January 13, 1990

Preston W. Kelley, District Director

Department of Transportation

P.O. Box 7310

San Francisco, California 94120

Re: I880/Cypress Replacement Draft EIR/EIS: More Comments

Dear Sir:

On Monday, 1/7/91, I went to your office on 1401 Lakeside in Oakland to look at the "Technical Studies" listed in Appendix D of the EIR/EIS. They were very revealing! (By the way, I asked to xerox several pages from them. Your employee said she would do it and mail them to me, but she didn't do it. Could you please expedite that?)

In the "Travel Forecasts" document, not enough information was disclosed to evaluate it. It is obvious that the pollution and fuel consumption predictions depend on these assumptions, so concealing the source of those predictions makes it impossible for them to be verified by an independent source. Of course, that secrecy violates CEQA and NEPA and defeats their purpose, which is to allow responsible decision-makers to evaluate the probable environmental effects of the project and its various alternatives. This document should disclose the assumptions and the formulas by which its projections were calculated.

However, it is highly likely that the computations were "fudged" in order to make the project seem worthwhile. As an example of how this was done, on p.14, Vol.1 is stated: "This 'mode split' package was not operational during 'preliminary' travel forecasting used in the preparation of the Draft Environmental Impact Statement. Instead, the percentage of persons using transit has been assumed constant for all alternatives in 2015 at a level equal to the 1987 percentage." Of course, by assuming that people will continue to drive, no matter how congested the roads are, and how much more freeway capacity is available, would slant your results toward needing more freeway capacity. This ignores the huge increase in transit ridership that has occurred since the earthquake, and is a good example of how highway projects are promoted through dishonest environmental "studies".

Many people are under the misconception that your Transit/TSM/"Limited" Freeway alternative would provide funds to build and/or operate transit improvements. The truth is revealed inside the "Travel Forecasts" "technical" report: (Vol.1, p.13) "Construction and right-of-way costs for the highway portion of the Transit/TSM/Freeway Alternative are eligible for federal emergency relief funding. Construction and operating costs for transit services would be borne by the respective transit agencies. Since securing funding resources for these improvements is not assured at this time, the transit improvements would not necessarily be implemented as part of the project" [emphasis added]. What more proof does one need of your bias toward highways?

In the "Energy" study, you admit that transit uses less energy to move the same number of people. This does not jibe with your assertion in the EIR/EIS that the build alternatives will use less energy than the No-Build.

In the "Air Quality" "study", there is no mention of traffic levels, or description of how they gave rise to your phony prediction that the build alternatives would clean up the air. If highway construction were so good for air quality, Los Angeles, after all, would be a paradise of fresh air!

If, as you assert in the EIR/EIS, the freeway will be so good for air quality and noise levels, I have a challenge for you: Why don't you and your senior staff move to homes next to the existing or proposed freeway? That would be a really good way of showing that you really believe what you are saying. On the other hand, if you refuse, it will be obvious that you are selling us lies. In any case, I would like to know your thoughts on this suggestion, which would surely improve trust in Caltrans.

The bottom line is that freeways aren't good for people, animals, plants, or any other living things. Their construction is just the result of one group of people (those living in the hills, far from the freeway) abusing a "weaker" group -- nothing new. You are saying to the people of West Oakland, "Bend over, and let us do it to you again." But we aren't going to bend over. Communities all over California and the rest of the U.S. are starting to "just say no" to freeway expansion. We did it in South Pasadena, San Francisco, Berkeley, Emeryville, Sacramento, New York, Denver, Portland, and many other places. I suggest that you start re-training your employees to support nonpolluting modes of transportation. I would hate to see them have to be laid off.


Michael J. Vandeman, Ph.D.