The Regional Alliance For Transit submitted two comment letters on the proposed Regional Transportation Plan. The one in March was sent before MTC decided to delay the RTP’s adoption, due, in part, to changed financial circumstances. The letter sent in April is a supplement to the March letter.


2 March 2009

Steve Hemminger
Metropolitan Transportation Commission
101 Eighth Street
Oakland, California 94607

Re: Comments on the proposed 2009 Regional Transportation Plan

To Whom It May Concern:

The Regional Alliance For Transit, RAFT, submits the following comments:

The revenue data (both operating and capital) for transit operators as assumed and presented in the Draft RTP is no longer valid and may be seriously unrealistic - at a minimum, it does not take into consideration the State budget action regarding State Transit  Assistance funding, the federal ARRA, changes in property tax revenues, or serious declines in sales tax revenues such as were  officially revealed to the VTA Board only last Friday. The current  document cannot be considered “financially constrained” in light of  this significant information.  Will the draft RTP be updated to  reflect financial realities - and more importantly, what opportunities  will be available to the public to comment on such changes before the  RTP is adopted?

Equity is one of the RTP’s three stated goals, supposedly co-equal with the others, yet there is little to show for actually achieving  this objective over the next quarter of a century, which affects  numerous - and increasing - numbers of low-income and minority  residents.  On at least three metrics, the “Project” fails to advance  the goal of Equity as it relates to impacts on residents of  “Communities of Concern” (CoCs):

A. Non-work trips, which are acknowledged as the great majority of trips taken for the region, are shown as a benefit to CoCs.  However,  for transit use, which is the sole option for many low-income and minority households, while both CoCs and non-CoCs show benefits, the  latter are significantly more improved by the “Project” (13.4%  compared to 8.9%). How is this Equity, especially considering that  CoCs start from a disadvantaged position?

B. Emissions under the Project more seriously burden CoCs than non-CoCs. Can nothing be done in this case?

C. “Affordability” is identified as “Either” for the Project. Again, given that CoCs start from a position of disadvantage, how does this move to enhance Equity?

The proposal from MTC’s own Minority Citizens Advisory Committee (MCAC) to provide more frequent and reportable “Snapshot” updates of  the Equity situation is an important one which should be promptly  adopted as MTC policy. As one example, how can the RTP include the  very costly extension of BART to Santa Clara County at the same time that VTA, the sponsor, is proposing to cut its local existing bus and  light rail service, on which so many minority and low-income riders depend?

MTC staff’s response to Attorney General Brown regarding AB-32 implementation and Greenhouse Gas reduction needs more action, rather than soothing words. The staff action to remove HOT-lane freeway expansions from the ARRA package last week was a useful first step.   However, at the February 25th MTC meeting, several Commissioners  expressed concern about how to make transit operating funds more  sustainable. What will MTC, through the 2009 RTP and other advocacy  efforts, do to advance this critical objective?

Thank you for the opportunity to comment on your agency’s proposed Regional Transportation Plan.


John Holtzclaw


April 8, 2009

Metropolitan Transportation Commission
101 Eighth Street
Oakland 94602

via email

Re: comments on new information regarding the proposed RTP

To Mr Kimsey, Director, RTP Preparation:

Thank you for the opportunity to provide you with additional comments and questions on your proposed Regional Transportation Plan (“RTP”). In this new political era that emphasizes transparency and accountability, the Regional Alliance For Transit (“RAFT”) would appreciate a substantive response to each of our questions or comments below.

Our understanding at RAFT is that the RTP must be balanced financially (“fiscally constrained”). The new information shows, for transit operators, a shortfall for capital rehabilitation and replacement of over $17 billion and for operations, a shortfall of over $8 billion. The total is over $25 billion, or an average of more than $1 billion per year over the twenty five year plan. How can the RTP be considered fiscally constrained? Are there actual plans for closing the financial gaps? Should not the MTC provide a description of what transit service will be provided by each operator for each year over the planning period and what expenses or revenues must be changed to attain financial sustainability?

AB 32 and SB 375 call for reductions in greenhouse gas emissions. RAFT believes the MTC should show how the transit capital and operating shortfalls will affect progress towards meeting the legislatively required goals. RAFT requests that MTC provide such information, and if the goals will not be met, please explain why not.

Since the passage of ISTEA in 1991, the MTC has heard from members of the public from time to time that costly transit expansion projects (generally, the high cost and low performance BART extensions) are making it ever harder to maintain the existing transit system. MTC is now in agreement (“T-2035 confirms that the current transit system is not sustainable for many operators.”). How much money has been spent on constructing and operating transit service on the BART extensions, from the passage of Resolution 1876 to the present? How much will it cost to maintain these same extensions over the life of the proposed RTP? If these BART extensions had not been built, with maintenance money freed up for use elsewhere, would other transit systems have had a better outcome than “not sustainable”? How much did these BART extensions add to BART’s capital shortfall? It should be noted that providing $70 million in §5307 funds for the BART Oakland Airport Connector project seems imprudent and inefficient, making less money available to existing transit service and an increase of the future burden of maintenance.

