June 2, 1991

Metropolitan Transportation Commission

101 8th Street

Oakland, California 94607

Re: April, 1991 Draft Regional Transportation Plan and Draft EIR


An Environmental Impact Report, by law, is intended to give decision-makers a complete and accurate assessment of all potential negative environmental impacts of the project, to help them make the best decision for the community. These documents are so full of lies and propaganda, it is clear that their purpose is simply to promote a preselected alternative (the so-called "transit/highway blend"), thus nullifying the environmental review process. It is pointless to try to list all of the lies; I will just list a few: "The Bay Area has been progressively cleaning up its air" (RTP, p.9) -- didn't the Sierra Club just win a lawsuit against you in federal court, because you had failed to make "Reasonable Further Progress" in cleaning up the air? "The [toll] road would be privately financed and operated" (RTP, p.22) -- hasn't the toll road consortium been openly seeking financing from local governments? Etc. Etc.

"How to Lie with Statistics" was once a popular concept and practice, and still is. Now, we also have "How to Lie with a Computer Program". Because you don't make public the data and programs you use, we can only detect the sophistry by its absurd conclusions. (One of the most useful principles of mathematics is that an absurd conclusion implies that false information, or faulty reasoning, must have preceded it.) For example, on p.17.13 of the EIR, you assert that the Highway Capacity alternative will lead to fewer vehicle trips, fewer vehicle miles of travel, and identical transit boardings, to the No Project alternative! (It is absurd results like this that lead to your equally absurd conclusions that the Highway Capacity alternative will also lessen air pollution (p.17.17) and energy consumption (p.17.19).) Since I have thoroughly examined these issues in other highway project comments, I will simply enclose copies of those comments, most of which also applies to this project. Please consider them part of my comments on the RTP & its EIR.

The law also requires, naturally, that an EIR examine "all feasible alternatives" to satisfying the project's goals. Here again, you fail to obey the law (nothing new to MTC!): You don't consider Transportation Demand Management (TDM), which is a very inexpensive way of reducing congestion. For example, halting highway construction, as amply demonstrated after the recent Loma Prieta earthquake, causes a permanent shift toward public transit use, as well as eliminating a significant number of unnecessary trips (Caltrans remarked that 90,000 vehicle trips simply "disappeared").

It is one thing to write a plan, but another to actually carry it out. Words are cheap; the best way to tell someone's intentions is to look at their behavior. MTC has been talking for years about discouraging auto dependence, but you still provide free parking to Commission members! I don't expect you to change the world, but I do expect you to do whatever is within your power to improve air quality and reduce congestion, which you claim are two of your goals. Actions speak louder than words!

As stated in the RTP, your goals are Mobility ["Access" would be more appropriate, since the goal is not to have people move as much as possible, but to provide access to what it is they need], Equity, Air Quality, and Economic Vitality. However, your massive highway expansion program belies these worthy goals. Highway expansion doesn't improve mobility or access; congestion merely expands to fill the available road space. For those who don't drive, access is actually decreased, since funds that could go to improving public transit are squandered on more and bigger auto facilities (freeways, parking lots, etc.). Freeways encourage urban sprawl, which spreads destinations farther and farther apart, decreasing access for everyone.

For the same reasons, highway expansion decreases equity. It serves mostly the wealthier segment of society -- those who drive. The poor, who are overwhelmingly dependent on public transit, end up with less access. And, they are required to pay for (via regressive sales taxes) the freeways that they don't use!

In spite of your computer modelling sophistry, the fact is that highway expansion does not improve, but worsens air quality. As can easily be seen from your charts, you "prove" that highway expansion improves air quality by assuming that no amount of congestion will induce people to shift from driving to taking transit (or not making as many trips). Of course, this is patently false, as the earthquake demonstrated. If freeway expansion were good for air quality, Los Angeles would be a paradise! There is plenty of scientific evidence showing that highway expansion increases air pollution (as well as fuel consumption). You and your staff have not been able to point to a single shred of evidence that it helps clean the air. You also fail to mention ozone depletion, one of the biggest and most serious effects of the automobile.

Highway expansion doesn't even improve the economy. The countries that are doing the best economically (e.g. Japan and Germany) are the ones that have invested predominantly in rail, rather than in roads. Rail lines require less maintenance, carry people and goods more economically, and of course are far less destructive to the environment. (Sea- and airports are also very destructive: the RTP mentions the dredging and filling of the Bay, respectively, that they require. And yet you continue to promote the endless expansion of those modes!)

In summary, this plan is intended primarily to maintain a giant pork barrel operation for raking in state and federal funds. It satisfies none of its nominal goals, but instead continues (no, expands) the nation's dependence on oil and environmentally destructive modes of transport. (For example, traffic signal timing, which you promote, serves only to make driving easier, and does not benefit pedestrians, bicyclists, and transit users.)

The only positive note that I noticed is that you plan to test the HOV lanes before and after, to see if they have the intended effect (lowering air pollution). Would that it were true.


Michael J. Vandeman, Ph.D.