November 27, 1988

George Gray, Deputy District Director

California Department of Transportation

P.O. Box 7310

San Francisco, California 94120-7310

Re: 1988 Caltrans District 4 State Highways: System Management Plan

Dear Sir:

It is difficult to be polite about a plan that violates the law in so many ways, asks for $8 billion, and will do so much damage to the environment. It is a huge edifice, built entirely on rotten foundations: all of the report's conclusions are based on a single false assumption, which until recently has gone unchallenged -- that expanding freeways, by speeding up traffic, decreases air pollution and fuel consumption.

This myth, which has been used to justify billions of dollars in highway expansion (euphemistically called "congestion relief"), could not be accepted by anyone familiar with Los Angeles, where freeway expansion has brought air- and environmental quality to one of the lowest points in the world. But its scientific disproof and elucidation has only recently been provided, by P.W.G. Newman and J.R. Kenworthy in their paper "The Transport Energy Trade-Off: Fuel-Efficient Traffic versus Fuel-Efficient Cities". They showed that, although drivers on expanded freeways do get better gas mileage, they end up driving farther and more often, and using public transit less, with the result that air pollution and fuel consumption always show a net increase.

In other words, your table 5.30-2 (p.228), under the headings Fuel Consumption, CO, and TOG, is rubbish. The figures under NOx are also rubbish, but for a different reason: NOx increases with speed, as your own Table 3.43-2 (p.82) shows. The figures labelled Time Delay are also nonsense, for still another reason: As Newman and Kenworthy showed, all capacity increases are growth inducing, and cause the added freeway capacity to fill up quickly, as people notice that they can drive faster. They move farther from work (to get cheaper housing), find jobs farther from their home (at higher pay), and end up with the same congestion, only more of it! Human nature. In fact, you admitted this on p.83: "However, a significant increase in VMT is projected for this same period and ... could result in a significant increase in fuel consumption and air pollution."

Actually, there is no way to eliminate congestion. You admit this on p.225: "in the long term, adding capacity alone will not alter the deteriorating LOS on freeways and the resultant delay". As long as people notice that traffic on the freeway has sped up, they will take advantage of it. The only way to prevent that would be to widen the freeway, but somehow keep the widening a secret! Thus, the whole report is vitiated by its false assumptions; there are no longer any benefits to this "congestion relief"!

But, then, why was it assumed that congestion is bad? As Newman and Kenworthy demonstrated, congestion is actually good, because it puts humane constraints on growth, without costing anything. Why is it assumed that expensive man-made ramp metering is good, while the free natural metering provided by congestion is bad? Congestion is given as a reason for widening freeways. It is not. It is the inevitable result of excess traffic and urban sprawl. Just as nasal congestion is not an indication that the nose needs to be widened, traffic congestion is a natural result of several underlying conditions that should be addressed: (a) allowing bad or drunk drivers to retain their licences (hence causing more traffic and more accidents and traffic tie-ups); (b) urban sprawl (rather than concentrating development in transit-accessible areas); (c) subsidizing the automobile (e.g., free parking); (d) making it easy to drive. When analyzed scientifically, congestion is seen as a natural way of keeping a lid on pollution and fuel usage. In fact, congestion is one of the few tools we have for doing so.

So what is the solution, and how should the report have been written? The Clean Air Act, the Cortese Bill (AB 3971, now law), the Sher Bill (AB 2595, now law), the Greenhouse Effect, and the Ozone Depletion all mandate a drastic decrease in VMT, in order to clean up the air and prevent a disastrous warming of the earth's climate, a rise in the oceans, and loss of the protection of stratospheric ozone, within the next 50 years. The solution is to turn to less polluting modes of transportation, as Los Angeles is finally struggling desperately to do. Caltrans should be proposing light and heavy rail transit systems, fed by buses, bike lanes, and pedestrian walkways, and converting existing lanes into HOV lanes. That is the only way to get the necessary transportation capacity, without destroying the environment that makes life worth living (or even possible!). In fact, this route is also less expensive. It is well known that rail transit can transport more people, faster, quieter, and cheaper than a freeway can. Every day, scientific advances are making light rail systems faster, quieter, more energy efficient, and more luxurious. When you consider that driving time is utterly wasted time, whereas time spent on public transit can be spent reading, relaxing, or even sleeping, it becomes clear that riding transit actually saves time, compared to driving. On p.118, you admit "Bus shuttle service to Amtrak and Caltrain would increase rail ridership and help to reduce congestion on the SHS." (However, on p.158, you err: "Amtrak bus service is not provided to or from the Peninsula Subregion and there are no plans to begin such service." You forgot about the Oakland-San Francisco bus.)

It will still be necessary to maintain roads for trucks, buses, and bicycles, but Caltrans should begin right away to switch from planning freeways to planning rail systems, since they are very different from freeways, and can go in very different locations. Light rail systems, for example, can go very close to homes and businesses.

There are hints of this possibility in the report. For example, on p.193, you say "The existing Amtrak service in the Route 80 corridor could be expanded to provide commute service. This service would help to relieve congestion in the corridor." Or on p.209, "The AT&SF line between Antioch and Stockton could be used for commuter rail service between these points and it could connect to BART in Antioch." However, in general, transit plans, where mentioned at all, are vague, nonspecific, "wimpy", and funded at a miniscule level. The subject of transit as an alternative to freeway expansion seems to be totally taboo; it is never broached. This is apparently a report from an organization that earns its money only from building highways. However, this is not Caltrans's mission. Your Policy Direction Statement (p.S2) mandates "a safe, effective and efficient transportation system; one that will support economic growth and provide mobility to the general public, in conformity with the environmental and social needs of California".

The California Environmental Quality Act, by the way, requires an EIR for a plan such as this, since it will potentially have a very significant negative effect on the environment. Also, while I am on the subject of CEQA, the "mitigation measures" you mention on p.11 are a joke. Providing alternative habitat for wildlife rarely works (how would you like your home to be moved somewhere "equivalent" to your present location?). Sound walls don't solve the noise problem and are a big problem themselves (causing glare and shadow, and blocking scenic views). And how can you mitigate the effects of benzene-caused cancer? Also on p.11, you claim to "Consider all environmental, social and economic effects of the state's transportation programs and projects in arriving at final transportation decisions." You are required by CEQA to do this, but you don't. The Greenhouse Effect is never mentioned. The Ozone Depletion (related to NOx) is never mentioned. Carcinogenic and mutagenic effects are never mentioned. On p.78 you assert that "as speeds drop so do ... all other ... environmental indicators deteriorate". You forgot about NOx, which decreases as speeds drop to LOS E. Complete economic analysis is never done. For example, on p.80 you say that delays are valued at $.10/minute, but you don't compare that to public transit, where almost no time is lost (since you can make productive use of time spent on transit).

In summary, congestion is not a problem, but a blessing. And even if you still want to reduce it, there are cheaper, more effective means than more business-as-usual losangelization (freeway expansion), which you admit doesn't work anyway! There isn't enough available land in California to eliminate congestion through roadway expansion, and even if there were, that would be a wasteful way to use the money. You are under no obligation to provide roadway for any wasteful use (e.g. commuting) that people dream up. After all, as the Driver's Handbook says, driving is a privilege, not a right.

Respectfully yours,

Michael J. Vandeman, Ph.D.