October 30, 1987

California Department of Transportation

Executive Office

Attn: Leo J. Trombatore, Director

1120 N. Street

Sacramento, California 95814

Re: Flaws in the 24/680 Project FEIS (Final Environmental Impact Statement)

Dear Sir:

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'



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


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


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?

Respectfully yours,

Michael J. Vandeman, Ph.D.

cc: George Deukmejian

Burch C. Bachtold

Tom Bates

Nick Petris

California State Air Resources Board

Bay Area Air Quality Management District