August 27, 1987
David L. Eyres, District Engineer
Federal Highway Administration
P. O. Box 1915
Sacramento, California 95809
I understand that the period for commenting on your Environmental Impact Statement, FHWA-CA-EIS-86-04F (regarding widening Highways US 680 and CA 24 between Pleasant Hill, CA and Walnut Creek), is still open. I would like to submit the following:
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 6-41 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! In order to arrive at that conclusion, you would have to assume:
1. Eight lanes of traffic (the "build" alternative) will be flowing smoothly, at the speed limit (with no "peak period demand not accommodated"), as shown in the chart on page 6-5. This is based on your traffic predictions for the year 2010 shown in the chart on page 2-4. However, those predictions are absurd. According to your own traffic figures, those predictions for 2010 were surpassed in 1985!
2. Adding more lanes does not encourage more people to drive; or in other words, traffic jams do not discourage people from driving. This also seems unbelievable to me.
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.
In the EPA's November, 1986 comments on the Draft EIS, they said that these figures could not be evaluated without access to the assumptions that were behind them. In spite of this, you DID NOT REVEAL THESE CRUCIAL ASSUMPTIONS in either your Final EIS or your Air Quality Report (because it would then be obvious why your figures are wrong).
I also think it's interesting that, although your traffic and pollution predictions were created in 1985, when you published your "Final" EIS in 1987, you did not revise the figures based on the data then available (which show how false those predictions are). You also don't publish, even in the Air Quality Report, the assumptions behind your calculations, so that someone could check your work.
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. If current data are analyzed honestly, they will show that this project will increase air pollution far beyond the "no build" alternative, and far beyond the air quality standards.
3. 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.
4. THIS LEAVES US ONLY ONE ALTERNATIVE: DECREASING TRAFFIC, AND HENCE REJECTING THIS PROJECT.
WITHOUT OUR HEALTH, WHAT ELSE MATTERS???
Michael J. Vandeman, Ph.D.
cc: Alan Cranston
Contra Costa County Board of Supervisors
Concord City Council
Pleasant Hill City Council
Walnut Creek City Council