Bay Area Monitor ~ February/March 2008

In This Issue:

Tapping the Renewable Resource of Kid Power

By Alec MacDonald

While the specter of climate change looms large for everyone, young people will bear the brunt of it simply because they’ll be around longer to see it get worse. Yet many of the decisions that factor in to addressing the problem are out of their hands; most of them aren’t old enough to get behind the wheel of a car (let alone buy one) or vote on a ballot initiative (let alone propose one). That doesn’t mean they have no recourse, though. From an early age, kids can grasp the basic science of global warming, become familiar with the behaviors and tools for fighting it, and start putting solutions into practice. They just need some guidance along the way.

Recognizing the importance of fulfilling that need, individuals and organizations across the Bay Area have stepped in to do so. The scope of the task can push the limits of a volunteer’s schedule or tax a nonprofit’s budget, however, so many have turned to the Bay Area Air Quality Management District for administrative support, financial assistance, and a little extra encouragement. The Air District may be better known for regulating stationary emissions sources in the nine-county Bay Area, but the agency also conducts regional outreach work as well, targeting young people in particular.

A Challenge to Clean the Air
A natural place to start is in the classrooms where kids spend so much of their time. To this end, the Air District has been helping math and science teachers better integrate environmental issues into their lessons through “Clean Air Challenge” training workshops. The workshops outfit participants with 15 customizable experiments, a package of support materials worth $800, and a $100 stipend for sacrificing their Saturday to attend. In the past five years, approximately 600 Bay Area middle and high school teachers have completed these workshops, which the Air District funds, shapes, and coordinates.

Petaluma High School science department chair Lee Boyes went through one of the first workshops before signing on to lead them as a trainer; now she directs other trainers.

“Our trainers are all full-time teachers, which makes it easier for them to connect with what’s happening in the classroom,” noted Boyes, who herself teaches honors chemistry to juniors and physical science to freshmen. “That’s been the key to our success.”

Boyes explained that the workshops offer a menu of lesson plans that correlate to state standards, enabling teachers to incorporate information about air pollution and alternative energy into their instruction without deviating from required curricula. And when the kids get the chance to explore pressing, real world scenarios, the scientific principles they’re studying become more concrete.

“It’s a hands-on program; it’s about students doing experiments and reaching conclusions,” she said about how the lessons involve practical applications like determining lung capacity, measuring ozone concentrations, or observing hydrogen fuel cells in action. “It really encourages students to develop a project and a hypothesis of some kind, and test it.”

Campaigning for Climate Protection
The same concept underlies a separate Air District effort seeking to put students in charge of calculating and then reducing the amount of greenhouse gases produced by their peers’ commute patterns. Based on work performed by an AP statistics class at Analy High School in Sebastopol, the Air District — along with the Climate Protection Campaign — is putting together a toolkit that kids everywhere can use to implement programs for reducing transportation-related emissions around their schools.

When the students at Analy surveyed their classmates, they found that almost two thirds were coming to school via individual car trips, accounting for a total of 2,500 gallons of gasoline consumed per week. In response, the students put together a vigorous campaign that reduced those individual car trips by 21 percent over a designated three week period; the key was rewarding walkers, bicyclists, or carpoolers with incentive prizes donated by local businesses.

“That went on to become a very successful model in terms of engaging the students, making it fun for them, and changing some of their attitudes about driving,” said the Climate Protection Campaign’s Maitreyi Siruguri, who confirmed that the related toolkit should be publicly available in the next few weeks. This toolkit will feature activities that not only overlap with curriculum standards (like in the Clean Air Challenge teacher training workshops) but also push students to build the outreach, publicity, and organizing skills necessary to affect large-scale change.

Helping Parents Breathe Easier
Parents also play an obviously vital role when it comes to addressing school commutes, and so the Air District has taken steps to collaborate with them as well on this issue.

Take Allysson McDonald, a mother of two living near Escuela Parkway in Milpitas. Her family chose the neighborhood because an elementary school, a middle school, and a high school all sit clustered along the parkway, but she came to see how this kind of layout generates terrible traffic congestion at pick up and drop off times. Beyond the impact to air quality, she feared the more immediate danger presented by the vehicles themselves that crossed paths with her children on their way to and from school (her younger son walked, her older son biked).

