7202 Stonewood Dr.
Huntington Beach, CA, 92647
Southern California Commuters Forum
13 February, 2006
Glen Campbell
Orange County Transportation Authority
550 S. Main St.
PO Box 14184
Orange CA 92863-1584
Dear Mr. Campbell;
The Southern California Commuters Forum (SCCF) is a group of independent voters, interested in the direction of transportation planning in the Orange and Los Angeles county region. The SCCF has reviewed the January 2006 draft of the Long Range Transportation Plan (LRTP) and the Preliminary Environmental Impact Report (PEIR). We submit our comments below.
We attach our comments on the draft Measure M Renew (MMR) document and ask that they be incorporated into the LRTP as well.
GENERAL COMMENTS
The LRTP professes no vision for the future, however, by examining the contents of the document one can ascertain what this future will look like. In short, it is a future with increased congestion on our freeways and roads coupled with a small shift in travel from automobiles to public transit. While the LRTP reduces the congestion growth compared to a no growth plan, it does not stop the upward trends in congestion and travel time. According to the information provided*, congestion will increase by about 260 percent and over 400,000 added hours of delay per day with the Balanced Plan while the transit share will only increase from about 1.5 percent of trips today to 2.3 percent in 2030.
* The LRTP obfuscates this information but with diligence it can be extracted from the data.
This sad future is the direct consequence of the LRTP's allocation of funds between freeways and roads (61%) and transit (38%) and the resulting selection of projects to pursue. We believe that the future can be much brighter if funds and projects are better allocated toward freeways and roads and more innovation applied to our freeways and roads.
The list of projects including those in the Unconstrained Alternative are estimated to cost about $50 billion and even then many projects are not mentioned such as double decking freeways and adding express and truck lanes and arterial expressways are not mentioned. All these add up to more than the $40 billion in projected funds. We believe that each of these projects should be listed in strict order of cost effectiveness, allowing for serving all sections of the county, and be selected starting with the most effective and on down. We do not believe that the present project list would pass this test. We have limited funding resources and it is imperative that we make the maximum use of them.
We therefore find the LRTP to be insufficient and in need of major revision.
LRTP SPECIFIC COMMENTS
1) Goals and Objectives
a) The document states an objective of "Minimize increases in congestion." This reflects a losers attitude on the part of OCTA and should be changed to "reduce congestion." In addition, this objective should be the first and primary objective as it is the most critical issue today and into the future.
b) Of the six means of accomplishment (page 3) all but one are transit related. This clearly demonstrates the principle thrust and interest of the OCTA. It is time that the OCTA recognizes that 99 percent our travel is on roads and freeways and start putting emphasis on these elements of our network. This list should be revised to properly balance freeway/roads versus transit goals.
c) Only one minor mention is made of goods movement and commercial traffic. These components are major transportation issues and are not addressed in the Goals and Objectives or the rest of the document. The only means of accomplishment is to support efforts by others. A transportation plan that does not adequately address these components is doomed to failure. Goods movement and commerce should be addressed here and in the rest of the document.
d) In several places emphasis is placed on growth in transit ridership as a measure of progress in mobility and quality of life. As most people prefer other means of travel it is not true that transit growth is a measure of these goals. In all places a more appropriate measure is "reduced travel time for all means of transportation."
2) Trends
a) Page 17; the math in the example trip time is wrong. The trip will increase from 30 minutes to 46 minutes, a 16 minute increase or 53% increase.
b) Figure 13 page 19 says that the current AM peak arterial average speed is 31 mph. Even in congestion free flow, arterial speeds are 40 to 50 mph not including stopping for traffic lights. But including traffic lights at less than half mile intervals, speeds are more like 20 to 30 mph. Speeds in AM traffic are even less. This means the speeds also shown for 2030 in Figure 14 are to high.
Correct the models to reflect real arterial conditions and then correct all mobility and environmental assessment figures.
3) Setting
a) Page 24 states that our freeway system is "nearly built out." This is a pessimistic view typical of OCTA and not true if one considers that; SR-57 can be extended, originally SR-39 was to be a freeway and could be made an expressway, the PEROW could be developed into a mini freeway, freeways can be double decked, the 241 can be extended, the 133 can be converted into a freeway or expressway, freeways can be widened, ideal ramp metering can be enforced, carpool lanes could be opened up, and for a price, other new freeways can be built. And finally there are future technology in automated highways and cars that can greatly improve freeway capacity. Given all these possibilities and a forceful OCTA, freeway capacity could more than be doubled.
