Regional Alliance For Transit
1000 Union Street, Suite 207
San Francisco, California 94133

5 January 2005

Metropolitan Transportation Commission
101 Eighth Street
Oakland, California 94607

Re: comments on the draft EIR for the 2030 Regional Transportation Plan and related documents

To Whom It May Concern:

As a means of providing comments on the draft RTP, DEIR, and related documents, and to help provide greater clarity regarding the programs and projects included therein, RAFT is submitting questions below for which we would appreciate responses from the MTC. If an answer to any question or request for information is not available, please explain why.

Learning from the Present and the Past

We understand the RTP encompasses not just the implementation of new transportation projects, but the maintenance of the existing transportation system. Which existing transportation projects or programs did the MTC review to determine if they warrant continued support over the planning period? Please provide the results of that analysis.

The Valley Transportation Authority is considering building more light rail lines (e.g., RTP project #22014) costing hundreds of millions of dollars. Whether the MTC should support such lines is not an unreasonable question. Was there an analysis undertaken by the MTC to determine whether the VTA’s relatively new light rail Tasman East, Tasman West and Capitol projects should be supported over the life of the RTP or shut down and their service replaced by buses? If so, please provide it.

RAFT has not seen a comprehensive analysis of the Tasman East/Capitol light rail line’s ridership. From the newspaper we read of high ridership, but missing are the figures of bus ridership losses as passengers have been forced to transfer to light rail due to cancelled bus services. Please provide the data the MTC has on the ridership of the Tasman East/Capitol light rail line and the changes in bus ridership due to the opening of these lines.

Ridership projections on the BART to Millbrae extension have not been what MTC, BART and samTrans expected before it opened. What steps has the MTC taken to make sure that the ridership projections for the BART to San Jose project are reasonable so that policy makers are not misled into selecting a project that will underperform expectations and cost more per passenger in reality than projected? What happens if such resulting costs are more than the transit operators can afford to pay?

For the 2001 RTP, the MTC had a series of six “goals” (e.g., Mobility, Equity, etc) and each Track 1 project was scored to identify which goals it would help to achieve. Please provide the results of the analysis done by the MTC to identify the extent to which such goals have been actually met to date. If the review was not done, please explain why. Will there be any review of the projects in the 2005 RTP to identify how, and to what extent, they achieved the new goals established therein?

How many new riders are attracted to improved bus service in the region in each of the RTP alternatives? What is the capital and operating cost of existing plus improved transit service in each alternative? What is the overall transit ridership in each alternative?

How does the MTC weigh the benefit of increased transit ridership against increased delay on highways? Where are the most significant highway delays in each alternative? If delay locations are common across alternatives, is the culprit land use or transportation investments?

Public Involvement

The MTC undertook a telephone poll to inform its decisions about the draft RTP. Please provide details to identify how the selection of 2,700 registered voters to participate in the poll did not exclude or underweight non–citizens. Also, please provide details on the weighting by county of those polled and compare it to the actual weighting of each county as measured by Census 2000.

Please provide detailed information about any two instances during the past decade about how public involvement at the MTC by low–income residents and or minority residents changed the outcome of an MTC staff recommendation for a significant transportation project or program.

The results of the “Phase 1” public involvement process identify numerous examples of low–cost amenities such as bus shelters and benches or longer hours of bus service that were deemed desirable by minority or low–income residents. Please identify where in the RTP the programming and funding for these improvements are listed, and when they will be implemented. If such requested improvements are not specified in the RTP, please explain why.

Environmental Justice

Please provide detailed information about how the MTC goes about reviewing ethnicity and incomes of expected new transit riders before it decides to support one project or program over another. For instance, the MTC continues to support BART to San Jose; please provide the analysis of the impacts to minority and low income VTA bus riders if the BART project is constructed and operated with funds reasonably expected to be available.

At a recent POC meeting, an MTC staffmember stated that steps are being taken to implement funding for the “Lifeline” program before increased funding under Proposition 42 becomes available in 2008. Please specify what such steps are, what the source of such funding is by fiscal year, and what criteria will be used to select the projects or programs to be implemented. If such criteria are not yet available, when will they be, and on what basis will they be decided?

