Bay Area Citizens
members submitted a number of substantive comments. (
in land use and transportation planning provided an objective
the Plan’s high density housing mandates and
additional mass transit subsidies won’t work, even to accomplish the Plan’s
own stated objectives—while they are detrimental to the citizens, cities, and
the Bay Area as a whole, and
the Plan’s analysis was irreparably flawed.
1. The Plan’s high density housing mandates and mass transit subsidies.
underfunds roads and bridges in order to increase mass
transit subsidies, particularly for rail
The Plan’s own analysis shows that 80% of all new
housing must be built in multistory, multifamily projects in crowded city
centers is not, remotely, plausible.
will have significant and irremediable health
offer no credible data to support that
locating housing next to jobs next to transit will lead to people giving up
their cars and working at the jobs next to the housing units.
The Plan also assumes that per capita transit ridership
will skyrocket more than 90% over the next 30 years, notwithstanding that its
mass transit policies simply continue the same types of initiatives that have
been tried in the Bay Area for the last 30 years—initiatives
that have led to a 10% decline in total transit
ridership and a more than 30% decline
in transit ridership per capita.
Since the fuel efficiency
of the passenger vehicle fleet will increase
from 20 miles per gallon (MPG) in 2010 to 50 MPG in
2040 due to state and federal regulations, the energy efficiency
gap gives a greenhouse gas emission advantage of passenger vehicles over mass
transit. Though some buses in large
cities run full and hence are both energy and greenhouse gas efficient on a
per passenger mile basis, this doesn’t mean that mass transit, on average, is
similarly efficient—and it is not.
The Plan also does nothing to address the
mobility needs of lower income Bay Area
residents who are reliant on a well-functioning bus system to get to work,
school, and other places.
Even if the Plan’s high density housing and mass transit
subsidies work as ABAG and MTC claim they will, those draconian policy
initiatives will only lead to a 1.2% difference in
greenhouse gas emissions in 2040 over doing nothing at all. Draft
EIR Table 3.1-28, p. 3.1-59.
2. The Plan’s analysis was irreparably flawed.
claims that it will take “a 25 to 35 percent
reduction from current emission levels” to
reach the statutorily required 1990 levels for greenhouse gas emissions. ABAG
and MTC have been aware all along, that this assumption is totally
inaccurate. They know that current models for greenhouse gas emissions for
both California and the US show that we are at or about 1990 levels now, and
on a continuing path downward due to new state and federal MPG regulations.
They know the impact of those MPG regulations will dwarf
(14-20 times or more) the paltry differences that they claim will result from
their draconian policy initiatives versus doing
They argue that the governing statute requires them to
ignore those MPG regulations, despite the plain text of the statute requiring
them to do otherwise.
And, when it is convenient for them do so, as when
considering the adverse health effects of
the Plan’s high density housing mandates, ABAG and MTC cheerfully claim credit
for the pollutant reductions due to those same MPG regulations that they
ignore when they are selecting their high density housing mass transit heavy
Their budget is the
funds that come from gas tax revenues. Their own internal models
require that by 2035 32% fewer gallons of gasoline will be used by
passenger vehicles in the Bay Area than were used in 2010, but it will be
approximately 50% less in 2035 over what they were in 2010.
So, do ABAG and MTC report a 50%
decline in gas tax revenues in their budget for 2035 or 2040? Of
course not. They “mitigate” these inevitable declines by ignoring most of the
declines, then assuming that the retail price of gas will increase over the
next 30 years by vastly higher rates than the Plan’s assumed rate of
inflation. As a result, the problem of 50% fewer gallons of gas used by
passenger vehicles in the later years of the Plan is “solved,” and the Plan
reports continuing increases in gas tax revenues, in defiance of reality, and
in utter disregard for proper budgeting and forecasting practices.
3. MTC and ABAG’s lack of response
Needless to say, none of what the comments
establish above was addressed or considered by ABAG and MTC. No changes in
the analysis were offered, and no modifications to the Plan were considered.
ABAG and MTC staff, for their part, simply
ignored the comments that questioned the Plan in their reports to the public
and to the ABAG Executive Board and the MTC commissioners. Their “Summary of
Public Comments” submitted orally and in writing on June 14, 2013, spent much
of its time discussing a public opinion survey where the agencies asked
residents whether they would be in favor of a Plan that helped the economy and
the environment, and made housing more affordable, then spent most of the rest
of the time discussing comments submitted by other government agencies. Their
“Summary of Public Comments” only touched briefly on the substantive concerns
raised in the overwhelming majority of the comment letters by discussing what
they characterized as “information or statements” made by the public about the
Plan that required “correction” or “clarification.”
ABAG and MTC’s responses to comments in
the Final EIR were similarly deficient. They lost fifteen letters entirely,
and it wasn’t until Bay Area Citizens repeatedly urged the agencies to look
through their records to find missing comment letters that they found those
missing letters. The responses to the issues raised in individual comment
letters provided by ABAG and MTC were astonishingly dismissive in many cases.
This lack of responsiveness by the agencies was a fitting, though sad, end to
a several year process where citizen concerns, citizen input, and the
substantive issues citizens raised, were completely ignored.