EnviroMetro – Environmental Policy

Copy of letter:  EnviroMetro 7.27.152015-08-21_17-10-44-EnviroMetro-logos

Environmental Policy Priorities for

2016 LA Metro Transportation Sales Tax

JULY 2015

We, the undersigned representative organizations serving the Los Angeles region, urge Metro to prepare a transportation sales tax measure that will reduce emissions, enhance equity, incorporate green infrastructure and integrate a network of waterway trails.

Over the next year, the Board of Directors of the LA County Metropolitan Transportation Authority (Metro) will consider bringing forth a transportation ballot measure in 2016 for a sales tax that will inform the update of the regional Long Range Transportation Plan, last updated in 2009. The specific ballot measure will include a set of proposed projects and expenditures for funds over a 30–45 year period with up to tens of billions of dollars to be collected. Approved in 2008, Measure R has improved the transportation network landscape in the region with over a hundred miles of fixed rail and bus rapid transit service serving San Fernando Valley and soon, Azusa and Santa Monica.  Additionally, as a self-help region, 70% of LA’s transportation funding comes from three existing sales taxes (Measures A, C and R) that support our infrastructure and services.

We encourage Metro, as the County’s transportation commission, to embrace its role as the planner and administrator of the existing and growing modes of transportation, including public transit and active transportation. According to the latest data, nearly 75% of all trips in the region are done by private vehicle (shared ride and drive alone) while 17% are done walking, 5% through public transit, and 1.4% through biking.[i] A future transportation sales tax measure should have an explicit goal of increasing public transit and active transportation and lowering drive alone trips. In doing so, it should be creative and aggressive in piloting first/last mile solutions like active transportation corridors (Class I & IV bike paths) or ridesharing (bike- and carsharing). We support building a large network of public transit as an important first step in shifting the region’s transportation mode use.

We also believe that transportation plays a critical role in land use, public health, and environmental outcomes in the region. Metro has an opportunity not only to transform the region’s transportation system but also to help the region reduce harmful emissions from private and cargo vehicles, make streets safer to walk and bike, connect more people to jobs and recreational places, and make green infrastructure enhancements that will help address current and future climate and drought challenges. We are excited about the opportunity to work with Metro’s staff and board to capitalize on the environmental, public health and placemaking benefits of transportation and transit projects.


Vision for 2016 Transportation Sales Tax


Consistent with state climate policy objectives, we believe that a future transportation sales tax measure should be guided by the explicit goal of reducing greenhouse gas (GHG) emissions from the transportation sector relative to 1990 levels (1990 levels by 2020, 40% below by 2030, 80% below by 2050). Preference should be given to transportation projects that reduce GHG, are GHG neutral or enhance the region’s multimodal network. Projects that increase the efficiency of our existing infrastructure such as converting freeway lanes to HOV or express lanes, bus rapid transit, dedicated bikeways, grand boulevards and complete streets are acceptable. However, no projects that induce additional vehicle travel, such as most new freeways or additional roadway capacity projects, should be funded

Guided by AB 32, California is on its way to reduce GHG emissions to 1990 levels by 2020. Governor Brown’s Executive Order (April 2015) set a target of 40 percent GHG reduction by 2030. Additionally, Governor Brown declared that California must cut its petroleum use by 50 percent by 2030 in order to meet federal air quality standards and climate goals[ii]. The Air Resources Board (ARB) includes reduction in the growth in vehicle miles traveled as a critical policy strategy as well as fuel efficiency and smart land use planning as tools to achieve the petroleum use reduction goal.

According to ARB, the transportation sector – the system for moving people and goods – is the State’s largest emitter of greenhouse gases (GHG). In 2012, ARB found that transportation emits 37 percent, far outpacing the runner up (industrial sector)[iii].  More recently, a UCLA report showed that transportation is LA County’s second largest GHG emitter (33.5%)[iv]. The South Coast Air Quality Management District (AQMD) provides a starker statistic showing that the transportation sector accounts for up to 85 percent of criteria and ozone precursor emissions (VOCs, NOX, CO, SOX, PM 2.5) in the South Coast Basin[v]. Much of LA County is within the South Coast Basin, thus its residents are heavily impacted by these statistics and policies in response to them.

