October 24, 1987
California Department of Transportation
Attn: Leo J. Trombatore, Director
1120 N. Street
Sacramento, California 95814
Re: Flaws in the 24/680 Project EIS
Thank you for your answer (through Burch Bachtold) to my September 25 letter on the above topic. Frankly, I am at a loss as to how to get you to take this matter seriously. I am a mathematician; I know that an absurd conclusion cannot come from valid premises through valid reasoning. Any 10 year old can see that your conclusions are absurd: expanding freeways does not, IN THE LONG RUN (e.g., by the year 2010), decrease air pollution! IN THE LONG RUN (and I hope to be around in the long run, as I'm sure you do), EXPANDING FREEWAYS INCREASES AIR POLLUTION. If you deny this, I would really have to doubt your integrity. I know that you want to build more freeways, but I really doubt that you want to do it at the expense of honesty.
Given that the EIS reaches a false conclusion, it must have arisen from (a) at least one false premise, or (b) false reasoning. And it was:
1. The traffic figures used (FEIS, p.2-4) are absurdly low. BY CALTRANS' OWN ACTUAL-TRAFFIC FIGURES, THE PREDICTED TRAFFIC FOR 2010 WAS SURPASSED IN 1985!
2. Mr. Bachtold said that ABAG's traffic projections were lowered ("translated into congested flow volumes"), but he failed to mention that (a) this translation was applied to the "build" condition, but not (or not equally) to the "no-build" condition, producing a false comparison; this can easily be seen in the chart on page 6-5; (b) in bringing the projections in line with "roadway capacity", he brought them BELOW TODAY'S ACTUAL TRAFFIC FIGURES!; (c) the chart on page 6-5 says that the "no-build" condition will cause congestion in 2010, but the "build" condition, by adding only 2 lanes, will miraculously have no congestion ("Peak Demand Not Accommodated"); DO YOU BELIEVE THIS?? I find it unbelievable.
3. In spite of Mr. Bachtold's exposition of his "rationale", I don't think using two different locations for produces a valid comparison of air pollution effects. Do you? If so, put 10 gallons of your favorite gasoline in your Cadillac, and I will put 10 gallons of my favorite gasoline in my Toyota, and let's see which gasoline gives better mileage. Want to bet on the results? Or is this NOT A FAIR COMPARISON???
4. Mr. Bachtold mentioned that "the air quality report for this project has been reviewed by ... the Bay Area Air Pollution Control District". Why didn't he mention that as part of this review they SERIOUSLY DISAGREED WITH CALTRANS' AIR POLLUTION PREDICTION?? (see their 10/9/86 comment in Vol. II of the FEIS). This is important, because it makes the difference between being in compliance with federal ambient air quality standards, and not being in compliance.
Can you please respond within 5 working days?
Michael J. Vandeman, Ph.D.