative impacts especially when considering disadvantaged communities. Guidance on how this should be accomplished will need to be formulated through the Policy Advisory Committee, as all transportation projects have the potential to generate negative impacts, and thus any criteria developed in the plan needs to include a comprehensive consideration of multiple factors. We’ve added the following language to illustrate this Policy within the “CTP should strive to limit new burdens and mitigate or eliminate existing burdens on underserved and disadvantaged communities.” 1) Recommended funding changes: Any changes to funding should be discussed as part of the findings of the fiscal analysis. 2) Aligning performance measures with partner agencies: This is an interesting inclusion for the guidelines. We'll need to research specific performance metrics, but we can include best practice language for aligning. This would be consistent with legislative direction for the plan. Added on PG 30 | Addressed | |
| 3 | Coalition for Clean Air, Active San Gabriel Valley, Move LA, Safe Routes Partnership, Climate Plan, and Planning and Conservation League | 27 | Our vision for the fiscally constrained element would resemble a short-term implementation plan that looks at the recommendations proposed in the final CTP and determines the steps to achieve them | This is already accomplished as part of the CTP Recommendations Element. Each Recommendation has discrete actions to be implemented during the CTP 2050’s 5 year lifespan. | Addressed | ||
| 4 | Coalition for Clean Air, Active San Gabriel Valley, Move LA, Safe Routes Partnership, Climate Plan, and Planning and Conservation League | 40 | We believe this is backed by the AB 285 report which states that “describing who was expected to take action, when, and with which resources would allow plan efficacy to be tracked and evaluated.” This would mean taking a more detailed approach to provide clear guidance to agencies, private partners, and advocates for how we are to achieve the goals outlined in the CTP. | The CTP 2050 included an implementation element that identifies partner agencies involved with implementation actions. In August we’ll be presenting an updated report and dashboard that further outlines progress made in implementing the CTP Recommendations. | Addressed | ||
| 5 | Coalition for Clean Air, Active San Gabriel Valley, Move LA, Safe Routes Partnership, Climate Plan, and Planning and Conservation League | General Comment | While we understand that the CTP has several limitations, including the inability to propose and list specific projects, we nonetheless believe that the guidelines can still be used to help accelerate the transition of California’s transportation investments toward improving safety, accessibility, equity, and climate resiliency across the state. Thus, we request that the California Transportation Commission take another look at how the fiscally constrained element is to be developed and used, and amend the language to reflect the need for a short-term focused plan designed to help meet the financial requirements to implement the recommendations set in the California Transportation Plan Guidelines. | The CTP is legislatively mandated to act as a minimum 20 year plan. All recommendations made are designed to function over the 5 year lifespan of the plan while making progress towards the 20 year goal. | Addressed | ||
| 6 | Disability Rights California | General | General Comment | The Problem: CTP 2050 fails to identify and respond to the most pressing transportation needs of the disability community. Solution: The CTPs’ discussion of the transportation needs of people with disabilities can be improved by revisions to the Guidelines. | Added section in CTP Topics for Discussion | Addressed | |
| 7 | Disability Rights California | General | General Comment | A) The Guidelines should include state and federal accessibility and non-discrimination requirements beyond Title VI of the Civil Rights Act. | Added in Appendix B | Addressed | |
| 8 | Disability Rights California | 12 | 3 CTP Content and organizational structures | General Comment | B) The Guidelines should expressly discuss the legislative intent of Government Code section 14000(c) in Section 3 of the Guidelines. | Added reference | Addressed |
| 9 | Disability Rights California | General | General Comment | C. The Guidelines should note the lack of current, comprehensive data on transportation for people with disabilities and identify it as an area for further study | Response captured for CTP | Addressed | |
| 10 | Disability Rights California | General | General Comment | D. The Guidelines should provide clearer direction to staff on how to conduct equitable, accessible outreach to communities who do not currently have a relationship with Caltrans. | Response forwarded to Equity Environment and Health branch for inclusion in Public Participation Plan. | Addressed | |