February 17, 1989
Darnall W. Reynolds
Caltrans District 4
P.O. Box 7310
San Francisco, California 94120
Re: SR237 EIR/EIS
I would like to offer the following comments on the SR237 EIR/EIS (SCH # 83092704). I am including in my comments the following documents, which are enclosed: "Does Free-Flowing Traffic Save Energy and Lower Emissions in Cities?", P.W.G Newman, J.R. Kenworthy, and T.J. Lyons, Search, Vol. 19, No. 5/6, September/November, 1988; and "Transport Energy Conservation Policies for Australian Cities -- End of Grant Report, Project No. 836", P.W.G. Newman, J.R. Kenworthy, and T.J. Lyons (Murdoch Univ., Murdoch, WA, Australia), August, 1987 (I am enclosing only the Summary). I am also including, by reference, the excellent paper "Transport Energy Conservation through Urban Planning and Lifestyle Changes: Some Fundamental Choices for Perth", by J.R. Kenworthy, 1987, which explains the need for fuel comnservation. Also "Fuel Consumption, Time Saving and Freeway Speed Limits", J.R. Kenworthy, H. Rainford, P.W.G. Newman, and T.J. Lyons, Traffic Engineering and Control, Sept., 1986.
This report violates CEQA in numerous ways. For example, an EIR must analyze all feasible alternatives. On p.22, you state: "The overall goal of the Route 237 Freeway Upgrade Project in this segment is to facilitate the flow of a large volume of traffic". Presumably you are referring to the transport of people and goods, since the mere shuttling of vehicles back and forth would have no purpose. For transporting people and goods, there are many feasible alternatives. The most practical and environmentally sound alternative is rail transport. It is well known that a rail line can carry as many passengers as an 8-lane freeway. You even mention such a project on p.32: "The LRT [light rail] alternative uses the Tasman Drive median from Milpitas to Sunnyvale." However, you fail to analyse this as an alternative to widening 237.
In fact, it would appear that there is a taboo at Caltrans to mentioning rail transit as a possible alternative to freeway expansion, even though it is required by law. I have never seen it addressed in any EIR or Negative Declaration. However, just yesterday I discovered the following comment in the "Route Concept Report" for Route 24, May, 1986: "A Southern Pacific right of way, from Concord to Pleasanton, is also currently being studied by Contra Costa County for a public transportation facility. This right of way runs roughly parallel to I-680. A public transportation alternative may contribute to relieving traffic demand on I-680 especially near the Route 24/680 I/C [interchange], which in turn, should relieve queuing on Route 24." If you can admit that public transit can is an alternative to widening I-680, why not for 237?
Rail transit is necessary, in any case, because the Earth has a very limited supply of oil, which is expected to run out in only 30 years. As the above papers mention, we need to begin conserving fuel, and the best way to do that is to stop expanding the highway system, build rail transit systems, and build housing and jobs close together. And until public transit has been built and in service for a reasonable time (say, 6 months), there is no way to know if the freeway really needs to be widened! After we give transit a chance to work in the 237 corridor, then we should examine whether there is still a traffic problem (more accurately, transportation problem). Ideally, this trial should include rail connecting San Jose to both San Francisco and Sacramento.
This brings me to the next defect of the EIR: the energy analysis. On p. 122 you state: "energy savings of approximately six million gallons per year would occur in relation to the current traffic conditions on Route 237." This is not true. Recent research (see the first article mentioned above) has demonstrated that speeding up traffic only saves fuel for an isolated vehicle, not for the community as a whole, and then only up to 34 MPH (see the 4th article mentioned above). Capacity increases that aim to speed up traffic always cause people to drive farther and drive more often, with the result that fuel consumption for the community as a whole increases! The only way to save fuel is to begin to wean ourselves from dependence on the automobile. Expanded freeways will simply fill up and soon have the same congestion, only more lanes of it.
This leads to the next defect: the air quality analysis. The same research and reasoning applies to air pollution as applies to fuel consumption: freeway vehicle capacity (as opposed to passenger capacity) increases always induce growth in traffic and worsen air pollution, even though an isolated vehicle may produce less pollution per mile as it speeds up. The first paper mentioned above explains why this is true, and describes the research that proved it. Although the "Air Quality Report" (Aug., 1988) was unavailable at Caltrans's office yesterday (3333 California St., S.F), I know what it will say: widening the freeway will not cause an increase in traffic. That is the only way that it could predict a decrease in CO!
Michael J. Vandeman, Ph.D.