October 24, 1989

Metropolitan Transportation Commission

101 8th Street

Oakland, California 94607

Re: Air Quality Contingency Plan ("MTC does not want to be caught up in a process that might artificially constrain our ability to fund the projects our partners in this region are planning." 903.40.01,p.1)


That quote says it all: MTC runs a pork barrel operation, where business interests control the people's elected representatives, and they in turn deliver the "pork" (freeway expansion projects) to make the already-rich even richer. How else could one explain the sudden about-face the MTC made on the air quality effects of freeway expansion projects? One moment, MTC demonstrated rare honesty and courage, and designated such projects as "D*" ("potentially detrimental to air quality"); the next moment, the projects all suddenly became "neutral"! How else could a 50% increase in the capacity of a major freeway (I680 from Willow Pass Rd. to Marina Vista) result in NO NET EFFECT ON AIR POLLUTION? I'm sure it was just a coincidence, that droves of pro-highway lobbyists had just called the MTC and complained about their D* ratings..

The problem of air pollution is so enormous, I'm sure you will agree, that it won't get solved without EVERYBODY doing his/her part. No one group, law, or government agency can do it alone. I do my part by not owning a car, and by walking, bicycling, and using public transit, whenever possible. The MTC also has a part to play, as you acknowledge: "MTC intends to fully fulfill its air quality responsibilities." (902.92.01,p.6)

How, then, do you explain the fact that Christine Monsen told me over the phone yesterday that MTC will rely totally on Caltrans's air quality analysis? If you have an obligation to judge the air quality effects of freeway expansion projects, how can you discharge that responsibility by deferring to an agency that is notorious for producing environmental documents that are heavily biased in favor of freeway expansion? You say that these environmental documents are "legal documents", and thus appropriate to rely on. However, there is no law against lying in an EIS, and there is no effective process for ensuring that the document is accurate.

On the other hand, there IS a process for ensuring the accuracy of scientific research, such as the work of J.R. Kenworthy and his associates, proving that freeway expansion INCREASES air pollution and fuel consumption. That process is the scientific method and the process of INDEPENDENT VERIFICATION of one researcher's results by others. When I mentioned the Kenworthy research in my comments on the Air Quality Contingency Plan, MTC answered that it was aware of "other, contradictory articles" (6271p,p.7). However, when I asked Christine Monsen what those "contradictory articles" are, all she could think of was an editorial. An editorial, as you well know, is not scientific research, and not worth mentioning in the same context as research.

You say "Determination of when a highway may be growth inducing and therefore contributing to deteriorating air quality is an inexact science which makes any judgement subject to challenge." (902.92.01,p.5) However, you are willing to rely totally on Caltrans's judgement, while rejecting the results of scientific research! Does that make sense? It is obviously of the utmost importance to answer this dilemma. In answering the comments, you say "We see no cogent means to resolve the dichotomy of opinion that exists concerning whether highway projects are benign or contributory to regional ... air quality degradation." (Detailed Comments and Responses, 10/20/89, p.9) Then why not do your own study? There must be many widened freeways in the Bay Area and elsewhere, for which "before" and "after" data exist. Just don't hire a pavement contractor to do the research!

If freeway expansion projects are "neutral" in their effects on air quality, why is highway construction delay a major part of the Air Quality Contingency Plan under the Clean Air Act?

EPA's credentials in the field of air pollution surely eclipse yours. In their 9/1/89 letter to Larry Dahms, they complain about your "failure to properly evaluate and consider potential adverse impacts of highway projects". They also state that "Currently existing environmental documents may not be adequate for making a determination whether a project has adverse air quality impacts. In addition to segmenting many projects, recent documents have not addressed ozone impacts and the effect of project-induced trips. Where existing documents are inadequate, MTC should delay any capacity-enhancing projects because of their potential adverse air quality impacts." Why have you ignored the EPA's recommendations?

On the chart describing "Procedures for Considering Highway Projects for Delay" is a process for judging an "Incomplete Air Quality Analysis" within a "Certified Environmental document". This contradicts Ms. Monsen's statement about relying on the certified environmental doocument. Exactly what does this process consist of? Surely, a piecemealed project lacking an analysis of the cumulative effects of all of its parts is incomplete. So is one lacking an ozone/HC analysis, as the EPA pointed out in the same letter. So are all studies not mentioning the Greenhouse Effect and the Ozone Depletion -- highly relevant "new information" that necessitates a supplemental environmental document for every project.

You say that you will allow all projects to go forward, as long as the sponsor "promises" certain "mitigations". Promises of future bandaids will not impress the victim of an amputation. You call this "a more certain option", but actually, there is no possible mitigation for the growth-inducing effects of freeway expansion. No one can remove tracts of homes or giant malls after they are built, nor persuade the occupants of such auto-dependent developments not to drive their cars.

You point to HOV lanes as proof of your air quality concerns. Where is the evidence that HOV lanes reduce air pollution??? Many of those "HOV lanes" don't even extend the full length of the project (e.g on I680 between SR24 & I580), none operate more than a small portion of the day, and all have been shown to draw patrons away from transit. HOV lanes which are added lanes actually increase the mixed flow capacity of the highway, so by your own criteria are potentially detrimental to air quality.

The United Nations has stated that we have to reduce fossil fuel consumption by 50% below current levels to avoid devastating rises in sea level and air temperature. If so, then we obviously won't need these expanded freeways. And all money wasted on them is desperately needed to stave off the Greenhouse Effect and the Ozone Depletion, to say nothing of reducing the National Debt.

I suspect that you think you are protecting the local economy with those highway projects. Then consider the fact that, since 1987, Japan is now the richest country in the world. They didn't get there by building freeways. They are almost entirely dependent on public transit.

In your writings, you often pat yourselves on the back. Wait until the job is done. Wait until the air in the Bay Area meets the State and federal standards. Then pat yourselves on the back. For the first time ever, your staff is proposing to add air quality as a criterion for prioritizing proposed projects in the RTIP. (6188p,p.6) (However, it would be "based upon existing environmental documents, if available".) Maybe there is hope for you after all!

Respectfully yours,

Michael J. Vandeman, Ph.D.