SBCCOG Strategic Growth Council comments on their Affordable

20285 S. Western Ave., #100
Torrance, CA 90501
(310) 371-7222
[email protected]
October 31, 2014 through SGC web comment portal by:
SBCCOG Research Director Walter Siembab
Receipt acknowledged by:
Allison S. Joe, AICP| Deputy Director
California Strategic Growth Council
1400 Tenth Street - Sacramento, CA 95814
[email protected] (o) 916-341-7371
Re: Comments by the South Bay Cities Council of Governments (SBCCOG) on the Strategic
Growth Council Affordable Housing and Sustainable Communities (AHSC) Draft Guidelines
The AHSC Draft Guidelines reflect a great deal of creative staff work. Thank you for the opportunity to
The SBCCOG has a big picture concern. The draft program alternatives for achieving carbon reductions
are narrowly confined to walking, cycling, and transit mobility options supported by increased
residential density, especially through TOD. While these may be traditional elements that lead to carbon
reduction, defining eligibility for grants only in those terms excludes more recent, innovative strategies
that fit more of the varied contexts found throughout California.
The South Bay of Los Angeles County includes 15 incorporated cities plus parts of both the City and
County of Los Angeles. The area is about the size of Portland with 1.5 times Portland’s residential
density and without a central city and the extensive public transit system. The Metro light rail system
(Green Line) runs along the South Bay’s northern border with only an insignificant extension planned
through 2035. Bus service is relatively poor and as a result public transit has only a 2.8% mode share.
Cycling mode share is around 0.8%. This despite relatively high residential densities organized in what
are essentially horizontal mixed-use neighborhoods.
The result of the extensive mixed-use development pattern is that most trips are too far to walk and too
short for transit. Adding density to an already dense sub-region will only generate more congestion since
even 100% increases in transit use and biking would still leave private vehicles with over 90% mode
Recognizing that the goal of zero emission mobility would not be achieved by the density-transit
strategy, the South Bay Cities Council of Governments began a research program in 2004 in order to
find an alternative. The Sustainable South Bay Strategy (SSBS) was the result -- completed in 2009 and
adopted by the SBCCOG Board in 2010.
El Segundo Gardena Hawthorne Hermosa Beach Inglewood Lawndale Lomita
Manhattan Beach Palos Verdes Estates Rancho Palos Verdes Redondo Beach Rolling Hills
Rolling Hills Estates Torrance Los Angeles District #15 Los Angeles County
The land use component of the SSBS is known as Neighborhood Oriented Development (NOD) and it
involves developing compact commercial centers within ½ mile of every home and gradually replacing
existing strip commercial with residential at densities compatible with adjacent neighborhoods. This
adds housing without increasing average residential density.
The mobility component of the SSBS involves introducing zero emission local use vehicles for those
trips that are too long to walk and too short for transit. 80% of trips are less than 3 miles. A mobility
services bundle (car sharing, ride sharing, van pools, bike sharing, and some form of public transit such
as DASH or DART services) are expected to reduce the number of vehicles per household and substitute
low carbon trips for high carbon trips.
Beyond the research that produced the SSBS, the SBCCOG has demonstrated the viability of the
mobility and land use components in a series of demonstration projects. They include a neighborhood
electric vehicle demonstration project (Local Use Vehicles: The Missing Mode in Sustainable Mobility),
a battery electric vehicle demonstration project (Drive the Future) both funded by the SCAQMD; NOD
proof of concept economic simulation funded by SCAG; and a PEV readiness plan funded by the CEC.
In all, over $2 million have been invested by SCAG, Metro, SCAQMD the CEC and the SBCCOG in
developing and demonstrating in the South Bay an alternative strategy to density -transit. Most mature
suburban sub-regions throughout California have development patterns and auto dependent mobility
similar to the South Bay. Density-transit as the sole basis for funding excludes many sub-regions.
In general, the SBCCOG urges that the SGC expand the funding criteria to include more options beyond
walking, cycling, transit and TOD, so long as the alternative strategy will lead to affordable housing and
carbon reduction.
A core issue is the reliance on VMT reduction as the sole metric linked to GHG emissions reduction.
From the South Bay perspective, total VMT is too coarse a metric. We break it down into tail pipe
VMT, pedal VMT and electric VMT. We want to minimize tail pipe VMT and increase the other two.
Our position is also consistent with the fact that 100% of vehicles sold in Southern California by 2025
will need to be zero emission in order for the region to meet federal air quality standards. Using total
VMT as the primary metric in the AHCS program fails to encourage progress toward the very real need
to encourage ZEVs in as many applications as possible.
A few examples of specific language changes that would follow from our general comments should help
illustrate the point:
A statement like “projects must demonstrate GHG reductions that focus on VMT reductions” should be
replaced by “projects must demonstrate GHG reductions that focus on reducing tailpipe VMT.”
Lists of eligible modes should be expanded by including Zero Emission Vehicles of any type, especially
those that are slow speed and short range.
Where investments in transportation & transit-related infrastructure are limited “to enhance: public
transit and pedestrian or bicycle access between transit station, housing and key destinations,” eligibility
should be expanded to transportation infrastructure that “enhances public transit, pedestrian, bicycle or
ZEV (including slow speed short range ZEVs) between all origins and destinations.”
References to TOD should be amended to also include neighborhood oriented development (NOD) or
other development patterns that support walking, pedal technologies and ZEVs including slow speed,
short range vehicles.
The definition of high quality transit corridors is too loose to offer guidance for affordable housing
development. A corridor with a single bus line that meets the fifteen minute peak-headway standard
does not justify building additional density. We have found that in most cases of HQTC in the South
Bay, the off-peak service levels are very poor and in many cases there is no evening or weekend service
whatsoever. Because of this permissive definition, about 70% of the major arterials in the South Bay
currently qualify as high quality transit corridors yet there is very little of actual high quality transit. And
mode share is stuck at 2.8% with little promise of improving. Additional density will reduce very little
carbon but will surely increase congestion.
In conclusion, the Draft Guidelines fail to recognize innovative strategies developed in areas where
transit does not now nor will in the future play a significant role providing mobility. Those areas deserve
access to funding for affordable housing as long as some form of zero emission mobility can satisfy the
travel demands created by the new housing development.
These few comments on the Draft Guidelines have been made from the perspective of the South Bay
Cities Council of Governments and its Sustainable South Bay Strategy. The various research and
demonstration reports upon which the SSBS is based are available at The
SBCCOG will be happy to work with SGC staff in order to identify ways for incorporating the SSBS
into the Guidelines.