December 10, 1989

Chris Brittle & Greig Harvey

MTC

101 8th Street

Oakland, California 94607

Re: "Screening of TCMs for the S.F. Bay Area", by Greig Harvey

Gentlemen:

There is a great danger that studies like this will be used to rationalize the MTC's "business as usual" policies (which are aimed primarily at maintaining a strong flow of state and federal dollars, whence the preference toward highway construction). In order to avoid such an appearance, you should (1) disclose all of your assumptions, as recommended on p.17 of the ARB's CCAA Draft Guidance #2 -- Transportation Planning Requirements; (2) disclose how TCMs were selected and rejected for study; and, most importantly, (3) study all TCMs that may be effective, regardless of their alleged unpopularity.

For example, one TCM must be the halting of roadway expansion. This is alleged to be unpopular, however, MTC's own survey showed that only 18% of the Bay Area population wants more freeway construction (probably less, since the earthquake). This is also the most cost-effective, since it would actually save billions of dollars that would be spent on highway expansion. Coupled with the use of the money to build an effective rail transit network, this TCM is hard to beat. In fact, most of the competing TCMs would be greatly weakened, if forced to compete with expanded freeways. Research indicates that a significant proportion of people will stop using transit and return to driving, if congestion is reduced by expanding the freeways.

HOV lanes, unless created from existing mixed-flow lanes, are not TCMs: they encourage transit riders to transfer to casual carpools (A/C Transit has lost thousands of riders to casual carpooling); if created via new pavement, they encourage people to drive, since the vehicle-carrying capacity of the freeway is increased; and they only operate as HOV lanes for a small proportion of the day, ignoring the fact that 65% of trips are non-work-related. In other words, they are for all practical purposes synonymous with freeway expansion.

Similarly, expanding BART parking encourages auto dependence. What could be more wasteful than using valuable real estate for holding a single automobile all day long? To avoid short trips to BART, with their attendant cold starts, walking, bicycling, light rail, or buses should be used to get to BART.

Free parking should not be given to anyone except the disabled. HOVs should pay the same as any other vehicle, since any vehicle trip is more destructive than walking, bicycling, or the use of transit. HOV riders, since they split the parking charge, will still pay less for parking than SOV riders.

TCMs that focus on certain times or places (e.g. congestion- or pollution-episode tolls) send the wrong message. Driving isn't more virtuous because it happens at a certain time or place. All trips and VMT should be targeted. We are not simply trying to shift pollution around, but to eliminate it. The appropriate measures of effectiveness are trips and VMT; mode shifts, emission reductions, congestion relief, etc. are too ambiguous.

Fuel taxes are not TCMs, if used to build more freeways, but only if used for air-quality or other justifiable purposes. This should be made clear. Similarly, arterial "operational improvements" are ambiguous. If average speeds are increased, or vehicle carrying capacity (as opposed to people- or goods-carrying capacity) is increased, the resulting growth inducement will overwhelm any alleged air quality benefit. (This is a good example of where assumptions need to be stated.)

Replacing older vehicles is enormously expensive. It is better to give them nowhere to park, so that they won't get driven where transit is available. The $1/gal. fuel increase wasn't accurately analyzed. The 1.7% trip reduction is not believable. Similarly, the 10% speed reduction obviously doesn't adequately take into account trip and VMT reduction. Speed reduction is also very vague: how would it be accomplished? It can't be done directly, so is useless as a TCM. It is also apparent that the research of Jeff Kenworthy and his associates has been ignored in your analysis. Unless you can point to research that contradicts their findings, you have no justification for ignoring their results, which are highly relevant.

Sincerely,

Michael J. Vandeman, Ph.D.