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
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???
Michael J. Vandeman, Ph.D.