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��� � � � � � � 11/18/2013 <br /> IfUHI .!a 11�t„����� N i' "�,� <br /> WORLD•CLAI!►YYLIC TRANS/dRTATlON.NfALKA\L!COMNUNITIii. <br /> February 24, 2012 <br /> CEQA Guidelines Update <br /> c!o Christopher Calfee <br /> 1400 Tenth Street <br /> Sacramento, CA 95814 <br /> Re:Camments re CEQA Streamlining for Infill Projects (SB 226) <br /> Dear Mr. Calfee: <br /> Thank you for the opportunity to comment on the proposed guidelines for implementatian of Senate <br /> Bill 226 ("Proposed CEQA Guidelines"). This letter autlines aur major areas af support and concern <br /> with regard to the draft guidelines. We appreciate the opportunity to provide early input and we plan <br /> to continue refining these recommendations. <br /> Comments an Appendix M: Per�ormance Standards <br /> 1. Regional Vehicle Miles Traveled (VMT) is the correct framewark. <br /> We support the use of VMT as the primary metric far evaluating a project's eligibility for streamlining. <br /> Using Traffic Analysis Zones (TAZs) and comparing these to regional average VMT is a <br /> straightforward way to quickly identify areas that are appropriate for ir�ill development. As the draft <br /> proposal recognizes, even certain prajects in higher-VMT zones can reduce their VMT through <br /> project design elements, such as by praviding campact design, free transit passes or ur�undled <br /> parking. <br /> 2. Eligible r�idential projeats should be in very low VMT lacatians, or reduce their VMT to <br /> 75% or less of average VMT. <br /> SB 226 should not inadvertently increase VMT, but that is a possibility with the dr�ft guidelines. <br /> Projects that are in TAZs with per capita VMT levels that are 100%or more than the regional average <br /> should not be eligible for SB 226 benefits. <br /> SB 22B explicitly establishes as among its goals the"implementation of the land use and <br /> transportation palicies in the Sustainable Communities and Climate Protectian Act of 2008 (SB 375)" <br /> and the "reduction of greenhouse gas emissions under the California Global Warming Solutions Act <br /> af 2006 (Divisian 25.5, commencing with Section 3850�, of the Health and Safety Code) [AB 32]."' <br /> The transportation and land use sector is respansible for nearly 40%of the state's GHG emissions.2 <br /> This sector is the largest source of GHG emissions in the state. Policy reforms such as SB 226 which <br /> are aimed at furthering the gaals of AB 32 or SB 375 in the transpartation and land use sectar must <br /> not be allowed tn encourage or facilitate above average driving rates. These outcomes wauld run <br /> ' California Public Resources Code,Ch.469,SEG.7,Sec6on 21094.5.5(b) <br /> 2 See Clrmate Cha e " Plan, Air Resources Board 2008 and firxii s in Senate Bill 375 of 2008 <br /> • . <br /> 1 RESO.#15305 <br /> MUFF#603 <br />