July 14, 1991

Bay Area Air Quality Management District

Attn: Mr. Henry Hilken, Planner

939 Ellis Street

San Francisco, CA 94109

Re: Addendum to, and Draft EIR for, the Draft Bay Area '91 Clean Air Plan



I am continually amazed at the audacity of our so-called "public servants", as they search out ever new ways to lie to their constituents, and pretend to be doing their job. Your "emission reduction & cost effectiveness estimates for TCMs" are pure fantasy, and were obviously calculated to justify your pre-existing, politically motivated highway- and development plans for the region.

You assert that improving bicycle access and facilities is 108% more expensive (less effective) than constructing HOV lanes! This is absurd, since bicycle facilities cost almost nothing compared to highway expansion, and are far more effective in reducing emissions. In fact, there is actually no evidence that highway expansion (HOV or non-HOV) has any air quality benefit. The emission reductions attributed to highway expansion were calculated by a computer model (claimed, in the DEIR, to be "beyond state-of-the-art" (p.4.2-17)) that is no better than snake oil. It is neither reliable nor valid, nor do its authors even understand what reliability and validity are! (This is true for all transportation modelers, as far as I can tell.)

Any measuring (or predicting) instrument must have its reliability and validity measured, before its users can claim any value for its outputs. Reliability and validity for the MTC models have never been measured! If they were, it would be obvious just how worthless they are. I asked modeler Chuck Purvis of MTC if his "calibration" process proved the model's validity. He said "yes", indicating that he has no idea what validity is. I also asked him to recommend some textbooks on transportation modeling. The authors of the textbooks also lacked an understanding of these most basic concepts of measurement science. It is understandable for someone whose entire profession rests on the use of these models would be reluctant to question them, however, that is the only intellectually, scientifically honest thing to do. (Laymen, not burdened with this technical knowledge, can simply take one look at those numbers and see that they are obviously bogus!)

Similarly, the claim that improved access to rail stations is 18% more expensive (less effective) than highway expansion is obviously wrong. One reason for these bogus results is the claim that freeway expansion provides a large travel time benefit, and that this benefit is worth $5 per hour. Studies by Newman and Kenworthy have shown that the provision of more road space actually results in people simply travelling farther, and actually ending up spending more time on the road. In any case, no time benefit is ever really achieved.

Likewise, the $5 is questionable: first of all, all time spent driving a car is lost time. Very little that is of any value can be accomplished while driving. Even the use of a cellular phone is very expensive. On the other hand, transit users can read, write, relax, or even sleep. Even if the elapsed time to their destination is longer, transit users actually save time, by having almost 100% use of their commute period. (E.g., I read EIRs while riding BART, which no driver can do!) Thus, it is clear that drivers really don't value their time. Truthfully, if there is any benefit to driving, it is the unmeasurable one of "privacy".

Hiding the cost-effectiveness of TCMs 21 and 22, by applying their revenues to some unnamed "transportation improvements", is also dishonest. They are TCMs in their own right (unless the revenues are used to fund harmful projects like expanded highways), and deserve to be rated just like the others. You apparently don't want the public to know just how very cost effective they are -- especially in comparison to highway expansion! A revenue measure that simultaneously reduces trips and VMT would far outshine all of your pork barrel "transportation investments" ("highway expansion" is never spoken by bureaucrats -- only euphemisms).


The DEIR is an extremely superficial analysis. It doesn't identify all potential significant impacts, nor does it correctly analyze those that it does identify. It takes MTC's analyses as gospel, without questioning any of them. It seems to have been written by people who are addicted to the automobile, and is frequently biased toward highway construction and against transit.

(For example, on p.2-29, no long-term noise impacts are identified for highway expansion (TCM 8), however, high density at transit stations is predicted to cause noise problems. One wonders why the avoidance of auto trips (due to the dense, non-auto-oriented development) wouldn't cause a net decrease in noise. Similarly, highway construction (financed mostly through gas taxes) is alleged to be good for business (Impact 4.4-5, p.4.4-12), whereas the gas taxes themselves are claimed to be bad for business (Impact 4.4-11, p.4.4-15)! It is claimed (by MTC) that highway construction doesn't cause population growth, but merely moves it around. However, you claim that density around transit stations would "increase the population" (Impact 4.4-10, p.4.4-15).)

The most serious defect of the DEIR is that you misrepresent the evidence on highway expansion and its effects on air quality, and hence don't consider the feasible alternative of halting highway construction. Thus, you falsely claim on p.3-21 that "a practical strategy for achieving a 75 percent reduction in ozone precursors cannot be achieved by 1997". Since, as you admit, you "must adopt all 'feasible' control measures", you have no excuse for not adopting the halting of highway construction as one of the feasible measures. Actually, the whole CAP seems to be designed with builtin loopholes that prevent any real reduction in auto dependence. Practically every single so-called "TCM" has a negative side that actually works to sustain auto dependence:

TCM 2: Prop. 111 requires a Trip Reduction Ordinance, but it is usually used as a way of getting more highway construction money, thus nullifying any positive effect it might have.

TCM 4: Some of the new rail starts (e.g. West Pittsburg, Dublin, and Guadalupe Light Rail) are intimately tied to highway construction that competes with the rail line for riders.

TCM 5: "Access to Rail Systems" is mostly a euphemism for "more parking". This serves to maintain auto dependence and wastes scarce transit dollars that would be better spent providing bus access to the rail stations.

