16 Monte Cimas Avenue
Mill Valley, CA 94941
383-0776 fax

January 2, 2005
By E-mail & U.S. mail

Steve Heminger, Executive Director
Metropolitan Transportation Commission
101 Eighth Street
Oakland, CA 94607

Re: Draft Transportation 2030 Plan

Dear Mr. Heminger:

The Transportation Solutions Defense and Education Fund, TRANSDEF, herein offers its comments on the Draft 2005 Regional Transportation Plan, known by MTC as Transportation 2030 or, simply, the RTP. TRANSDEF congratulates MTC staff on making this RTP more strategic and more regionally oriented. Past RTPs were so focused on the list of funded projects that actual transportation results got short shrift. This RTP begins to correct that. However, the Draft Plan does not take advantage of what was learned when MTC evaluated its first formal RTP alternative.

As TRANSDEF's two letters on the Draft Environmental Impact Report (DEIR) (submitted under separate cover) indicate, the TRANSDEF Smart Growth Alternative produced better results in multiple arenas: it is the Environmentally Superior Alternative; the alternative offering the most accessibility to jobs; and the most savings of money; and it is the fiscally constrained alternative with the most user benefits for low income communities and for the general public, as well as the most congestion relief. These results are striking enough to warrant MTC incorporating as many elements as possible into the Final RTP.

There is no underlying intellectual justification from a regional perspective for the project selection choices in the Project Alternative or the Fiscally Constrained Alternative (which is why they don't perform as well), other than that they were recommended by their respective counties. The TRANSDEF Smart Growth Alternative, by contrast, is based on a specific regional strategy of reducing the use of single occupant vehicles, implemented by providing convenient transit that is financially attractive to drivers, by reforming market forces, by shifting housing closer to jobs, by supporting transit densities and mixed use, and by locating jobs and housing near transit (Smart Growth). These strategies work better (and are much more affordable) than the traditional strategy of responding to traffic congestion by increasing roadway capacity and building BART extensions. In summary, neither the Project Alternative nor the Fiscally Constrained Alternative is the best use of the region's scarce funds.

For the Bay Area to get more for its money, and preserve more of its quality of life, MTC will need to become an active regional advocate, representing the region in local jurisdictions' planning decisions, encouraging them to 'think regionally,' especially in controversial cases where a local jurisdiction is harming the region. MTC needs to be willing to withhold transportation funds where a land use decision would undermine the effectiveness of an investment.

TRANSDEF appreciates the work of MTC staff in evaluating the TRANSDEF Smart Growth Alternative, and hopes that the analysis will be useful in supporting a further shift towards pro-regional policies. We further hope that the Alternative is helpful in demonstrating to existing residents that denser development can provide benefits not only to the region as a whole, but to them as well.

In the following comments, we identify the large amount of pro-regional language in the Plan that we support, as well as a smaller amount of language that we disagree with. These comments pertain only to the Plan itself, and not to the EIR.

Pro-Regional Policy Language in the Plan
We are very pleased to see that ". . . MTC found strong public support for better connecting transportation and land-use decisions, developing more convenient transportation options, and pursuing greater regional cooperation on issues surrounding the location of new development." (pp. 1-2) Land use decisions made in consideration of their regional impacts will lead to better long term transportation results.

"The bottom line is that the Bay Area must accommodate more of its growth in existing urban and suburban areas, which are already well served by the region's road and public transit networks." (p. 2) We agree that this controversial result can be accomplished "only with a frank recognition of the hard work required, [and] a willingness to experiment and innovate ...." (p. 1) The work is highly political. That is why TRANSDEF's leading request during the Air Resources Board-sponsored Roundtable process was for MTC to exercise leadership in building consensus for Smart Growth amongst local government leaders. While the advocacy has not been as extensive as TRANSDEF might prefer, MTC has made a significant commitment in this direction.

"A renewed financial commitment to infrastructure repair should not come without strings attached. No public agency should receive additional funds unless it agrees to support and implement measures to improve the efficiency of the transportation network." (p. 2, emphasis in original) These statements exemplify the bold "willingness to experiment and innovate" cited immediately above.

"There are simply too many cars trying to squeeze through too small a space at the same time. Demand exceeds capacity, and delays result." (p. 3) While we certainly agree with the conclusion, we note that it leads directly to a congestion relief strategy of reducing demand-one that has not been used much by MTC. TRANSDEF believes that demand reduction through pricing, Smart Growth and convenient transit is the optimal overall strategy for MTC.

