Regional Alliance For Transit
Founded 1992

1000 Union Street, Suite 207
San Francisco, California 94133
Telephone: 415 440-6895
Email: raft@mtcwatch.com

June 18 2007

Metropolitan Transportation Commission
MTC Public Information
101 Eighth Street
Oakland, ca 94607

Re: Comments on the Draft Public Participation Plan released to the public on May 4, 2007

The Regional Alliance For Transit (RAFT) submits the following comments and questions for your consideration:

1.    What are the changes between the current plan and the proposed new plan? How will the public know what is different?

2.    How has the current public participation plan worked? We are unable to locate your evaluation of it in the draft Public Participation Plan, other than a reference to comment cards submitted at previous RTP meetings.

3.    How will the MTC determine if the new plan is a success? How does the MTC define success? What metrics will be used for evaluation?

4.    We do not agree with the thinking about the TIP as stated on page 25 of the draft: "...there is comparatively less value for public to participation (sic) in the TIP.…” The Department of Transportation in the Federal Register (Volume 72, Number 30, §450.316, 14 February 2007) makes it clear that the TIP is an important document for public comment. For instance, (vi) states that the MPO will demonstrate “explicit consideration and response to public input received during the development of the metropolitan transportation plan and the TIP.” Among other things, the TIP is the means the MTC uses to identify projects and programs to be funded in the near term and also which others to not fund in the short term in the twenty five year long range regional transportation plan.

5.     Further, how will the MTC demonstrate “explicit consideration and response to public input,” both for the RTP and the TIP? Many of RAFT’s comments on the DEIR for the 2005 RTP (see http://www.mtcwatch.com/pdfiles/1-05_RAFT-MTC_RTP.htm) were not responded to, and the letter we received back from the MTC indicated that we had exceeded some unspecified “quota” of comments. How will this be handled for the next round?

6.     The MTC web site states the draft plan will be translated into Chinese and Spanish. A draft in Spanish is available, but the one in Chinese does not appear to be available, with but two days remaining in the comment period.

7.    When and how will the general public have the opportunity to comment on the “tribal consultation” elements of the proposed plan?

8.    When documents are reported to be available at the Bort Metrocenter library, they indeed should be readily available there. Too often, the response we hear is something like, “we don’t have it, you have to contact (xxxx) on staff.”

9.    As time goes by, the mtc relies more often on the nine Congestion Management Agencies for public involvement work. The new plan should require that the CMAs will follow the MTC plan, and acknowledge that the MTC is actually the ultimate responsible agency at which the public may comment on its work. How will MTC oversee the CMAs’ public participation processes on the MTC’s behalf?

RAFT looks forward to receiving your responses to our input.


Michael Kiesling for RAFT