February 11, 1990


Attn: Public Information

101 8th Street

Oakland, California 94607

Re: TCMs Proposed to Meet Federal Air Quality Standards: Additional Comments


Because many of the TCMs are rather vague, and because their implementation depends to a large degree on MTC's participation and/or direction, it is relevent to note MTC's past lack of diligence in performing its air quality duties. Seven years was a long time for us to wait for clean air (in my case, one-sixth of my life)! It is a tragedy that, in a supposedly "democratic" country ("of the prople, by the people, and for the people"), such abuses can exist. As we celebrate the rise of democracy in Eastern Europe and the Soviet Union, we should not forget that we don't have democracy here -- not when our own elected officials can, in the pursuit of financial gain, continue to ignore the most basic health needs of the people who put them in power. We are not going to stand for seven more years of dissembling and procrastination.

The purpose of the TCMs is to bring the Bay Area into compliance with the federal ambient air quality standards. This means that the measures must reduce emissions to a level that will meet those standards in spite of continuing growth. Your methodology, in contrast, only aims to reduce emissions by a constant amount, in accordance with an Air Quality Plan that is 8 years out of date. You have not even attempted to demonstrate that the ambient levels that will result will be within the proper bounds as soon as practicable and continuing into the future.

It is clear that meeting the standards is possible: approximately 90% of CO and 45% of HC come from the automobile and its relatives. Since no trip can be made without a place to park at the destination, sufficiently high parking charges could be used to reduce driving to any desired level, even close to zero! (This is what we mathematicians call an "existence proof".) Market-rate parking charges should be implemented at the state level, and passed down to every subordinate level of government. The levels should then be increased yearly, if necessary, based on actual ambient pollution levels attained (not emission inventories, which are hard to compute and hence easy to "fudge"). The only exceptions should be for the disabled who for some reason cannot utilize public transit. The parking charges should be used to subsidize public transit, so that it can be as cheap as possible and provide adequate mobility for everyone.

According to the United Nations, we need to reduce fossil fuel consumption by half in order to avoid the devastating effects of global warming. Therefore, we won't need even the highway capacity that we have now, much less any additional vehicle capacity. As a minimum, all highway vehicle capacity increases should be halted immediately, until it can be demonstrated that we have attained and can maintain federal and state air quality standards and have no feasible alternative to highway expansion. (We also need a retraining program for Caltrans employees to prepare them for conversion to rail-based priorities.)

It is quite a coincidence that all of the measures which make driving easier or which bring additional funds to Caltrans (TCMs 24, 25, 15, 26, & 20) appear at the top of the emission-reductions chart! Greig Harvey stated that he used "conservative assumptions" in his analysis, but this is clearly not true. For example, TCM 15, which would fund the widening of numerous freeways and other arterials, should have associated with it the assumption that trips and VMT would increase in proportion to the added vehicle capacity. (E.g. on I-680, where 2 lanes are added to the existing 4, he should assume a 50% increase in traffic.) The conservative (and quite reasonable, judging from the findings of J. R. Kenworthy et al) assumption would be that traffic expands to fill the available capacity. Exceptions to this rule (e.g. possibly I-980) seem to be rare. Using such an assumption, he would have computed increases, rather than decreases, in emissions (per the only available research on this issue, that of Kenworthy et al). One doesn't have to be a professional traffic engineer to understand this. (We do need a gas tax, but one whose proceeds are applied exclusively toward road maintenance and transit. Only then could we expect air quality gains.) Similarly, the analysis of TCM 20 does not utilize this reasonable, conservative assumption.

TCMs 24, 25, & 26 serve to encourage driving, and thus in the long run probably are marginal, if not outright counterproductive. For example, traffic signals, rather than serving all motorized traffic, should be designed with overrides that give preference to transit vehicles, bicycles, and pedestrians. The FETSIM research was conducted under the supervision of Elizabeth Deakin. I asked her why she did not, as a part of the FETSIM research, investigate possible growth inducement due to speeding up traffic. She told me that she didn't think such research was necessary. Emission reduction estimates from TCM 26 seem extremely overstated. If "Incident Management" were such a productive technique, considering its relative cheapness, it would have been implemented long ago. The incident-reporting signs on the Bay Bridge are a joke. What are we to do, when we learn that there is an accident ahead? Turn around??

Air pollution is an extremely large problem. Let's work together on its solution, which will benefit not only everyone in the Bay Area, but the rest of the world as well.


Michael J. Vandeman, Ph.D.