June 18, 1990


Attn: Public Information

101 8th Street

Oakland, California 94607

Re: 6/8/90 Draft State Transportation Control Measure Plan


There is a children's story called "Can the Leopard Change His Spots?" (or was it "Can the Tiger Change his Stripes?") In any case, the answer was "No". The proposed Plan is just as ineffectual as MTC's 1982 federal Air Quality Plan, probably for the same reason: the primary goal seems to be to guarantee that highway construction continue unabated, drawing federal and state dollars to the Bay Area with no regard for the effect on the environment. The only noticable change in these plans, with their heavy emphasis on freeway expansion, has been that the new lanes are now called "HOV" lanes. This certainly doesn't change the fact that the effect on our air quality will be enormous. And negative. Indeed, MTC dishonesty would seem to be the primary reason that we haven't achieved the air quality standards.

Chris Brittle has said that MTC can't achieve the required 25 ton reduction in hydrocarbons by 1997. And the proposed Plan also throws up its hands and gives up after achieving less than half of the required emission reductions. But you fail to mention that this moves the Bay Area from the Clean Air Act's "Serious" category to the "Severe" category, with an accompanying increase in our obligations under the Act. Please correct this oversight.

You say you are "committed" to developing a plan "which will achieve state standards". Then why did you leave the job half done? MTC's past actions don't engender much trust in such propaganda. You plead "technical uncertainty", however, everyone agrees that we simply need a reduction in vehicle trips and VMT. A simple way to achieve that would be a large gas tax, increasing yearly until the ambient air quality reaches the desired level. You fail to mention the enforcement powers included in the CAA that would make that feasible.

You continually refer to the "cost" of air quality measures, but fail to consider the appropriate measure -- net (or relative) cost. (By the way, cost, and especially cost effectiveness, are never mentioned in relation to your sacred cow -- freeway expansion -- only in relation to things you don't want to do, such as clean up the air.)

Your attitude seems to be "Gee, we want to clean up the air, but all those other people [the legislature, the public, etc.] just won't let us". Baloney. MTC is continually spouting the virtues of "Flexible Funding", which allows them to spend gas tax money on whatever mode is desired, not just highways. But then you went ahead (in the RTIP) and allocated 99% of the "flexible" funds to more highway construction: when you have the power to make air quality progress, you consistently do the opposite! Even when you have the power and the legal obligation, as in the case of the federal Clean Air Act, you go out of your way to violate the law and knowingly approve highway expansion projects that will worsen the air (v. Judge Henderson's latest order to MTC to come up with more honest criteria for judging the air quality effects of highway projects).

The very least that you could do would be to tell the public the truth, but you don't even do that. You persist in using the excuse that highway expansion improves the air, when it is obvious to any 8-year-old (and to all experts in the field) that the opposite is true. Stopping highway expansion would go a long way toward reducing vehicle trips and VMT, and hence toward achieving the clean air goal that you say you are committed to. And you have the power and authority to do just that: it is written into the federal CAA.

After talking at length about all the "uncertainties" in this process, you then proceed to bank on those very uncertainties to achieve the emissions reductions (Inspection and Maintenance, a new federal CAA, "clean fuels" (an oxymoron), etc.) This is a very frequently used MTC ruse: give up trying to achieve anything real today, while promising salvation from a future "messiah" (or perhaps a bunch of messiahs!). We can't figure out how to achieve clean air, but surely Bay Vision 2020 (or Congestion Management Plans, or the Bay Area Economic Forum, or somebody) will be able to save us! Considering your past record, all such overflowing optimism should be ignored. We need a major change in behavior, not more empty speeches.

You mention a problem with "equity" in relation to the "market approach". Funny, you never mention any equity problems when you discuss highway construction! For example, the way freeways divide and destroy neighborhoods, force long-time residents to sell their homes and begin life over in a new, less convenient neighborhood, take sales taxes from the poor and other non-highway users to build freeways that pollute their air and destroy their peace and quiet, etc. One might say that your concerns about equity, cost, etc. are "context-sensitive". Another good example is BART parking (in fact, most long-term parking): a BART parking space is nothing but a several thousand dollar bribe to get a single individual to ride BART! Where is the equity in that? Where is my bribe? Where is cost effectiveness now? Your concerns are feigned, like crocodile tears. There is no inequity in making gasoline more expensive, since transit use is cheaper than driving.

Parking increases simply increase auto dependence and are counterproductive. They serve only auto users, and waste money that could better be used to provide feeder bus services. Or provide bicycle access to transit. Bus operators say it is unsafe to carry bicycles on buses; however they could be very easily secured to seat-top hand holds with a simple strap, and would be no trouble when the bus is not full of people. A lot more could be done to give priority at traffic lights to pedestrians and bicyclists (e.g. give them a button they can push to immediately begin the switch to green). Timing lights for motorists is just moving in the wrong direction, if we want to make driving less attractive and nonpolluting modes more attractive. Pollution savings claimed for signal synchronization are bogus. I know how this research was done, and the driving-discouragement that is provided by non-synchronized lights (to say nothing of pedestrian/bicycle-favoring lights) was never considered.

You mention the difficulty of researching new transit routes. That is simple: just use highway corridors (for rail), where the research has already been done and a ready market has been provided: auto users.

Carpool lanes, however you fudge the air quality modeling, cannot improve air quality if they involve adding new lanes to a roadway. Carpool lanes, if they are created at all (I am not convinced that they have any value), should be created from existing mixed-flow lanes. Among indirect sources, you neglected to mention the most significant -- roads.

The Public Education discussion is in the right direction. However, there should be more emphasis on public school and college education. Attitudes are formed early. And speaking of children, they don't listen to hypocrites. They, like all of us, listen to what you do, not what you say. The best possible education you could provide (perhaps the only education) is role modeling.


Michael J. Vandeman, Ph.D.