The California Bicycle Coalition has submitted two letters to the Strategic Growth Council with feedback on their proposed guidelines for administering the $130 million “Affordable Housing and Sustainable Communities” grant program. The program is intended to support measures that reduce greenhouse gas emissions by reducing vehicle miles traveled and could play an important role in funding the infrastructure improvements we need to enable more bicycling throughout California.
One of our letters was submitted in coalition with other active transportation organizations. That letter is posted here. The other letter was submitted by us to clarify and expand on some of the points in the first letter. That letter is posted here, and included below:
October 31, 2014
Ken Alex, Chair
Strategic Growth Council
Sacramento, CA 95814
Re: California Bicycle Coalition recommendations on the AHSC Program Guidelines
Dear Mr. Alex,
On behalf of our membership and affiliates’ membership of more than 30,000 bicycle advocates across California, we are writing to comment on the guidelines for the Affordable Housing & Sustainable Communities greenhouse gas reduction program. We are excited about this program. We know that making our communities less dependent on automobile transportation will have cascading effects leading to vastly more sustainable communities and healthier, happier Californians. We support Vehicle Miles Traveled (VMT) reduction as the primary greenhouse gas (GHG) reduction strategy for the AHSC Program.
We applaud the work of the SGC staff in getting us so far toward a great program. We appreciate the opportunity to provide this feedback on the program guidelines. We reaffirm the comments we made as part of the Coalition on Active Transportation Leadership (CATL) in its Oct 22 letter. We submit these comments as further clarification and refinement, especially with regard to the bicycle-related portions.
The following are suggestions for changes to the scoring criteria.
- The first threshold requirement of ICP projects should not limit projects to those that increase transit use. An project that only increases walking and biking might help meet the goals of the AHSC program better than any other project but would be inelgible as the guildelines are currently drafted. Please change this threshold requirement.
- Section 107 (e)(4) provides bonus points to projects that implement an element of a bicycle or pedestrian master plan. However, the AHSC will be stronger if projects are required to implement elements of such plans. Please refer to our comments in the CATL letter.
- Section 107 (i) limits allowable parking to reasonable levels for most locations, but some locations in California impose even stronger limits. The AHSC guidelines should not provide bonus points to projects that provide parking in excess of the amount allowed in a jurisdiction, so this guideline should be revised to refer to the proposed limits or the maximum allowable parking according to local zoning, whichever is lower.
- Section 107 (k) gives bonus points for bicycle features. This section should be reorganized in order to more effectively enable more bicycling.
- The single most important factor in the ability of people to bike is the degree to which their destinations are connected to each other via low-traffic-stress streets. The methodology to evaluate the degree of traffic stress is not complicated and widely available and could be employed to evaluate whether a project is located on a bicycle-friendly network of streets. Such a methodology is vastly superior to a simple measurement of miles of bike lanes and paths because a housing project or qualifying transit station could be surrounded by bike lanes but separated from them by dangerous high-traffic streets or intersections. We would be more than happy to meet with staff to help you devise an easy way of evaluating the bicycle-friendliness of a project and project area. This connectivity issue should be prioritized with the most points in the scoring matrix. Projects should get even more credit for contributing to improvements in connectivity.
- The next most important issue is bike parking. Housing projects should be required to provide secure, indoor, secure bike parking (protecting the bike and its components, such as provided by a bike cage accessed only by residents) at a ratio of 1 space per unit or in accordance with local regulations, whichever is higher. Transit stations should provide bike parking sufficient to meet demand, including a mix of racks and short-term lockers that protect the bike and its components.
- Permitting access to bikes on the transit vehicle should not be an acceptable alternative to secure bike parking as implied by subsection 107(k)1.(A).
- Providing points for the provision of a bike repair kiosk is a great, innovative idea. We would be happy to direct your staff to examples of very simple and affordable bike repair kiosks that provide self-service tools and pumps.
- Points for being in proximity of a bike sharing system should be minimal and limited to bike sharing programs that are accessible to low-income users.
The following are suggestions for changes to the definitions.
- The “First Mile – Last Mile Strategy” definition should clarify the actual distance of trips in miles from a transit station that such a strategy is intended to serve. We support the definition of the Federal Transit Administration which has determined that the most appropriate planning radius for bike improvements is three miles, while for pedestrian improvements it’s a half-mile. Either the guidelines should refrain from using the jargon “first mile-last mile” and simply refer to bicycling and walking improvements a 3- and ½-mile radius of the transit station, or the definition of that straetgy should clarify that it’s really “First 3 Miles – Last 3 Miles” or “First ½-mile-Last ½-Mile.”
- The definition of “complete streets” is too vague. Merely adding a striped bike lane to a high-speed arterial does not make that street a “completely bikeable” street from the point of view of most people. The definition of “complete street” ought to specify low-traffic stress bike routes and safe and comfortable pedestrian conditions.
- The definition of “Active Transportation Program” should be broadened to include encouragement and enforcement programs, not just educational programs.
- The list of economic co-benefits does not include the most important one for the purpose of the AHSC program: reduction in transportation costs due to reduced car use. Its example of reduced-cost transit passes neglects the reality that for many people transit is not a realistic option for their trips, but a bike could be. The list should be revised to add, “increased disposable income for families due to reduced automobile use.” Subsidies for bike purchases should be considered an eligible expense under the program.
Again, we are grateful for this opportunity to provide feedback on the AHSC guidelines. Please don’t hesitate to call me to follow up on any of these suggestions, or if you have questions about them.