The MTC’s “Community Based Transportation Planning Studies” have identified a range of programs and projects to improve mobility in selected low–income communities in the region. Please specify, by community, which of these improvements will be provided and the source of funding for such improvements, by fiscal year.

The “Equity Analysis” report identifies that approximately one–third of the region’s population reside in “Communities of Concern” (CoCs, page A-1), yet they are calculated to suffer, in general, approximately 40% of the vehicle travel and emissions “burdens” (page G-1). At the December MCAC meeting, the MTC’s staff stated that the difference in these ratios was “not disproportionate.” On what basis is this conclusion arrived at? One explanation given at the meeting was that people from other areas might travel into a CoC and thus cause at least part of the added burden. Does this mean that CoC residents are assumed to not travel anywhere else? Please also provide an explanation of what level of discrepancy would be necessary to be considered “disproportionate.”

How are health benefits of residents of each of the RTP alternatives quantified? Is an increase in pedestrian and bicycle trips noted as a health (or any other kind of) benefit?

What is the difference in transit level, frequency, and span of service that will be provided under each RTP alternative to bus riders compared to rail passengers, by transit operator, in each of Alameda, Contra Costa, San Francisco, San Mateo and Santa Clara counties? What is the estimated cost per rider for each operator in these counties, for each alternative?

A Curious Situation With a Very Costly Project

Page 115 of the draft RTP, dated October 2004, project #22800, states that $3,301,000,000 is for “BART extension into Santa Clara County (construction reserve only; full project not included in Financially Constrained Element).” RAFT would appreciate a thorough amplification and clarification of this project. The VTA, the project’s sponsor, has agreed to allocate $2 billion in 2000 dollars to the project, and the MTC publication shows 2004 dollars. Is the increase of over 50% due to inflation over the four years? If not, to what is it attributable?

For project #22800 what is meant by the term “construction reserve?” To what extent is such a project description eligible for FTA New Starts funding? What elements or portions of the full “BART to San Jose” project are expected to occur, and with what phasing, if any, if the $3.3 billion is expended?

No other funding for the project has been secured, and the VTA has not agreed to allocate additional amounts to the project. Please provide information about how the $3.3 billion figure was derived.

What finished project is assumed in the MTC project #22800 that costs $3.3 billion? In the “notes” to this project is “... operating funds not identified; see Santa Clara project #22909 below.” This second project shows that $2.7 billion will be needed for this project and one other VTA project, but that the source is unknown and not in hand today. Without BART to San Jose operating funds identified, how can the MTC support this project? How can it be in a financially constrained RTP?

Please identify all Muni or AC Transit transit improvement projects or programs during the past ten years that were not supported or included in an RTP by MTC because “operating funds (were) not identified” and explain what is the difference from the VTA project.

Not a Goal: Cost Effectiveness

Will the MTC ever use cost-effectiveness as a criterion for transportation project and program selection? What exactly is required for this to happen? If not, why not?

RAFT notes that the BART to San Jose project is calculated by the VTA to have a cost per new passenger of about $32. For one new passenger, the cost per fifty–week year, with a round trip each weekday, is an astronomical $16,000. According to the RTP, Bay Area residents want a goal for the MTC to be “a process that ensures major new transportation investments have been well scrutinized for cost-effectiveness.” However, the MTC has not adopted this goal. What keeps the MTC from carefully scrutinizing major new transportation investments for cost–effectiveness?

Is there any policy, rule, regulation or law that requires the MTC to provide funding to transportation projects that are not cost–effective? If so, please provide specifics. Is there any policy, rule, regulation or law that forbids the MTC from funding cost–effective transportation projects? If so, please provide specifics.

County Sales Tax Expenditure Plans

Is the MTC required to support, or to include in the RTP, all projects that are included in a county sales tax expenditure plan? If so, under what authority? Is it permissible for the MTC to not support, or to not include in the RTP, or to do so only selectively, a project that is a part of a county sales tax expenditure plan? If so, under what authority?