The region’s largely outdated auto-centric transportation system created a culture of single occupant vehicle travel that chokes Angelenos in endless traffic congestion and air pollution. According to the LA County Asthma Coalition: “Asthma rates have gone up over the last decade for both Hispanic and non-Hispanic Black children.” “Black children have the highest rates of asthma (25%) compared to Hispanic children (8%), non-Hispanic White children (7%), and Asian/Pacific Islander children (4%).” “Among adults, non-Hispanic Blacks have the highest rates of asthma (10%), followed by non-Hispanic Whites (8%), Hispanics and Asian/Pacific Islanders (5%).”[vi]. As the Centers for Disease Control (CDC) unequivocally states, “exposure to traffic emissions has been linked to many adverse health effects including: premature mortality, cardiac symptoms, exacerbation of asthma symptoms, diminished lung function, increased hospitalization…”[vii]

Not surprisingly, the CDC’s recommendations to improve air quality include greater investment in public transit and strategies to boost transit ridership, encouraging transit oriented development, implementing congestion reduction initiatives, reduction of vehicle miles traveled, expansion of multimodal transportation resources including investment in pedestrian and bike paths, dedicated bus lanes and cleaning up diesel vehicles, among several other ideas[viii]. Elevating the importance of expanding the multimodal transportation system in LA County, a report by the University of California and the Institute for Transportation and Development Policy found that a significant shift to public transit and active transportation – coupled with a decrease in road construction, parking garages, and other ways in which car ownership is encouraged – can reduce urban passenger transportation CO2 emissions by 40 percent and save over $100 trillion in operation costs by 2050 even as urban population growth continues.[ix] We believe that Metro is headed in this direction and strongly encourage you to shift your efforts into high gear. We are excited about the launch of the bike share program, deployment of Zipcars on ten Metro stations[x], and your implementation of the award winning First/Last Mile strategy.

Emissions Reduction from Clean Goods Movement

Furthermore, ARB recently underscored the urgent need to transition to a zero emissions freight system[xi].  While current regulations and clean air programs will reduce statewide NOx and PM 2.5 emissions from the freight sector by over 50 percent by 2020, those benefits will be short lived as growth in freight activity is expected to gradually overcome the benefits of current controls (Ibid, 11-12).  Moreover, in the South Coast AQMD region—home of the largest port complex in the nation—meeting upcoming federal clean air standards for ozone and PM 2.5 will require significant additional emissions reductions over the next fifteen years (Ibid, 13).  To achieve these goals, “California must take effective, well-coordinated actions to transition to a zero emission transportation system for both passengers and freight.”(Ibid, 1) Further, new health science indicates that “infants and children are 1.5 to three times more sensitive to the harmful effects of exposure to air toxics, like those emitted from freight equipment, than we previously understood…”(Ibid, 2). Therefore, we believe that a future transportation sales tax ought to target funds for deployment of existing zero or near zero emissions freight technology, explore local pick up/delivery at the ports, and investments to existing freight technologies such as on-dock rail and grade separations to the existing freight rail system.

Metro value – “Sustainability:  We commit to reduce, re-use and recycle all internal resources and reduce greenhouse gas emissions.”[xii]



Enhance Equity and Improve Health Outcomes of Region’s Transportation System, in particular for “Disadvantaged Communities” (DACs) – Target Funding, Prioritize Multi-benefit Projects, and Avoid Substantial Burdens.

  •  Consistent with the state legislation (SB535) directing funding to DACs, we believe that Metro should have a specific policy to target funding to the most impacted communities in the county.
  • Identify top disadvantaged communities (DACs) for transportation investments based on CalEnviro Screen 2.0’s calculations.

As Metro considers the project package to be included in a future measure, it is important that communities most impacted by localized air pollution from highway and high volume roadway traffic as well as pedestrian and biking accidents not be additionally burdened by the many known health risks of such exposure.

We concur with Manuel Pastor’s (et al.) definition of transportation equity – having equitable access to quality, affordable transportation options to employment, recreation, school, services, and cultural/natural destinations; sharing the benefits and burdens of transportation system and investments; and being a partner in the planning process leading to shared decision-making and equitable outcomes[xiii].

Ridership & Transportation Impact Demographics

Metro’s rider survey shows that a majority of transit riders are people of color whose median incomes are below the county’s median[xiv]. While this is true for both modes, a higher portion of bus riders (86%) are people of color compared to rail riders (77%). Additionally, bus riders have lower incomes and lower levels of car ownership than rail riders. As Metro expands the public transportation network and seeks to attract new riders, we believe that it should also strive to improve service, including maintaining low fares and increasing operations, for its current ridership, 75 percent of whom ride buses.

