November 19, 1988
Burch C. Bachtold, District Director
P.O. Box 7310
San Francisco, California 94120
I would like to offer the following comments on the Proposed Negative Declaration/Initial Study, "The Widening of U.S. Route 101 from The Routes 280/680/101 Interchange North to the De La Cruz Boulevard/Trimble Road Interchange", of October, 1988. In order to avoid repeating myself, I am including in my comments my March 26, 1988 letter to you on I680, my October 23, 1988 letter to Robert E. Farris, FHWA, my November 5, 1988 letter to the Berkeley City Council on I80, the 11/18/88 Oakland Tribune article, "Berkeley opposition leaves I-80 project in doubt", and P.W.G. Newman and J.R. Kenworthy's paper "The Transport Energy Trade-Off: Fuel-Efficient Traffic versus Fuel-Efficient Cities". I would appreciate it if you would publish all of these, as part of my comments. They all contain essential parts of my argument that should be available to whoever will be making the final decisions about this project.
1. At your November 2 (?) "Open House/Map Display", Caltrans handed out a 1-page "information" (propaganda) sheet titled "Background", that states: "The only issues apparent at this time are of an engineering nature, i.e. capacity, ground water, safety, and traffic handling during construction. There is no known opposition to the project." This is not true. There are grave doubts among many people these days about whether any freeway expansion is justified, as exemplified in the city of Berkeley's refusal to accept the widening of I80. In particular, there is tremendous opposition to the continual increase in air pollution, noise, and wildlife habitat destruction that these projects entail, to say nothing of their violations of CEQA (California Environmental Quality Act), NEPA (National Environmental Policy Act), and CAA (the Clean Air Act). For example, some of the groups expressing opposition to the I80 widening were the Sierra Club, the Ecology Center, the East Bay Greens, and Urban Ecology.
2. The PND (Proposed Negative Declaration) states on the first (unnumbered) page that the purpose of the widening is "to alleviate current and projected future peak hour traffic congestion". If that is the case, then one of the existing lanes should be used for an HOV lane during that peak period. An environmental document is supposed to give decision-makers enough information to make the best decision, including an analysis of all feasible alternatives, especially alternatives that could save the taxpayers money and protect the environment as well.
3. It also say "There will be no significant adverse effect on air quality, energy consumption, ... use of natural resources, ... aesthetic quality, ... water quality, ... land use, growth ...". This is not true. Newman and Kenworthy proved scientifically that freeway expansion significantly increases air pollution and fuel usage. As described in my October 23 letter (see attached), the myth of less pollution and fuel savings due to increased vehicle speeds depends on the false assumption that the expansion will have no effect on driving habits and land use. What actually happens, is that the added vehicle capacity always encourages people to drive more, drive farther, live farther from work, work farther from home, etc., which totally eclipses the small savings from increased vehicle speed.
4. The Table 1 traffic figures (p. II-4) show that the freeway, even at its heaviest peak period, is not even at capacity! The highest figure shown is 4940 vehicles/hr., or 1647 vehicles per lane (in one direction). The capacity of a lane is about 1950 vehicles per lane. Thus, there is no justification for widening the freeway, especially without first trying other, cheaper measures. For example, using an existing lane as an HOV lane during peak periods, ramp metering, TSM, and the creation of rail transit lines to handle the excess traffic, as was done in the Guadalupe corridor and is being planned in numerous locations throughout Santa Clara County. These figures are also inconsistent with the traffic figures given in Appendix D, for which no explanation is given.
5. On p. II-5 the PND refers to "congestion-related accidents". You offer no evidence that the accidents are related to congestion. It is more likely due to faulty driving. Such drivers should have their licenses revoked, which would provide more patrons for transit, relieve congestion, and protect others from harm, all at almost no cost!
6. You also say on the same page that HOV lanes "reduce congestion, improve air quality, conserve energy, and maximize the number of people a transportation facility can carry". If so, you should institute this at once, without widening the freeway! When you promise these benefits "in conjunction with freeway widening", you make the statement false: there is no way to increase the traffic and improve air quality at the same time.
7. On p. III-4, you say that an unwidened freeway "would be a significant bottleneck". This is precisely its value! Since there is no way to widen all our freeways sufficiently to handle all the capacity (e.g., Caltrans has said that it would take about 18 lanes on I680), it is time to admit that this "solution" is not a solution at all, but a dead end. The days of "business-as-usual", rubber-stamped, unlimited freeway expansion are over. It is time to turn to the only solution possible: clean, efficient, fast rail transit, combined with numerous other equally benign measures that don't make our cities totally uninhabitable. It is very significant that the wealthy support freeway expansion, until it comes to their own neighborhood (as is happening now with I85 in Cupertino)! Freeways are okay only if they are in someone else's neighborhood.