In a survey of their own, McDonald and other concerned parents found similarly dispiriting results to the statistics class at Analy. To discuss the problem, PTA members, other local residents, and representatives from the city and school district began holding meetings, with the Air District stepping in to move things along.

“Having an outsider come in to facilitate those meetings was very helpful,” McDonald commented about the Air District presence. “There have been times when we’ve had some differences of opinion, and it’s good to have someone who’s not an involved member of the community to keep us from getting entrenched in a battle.”

The dialogue gave rise to the implementation of several solutions, including crosswalk improvements, an increase in the number of loading zones serving the schools, and special walk-to-school days. Also planned for the neighborhood are wider sidewalks, shade trees, and a new bus dock.

While much of the burden of moving this process forward has fallen to volunteers like McDonald, their load will soon be lightened. Taking up their cause, the Bay Area affiliate of the lung health advocacy organization Breathe California will be providing assistance with paid staff time — made possible by a $25,000 grant from the Air District.

Funding the Future
Breathe California received the money through the Air District’s Climate Protection Grant Program, which on December 19, 2007 dedicated a total of $3 million toward reducing greenhouse gas emissions. All told, the Air District awarded 53 grants of varying amounts to local governments and nonprofits across the nine Bay Area counties, for applications in five different categories: developing climate action plans, building human resource capacity, regionalizing best practices, fostering innovation, and reaching out to youth.

In addition to Breathe California’s proposal to further ease the situation along Escuela Parkway in Milpitas, the Air District is funding six additional organizations with youth-oriented objectives:

• Earth Team will receive $22,496 to conduct an environmental leadership program with high school students.

• The Solar Living Institute will receive $24,900 to train kids to install solar photovoltaic systems.

• The Marin Conservation Corps will receive $25,000 to encourage elementary school students to practice energy conservation at home.

• Strategic Energy Innovations will receive $25,000 to show Americorps youth how to do residential energy audits in affordable housing units.

• The Sonoma Ecology Center will receive $25,000 to support bilingual education lessons on energy efficiency for middle school ESL students.

• The Transportation and Land Use Coalition will receive $24,986 to test a “pollution punchcard” contest as an incentive for fostering alternative modes of commuting to school.

Collectively scheduled to launch in March, each of these projects is intended to be action-oriented, with specific deliverables due upon completion.

As Air District Community Outreach Manager Richard Lew attested, the agency wants to see quantifiable results for any work it underwrites. “If we fund a program, we want it to succeed, and then take that success and make it happen on a wider replicable scale,” he said.

Lew manages the Air District’s outreach to young people, and would like to ensure they have the chance to get involved in preparing for what is on the horizon for them. As he put it, “They have the greatest vested interest in issues like climate protection because it affects their future in a much more profound way.”

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Cooking up New Rules at the Air District

By Alec MacDonald

Most people are aware of the health risks that come with eating red meat — but what about breathing it? The surprising fact is that grilling beef fills the air with particulate matter (which contributes to asthma, bronchitis, and other respiratory problems) and polycyclic aromatic hydrocarbons (many of which are known carcinogens). In response to this hazard, the Bay Area Air Quality Management District recently passed a rule intended to clean up what comes out of the kitchen vents of those Bay Area restaurants that grill a lot of beef.

“Hamburger meat produces three times more emissions [than chicken] because of the fat content — you’re using something that’s about 20 percent fat,” explained Virginia Lau, an air quality specialist with the Air District. “That’s why the rule is geared toward hamburgers and steak.”

The rule targets two kinds of commercial cooking equipment: chain-driven charbroilers (found in fast-food chains like Carl’s Jr., Burger King, and Red Robin) that move food through a heated area, and under-fired charbroilers (found in dine-in franchises like Outback Steakhouse, Sizzler, and Applebees) that keep food stationary above a heat source. In essence, the rule will require that both types of charbroilers be fitted with emission control devices.

In the case of chain-driven charbroilers, the device in question is a catalytic oxidizer that converts air contaminants to water and carbon dioxide (which is of course a greenhouse gas, but eliminating toxicity proves the more pressing priority in this particular scenario). The heat of the grill activates the process, so catalytic oxidizers have the benefit of being especially energy efficient. They have been relied upon for years in southern California, due to a commercial cooking rule passed a decade ago by the South Coast Air Quality Management District (which regulates 10,743 square miles in Orange County and portions of Los Angeles, Riverside, and San Bernardino counties, an area inhabited by over 16 million people).

