September 8, 1991

Metropolitan Transportation Commission

101 8th Street

Oakland, California 94607

Re: 1992-96 TIP and TIP Air Quality Assessment


Commission Chairman Steve Weir indicated at the last TIP hearing that he is disatisfied with the RTP's "Highway Emphasis" and "Highway-Transit Blend" alternatives (because of excess highway emphasis and inadequate transit emphasis), and that he was requesting postponing consideration of the TIP until now, in order to modify it. The current TIP and Air Quality Assessment (AQA) show no evidence of any rethinking. They are decidedly "business as usual" -- a continuation of the highway emphasis that has characterized MTC for as long as I can remember. Only the rationalizations have changed.

Working with MTC is like playing a shell game: We know the outcome will always be the same -- more highway expansion and more rationalization. The game is to find out where the critical deceptions are hidden. Which shell is the pea under now?

This year, it has been in the computer modeling. It is easy to see that a deception is occurring, because the numbers are so absurd. For example, in Table D.1, p.III-77 of the AQA, for 11 of the 25 corridors, MTC predicts more VMT (Vehicle Miles Travelled) in the No-Build 2010 scenario than in the Build. In other words, expanding freeways causes people to drive less! You cannot derive absurd conclusions without using either false assumptions, or specious reasoning. I don't know which it is, because, in spite of repeated promises by MTC (Chris Brittle) to disclose the details of their modeling runs, they haven't done so.

In addition to absurd results, it is extremely suspicious that you report your results in tenths of a ton. Your models are obviously not accurate enough to predict with such precision, nor to predict, as you do, a difference between the Build and No-Build cases to a tenth of a percent. It is also scientifically and professionally dishonest not to disclose the level of uncertainty in your results: within what range could those values actually lie? For example, you assert that the Build case will result in 1.8% less CO (in Table 8.2, p.III-57), when the accuracy of your model (if there is any) would allow you only to say that the actual number is between, say, -25% and +25%. (And, obviously, you can't assert with confidance that the Build case will improve air quality.) See the enclosed paper, "Snake Oil in a Computer" for an elaboration of my comments on your modeling.

Besides all the highway expansion projects, I oppose all of the BART and Caltrain parking expansion projects. Please see the enclosed letter to BART for my reasons. Building parking beyond that needed for the disabled simply increases auto dependence. We build $10,000 parking spaces for single-occupant cars and don't charge the users a penny, while providing very poor bicycle parking facilities, and actually charging bicyclists to use them! For a region that has failed to attain minimal air quality standards for over 20 years, you don't seem to be in much of a hurry to reduce dependence on the automobile!

For my comments on your so-called "TCMs", please see the enclosed letter to the Bay Area Air Quality Management District. Many of the "TCMs" are not TCMs at all, since they promote the use of the automobile (especially # 15, 20, 24, and 25, which expand highways and time traffic lights to make driving easier). Others are implemented in such a way that they appear on the surface to be beneficial, but are actually not. For example # 13 provides money to build (automobile) bridges.

I know there must be a pony in there somewhere!


Michael J. Vandeman, Ph.D.