Appendix E

Minority Statement of Michael A. Replogle

The committee charged with evaluating the effects of added highway capacity on the environment and energy use has reviewed extensive literature and conducted numerous meetings in pursuit of consensus. Although I concur with many of the report's findings, some of the findings and much of the report's tone are based on judgments or opinions I must reject on the basis of my 18 years of experience as a transportation planning engineer and modeling professional. The committee report is correct in identifying the need to improve our analysis tools, but it errs by asserting that we cannot adapt these tools to meet current regulatory requirements without substantial delay. The problem is not a lack of good science to support analysis, but institutional resistance to the use of good science in transportation analysis that would challenge entrenched and powerful pro-highway expansion interests. One might hope that the report will contribute to increased investment in improved analysis and transportation/environmental monitoring systems. It would be unfortunate if the report's conclusions are misread as an excuse for inaction, regulatory rollback, and a resurgence of business-as-usual highway policies on the basis that we just



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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use Appendix E Minority Statement of Michael A. Replogle The committee charged with evaluating the effects of added highway capacity on the environment and energy use has reviewed extensive literature and conducted numerous meetings in pursuit of consensus. Although I concur with many of the report's findings, some of the findings and much of the report's tone are based on judgments or opinions I must reject on the basis of my 18 years of experience as a transportation planning engineer and modeling professional. The committee report is correct in identifying the need to improve our analysis tools, but it errs by asserting that we cannot adapt these tools to meet current regulatory requirements without substantial delay. The problem is not a lack of good science to support analysis, but institutional resistance to the use of good science in transportation analysis that would challenge entrenched and powerful pro-highway expansion interests. One might hope that the report will contribute to increased investment in improved analysis and transportation/environmental monitoring systems. It would be unfortunate if the report's conclusions are misread as an excuse for inaction, regulatory rollback, and a resurgence of business-as-usual highway policies on the basis that we just

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use do not know what the future might bring. Citizens need no experts to know that one does not cure obesity by loosening one's belt nor cure traffic-related problems by simply expanding highways. Readers of this report should consider two closely related reports issued in 1994 by high-level study commissions in the United Kingdom. These considered a wider range of evidence and drew conclusions and judgments that contrast with the committee report and are generally more consistent with this minority statement. The Standing Advisory Committee on Trunk Road Assessment (SACTRA) report, Trunk Roads and the Generation of Traffic, is focused specifically on the strong evidence that highway capacity expansion spurs increased motor vehicle travel demand (SACTRA 1994). In the Royal Commission on Environmental Pollution (RCEP) report, Transport and the Environment, an overview is given of the broader challenge of making transportation more sustainable, including extensive discussion and recommendations regarding the role of road investment in contributing to environmental degradation (RCEP 1994). The committee report does not give appropriate consideration to evidence related to the effects on energy use and the environment caused by a reduction of highway capacity—for example the effects of traffic calming and traffic cells—although such evidence is highly relevant to the issue at hand. While asserting that transportation pricing strategies are more important than changes in highway capacity in determining environmental performance, the report gives only limited consideration to evidence from outside the United States that might isolate the effects of highway capacity changes from the effects of transport pricing, levels of public transportation provision, and alternative land use and urban design patterns. Excluding this evidence, and in a tone that appears to subtly play to one side of current contentious domestic policy debates, the report concludes that our state of knowledge is insufficient to evaluate the effects of added highway capacity to support current federal environmental regulations. It is intellectually inconsistent for the report to argue that on the one hand, current models cannot evaluate the effects of changes in highway capacity on the environment, while on the other hand asserting that alternative strategies, such as time-of-day tolls, will have known and larger effects on air pollution emissions. If we lack the ability to develop reasoned estimates of likely effects of changes in high-