“The technology is very well developed and very well established,” Lau noted, “so the costs are very well known.”

This is not as true for controlling the emissions of under-fired charbroilers. Doing so involves a device called an electrostatic precipitator, which collects particulate matter by first giving it an electric charge with an ionizer, and then harvesting it on plates of opposite charge (these plates act like magnets to the charged particles). Naturally, the plates become dirty, and must be periodically washed.

Not all restaurants will be affected by the Air District’s new rule. Its requirements apply to those purchasing a weekly minimum of beef (500 pounds for users of chain-driven charbroilers and 1,000 pounds for users of under-fired charbroilers) and there are exemptions if less than 80 percent of that actually gets grilled. Under these criteria, nearly 650 eateries in the Bay Area must comply — although they will do so somewhat begrudgingly, due to concerns about the costs involved. The Air District has faced continued resistance from the industry, despite having redrafted the rule in an attempt to eliminate the impact to smaller establishments and extend the horizon for putting emissions controls into practice.

As it stands, these controls will be mandatory for chain-driven charbroilers starting on the first of next year, and one year after that for any new under-fired charbroilers (current owners of these grills have until 2013 to retrofit them). To become more familiar with these and other details, restaurant operators and other interested parties can download the full text of the rule on the Air District’s website.

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Transportation 2035 Moves Forward

By Leslie Stewart

“We do this every three years, and every time it’s different,” said Steve Heminger, executive director of the Metropolitan Transportation Commission (MTC), as he introduced a discussion of policies for the next Regional Transportation Plan (RTP) at a Commission workshop on November 28 last year. This year, regional planning will certainly involve change, as there are significant differences between the 2035 RTP, “Transportation 2035: Change in Motion,” and its predecessors.

Scope
Transportation 2035 has a larger scope and vision. The Association of Bay Area Governments (ABAG), the Bay Area Air Quality Management District (Air District), and the San Francisco Bay Conservation and Development Commission (BCDC), are participating in its preparation. “This plan isn’t just about transportation anymore,” commented MTC senior planner Ashley Nguyen. “It includes focused growth, climate protection, market-based pricing mechanisms, and technology as well.” Nguyen stressed that local communities should look at ways this RTP can fast-forward their plans for new compact development near transit.

Performance Objectives
Planning goals in each of the “3 E” categories (Economy, Environment, and Equity) have been matched to specific performance objectives — some that are state or federal mandates — to be met by 2035:

• Environment
o Carbon dioxide 40 percent below 1990 levels
o Fine particulate matter 10 percent below 2006 levels
o Coarse particulate matter 45 percent below 2006 levels
o Vehicle miles traveled (VMT) 10 percent below 2006 levels

• Economy
o Congestion 20 percent below 2006 levels

• Equity
o Share of income spent by low- and lower-middle income households on housing and transportation 10 percent below 2006 levels

MTC recently added performance objectives for maintaining local roadways, state highways, and transit systems, as well as for reducing fatalities and injuries associated with motor vehicle collisions (including those involving bicyclists and pedestrians).

Strategies
MTC tested how the more traditional infrastructure improvements could help the region to meet the ambitious performance objectives. New to the RTP process, however, is another strategy that proposes a mix of focused growth and transportation pricing. It includes:

•The FOCUS program, which is being guided by the Joint Policy Committee, a consortium of MTC, ABAG, the Air District, and BCDC. The RTP is based on ABAG’s Projections 2007, which depicts outcomes of previous smart growth policy decisions. FOCUS recently defined Priority Development Areas and Priority Conservation Areas to better direct growth in the region. To understand the degree to which focused growth strategies could help target attainment, MTC evaluated an alternative land-use scenario, which looked at more concentrated and transit-oriented land use than Projections 2007.

•A transport pricing scenario with three components that would increase auto operating costs five-fold: a targeted parking surcharge, congestion pricing of 25 cents per mile on congested freeways, and a carbon/VMT tax that would double auto operating costs. Discounts would be built in for low-income travelers. While MTC does not intend to pursue these hypothetical pricing strategies, it was interested in ascertaining the effects of pricing on travel.

