‘DEI Bike Lanes’ – Sacramento City Council Inflates Bicycling Numbers for Federal Taxpayer Grants

Federal Funding Source: Congestion Mitigation and Air Quality (CMAQ) and Regional Surface Transportation Program (RSTP) funds administered by the Sacramento Area Council of Governments (SACOG) as the designated Metropolitan Planning Organization

Known Federal Awards (Prior Rounds):

• 2020/2021 SACOG Regional Program round: $3,120,000
• 2022/23 SACOG Regional Program round: approximately $6,803,000 (staff-recommended award)
• Combined total awarded to date: approximately $9,923,000

Currently Programmed Metropolitan Transportation Improvement Program (MTIP) (2025 FSTIP):

• SAC25264 (Phase 1): $11,644,000 total; $7,954,000 federal; construction target 2027
• SAC25265 (Phase 2): $4,059,128 total; $850,000 federal; construction target 2028
• Combined MTIP total: $15,703,128; federal portion: $8,804,000
• FY2025/26 federal funds at immediate risk of obligation: $1,995,000

 The City took the American River Parkway’s total annual system-wide visitation and simply applied it as the projected daily usage for this specific 4.0-mile project segment.

The Sponsor’s Note expressly conditions the 13,500 Average Daily Trips on completion of the ultimate Sacramento River Parkway trail to downtown. Notably, This project does not complete the trail to downtown, as it terminates at Zacharias Park. North of Zacharias Park, a 1.4-mile fenced-off gap through the Little Pocket neighborhood remains, and it is acknowledged in the City’s own 2022/23 application as a separate future project with no funding, no timeline, and no commitment. The City submitted an ADT projection conditioned on a network that this project does not produce and cannot produce alone.

This application resulted in a federal award of $3,120,000.

Document 2 — 2022/23 Application, Application Element 5: Cost-Effectiveness Calculation, and Application Narrative

(Attached as Exhibits B & B.1)

Approximately one year later, the City submitted a second Transformative Category application to SACOG for the identical project (SAC25264, SAC25265), same geographic scope, same project contact, same trail between Garcia Bend Park and Zacharias Park. The cost-effectiveness spreadsheet contains:

• Daily Travel (Average Daily Trips): 9,000
• Annualization Factor: 365
• Project Cost: $20,761,000
• Useful Life: 50 years
• Calculated Score: 7.91 (approximately 8)

The total population of Sacramento’s Pocket area is 25,000.

The Sponsor’s Note reads:

“The Jedediah Smith Memorial Trail along the American River is used by approximately 5M people per year. The ADT assumes 2/3 similar annual usage upon the completion of the ultimate Sacramento River Parkway trail to downtown.”

The two Sponsor’s Notes are word for word identical except for the insertion of “2/3” in the second application. The arithmetic confirms: 5,000,000 × (2/3) ÷ 365 = 9,132, rounded to 9,000.

The entire change in methodology between the 2021 and 2022/23 applications consisted of inserting the characters “2/3” into an otherwise identical sentence.

This application resulted in a staff-recommended award of approximately $6,803,000.

Document 3 — 2022/23 Application, Application Element 6: CMAQ Calculation

(Attached as Exhibit C)

The same 2022/23 application package also includes a CMAQ emission reduction calculation — Application Element 6 — which contains a third distinct ADT figure across the two application rounds:

• Average Daily Traffic (ADT): 9,619 trips per day
• Days of use per year: 325
• Annual auto trips reduced: 15,006
• Annual auto VMT reduced: 56,871
• CMAQ funding requested: $15,237,000
• Project scope described as: 3.79 miles of new Class 1 facility

This figure differs from the 9,000 ADT in the cost-effectiveness calculation submitted in the same application package. The City submitted two different ADT figures within the same grant application with no explanation of the discrepancy and no reconciliation between them.

The The Community Multiscale Air Quality (CMAQ) figure of 9,619 is higher than the cost-effectiveness ADT of 9,000, meaning the CMAQ calculation claims more vehicle-substituting trips than the cost-effectiveness calculation claims total daily users. This internal inconsistency within the same application confirms that no unified methodology generated these figures. 

