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David C.,
Could you please forward the comments below to TSC members?
Thanks,
Colin
***
Transportation Safety Committee Members,
I am writing to comment on the draft General Plan Circulation Element which you will be reviewing at your meeting
tomorrow (Tuesday, 1/17). In general, CRTP appreciates and strongly supports the draft Element’s focus on enabling,
encouraging, and incentivizing safe, healthy, low‐carbon modes of transportation like walking, biking, rolling and public
transit.
We offer the following specific comments in the hopes of strengthening this focus:
1. Vehicular Level of Service (LOS) is a measurement of traffic congestion. It is now well established that
attempting to minimize congestion/improve LOS by adding vehicular capacity: (a) causes people to drive more;
(b) does not actually reduce congestion in the long term; (c) often decreases safety in the short term by
temporarily increasing traffic speeds. Despite all of these arguments against using LOS as a policy tool, the draft
Circulation Element still establishes maintenance of LOS to “minimize [vehicular] delay” as a policy goal (Policy T‐
4). Furthermore, Table T‐5 lists many major projects planned partly or entirely to address LOS “deficiencies” or
“relieve” congestion. (See also Appendix T‐A.) Many of these projects are also needed in some form to improve
safety, but could likely be improved from a safety and multimodal perspective if LOS were not a policy
consideration. Finally, it should be noted that while we appreciate and support proposed Pocliy T‐4b.2, the
arguments against capacity increases apply to all capacity increases, not just new vehicular travel lanes. We
strongly encourage the Committee to recommend entirely removing LOS and congestion management from the
policy goals and considerations in the Circulation Element.
2. The draft Element includes many roundabout projects. Please refer to CRTP’s recent comments and references
related to roundabouts and the need to address critical bike and pedestrian user concerns when considering or
designing them.
3. We note that, pursuant to the adopted Regional Transportation Plan, HCAOG is planning to conduct bike and
pedestrian level of traffic stress (LTS), connectivity and access analysis for streets in the greater Humboldt Bay
region, including Arcata. When complete, it will be important to update and prioritize proposed bike and
pedestrian network improvements to reflect this newly available information.
4. The (currently blank) target for increased transit mode share at Policy T‐3 should be consistent with the adopted
Regional Transportation Plan targets to double transit trips by 2025, double again by 2030, and again by 2045,
2
and to increase non‐auto mode share to at least 30% by 2030 and at least 40% by 2050. See also Policy T‐5
regarding bike and pedestrian mode share.
5. It is past time for A&MRTS to merge with the rest of the county’s transit systems under the umbrella of the Humboldt Transit Authority. Running such a small system as A&MRTS independently is inefficient and causes confusion and friction for transit users needing to access other systems like RTS. The Circulation Element should
establish a goal of transitioning A&MRTS to an HTA operation and establishing unified branding, pricing and
scheduling.
6. The Circulation Element should include a policy to investigate on‐demand microtransit and similar systems for improving transit when ridership and/or land use patterns don’t justify expanded fixed‐route service.
7. Proposed Policy T‐4c.2 specifies that traffic calming should not “compromise emergency access.” However, it must be recognized that there are times when slowing traffic will inevitably slow emergency vehicles as well. At such times, the overall risk to life and safety from all sources — including speeding traffic and emergency access —
should be considered. Emergency access cannot be a blanket excuse not to implement life‐saving traffic calming interventions.
8. It is unclear why proposed Policy T‐4c.4 is included. Closing residential streets to through (vehicular) traffic is a common strategy for improving both safety and multimodal access, and should be part of the city’s toolbox without undue restriction.
9. Policy T‐5a.2 should reflect that Class IV, not Class II, bike facilities should be provided on high‐demand streets,
as well as higher‐speed and higher traffic streets. Arcata cannot truly consider itself a bike‐friendly city with no
protected Class IV bike facilities.
10. Proposed Policy T‐5e specifies that required bike parking in new development shall be calculated as a proportion of vehicle parking. Since the city is moving toward minimizing new vehicle parking requirements, but wishes to encourage biking, this policy link is unwise. Bike parking requirements should be calculated independently from car and truck parking.
11. Policy T‐5h should reflect a minimum clear path of 6 feet on sidewalks as a best practice.
12. Policy T‐6 and its sub‐policies refer frequently to the need for “adequate parking” and reflect the widespread misconception that parking demand is a fixed variable. In fact, research demonstrates that the availability of (free or underpriced) parking encourages driving, so there is no such thing as “adequate parking” independent of cost or availability. Guiding Principle H reflects this in calling for “fee‐based parking prices that are high
enough to drive more active and shared transportation.” This is a critical TDM strategy, but is not explicitly reflected in Policy T‐6. The policy should be revised to reflect a goal to minimize or reduce free and underpriced
vehicular parking as part of the city’s transportation demand management program.
13. Policy T‐6c says the city will “consider” eliminating costly parking mandates. This is a good first step, but really there is nothing to consider. The city should join a growing list of communities across the country and commit to just eliminating minimum parking mandates altogether.
14. Policy T‐8 should include a sub‐policy requiring an increase in metered and/or permit parking as a source of
revenue for transit and active transportation improvements.
Thank you.
‐‐
Colin Fiske (he/him)
Executive Director
Coalition for Responsible Transportation Priorities
www.transportationpriorities.org