Submitted on behalf of the Southern California Council on Environment and Development (SCCED) by Jim Stewart, Ph.D.
Prepared 3/12/01

The 2001 RTP Update Program Environmental Impact Report (PEIR) has been prepared by the Southern California Association of Governments (SCAG) for the six county region comprised of Ventura, Los Angeles, Orange, Imperial, San Bernardino and Riverside Counties.

ANALYSIS OF IMPACTS

Impacts 3.2-2, 3.2-3 and 3.2-5 fail to mention the vast deterioration of conditions from the current situation. The huge loss of mobility and economic and social impact of travel time delay must be included as an unmitigated result of this plan. As RTP Appendix J reports, the Vehicle Hours Delayed will increase by over 100% from 1.5 to 3.0 million hours per day. Using the SCAG valuation of time of $8.59 per hour for passenger vehicles and $27.00 per hour for trucks, the cost to the region will rise from $5.2 billion per year in the base year of 1997 to $10.7 billion per year.

Impacts 3.4-1 and 3.4-2 mention significant increases in air pollutants, especially PM10, but no mitigation measures are listed, yet there are many that could be done, such as increasing funding for transit and non-motorized transportation.

Impact 3.5-3 clearly states that constraining LAX to existing activity levels produces the least noise impact. If the final plan proposes any capacity increase at LAX, major mitigation measures must be implemented.

Impact 3.10-3, increase of natural petroleum and diesel consumption, will be very significant. The statement in the draft PEIR stating that the implementation of the RTP Update would reduce the amount of automotive fuel consumed is in error — page EN-17 indicates a 22% increase in fuel consumption.

MITIGATION OF SIGNIFICANT IMPACTS

CEQA section 15126.4(a)(1) says: "An EIR shall describe feasible measures which could minimize significant adverse impacts…" The DEIR fails to present mitigation measures to avoid the above impacts. The PEIR must include specific minimum measurable performance standards for all mitigation measures, and contingency plans if performance standards are not met.

AIR QUALITY ISSUES

SCAG has included non-viable projects in its air quality calculations. The Federal government is no longer considering Southern California for a $960 million seed money grant for Maglev. With no federal grant readily available, and no assurance of private funding, Maglev cannot be forecast as a viable component of these plans.

Although other levels of emissions will be reduced in the SCAG plan, PM10, the most dangerous of all pollutants, will increase by 39%, causing thousands of deaths. The USEPA estimated over 3,000 excess deaths and 52,000 respiratory episodes occur annually in Southeast L.A. County alone from current levels of particulates.

The air quality analysis relative to PM10 in the PEIR needs to be completely redone. It ignores the impact of the huge increases in road dust over the plan period, caused by the additional VMT, plus the additional lane miles. As the PEIR states, VMT would increase from 346 million in 1997 to 492 million by 2025. Freeway lane miles will increase by 2129 miles.

The only acceptable mitigation would be reduction of VMT by at least 40%, just to maintain current levels of PM10. The only mitigation to achieve these reductions would be for large increases in transit services. The RTP must be revised to increase transit services and decrease VMT to provide acceptable mitigation for PM10 and PM2.5.

SUSTAINABILITY ISSUES

Sustainability of the transportation system needs to be guaranteed for future generations. Fuel supplies are projected to become increasingly scarce and expensive in the coming years. If we do not implement more far-sighted solutions, SCAG and MTA plans forecast that over 80% of trips will still be made by private automobiles in 25 years, with little change in transit usage, resulting in over 22% increase in petroleum fuel use.

Recommended mitigation measures include:

• Long Range Planning — True long range planning involves looking at the expected population growth and transportation needs over the next 50 years or more.
• More funding for maintenance — The American Society of Civil Engineers has stated that nearly a third of California's bridges are structurally deficient or functionally obsolete and nearly a third of the roads are in poor or mediocre condition.
• Plan now for the end of cheap oil — The looming oil shortage requires immediate actions to greatly reduce auto and truck use before 2010, including major expansion in public transportation, new goods movement strategies, and large increases in taxes on gasoline and diesel fuel.

PROJECT ALTERNATIVES

CEQA Guidelines Section 15126.6(b) states: "Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment, the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project."

We request that SCAG consider and analyze a project alternative that integrates transportation planning, land use reform, and energy efficiency standards compatible with smart growth or livable communities scenarios. Such an option would address a range of significant environmental impacts, including loss and degradation of wildlife habitat and ecosystem function, polluted water runoff, air pollution, high rates of automobile dependence, as well as sustainability issues in terms of petroleum.