"A proven strategy to reduce freeway delay is to meter entering vehicles with traffic lights at freeway on-ramps . ... This opposition must be overcome." (p. 3) We appreciate the way this strategic approach to improving transportation keeps focus on the regional benefit, rather than on the opposition.

"The bigger challenge is overcoming the institutional tangle of multiple owners and operators of the transportation system so their unifying mission becomes maximizing the effectiveness of the system as a whole." (p. 3) We would like to see MTC formally adopt as its mission "maximizing the effectiveness of the system as a whole." This is precisely the kind of regional thinking we want to see at MTC.

"...the time has come to begin consolidating these two dozen [transit] operators into a smaller and more manageable number of agencies." (p. 3) We agree, and would like to see MTC facilitate the development of programs where larger operators offer contract administrative services, such as human resources, payroll, and purchasing, to smaller operators. This approach would allow the elimination of redundancies and the production of economies of scale without the loss of local control. It could eventually lead to the sharing of senior management or political merger.

While the promotion of casual carpooling (p. 5) is a strategically elegant idea, we are unaware of any MTC program or proposal in this area. Casual carpooling in the Bay Bridge corridor imposes costs on AC Transit for extra afternoon service, because of the failure of casual carpoolers to achieve an equivalent volume in the reverse commute. Please explain what is intended by MTC in this area.

While TRANSDEF continues to disapprove of the specifics of the Resolution 3434 investment package, we strongly support that "the Draft Transportation 2030 Plan conditions Resolution 3434 discretionary fund allocations on local governments taking steps to implement the Smart Growth Vision through general plan amendments and zoning changes." (p. 5) The reasons for this policy are right on target: "This new approach both responds to the Bay Area's acute housing shortage and gets the most ridership "bang for the buck" out of these costly rail transit extensions." (p. 5) If the policy is made strict enough to actually produce significant amounts of transit-oriented development, it will have been MTC's most important policy initiative in the past decade.

While the use of the term "down payment" throughout the Plan minimizes the significance of the fiscally constrained funding source for the Plan, in the area of Lifeline Transportation, it is precisely the right term. "Any of these solutions will require new funding, however, and the Draft Transportation 2030 Plan makes a $216 million down payment to get the region started." (p. 5) The two unanswered questions surrounding the Lifeline Program are "How much money is really needed over the RTP period to provide for the needs of low-income communities in the Bay Area?" and "What share of the existing transportation funding pie do low-income communities deserve, as their fair share?" TRANSDEF believes that over the life of the Plan, the $216 million represents only a down payment. The rest of the fair share should come from existing funding, as it would be inappropriate to use new revenues to address past and present discrimination.

TRANSDEF strongly supports the approach "Market Forces Are Key to Success" (p. 6). We agree that "At the very least, the state gas tax should be indexed with inflation." (p. 6), but think a better approach would be to index the gas tax to the cost of maintaining the existing system. There's no good reason that our society has not simply agreed to pay what it costs to keep the roads paved and bridges maintained.

We think the statement "in the long run, building unpriced road capacity in a growing region is fighting a losing battle with traffic congestion." (p. 6) is so important that it should be the centerpiece of MTC policy. Unfortunately, here it is merely a wistful observation in a Plan which uncritically throws large amounts of valuable resources into precisely that losing battle.

TRANSDEF supports the suggestion to "change MTC"s enabling statute to permit the Bay Area electorate to approve a regional gasoline fee with a simple majority vote." (p. 7)

TRANSDEF is pleased to see the sober evaluation that "At present, we are losing ground on most of these [RTP] objectives." (p. 7) Without realistic self-appraisal, it is impossible to self-correct. Our question in response is, "is MTC willing to change direction and try to do something to stop losing ground?" It would appear so, on the basis of the Plan's statement that "Tomorrow's transportation challenges should prove no match for a mobilized citizenry with the determination, the vision, -and the courageto overcome them. Mobility for the next generation depends on the bold steps we take today." (p. 7) Just how bold is the Commission willing to be? The TRANSDEF Smart Growth Alternative is nothing if not bold.

In response to public outreach, MTC has gone far in putting forward the pro-regional policies cited above. "E-voters clearly were in the mood for change, as 89% agreed that the Bay Area should critically reexamine all its transportation policies, programs and projects." (p. 9) A critical question, given the exceptional agreement of the public input, is whether this RTP's pattern of transportation investments differs materially from past RTPs.

Unfortunately, the investments in the new RTP are all too consistent with past RTPs, with the following few exceptions: the setting aside of $200 million for regional bicycle/pedestrian projects, the setting aside of $216 million for Lifeline transportation, and the quasi-removal of the VTA BART extension from the Fiscally Constrained Plan.

