16 Monte Cimas Avenue
Mill Valley, CA 94941


October 3, 2001

Hand Delivery

Sharon Brown, Chair
Metropolitan Transportation
101 Eighth Street
Oakland, CA 94607

Re: Draft 2001 Regional Transportation Plan

Dear Chair Brown:

MTC has produced a large number of reports for this RTP cycle, leaving the public with the inherent danger of missing the forest for the trees (and having had both cut down for paper production). We would like to use this opportunity to identify for policy makers the things that really stand out, that can serve as a basis for decision.

While MTC did an extensive hearing process for this RTP, the public input is not reflected in the final product. A close reading of the "RTP Responses" on pages 25 will disclose that MTC hasn't changed anything it was doing or thinking as a result of public input. While the RTP reports that the public "expressed a sense of urgency to address the [worsening transportation] situation" (pg. 26), nothing in the RTP self is responsive.

While the RTP proposes extensive areas of inquiry for "Investigation/Experimentation" nothing even vaguely experimental is proposed for funding in the RTP. The same comments have been made by the public at RTP hearings going back to 1994. If MTC wants to be seen as both responsive and innovative, it will have to actually adopt some of these programs.

TRANSDEF would like to see MTC study the feasibility of a "Gateway" strategy, wherein existing bottlenecks to auto driving that have parallel transit rights-ofway are evaluated to see if leaving the bottlenecks in place, while expanding transit service, can encourage a mode shift to transit, along with a shift in land use towards transit oriented development. The two projects most implicated by such a strategy are the MarinSonoma Narrows widening project and the Caldecott Tunnel 4th bore project. These projects should not be funded until they have been throroughly reviewed as suggested. We believe that the only way to improve congestion, mobility and air quality is to shift funding towards transit with the goal of changing land use. The experiment of funding more auto mobility has already been done all across America. The experiment failed. The Bay Area should be trying a different course.

The most significant finding in the RTP DEIR is the increasing trip length, indicating that the principal problem to be addressed in regional transportation planning is long distance auto commuting. The daily VMT is projected to increase 48.6%, while daily vehicle trips are projected to increase only 30.5%, indicating a significant increase in travel per trip. Not surprisingly, the huge increase in VMT is projected to cause a 152% increase in daily vehicle hours of delay. Were the RTP to strategically address the long distance commuting problem, it would be possible to reduce congestion, reduce emissions and reduce many of the cumulative impacts of sprawl development.

One striking finding of the DEIR is that implementing the proposed RTEP will have no impact on the average travel time per trip. (Table 2.1-7) "All differences in vehicle trips at the corridor level comparing Project B [no RTEP] to Project Alternative [with RTEP] are negligible (<0.3% in all corridors)." (Table 2.1-9) Amazingly, the Project Alternative 00, ROG and PM10 emissions are higher than the Project B emissions estimates. (Table 2.2-7) So much for the strategy of getting people out of their cars by building heavily capital intensive projects! Billions of dollars of expense will produce no measurable positive impacts. This indicates that further thinking needs to be done on promoting cost-effectiveness. Those billions of dollars, if spent cost-effectively, could produce measurable improvements in performance measures.

The RTEP proposes to give all the expansion money to projects for choice riders-those who could drive if they wanted to. None of this expansion money is going to new lifeline transit service for the transit dependent, a clear-cut violation of the Civil Rights Act. This is arrogance on an exceptional level, given the current scrutiny that MTC is under: a conditional MPO certification and the active investigation of multiple environmental justice complaints.

The RTEP has no criteria to prioritize the region's needs. A project level set of performance measures is needed, and is required by the CTC. An obvious hierarchy of criteria can be discerned, starting with the effectiveness of a project in creating a seamless regional network. The definition of such a network ought to be the prime task of a regional transportation planning agency. (Please note that this is a very different process than choosing between projects proposed by sponsors.) Project readiness and financial criteria come much lower down as important criteria. Cost per new rider should be a very highly rated criteria, if not the uppermost.

MTC should take the opportunity to evaluate how it did in implementing Res. 1876. Our understanding is that the past decade has been wasted on hugely expensive BART projects, while the region has sunk into gridlock. Had MTC taken a different direction back then, things might be dramatically different now. This is why alternatives analysis in the RTP EIR is so absolutely critical. In the absence of good creative ideas, mediocre ones have been allowed to parade as professional transportation planning.

In the spirit of completeness, several of MTC's recent initiatives have been very productive. The Performance Measures project has been very fruitful. Had the RTP had any feasible alternatives, the performance measures would have been a very helpful evaluation tool. Similarly, the Lifeline Transit appears to be a wellmeaning and properly focused element of an equitable transit funding program. Unfortunately, the program, or a placeholder, has not been proposed for funding in Track 1.

TRANSDEF continues to be very concerned that MTC, and its principal product, the RTP, fail to adequately value healthy air quality and a sustainable, liveable future. If it did, the RTP, and the process that surrounds it, would look very different. We look forward to the Commission demonstrating explicit consideration of public input, as required in Title 23 CFR §450.316(b)(1). Thank you for this opportunity to comment.


S/ David Schonbrunn,

Earthjustice LDF
Sierra Club, John Holtzclaw
Marc Chytilo, Esq.