September 7, 1992

Metropolitan Transportation Commission

101 8th Street

Oakland, California 94607

Re: 1993 Draft TIP and TIP Air Quality "Assessment"

Gentlepersons:

How about that? After reading over my comments on last year's TIP, I can just send in the same comments again this year! Even the part about MTC never changing is still appropriate. Again, in spite of Steve Weir's shovelful about shifting the emphasis away from highways to transit, the Highway Element (Vol. II) is still, for some reason, much thicker than the Transit Element (Vol. I). Of course, cost totals are absent, so that we can't compare them in dollar terms, but highway spending undoubtedly far outweighs transit spending. The same, to an even greater extent, applies to bicycle and pedestrian projects, which are practically invisible. It is clear where MTC's priorities are: on a scale from 1 to 10, business and highways is 2-10, transit is 1, and walking and bicycling don't even rate lip service.

What is needed is a system of priority scoring that places the proper emphasis on projects that are truly beneficial, environmentally and economically (for example, transit is not only environmentally superior to roads, but creates more and higher-quality jobs as well). Transit projects should compete head-to-head, honestly (e.g., taking into consideration the massive hidden auto subsidy that makes road projects appear cheaper), with road projects. MTC's scoring system continues the tradition of dishonesty in this regard. Its aim, like all MTC tools, is simply to justify the projects that the business/developer/highway lobby wants.

MTC continues its tradition of wasting transit funds on projects that are really highway projects, since they benefit only drivers: BART parking, grade separations, and joint BART-highway projects like Highway 4 in Contra Costa.

The Air Quality "Assessment" is the same doctored nonsense as usual: The goal is to prove that highway expansion doesn't worsen air quality (even though it is obvious to everyone that it does). The way this is done is to assume that highway construction has no significant effect on people's driving habits (which we all know it has). Thus, whatever growth-inducing traffic level is assumed for the Build condition is squeezed into the smaller highway system of the No-Build condition, to achieve the desired congestion. Surprize! More emissions!

Sincerely,

Michael J. Vandeman, Ph.D.