8. A PND is supposed to be unbiased. You should not use such expressions as roadway "improvement" (p. III-5). These are not improvements.
9. On p. IV-19 you assert that this project is not in conflict with the Bay Area Air Quality Plan. This is not true. The AQP has as its goal bringing the air in the Bay Area into conformity with state and federal air quality standards. We are not in conformity now, and obviously, projects that will increase air pollution, such as this one, could not possibly be in conformity with such a plan. This is a 33% increase in capacity, and therefore a 33% increase in air pollution, noise, and other negative environmental effects. Besides that, the AQP mandates that a lack of progress in meeting the standards will trigger a delay in all such capacity-increasing projects. This requirement is being violated.
10. On p. IV-20 you quote MTC Policy 4.3: "Before approving new facilities, alternatives such as increased transit, use of high occupancy vehicles, adjustments to operation procedures, or adjustments leading to changes of demand shall be considered." This policy is being violated here.
11. On p. IV-22 you say that the project would "help promote planned development". How can added freeway capacity be restricted to use by certain planned developments, but not other, unplanned ones?? Answer: it obviously can't!! In other words, the project is growth inducing, and therefore requires an EIR, not an ND. To try to argue that added capacity will address planned growth, but not future, unplanned growth, is pure speciousness.
12. On p. IV-31, you say that the "air quality in the South Bay suffers significant degradation because the area is downwind of the many pollutant sources in the north and central Bay Area". This is true, but you fail to mention that San Jose creates plenty of its own pollution, largely from auto and truck traffic. You leave the impression that San Jose is simply a victim of others' pollution, which is definitely not true.
13. In your environmental checklist, pp. V-1-5, items 5-7,11,13,16-18,20,33,35,42,43,47,50, & 53-56 were answered incorrectly. If they were answered truthfully, it would be obvious that an EIR, not an ND, is required by CEQA for this project.
14. On p. VI-4, you state that "Each of the proposed build alternatives would reduce traffic congestion and improve peak period traffic flow without causing an overall increase in vehicle travel in the general corridor." This is obviously false, and is contradicted by the Newman and Kenworthy research and by my argument in paragraph 11, above.
15. Your air quality analysis on pp. VI-8-11 is faulty, for the same reasons. In the long run, the freeway will fill up and be congested to the same degree with 33% more traffic. Thus, it will produce 33% more air pollution. The analysis is specious because it assumes that the traffic will go 55 MPH (see Appendix D), even 22 years from now! This is unbelievable. No honest computer modeling would predict exactly 55 MPH for all build conditions. This "coincidence" is highly suspicious. In any case, it is only a modeling, not a scientific study of actual conditions, as was done by Newman and Kenworthy.
16. On p. VI-11 you say that analysis of ozone is "impractical" (you give no explanation). Then you say that "it would not reasonably appear that the ozone effects of this project would be substantial or significant". How do you know, if a scientific analysis of it is "impractical". An environmental document is supposed to consist of facts, not bald, unsupported assertions.
17. CEQA requires the analysis of cumulative effects of all related projects, e.g, in this case, the effects of the widening of all of I101. On p. VI-12 you say that "the regional air quality planning does include the cumulative air quality effects of population growth, job changes and highway improvements". This is not true. There has never been such a cumulative analysis, and MTC says in its "Air Quality Analysis Supplement to the 1988-92 TIP" (9/23/87) that such an analysis would be too expensive (p.18). (CEQA says specifically that expense is no excuse.)
18. Also on p. VI-12, you say that the project "conforms to the SIP" (Air Quality Plan). The EPA does not agree with this. How do you explain that? This is simply saying what you have to say in order to satisfy the CAA.
19. On p. VI-16, you again state that "Although this is a major capacity increase, the project would not create excess capacity". Where is the evidence of this? Decisions are supposed to be based on "evidence in the record". As I stated before, I have given evidence to the contrary. This growth-inducement section is pure double-talk. On p. VI-18, you again admit that it "would support tax-generating development".
This project should not be built, and at the very least, requires an EIR, not a Negative Declaration. It would have significant negative effects on air quality, noise, growth-inducement, and other environmental destruction. To assert otherwise defies logic.
Michael J. Vandeman, Ph.D.