If, as the adage goes, it's impossible to tell the dancer from the dance, then it might be even harder to tell the SCS from the RTP. 

With perhaps less grace than that of a ballerina, the much-anticipated Sustainable Communities Strategies mandated by Senate Bill 375 are set to become cornerstone of regional planning. And yet, amid Regional Transportation Plans � not to mention regional comprehensive plans, county general plans, transportation funding schemes, and, of course, cities' own general plans � it's hard to tell where a region's own initiative ends and SB 375's mandate begins.

That is the impression given off by the combined draft RTP/SCS that the San Diego Association of Governments released April 22. In accordance with SB 375, the state's 18 metropolitan planning organizations must devise an SCS to demonstrate how they will reduce greenhouse gas emissions through land use and reduction of vehicle miles traveled. SANDAG has been scheduled to release and complete its SCS first. 

The release of SANDAG's draft RTP/SCS therefore marks a highly anticipated juncture in the long saga of reducing California's carbon footprint. The draft RTP/SCS is currently in its 45-day public comment period; a series of seven region-wide workshops is scheduled to begin June 7. SANDAG plans to release the draft environmental impact report for the RTP/SCS in June as well. 

For all the debate surrounding the SCS and its emissions targets, the document that the public will consider during those workshops is relatively thin in light of its statewide significance. It occupies only a single, 77-page chapter in SANDAG's nine-chapter, 313-page draft RTP and summarizes the region's overall growth and transportation strategies. 

Since the SCS is not a plan per se but rather a way of showing that a region can meet SB 375 targets, the SCS chapter deals largely in generalities and goals. It quotes mandates from SB 375 and then explains how the RTP and Regional Comprehensive Plan meet those goals. The remainder of the draft RTP, based partly on existing plans such as the Regional Transportation Improvement Program, and the cities' and county's general plans explain how the region's landscape is actually going to change. 

While the notion of efficiently coordinating transportation, housing, and commercial development across thousands of square miles and millions of people sounds daunting, officials in the San Diego area say that drafting the SCS was not nearly as difficult as it may be for other regions. 

"A lot of the stuff in our plan is not new to us," said SANDAG Executive Director Gary Gallegos. "It's not a huge game-changer because we were already doing a lot of these things because they were good for us." 

The SCS relies on complex forecasts for regional growth--which is anticipated to include a growth in population from 3.2 million to 4.4 million and 400,000 more housing units by 2050--but much of the actual planning work that will contribute to the SCS has already been done. 

Indeed, much of the region's growth is already prescribed and accounted for, some of it before SB 375 was even imagined. 

"San Diego, in spite of the fact that SB 375 and AB 32 came along, was already doing a lot of what was required by those pieces of legislation we had incorporated into our planning," said County Supervisor Ron Roberts, who also is also an ARB board member. "We were already on a course to get to the transportation corridors and move the density from the furthest out areas." 

The California Air Resources Board set per capita emissions reductions targets for the state's MPOs just last October. San Diego's targets are 7% by 2020 and 13% by 2035. 

By now, the methods for reaching such targets have become well accepted throughout the state. Regions are encouraging compact development, beefing up public transit plans, and allocating new housing�according to Regional Housing Needs Assessments�in locations that enable residents to drive less, rather than by spreading housing evenly around a region. San Diego especially is investing in transportation demand management (TDM) strategies such as high-occupancy toll lanes on its freeways. 

A combination of all of these tactics, officials say, will enable the region to meet, or even exceed, its SB 375 targets. Moreover, SANDAG is going beyond 2035 and actually is planning for growth through 2050. 

While this might seem like a bold move, many are not convinced that 40-year projections are even realistic. 

"I'm kind of cynical about how clear the crystal ball is when you get out 15 or 20 years," said Roberts. 

Moreover, even after a lengthy debate at ARB over what would constitute "ambitious but achievable" targets, some say that San Diego's plan is nether ambitious nor achievable. 

"I don't think it hits the mark at all," said Bruce Reznik, executive director of the Planning and Conservation League and former executive director of San Diego's Coastkeeper. "It's kind of funny because I know the San Diego plan is heralded as first out of the gate and a good model." 

Reznik said that SANDAG's SCS has fallen prey to what he described as low expectations fueled by enthusiasm for SB 375. 

"Everyone wants to see 375 be successful," said Reznik. "You pass this law, and (Sen. Darrel) Steinberg and the Legislature and the environmental groups want to see the momentum and see the first one be successful. The problem is you can't lower the bar so much that anything looks like success."

Reznik said that the bar has been lowered by virtue of the RTP's continued emphasis on automobiles in the region. While the plan envisions significant capital investments in infrastructure such as new light rail lines, critics note that the driving force behind the transportation plan still prioritizes roads. 

That driving force is TransNet, a $40 billion sales tax measure passed in 1988 and renewed in 2004 to fund up to $17 billion worth of transportation projects in the region through 2050. Much of that funding is earmarked for road improvements, thus relegating the vast majority of transit projects to a distant, uncertain future. The estimated cost of all the measures envisioned by the SCS is considerably more, however. 

"It's got some good transit measures but the reality is that they're looking to massively fund highway expansion before you ever seen real, meaningful transit adopted," said Reznik. "Yes, there's money for transit down the line, but it's totally speculative." 

The RTP predicts, but does not guarantee, revenues of $196 billion projected out 50 years, with 60% from local sources, 22% from the state, and 18% from the federal government. 

Moreover, sources of funding to operate many of these planned capital investments and service improvements remain discomfortingly unclear. Anderson admitted that the funding for transit operations that would support the SCS are far from secured. 

