Return to list of letters Letter Date 2007-02-09 Recipient Jeremy Ketchum, Environmental Branch Chief, Caltrans Subject Sac 50 Bus/Carpool Lanes DEIR/EA Jeremy Ketchum, Environmental Branch Chief Attention: Ken Lastufka Dept. of Transportation, Environmental Planning 2389 Gateway Oaks Drive, Suite 100 Sacramento, CA 95833 Sac 50 Bus/Carpool Lanes and Community Enhancement Project Draft Environmental Impact Report/Environmental Assessment (DEIR/EA) Dear Mr. Lastufka, Thank you for the opportunity to comment on the DEIR/EA. This project would further unbalance an already unbalanced transportation system. There is overwhelming agreement among transportation experts that too many trips are made by automobile now. Many of the environmental, economic, energy, health, safety and other consequences of those automobile trips are clearly undesirable. A transportation system focused on travel by automobile is ultimately unsustainable because of its enormous energy needs and the impacts on the environment, including the threat of catastrophic global climate change. The Hwy 50 carpool lane project adds capacity to the transportation system for automobiles, assuring that more and longer trips will be made by automobile for decades to come. How this project affects bicyclists. Widening Hwy 50 will affect bicyclists in three ways. It will encourage longer trips and more suburban trips. These are trips less likely to be made by bike. It will use scarce transportation funds that could be spent on bicycle projects and other projects that do less damage to air quality and the environment. It will increase motor vehicle traffic and create safety problems for bicyclists, especially at interchanges. The safety problems will discourage bicycle use. Carpool formation A key project parameter should be how many carpools are formed. But it appears the project doesn't rely on an increased number of carpools to reduce congestion. Congestion will be reduced, at least temporarily, but the reduction will result not from the formation of new carpools but because of the increased number of lanes. What is likely to happen is that existing "carpools," which typically are carpools of convenience such as spouses sharing a ride or parents taking children to school, will switch from mixed-flow lanes to the HOV lanes. That will free up capacity in the mixed flow lanes making them less congested. With less congestion in the mixed flow lanes the time saving incentive that HOV lanes might offer will be reduced. Most single occupant vehicle drivers won't bother trying to form a non-familial carpool unless their time savings are great enough to compensate for the inconvenience of carpooling. Since one of the stated project goals is to provide incentives for commuters to use carpools, vanpools or buses for peak period travel, we believe the project should include an evaluation component to see if it effective in doing so. In addition, the DEIR evaluation of project alternatives should include an analysis of the likely impacts on carpool formation. It would be useful if the DEIR did the same analysis for the "take a lane" alternative which was eliminated based on performance. Purpose and Need The DEIR/EA asserts that adding HOV lanes will reduce “accidents.” There is evidence that the speed differential between HOV lanes and mixed flow lanes increase the number of crashes. A Texas Transportation Institute study suggests that High Occupancy Vehicle (HOV) or carpool lanes that are not separated from regular lanes with a physical barrier experience a 41-56 percent increase in injury crashes. This is a significant impact to the human environment. What impact could be more important to the human environment than crashes causing injury to the human body or than the taking of human life? Adding HOV lanes will likely increase average vehicle speeds and weaving maneuvers by motorists across more lanes. These changes could increase the severity of crashes, making them more dangerous than the lower-speed rear-end collisions that the DEIR/EA indicates are typical today. The DEIR/EA should more fully analyze the impacts on safety as part of the impacts on the human environment. Range of Alternatives The DEIR/EA does not include a reasonable range of alternatives. Evaluations were made on two build alternatives and a no build alternative. A number of other alternatives were considered but eliminated because of technical issues, costs and other considerations including public controversy. None of these other alternatives were evaluated in the DEIR/EA; therefore it is not possible to determine whether they were environmentally superior. Alternatives not evaluated include adding auxiliary lanes only, Bus Rapid Transit only, High Occupancy Toll (HOT) lanes, taking an existing lane for HOV use. Not a single non-freeway oriented alternative was evaluated. No alternative that viewed the transportation system as an integrated whole was evaluated. The “range” of alternatives evaluated varied insubstantially, essentially differing only in where the project HOV lanes would start and end. One of the reasons that toll or HOT lanes were removed from consideration was that “Projected congestion in the US 50 corridor through 2030 will not be great enough to generate toll rates and revenues necessary to generate a positive cost/benefit ratio.” Yet the project purpose is to deal with what is described as a “heavily congested” US Hwy 50 along with future congestion that is projected to increase significantly in duration and severity. The DEIR/EA should explain this apparent inconsistency between too much congestion to tolerate and an inability for that intolerable congestion to be bad enough to institute a workable pricing mechanism. (We note that the President’s proposed budget includes funding for congestion based pricing systems.) It is clear a larger range of reasonable alternatives exists. For example, “A Comparison of Highway and Travel Demand Management Alternatives Using an Integrated Land Use and Transportation Model in the Sacramento Region,” by Caroline J. Roder, John E. Abraham and Robert A. Johnston (Transportation Research Board meeting, January, 2002) concludes that there are alternatives that would be environmentally superior as well as superior in reducing congestion. The study abstract says, “…transit investment with supportive land use polices or pricing policies may be very effective in reducing VMT and emissions. Fourth, transit investment with supportive land use or pricing policies may provide congestion reduction that is as great, if not greater, than highway investment policies.” The DEIR/EA should evaluate a reasonable range of alternatives that meet most or all project goals. These alternatives should include alternatives that take a system-wide approach to transportation. Project segmentation The DEIR/EA improperly attempts to segment the project. The two project alternatives evaluated have the HOV lanes stop short of reaching the downtown area. This is inconsistent with the project description in Section 1.2 which says the DEIR/EA