16 Monte Cimas Avenue Mill Valley, CA 94941


June 6, 2001

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

Re: 2001 RTP Equity Analysis

Dear Chair Brown:

Our organization has been active throughout the Environmental Justice Equity Analysis process, starting with our September 2000 request to Steve Heminger to immediately convene a working group. That group finally started working months later, under heavy timeline pressure that was completely avoidable. We offer these comments to highlight the still-existing fundamental disagreement as to the purpose of an equity analysis.

Although we will primarily point out shortcomings here, we want you to know that we strongly support the following Areas of Progress identified in the staff report: the development of a lifeline transit network, the upcoming affordability study and community transportation plan studies, the first financial support for community organizations willing to assist in RTP outreach (and an ongoing refusal to provide income replacement for low income people involved in transportation planning), the development of an EJ component for project submission forms, and increasing support for TLC and HIP programs. We appreciate this movement in the direction of equity.

During the work of the EJAG so far, there still is no agreement as to the purpose of the equity analysis. Rather than allowing enough time to get clear on this, staff has pushed the process relentlessly forward, without ever saying what equity looks like. As you might imagine, this lack of clarity hurts the development of a meaningful analysis.

TRANSDEF fundamentally disagrees with staff's assertion that RTP equity is about changes in access. In 1998, MTC staff created an analytic method that supposedly would identify disproportionate changes in accessibility between various RTP alternatives. This method, which was strongly pushed on us again this year, has two critical flaws: First, MTC's past practice has been to make RTP alternatives so similar as to eliminate any significant differences in impacts. Thus, the analysis is unlikely to show anything that would aid a decisionmaker in setting policy.

Second, the method confuses access with equity. TRANSDEF believes that equity is relatively simple: it is a fair share of the monetary benefits of the RTP. The cost of providing transit access is an inverse function of land use density. It costs more per capita to provide transit in the suburbs than in the cities, because people are more spread out, and they use their cars more. Equal access would mean that the cities get shortchanged. We believe that MTC has historically subsidized the suburbs at great cost to the cities, and that a fair share allocation would produce cheaper, more convenient transit service in the cities (and a more expensive suburban commute). We believe that the purpose of an equity analysis is to investigate this question. Unfortunately, we have never been able to engage staff or Commission in this serious issue.

Another example: The proposed Lifeline Transit System mapping work is important and useful, but its relevance to an equity analysis is limited. This mapping will result in the definition of a transit system benefitting low income and minority communities. However, the question still remain as to what level of regional funding to operate such a network these communities deserve as their fair share of the RTP. Nothing in the package proposed by staff will produce answers in time for this RTP.

A Counter Proposal
TRANSDEF suggests that, given the absence of a ringing endorsement of the proposed equity analysis by EJAG, MTC offer the following option to the EJAG: Eliminate the travel demand model-based accessibility study from the equity analysis, and replace it with a thorough accounting of MTC's past project funding decisions.

This idea arose after receiving MTC's Annual Report in the mail. We appreciate your sending it to us and inspiring the following thoughts. The staff report on the EJAG cites a number of extraordinarily high percentages of total transportation funds allocated by MTC to transit. MTC has publicized this kind of data in the past to stress its commitment to transit. The percentages have risen from 53% to 62% to "nearly two-thirds" and have now reached 82%. Since 1994, we have been dubious of these representations, noting, for example, the completely inappropriate presence of transit farebox revenues in the funding MTC claims to dedicate to transit. We appreciate the willingness expressed in the EJAG staff report to develop RTP statistics that more closely represent MTC's actual allocation of funds under its discretion. This is helpful.

Along these lines, we request a further commitment to transparency. In the Annual Report, there is an extended breakdown of formula funds for transit (pp. 22-23 in the 2000 report). However, there is no corresponding breakdown of programming and allocations-one that would be useful in verifying MTC's commitments by mode. We would like to see at least the same annually aggregated information that previously had been presented in Transactions. The report should identify funding sources, including separate columns for STP, CMAQ, 5307, 5309 and the entire AB 1107 proceeds, as well as listing annual unlinked ridership statistics by operator.

Similar to the request of the Transportation Equity Network in DOT's rulemaking last year, we would like MTC to publish an annual report of its funding decisions. A report of the concrete decisions made in the past year would strongly complement the equity analysis for the RTP cycle, which is always somewhat theoretical. We request a comprehensive annual listing of funded projects, sorted by recipient, in response to the TEA-21 requirement that Metropolitan Planning Organizations make available to the public an annual listing of projects for which federal funds have been spent in the previous year. (Because our interest is in reviewing the actual funding decisions of the Commission, identifying projects at the point at which they have reached the expenditure stage would add an unnecessary complication.) If other EJAG members agree, the time saved running the travel demand model could be better put to use producing project funding reports for the years 1998-2000. That would provide useful information about the Commission's actual decisions. When that information becomes available, discussions of equity can be grounded in reality.

TRANSDEF appreciates this opportunity to express these thoughts to the Commission.


S/David Schonbrunn,

cc: FHWA
Earthjustice LDF
Sierra Club
Marc Chytilo, Esq.