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use way capacity, we are unlikely to have the ability to estimate the effects of changes in pricing, technology, or other system attributes. However, the report's lead finding in the Executive Summary concludes that “analytic methods in use are inadequate for addressing regulatory requirements [to assess the effects of added highway capacity on air quality]. The accuracy implied by the interim conformity regulations issued by EPA [the Environmental Protection Agency], in particular, exceeds current modeling capabilities. . . . The current regulatory requirements demand a level of analytic precision beyond the current state of the art in modeling.” Current traffic and emission models need expeditious improvement and substantially higher levels of research, data collection, development, and dissemination of best-practices techniques. However, significant and steady improvement in operational regional models for evaluating the likely emission, system performance, travel behavior, and development impacts of changes in highway capacity, pricing, and policy is possible in both the short and mid-term to meet current regulatory requirements. State-of-the-art modeling methods, if applied with common sense (e.g., considering likely effects of transportation capacity on land development patterns), are adequate to judge the probable direction and approximate magnitude of regionally significant highway capacity additions in transportation plans. Unfortunately, in the 5 years since passage of the Clean Air Act Amendments of 1990 (CAAA), metropolitan planning organizations (MPOs) that are typically responsible for evaluating transportation conformity have made only slow progress in improving their analytic tools to respond to new policy requirements. Ironically, much of the resistance to improved transportation and air pollution modeling practices in the past has come from the same parties that have most strongly resisted Clean Air Act implementation and that now seek to weaken or overturn its provisions requiring transportation plans and programs to contribute to air quality attainment. Inappropriate use of the models can be addressed by recognizing their shortcomings and devising incremental improvements (Replogle 1993a; Cambridge Systematics, Inc. 1994; Harvey 1993; U.S. District Court 1990). Rather than devoting adequate resources and methods to accomplish this, many state and regional transportation agencies prefer to question the requirements of the regulatory process, citing the small differences

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use they find between “build–no-build” scenarios when these are analyzed using deeply flawed models. The Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) gave states unprecedented flexibility to use federal transportation capital assistance funds for planning, data collection, model development, and investments in different modes of travel. However, many states have been slow to flex funds from traditional highway construction to support improved performance measurement, modeling, and management systems. CAAA and ISTEA require a positive demonstration that transportation plans and programs contribute to public health and other goals, with the potential to cut off federal transportation funds to jurisdictions that fail to address persistent health-threatening air pollution problems related to motor vehicle use. Our scientific knowledge is more than adequate to support the CAAA mandate that transportation spending be consistent with health-based air pollution control plans. Despite its assertions to the contrary and statement that “the complex and indirect relationship between highway capacity [and] air quality . . ., which is heavily dependent on local conditions makes it impossible to generalize about the effects of added highway capacity on air quality . . . even with improved models,” this report concludes that “limiting highway capacity . . . is likely to have relatively small effects, positive or negative, on metropolitan air quality by current attainment deadlines.” Whether highway capacity will affect emissions over the 20-year life of transportation plans and for the duration of a region's maintenance period, as required by the CAAA, is not judged. The report strays from its assigned scope in implying that current regulations represent a collision of environmental goals and economic objectives likely to lead to delay and reassessment of environmental regulations, and to error and manipulation of the policy process (Executive Summary). The assertions of the report's conclusions ignore strong evidence that restraints on motor traffic growth can be highly supportive of economic development (Hook and Replogle 1995) and reveal the challenge faced by those who would defend the CAAA's mandates for transportation planning. Although the report recommends “a more constructive approach” toward adding new highway capacity, with congestion pricing to mitigate emissions growth, the report does not discuss the likely effects of restraining road

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use capacity within a road pricing context. It is nonetheless arguable that higher motorist user fees and investments in public transportation and other alternatives would encourage earlier and greater energy and air pollution emissions reductions in a policy environment that limited, rather than accommodated, new highway capacity. KEY FINDINGS The effects of added highway capacity on energy use and the environment are complex and vary over time. Although we cannot determine with great precision the effect of an individual project, we can with some confidence determine the general direction and relative magnitude of changes that are likely to accompany substantially different investment programs and policies. We now know that trying to reduce emissions by emphasizing supply-side high-occupancy vehicle (HOV) and single-occupancy vehicle (SOV) highway capacity expansion strategies is at best uncertain and temporary. It often makes the problem worse by spurring greater motor vehicle travel demand and lower-density, automobile-dependent land use patterns and by reducing the relative attractiveness of alternatives to automobile travel. Although technological improvements to vehicles, fuels, and vehicle maintenance promise further cost-effective reductions in air pollution emissions, action is needed to manage the growth of traffic demand to reduce emissions of greenhouse gases and air pollution, curb noise pollution, manage traffic congestion, reduce dependence on foreign energy supply, boost the sustainability of our local and regional economies, and enhance community livability. Limiting further highway capacity expansion, reducing highway capacity, and calming traffic (especially in central areas) can be effective strategies for reducing energy use, air pollution, and other environmental problems, particularly when done in a context of regional growth management that encourages revitalization of urban and sub-urban centers instead of further sprawl. Smoothing traffic flows to reduce sharp acceleration and deceleration also offers significant promise for reducing emissions when done within a balanced multimodal transportation policy framework that includes effective demand management tools, such as road and parking pricing. Auto-

