16 Monte Cimas Avenue
Mill Valley, CA 94941

June 28, 2004
Hand Delivery

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

Re: Draft 2005 TIP and Air Quality Conformity Analysis

Dear Mr. Heminger:

TRANSDEF is dedicated to improving the planning of regional transportation, land use and air quality. We have actively participated in planning processes at your agency for the past 11 years. We are pleased to offer the following comments on the Draft 2005 TIP and Air Quality Conformity Analysis:

1. The Financial Constraint Analysis appears to erroneously contain FTA Section 5309 New Starts funds in 2006-07, despite the fact that no TIP funds are shown for the BART SFO extension in that year. This same analysis amusingly charts funds from the “Inter-regional Transpiration Improvement Program (ITIP)"

2. Spellings in the TIP Projects listings are unreliable. Examples like "Daughtery Rd Improvements, Houston Place to I-580" and "Marin: US 101/Greenbrea" fail to inspire confidence that an adequate attention to detail has been exerted, thereby putting into question the validity of the funding numbers and the dollar totals. If the spelling hasn't been proofread, there is no reason to trust the numbers either.

3. We object to MTC having allowed BART to not make the funding of seismic retrofit its highest priority. Instead of protecting life safety, BART proposed, and MTC acquiesced, to replace fare gates instead, to the tune of $110 million. In addition, the SFO extension consumed BART reserves and placed the system in deep debt. Both of these projects represent bad judgment. MTC needs to exercise its overall responsibility for the allocation of regional funds, especially where its grantees fail to be responsible themselves.

4. Instead of building a Richmond BART parking structure, it would be more beneficial to regional traffic congestion to use those same funds to operate express buses and park and ride lots to serve the public that would otherwise drive to the BART station. Frequent service to outlying areas, as determined by survey of BART riders, coupled with a lack of parking, would shift users to the transit mode and reduce growth in VMT, thereby producing twice the benefits.

5. The TIP entry for the BART Warm Springs Extension, ALA50015, impermissibly shows local sales tax money committed to construction in 2004-05 and 2005-06. This is not allowed by Measure B, which requires full funding of the San Jose extension before the release of construction funds. Clearly, that project has not been fully funded-even prior to admitting the cost of debt service and prior to the inevitable cost overruns. It has neither a TCRP allocation nor a FFGA. Is MTC proposing to have BATA release RM1 funds for construction of the extension prior to it being fully funded? If so, aren't those funds needed for cost overruns on bridge construction? Programming construction funds for the Warm Springs Extension is a serious mistake-it is throwing desperately needed money into a hole for a project with no independent utility. The region does not need to spend $790 million to provide rapid transit to vacant industrial land, especially where there isn't even a commitment to meet the regional Land Use Platform standards now in development. This entry is the most egregious in the entire TIP document.

6. The Assessment of VTA overall financial ability (last bullet on page 102) is ludicrous. It says "VTA has the financial capability to operate the existing level of service, as long as additional downward adjustments can be made in service levels or new revenue sources become available." In short, VTA does not have the financial capability to operate the existing level of service. The Assessment conclusion should state that, as the text at the bottom of page 101 actually did. The statement on page 102 about the sales tax being permanent is only partly correct. The tax passed in 2000 will sunset.

7. VTA has exhibited terrible judgment in borrowing money to fund the preliminary engineering for its ill-fated San Jose BART extension. The only justification for spending the money, other than the wounded pride of an agency unwilling to deal with reality, was the claim that it would be cheaper to do the engineering now and put it on the shelf for another ten or twenty years. This conclusion was possible only by ignoring the cost of debt service. By authorizing this expenditure by putting it in the TIP, MTC is abetting VTA in going forward with this irresponsible scheme. MTC thus accelerates the day when it will have to step in to save the passengers that depend on an agency dedicated to its own bankruptcy.

8. Please provide further detail as to the design for the Vasco Road Safety Improvements, ALAO30002. The project description is unclear as to whether the safety improvements are being designed in such a manner as to serve as the first phase of an eventual growth-inducing road widening project. While we support safety improvements, we would object vigorously if this project were, in fact, a Trojan horse for a future widening project.

9. The I-205 Widening from I-580 to San Joaquin County line, ALA978028, is a project with serious interregional impacts. What regional concerns went into the project's approval? Is this a widening of the gateway into the Bay Area? Is it part of a plan to create a bottleneck that in turn creates the political demand for further widening? It is unclear from the project description whether the project is within Alameda or San Joaquin counties. Please clarify why San Joaquin would be funding a project outside its boundaries. While MTC has begun discussion of issues by joining in an lnterregional Partnership, the documents of that Partnership have been impossible to obtain. TRANSDEF called and requested to be placed on its mailing list, but never received any mail. All documents produced by the Partnership need to be made available on MTC's website. In addition, the Planning and Operations Committee needs to agendize a policy discussion about managing the gateways to the region. In the absence of firm policy, the likely outcome of the status quo will be creeping widening, as is apparently represented by this project. Any gains made by MTC on the congestion problems of the region stand to be reversed by growing traffic entering the region as a consequence of the absence of a firm MTC interregional policy. The Mid-State Tollway Policy is still the gold standard of a successful MTC policy. Further work is needed to live up to that standard.

10. TRANSDEF is still unaware of a viable explanation of why the adjustment to ARB's Bay Area VMT that comes from MTC's travel demand model results in speeds that are meaningful in the generation of an air emissions analysis. The Draft Transportation Air Quality Conformity Analysis states that "New speed distributions ... were applied to passenger cars..." but fails to explain where these distributions come from. Because the VMT adjustments result in higher volumes of vehicles using the same constrained roadways as the lower volumes predicted by MTC's model, it continues to boggle the mind as to why the average speeds should be assumed to be the same as those produced by the model, and why those speeds would produce motor vehicle emissions numbers that are in any way meaningful. The problem here is the ongoing discrepancy between MTC's prediction of VMT and ARB/BAR's method. There needs to be resolution.

TRANSDEF appreciates this opportunity to provide comments on the Draft 2005 TIP and Transportation Air Quality Conformity Analysis.


David Schonbrunn