September 15, 1991

Congestion Management Agency

Attn: Jose L. Moscovich, Deputy Director

24301 Southland Drive, Suite 200

Hayward, California 94545-1541

Re: Alameda County Congestion Management Program and Draft EIR


The CMP, and the legislation that spawned it, are fatally flawed. While purporting to improve air quality, they are actually doing just the opposite. You cannot reduce air pollution by expanding the highway system! That is obvious to anyone with a grade school education. The rationalization goes like this: since grams of CO and HC emitted per mile for a given vehicle decrease as speed increases (up to a point), we need to speed up traffic in order to clean the air.

As with all absurd conclusions, there must be a flaw in the assumptions, or in the reasoning used to derive the conclusions from the assumptions. In this case, the flaw is in the reasoning: while it is true that speeding up a given vehicle can reduce its emissions per mile, expanding roads does more than simply speed up existing vehicles. Expanding the highway system, as Jeff Kenworthy and Peter Newman demonstrated in their research (the only scientific research on this subject!), also causes people to drive farther and more often. And the latter effect is much larger than the former. In other words, although drivers get better mileage and produce fewer grams of (some) pollutants per mile, they drive so much more after the roads are expanded that their total emissions actually increase!

All over the world, it has been found that people have a rather constant time budget for travel. Rather than limiting their travel on the basis of distance, they generally use time: they are willing to spend a certain amount of time driving to a restaurant for dinner, a different amount for grocery shopping, a longer amount going to work, etc. The amount of time seems to depend on how valuable the goal is to them. For a once-in-a-lifetime vacation, for example, some people will travel to the other end of the globe. But for daily commuting, half an hour or an hour is about maximum. So if a new freeway is built, or an existing one is expanded, so that people can now travel twice as far in that hour, they begin looking for a higher-paying job within a larger radius of home. And they begin looking for cheaper or more attractive housing, farther from where they work. And they are willing to drive farther to do their shopping.

Experience shows that added lanes and new roads fill up rather soon after they are completed. The result: simply more lanes of congested traffic. Not only do people change their driving habits, but developers and other businesses that thrive on growth are not stupid: as soon as they hear the first whisper of plans for new road capacity, they begin planning how to profit from that added capacity. In fact, they are inevitably the strongest advocates for new road capacity. (Why they aren't as strong advocates for public transit, which can provide the same mobility with far less financial and environmental cost, is beyond me.) There isn't a shred of evidence that highway expansion improves air quality!

The bottom line is that the CMP is a fraud. It doesn't manage congestion. It creates it! The only way to permanently reduce congestion is to reduce the need to drive: build attractive public transit, design compact communities with a mixture of housing, jobs, and retail (with essentials like groceries always within walking distance), and begin to discourage driving by making it more inconvenient and more expensive. Remove the subsidies for driving. Eliminate free parking. Everywhere. Encourage walking, bicycling, and the use of public transit in every way possible. Begin to discourage long-distance driving. Stop expanding freeways. Begin converting freeways back into expressways, and expressways back into parkways. In other words, bring back the small-town atmosphere that most of us enjoyed while growing up. Put the quality back into our communities.

It is time to admit that the good life is not represented by Los Angeles-style development. All that Los Angeles accomplished was to bury its most valuable land under concrete. As we push our farms farther and farther away (and many of them into extinction under freeways and sterile housing tracts), we wonder why our food keeps getting more and more expensive, while at the same time less and less tasty!

I went to an outreach session for the community on the Alameda County Transportation Plan. The public was unanimous in its opposition to more highway expansion. None of this shows up in your plan. On p.IV-16 of the EIR you list the objectives of that Plan, including "to meet the needs of all social groups" and "to minimize social and economic disruptions to communities and impacts on environmental resources from transportation systems". In both cases, highway expansion is inappropriate. A good example is the Cypress Corridor, where the community is virulently opposed to the social, economic, and health damage that the previous Cypress freeway brought. You also list "reducing automobile use" as one of your goals. That can't be done by laying more pavement, even in the form of so-called "HOV" lanes.

You cite MTC's air quality modeling (p.V-23) as proof that the CMP will improve air quality in the county. That modeling is totally worthless, since it has never been validated by comparing it with reality! (See my enclosed paper on modeling, "Snake Oil in a Computer".) Then you assert "Projects in the CMP CIP [Capital Improvement Program] are aimed to relieve congestion, and hence improve local and Countywide air quality." As I explained above, they can't relieve congestion, and even if they could, that would not improve air quality. Even so-called "transit improvements", when they consist of expanding parking (such as is happening at many BART stations), simply increases our dependence on the automobile. A much more cost-effective way to increase BART usage would be by improving bus, bicycle, and pedestrian access. (For example, a bicycle locker costs significantly less than the $7500-$15,000 we spend to build auto parking spaces!)

On page V-26 of the EIR are some strange statements, inconsistent with the rest of the EIR. For example, "In the unlikely event that emission increases from these capacity-increasing projects were to counteract anticipated Countywide emission reductions, these projects would have a significant, adverse impact on air quality." Since you already said that the projects would improve air quality, why are you now admitting that they could do the opposite??? And why do you say that that would be "unlikely"? You offer absolutely no evidence for either assertion.

On page VI-24 is an even stranger statement: "the net expected change in Countywide emissions between the [Project and No Project] would be negligible. The Project emissions are therefore taken to be the same as the No Project emissions." If the Project doesn't reduce air pollution, then why are we pursuing it? Wasn't that the goal of this legislation? Again, on p.VI-28: "the Transit Emphasis alternative would be the environmentally superior alternative because it has fewer projects than the Highway Emphasis alternative with a substantially higher ratio of transit to highway projects". If that is so, then why are there any highway projects at all? And why did you try to show that highway projects clean the air? And why does Table 28 (p.VI-20) claim that the Highway Emphasis alternative would produce less CO and HC than the Transit Emphasis?

On p.VII-13, you assert that there will be no significant noise impacts. Why does MTC disagree (on p.87 of their final EIR)? MTC also admits to significant negative effects on cultural, visual, water, and energy resources, and on population growth and "seismicity' (earthquake safety). Why don't you?

Let's be honest. We all know that highway expansion worsens air quality. The only reason you and MTC and the other elements of the highway lobby keep insisting that road-building is good for the air is that air quality legislation is the one factor that can actually bring your road-building pork barrel to a halt. If you admitted that your projects would worsen the air, as you freely admit they will damage biological resources, they simply could not be approved by MTC or the Federal Highway Department, and could not get built!



Michael J. Vandeman, Ph.D.


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