In Los Angeles County, low-income communities and communities of color are exposed to the highest rates of transportation-generated pollution and consequently suffer from higher rates of asthma, COPD, obesity, and other chronic illnesses.  Ozone concentrations, diesel Particulate Matter (PM) emissions, and traffic density are three of the pollution burden indicators used in CalEnviro Screen’s score for a community’s level of exposure to cumulative localized air pollution[xv]. Many of the census tracts in LA County are among the top 25% of the state’s “disadvantaged communities” as defined by California EPA, including regions not served well by public transit such as the San Gabriel and San Fernando valleys as well as East LA and South East LA county.

Target Spending to Decrease Localized Air Pollution, UHI vulnerability, and Increase Access

Current predictions show that LA County residents will experience more days with extreme heat, both raising the threat of urban heat island (UHI) effect and increased ground level ozone levels from transportation and other sources. Given its extensive network of bus stops in the region, Metro should prioritize multi-benefit projects such as cool pavements and coatings, increased tree canopy, and shaded transit stops which will help cool down entire neighborhoods, reduce UHI, and improve air quality. According to data from the National Weather Service, on average, heat kills more people annually than any other weather disaster.[xvi] Thus, projects that lower the heat index have the potential to reduce the number of heat related mortalities and hospitalizations.

We believe that Metro should require that every new transportation project demonstrate how it will lower, not add to, the localized air pollution in DACs. Furthermore, future projects should mitigate against the displacement of local businesses or people of color and low-income residents (e.g. affordable housing set asides for transit-oriented development). Displacement protections have a clear GHG-reduction nexus. A recent ARB report found investing in sustainable communities, including affordable housing near transit, yields high environmental, health, and economic co-benefits.[xvii]

Low-income communities and communities of color disproportionately lack access to green space in the county, and transportation is a significant barrier for many residents to access existing state and national parks in the region. Metro has the opportunity to connect many underserved Angelenos to the region’s incomparable natural resources such as the San Gabriel Mountains National Monument and Santa Monica Mountains, and to enhanced employment and healthy recreational opportunities by providing low cost public transit and active transportation options. We encourage Metro to work with local governments in building out a comprehensive active transportation network, including  safe routes to schools plans for each school district within Metro’s service area, required pedestrian safety plans for every city, and low cost/time efficient “Transit to Trails program” public transit to community, regional parks and national recreation areas. Los Angeles needs a multimodal transportation system that works on Saturday, Sunday and holidays – not just weekdays.

Metro value – “Service Excellence:  We commit to provide safe, clean, reliable, on-time, courteous service for our clients and customers.”



The region’s urban river corridors are strategically located to serve as key non-vehicular transportation, safe routes to school corridors and first/last mile connections providing a multi-objective green infrastructure network for the benefit of millions of residents throughout the basin. Located within close proximity to all major transportation stops, they connect schools and businesses to public transportation networks and hubs and are complementary to the public transit system. Systematically developing non-vehicular transportation along urban river corridor infrastructure presents an opportunity to advance active transportation in a space that was previously underutilized, where there is essentially no competition with other modes of transportation. We call on Metro to commission a comprehensive plan for implementation of a Los Angeles basin-wide active transportation network inclusive of a waterway network of trails along the Los Angeles, San Gabriel, and Rio Hondo Rivers, Tujunga Wash, Arroyo Seco and associated washes, creeks and streams. This plan should guide implementation of the La Basin Wide Waterway Trail Network, which we advocate completing within the first 20 years of the transportation measure funding. This trail network will be complementary to proposed metro line extensions and also serve as key access to connect urban residents to public schools, community centers, workplaces, natural lands, and local, state and national parks and forests. Urban River transit corridors are a backbone hallmark of most great metropolitan areas of world.



Incorporate Green Infrastructure & Biological Mitigation for Metro & Local Return Projects

California is experiencing an historic drought, leading both Governor Brown and LA Mayor Garcetti to issue significant water conservation mandates. Should voters approve a transportation sales tax, Metro will have the opportunity to continue the largest public works construction campaign in the nation. In 2011, the Metro Board became a national industry leader when it unanimously approved its green construction policy, signaling its leadership to tackle air emissions from Measure R construction related activities[xviii]. In consideration of Metro half-cent sales tax initiative, the EnviroMetro coalition is looking at myriad community benefits opportunities that could come from transit expansion plans. Two benefits are water quality and water supply improvements.

