April 5, 1989

Darnall W. Reynolds

Caltrans District 4

P.O. Box 7310

San Francisco, California 94120

Re: SR237 Air Report and Energy Conservation Report

Dear Sir:

In November, 1988 I sent to Robert Best, Burch Bachtold, and George

Gray of Caltrans scientific research papers proving that freeway expansion,

such as the current SR237 project, in the long run increases air pollution

and fuel consumption. Caltrans has apparently chosen to deliberately ignore

the scientific evidence, and continue to produce documents, in an effort to

justify freeway expansion projects, that are worthless.

J.R. Kenworthy, H. Rainford, P.W.G. Newman, and T.J. Lyons, in their

September, 1986 paper "Fuel Consumption, Time Saving and Freeway Speed Limits"

in Traffic Engineering and Control revealed that maximum fuel efficiency

occurs at 34 MPH (55 kph). This contradicts your graph on p.9a of the Energy

Report, and gives the lie to your claims of fuel savings due to speeding up

traffic to 55 MPH. In Search, Vol. 19, September/November, 1988, "Does Free-

Flowing Traffic Save Energy and Lower Emissions in Cities?, Newman, Kenworthy,

and Lyons demonstrated that highway expansion actually increases emissions and

fuel consumption, due to inducing people to drive farther and more often. This

paper contradicts the energy savings alleged in the Energy Report, as well as

the CO reduction claimed in the Air Report.

For example, on p.1 you claim that the energy used in the construction

can be repaid within 4 years. In the long run, there will be a NET LOSS, not

a gain. You don't give enough evidence to justify your claims. For example,

on p.6 you assume that congestion will have no effect on VMT. This defies

common sense, and is also contradicted in your I880 Negative Declaration,

where you admit that congestion causes many people to take another route OR

NOT DRIVE AT ALL. You give no evidence to support your claim. On pp.16-17,

you show the build condition causing a small rise in traffic (about 25%),

whereas a doubling of capacity and conversion to a freeway should cause a

GREATER THAN 100% increase in traffic. The proper traffic figures would

undoubtedly lead to a more accurate conclusion.

On p.1 of the Air Report, you mention the Air Quality Plan. You

neglect to mention that much of the Plan was never carried out, and was

only addressed after Citizens for a Better Environment, and now the Sierra

Club, threatened a lawsuit. In particular, failing to achieve Reasonable

Further Progress in many years between 1983 and the present was supposed

to trigger implementation of a Contingency Plan that would delay highway

projects such as this one.

On p.2 is Caltrans's boilerplate Clean Air Act Conformity argument.

This argument has been rejected by the EPA (e.g. by David Howekamp, Director

of the Air Management Division, Region IX, in a recent letter to FHWA).

On p.4, you show figures purporting to show that CO will decrease.

However, this conclusion is based on the faulty traffic/growth inducement

argument mentioned above. And we are not even given the traffic assumptions

so that we could come to a judgement about the conclusions. On p.5 you

assert, without giving any evidence, that the project will have no

significant effect on ozone. Common sense, and the above-mentioned papers,

indicate otherwise. On p.6 you assert that the cumulative effects of highway

projects have been studied. This is not true. You don't refer to any

document where such an analysis can be found. MTC said that it would be

impractical and expensive, and chose not to do it.

As I have said many times, Caltrans should stop trying to pave over

all of California, and start learning how to achieve their transportation

(and continued employment!) goals through mass transit, particularly rail.

Surely the Valdez oil disaster demonstrates that we are not adequately

protecting our environment. Or do you need more evidence???

Sincerely yours,

Michael J. Vandeman, Ph.D.