I was involved in a car accident on a surface street (non-highway) in
Norwalk, CA. Cars in all three lanes stopped at an intersection and
once the light turned green I allowed at least 1.5 car lenghts before
I released the brake. I was looking for parking and was unable to stop
in time when the car in front of me stopped.   The deputy that took
down the police report mailed me a traffic citation. He was not
present at the time of the infraction, but through the accident report
concluded that I violated traffic code 22106, Unsafe start. This
accident occuried during a period of high congestion on the road and I
hit the person at a low speed (my airbags did not deploy). I want to
fight this ticket and decided to fill out a trail by declaration.
According to 22106, this is only a violation on the HIGHWAY; it never
mentions the surface streets. Additionally the deputy could have
misinterpreted me and falsely assumed that I broke the law. Are these
good points to bring up in the declarations and are there more I can
add?

I believe you mean TRIAL (not "Trail") Hence "TRIAL by Written Declaration"

I don't live in California and I have never seen that state's vehicle
code before today.

My comments are intended to be general observations on traffic laws
and laws in general.

Throughout almost all traffic laws in all countries where a driver is
following behind a car proceeding along a road in the same direction
as they are, the driver behind has an obligation to stop before they
hit the car in front of them. It doesn't matter a damn why the car in
front stopped, or how fast they stopped, the driver behind has an
absolute obligation to stop before they hit the car in front.
Therefore the driver behind must adjust their driving, pay attention,
and judge their own speed and separation from the vehicle in front so
they can stop before they hit the car in front.

I am not in California but I found the laws I believe you are
referring to at this location
http://www.dmv.ca.gov/pubs/vctop/vc/vc.htm
It is called "2006 California Vehicle Code"

Code 22106 is not called "Unsafe start" as you said but rather it's title is
"Starting Parked Vehicles or Backing"
and it says
"22106.   No person shall start a vehicle stopped, standing, or parked
on a highway, nor shall any person back a vehicle on a highway until
such movement can be made with reasonable safety."

Laws should always be read in their context. When reading any law,
statute, act, code, rule, or regulation you will find words that have
particular meanings. Those meanings may not be what you personally
commonly understand them to mean but the meaning given to the words by
some other law. However most laws in democractic countries use words
and meanings that the majority of people agree on.

Typically the law, statute, act, code, rule, or regulation contains a
set of meanings or definitions of words and phrases and typically
those are at or very near the beginning of the law, statute, act,
code, rule, or regulation. Many words and phrases are used across many
or all the written laws of a country so most countries have a set of
Interpretation laws. Where I live that law is called the
"Interpretation Act".

In your case you are concerned that the road you were on was a
"surface road" whatever that phrase means to you and not a "highway".
I couldn't find the phrase "surface road" in the 2006 California
Vehicle Code however you may care to look in the same Vehicle Code at
590 and 360
590.   "Street" is a way or place of whatever nature, publicly
maintained and open to the use of the public for purposes of vehicular
travel. Street includes highway.
360.    "Highway" is a way or place of whatever nature, publicly
maintained and open to the use of the public for purposes of vehicular
travel. Highway includes street.

Finally, I imagine you told the Deputy you were looking for somewhere
to park. I would interpret that as saying "I wasn't paying complete
attention to the vehicle ahead of me".

Good Luck.