The CTP 2050 is Really a Statewide APS

The California Transportation Plan must reconcile its aspirations with the real world constraints built into Regional Transportation Plans.

The draft California Transportation Plan (CTP2050) creates a resilient vision for the state’s transportation network. One that is modally diverse, equitable, less reliant on the automobile, and better for the climate. What’s not to like? California needs such a vision to forge new low carbon programs that improve safety, transit, health, equity, and the economy. But the CTP2050 lacks the financial analysis to put it on par with regional transportation plans (RTPs).

As a result, the CTP2050 is the functional equivalent of an Alternative Planning Strategy (APS).

Those familiar with SB 375’s regional GHG reduction targets may assume the “APS label” is a criticism. It is not. We do not quibble with the CTP2050’s goals. They are consistent with both state and MPO goals. We use it to help explain the relationship between the state’s RTPs and the CTP2050.  Put simply, RTPs are fiscally constrained and the CTP2050 is not.

Our main point: Caltrans should explain how the CTP2050 can be used in tandem with regional plans to achieve state goals. This includes a more detailed description of how the CTP2050 is different from RTPs, including a list of all planning assumptions within the CTP2050 that cannot be included in an RTP. This also sets a baseline for new analysis that must be included in the next state plan, which is due in 2025.

Quick Definitions to Start

A couple of definitions are in order. In California, a regional transportation plan (RTP) must include a Sustainable Communities Strategy (SCS) to achieve a GHG reduction target set by the Air Resources Board (ARB).  The RTP must also be fiscally constrained, meaning there has to be a realistic budget supporting all of the strategies, projects, and programs over the planning period. If a Metropolitan Planning Organization (MPO) cannot feasibly achieve the target given its available and anticipated resources, it develops a separate “hypothetical” plan called an Alternative Planning Strategy (APS)  that shows how the target may be achieved. The APS is not required to be fiscally constrained.

For more: See SB 375: APS v. SCS.

Why The Distinction Matters

The CTP2050 must integrate state and regional planning processes. See Gov’t Code § 65700. RTPs complement the CTP2050, but not in the way most people assume. The CTP2050 does not “roll-up” the state’s regional plans to build a single vision. Nor are the state and regional plans consistent with one another.

How can this be?

The answer lies in understanding their differences. The stronger fiscal grounding of the RTP provides a performance scenario based on expected resources. Alternatively, the CTP2050 may consider scenarios that stretch beyond RTP best outcomes. The new vision creates a framework and justification for new policy, which can result in new resources and tools for state, region, and local governments. Future RTPs may then incorporate these new tools as they are enacted to develop even higher preforming best outcomes.  With each iteration, the gap between future vision and current baseline narrows.

It’s a nuance that is hard to see. Even the Legislature missed it when amending the CTP statute was last year (AB 285).  The new statutory language assumes a more linear relationship. As a result, the next CTP (due in 2025) must include an analysis of the actions that each region has taken to achieve the objectives in the previous CTP. See Gov’t Code § 65072(b). Put another way, Caltrans must review how fiscally constrained regional plans are achieving an aspirational vision untethered by fiscal feasibility.

It’s like reviewing the quality of an apple on the thickness of its rind.

But there is an opportunity here. Caltrans can use CTP2050 to prepare for the required analysis in 2025 constructively. Language can be inserted to educate everyone about the value and role of these two very different plans.  They can also address how to appropriately evaluate the extent to which they are complimenting one another. In doing so, Caltrans would create a better framework for state-regional-local cooperation.

Below is the start of our contribution to this effort. We explain three fundamental differences between the CTP2050 and RTPs to underscore their differences. And we make two recommendations for the Caltrans and the Strategic Growth Council to improve the framework for cooperation.

Three Ways the CTP2050 is Like an APS

Here are three ways in which the CTP2050 is very different from a regional transportation plan and more like an Alternative Planning Strategy.

1.  No Financial Constraint Analysis

The CTP 2050 lacks a “fiscal constraint” analysis.  In contrast, an RTP estimates each revenue source over the 20 year planning period. MPO in a non-attainment areas (which includes 15 of 18 California MPOs) cannot add a strategy to its plan without identifying adequate funding to support it. The federal Clean Air Act requires this kind of “conformity” to assure that the anticipated improvements in air quality will materialize.

Like an APS, the CTP2050 does not include a fiscal analysis. The CTP2050’s  “financial assessment,” merely describes the funding sources. There is neither an estimate of fund availability nor a discussion about how funds should be prioritized. For example, the CTP2050 does not estimate the total of federal funds that can be expected over the planning period. Of course, that is difficult to predict.  How can we know what Congress will do in 2025 much less 2040?

Yet every RTP must included this kind of analysis–for each federal, state, and local funding source.  And the limits to those forecasts constrain the number of projects, programs, and strategies that can be included in an RTP.

2.  Planning Assumptions are not Scrutinized

CTP2050’s planning assumptions are also not net vetted by a conformity analysis. In contrast, federal law requires each RTP to include “reasonable” planning assumptions. (This assures better compliance with the Clean Air Act). State law also requires ARB to review whether the SCS (included in the RTP) is sufficient to achieve the region’s assigned GHG emissions reduction goal.  Although the CTP 2050 must include economic forecasts, federal officials do not scrutinize their reasonableness in the same way.

