Transportation Element of the Comprehensive Plan: Big Questions | A Pragmatist's Take | Douglas Moran | Palo Alto Online |

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By Douglas Moran

Transportation Element of the Comprehensive Plan: Big Questions

Uploaded: Aug 27, 2015

The Citizens Advisory Committee (CAC) will be discussing the draft of the Transportation Element at their September 8th meeting and part of their October 20th meeting. The Comprehensive Plan is an awkward mashup of Vision Statement, Mission Statement, Priorities, To-Do List, fanciful wishlists, reassuring nods to various interest groups?

The draft Transportation Element is heavy on the first two: 60 of its 101 policies are statements of principles, that is, they have no programs intended to implement them. The remaining 41 policies have a total of 120 programs attached to them.

Background: The CAC discussions are confusingly based on three versions of the Comp Plan. City Hall has invited Online Commenting relative to the current version. However, discussions are relative to draft of 2014 that the Council sent back for more consideration (hence the CAC). Shortly before the August CAC meeting on another section of the Comp Plan, Staff distributed a substantially augmented version of that section from 2014 draft, and it was used as the basis for discussion at that meeting.
My discussion here is based on the Draft Element. The numbering scheme is "Tx.y.z", where "T" identifies the item as being part of the "Transportation Element" (replaced by "RC" for items related to the Rail Corridor); "x" is the number of the Goal within that Element; "y" is the number of the Policy within that Goal; "z" is the number of the Program for implementing that Policy. The current Comp Plan uses a different number scheme, and the draft Plan provides a mapping between the current items the proposed organization.

I have provided links into the draft document?a PDF?so that you can double-check my copying, and to see what I have elided and the context of the item being cited. Let me know of errors (there is an email link next to the photo of me at the top of the page).

I expect that many of you readers have been involved in the development of a Vision Statement or Mission Statement, either in a commercial enterprise or another organization. These debates often extend for hours, but I have been surprised by how many of the participants don't recognize that the purpose of the exercise is the "journey", not the "destination". For example, there often is intense debate on selection of exact words: Forcing the participants to examine precisely what they want to say and what the various candidate wordings convey is a proven mechanism to force the desired discussion of what is most important. Yet days later, I have heard some of those participants dismiss questions about the meaning of the wording, saying that the meaning is "obvious". All the knowledge and understanding developed in reaching the result has disappeared. Analogous to going on a long vacation, and the only pictures you keep are of unpacking the suitcases upon your return.

Absent this "legislative record", it can be very hard to judge the intent of the wording. Especially when there is problematic wording: Was it the result of author not understanding the complexities, or of the author not bothering to be precise, or of the author trying to slip something by the reader?

For example, Policy T1.4 states "Locate higher density development near transit corridors?" Is this a policy trying to be a restriction?that such developments should only be in such locations?or is it a call to enable more such developments?

For example, Policy T4.1 "Provide sufficient motor vehicle and bicycle parking ? to support vibrant economic activity. ?" Is this more free parking? Only two of the 13 implementing programs mention financing, and then only at the level of "evaluate" (T4.1.4) and "explore options" (T4.1.10), whereas the policy reads more as "Do it now, regardless!" Consequently, my reading of this item in isolation would be that it calls for taxpayer-financed construction, but this is contrary to what I know of current thinking.

----Who was "at the table"----

During the Public Comment period at the August CAC meeting, Annette Glanckopf pointed out the imbalance in the items addressing different demographic groups, citing seniors as an example of getting short shrift (paragraphs 5-6 from end of article "Residents challenge membership of new citizen panel" (2015-08-14) plus online comments). Gross disparities are a warning sign of an underlying problem in the process?one that cannot be fixed simply by adding more items relevant to those groups. It is a warning that those groups' concerns and interests were not adequately represented in the consideration of all the items in the draft.

When one looks at the draft Transportation Element, the disparities indicate that one interest group was overwhelmingly dominant: a subset of bicyclists. As I read the various items, I saw instance after instance where there seemed to have been no one to challenge them about practicality, cost-effectiveness and other tradeoffs. For example, Policy RC3.1 "Seek to increase the number of east-west pedestrian and bicycle crossing along Alma Street, particularly south of Oregon Expressway." Yes, there are long stretches without crossings, and there have been a couple of times a crossing between Oregon and Meadow would have been convenient to me. However, I have never gotten a responsive answer to the practical question "What is the actual need? That is, where would people be coming from and going to, and how many such people are there?" Tunnels and overpasses are ridiculously expensive, and there are so many more cost-effective things you can do for bicyclists and pedestrians. Oh, I forgot?for some, Palo Alto is a "Cost is no object" zone.