Scenario Analysis
For infrastructure, this analysis indicates that:

•The Freeway Performance Initiative (which includes
improvements such as ramp metering, more carpool lanes, and signal coordination) was cheap and effective at reducing congestion and emissions.

•High-Occupancy Toll (HOT) lanes, as complemented by a
bustling network of regional and local buses, are more costly, but introduce a new funding source: “voluntary contributions” by motorists willing to pay for speed and convenience.

•Rail and ferry systems have a very high cost relative to
their impact, but continue to grow in popularity.

Performance-based Analysis
Performance-based analysis of proposed transportation projects was begun by MTC during the last RTP process and has contributed to work on the new plan. According to Heminger, the scenario analysis shows the power of pricing and land use changes — versus infrastructure improvements — to meet targets. The Bay Area has a mature infrastructure system, and as Heminger put it, “Any new capacity will fill up unless you price it.”

“Man on the Street” Support
At the ABAG Fall 2007 General Assembly, ABAG Executive Director Henry Gardner observed that after two decades of “smart growth” planning in the Bay Area, there had been more “smart talk” than “smart walk.” According to a recent MTC poll, it appears that Bay Area residents have now found a compelling reason to walk the talk, and that reason is climate change:

•65 percent of respondents said that global warming was extremely important and should be one of the region’s highest planning priorities.

•69 percent of respondents would consider paying 25 cents per gallon more for gas if revenues went to limit or reduce global warming.

•74 percent of respondents would prefer a small home with a short commute to a larger home and longer commute, an increase of 17 percent over four years.

•87 percent of respondents said that protecting air quality in the Bay Area was extremely or very important.

Participants at public MTC workshops also said that climate protection is important, that new road pricing fees are acceptable if people know how they will be used and are assured that equity is being considered, and that good transit and affordable housing are key components of regional programs.

Policy Challenges
New approaches bring new questions. Among them are which funding sources and incentives should be used to encourage focused growth, and how to balance the benefits and revenues from pricing strategies against their impact on the target of decreasing housing and transportation costs for lower income residents. Use of HOT lane revenues in non-HOT lane corridors will require a regional agreement and/or legislative changes.

Funding Projections
As required by federal law, MTC is using escalated dollars for the plan, which makes it difficult to compare to the previous RTP. In addition, some funding sources are estimated less conservatively, and restricted funding sources have been combined when estimating the total amount of money available for the region and by county. These financial assumptions will be examined as the RTP proceeds.

Proposed projects for Transportation 2035 must be submitted by each county through their Congestion Management Agencies (CMAs) by March 5, 2008. According to Robert McCleary, executive director of the Contra Costa Transportation Authority, several CMAs have expressed concern about the funding assumptions. “We all want a plan that’s visionary,” said McCleary, “but we don’t want it to be completely unrealistic.” His CMA plans to submit a financially constrained list of projects based on numbers it feels are realistic at this time.

Project Evaluations & Trade-Offs
Between March and mid-April, projects that are part of the Freeway Performance Initiative and up to 100 other projects that are high-cost and have area-wide impacts will be evaluated “with respect to the performance objectives identified by the Commission as part of the visioning process,” according to Nguyen. Results of these evaluations, along with vision policy strategies to be considered by the Commission, will contribute to a series of discussions between mid-April and June by MTC Commissioners, partner agencies, and the public regarding the trade-offs that must be made when developing a plan where the wish list is bigger than the budget.  The Commission is scheduled to adopt Transportation 2035 in early 2009.

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Developing New Contingency Plans in the Wake of an Oil Spill

By Chris Ingraham

Three months after the Cosco Busan container ship collided with the fender of the western span of the San Francisco-Oakland Bay Bridge — ripping a 100-foot gash in the ship’s hull and spilling 58,000 gallons of oil into the San Francisco Bay — policy-makers in the region face the challenge of evaluating the collective response to the disaster, and determining how their agencies might better prepare for future oil spills.

John Escobar is the assistant general manager of operations for the East Bay Regional Park District (EBRPD), which oversees 31 miles of shoreline in Alameda and Contra Costa counties that were affected by the incident. Involved in the local response to the disaster from the beginning, he helped establish and now chairs a new East Bay interagency committee devoted to assessing that response. His intention is to approach the problem with a basic premise: “You probably shouldn’t leave your local resources idle while you wait for a federal response to get to you.” Unfortunately, this is one principle easier stated than followed.