The real issue is one of will. OCTA has been willing to set down the gauntlet on developing transit but has been unwilling to tackle even a handful of homeowners for road and freeway projects. OCTA must stand up as an all around transportation developer.
b) . Page 25 states, "In 2005, the 91 Express Lanes carried an average of 34,000 vehicles during weekday morning peak hours," Given that the maximum capacity of a freeway lane is about 2000 vehicles per hour this is an impossible traffic figure.
c) The LRTP provides various data on performance of freeways, roads and transit but skillfully avoids and direct comparison of travel trips, passenger miles, travel speed, delay for each mode. These comparisons are needed to assess the performance of each mode and should be added.
d) The completed MPAH will have a total of 1527 miles of arterials and the Bike plan (Appendix A) will have 1617 miles. Given that arterials carry a thousand times more traffic than our bike lanes, it is a sad tribute to OCTA's bowing to the bike lobby that we will build more bike lanes than arterials. The Bike Plan should be revised downward from its 56 percent expansion.
e) Page 38 discusses the future of carpool lanes. While it is true that more vehicles have moved over to the carpool lanes it is also true that carpooling in general is declining. As the primary purpose of HOV lanes is to encourage carpooling the HOV lane system must be deemed a failure. (This is true independent of the continued invention of clever but mostly irrelevant performance measures by carpool advocates.) Furthermore, as the growing use of the lanes (by people that would carpool independent of the lanes) load up the lanes, their advantage has continued to diminish.
Consequently, the OCTA should add to its list of carpool alternatives, the idea of stopping expansion and even conversion back to mixed flow lanes.
f) Page 42 states, "To maintain existing pavement conditions will take an investment of $1.64 billion over the next 15 years." The present condition of our roads is far from satisfactory. The LRTP should strive to improve rather than maintain our road conditions.
g) Page 45, Figure 28. The weekday ridership estimates are pie-in-the-sky, inflated estimates. The Table should be removed or so stated. How for example could the Orange line ridership be 55,300 when the length of the line is not known to an accuracy of 300 percent? Eliminate the table or delete ridership projections.
h) Strategies for Success, Page 48. There is no reason to place such strong emphasis on limiting freeway growth by not expanding ROW. Given all the transportation growth projection data this limit is a strategy for failure. The draft MMR proposes about 134 new freeway lane miles, about a ten percent increase which is no match for the 39 percent increase in travel miles projected. The proper strategy should be to, "a) Expand freeway capacity, as needed, to meet future demands. b) Minimize new ROW when possible."
4) The Plan
a) The plan and its assessment provide no insight on the effectiveness of individual projects. It is therefore not possible for the reviewer to assess the utility of the specific projects considered in each alternative. Without such data the reviewer has no basis for comment and must therefore reject the plan as written.
b) The Constrained Plan includes adding HOV drop ramps and connectors on the 405, 22, 55, 605 and 57. These projects will cast $480 million. These projects will have less effectiveness than several of those in the Balanced and the Unconstrained Plan. All projects should be rated as to cost effectiveness and should be prioritized accordingly. The connectors and drop ramps should be moved to the Unconstrained Plan list and replaced by more effective freeway widening and extension projects.
c) In conjunction with the above the initial widening of the I-405 should be moved from the Balanced to the Constrained Plan and the further widening of the I-405 in the Unconstrained plan moved to the Balanced Plan.
d) The cost of expanding the Metrolink all day service to LA and Riverside counties in the Balanced Plan seems excessive given the limited increase in passenger service (7,000 out of 16,000,000 passenger trips). Furthermore, expansion of this service into the other counties cannot be accomplished without concurrence and expense in these counties. The LRTP does not address this issue.
OCTA should address this issue along with cost sharing. OCTA should consider a scaled down frequency plan to LA and Riverside that would cost less and be more cost effective.
e) The plan does not address goods movement. A major part of our freeways are consumed with freight traffic. This traffic will increase significantly in the next 30 years. Increased traffic will not only make commerce more costly and inefficient but will also severely impact passenger traffic on our roads and freeways. The LRTP is silent on how the plan will address this issue.
f) Page 76, Figure 48, Costs. The Balanced Plan allocates 38 percent of the projected funding to the Transit Sector. This despite the fact that transit is projected to never amount to more than 2 percent of travel and will only handle 2.5 percent of the growth in travel.
These small percentages for transit strongly imply that a much lower allocation of funds to transit and more to roads and freeways would result in a better future for the vast majority of OC citizens. The OCTA talks a lot about equity and fair share but does not apply these principles to the majority of commuters. It is time to reverse this situation. A more proper allocation of funds between sectors would allocate about 5 to 10 percent to transit.
Furthermore the transit plan in the LRTP is too heavily weighted toward the strip along the Metrolink line and does not adequately address the needs of the West and South Counties.
Furthermore the funding for expanding Metrolink service sold to the public when the plan to drop Centerline was approved more than doubled from the approximately $250 Million originally stated.
It is therefore recommended that the funding allocated to expanding the Metrolink Service in both the Constrained plan and the Balanced Plan be greatly reduced. As a minimum the following reallocation of funds should be implemented. Referring to the allocations in Appendix C;
- Reduce the funding for Metrolink expansion in the Constrained Plan from $752 million to $250 million
- Eliminate the $500 million expansion of Metrolink in the Balanced Plan (Measure M Renew).
- Revise the $7538 million allocation in the Constrained Plan to include new BRT lines and reduced by $1000 million.