In 1993, MTC noted in a letter sent to several members of BART’s board of directors that the MTC–sponsored arrangement whereby most of the AB 1107 funds go to BART, but with most local funds going to the Municipal Railway and AC Transit, had been advantageous to BART and disadvantageous to the other two systems (copy attached). Is the MTC going to take action to provide additional funds to the Muni and to AC Transit, which have a combined operating deficit in the plan of over $2 billion? BART does not have a forecasted operating shortfall in the plan. BART’s outstanding debt that is secured by the AB 1107 funds amounts to $748 million, according to the most recent annual report. Thus, BART has no operating deficit, even after the interest expense is taken into account. This means BART is not subject to the same treatment other operators face with MTC’s Transit Capital Priorities Process.

In terms of capital rehabilitation and replacement, of the $6 billion in “discretionary” funds available to MTC, BART will receive 42% of the total for the entire Bay Area. The Municipal Railway, which carries many more passengers, will receive less money than BART. AC Transit will receive 9% of what BART is to receive, yet AC Transit carries far more passengers than 9% of what BART carries. Does MTC value a passenger trip on the Municipal Railway and AC Transit as equal to that of a passenger trip on BART? Please explain why the subsidies and commitments differ so much for the Municipal Railway and AC Transit compared with BART. In the 1993 letter noted above, MTC advised BART that “this total far exceeds MTC’s commitments to any other agency and represents almost 50% of MTC’s total discretionary allocation authority for capital purposes in the region.” Is there a long–standing MTC policy that requires BART receive nearly 50% of discretionary capital funds in the Bay Area? If not, please provide information as to why BART consistently and over many years receives the lion’s share of MTC’s discretionary funds.

The VTA has the largest operating shortfall of any Bay Area operator ($3.2 billion), yet it is to build the most expensive transit project in the RTP (BART to San Jose). Is there any reason to believe that residents who lose bus service over the planning period will find the BART project to be an affordable substitute? RAFT requests that the MTC provide information about the household incomes and ethnicity of bus passengers who will lose service and the household incomes and ethnicity of residents who will gain transit service with the proposed BART extension. If the MTC is concerned about sustainability, should not the BART to San Jose extension be stricken from the RTP?

In the March 25th slide show (“T2035 Financial Revisions”) Recommendation 1 includes a $1 billion revenue item entitled “Santa Clara VTA Joint Development Revenue.” The idea sounds good. Has MTC been able to identify any transit joint development revenue source in California that actually produces a similar figure? If so, it would be helpful to know more about it. RAFT does not want the VTA to count on $1 billion if there is not a significant likelihood of success.

Also in the slide show is a page on discount fare policies—“Addressing Transit Sustainability, Can we continue to afford to accommodate inconsistent service policies when simple policy agreements are possible (e.g., discount fare eligibility)?” RAFT is uncertain as to how much money would be raised if all operators had a similar discount for each type of passenger. RAFT requests that MTC provide this information and the basis for the statement that the policy agreements are “simple.”

One of our members recently noted that the MTC has a map showing the streets, ferry routes and railroads that make up the Metropolitan Transportation System, but that there does not appear to be a map showing the important bus lines in the Bay Area. His suggestion, for your consideration, is to produce a map showing each bus line having a 15 minute headway, or better. Fifteen minutes is the generally accepted headway that separates transit that people will use if they have a choice from the form of transit that only people with no choice have to use. If a goal of the Bay Area is to have a first class bus network, when will the MTC produce a map such as what is described here?

Consider the transit system CCCTA, in central Contra Costa County. It has just one line running on a fifteen minute headway (the free shuttle in downtown Walnut Creek). In the 2005 alternative RTP submitted by Transdef, there were several rapid bus lines created in the CCCTA service area. One of them, for example, included service from Concord’s BART station to Walnut Creek’s BART station, via Pleasant Hill’s BART station. The existing service of CCCTA, line 15, operates on a 60 minute headway. Or consider the very large commercial development in San Ramon. The 2005 alternative had a rapid bus line from the Crow Canyon area to Dublin’s BART station. The existing bus service, line 36, today operates on a 60 minute headway. Or consider AC Transit line 99 (Mission Boulevard) with trip generators at BayFair’s BART station, Hayward’s BART station, South Hayward’s BART station, Fremont’s BART station and a transfer connection with the bus line serving California State University East Bay. The headway is 30 minutes. If a goal of the MTC is to increase transit ridership and meet the requirements of AB 32 and SB 375, would it not be helpful to consider cost effective improvements in transit service on bus lines such as these three as well as others?

Thank you again for the opportunity to comment on the proposed Regional Transportation Plan. RAFT members look forward to your responses.


M. Williams

for RAFT