pertains to the “US 50 Bus/Carpool Lanes Project from downtown Sacramento to Sunrise Boulevard.” In addition, news reports (Sacramento Bee, January Backseat Driver) and discussion with Caltrans officials at their Open House January 10, 2007 indicate that Caltrans plans for the HOV lanes eventually to reach downtown. The DEIR/EA should evaluate impacts of a Hwy 50 carpool lane project that ends downtown. Environmental Impacts Not Evaluated Greenhouse Gas Emissions The DEIR/EA does not address the significant impacts of greenhouse gas emissions. In a March 2006 letter, the California Attorney General criticized the Orange County Transportation Agency (OCTA) for not analyzing greenhouse gas emission in the EIR for the county’s long-range transportation plan. As a result, OCTA reached an agreement with the Attorney General’s office to take additional steps regarding greenhouse gases. Since then, California has taken further action to regulate greenhouse gases, passing into law AB 32, the Global Warming Solutions Act. This law and the legislative record leading to its passage clearly demonstrate the importance placed on the issue of global warming by the governor and legislature. The recent report by the International Panel on Climate Change is conclusive that climate change is occurring and very likely caused by human activity. Estimates in California are that 41 percent of greenhouse gases come from the transportation sector. The DEIR/EA should evaluate impacts of greenhouse gas emissions. Air Quality The DEIR/EA does not address the significant impacts of very fine and ultrafine particulates and other possible pollutants that increase health risks within one mile of high volume traffic corridors. Studies in the Sacramento area and southern California have identified the geographic extent of the impact and the health risks. (See Sacramento Bee article, “Living near busy roads tied to kids' lung risk, Impact on breathing is long-term health threat, study says” January 26, 2007.) Children breathing the polluted air are at increased risk of lung and heart disease. As noted in section 2.4.1.1.of the DEIR/EA, 14 schools are within the study area, including 5 within 1,000 feet. In addition, there are parks, libraries, residences and commercial buildings adjacent to Hwy 50 in what is a highly developed urban/suburban corridor. The California Air Resources Board requires Health Risk Assessments when new land uses are planned near high volume roadways. There are impacts when new land uses come to roads. There are also impacts when in effect, as for this project, roads come to land uses. The same Health Risk Assessments should be made when new freeway lanes and greater capacity/vehicle emissions are added near existing land uses, especially when the land is occupied by sensitive receptors. The DEIR/EA should fully evaluate impacts of particulate and toxic air pollution in the corridor. If this project goes forward despite the impacts, it should include the planting of the most appropriate tree species along Hwy 50 to mitigate the distribution of air pollution caused by Hwy 50 traffic. Traffic circulation on local streets The DEIR/EA does not address the traffic circulation impacts on local streets. The project is designed to increase Hwy 50 capacity and the DEIR/EA acknowledges that Hwy 50 traffic volume will increase because of the project. Yet there is no assessment of the environmental impacts, such as traffic circulation, noise, and air quality on the surface streets that must carry the increased traffic volume to and from the freeway. Parking In addition to traveling on local streets, the increased traffic resulting from the project will eventually need to park. There is no assessment in the DEIR/EA of the land use ramifications of this additional parking, the aesthetic impacts of the parking or what increase there might be in impervious surfaces. Since roads and parking can consume 30 percent or more of the surface area, this may be a significant impact. The DEIR/EA should analyze impacts of additional traffic and parking requirements. Growth inducement On page 46 of the DEIR/EA a statement says “None of the available data suggest that not building the proposed project would prevent or reduce the level or type of development outlined in local planning documents. This statement is incorrect. “A Comparison of Highway and Travel Demand Management Alternatives Using an Integrated Land Use and Transportation Model in the Sacramento Region,” by Caroline J. Roder, John E. Abraham and Robert A. Johnston concludes that “transportation investment in both highway and light rail may allow for greater decentralization of regional development.” In addition, no specific data or study is necessary to conclude that while transportation may follow land use, that it is equally true that land use follows transportation. The DEIR/EA should reassess the growth inducing impacts of the project. Section 2.12.2.2 and Section 2.14 The DEIR/EA claims the build alternatives for the project will not increase vehicle miles traveled and that energy demand would be reduced by the project. However, the study previously cited, “A Comparison of Highway and Travel Demand Management Alternatives Using an Integrated Land Use and Transportation Model in the Sacramento Region,” by Caroline J. Roder, John E. Abraham and Robert A. Johnston concludes that “new highway capacity projects, even if they include HOV lanes, may increase VMT and emissions. The DEIR/EA itself notes that “…addition of transportation infrastructure may induce growth by allowing access to previously inaccessible areas.” Adding capacity to the freeway is the same as increasing access. That additional capacity will encourage sprawling growth and more and longer vehicle trips. While growth is projected to occur with or without the freeway expansion, the there can be little doubt that the location of that growth will affect vehicle miles traveled and emissions. We believe that evidence suggests that freeway expansion will affect location of growth. Greenfield developers and land speculators support road expansion because they believe it is profitable to do so. Functionally a gridlocked freeway would be the same as no access at all. At the other end of the spectrum, the more free-flowing a freeway, the more access it creates and the more growth is induced in outlying areas. The DEIR/EA should reassess the energy impacts and changes to vehicle miles traveled. SABA is an award winning nonprofit organization with more than 1.400 members. We represent bicyclists. Our aim is more and safer trips by bike. We’re working for a future in which bicycling for everyday transportation is common because it is safe, convenient and desirable. Bicycling is the healthiest, cleanest, cheapest, quietest, most energy efficient and least congesting form of transportation. Yours truly, Walt Seifert Executive Director cc: Sacramento City Council Sacramento City Manager Sacramento Transportation Authority Board Sacramento Area Council of Governments Board Return to list of letters