As a result, the CTP2050 includes many assumptions that would not be allowed in an RTP.

One is the magnitude of CTP2050s road pricing assumption. The 2050 scenario assumes that vehicle operating costs (VOC) will increase by 50 percent in major urban areas.  (See page 81 of the CTP2050 Public Review Draft). That makes sense because price is the most significant factor affecting how much people choose to drive. A higher VOC means people will drive less.

But how does that compare with current practice? A good current estimate for VOC is 18 cents per mile. A 50 percent increase equals another 9 cents per mile (meaning that the 2050 cost of operating a car will increase to 27 cents per mile). To compare, the new gas taxes in SB 1 only increased VOC by approximately 0.7 cents per mile, or about 1 cent per mile in 2050 dollars (assuming inflation slightly out paces expected fuel efficiency gains).

Imagine if an MPO achieved its target by assuming vehicle operating costs increased by 50 percent.  

That means CTP2050 assumes increases in vehicle operating costs that are 8 times greater than SB 1.  (Reminder: SB 1 endured a repeal initiative).

Now imagine if an MPO achieved its target by assuming vehicle operating costs that were equal to eight SB 1s to achieve its GHG target.  Stakeholders would cry foul. The federal reviewing agencies find that the assumption did not conform to Clean Air Act requirements. And ARB would withhold its approval that the plan, questioning whether the plan could feasibly achieve the region’s GHG reduction target.

This example alone demonstrates why an RTP cannot be consistent with CTP2050.

3.  No Environmental Review

The CTP 2050 is not subject to environmental review under the California Environmental Quality Act.  RTPs are. That means that the CTP2050 does not have to review alternatives nor identify all adverse environmental impacts that require feasible mitigation measures. Enough said.

CTP 2050 Scenario Assumptions
The CTP2050 Draft 2050 Baseline Scenario (blue column) already includes undefined GHG reductions.  But that is not the case.  As we note in Transportation’s 7 Percent Emissions Gap: Explained, the Scoping Plan does not include a sufficient plan for a significant portion of transportation emissions.

Recommendations for a Complimentary CTP2050 to RTP Relationship

Caltrans and the Strategic Growth Council should anticipate the confusion and misunderstanding that can come from comparing a fiscally constrained plan to an aspirational vision. Here are two things it can do:

1.  Describe the Different Objectives of the CTP2050 and the RTP

Using examples like road pricing, Caltrans should demonstrate how the objectives in the CTP2050 relate to the fiscal constraint analysis in the RTP. The current draft only devotes one sentence to the fiscal difference between the two. Page 18 provides that RTPs “include a financially constrained project list that must undergo an environmental review and be consistent with air quality conformity requirements.” That is not enough.  

The CTP2050 must acknowledge its reliance on assumptions that cannot be included in an RTP. A list of those assumptions should be created with a description of why they are unlikely to be approved by the FHWA as a current planning assumption if they were included in an RTP. This will help prevent misunderstandings that could result from the different planning assumptions used in the CTP2050 versus RTPs (like road pricing). This kind of detail and understanding will improve the ability of regional representatives, state officials, and stakeholders to have constructive conversations about how best to achieve CTP2050’s vision.  

Recent legislation also requires the Strategic Growth Council to issue a report assessing how the CTP and RTPs will influence the configuration of the statewide integrated multimodal transportation system. This would be another excellent opportunity to examine the aspiration to reality relationship between the plans. This focus can assist the SGC in making further recommendations for climate programs it administers and advises upon. See Gov’t Code § 65072(c).

2.  Commit to Conducting a Feasibility Analysis

State statute requires that the CTP to address “how the state will achieve maximum feasible emissions reductions” consistent with state goals. See Gov’t Code § 65072(a). We note that the word “feasible” does not appear anywhere in the CTP2050 despite this statutory language. And as we noted above, that the financial assessment does not really assess the likely availability of funds. Nor does it estimate the costs. As a result, we cannot know from the information provided that the scenario achieves maximum feasible emissions. Within 12 months of finalizing the CTP 2050, Caltrans should commit to conducting a feasibility analysis of its various strategies. This timing assures that the information can inform the Strategic Growth Council report.

The Benefit of Daylighting the Assumptions

Feasibility is where aspirational goals become real. California cannot achieve aggressive climate goals without a straightforward conversation about costs, impacts, and tradeoffs. Accordingly CTP2050 must set the table for more cooperative conversations between local and regional government, transit operators, congestion management agencies, and the goods movement industry. See Gov’t Code § 65070(a).

ARB already drew the same conclusion. The SB 150 Report (which analyzed how the regions were doing in achieving GHG emission reductions) concluded that California – at the state, regional, and local levels – has not gone far enough. We must structurally change how we build communities. Success requires state, regional, and local agency officials to make multiple changes that address the interconnected relationship between land use, housing, economic and workforce development, transportation investments, and travel choices. [See SB 150 Report, page 6].

Put another way, meeting climate goals is not just the responsibility of MPOs. Or the state. Or local governments. The CTP2050 vision requires cooperation to effect change. There is an important opportunity to collaborate with regional and local agencies to achieve state objectives. Caltrans should seize the moment.


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