April 21, 1991

Board of Directors

Bay Area Air Quality Management District

939 Ellis Street

San Francisco, CA 94109

Re: Bay Area '91 Draft Clean Air Plan: Not Implementing All Feasible Controls


Your middle name should be "Overly Optimistic". This is fine, in most situations. I would much rather be around optimists, than pessimists. It is not good, however, when it interferes with achieving an important goal. And it does. On p.70 you admit that all previous Bay Area air quality plans have "undercontrolled emissions compared to what was necessary to meet air quality goals". Why should we trust that you are going to do it right this time?

Another indicator that you cannot be trusted is the fact that you had to be sued in federal court (by CBE) to get you to implement the previous air quality plan, and even there you continued to try to prevent it from happening. (There wasn't a single word about this in your CAP. On the contrary, you lied about it on p.30: "Carrying out all 'feasible' measures will continue the comprehensive control strategies that have typified the Bay Area programs for several decades." "Footdragging" would describe your efforts better.)

I can't understand your need to continually pat yourselves on the back and lie. That just arouses more distrust. On p.10 you state that "air quality has improved steadily over the past twenty years". And on p.11, "CO levels improved steadily in the region despite increases in travel and congestion". A glance at the jagged up-and-down graphs on the very same pages, however, makes it obvious that the progress, if there has even been any statistically significant downward trend (pretty doubtful), has not been "steady"! And Judge Henderson agreed, when he concluded that you had not been making "Reasonable Further Progress" in the 1982-1987 period. Have you been practicing "How to Lie with Statistics"?

Another, more subtle lie, is the trust you place in your modeling, as indicated, e.g., in the fact that you estimate emissions down to a single ton per day. Why not go to tenths of a ton? Why not hundredths? Standard practice in statistics is not to express the conclusions with any precision greater than that justified by the method used. It is doubtful that your models can predict emissions to within 1 ton. In fact, judging from the description of your model validation process on p.18 (it is similar to MTC's -- see the enclosed letter re MTC's modelling), you have not proven any validity for your models. In any case, such models at best have very low reliability and validity. The Bay Area's failure to meet federal air quality standards in 1987 called into question your ability (and/or willingness) to predict air quality accurately.

The most serious defect of the CAP is that it does not implement all feasible controls, even though this is required by the law. Halting the expansion of the freeway system in the Bay Area is one of the best control measures we have available for discouraging auto use and auto dependency. Congestion, as shown by the earthquake, is a very easy (and humane and fair) way to eliminate a large percentage of auto traffic. In the Cypress corridor, Caltrans estimated that 90,000 vehicle trips per day disappeared overnight (that's about 25%). Public transit accommodated many of those trips (e.g. BART increased more than 10%), and others probably were simply eliminated. This measure is obviously feasible, since it is in effect today (most of the freeways haven't been expanded yet)! It is also clearly one of the most cost effective of all possible measures; in fact, it's free! Foregoing the "luxury" of highway expansion would save billions of dollars, and free up those funds to improve public transit, save our schools from budget cuts, and attempt to mitigate the damage that cars and freeways have done to our environment, health, and lifestyle. (By the way, you should list the cost-effectiveness figures for the TCMs, as you did for stationary source controls.)

On p.28 you state that we are required to achieve "no net increase in vehicle emissions after 1997". How can we do that, other than by stopping to expand our roads???

Stopping highway expansion and shifting the funds toward public transit would also help the economy (it is well known that transit creates many more jobs, and higher quality jobs, than does highway construction) and increase the equity of your plan. The poor live mostly in the inner cities, where public transit, bicycling, and walking are viable. (The notion that the poor drive cars, and thus would be adversely affected by controls on driving, is a myth. They are ideally situated to take advantage of better transit, bikeways, and pedestrian amenities.) Expanding highways makes no sense, and opens you up to a lawsuit, since you are required to implement all feasible measures, and since highway expansion (even in the form of "HOV" lanes) is not a TCM -- it doesn't reduce air pollution. The same goes for so-called "transit service improvements" like the construction of more parking lots. This only increases auto dependence. Transit access should be by bus, bicycle, walking, or other clean mode of travel.

Another important measure was omitted: research. Since a number of your measures are of uncertain value, you should monitor their effects to make sure they are delivering the promised emissions savings! For example, there is evidence that the HOV lanes in Santa Clara have actually decreased the proportion of ridesharing (by freeing up lanes for single-occupant drivers).

You make no mention of global warming and ozone depletion, both of which are caused, in the U.S., mostly by the automobile. Ignoring them won't make them go away. The ozone protection over North America has already gone down 4-5%. The U.N. has concluded that we need to reduce fossil fuel consumption 50% below current levels. Building more highways won't accomplish that, and when we do reduce traffic that much, none of the new lanes will be needed. They are just pure waste -- a gift to the highway construction industry and Caltrans.

On p.69 you mention contingency measures. These should be an explicit part of the CAP. And they should be unequivocally beneficial to air quality, unlike some of the "fuzzy" measures that are of unknown value. Eliminating or reducing parking would be a good one.

I love your repeated attention to the fact that everyone must do his/her part. That is where true equity lies. Each person's part may be different, but we all have one. Now let's see you do yours!


Michael J. Vandeman, Ph.D.

P.S. I have a question. Where does CO go? Does it get converted gradually into CO2? What is its half-life? Thank you.