When TOD is a Square Peg for a Round Hole

When TOD is a Square Peg for a Round Hole

Square Peg for a Round HoleMore than 4 years after the San Rafael city council voted to make Civic Center a PDA the city published an analysis. The analysis seems to suggest  Civic Center is a square peg and the PDA categorization a round hole.

The Civic Center PDA designation is set to apply a fast growth planning philosophy to Terra Linda, turning it into Northgate City with multiple 5 story high density apartment blocks on both sides of 101.

The PDA targets the ½ mile area around Civic Center station on both the Northgate and Civic Center sides of 101. Currently there are 1,065 homes, most single family, in this area. However, with the MTC Station Area Planning Manual PDA designation of “transit town center” the council has set a goal of packing in up to 7,500 housing units – a seven fold increase.

Residents have turned out in number repeatedly expressing their opposition in planning and council meetings – but at almost every turn up until now their concerns have been dismissed and they have been told not to worry as in future the same process will protect them.

PDA Benefits – a Vegas Gamble with Distant Odds of Success

The Civic Center PDA is a designation made by the city in the hope of receiving transportation funding from Plan Bay Area. Clearly if the city receives funding that is close to or matches the costs needed by the city to support the proposed development the PDA designation may be worthwhile. However the funding amounts are unclear and uncommitted.

To achieve just the initial 620 housing unit capacity (not the full 7,500 unit build-out) – the capacity of the area identified in the city’s General Plan – would require extensive highway improvements. Just one such improvement is the Freitas interchange would cost in excess of $14m. This omits consideration of multiple other improvements that may be required. So how much of this $14m+ burden to taxpayers might the city expect to receive from Plan Bay Area?

MTC allocated just $10m to all of Marin in the last 4 year funding cycle of which at least 50% must be allocated to PDAs. However this must be split between six PDAs in Marin including the Marin County Unincorporated 101 Corridor, Marin City, California Park, Strawberry Village and downtown San Rafael. Civic Center’s share of this funding is unclear.

The city’s August 2013 report estimates that:

“if current policies are continued the six years following the current four year-cycle might generate another $10m to $20m in transportation funding for Marin and with 50% directed to PDAs this would generate $5m to $10m in future funding cycles”

These amounts must however be divided up among five other PDAs. One might reasonably expect Civic Center to receive $1-2m at best.

So while the PDA imposes very clear and substantial costs in the tens of millions of dollars, it is likely to receive no more than a few million dollars from Plan Bay Area’s grants. A drunk gambler in Las Vegas might take those odds, but the city should not be playing with San Rafael taxpayers’ money in such a manner.

A Noble Goal – Reducing Greenhouse Gases

Plan Bay Area aims to reduce greenhouse gases by concentrating 80% of new housing into less than 5% of the land area. This 5% of the land area are represented by “Priority Development Areas” or PDAs – they are specifically located within ½ mile of transit hubs. The hope is that a substantial number of the new residents will abandon their cars and take transit.

The thinking is that transit uses less greenhouse gases – but since the transit proposed is the SMART heavy diesel train which gets just 1.1mpg, compared to cars which are mandated to achieve 54.5mpg by the EPA the reverse is actually achieved. With cars carrying 1.67 passengers on average unless the train achieves an average ridership the length of the line of 82+ passengers it will serve to increase greenhouse gases.

The placement of thousands of new apartments is almost certain to add more traffic to highway 101 choke points causing more congestion and more emissions!

This all overlooks the simple fact that the SMART train dead-ends in San Rafael.

Is Civic Center a Match for Transit Oriented Development?

The study published by the city of San Rafael states:

“One study found that vehicle trips per dwelling unit decreased by 15-25 percent for transit-oriented apartments in low-density suburbs”

It cites a study “Vehicle Trip Reduction Impacts of Transit-Oriented Housing” by Robert Cervero and G.B. Arrington (2008).  Interestingly this reference actually doesn’t reinforce the case for Civic Center being a PDA. Cervero’s report states on page 2:

“Many TOD proposals have been abruptly halted or redesigned at lower densities due to fears that dense development will flood surrounding streets with automobile traffic. Part of the problem lies in the inadequacy of current trip generation estimates, which are thought to overstate the traffic-inducing impacts of TOD. Some analysts, however, have identified a serious “suburban bias” in the current ITE [trip] rates. Typically, the data used to set trip rates are drawn from suburban areas with free and plentiful parking, low-density, single land uses, and minimal transit services. “

Suburban areas with free and plentiful parking, low density, minimal transit services – that’s a fairly accurate description of Civic Center.

The report then assesses a set transit of oriented development sites that it sees as more appropriate; consequently these locations would not flood surrounding streets with traffic. You can see the results in a chart and table linked to from this article.

The Cervero study cited by the city of San Rafael is almost an affirmation that the Civic Center PDA is not suited for transit oriented development.

A comparison of the commute times finds that Civic Center is the only location with an indirect commute – all 16 locations in Cervero’s study had direct transit to central business districts.

Furthermore the average commute time – even assuming the SMART train is built and financially viable enough to continue operations – is almost triple that of the developments in Cervero’s study. The locations in Cervero’s study have an average commute time to major employment centers of 35 minutes while to get from Civic Center to the major employment center of San Francisco on the train would take 95 minutes.

The upshot of Cervero’s study is that Civic Center is poorly suited for transit oriented development. The significant distance from a major employment center, plentiful parking in the surrounding areas and low density means it is unlikely to significantly reduce car usage. So while the city’s report states that vehicle trips per dwelling should decrease by 15-25 percent, this is only true for developments with entirely different characteristics.

The city’s Q&A references a second study published in 2004 “Transit Oriented Development (TOD) in the United States: Experiences, Challenges and Prospects”. This report states on page 22:

“Since TODs increase accessibility among those living, working, and shopping near transit, an extensive transit network is also often necessary for the benefits of TOD to materialize”

While SMART provides some limited connectivity it can hardly be described as “an extensive transit network”.  The report goes onto state:

“transit users are highly sensitive to service quality; therefore, running frequent and reliable trains and minimizing the need to transfer can be critical to the future of TOD.”

It is already known that SMART will not be reliable. Farhad Mansourian, SMART’s general manager states that on days when SMART’s train tracks are submerged by water, which occurred on 3 days in 2012 during king tides in the Gallinas Creek immediately adjacent to Civic Center station, the train will not operate. Sea levels are rising so that the number of days SMART will not operate is only likely to increase.

To the report’s second point we might consider that one day SMART does connect to Larkspur. Getting to a job in San Francisco using SMART requires at least one transfer at Larkspur ferry, and for many a likely second transfer when they arrive at the San Francisco ferry terminal to get to an office deeper within the city.


Retaining Civic Center’s designation of Priority Development Area does not appear logical:

  • The certain costs of even a more limited 620 unit build-out are exponentially greater than any reasonable estimation of grants or other financial benefits that the city is likely to receive.
  • Even the smallest class of PDA as defined by MTC’s Station Area Planning Manual, a “transit neighborhood”, has a target of 4,000 housing units, far exceeding the capacity of the area as defined by the city’s General Plan
  • The location does not fit the characteristics described by the expert reports cited by the city as critical factors needed for successful transit oriented development. Car trips per housing unit are not likely to be substantially reduced, but traffic congestion on 101 and greenhouse gas emissions will surely increase.