TRANSPORTATION SOLUTIONS DEFENSE AND EDUCATION FUND
16 Monte Cimas Avenue Mill Valley, CA 94941 415-380-8600
March 8, 2004
Senior Transportation Planner
Contra Costa Transportation Authority
3478 Buskirk Avenue,
Pleasant Hill CA 94523
Re: 2004 CTP Update DEIR
Dear Mr. Beck:
TRANSDEF is a Bay Area non-profit advocating for improved regional planning for transportation, land use and air quality. While we ordinarily focus on planning at the regional level, several of our colleagues requested that we review the DEIR for the 2004 Update to the Countywide Comprehensive Transportation Plan, out of doubt about its technical reliability. We are disappointed to report that this document is status quo planning which will result, absent intervention, in the commitment of extensive resources to an undesirable future of gridlock and congestion. Rather than take up the challenge of planning for a more desirable future, the DEIR remains stuck in the narrow confines of traditional transportation thinking. Given the projections of extreme congestion for even the Preferred Alternative, the absence of a focus on the linkage of transportation and land use is unacceptable. We present our specific comments below.
Linking Land Use to Transportation
The usefulness and credibility of the DEIR are seriously compromised by a series of decisions affecting the linkage of transportation and land use:
1. The modelling was based on a fixed 2025 land use, so that the distribution of transportation funding in each of the alternatives had no effect on location and development decisions of 2025 residents. A massive investment in transit has little effect on ridership, due to development being assumed to following now-obsolete auto-oriented county development trends. More sophisticated modelling would be interactive between transportation and land use.
2. The planning process made no use of the County's million-dollar plus investment in Shaping Our Future. Given the current heightened recognition of the importance of land use in solving transportation problems and the utterly unsatisfactory performance of even the Preferred Alternative, it is unconscionable to not study one or more Smart Growth alternatives.
3. The failure of any of the 2025 alternatives to perform tolerably as transportation raises the bar for mitigation. Whether as TCMs to mitigate the rate of increase in VMT over the rate of population growth, to mitigate unacceptable levels of congestion, to mitigate the cumulative impacts of suburban growth, or for some other rationale, the DEIR needs to explore a variety of means to improve 2025 conditions.
4. TRANSDEF believes that conditioning local receipt of regional and state funds on compliance with a series of measures is the most obvious method of make local jurisdictions responsible for minimizing the impact of their development decisions on neighboring jurisdictions. This approach is being studied by ABAG and MTC as part of the implementation of the Regional Agencies Smart Growth process.
5. Another possible mitigation would be the imposition of a regional transportation impact mitigation fee. This would mitigate impacts beyond the earlier Measure C fees, and would apply to trips leaving local jurisdictions for points within Contra Costa, as well as outside the county. The fee would be based on auto trips generated, and would be waived for any project adjacent to frequent (15 minute peak headway) transit. Such a fee would help level the playing field between infill and greenfield development.
Transit System Effectiveness
Something is very wrong in the assumptions about transit expansion for Alternatives B and C. Mode share outputs are unreasonable. Despite the expenditure of vast sums of money for transit, little change occurs in ridership compared to the No Project Alternative. Because the highway mode will be very unpleasant to use, with high levels of congestion, a well-designed transit system on separate rights-ofway, HOV lanes or transit priority lanes should have significant travel time advantages. The fact that the mode share outputs fail to reflect this commonsense conclusion indicates that the transit system coded into the model must be inferior to contemporary professional practice. In responding to this comment, please provide the following:
1. Travel times for transit and SOV travel for representative O/D pairs.
2. Identify the design elements incorporated into the transit network to enhance ridership.
3. Explain how, despite the diversion of 15,700 VMT/day for transit riders away from Non-Transit Activity, it is reasonable that the model predicted that Non-Transit Activity actually increased by 2000 VMT/day. (Table 2.2-11)
When modelling an alternative with substantial increases in transit service, in order to be credible, current best practices must be incorporated. This has apparently not occurred in this DEIR. Elements that need to be included, at a minimum, are: Bus Rapid Transit, bus priority lanes, traffic signal priority, proof-of payment, and extensive bus pass distribution systems.
It is disturbing to see the Highway Lobby's oldest canard repeated yet again here: 'Widening the highway will relieve congestion.' Only, this time, the message is even more egregious: 'Widening the highway is good for you and for the environment.' Through bogus air emissions modelling, discussed below, EIR preparers have the gall to conclude that auto-oriented Alternative A is environmentally superior to the other alternatives.
