August 15, 1999
Bay Area Air Quality Management District
Attn: Milton Feldstein
939 Ellis Street
San Francisco, California 94109
Re: Federal Air Quality (Shell Game) Plans
Dear Mr. Feldstein:
If you would put as much energy into cleaning up the air as you do in trying not to do it, but to convince the public that you have, we would have met all of the standards long ago. We should stop trying to please businesses who don't want people to know how dirty the air really is, and try to actually achieve the clean air and public health that is the ultimate goal of these laws.
There are several reasons why we appear to be achieving the federal standards. The main reason is that we "ship" most of our pollutants into other air basins such as Sacramento and the San Joaquin Valley, preventing them from achieving their clean air goals and keeping them Nonattainment Areas. This reason alone is sufficient not to try to be named an "Attainment Area". It would be an insult to the people living in those areas.
A second reason we seem to have met the federal ozone standard is that the BAAQMD has deliberately ignored NOx. This has (reportedly) the effect of lowering our ozone level, while increasing ozone levels downwind, as well as acid rain and damage to crops, forests, and lakes.
A third reason is that BAAQMD has aquiesced to the Metropolitan Transportation Commission's so-called "Transportation Control Measures", many of which may reduce emissions slightly in the short term (by reducing traffic congestion), but are by the same token guaranteed to increase emissions in the long term (by promoting long-distance motor vehicle travel). TCMs 4 and 20 consist of constructing HOV lanes by expanding freeways all over the Bay Area! This only subsidizes long-distance motor vehicle travel, and does nothing to reduce the two largest sources of motor vehicle emissions: the number of trips (i.e., "cold starts" and "hot soaks") and VMT (vehicle miles travelled). Similarly, HOV 8 built parking lots, instead of funding transit or bicycle projects that could have completely eliminated auto trips.
TCMs 13-15 increase tolls and gas taxes, but preclude any chance for an air quality benefit by using the money to expand roads and bridges! TCMs 24-25 are putting millions of dollars of "air quality" funds into synchronizing traffic signals around the Bay Area, which once again merely subsidizes long-distance auto travel at the expense of transit, bicycling, and other clean modes of travel. In spite of statements by people like Elizabeth Deakin, who profit from promoting signal synchronization, there is absolutely no credible evidence that it has any air quality or fuel consumption benefit!
TCM 26 further increases the auto subsidy by spending more public money to help motorists whose vehicles break down or have accidents on our freeways. Unbelievable as it sounds, MTC even has plans to put roving tow trucks on all of the freeways, simply roaming around burning up fuel and looking for motorists in need of help! Needless to say, nothing is being done to provide comparable help for pedestrians or bicyclists. This would be like paying nurses to drive around looking for people who are sick. If we can't afford such service in the medical field, why should we pay for such a luxury when it involves motorists?!
Similarly, BART is building $10,000 parking spaces to lure rich suburbanites onto a train. I'm surprized they don't offer to also drive them to the station and park their car for them! I guess we'll have to wait till next year for that. Meanwhile, bicycle and transit users are treated to delays and inconvenience, such as illegally parked motorists at Walnut Creek Station who impede bus movements (while the BART police look on and do nothing), and traffic lights (e.g. at Walnut Creek Station) that give an enormous amount of time for through auto traffic, but only 4 seconds for buses to turn left into the station. BAAQMD, of course, has been completely silent, or even supportive, of all of these auto subsidies!
Another important reason we are apparently progressing is that we don't sample the air in the right places, especially for CO. A sampling station near any of our freeways would tell a different story, but one that the business "leaders" who pull BAAQMD's strings don't want to hear.
Another reason for rejecting the "Attainment" strategy is that, as is well known, the current federal ozone standard (12 ppm) is far too weak. The state standard is 9 ppm, and the EPA is reportedly considering lowering the federal standard to 6 ppm. This would mean that every single ozone measurement station in the Bay Area would be in violation of the standard, even San Francisco! This hardly describes an "Attainment Area".
The "Conformity Process" section of the plan is a joke. You say that "MTC will not approve any transportation plan, program, or project unless these activities conform to the purpose of the SIP". I wish it were true! Actually, MTC has approved, and continues to approve, many projects, as described above, that increase dependence on motor vehicles and make it easier to drive. In fact, that seems to be their primary objective. The fact that a corrupt federal judge gave them the permission to do it doesn't change the fact.
Thank you for listening.
Michael J. Vandeman, Ph.D.