For those that like numbers, Goal T3 "Protect Neighborhood Streets?" has 5 policies and 4 programs. Bicycle Parking has 3 policies and 5 programs.

The second group with disproportionate influence as "sustainability advocates". For example, Policy T7.3 "Support the efforts of the Metropolitan Transportation Commission (MTC)? that support greenhouse gas reduction. Encourage MTC to base the region's ? on greenhouse gas reductions." So, prioritize GHG considerations, with no mention of providing service. I have been at MTC-sponsored meetings where they put zero value on people's time: Turning a 30-minute commute into a 2-hour commute was acceptable, simply on the notion that it would reduce GHG (no attempt at quantifying it). Recognize that MTC is a primary partner of ABAG in pushing high-density development on the theory that this region needs/wants high rates of population growth, and "sustainability" is part of how it tries to justify its assumptions.

----Transit Corridors----

The term "transit corridor" is used throughout this document without being defined, but the interpretation of that term is crucial to many policies and programs. The term has a long history of abuse in Palo Alto politics. For example, El Camino is classified as a transit corridor because of the VTA 22/522 bus line, and that classification is used as a rationalization for development decisions based on hypothetical transit usage, rather than observed usage. Arastradero Road is often characterized as a transit corridor, despite having a bus route (#88) that runs infrequently (hourly), only weekdays, and doesn't go much of anywhere (judge for yourself). And then there have been the "Built it and they will come" transit corridors: The belief that if you build high density housing and offices where there is no transit, that will result in usable transit being expanded to that area. This attitude resolutely resists understanding the level of density needed to support viable transit. Hint: If you build 40-60 housing units not on a bus line (think Alma Plaza), no way are you going to get a bus line stopping there every 10 minutes.

Recognize that when many pro-development advocates use the phrase "near transit" that they mean all of Palo Alto (including Foothill Park?), because their basis for comparison is Tracy and Los Banos. I kid you not. These is not just random ideologues, but include elected officials (then and now).

Consequently, any time you see phrases such as "transit corridor" or "near transit", anticipate that developers and their allies on Staff will use that term to put high density housing and offices in locations that a typical person would see as too far from transit to be relevant.

----Anti-Affordable Housing----

Policy T7.20 "Support the regional Grand Boulevard Initiative for El Camino Real?". That Initiative calls for massive redevelopment of the area 0.25-1.0 miles on either side of El Camino into offices, high-density housing and retail that fits into that style of development (example, restaurants on the first floor of office buildings). T7.20 includes one Palo Alto-specific exception?no dedicated bus lanes?but ignores a host of other problems that the Initiative would pose for Palo Alto. It omits Council's direction that exempts single-family neighborhoods from being rezoned to encourage redevelopment. For visualization: Middlefield Road is within this 1-mile distance until you get south of Charleston Road. However, unaddressed by both Council and the CompPlan is that much of Palo Alto's more affordable (less unaffordable?) housing is inside this band. Experience has demonstrated replacing older apartment buildings with new higher-density ones does not improve affordability?quite the contrary.
Note: A majority of the 17 voting members on the current CAC either come from groups advocating this type of redevelopment or personally advocate it.
Aside: I discussed other problems with the Initiative in my blog "El Camino Sidewalk Width and the 'Grand Boulevard' Delusion" (2014-03-29).

----Promoting Redevelopment----

Policy T1.3 "Make land use decisions that promote infill, redevelopment, and reuse of vacant or underutilized parcels employing minimum density requirements that support walking, bicycling, and public transit use" (emphasis added; the grammar is awkward). Without the emphasis, this probably seems innocuous. However, recognize that to many developers, growth advocates ? virtually all parcels in Palo Alto are "underutilized". For example, I routinely hear single-family homes attacked as wasteful and a scourge on the environment. And the 50-foot height limit is constantly criticized. And we "need" denser, taller buildings along El Camino and in the CalAve area.

Experience demonstrates that in Palo Alto's current situation, redevelopment increases prices, not just for occupants of building being redeveloped, but those in nearby buildings. So you might ask "Why does City Hall want to promote making the city even less affordable to residents?" You might well ask that.

----What sets the pace? Development or Infrastructure?----

There are some items that recognize the need to balance development and infrastructure capacity. For example, Program T1.7.4 "Consider Caltrain capacity in evaluation of proposed Transportation Demand Management measures" (Caltrain is running near capacity already). And Policy T4.1 "?Limit under-parked development while there is insufficient public parking." However, there are more items that are pro-developer, with the implicit assumption that the burden of providing infrastructure is on the public. With it becoming increasing more expensive and difficult to expand infrastructure, this can translate into developer profits coming at the expense of diminished infrastructure for residents. For example, Goal RC5 "Infrastructure should keep pace with development" is the reverse of what is in the interest of the city and its residents.