"Transnet is focused on the capital side, but to get the headways that create a real effective transit system requires operating funds and an affordable price," said Bill Anderson, San Diego's outgoing planning director (see sidebar). 

Fitts said that if San Diego and other cities increase their densities, as planned, then the southern part of the county will become a cauldron of gridlock if transit funding does not materialize. 

"If you don't have robust transit infrastructure, it's going to look like west Los Angeles," said Michael Fitts, staff attorney at the Endangered Habitats League. "It's going to be a nightmare."

Anderson suggested that a current proposal by Gov. Jerry Brown to allow local taxes to pass with a 55% -- instead of two-thirds -- vote could allow cities to create special funding districts to support transit. He also warned that the city should continue to assess impact fees on new development, even though officials might be tempted to lower those fees amid the recession. 

Gallegos said, however, that the RTP does emphasize public transit and takes a new approach to highways by including elements like managed lanes and high-occupancy toll lanes. As well, he said that the inclusion of projected funding as opposed to specific funding sources is nothing unusual for a long-range plan. 

"The plan itself does rely on future revenues, but that's the case in all plans that are put together throughout the state," said Gallegos.

SB 375 was designed largely as a method of encouraging, but not mandating, development that would reduce per capita carbon emissions. Though SCSs are tied to RTPs, which are, in turn, tied to federal transportation funding, the implementation of an SCS ultimately depends on the voluntary participation of member cities�and, less directly, on the enthusiasm of developers to build higher-density projects. In a dramatic shift from past patterns, the SCS, in accord with SANDAG's Regional Housing Needs Assessment, envisions that 87% of new housing will consist of multifamily housing.  

Accepting the new affordable and market-rate housing envisioned by SANDAG's projections is crucial to the plan's success because new housing is expected to not only ease the jobs-housing imbalance within the county, but also between the county and neighboring counties. For instance, many commuters come into the jobs-rich county from housing-rich Riverside County, thus creating long-distance traffic and pollution on a daily basis. 

"Right now San Diego is a jobs safety valve for the housing surplus in Riverside County," said Fitts. 

While new transportation projects that are funded at the county level are likely to be embraced, housing and other improvements at the municipal level may complicate SANDAG's vision. 

"As an MPO, they don't have any land use authority," said Barry Schultz, former chair of the San Diego (City) Planning Commission. "So we're dependent upon the local cities to actually implement the type of land use pattern that is the foundation of the whole SCS." 

In the City of San Diego, the SCS is not expected to be a tough sell. The city encompasses roughly half the region's population and spans roughly as much built acreage as do the cities and unincorporated communities throughout the rest of the county. Therefore, some say, as goes San Diego's municipal general plan, so goes the region. 

"The single most important land use decision had already been made, and that was the approval of an updated general plan for the City of San Diego," said Fitts. 

The city completed an overhaul of its general plan in 2008 and subsequently won the American Planning Association's Burnham Award for excellence in a comprehensive plan. The plan is built around the concept of a "City of Villages" in which future development in the famously sprawling city is concentrated around commercial and mixed use nodes to create neighborhoods that are both pleasant and energy efficient. 

SANDAG's SCS embraces this strategy wholeheartedly, say local officials. 

"They're really well matched up," said Anderson. "Our plan, called City of Villages, was already predicated on steering future growth towards mixed use, transit-served, pedestrian-oriented areas near job centers. The SCS is just a natural extension of what we're already planning." 

Likewise, the more dense, and poor, cities of the southwest county, including National City and Chula Vista, have indicated their embrace of density. Moreover, Schultz noted that the SCS and RTP could, if implemented properly, contribute to equity in the region by giving poorer residents ways to reach and live in more prosperous parts of the county. But, he said, it shows little promise of doing so. 

"We really haven't done the type of analysis to identify where the gaps are in connecting low- and moderate-income communities to the job centers in the region," said Schultz.  

As well, cities on the other end of the county may not be such eager participants in some elements of the plan. 

"Some of (cities) seem to be adamant that there's no room, they've already done their share, they don't want more (housing) allocations," said Roberts. "In some of the northern beach communities there was a feeling that we're all built-out."

Some of this attitude, critics say, stems from the relative affluence of some North County cities. 

"Smaller cities that tend to be more affluent and want to limit growth so that they don't change the character of their community," said Stephen Haase, a senior vice president at developer Baldwin and Sons. "That to me is unfortunate because they're limiting themselves and the diversity that that community can embrace."  

Carl Hilliard, deputy mayor of Del Mar, acknowledged that he is wary of the possibility that the Regional Housing Needs Assessment, in conjunction with the SCS, could compel Del Mar to take on an amount of affordable housing that might be discomfiting. One scenario under the RHNA, he said, would call for the city, which has 4,500 residents and a median household income of $120,000, to take on 2,400 new affordable units. 

"The affordable housing element is problematic because of the fact that we're so small," said Hilliard. "We're totally built-out.  And 22 percent of our land is fairgrounds and flood plain.  We're willing to do our share to the extent that it's possible to do it."  

Contacts & Resources:


Michael Fitts, Staff Attorney, Endangered Habitats League, 310.947.1908 

Gary Gallegos, Executive Director, San Diego Association of Governments, 619.699.1900

Bruce Reznik, Executive Director, Planning & Conservation League, 916.822.5631

Ron Roberts, Supervisor, County of San Diego, 619.531.5544

Barry Schultz, Special Counsel, Stutz, Artiano, Shinhof, & Holtz, 619.232.3122