January 1, 1992

Berkeley City Council

City of Berkeley

2180 Milvia Street

Berkeley, California 94704

Re: Caltrans's I-80 "Environmental Reevaluation"


The City should continue to oppose this project. In particular, we should refuse to sign a freeway agreement, without which it will be impossible to build, since it requires additional right-of-way through Berkeley. The reasons are too numerous and complex to adequately describe in less than a book, but here is an overview.

Any capacity-increasing highway project in an area with increasing traffic encourages people to drive more, and hence increases our dependence on the automobile and on petroleum. Even if the widening were simply to add an HOV lane (which it's not), experience and common sense indicate that any "incentive to use HOVs" is cancelled by an equivalent incentive to drive alone, since all HOVs are removed from the mixed flow lanes. In Santa Clara County, the experience has been that the both the absolute number of carpoolers, and the proportion of people carpooling, have decreased since the new HOV lanes opened!

Caltrans admits (see the tables on pp.23-25) that the project will increase emissions of CO. This is a major increase in honesty over all other Caltrans environmental documents that I have seen; however, it gives us a good reason to oppose it. Even though the projected levels of CO are below current ambient air quality standards, I see no reason to allow them to rise, especially since the project has many other faults and no real benefits for Berkeley.

They describe most of the inputs to the CO analysis, but conveniently omit the traffic counts, which have traditionally been the primary means by which Caltrans has manipulated CO projections to fit its goals of building more and bigger freeways. "No-build" traffic is always projected to be slow and congested, while "Build" levels are arbitrarily "constrained" to a level permitting free-flowing 55 MPH traffic. This has the effect of making CO projections artificially high in the "No-build" case, and low in the "Build" case. ABAG cooperates, by predicting large increases in traffic. In other words, they deny the possibility of the region ever reducing its dependence on the automobile! And they also deny the possibility that expanding roadways causes people to drive more (or the converse, that congestion discourages people from driving).

Caltrans fails to mention that the project will increase ozone. It is obvious that any project that encourages driving will increase hydrocarbons, and hence ozone. They also fail to mention that the EPA has concluded that there is no safe level of ozone exposure. Even the state standard of .09 pphm isn't strict enough to protect human health.

Some other bad ideas that are a part of this project are traffic signal synchronization (which encourages driving but does nothing to promote cleaner modes of travel), expanded Park and Ride lots (we should encourage people to take transit, not drive), and a "continuous roving tow truck service" (which generates more pollution.

The so-called energy savings attributed to the project are reversed, if more honest traffic counts are used: increased auto dependence simply delays the day when we will convert to the more energy-efficient modes of transportation -- walking, bicycling, and light rail. For the same reason, the project is not "cost effective", as asserted on p.7. For a much lower cost, a rail line can carry as many people as eight freeway lanes.

It is not acceptable to take any more wetlands. So-called "mitigations" (creating new wetlands elsewhere) are about as acceptable to wildlife as the equivalent dislocation would be to humans. Caltrans also fails to adequately assess the effects on endangered and other wildlife. They are affected by all of the environmental poisons and noises that affect us, plus the toxic runoff from the additional pavement and traffic. It is not a coincidence that we have driven and are driving hundreds of species in this country to extinction. Roads play a major part in that tragedy, both by directly killing animals and plants, as well as by degrading and fragmenting habitat. It is time to stop expanding roads and start removing as many as possible and replacing them with cleaner modes of transportation (including provisions for wildlife crossings).

Last, but not least, there is no mention of Global Warming or Ozone Depletion, both of which are serious threats caused in large part by the automobile. Because they constitute significant new information, a new EIR, not an "Environmental Reevaluation", is required by CEQA.

Sincerely yours,

Michael J. Vandeman, Ph.D.