For example, Goal RC4 and Policy RC4.1 effectively acknowledge a significant deficiency in the plans for high-density development in the Rail Corridor?it is poorly connected to parks, community centers, libraries, schools??and calls for infrastructure improvements (public spending) to support this high-density development, including ways to increase school capacity.

Policy T2.9 "Prohibit development that causes Level of Service (LOS) E for a particular intersection unless the City Council or the Director of Public Works finds that (1) there are no feasible improvements?" Claiming "no feasible improvements" has long been successfully used by connected developers to avoid having to take responsibility for the traffic generated by their projects, although they usually first claim that those projects will only generate traffic below the level of significance.


The draft is surprisingly less hostile to vehicle traffic than you might expect, which is to say, it is not entirely hostile. There are items that call for "slowing" traffic without regard to its current speed (Program T3.2.2 and Policy T3.4) I am not being pedantic: During the public meetings on the Arastradero Road Restriping Trial, complaints about a level of congestion that had cars moving at 5-10 mph were met will calls that traffic should go even slower. Aside: In actual parking lots (in shopping centers, office parks), I know of no attempt to have vehicles go less than 5 mph.
Note: Although the authors of these items mention Traffic Calming, they seem to misunderstand the concept, equating it with slowing traffic. As the name implies, "calming" involves making movement safer by making it smoother and more predicable, eliminating both the high and low speeds, rapid changes in speed, unnecessary lane changes?

A number of the items suffer badly from tunnel-vision or lack of coordination with other sections. For example, Policy T2.4 "Ensure that additional lanes are not installed at the expense of bicycle lanes, sidewalks, or landscaping." Many residential streets suffer from cut-through traffic because of congestion on major streets. One way to reduce that cut-through traffic would be to increase capacity on the major street, such as by adding a lane (acknowledged on that same page in Policy 2.8). I suspect many residents would be more than willing to lose some landscaping on thoroughfares to increase their capacity if it improved safety on residential streets. Narrowing little-used sidewalks would also be an acceptable tradeoff to me. But this policy prohibits that.

Policy T5.1 "? Prioritize pedestrian, bicycle, automobile safety and transit accessibility over vehicle Level-Of-Service at intersections." Unless you have been in a bunch of meetings on bike safety, you probably don't realize how counter-productive, even dangerous, this policy is (it is inherited from the current CompPlan). You are at a meeting and a lone bicyclist or pedestrian claims that a particular feature of an intersection makes them "feel" unsafe, and request/demand substantial changes, often ones that are likely to increase congestion (decrease LOS). Since these are personal feelings, they cannot be subjected to considerations of facts, logic or risk-assessment. That person will reject simple work-arounds with little more than "I shouldn't have to." For pedestrians, this may mean refusing to detour tens of feet (crossing elsewhere in the intersection); for bicyclists, refusing to take an established bike route 1-2 blocks away. Even though these people make only a modest attempt to cover their self-absorption with a thin veil of ideology, this policy makes it hard for Staff to tell them "No". Recognize that caving in to such people isn't simply a matter of inconveniencing thousands of others, reduced LOS (increased congestion) pushes traffic onto residential streets, creating a disproportionate danger. This policy fails both in how it makes tradeoffs at the intersection in question and in failing to consider the ripple effects of reduced LOS.


The draft plan replaces the current Policy T-47 "Protect residential areas from the parking impacts of nearby business districts" with Policy T4.5 "Create and maintain residential permit parking programs in appropriate areas of the City when supported by impacted neighborhoods." We live in an era of greatly reduced expectations.

----Wasting Transit Funding----

T7.15 "Support the development of an efficient and quiet regional rail system that encircles and crosses the Bay,?" These have long been the code words for BART. Do not think for a moment that this includes Caltrain: In the discussion of transit between the BART station in Fremont and the South Bay, this criteria was used to reject a Caltrain-style system?only full-fledged BART was acceptable, regardless of cost. Remember that the BART-to-SanJose decision took funding away from Caltrain improvements. So why should Palo Alto be advocating for a hyper-expensive rail connection to feed East Bay commuters into northern San Jose (and eventually northern City of Santa Clara)?

Policy T7.18 "Support design and implementation of a Dumbarton rail crossing?". Sorry. It died during a mugging by VTA looking more money to feed its insatiable BART addiction.

T7.19 "Collaborate on extensions of VTA Light Rail?" The VTA Light Rail system is consistently rated one of the worst, often the worst, such system in the US on both cost and service. In 2012, an extension into the West Valley was estimated to cost $175M to build and to add only 200 new riders ($875K/rider). Since official estimates routinely turn out to be a fraction of actual costs, guestimate $2-4M per rider for that extension (if/when it gets built). Yet, I don't see that Palo Alto considered the cost-effectiveness of a similar extension to us.