- Revise the $1000 million in the Balanced plan to $500 million and change the emphasis from extensions to Metrolink to provide countywide service.
- Eliminate the allocation of $227 million to regional gateways as these gateways are likely not to ever occur.
The $2729 should be allocated to the roads and freeways sectors so that an improved distribution of 32 percent to transit and 68 percent to roads and freeways can be accomplished with added projects from the Unconstrained Plan.
5) Funding Sources Page 77, Figure 49
a) This figure shows a $12 billion funding source for Measure M Renewed (MMR) along with an additional $0.9 billion from city funds for the Balanced Plan. However the funding table does not show any additional State or Federal matching funds for the MMR projects it proposes. While matching funds may be hard to predict for these projects, it is hard to believe that there will be no matching funds over the next 30 years.
Some estimate of matching funds should be included in the LRTP if it is to provide a best estimate of the future.
b) The figure shows the same transit fare revenue for both the Constrained Alternative and the Balanced plan even though the plan states the transit ridership will increase in the Balanced Plan. An estimated increase in transit fares should be included in the LRTP
c) No mention is made of the Governors Plan. Although this is speculative, a section should be included to discuss this possibility. Perhaps another alternative wherein those projects that could be funded with the Governors Plan and matching funds are accounted for.
d) Projected gas taxes in the next 30 years for OC residents should amount to about $24 Billion. Yet the Figure shows only about $12 Billion from State and Federal gas taxes. No mention is made of this missing $12 billion. No action is proposed by the county to correct this travesty. The LRTP should include a plan to at least attempt to put pressure on State and Federal governments for a proper distribution of our taxpayers resources.
e) Additional funding from the above items should be applied to the roads and freeways sectors to further improve the equity and fair share distribution of funds.
PEIR SPECIFIC COMMENTS
1) SECTION 5, ALTERNATIVES
a) Balanced II Alternative. The Balanced II plan compared to the Proposed shows less VMT, less gasoline consumed, less daily trips, no difference in emissions, less VHT and higher average speed. The only drop in performance is the slight drop in transit trips.
Page 5037 says, "Implementation of projects within the Balanced II Alternative would result in greater impacts (compared to the Proposed plan) to the transportation system. The term "greater impacts" has a negative connotation and should be changed to "greater positive impacts."
With all these factors, we recommend that Balanced II plan become the Proposed Alternative.
b) Table 5.12 shows Balanced II plan has fewer auto trips and fewer transit trips compared to the Proposed plan. As the analysis is conducted with constant person trips, how can both measures go down. These results need to be checked.
c) Tables 5.2, 5.3 and all other tables in section. Compare Baseline to alternatives rather than the other way around. Results are confusing when looking at percent differences. E.g. Table 5.2 Proposed plan has 85,818 VMT while Baseline has 85,087. This is shown as a minus 2 percent change. If the comparison was to the Baseline then it would show the Proposed plan as plus 2 percent. This is not standard practice and should be reversed. Compare all other alternatives to the Baseline and change the sign on the differences. The one exception is Existing to Baseline which is shown properly (in historical sequence).
2) Section 4.11.6 SIGNIFICANT UNAVOIDABLE ADVERSE IMPACT
This section states, "The following significant unavoidable adverse socioeconomic impact has been identified:
• Disruption or division of existing communities by separating community facilities, restricting community access, and eliminating community amenities"
One wonders what is meant by the term, "significant." It gives no quantification of the impact. Essentially no new roads have been added and the so called disruption amounts to some facilities being tens of feet further apart than previously. This is hardly what might be considered significant. On the other hand, providing for better travel and easier access to community facilities for all people is a positive impact that is not even considered.
The section should state that, "NO SIGNIFICANT ADVERSE IMPACT OCCURS." All other similar sections should be reviewed with regard to the meaning and level of, "significance."
3) 5.8 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
a) Table 5-17 page 5-59 discusses a criteria named "Socioeconomic." This criteria is misnamed, there is nothing "economic" in it. The criteria deals with population and housing as discussed in Section 4.11. In fact the PEIR failing is that it does not have any criteria dealing with the economic welfare of the county.
A criteria dealing with economic impacts should be added. Certainly reducing congestion and along people to get to work and shopping quicker has an economic impact.
b) The statements in this section may be correct but are meaningless. They basically state that doing nothing or less is environmentally superior than doing something. This is not surprising as all the criteria are carefully selected to deal with negative impacts which predetermines this conclusion. The criteria does not deal with such impacts as congestion, poorer economic growth, or the wellbeing of the population.
The section does not deal with the relative quantitative impacts (there is no way to logically do that) but it results in meaningless statements. For example the section says" The Unconstrained Alternative would meet the objectives of the Proposed Plan but would result in greater environmental impacts than the Proposed Plan and is therefore not considered the environmentally superior alternative." This leads one to the conclusion that only that alternative that barely meets the objectives is the best choice independent of the benefits of the alternative. The section should be deleted or its limitations stated.
Sincerely Yours
David L Mootchnik
Member, SCCF
714 842 8766