The BART extension is still troubling, nonetheless. The so-called "construction reserve" has a large component of phantom TCRP and New Starts funding, which are extremely speculative because of the State budget deficit and the federal Not Recommended status. Because no prudent manager would consider these two funding sources to be reliable, they should definitely be reclassified as Vision Element. The Total project cost appears to lack bonding costs as well as recent project cost escalation. VTA has failed to demonstrate that it has the financial ability to build and operate its entire VTP 2030 Plan, even with a hypothetical additional half-cent sales tax (about which voters seem dubious). To avoid letting the credibility of the entire Plan be tainted by doubts about its largest single project, MTC needs to issue a special report showing that the fund sources for each of VTA's RTP projects balance with their realistic costs. Otherwise, MTC needs to delete the extension project entirely from the RTP.

The bullet point RTP goals on page 9 are excellent. Because they are mostly measurable, they are better goals than the formal six RTP goals adopted by the Commission. Unfortunately, the Draft RTP does not score as well on these goals as the TRANSDEF Smart Growth Alternative would.

"Among the projects considered were at least 40 projects proposed by members of the public..." (p. 38) Mentioning this fact for the second time, without an indication that any of the projects were actually accepted into the RTP, hints of window dressing. We support the idea of public submissions (and submitted a project ourselves), but note that the institutional structure makes it almost impossible for a publicly submitted project to actually be adopted.

"An area that deserves special scrutiny for the next long-range plan is how to use performance measures to evaluate projects before voters have endorsed a project and committed to funding it through a local sales tax measure." (p. 38) We strongly agree.

"MTC must consider the needs of all travelers in striving for an equitable distribution of mobility benefits. Whether the destination is work, school or the doctor, all Bay Area residents-regardless of income-must be able to get from place to place." (p. 52) Yes!

The "Seamless Transit Trip" section starting on page 60 was well thought-out.

"Our transportation system's ability to handle this growth depends on where these people will live and where the jobs will be located." (p. 64) MTC should attempt to move faster in the Smart Growth direction than Projections 2003. "These investments will be cost-effective only if sufficient numbers of people live and work near the new rail stations, bus stops and ferry terminals." (p. 64) We agree.

"Condition Transit Funds on Supportive Land Use. MTC will develop a new policy to ensure that the investment of regional discretionary dollars for major new transit projects will be matched by local land-use patterns, plans and policies supporting adequate housing and employment densities." (p. 65) We very strongly agree.

RTP Assertions we disagree with:
"electronic toll collection can make traffic-choked toll plazas just a distant memory..." (p. 1) MTC's own analysis of Bay Crossings shows continuing congestion at toll plazas in the future, despite implementation of electronic tolls. Higher tolls with HOV and transit incentives would reduce congestion.

The "carefully selected additions to the Bay Area transportation system." (p. 1) are, in our opinion, precisely the worst possible additions, due to their expense and the resulting increase in auto driving that would result. "These include extending BART to San Jose and Santa Clara; unclogging some of the region's most notorious highway bottlenecks (including the Cordelia Junction, Novato Narrows and Caldecott Tunnel);.. (p. 1) Nothing in MTC's modelling results indicates that there is any reality to the claim of 'unclogging bottlenecks.' Congestion (VHD) doubles! Bottlenecks will undoubtedly continue to affect drivers. In fact, by continuing to support the single occupant driver, the RTP encourages some of the very growth in VMT that prevents congestion from being eliminated. "...the congestion-busting potential of this road-pricing concept" (p. 1) is nothing more than irresponsible hype. MTC has a duty to the public to inculcate reasonable expectations. Talk of congestion-busting, while undoubtedly popular with the public, will inevitably result in poor policy decisions. The Environmental Impact Report process allows MTC to evaluate alternative strategies, including ones that may seem counter-intuitive, to see what can actually be accomplished about congestion.

"All these things are possible. But only with... plenty of additional dollars." (p.1) We believe this claim to be dubious, both as to the possibility of 'congestion-busting' and the possibility of raising the additional dollars. A more responsible approach would focus on optimizing the results possible with available funds (i.e., a constrained plan). Focusing instead on a 'wish list' plan lacks the intellectual rigor of being forced to do more with less. For this very reason, we disagree that the Plan is "coaxing maximum productivity from our existing system and endowing the greatest possible legacy for future generations. But additional installments-of both political and financial capital-will be required to fully realize the Transportation 2030 Vision." (p. 1) We do not see a vision in the Plan. The Plan fails to achieve a future more attractive than the present-the quality of life declines. Too much of the Plan is a collection of individual projects which do not add up to a coherent strategy.