TCM 7: I have never seen any evidence presented that ferries actually reduce emissions. This TCM should be given a better analysis. In any case, a ferry is needed from the East Bay to Marin, for bicyclists.

TCM 8: There is plenty of scientific evidence indicating that highway expansion worsens air quality, but MTC has never been able to point to any that says it can improve air quality (except for its dubious computer modeling, which does not constitute evidence). This measure is simply not a TCM, and doesn't deserve to be part of a Clean Air Plan. (HOV lanes created from existing lanes, however, would be acceptable.)

TCM 9: Bicycle access should be provided by means of highway, not transit, funds. Use of transit funds would be counterproductive.

TCM 11: TOS is mostly a waste of money on ideas of unproven value (e.g. the sign on the Bay Bridge that tells you there is an accident ahead: are you supposed to turn around?!). It also increases our investment in the automobile, when we should be putting our money into something more cost-effective: public transit. The one exception is ramp metering, which could eliminate the need to widen freeways, by simply not allowing them to fill beyond their capacity.

TCM 12: Signal timing benefits only drivers, making it easier to drive. This money would be better spent promoting cleaner modes of transportation, by giving pedestrians, bikers, and buses the ability to override traffic signals. The research "proving" air quality benefits for signal timing was biased: it considered only the effects on automobile drivers, and did not investigate the possibility of its increasing trips and VMT by making it easier to drive.

TCM 13: Reducing transit fares is an excellent TCM, if it doesn't entail reduced service. As mentioned in the DEIR, it is especially good for balancing the equity of measures that make it more expensive to drive.

TCM 15: Paying people to drive, even in a carpool, is in the long run a bad idea. The automobile is fast becoming obsolete. Our money is more wisely spent on public transit, which benefits far more people, more efficiently.

TCM 16: Highways are indirect sources, and should be included in this TCM (which counteracts TCM 8).

TCM 17: Education is very important, but the Bay Area agencies are notorious for obfuscating and distorting the truth, and should not be entrusted with this task.

TCM 18: This TCM is contradicted by TCM 5's emphasis on building parking around rail stations. Uses around freeway-median rail stations should be very carefully considered: it is very dangerous to one's health to spend much time next to a freeway, so meeting/conference centers and other short-term uses are more appropriate than housing. High-speed rail stations should be fed by buses, giving them more patrons than if we simply try to crowd housing around them.

TCMs 21 & 22: These are excellent TCMs, unless the revenues are used to build more auto facilities, such as bridges and freeways, in which case they will be counterproductive. "Congestion pricing", besides being expensive to implement and administer, sends the wrong message: auto trips are bad all the time, not just when they cause congestion!

The DEIR seems to ignore ships and airplanes as mobile sources. This is an important oversight, since there is a great deal of pressure to expand the use of these unclean modes of transport. It also ignores the growth-inducing effects of highway expansion and its long-term negative effect on air quality. We know that in the long run, any new highway lanes simply fill up, causing a few lanes of congestion to be replaced with several. These are also significant irreversible effects, as is the paving over of valuable farmlands.

The air quality analysis is superficial and very flawed. As I indicated above, many of the TCMs will have negative effects on air quality. In addition, the issue of global warming is all but ignored (since the DEIR refuses to face any of the long term negative effects of highway construction).

Nobody, even Caltrans, claims long-term benefits from highway expansion. Everyone admits that they cannot relieve congestion except for a moment. The DEIR, however, does claim that benefit (p.2-12)!

On the same page, you note increased congestion around rail stations. However, your mitigation measures are all oriented toward benefitting the automobile. You seem completely unaware that it is possible (and desirable!) to access stations by bus, bicycle, or other clean mode!

Claims of energy savings are exaggerated. As the work of Newman and Kenworthy has shown, highway expansion (and other means of speeding up traffic that don't restrict its volume) actually increases per capita fuel consumption.

One of the most serious failings of the DEIR is that it claims that effects on wildlife can be mitigated to insignificance. If this were true, species would not be endangered in the Bay Area (and many already extinct here)! This is happening because such mitigation is either not possible, or rarely carried out. I would guess the former: what we think is "insignificant" or an adequate "mitigation" is obviously not so regarded by the species affected. Added lanes on highways are not insignificant. Speeds are increased, and the probability of safely crossing is drastically reduced. Humans understand freeways, and still are often killed trying to cross them. Animals have an even harder time. And there is no recognition in the DEIR that the mere presence of a road can present enough of a barrier to a species that it will refuse to cross it, and become extinct due to inadequate genetic diversity.

The noise analysis (Impact 4.11-5), claiming decreased auto VMT and no significant noise impact from TCM 8, is just wrong. Highway expansion increases VMT, and significantly increases noise (probably in proportion to the number of lanes added). In Santa Clara, the experience with HOV construction was that it actually decreased the proportion of people in HOVs (because the removal of the HOVs from the mixed flow lanes made it easier to drive SOVs).

In summary, the DEIR fails in its mission of providing "a document that is meaningful and useful to decision-makers and the public" (p.1-1) and "a sufficient level of detail to permit full assessment of significant environmental impacts by reviewing agencies and members of the public" (p.1-4). It is dishonest, and biased toward maintaining the status quo.


Michael J. Vandeman, Ph.D.