I would like to offer the following comments on __. I am including in my comments the following documents, which are enclosed: "Does Free-Flowing Traffic Save Energy and Lower Emissions in Cities?", P.W.G Newman, J.R. Kenworthy, and T.J. Lyons, Search, Vol. 19, No. 5/6, September/November, 1988; and "Transport Energy Conservation Policies for Australian Cities -- End of Grant Report, Project No. 836", P.W.G. Newman, J.R. Kenworthy, and T.J. Lyons (Murdoch Univ., Murdoch, WA, Australia), August, 1987 (I am enclosing only the Summary).

Presumably you are referring to the transport of people and goods, since the mere shuttling of vehicles back and forth would have no purpose. For transporting people and goods, there are many feasible alternatives. The most practical and environmentally sound alternative is rail transport. It is well known that a rail line can carry as many passengers as an 8-lane freeway. You even mention such a project on p.32: "The LRT [light rail] alternative uses the Tasman Drive median from Milpitas to Sunnyvale." However, you fail to analyse this as an alternative to widening 237.

Rail transit is necessary, in any case, because the Earth has a very limited supply of oil, which is expected to run out in only 30 years. As the above papers mention, we need to begin conserving fuel, and the best way to do that is to stop expanding the highway system, build rail transit systems, and build housing, basic services, and jobs close together. And until public transit has been built and in service for a reasonable time (say, 6 months), there is no way to know if the freeway really needs to be widened! After we give transit a chance to work in the 237 corridor, then we should examine whether there is still a traffic problem (more accurately, transportation problem). Ideally, this trial should include rail lines connecting San Jose to both San Francisco and Sacramento.

This brings me to the next defect of the EIR: the energy analysis. On p. 122 you state: "energy savings of approximately six million gallons per year would occur in relation to the current traffic conditions on Route 237." This is not true. Recent research (see the first article mentioned above) has demonstrated that speeding up traffic only saves fuel for an isolated vehicle, not for the community as a whole, and then only up to 34 MPH (see the 4th article mentioned above). Capacity increases that aim to speed up traffic always cause people to drive farther and drive more often, with the result that fuel consumption for the community as a whole increases! The only way to save fuel is to begin to wean ourselves from dependence on the automobile. Expanded freeways will simply fill up and soon have the same congestion, only more lanes of it.

This leads to the next defect: the air quality analysis. The same research and reasoning applies to air pollution as applies to fuel consumption: freeway vehicle capacity (as opposed to passenger capacity) increases always induce growth in traffic and worsen air pollution, even though an isolated vehicle may produce less pollution per mile as it speeds up. The first paper mentioned above explains why this is true, and describes the research that proved it. Although the 237 "Air Quality Report" (Aug., 1988) was unavailable at Caltrans's office yesterday (3333 California St., S.F), I know what it will say: "widening the freeway will not cause an increase in traffic." That is the only way that it could predict a decrease in CO! However, on p.89 you admit "the project would have a growth-inducing impact." It is this growth inducement that will cause the added lanes to fill up very quickly, probably as soon as they are finished. As soon as the widening gets approved, developers will be wasting no time to take advantage of the added access. While it is intuitively obvious that freeway expansion worsens air pollution, and a trip to Los Angeles will confirm that, the above papers also give scientific evidence to that effect.

This also implies that congestion is not a sufficient reason for widening a freeway: congestion serves the very useful purpose of restricting growth that could be environmentally damaging, as growth in the 237 corridor certainly would be: extremely valuable wetlands and farmland would be destroyed. We are not talking of mere convenience. Our very lives depend on the existence of wetlands and farmland! Projects such as this one are nothing short of suicidal!

Safety is usually mentioned as a reason for eliminating congestion, using the number of accidents. However, this is faulty reasoning: congestion may give rise to more accidents, but they will be "fender benders", not truly serious accidents. Speeding up traffic will cause much more serious accidents to occur. In other words, safety is actually decreased.

Third, there is no moral or legal requirement to build freeway capacity for everyone who wants to drive, particularly since the automobile is so destructive of the environment and our health. In fact, it says on the first page of our Driver's Manual that driving is a privilege, not a right.

This is made even clearer when we examine the most serious effects of the automobile yet discovered: the Greenhouse Effect (to which the automobile contributes 40%) and the Ozone Depletion (exacerbated by automobile air conditioners). The United Nations has said that we must reduce traffic by 50% by 2050. We can't do that by expanding the highway system. The California Clean Air Act and the Cortese Bill (now Law) also mandate reducing traffic, until we meet State air quality standards. The results of the Greenhouse effect will be infinitely more expensive than any amount of commuter delays! And in the S.F. Examiner today was an article ("Ozone disturbances found at the North Pole") saying that the ozone depletion problem is even more serious than we thought. The fact that the EIR ignored these two serious environmental effects adds two more violations of CEQA.

Freeway expansion is stupid, suicidal, and unnecessary, and must be stopped. I suggest that Caltrans build upon their phenomenal recent successes with rail transit (e.g. Caltrain) and stop trying to pave over all of California.

Respectfully yours,

Michael J. Vandeman, Ph.D.