August 21, 1987
United States Environmental Protection Agency
215 Fremont Street
San Francisco, California 94105
The California Department of Transportation (Caltrans) and the Federal Highway Administration (FHWA) are planning to widen Highways US 680 and CA 24 between Pleasant Hill, CA and Walnut Creek. They have submitted a Final Environmental Impact Statement, FHWA-CA-EIS-86-04F, in justification of this project. Please reject this document and this project!
As you well know, the San Francisco Bay Area is a Nonattainment Area with respect to both Federal (as set in the Clean Air Act of 1970, amended in 1977) and State Air Quality Standards (in plain English, the air isn't fit to breathe!). The EIS bases its case on a chart on page 2-4 which states that the proposed project will actually improve the air quality, relative to the alternative ("No Build"), and implies that widening the freeway will keep the air quality within the standards. This is pure fantasy! There is no way that 8 lanes of traffic jam (in the year 2010) will produce less pollution than 6 lanes of traffic!
1. In your November, 1986 comments on the Draft EIS, you said that these figures could not be evaluated without access to the assumptions that were behind them. In spite of this, Caltrans DID NOT REVEAL THESE CRUCIAL ASSUMPTIONS in either their Final EIS or their Air Quality Report (because it would then be obvious why their figures are wrong).
2. Their prediction was based on estimates of peak-hour traffic volume in 2010 of 17,900 and 16,500 (north and south of the interchange, resp.). These predictions for 2010 were already passed IN 1985 (when the traffic figures, according to Caltrans' own counts, were 19,900 and 14,600)!
3. Caltrans must have assumed that adding 2 more lanes would not encourage more people to drive (or, in other words, that traffic jams don't discourage people from driving). The correct figures for the carbon monoxide 1-hour total parts per million, using the more reasonable assumption that the traffic expands to fill the available roadways, would be more like 16.5 for the No Build alternative (within the standard) and 22 (in violation of the standard) (in the proportion of 6 lanes to 8) if the freeway were expanded as planned.
If our Air Quality Standards mean anything at all, they imply that we must reject ANY PROJECTS WHICH TEND TO INCREASE TRAFFIC:
1. We are already in violation of those standards.
2. The Bay Area Air Quality Management District (BAAQMD) has done an excellent job of controlling stationary sources, but say they have no jurisdiction over moving sources of pollution.
3. This leaves us only one alternative: DECREASING TRAFFIC.
According to your title, your job is to PROTECT THE ENVIRONMENT. Please reject this project, and all others like it that make the environment worse! Without our health, what else matters??? This money would be better spent extending BART (rapid transit).
Michael J. Vandeman, Ph.D.