October 30, 1987
California Department of Transportation
Attn: Leo J. Trombatore, Director
1120 N. Street
Sacramento, California 95814
Re: Flaws in the 24/680 Project FEIS (Final Environmental Impact Statement)
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
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. If the translation "into congested flow
volumes" resulted in no predicted congestion in the "build" condition, why
didn't it do so in the "no build" condition (in both cases, there would be a
HUGE excess of demand over capacity)?
3. In spite of Mr. Bachtold's exposition of his "rationale", I don't think
COMPARING TWO DIFFERENT LOCATIONS 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 Air Resources Board and the Bay Area Air Pollution
Control District". Why didn't he mention that as part of this review BAAQMD
SERIOUSLY DISAGREED WITH CALTRANS' AIR POLLUTION PREDICTION?? (see their
10/9/86 comment in Vol. II of the FEIS). In spite of this, CALTRANS did not
revise their figures! This is important, because it makes the difference
between being in compliance with federal ambient air quality standards, and
not being in compliance.
Mr. Trombatore, do you plan to BLANKET California with freeways? If not,
where will you stop? Where do you draw the line? How will you know when you
have gone too far??? I suggest that the criterion be AIR QUALITY. This is
objective and measurable. The San Francisco Bay Area is a nonattainment area,
with respect to federal ambient air quality standards. The air cannot be
cleaned up without decreasing traffic, and any project that is "growth-
inducing", such as freeway expansion, will only make the situation worse.
Clearly, none of us, including you, I'm sure, want a state that is wall-
to-wall pavement. The only thing we disagree on, is where to draw the line.
May I suggest that we draw the line NOW?? I realize that stopping freeway
expansion is a new concept, but I see no other way to preserve the natural
environment on which all life depends.
I would appreciate a personal reply from you. Can you please respond
within 5 working days?
Michael J. Vandeman, Ph.D.
cc: George Deukmejian
Burch C. Bachtold
California State Air Resources Board
Bay Area Air Quality Management District