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3921 East Bayshore Road, Palo Alto, CA 94303      tel. (650) 417-2571

 

September 25, 2001

 

The Honorable Sharon Brown, Chair
MTC
101 Eighth St
Oakland, CA 94607

 

Dear Ms. Brown and MTC Commissioners:

This letter is to submit our comments on the draft RTP and RTEP. We concur with the recommendations and comments submitted by the Bay Area Transportation and Land Use Coalition. In addition, we have the following specific comments.

Regarding the RTP:

  • We ask that you include the Transbay Terminal project, including Caltrain Downtown Extension, in Track 1 of the RTP. This project is on the verge of receiving state funding and must be given the priority that it deserves. We cannot emphasize enough how important this project is to us and to the region.
  • We applaud the inclusion of the electrification of Caltrain in the list of Track 1 projects.
  • We're concerned about an apparent $74.6 million shortfall in capital costs being provided to Caltrain, as well as shortfalls in operating costs to other transit providers. Caltrain and other transit providers must not be forced to increase fares to make up the difference.
  • To allow the Bay Area to comply with federal air quality standards, we ask that Caltrain track improvements, especially in southern Santa Clara County between South San Jose and Gilroy, be prioritized over highway expansions in the same locale. Please continue to exclude Alternative 2 of the Route 101 widening from the RTP.
  • Already some 90% of the monies must go to maintaining what we have. In general, we request that any expansion monies go to transit and smart growth incentives rather than highways, to improve our ability to meet air quality standards, reduce sprawl, and to reduce the future per-capita financial burden and upkeep required on our roads.

Regarding the RTEP:

We request that the following cost-effective projects be made Tier 1 projects.

  • The Transbay Terminal (TBT) and Caltrain Downtown SF Extension must be considered one project, and made a Tier 1 project. MTC's own $11 cost per new rider is quoted for both projects together. A common EIS/EIR is being prepared for both projects together. Money and time will be saved by financing both projects together. The two components of this project must not be artificially split.

There is no excuse for omitting this project from RTEP Tier 1. This project is extremely important to improve transit connectivity between San Francisco, the East Bay, northern Bay Area counties and the Peninsula. Since most of the funding is about to be secured, it should be made a Tier 1 project. Giving Tier 1 status to this project will also fulfill one of the last remaining commitments of the 1988 RTEP agreement.

We feel there is a double standard being applied when "local match" is given as the reason for making the BART to San Jose project Tier 1 while excluding the Transbay Terminal project. The complete Transbay Terminal project, including the Caltrain extension, is likely to have over 85% local match.
  • Caltrain Express Improvements: Caltrain connects major population centers and is essential for mobility along the western half of the Bay. Express trains entice motorists to switch to riding the train, which is important for air quality and regional economic productivity, but comparatively little has been done to upgrade Caltrain's infrastructure.

Caltrain Phase 1 track improvements, planned to be completed by 2003, are just a small step toward maximizing the transportation potential of Caltrain. Caltrain, especially when integrated with Dumbarton rail service, will not achieve full functionality without the Phase 2 and 3 improvements. These cost-effective improvements will save many thousands of hours for commuters and reduce tons of air pollution. Even so, these improvements will barely allow Caltrain to keep up with existing demand. We ask MTC to recognize this and make Caltrain express track improvements Phases 1-3, priority Tier 1 projects.
  • ACE Service: Despite the fact that ACE has made it difficult to buy tickets and doesn't advertise its services, the Altamont Commuter Express train service has become so popular that it's often standing room only and many riders have stopped riding the train because it's too overcrowded. ACE has filled to capacity within a few short years, and it has a proven track record.

Therefore, we are greatly dismayed to see that improvements to the ACE service, which are listed in the draft RTEP as being by far the most cost-effective of all the rail projects, is not being made a funding priority in a financially-constrained plan. Why are other much more expensive projects that serve some of the same populations as ACE being giving funding priority instead?
  • Capitol Corridor Service: The Capitol Corridor system is the fastest growing rail line in the U.S., with ridership more than doubling in the past 3 years. The Capitol Corridor and ACE trains continued to attract new riders even while the BART system experienced a downturn in ridership due to the slowing economy. With a new station being planned in Solano County, the Capitol Corridor will serve more people than ever and will need to add more trains and fix tracks which slow the service in the south Bay Area. Therefore, we ask that Capitol Corridor system track improvements and service expansion be fully funded to allow more people to use this express intercity service instead of driving.

Increased ACE and Capitol service are consistent with VTA policy and have VTA RTP partial funding, that is not reflected in the draft RTEP. Moreover, the Capitol Corridor improvements are nearly four times as cost-effective as the proposed BART to San Jose extension. We ask that you assign Tier 1 status to the Capitol Corridor improvements.

With even the very modest improvements proposed, the combined increase in ACE and Capitols service would provide three trains an hour in the commute direction and one train per hour in the reverse commute direction, yet these gains have been excluded from the draft RTEP. We ask that you remedy this.

We are pleased to see Dumbarton Rail is being made a Tier 1 project, as it will provide direct transbay rail service from the Southern Alameda County to the entire Peninsula from San Francisco to San Jose, and has widespread community support. We further note that funding for Hayward Bypass, recently ruled illegal, could instead fund the extension of Dumbarton rail to Hayward as envisioned by the 1999 Dumbarton Rail study.

General Policy Comments

In a financially-constrained plan, it's incredible that one project whose full cost is not yet known is being allowed to eat up the lion's share of regional funds. Furthermore, basing the RTEP on "local match" encourages the very worst public policy, in which the region becomes obligated to throw good regional money after bad simply because of a local political decision.

Given limited funds, MTC should pursue the most cost-effective projects first. Projects should compete regionally based on their cost-effectiveness per new rider as well as absolute dollar amounts requested. This means that if a project had 20% local funding out of $5 million, it may be and should be higher priority than a project with 50% funding out of $7 billion. The absolute dollar amounts are the bottom line in terms of getting the best regional results for our total regional investment.

If funding the BART extension to San Jose means that the plethora of more cost-effective rail projects go unfunded, MTC should consider making the BART extension terminate at Milpitas light rail. This will help to contain costs and preserve vital funding for these other much-needed projects.

At the very least, MTC should ask VTA to present a financially constrained plan that demonstrates that they can pay for the projects in the Santa Clara County portion of the RTP, and have enough monies left over to operate the local bus service and other services in the plan, before including the BART to San Jose extension in the RTP or RTEP.

No Opportunity for the Public to Submit Projects

We are greatly concerned that the public was not given the opportunity to give input on projects in the formulation of the draft RTEP, and that this whole process has been so rushed. There are other projects that we would have recommended for study and/or implementation in the RTEP.

  • For example, we'd like to request that money be allocated to study a new transbay conventional rail crossing near the Bay Bridge, since both the Bridge and the BART tube are expected to provide inadequate capacity in the not-too-distant future, within the time frame of the proposed new RTEP agreement.
  • We'd also very much like to see built a new transfer-only station between BART, ACE, and Dumbarton Rail at Shinn Road in Fremont be funded as part of BART or ACE improvements.

As the Bay Area Transportation and Land Use Coalition has pointed out, a number of studies are pending that will provide much better financial and ridership information for making these long-range plans. We hope that the RTEP won't be finalized without significant additional information, thoughtful planning and public input.

Thank you for taking these comments into consideration.

Sincerely,

 

 

Margaret Okuzumi

Executive Director

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