According to its sustainability policy, the Authority intends its approach to the design, construction, and operation of the high-speed rail system to contribute to a more sustainable California. The policy also states the Authority's commitment to employing leading edge construction methods to make the project a model for future rail infrastructure. Described by the Authority as "all-encompassing," the sustainability policy is supposed to guide the system's energy and natural resource use, impact on local communities, construction practices, and operations. State and federal commitments mandate certain aspects of the Authority's focus. For example, Proposition 1A-which provided funding for the high-speed rail system-requires the Authority to plan and construct the system in a manner that minimizes the impact on the natural environment. Further, in a 2010 memorandum of understanding with the federal government, the Authority pledged to be environmentally conscious throughout the design, construction, and operation of the system. Other aspects of the Authority's sustainability policy, such as encouraging transit development in local communities, are compatible with legislative priorities for sustainable transportation planning.
Although the Authority's sustainability policy includes goals consistent with best practices, it also has shortcomings that limit its effectiveness. According to the expert we retained to assist us in assessing the sustainability policy, it includes valuable objectives that generally align with established best practices. However, our expert found the policy does not sufficiently distinguish between construction of the system-which has a significant impact on the State's environment-and its eventual operation. Some of the policy's priorities, such as reducing car and other vehicle travel, clearly focus on the effects of system operations and have no direct construction implications. However, the Authority has not identified construction-related objectives for all of its priorities even though the priorities themselves have relevance during the construction stage. For example, although the policy lists conservation of nonrenewable energy as a priority, the related objectives pertain only to the system's operations. Our expert noted that best practices concerning this priority, including those from the Global Reporting Initiative-with whose standards the Authority claims compliance-require a project to consider the total amount of energy used during construction.6
The Authority's implementation plan does not include measurable, process-focused metrics related to construction for many of the objectives in its sustainability policy; this lack of actionable detail makes ensuring the system's current and future compliance with the policy's goals challenging. | Our expert observed that because the policy does not consistently and explicitly address the impacts caused by the construction phase of the system, the Authority's implementation plan-which details how it will assess compliance with the policy-is not always specific about what the Authority should measure during construction in order to determine success. Further, the implementation plan does not include measurable, process-focused metrics related to construction for many of the objectives. For example, the plan states that the Authority will monitor the degree to which the system's eventual operation improves air quality by tracking the number of emergency room visits for asthma sufferers; however, the plan does not include a metric to measure the degree to which the construction affects current air quality. Our expert concluded that this lack of actionable detail makes ensuring the system's current and future compliance with the policy's goals challenging. |
Because construction is significantly underway in the Central Valley, we asked our sustainability expert to review best practices for monitoring sustainable construction and compare those practices to the Authority's plans and actions. After reviewing 13 comparable infrastructure projects as well as guidelines published by the American Public Transportation Association, our expert determined that current industry standards call for organizations to estimate the material impacts resulting from construction before beginning projects. Organizations should then establish specific goals and-once construction has begun- measure actual progress against those goals to determine where they have been successful.
The Authority has set initial estimates for some construction impacts, but it has not comprehensively measured actual progress against those estimates. Before beginning construction on the system, the Authority estimated the level of greenhouse gases and other pollutants that construction activities would emit. Our expert reviewed the Authority's calculations and found them to be reasonable and in line with guidance from the California Air Resources Board. Further, the Authority required each of its construction contractors to submit estimates of impacts, such as greenhouse gas emissions, within sixty days of receiving approval to begin work. Relying on contractors to determine these estimates presents a risk that they may overestimate emissions, but our expert concluded that doing so is a standard industry practice.
Although it properly completed initial estimates, the Authority did not ensure the accuracy of subsequently collected sustainability data. The Authority relies on each of its construction contractors to self-report information on their sustainability performance-such as their usage of heavy equipment and water-into a central database. The oversight firms for the three current construction projects then review these submissions and pass them on to the Authority's sustainability unit, which RDP consultants lead and almost completely staff. Despite these protocols, when we attempted to validate a selection of nine database entries against supporting documentation, we found that the Authority could provide sufficient supporting documentation for only three entries. We therefore were unable to determine the accuracy of the Authority's data. An inability to ensure accurate data could limit the Authority's ability to reliably compare actual performance against estimates. | Although it properly completed initial estimates, the Authority did not ensure the accuracy of subsequently collected sustainability data, which could limit the Authority's ability to reliably compare actual performance against estimates. |
Further, our expert found that the Authority has not comprehensively evaluated the sustainability performance of the currently active construction projects. Neglecting to monitor all pertinent aspects of performance continuously throughout construction could result in the individual construction projects falling short of their goals; if it reviews progress only after it completes a specific project, the Authority will have missed any opportunity to intervene in order to improve sustainability outcomes. The Authority provided documentation showing that it is tracking two environmental impacts, greenhouse gas emissions and other air pollutants, against benchmark estimates. However, that documentation did not include equivalent comparisons related to the environmental impact of waste produced from construction, despite the fact that each construction contractor provided a benchmark estimate for waste. In addition, our expert observed that the documentation the Authority provided also does not allow it to effectively project whether contractors will meet or exceed their estimates because it does not account for actual construction progress to date. Finally, we noted that the current construction contracts do not require contractors to estimate the environmental impact of water usage for the project, and as a result, construction contractors did not provide benchmark estimates for water use.
Evaluating the sustainability impact of the system's construction on an ongoing basis is also critical because it will enable the Authority to set standards for future construction. The Authority has not yet developed a systemwide baseline or identified a universal metric against which to anchor future construction projects, which may differ in scope and type from current projects. For example, the Authority's plans for completing the system call for significant tunneling, which it has not yet attempted. Although its sustainability report from 2016 stated that the Authority planned to adopt 2015 as its baseline year, the Authority has not moved forward with this plan. Therefore, it is not yet prepared to hold future construction contractors to a baseline it has established using current construction activities. The Authority's sustainability director told us that her team is in the process of using recently completed systemwide construction plans and current construction data to develop a metric that will allow the Authority to set standards for future projects. She stated that the Authority plans to complete this process before it enters into any additional construction contracts, but that the process is complex and will be challenging.
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6 The Global Reporting Initiative is an international organization that develops sustainability standards that many of the world’s largest corporations use.