The Strategic Expansion discussion on page 4 is unnecessarily argumentative, where it claims to be factual. The policy questions it hints at are not answered: Does "tinkering at the margins of the mainline freeway capacity that exists today" (p. 4) provide benefits commensurate with the high project costs ($3 or 4 billion is still a lot of money), or would it be more cost-effective and environmentally sensitive to shift to a demand reduction strategy, as tested successfully in the TRANSDEF Smart Growth Alternative? Can land development patterns be shifted so that it is cost-effective to provide transit service for all new residents to the region? This was also tested successfully in the TRANSDEF Alternative.

TRANSDEF is not enthusiastic about HOT lanes, because they are only a partial implementation of road pricing. The TRANSDEF Smart Growth Alternative tested the effect of parking cash-out on all employee parking in the region (a practical surrogate for universal road pricing), and found it was a helpful component of demand reduction.

We are doubtful that "As user charges, the regional gas fee and the HOT lane tolls have the potential not only to finance additional system supply but to influence demand for scarce roadway capacity." (p. 7) Because the regional gas fee would only be a small percentage hike, and because the HOT lanes would accommodate only a small percentage of overall demand, we think it unlikely that these will be effective in reducing demand. On the other hand, the TRANSDEF Smart Growth Alternative succeeded in reducing the growth in demand, which significantly helped its overall performance.

"While Projections 2003 does not achieve all of the Smart Growth Vision's numeric goals for directing new growth to already-developed areas..." (p. 32) In fact, it only achieves about half the basic Smart Growth goal of not increasing the in-commute to the Bay Area from the Central Valley.

"Efforts to attain the standards for particulate matter will be the subject of future air quality planning exercises." (p. 49) Planners already know that as VMT increases, particulate emissions from fugitive dust increase. Because particulates are the most harmful to human health of all air emissions, MTC is being irresponsible to its breathing public by not acting now to reduce the growth in Vehicle Miles Travelled.

We were shocked to see that, even after the outcry of the Welfare-to-Work Task Force, MTC still reprinted the discredited 4th bullet from the PPIC report on Transportation Spending: "Cost is unlikely to be a barrier to transit use for most low-income households but may be a barrier for some." (p. 54) At the very least, the quote should have had a footnote setting forth its controversial history.

The description of Lifeline program objectives on page 54 seems to not include the delivery of any actual transit service.

The I-880 Corridor improvements (p. 76) should include incentives for nighttime truck and warehouse operations rather than capital improvements.

The I-580 Corridor improvements (p. 76) should include inland rail, but not expand roadway capacity at the Altamont Pass.

"MTC directs a majority of the transportation funds under its control toward public transit projects, including significant expansion of the region's transit network." (p. 64) This is a factually inaccurate statement, if "under its control" is used in the commonsense meaning of "under its discretion." While MTC does direct a majority of funds that pass through it to public transit, roughly two-thirds of discretionary funds go to roads and highways. The fact that an extremely high percentage of transit funds are categorical, so that they cannot be spent on roads, creates the incorrect impression that MTC "directs" the largest part of its funding to transit. This is not so. See Declaration of Thomas Rubin, Bayview Advocates v. MTC.

Other Comments
The RTP is an attractive document, with excellent graphic design. It is highly readable, and does a competent job of articulating the complicated world of transportation policy, funding and law. Without being critical, we are curious as to the intent behind the selection of the scooter as the Plan's iconic image. While it is not obvious how a scooter relates to the mission of the Plan or MTC, at least it is affordable.

For the vertical scale on the Pavement Condition graph on page 40 to work properly, Failed should be at zero.

It would be good to include the transit operating shortfall and local streets and roads shortfall total figures in the Plan.

An additional Appendix page is needed that summarizes county totals for each of the three expenditure purposes. This would act as the detail page for the Draft Transportation 2030 Plan Expenditures pie chart on page 35.

Project 22436, the U.S. 101 Southbound Auxiliary lane from Lincoln to Mission was deleted from Marin County's submission at one point, because it scored extremely low. It seems to be a mistake that it is in the Plan.

TRANSDEF is pleased to acknowledge that MTC has come a long way. We have identified much in the Plan policies that we support. We hope that, as the Staff and Commission review the Alternatives and see just how well the TRANSDEF Alternative performed, that they will decide to incorporate many of the ideas contained therein. TRANSDEF stands ready to offer its assistance.


/s/ David Schonbrunn

David Schonbrunn,