This conclusion is based on assumptions that lead the model to predict higher average travel speeds for Alternative A. Obviously, no one there ever heard of induced demand. Contemporary thought is that adding road capacity encourages a further dependence on the auto, both for existing residents, and for those making decisions to locate jobs and housing there in the future. This results in the increased capacity being 'used up' quickly, resulting in even higher future levels of congestion. Something is very wrong with a model that predicts new road capacity to still be available 25 years later.
TRANSDEF challenges the model's conclusions that added road capacity will yield higher 2025 average travel speeds. We laugh at the conclusion that Alternative A will have lower ozone precursor emissions than the other Build Alternatives. Besides our general disbelief, we also question whether the tiny quantitative differences in air emissions between the alternatives have any meaning for purposes of selecting an alternative. We doubt the differences are quantitatively significant, given the uncertainties in the model itself and grave doubt in its assumptions.
Air Quality Criteria of Significance
The Criteria of Significance for air quality impacts were selected arbitrarily, bearing no resemblance to the criteria identified in the BAAQMD CEQA Guidelines. They were made up of whole cloth, apparently by the EIR preparers, perhaps so as to create a distinction between the impacts of Alternative A and the other alternatives.
DEIR Criterion 1, local violations of air quality standards, is not a recognized criterion. Studies on diesel off-road equipment indicate that construction is a highly polluting activity, emitting carcinogenic and asthma-exacerbating particles. Following the suit by Sacramento Municipal Air Quality Management District against Caltrans (which followed the publication of the BAAQMD CEQA Guidelines), it is now recognized that best practices for public agency construction contracts require the provision of equipment meeting the most current CARB diesel standards.
BAAQMD CEQA Guidelines require that a plan such as the CTP Update demonstrate consistency with the adopted Clean Air Plan. "Plans showing a VMT growth rate higher than the population growth rate would be considered to be hindering progress towards achieving this performance objective [due to absence of adequate TCMs], and thus inconsistent with regional air quality planning. This would represent a significant air quality impact." (p. 22) The DEIR instead uses a bogus '5% increase over No Project' criterion, which has no foundation in science or law. Because the Bay Area is a Non Attainment area for ozone under the one-hour and eight-hour federal standards and the state standard, any increase in ozone precursors is a matter for concern.
The criteria for significant impacts on Environmental Justice captured the potential harmful impacts, but failed to state Criterion 3: A significant impact will occur if the project as a whole will result in disproportionately fewer benefits to minority or low income neighborhoods. Not only should this criterion be added, potential impacts should be evaluated.
Environmentally Superior Alternative
The analysis of the Environmentally Superior Alternative suffers from the garbage-in/garbage-out syndrome. As demonstrated above, the Impact Significance conclusions on transportation, air quality and energy impacts are unsupportable and counterintuitive. At best, Table 2.1-5 documents only an 8% difference between alternatives in hours of delay/day. Given the dubiousness of the model outputs, a difference of this magnitude is not an adequate basis on which to make decisions. In fact, even using the questionable data, Alternative C has the greatest beneficial impact on freeway delay of all the alternatives! On the other hand, the conclusion that Alternative C would have the least land use impacts is robust and convincing. Less agricultural lands would be converted to suburban development under Alternative C. TRANSDEF strongly urges the CCTA to identify Alternative C as the Environmentally Superior Alternative.
TRANSDEF believes that the DEIR looks at the issue of growth inducement backwards. Rather than look at consistency with local plans, which fail to take regional and subregional impacts into consideration, this DEIR is the appropriate place to look, first, at the consequences of growth, and then, at the management of growth. It is only at the regional or sub-regional level that potentially effective responses to a predicted future of congestion and gridlock can be formulated. Not only do we disagree that "Second, due to existing congestion, transportation plays a minimal role in attracting or inducing new development for the county as a whole," we are convinced that active intervention through the programming of transportation funds as part of a comprehensive Smart Growth program could act as a lever to shift development trends in the direction of a more benign pattern of development and make the future a more attractive place to live.
Thank you for this opportunity to comment on the DEIR for the 2004 Update to the Contra Costa Countywide Comprehensive Transportation Plan.
/s/ David Schonbrunn