The absolute magnitude of the CMAQ-claimed emission benefits warrants specific attention. The CMAQ calculation claims 15,006 annual auto trips reduced — which at 325 days of use per year represents approximately 46 daily vehicle trips eliminated from a corridor carrying 32,222 single-occupant vehicle trips per day as observed in the 2020 PPA. The project’s entire CMAQ-qualifying benefit is a claimed reduction of less than one-tenth of one percent of existing corridor vehicle traffic. The claimed annual NOx reduction of 11 pounds per year – which is the equivalent to removing approximately 11 passenger vehicles from the road – is the basis on which $15,237,000 in CMAQ-designated federal funds was requested.

CMAQ funds are specifically designated for cost-effective air quality improvements in nonattainment areas. Whether a project claiming 46 daily vehicle trip reductions genuinely qualifies for CMAQ designation is a question the OIG may wish to examine.

In the same 2021 competitive round where Sacramento’s trail received $3,120,000 in CMAQ-designated funds based on an ADT of 13,500, the City of Folsom submitted a documented application for the US 50 Empire Ranch Road interchange and scored approximately 16 on cost-effectiveness — higher than Sacramento’s approximately 15 — and received zero from the same competitive pool.  That project would construct a four-lane overpass with full ramp connections on US 50, specifically designed to reduce congestion, improve safety, and reduce travel time for tens of thousands of daily commuters on one of California’s most traveled freeway corridors.

THE AMERICAN RIVER PARKWAY COMPARISON IS INDEFENSIBLE

The Jedediah Smith Memorial Trail along the American River (the sole analytical basis for both ADT figures in both applications)  is not a valid comparable facility for the Sacramento River Parkway Pocket segment. The relevant differences are objective facts documented in the City’s own application materials.

The network completion condition stated in both Sponsor’s Notes is not satisfied by this project, as acknowledged in the City’s own application. Both notes state the ADT assumes usage upon completion of the ultimate Sacramento River Parkway trail to downtown. The City’s own 2022/23 application narrative acknowledges on page 15 that a separate 1.4-mile gap remains as a future project. This gap is geographically distinct from and north of the current project, which terminates at Zacharias Park. Users attempting to commute from the Pocket segment to downtown must leave the levee at Zacharias Park and navigate surface streets before reconnecting to any existing off-street trail heading toward downtown. The American River Parkway, whose 5 million annual users form the basis of both ADT projections, is a continuous 32-mile off-street system with no equivalent surface-street gap requiring navigation at any point in a user’s journey.

Length. The American River Parkway trail system is approximately 32 miles long. The Pocket segment is approximately 4.0 miles — roughly 12% of the comparison facility’s length. Claiming equivalent total daily usage means the Pocket segment would be used approximately eight times more intensely per mile than the American River Parkway. No analysis supporting this per-mile intensity claim appears anywhere in the application record.

Destination amenities. The American River Parkway has swimming beaches, equestrian trails, fishing access, multiple regional parks, picnic areas, a nature center, and connections to Folsom Lake. These destination amenities generate a substantial portion of the American River Parkway’s 5 million annual users. The Pocket levee trail project is a paved path atop a flood control levee running through residential backyards – at least 68 of which would need to be obtained by the City.

Observed demand characteristics. The City’s own PPA data shows 2% bicycle mode share within 0.5 miles of the project and 814 jobs within walking distance. The City cited both figures in its own application narrative, acknowledging they reflect a highly car-dependent neighborhood with limited active transportation demand. The City derives 13,500 and 9,000 not from this baseline through any documented induced demand methodology, but from the American River Parkway comparison with no adjustment for the fundamental differences between the two facilities.

The arbitrary percentage reduction. The reduction from 100% to 67% of the American River Parkway’s usage between the 2021 and 2022/23 applications was implemented by inserting “2/3” into an otherwise identical note. No analysis explains why two thirds rather than one half or any other fraction. The American River Parkway did not change between 2021 and 2022/23. The project scope did not change. The Little Pocket gap did not close. The network completion condition was no closer to being satisfied. No documented factor changed that would analytically produce a 33% reduction in projected usage. A genuine comparable facility analysis produces a percentage based on documented, cited factors. No such documentation exists anywhere in either application.