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use mated vehicle speed limitation using intelligent transportation systems may also offer a promising future strategy and merits further investigation. The best way to ensure that transportation plans and programs contribute to improved air quality is to ensure that they provide expanded opportunities to meet daily needs for access to jobs, shops, services, and recreation with less forced dependence on petroleum-fueled motor vehicles. This means promoting accessibility instead of mobility, using information and communications more effectively to manage community and mobility systems and to provide virtual access, and integrating land use and transportation planning and development with sound urban design for more livable, walkable, and efficient communities. It means explicating the hidden subsidies and tax expenditures that now spur inefficient consumption and investment patterns, charging motorists for these costs, and encouraging a new sense of values about transportation and the responsibilities of individuals in communities. Much more research, data collection, and model development are necessary to support local and regional planning and policy evaluation and to better ascertain the effects of alternative investments and policies on energy use and the environment. This research, data collection, and development of decision-support systems should be undertaken as a partnership involving local, regional, state, and federal agencies within the ISTEA planning systems framework. The creativity and initiative of the private and nonprofit sectors should be encouraged in developing these new management systems for sustainable regional economies and healthy communities. Special attention should be paid to developing modal motor vehicle emission models and activity-based microsimulation models of travel behavior and surface transportation system performance. The federal government could play an important role by developing an information-based National Transportation System in cooperation with states and regions to strengthen strategic management systems for monitoring transportation system performance against key benchmarks, in addition to the factors that affect travel demand and transportation service quality. These systems are necessary to ensure that transportation investments will contribute to wise expenditure of scarce taxpayer dollars, improved air quality, safety, productivity, and more livable

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use communities. Performance-oriented federal funding for transportation could also play a useful role. INDUCED TRAFFIC EFFECTS: FINDINGS FROM A MAJOR UNITED KINGDOM STUDY The committee's conclusions regarding induced traffic are an improvement over earlier official studies, but are so heavily modified and hedged as to have little meaning. The recent British SACTRA study commission offers more useful guidance on the effect of major road projects (which it calls “schemes”) and has far greater confidence than this report in the ability of current scientific knowledge to evaluate these impacts. SACTRA found that . . . induced traffic is of greatest importance in the following circumstances: where the network is operating or is expected to operate close to capacity; where traveller responsiveness to changes in travel times or costs is high, as may occur where trips are suppressed by congestion and then released when the network is improved; where the implementation of a scheme causes large changes in travel costs. This suggests that the categories of road where appraisal needs to be most careful are improvements to roads in and around urban areas, estuary crossing schemes, and strategic capacity-enhancing interurban schemes, including motorway widening. . . . [Studies] we have reviewed demonstrate convincingly that the economic value of a scheme can be overestimated by the omission of even a small amount of induced traffic. We recommend that variable demand methods should now become the normal basis of trunk road forecasts, and these forecasts must be carried through into the operational, economic, and environmental evaluation of schemes in a systematic way. In particular, where networks are operating close to capacity, suitable procedures must be used to represent the constraint of traffic in the base case and the release of traffic growth

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use in the do-something case as additional capacity is provided. . . . We do not think that continuing to appraise solely at the scheme level using the fixed demand approach is, either intellectually, or in practical terms, acceptable. It is this central conclusion which has led us to make the recommendations in this Report. (SACTRA 1994, iii-iv) The report continues as follows: Results of published research demonstrate the following important findings, to a reasonable level of confidence: (a) there is an effect of fuel prices on traffic levels, and a larger effect on fuel consumption; (b) the quality and/or price of public transport can have a small effect on car ownership or use, or perhaps both; (c) the length of the motorway network is one of the influences on the amount of traffic using it; (d) some but not all of the time saved on travel when journey speed increases is likely to be used for additional travel; (e) car users do in fact trade off time and money to an extent and a measure of this trade-off is given by the empirical estimation of the value of time savings; (f) journey times can have an influence on depot location and length of haul of freight operations; (g) the land-use changes consequent on improved access are likely, in turn, to lead to changes in the patterns of travel, car dependence, and the volume of travel. (SACTRA 1994, 45) SACTRA concluded that in the short term, “about half the time saved through speed increases might be used for additional travel . . . the longer-term effect is likely to be greater, with a higher proportion (perhaps all) of the time saved being used for further travel” (SACTRA 1994, 47). These conclusions are more comprehensive and succinct than the committee report and differ in some key respects, particularly with regard to the potential impact of highway expansion on freight travel, the elasticity of travel demand with respect to time savings, and the prospects for improving plan and project appraisal. It is the position of this minority statement that SACTRA has better stated the current state of scientific knowledge in this area. The “fixed demand” approach (i.e., assuming that building new highway capacity will ave no effect on land use and time-of-day of travel or other components of