Two days after the November 7 accident, Governor Schwarzenegger visited the spill site and proclaimed a state of emergency, mobilizing forces and freeing immediately available money from a state trust fund designated for emergencies. Because oil from the Cosco Busan spill first reached shore on the west side of the Bay and didn’t touch the east side until a few tidal cycles later, the federal response focused principally on cleaning the more high profile shoreline along San Francisco and Marin counties. So when the time came to clean and restore the East Bay, many of the federal resources were already expended. This lag left East Bay agencies such as EBRPD scrambling to deal with the spill as additional Cosco Busan and federal responders were arriving from out of the area.

Escobar speculated that Contra Costa County was probably best equipped and prepared for the spill because of all the refineries in the area, which had readily available resources and employees equipped to deal with potential accidents. “Still, in the future, all counties and agencies need to keep employee training up to date, have proper equipment on hand, and know where available resources can be found,” he said.

Volunteer efforts should factor in to the solution as well, but well-intentioned citizens occupy a different category than employees, who have stringent training requirements to protect against the dangers of exposure to hazardous materials. While personnel at refineries in Contra Costa County and elsewhere have such training, the same is not true for volunteers who just want to help. As Escobar observed, “We’re in a quandary about how to balance a strong community interest in protecting the Bay without needlessly exposing volunteers to hazardous materials.” So while EBRPD’s initial focus was to collect and save oiled birds — which lose their capacity to regulate their internal temperature and sometimes suffer from impaired or grounded flight, both of which diminish their ability to feed sufficiently — the agency couldn’t offer volunteer opportunities because of the training required and the inherent dangers of working on rocky shoreline areas. Volunteer opportunities were later organized to assist with non-hazardous work along the shoreline.

Myriad other organizational concerns arise during such catastrophes, and Escobar is working to anticipate them in conjunction with other agencies in the area, such as the Office of Emergency Services and the state’s fish and game office. These organizational concerns range from waste disposal and transportation — how, where, and by whom — to the gathering and mobilization of heavy clean-up equipment not always kept readily on hand. One method for containment, for instance, is to drop floating containment sheets booms over oil slicks, thereby stopping or diverting the oil. These containment booms, which extend above and below the water’s surface, need to be taken to sea in a boat large enough to accommodate their bulk, then distributed in the water by people experienced enough to install them properly. Having the people and equipment ready at a moment’s notice is not an insurmountable problem, of course, but the example illustrates the difficulty of carrying out a swift and thorough response. Where do we find these booms? And how do we gather the people to install them?

Most of the constructive thinking about managing oil spills focuses on rehabilitation rather than prevention. To a certain degree, the thinking goes, accidents will happen no matter how safe we may try to make the boats, or how strictly we control their passage through the region’s waters. In fact, a repeat of November 7 nearly came on January 10 when a barge loaded with 2.6 million gallons of oil collided with the Richmond-San Rafael Bridge; although the bridge’s fender system was damaged, no oil was spilled.

When disaster does strike, experts agree that oil is more easily retrieved before it hits the shore, and that waiting for the oil to reach a coastline poses more environmental risks. Accordingly, oil spills must first be contained, so their damage is therefore minimized, and then the spills must be cleaned, so the injured marine ecosystems might sooner be restored to relative healthfulness. Alongside the containment and cleaning of oil spills, however, it is important that tests be conducted to determine the extent of a spill’s impact. These tests are often as expensive as cleanup efforts, and prove important when the court system determines the legal liability of the ship owners responsible for the accident. As of December 18, testimony before Congress estimated the Cosco Busan would be responsible for $61.8 million of the damages.

Locally, the environmental advocacy organization Save the Bay is pushing for further investigation into the accident’s cause. Save the Bay is also assisting federal agencies in assessing damage to the area’s various ecosystems, from eelgrass to sandy beach, to rocky intertidal habitats and oyster beds. By investigating the accident and assessing the extent of its damage, they hope to hold the Cosco Busan accountable for the incredible cost of loss and repair. Save the Bay also plans to help restore 100,000 acres of Bay wetlands (vital because such areas filter pollution and naturally clean the Bay’s waters) by organizing hundreds of volunteers to plant native seedlings along the shoreline. While this sort of constructive solution is valuable year-round, as Escobar points out, it adds to further organizational challenges. Namely, with so many marsh renovations being done annually to the Bay’s shoreline, it is crucial that state and local agencies have updated maps to ensure that containment boom will be placed to protect these areas the next time a spill occurs.

