December 6, 1989

Air Resources Board

1102 Q Street

P.O. Box 2815

Sacramento, California 95812

Re: "California Clean Air Act Guidance #2 -- Transportation Planning Requirements"


Your document seems motivated more toward "keeping the peace" with the pro-highway lobby, than with cleaning up the air. There is one crucial issue that must be resolved, if we are ever to have clean air in California, and you consistently and deliberately ignore it and pretend it doesn't exist: WHEN ARE WE GOING TO STOP EXPANDING THE HIGHWAY SYSTEM?

As you well know, all current scientific research supports the conclusion that expanding highways simply encourages people to drive farther and more often, resulting in a net increase in air pollution and fuel consumption. There isn't a shred of evidence to support the opposing view -- the myth that you can somehow expand freeways and speed up existing traffic without people noticing the increased capacity and taking advantage of it. Expanded freeway capacity is the developers' dream, and they aren't shy about saying so.

Of course, Caltrans continues to deny all of this, because they don't want to endanger the flow of state and federal dollars for highway construction. And on this issue, you are obviously in bed with Caltrans, along with the Federal Highway Department, the Department of Transportation, the Association of (S.F.) Bay Area Governments, the Metropolitan Transportation Commission, the Bay Area Air Quality Management District, and most businessmen and politicians. Frankly, there are very few public officials who have the guts to tell the truth about this subject. So why should you be any different? (You wisely require agencies to "thoroughly document" all of their assumptions (p.17). How about following your own good advice?)

Halting roadway expansion should be listed as one of the "reasonably available" TCMs. It is a TCM, because constraining available roadway obviously discourages people from driving. (This was dramatically demonstrated after the October 17 earthquake.) It is "available", because it is already in existence -- all we have to do is not widen any more roads. And it is "reasonable", because in the MTC's recent random survey of opinions in the Bay Area, only 18% of the population favored more freeway expansion (in contrast, 34% want more rail transit) ("Views of Bay Area Residents on Traffic and Growth Issues", July, 1989).

In contrast, HOV lanes are not TCMs unless they are created from existing lanes. If they consist of new pavement, they increase the vehicle-carrying capacity of the freeway, they don't serve "the purpose of reducing motor vehicle emissions", they lessen the incentive to use public transit (A/C Transit has lost thousands of passengers to casual carpooling, and has had to drastically cut back their service), and they only operate as HOV lanes for a small part of the day. In other words, they are for all practical purposes synonymous with highway expansion.

Similarly, "traffic flow improvements" are not TCMs, unless they encourage traffic to flow at a steady speed WITHOUT INCREASING THE AVERAGE SPEED. Increasing speeds just encourages people to drive more (just as restricting speeds discourages driving).

On p.6 you state that "The ARB will not approve air quality plans that are not consistent with the region's ongoing transportation and congestion relief effort." You are putting the cart before the horse. Air quality is mandated by law. Many local "transportation and congestion relief efforts" actually violate the law (CEQA and the federal Clean Air Act). Transportation plans must conform to air quality requirements, not vice versa. "Congestion relief", if implemented via highway expansion, is ANTITHETICAL to air quality.

You quote the federal Clean Air Act as including highways among indirect sources, and hence coming under the purview of indirect source controls. Please elaborate on this. Guidance is needed here.

On p.27 you mention $3 billion for rail transit twice, giving the (wrong) impression that the total is $6 billion. The AB471 discussion is irrelevant, if it isn't funded yet, particularly since its overwhelming emphasis is on highway expansion. On p.C-3 Pam Burmich mentions "time-related targets" and "vehicle occupancy-related targets". These are inappropriate. Only trip and VMT reduction should be used, as these are the most directly related to emissions.

The bibliography is incomplete without the only research on the environmental effects of freeway expansion, that of Professor Jeff Kenworthy and his associates.

Thank you for the opportunity to comment on this important document, which can significantly affect the success of the Clean Air Act.


Michael J. Vandeman, Ph.D.