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use travel demand), which SACTRA finds unacceptable, is the same approach that in the United States produces differences between scenarios smaller than the error term of the models of which this report is critical. SACTRA prescribes the use of currently available improved analytical methods for project appraisal instead of questioning our ability to perform such analysis to meet regulatory requirements. DETERMINANTS OF TRAVEL DEMAND Effects of Subsidies The committee report implies that growth in traffic is an inevitable function of income and economic growth (Chapter 4) and indeed these are important factors in traffic growth. However, the report generally avoids discussing the effects of hidden subsidies and transport pricing systems in explaining the growth of motor vehicle use, although these too are key determinants that reinforce automobile-dependent lifestyles, consumption trends, and land use patterns. In the United States a major share of the costs of highway construction and maintenance continues to be paid for out of general tax revenues, mostly at the local government level. The large past investment in highway capacity by taxpayers imposes a stream of current and future costs that affect the provision of added capacity. The recent report by the U.S. Congressional Office of Technology Assessment (OTA), Saving Energy in Transportation, provides a good accounting of these elements (OTA 1994, 91–111). OTA identifies $76.5 billion in 1990 public spending on highway construction, maintenance, and services covered by payments by motor vehicle users, along with hidden private sector expenditures related to motor vehicle use of $150 to $400 billion a year in 1990 for parking. OTA estimates that U.S. taxpayers provided $33 to $64 billion in subsidies for highway construction and motor vehicle infrastructure and services in 1990, after accounting for total costs and deducting payments by motor vehicle users. Nonmonetary externality costs related to motor vehicle use are estimated at $325 billion to $580 billion per year in 1990. According to OTA, “Approximately 49 to 61 percent of the total monetary and nonmonetary costs of motor vehicle use, excluding the value of time, are efficiently priced [i.e., paid and recognized by motor vehicle users]” (OTA 1994, 109–110). The report continues,

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use “Motor vehicle users paid openly for 53 to 69 percent of the social (public plus private) costs of motor vehicle use, both monetary and nonmonetary, excluding the value of time . . . if subsidies were withdrawn, externalities ‘internalized,' and hidden costs brought out into the open and directly charged to motor vehicle users, the perceived costs of motor vehicle use would increase substantially (by 14 to 89 percent, depending on whether nonmonetary costs and other factors are included), and people would drive less.” Such factors play a major role in influencing the effects of highway capacity changes on energy and the environment, as this committee report implies in its closing discussion of “managed capacity” strategies. Effects of Added Highway Capacity on Freight Travel Demand The RCEP report states, “It is clear that where an alternative is available, moving freight by road takes more space, uses more energy, produces more pollution, and is more likely to lead to an accident” (RCEP 1994, 166). The short-term potential to switch freight from road to rail, water, or pipeline transportation is limited by the specialized functional requirements for many types of shipments, as this committee report correctly notes. However, over a period of two or more decades, alternative transportation investment choices could produce profound differences in freight travel demand. Contrast, for example, a program of significant further public investment in freeway capacity expansion with a program of minor highway capacity expansion, conversion of existing HOV and SOV freeway lanes to privately managed toll facilities, and a combination of policies promoting more aggressive private development of intermodal transfer facilities, railways, water-and pipeline-based freight systems, and intelligent intermodal freight management systems. Highway capacity expansion will clearly affect the use of just-in-time shipping, and in the longer term, the location of commercial, warehouse, and industrial activities. Effects of Added Highway Capacity in Built-Up Areas The committee report asserts, “Within developed areas, traffic flow improvements such as better traffic signal timing and left-turn lanes