----Insufficient paranoia----

A basic problem with people attracted to government?official, employees, and many advocates?is an over-confidence in their ability to predict and control events. They tend to ignore unintended consequences ("The road to hell is paved with good intentions") or the ability of others to "game" the system. This is a major failing throughout the draft CompPlan (and the current one). For example, in Program T1.7.1 "Formalize the City's Transportation Demand Management (TDM) program by establishing an ordinance?provide a system for incorporating alternative measures as new ideas for TDM are developed. ?" The laudable intent is to allow flexibility for better measures, but notice that it says "alternative" rather than "better". City Hall has a history of knowingly allowing "aspirational" TDMs (simply hoping that building occupants will somehow find a way to make fewer vehicle trips). For example, delusionally high rates of transit usage, or assuming that the occupants of the housing units in a mixed-use complex will also be employed in that very same building. This also allows for vanity TDMs, that is, they look good in the brochure/resume but effectiveness is irrelevant.

----Vanity "Sustainability"----

The draft embraces long-discredited attitudes about sustainability and Greenhouse Gases (GHGs), for example, looking only at the emissions from a vehicle rather than full life-cycle effects. This tunnel vision of the problem has led Sustainability advocates to support a range of counterproductive measures. I term it "vanity" because it allows those advocates to feel good about themselves without having to do the work needed to actually be effective. The first two policies in this draft (T1.1, T1.2) reflect this problem.

----Humorous?: Planning to implement a by-then obsolete plan----

In this draft plan, implementation of the Bicycle Pedestrian Transportation Plan of 2012 is called for in 2 Policies (T1.20, T1.24) and 4 Programs (T1.19.1, T1.19.2, T1.19.5, T4.14.1). And Program T1.19.3 calls for updating that plan every 5 years. So we have a draft plan calling for the implementation of an existing plan, but this draft plan is unlikely to be approved before that existing plan is supposed to have been superceded.

On the other hand, given the current track record, we probably shouldn't expect the work on the 2017-2021 Bicycle and Pedestrian Plan to begin before 2019 or to be completed before 2026 (local estimating rule: work on a plan should start late and last longer than its intended duration).


Cruft is a description for items, or portions thereof, that shouldn't be in the draft CompPlan because they take up space, and thereby inhibit focusing on what is important. Some are too trivial. Some have clearly not been thought out. I discussed this in my previous blog entries on this update to the CompPlan
? The Remedy to Inadequate Citizen Input? More of the same (2015-07-31)
? 143 important decisions in 150 minutes by a 20-member committee (2015-08-05)

Desirable, but any idea about how to do it?
Goal RC3 "Connect the east and west portions of the City through an improved circulation network that binds the City together in all directions."

Public Financial Support for Private Enterprises?
The draft language uses words like "support", "promote incentives" and "encourage" relative to private commercial activities. Some of these are undoubtedly intended only as vanity statements?allowing members of the ruling class to congratulate themselves on Palo Alto being a "leader" in these areas, without actually planning to do anything practical or effective. However, this is an official planning document and there is the ever-present danger of vacuous statements being turned against the City and its taxpayers.

Examples: car-sharing companies (T1.2.2) and services (T1.18); taxi service (T1.17);

Example: Program T2.6.3 calls for the City (taxpayers) to provide shuttle buses between the train station and Stanford Shopping Center, Stanford Medical Center and Stanford housing in the Sand Hill corridor. Is this really intended to be a commitment by the City, or is it just sloppy writing (inherited from current CompPlan)?

Do we really need to mention that?
There are four programs involving publishing maps (T1.19.4, T2.1.1, T5.7.4, T5.7.6); one to maintain the security fence at the airport (T8.1.3); "In business districts, keep sidewalks clean?" (T1.25.3); ?
Lobbying other agencies to "Do your job": for example, there are at least 3 policies T1.14, T1.15, T1.16 that could easily be rephrased as "Encourage VTA to provide competent service" (VTA: Santa Clara County's Valley Transportation Authority).

Although they were fewer than expected, the instances of hubris or puffery were still present.
For example, "highest quality general aviation-related services" in Program T8.1.1.
For example, Palo Alto needing to be a regional leader: Policy T7.1 " Lead and participate in initiatives to manage regional traffic" (emphasis added). Why should Palo Alto get involved in decisions on carpool lanes between Redwood City and San Francisco (Policy T7.4)?

Program T4.3.2 "Provide way-finding for parking?" : Since the draft provides no explanation of items, we don't know whether a practical case was made for this, or if it was just someone wanting to have the latest toys.

An abbreviated index by topic and chronologically is available.

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