ABAG Projections

From time to time (e.g., Alameda County Congestion Management Agency draft RTP comment letter to the MTC of December 15, 2004) local government officials state that the MTC must use ABAG projections for the RTP by law or statute. Please provide citations to any state or federal policies, rules, regulations or laws that require that the MTC use only ABAG projections.

ABAG has recently issued its Projections 2005 report, yet the draft RTP continues to rely on the 2003 Projections. If MTC has an obligation to use ABAG data, under what authority is MTC allowed to utilize outdated information?

Financial Responsibility

Please specify the basis in federal and state rules, regulations and laws and or regional policies which are used to determine which federal and state funds, and in what amounts, are provided to County Congestion Management Agencies for distribution and project definition.

Please provide the specifics of the analysis under which federal and or state funds (including but not limited to STP, CMAQ, and STA) are being set aside for MTC to allocate to “regional programs.” Please also provide the results of the Title VI analysis that was conducted by MTC in order to determine how much funding from each source will be available for each of these “regional programs.”

In the Bay Area, besides the MTC, what other local agencies, such as CMAs, have the ability to determine the allocation of §5307, §5309, STP, CMAQ and STIP funds? Please specify for each fund source.

The MTC’s Abilities and the Transdef Smart Growth Alternative

Does the MTC have the ability to withhold funding from an area that has “dumb” growth policies and practices and or to provide funding to another area that has “smart” growth policies and practices? If so, under what authority?

Does the MTC have the ability to direct funding of projects and programs to geographic areas such as west Contra Costa County or the Walnut Creek/Lamorinda area of Contra Costa County and to limit funding to other areas such as the San Ramon Valley and eastern Contra Costa County? If so, under what authority?

In a December 8, 2004 memorandum from the Contra Costa Transportation Authority staff to its Planning Committee, it is stated that one of the RTP alternatives (Transdef Smart Growth) “assumes that MTC has land use powers that it does not have.” Please provide a list of those powers to the extent that they are known to the MTC.

In its draft RTP comment letter to the MTC, the Alameda County CMA states that the Transdef alternative includes “parking charges at all employment sites...(and) there is no clear authority to impose the parking charges.” RAFT understands that the Transdef alternative utilizes parking cash out, not parking charges. Is this correct? Also, does the MTC have the ability to require parking cash out anywhere in the Bay Area? If so, where and under what authority? Would the implementation of parking cash out in the Bay Area help improve our quality of life over the life of the 2030 RTP? Why or why not?

The Alameda County CMA’s draft letter also states that Transdef’s “land use assumptions are not consistent with local general plans thus making the alternative infeasible without approval of general plan amendments throughout the Bay Area.” Do the Transdef alternative’s land use assumptions require any general plan amendments by local governments that are different from those required by the MTC’s own alternatives? If so, please specify.

The Alameda CMA also wrote in its draft letter that “BRT” was added in Livermore, Pleasanton, Oakland Airport and Cal State Hayward. Is this correct? RAFT understood that, with the possible exception of parts of the CSUH project, these projects are Rapid Bus similar to what operates on AC Transit’s line 72R today, not costly Bus Rapid Transit with exclusive fixed guideways. Please clarify what the MTC understands to be the difference. The CMA continues by stating that “no source of operating funds was identified for these services.” Did the MTC require an identification of specific operating funds for these (or any other new) services? If so, please specify. Could not, for example, STP funds be converted to §5310 and used to offset ADA paratransit costs, freeing up operating funds for use with the new services? Why or why not? Also, is the situation with these new services any different than is the case with project #22909? If so, how is it different?

How have local land use controls changed in the past twenty years? Is it not reasonable to assume the trend to densification in the Bay Area will continue in the next 25 years, much as the Transdef alternative assumes?

What is the mode split in the I-580/I–680/I–880 corridors across the RTP alternatives? How many intra-regional trips are attracted to the High Speed Rail system in the TRANSDEF alternative? How many are attracted to transit in the other alternatives? Given a project justification of moving passengers from southern and eastern Alameda County to Santa Clara County, would the VTA’s proposed BART to San Jose project be a good investment if high speed rail is constructed and operated over the Altamont Pass to downtown San Jose? Why or why not?

We appreciate the opportunity to comment and look forward to your responses.


for RAFT
S/M. Kiesling