February 7, 1990


Attn: Public Information

101 8th Street

Oakland, California 94607

Re: TCMs Proposed to Meet Federal Air Quality Standards: Statement for 2/9/90 Public Hearing, MTC, Oakland


Your "Proposed Transportation Control Measures for the Contingency Plan" demonstrates once again what I said at the August 25 hearing -- that you have no intention whatsoever of attempting to achieve the federal (much less the state) air quality standards. Your proposal, rather than addressing any environmental realities, promotes your political agenda, which is to enrich yourselves and your pro-highway, pro-development friends, at the expense of the health and well-being of the community.

The TCMs, per the Clean Air Act and Judge Henderson's order, are supposed to restore RFP (Reasonable Further Progress toward the air quality standards) in the Bay Area. However, you don't even address RFP! You assume that the TCMs are only responsible for an imaginary "transportation share" of RFP, when the Contingency Plan clearly states that "These TCMs will be designed to bring the region back within the RFP line."

Your job is to demonstrate that the proposed measures will reduce emissions sufficiently to meet the standards, in spite of expected growth in the region. You don't do that. In fact, you don't offer any proof whatsoever that the TCMs will be sufficiently effective, nor any estimate of when the standards will be met.

In fact, several of the so-called TCMs are not TCMs at all, since they serve to increase traffic and increase auto dependence in the region: TCMs # 4 & 20 allow for expanding the vehicle capacity of highways, as long as the added lanes serve for a few hours a day as HOV lanes. You offer no evidence (and there is none) that these measures will improve air quality. TCMs # 7 & 8 emphasize park-and-ride lots. However, building more parking lots (rather than expanding public transit so people don't have to drive at all) just increases auto dependence. Since 70% of the emissions in the average auto trip are due to the cold start (beginning of the trip) and the hot soak (end of the trip), it is more important to prevent trips entirely, than to merely shorten them.

TCMs # 13 & 15 are also counterproductive, since the vast majority of the funds generated are earmarked for roadbuilding! Of course we need higher bridge tolls, gas taxes, and other automobile user fees, but if the proceeds are spent on highway expansion, they will serve to increase traffic, emissions, and fuel consumption, as well as drawing patrons away from public transit. Bus riders pay $3.00 (round trip) to cross the Bay Bridge; BART riders pay $2.80; drivers pay only $1.00! Rather than increasing the bridge tolls to $2.00, drivers should pay at least as much as transit users, and preferably more, since they are responsible for much more wear and tear on the bridge. Haven't we subsidized the automobile long enough?

You are 7 years late in implementing the Contingency Plan: the first RFP failure was in 1983. Rather than insulting us with another wimpy, totally ineffective TCM plan that will damage the health of Bay Area residents for another 7 years, why not implement enough tough, measurable TCMs to really do the job? When the Bay Area has proved that it can meet the federal and state air quality standards for a year, then ease up on any that are too burdensome. But until you prove that you can meet the standards, why should we trust you again??


Michael J. Vandeman, Ph.D.

"REVERSING THE TREND TOWARD AUTOMOBILE DEPENDENCY -- A RATIONALE FOR HALTING FREEWAY EXPANSION", An Excerpted Bibliography of J.R. Kenworthy, P.W.G Newman, and T.J. Lyons. Michael J. Vandeman, July 19, 1989.

Newman, P. W. G. and J. R. Kenworthy, "The Transport Energy Trade-Off: Fuel-Efficient Traffic Versus Fuel-Efficient Cities". Transportation Research-A, Vol.22A, No.3, pp.163-174, 1988.

Newman, P.W.G., J.R. Kenworthy and T.J. Lyons, "Does Free-Flowing Traffic Save Energy and Lower Emissions in Cities?" Search, Vol.19, No.5/6, September/November, 1988.

Kenworthy, J.R., H. Rainford, P.W.G. Newman, and T.J. Lyons, "Fuel Consumption, Time Saving and Freeway Speed Limits", Traffic Engineering and Control, September, 1986, pp.455-459.