In LA County, stormwater runoff carries metals, bacteria, pesticides, fertilizer, grease, and trash across 3100 miles of street surfaces and 5500 miles of stormwater pipelines. The discharges plague the waters surrounding us such as the Los Angeles and San Gabriel Rivers, their many tributaries, creeks, and ultimately the Pacific Ocean daily.

In recent years, storm water runoff has been recognized as a potential supply, particularly for outdoor irrigation. With the proper capture and filtration devices, studies show that LA County could capture a little more than 150,000 AF in dry years and up to 700,000 AF in wet years. Especially during drought years when every drop counts, it makes perfect sense to capture as much storm water runoff as possible.

Environment Now, one of our members, has reached out to the LA Regional Water Board staff to review Metro’s storm water runoff permits. An initial survey yields that Metro is covered under the statewide construction and industrial permits. Metro regularly reports about source controls and water quality monitoring related to dozens of Metro projects. Because Metro was not previously required to submit electronic reports, not all reports have been obtained. EN will formally request copies of these records to consider the railway expansion plans more holistically in the coming weeks.

It should be noted that a storm water element in transportation plans is not unprecedented in Southern California. The Orange County Transportation Authority incorporated storm water funding into the renewal of transportation funding measure. In 1990, OC voters approved Measure M, a 20-year program for local transportation improvements funding by a half-cent sales tax. In 2006, OC voters approved a continuation of Measure M, extending the conclusion of this sales tax another 30 years. Two percent (2%) of gross revenues (estimated at $327 million over 30 years) will be set aside to help OC municipalities improve water quality, including capital and operations improvements. Additionally, all new transportation projects will include water quality mitigation as part of the project scope and costs. Not only is it imperative for us to save water but also extremely important to design and build public projects that will capture and manage storm water to recharge groundwater sources and increase the supply of water for some of our non-potable needs, making our region more drought resilient.

Therefore, we believe that Metro should amend its “Green Construction Policy” to incorporate integrated water management features such as storm water runoff capture and management as well as permeable surfaces into the design and construction of all rail, bus rapid transit, arterial or highway improvements and other projects such as TOD, joint development projects, maintenance facilities, and parking lots. To assist Metro, the Board should cooperate with and require local municipalities to capture and infiltrate storm water based on analysis of permeable soil per their legal duties.

While we recognize the importance of allocating funds for local government use (Local Return), we believe that Metro should establish the goals of stormwater runoff capture and management as guidelines for the expenditures of Local Return. Additional goals should include active transportation investments, first/last mile investments including bike sharing and car sharing programs, complete streets infrastructure, safe routes to school or public demand response systems. Programs like complete streets have the added benefits of incorporating storm water retention practices and contributing to shaded passage ways which reduce the heat island effect and improve air quality.

Protecting Natural Habitats from Construction Impact

Similarly, transportation construction will impact natural habitats and Metro should be proactive in mitigating this. We recommend instituting a robust and comprehensive Regional Advance Mitigation Program, such as those already used successfully in Riverside, San Diego, and Orange County transportation sales tax measures.  In the context of the Metro Long Range Transportation Plan and related funding measures, we propose that Metro coordinate with relevant regional planning entities like the Southern California Association of Governments in the creation of a regional GIS Green Infrastructure database and plan inclusive of following county-wide data layers: Transportation Projects, County-wide Habitat Assessment, Open Space & Parks Networks, Water Resources & Stormwater Management, Air Quality, Climate Mitigation, Urban Forest and Heat Island. Subsequently every project should be reviewed, scored and prioritized for funding and implementation based on alignment with the Basin-wide Green Infrastructure Plan.  The goal of this process is to facilitate alignment between key Public Agencies responsible for long term planning and implementation of infrastructure throughout the LA Basin to ensure a balance of grey and green infrastructure.

Metro value – “Sustainability:  We commit to reduce, re-use and recycle all internal resources and reduce greenhouse gas emissions.”



We look forward to working with the Metro Board and Committee members to craft a transportation measure that will help meet CA’s strong GHG and air quality goals, as well as our aspirations for public health, equity, and green infrastructure development, to improve the quality of life for all residents and create a more sustainable, healthy and livable Los Angeles County.