How can policy address all of this? Unfortunately, much of the public focus surrounding oil spills is about returning recreational areas to the usable interface to which we’re accustomed. People want fishing laws reinstated and their parks and beaches reopened. Already, local agencies have done a remarkable job cleaning coastal parks and beaches sufficiently enough that most are again open for regular use, and the state has reinstated most regular fishing laws. Now, Escobar said, it’s important to create better local agency coordination, and “to be more engaged in updating the ACP [Area Contingency Plan], which is the road map for oil spills in the area.”

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A More General Look at Coordinating Responses to Regional Emergencies

By Chris Ingraham

On January 3 of this year, elected officials from San Jose, San Francisco, and Oakland convened on Treasure Island to introduce the Regional Emergency Coordination Plan (RECP), a new 145-page response plan for emergencies in the Bay Area, funded by a $2.2 million grant from the Department of Homeland Security. According to the plan’s introduction, it “defines procedures for regional coordination, collaboration, decision-making, and resource sharing among emergency response agencies in the Bay Area.” As outlined by the plan, this includes the counties of Alameda, Contra Costa, Del Norte, Humboldt, Lake, Marin, Mendocino, Monterey, Napa, San Benito, San Francisco, San Mateo, Santa Clara, Santa Cruz, Solano, and Sonoma. The plan exhaustively details which responsibilities are expected of regional, state, and federal agencies in the event of a large public emergency, and it can be activated after any disaster, be it caused by humans or by nature.

Essentially, the plan reads like a long skeleton of bullet-pointed lists: lists of objectives, lists of expectations, lists of organizations, lists of regions under each organization’s jurisdiction, lists of responsibilities and duties each organization is expected to fulfill, lists of different levels of emergency, and lists of which circumstances need to exist for various organizations to be held accountable for fulfilling their responsibilities in a given emergency. Such a plan will perhaps be of most use if taken into consideration now, before an emergency, as opposed to the kind of plan evoked and referred to once an emergency arises. In other words, while the RECP does a thorough job of delineating responsibilities and hierarchies of power, it does not often address the question of how, exactly, many of the necessary responses can be implemented or prepared for.
For example, the plan lists its priorities in the following order: saving lives; addressing human needs; caring for vulnerable populations; protecting property; restoring basic services; protecting the environment; and finally encouraging community and economic recovery. Take the problem of restoring basic services, such as power, sanitation, or public transportation. In the event these need to be restored, the RECP says, utility companies are responsible for “restoring utility services in accordance with emergency restoration procedures.” Yet this leaves unanswered the question of how they are supposed to do that, say, if an earthquake has knocked out important power hubs. While this level of specificity is beyond the purview of the RECP, however, at least it should still prove useful in establishing a chain of responsibility and communication.

To access the plan, click here.

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Bay Area League Day - Transportation Solutions to Climate Change

9:00 a.m. - 2:30 p.m. on Friday, February 22, 2008
Nile Hall, Preservation Park (12th Street and MLK Jr. Way), Downtown Oakland

SCHEDULED PROGRAM

Registration and Refreshments

Keynote: Transportation 2035 & Climate Change
Therese McMillan, Metropolitan Transportation Commission

Panel 1: Perspectives on the Regional Plan & Funding Options
Stuart Cohen, Transportation and Land Use Coalition
Robert McCleary, Contra Costa Transportation Authority
Bob Allen, Urban Habitat

Lunch

Panel 2: Safe Routes to Schools & Other Local Solutions
Jim Smith, Bay Area Air Quality Management District
Rochelle Wheeler, Alameda County Transportation Improvement Authority

Panel 3: Sub-Regional Bus Service & Pedestrian/Bicycle Options
Robert Raburn, East Bay Bicycle Coalition
Chris Augenstein, Santa Clara VTA

To preregister, send a check for $25 ($15 if not having lunch) payable to the League of Women Voters of the Bay Area, 1611 Telegraph Avenue, Suite 300, Oakland, CA 94612, or register online at www.lwvbayarea.org/BALD.html. The deadline for preregistration is February 13, after which the cost increases to the day-of-registration fee of $30. Call (510) 839-1608 for more details.

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