May 6, 1991

Air Resources Board

1102 Q Street

P.O. Box 2815

Sacramento, California 95812

Re: Proposed Guidance -- "HOV System Plans as Air Pollution Control Measures" & "Transportation Performance Standards of the CCAA"


These documents are clearly unrelated to air quality. They are designed to justify the continued highway expansion plans that are intended to enrich Caltrans, politicians, and big business. However, there is still a remote chance that someone might take you seriously, so they require a response.

The questions that must be answered about HOV lanes (especially when they are implemented via highway expansion) are: do HOV lanes decrease air pollution and fuel consumption (are they beneficial), and if so, are they cost-effective compared to other available measures? You attempt to show that they are beneficial, but you give absolutely no scientific evidence to support it. This is, of course, because there is no such evidence! In fact, as you well know, the only scientific research on this issue has shown that highway expansion increases air pollution and fuel consumption (see references below).

A few years ago, I pointed this out to Anne Geraghty of the ARB. She said that the research was done in Australia (of course, this isn't true, demonstrating that she hadn't read it), and that we need research done in the U.S. Well, the research has now been done in the U.S. (by Tom Addison), and it came to the same conclusion. Of course, your bibliography conveniently omitted any mention of any of this research.

Since added HOV lanes don't reduce emissions, they don't fall under the CCAA's definition of a transportation control measure (TCM). The calculation of alleged emissions reductions that you present in Appendix C completely ignores the growth-inducing effect that increased highway capacity has on trips and VMT, and is thus as phony as a $3 bill.

Your analysis of cost-effectiveness is equally specious. Added HOV lanes don't save fuel, as I stated above. And their cost is enormously greater than such demand reduction measures as a gas tax, pollution tax, parking charges, or parking reductions, all of which provide a net income!

It is not obvious that, as you say on p.1, "an HOV system provide[s] incentives for drivers to use ridesharing and transit modes". By adding an HOV lane, HOVs are removed from the mixed flow lanes, making it easier to drive alone. In fact, an analysis of HOV lanes in Santa Clara found that the proportion of people ridesharing or using transit decreased following addition of an HOV lane!

Your analysis of the effects of congestion (p.1) is also bogus. When speeds are decreased from 55 to 20, obviously many people will stop driving or forego the trip altogether. This is exactly what happened when the Cypress freeway fell down: 90,000 trips/day simply disappeared (according to Caltrans). You also ignore the fact that increasing speed increases NOx.

The CCAA requires us to reduce trips and VMT. (The greenhouse effect, which you ignore completely, also requires this. The U.N. has stated that we need to reduce fossil fuel consumption 50% below current levels.) Clearly, expanding highways does not support this goal, and in fact, encourages increased trips and VMT! If we have to decrease trips and VMT, how do we know that we will need any added vehicle capacity? Shouldn't we first decrease trips and VMT, and then see if any added vehicle capacity is justified?

On p.6, you call these issues "unresolved technical issues". They are neither unresolved, nor technical. It has already been amply demonstrated that added vehicle capacity worsens air quality. Even if the issue were unresolved, the seriousness of our air pollution risks makes it imperative that we first determine if we are headed in the exactly wrong direction, before we proceed with highway construction plans that could make air pollution worse all over the State for many decades to come!

On p.8 you applaud HOV lanes that led to casual carpooling. But you conveniently forgot that casual carpooling siphoned so many passengers off of public transit that it caused serious financial difficulties for A/C transit, which had to raise fares.

You mostly ignore the fact that HOV enforcement is a nightmare in most situations: where, and how, could a vehicle be pulled off the road in order to cite it? Most HOV lanes will be at the median, where there is no shoulder. On p.13, you blithely assert that 2-person HOVs are more beneficial, although you cite no proof other than a personal opinion! Also on the same page, you recommend park-and-ride lots, although you have no evidence to support your conclusion. Clearly, supporting pedestrian, bicycle, and transit access rather than auto access would be more likely to reduce auto dependence.

On p.21 you ask if demand management is cost effective, but don't answer the question. Clearly, demand management is cheaper than massive highway construction. You then assert that HOV lane construction is cost effective "because its primary costs are borne by the transportation sector". Not only is this false (under Prop. 111, local sales taxes must provide a 50% local match), but just because it is being paid for doesn't make it cost effective!

Under "Monitoring HOV system performance", you should measure trips & VMT in the entire corridor, not just on the highway, since the added capacity can be growth inducing throughout the corridor. And under "HOV system inicators", vehicle speeds and hours of delay are irrelevant; only trips, VMT, and emissions are relevant, since they relate to the purpose of the CCAA.

You omit discussion of added mixed-flow (non-HOV) lanes. Since many new highways and new mixed-flow lanes are planned throughout California, guidance is direly needed to stop this madness. In the second paper, you refer to the need for no net increase in vehicle emissions after 1997. Obviously, this will require an end to highway expansion, since there is a limit to emissions reductions in the automobile, but no limit to trips and VMT (except lack of auto facilities such as road space and parking).

In short, your papers are nothing but opinions calculated to justify a political and business agenda, completely unsupported by any scientific studies. Corruption is an Air Resources Board trying to please big business, while adding to the misery of the residents of California. How do you sleep at night?


Michael J. Vandeman, Ph.D.


Tom Addison, "A Study of Freeway Capacity Increases in the San Francisco Bay Area and Greater Sacramento", EPA Region IX, Air Programs Branch, 9/28/90.

Stanley Hart, "Huge City Subsidies for Autos, Trucks", California Transit, July-Sept., 1986.

Jill Jaeger, "Developing Policies for Responding to Climatic Change", World Meteorological Organization, April, 1988.

P.W.G. Newman and J.R. Kenworthy, "The use and abuse of driving cycle research: clarifying the relationship between traffic congestion, energy and emissions", Transportation Quarterly, Vol.

38, 1984, 615-635.

P.W.G Newman, J.R. Kenworthy, and T.J. Lyons, "Does Free-Flowing Traffic Save Energy and Lower Emissions in Cities?", Search, Vol. 19, No.5/6, September/November, 1988.

P.W.G Newman, J.R. Kenworthy, and T.J. Lyons, "Transport Energy Conservation Policies for Australian Cities", End of Grant Report, Project No. 836, August, 1987.

J.R. Kenworthy, H. Rainford, P.W.G. Newman, and T.J. Lyons, "Fuel Consumption, Time Saving and Freeway Speed Limits", Traffic Engineering and Control, September, 1986.