Belinda V. Faustinos

Interim Executive Director, Council for Watershed Health

San Gabriel Mountains Forever

Caryn Mandelbaum

Fresh Water Program Director

Environment Now


Christy Zamani

Executive Director

Day One


Claire Robinson

Managing Director

Amigos De Los Rios


  1. Malcolm Carson

General Counsel and Policy Director of Environmental Health

Community Health Councils


Dan Silver

Executive Director

Endangered Habitat League


Daniel Rossman

California Senior Regional Representative

The Wilderness Society


Fernando Cazares

LA Regional Coordinator



Jessica Meany

Managing Director

Investing in Place


Jill Sourial

Urban Strategies Program Director

The Nature Conservancy


Jonathan Parfrey

Executive Director

Climate Resolve


Laura Muraida

Research Coordinator



Maria Camacho

Director of External Affairs

LA River Revitalization Corporation


Tamika Butler

Executive Director

Los Angeles County Bicycle Coalition


Tori Kjer

Los Angeles Program Director

The Trust for Public Land


Wesley Reutimann

Executive Director

Bike San Gabriel Valley


Will Wright, Hon. AIA LA

Director, Government & Public Affairs

American Institute of Architects/ Los Angeles Chapter


[i] Safe Routes to School. Analysis Brief – Travel in LA County. Website accessed June 12, 2015 https://saferoutescalifornia.files.wordpress.com/2012/08/travel-in-la-county_nhts2009.pdf

[ii] California Air Resources Board. California’s 2030 Climate Commitments – Cutting Petroleum Use in Half by 2030. Website accessed June 8, 2015. http://www.arb.ca.gov/newsrel/petroleum_reductions.pdf

[iii] California Air Resources Board. California Greenhouse Gas Inventory. Website accessed June 7, 2015


[iv] Mark Gold, Stephanie Pinceti, Felicia Federico. 2015 Environmental Report Card for LA County. UCLA Institute of the Environment and Sustainability. http://www.environment.ucla.edu/perch/resources/report-card-2015-energy.pdf

[v] South Coast AQMD. 2012 Air Quality Management Plan. Site accessed July 14, 2015. http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management-plans/2012-air-quality-management-plan/final-2012-aqmp-(february-2013)/chapter-3-final-2012.pdf

[vi] Los Angeles County Asthma Coalition. Asthma Fast Facts. Website accessed June 8, 2015. http://www.asthmacoalitionla.org/

[vii] U.S. Centers of Disease Control. CDC Transportation Recommendations. April 2010. Website accessed June 7, 2015. http://www.cdc.gov/transportation/recommendation.htm

[viii] “Improve Air Quality” section, Page 3. Ibid.

[ix] Michael A. Replogle & Lewis M. Fulton. A Global High Shift Scenario: Impacts And Potential For More Public Transport, Walking, And Cycling With Lower Car Use. Executive Summary (P.5). Institute for Transportation & Development Policy and UC Davis. November 2014. https://www.itdp.org/wp-content/uploads/2014/09/A-Global-High-Shift-Scenario_WEB.pdf

[x] LA Metro, The Source. “More Zipcars coming to Metro stations.” http://thesource.metro.net/2015/05/29/zipcar-adds-more-car-sharing-locations-near-metro-station/

[xi] California Air Resources Board. Draft CARB Sustainable Freight: Pathways to Zero and Near-Zero Emissions (April 2015)

[xii] LA County Metropolitan Transit Authority. Who We Are: Vision, Mission & Values. Website accessed June 8, 2015 (http://www.metro.net/about/agency/mission/)

[xiii] Vanessa Carter, Manuel Pastor, Madeline Wander. An Agenda for Equity: A Framework for Building a Just Transportation System in Los Angeles County. Commissioned by the California Endowment, USC Program for Environmental and Regional Equity. November 2013

[xiv] LA Metro. Results for Metro’s biannual onboard survey. May 6, 2014 http://thesource.metro.net/2014/05/06/results-for-metros-biannual-onboard-survey/

[xv] Matthew Rodriguez (CA EPA Secretary) & George V. Alexeeff (OEHHA Director) California Communities Environmental Health Screening Tool, Version 2.0. Office of Environmental Health Hazard Assessment. October 2014. http://oehha.ca.gov/ej/pdf/CES20FinalReportUpdateOct2014.pdf

[xvi] Natural Weather Service – Office of Climate, Water and Weather Services. Weather Fatalities, 2004-2013. Website accessed July 14, 2015. http://www.nws.noaa.gov/om/hazstats.shtml

[xvii] California Air Resources Board, Cap-and-Trade Auction Proceeds: Benefits of Investments in the Proposed Fiscal Year 2014-15 Budget (CARB, 2014).

[xviii] Steve Hymon. Metro Board approves green construction policy. LA Metro Source. Website accessed June 10, 2015. http://thesource.metro.net/2011/08/04/metro-board-approves-green-construction-policy/





Translate »