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use that alleviate bottlenecks may reduce some emissions and improve energy efficiency by reducing speed variation and smoothing traffic flows without risking large offsetting increases from new development and related traffic growth.” In Chapter 6 the report states, “In central cities and other built-up areas these longer-term impacts [of stimulated travel demand] are likely to be small because the potential for development is limited.” Although small capacity-expanding projects individually may have positive short-term effects on emissions, when many such projects are combined, the effects on latent traffic generation are likely to be significant, as the report acknowledges. Alleviating bottlenecks with new highway capacity frequently leads to the greatest release of latent or suppressed travel demand, especially in more densely developed areas. In many cases traffic flow improvements are taken at the expense of pedestrians, bicyclists, and users of public transportation. These investments often make it more dangerous to travel in the community except by motor vehicle, or represent lost opportunities to restore a walkable streetscape and near-road environment. In many older urban and town centers, such “improvements ” have contributed to the decline of old shopping districts, which have lost their amenity and charm, often sacrificing traffic slowing and pedestrian-enhancing on-street parking in the interests of faster and greater traffic throughput to spur the driver on to the nearby shopping mall, where pedestrian space is privatized and controlled and accessible only by car. Areawide traffic signal control systems that significantly boost average travel speeds across many streets and corridors can spur induced traffic and thus may more than fully offset any short-term emission reductions due to traffic smoothing and speed change effects, unless accompanied by effective and ongoing travel demand management programs (TDM), such as pricing, parking management, and street space reallocation for transit and nonmotorized travelers. Consideration of Alternatives to Highway Capacity Expansion Consideration of alternative scenarios is vital to answering the question, “What is the effect of added highway capacity on energy use and the environment?” Alternatives will produce different patterns of

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use vehicle emissions per mile traveled increase due to more aggressive acceleration, braking, and use of second gear, traffic calming will likely lead to overall emission reductions due to its influence on travel demand (see Table E-1). A recent FHWA report discusses the German experience with traffic calming in six cities and towns in the early 1980s: The initial reports showed that with a reduction of speed from 37 km/h (23 mph) to 20 km/h (12 mph), traffic volume remained constant, but . . . air pollution decreased between 10 percent and 50 percent. The German Auto Club, skeptical of the official results, did their own research which showed broad acceptance after initial opposition by the motorists. Interviews of residents and motorists in the traffic calmed areas showed that the percentage of motorists who considered a 30 km/h (18 mph) speed limit acceptable grew from 27 percent before implementation to 67 percent after implementation, while the percentage of receptive residents grew from 30 percent to 75 percent. (Project for Public Spaces 1992) This experience of initial skepticism of traffic calming, followed by its widespread popularity after implementation, has been experienced in hundreds of communities across Europe, Japan, and Australia, along with the few U.S. communities that have adopted such strategies, such as Palo Alto, California, and Seattle, Washington. Reducing Road Capacity with Traffic Cells for Environmental Benefit Many places in Europe and Japan—cities such as Göteborg, Sweden, Hannover, Germany, and Osaka, Japan; suburban new towns such as Houten, Netherlands; and established automobile-oriented suburban centers such as Davis, California—have successfully implemented traffic cell systems. These typically consist of a set of radial pedestrian, bicycle, and transit-only streets focused on a central area. Whereas pedestrians, bicyclists, and public transportation can freely cross these streets, automobile traffic cannot, but must instead use a ring road around the center. Traffic cell systems are very effective at

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use eliminating through-traffic in central areas and shifting short automobile trips in the central area to walking, bicycling, and public transportation, significantly reducing cold start and evaporative emissions. Reducing central area traffic and increasing street space dedicated to walking, bicycling, and public transportation makes these alternatives more attractive and diminishes parking requirements in the central area. Success in reducing environmental impacts depends on curbing automobile-oriented peripheral development. Göteborg, Sweden, introduced traffic cells in the mid-1970s together with priority for public transportation at traffic signals, new suburb-to-downtown express bus service, and central area parking controls. Noise was cut from 74 to 67 dB in the main shopping street, peak carbon monoxide levels dropped 9 percent, 17 percent fewer cars entered the center city, weekday transit trips to the center were up 6 percent, traffic on the inner ring road was up 25 percent, and the costs of running public transport went down 2 percent. Nagoya, Japan, introduced traffic cells in residential areas in the mid-1970s, together with a computer-managed signal system, bus lanes, bus priority at traffic signals, staggered work hours, and parking regulation. This resulted in a 17 percent increase in traffic speeds on main roads covered by the signal system, and a 3 percent increase in bus ridership. Fifteen percent fewer cars entered the central area in the morning peak, and automobile-related air pollution decreased by 16 percent (National League of Cities 1979). The Downtown Crossing pedestrian zone in Boston, Massachusetts, is a limited traffic cell serving a core area with 125,000 employees. Eleven blocks of the central business district were closed to traffic in 1978 while steps were taken to improve transit service and parking management. In the first year, there was a 5 percent increase in visitors to the area, a 19 percent increase in weekday shop purchases, a 30 percent increase in weeknight purchases, an 11 percent increase in Saturday purchases, a 21 percent increase in walking trips to the area, a 6 percent increase in transit trips to the area, a 38 percent decrease in automobile trips to the area, and no increase in traffic congestion on adjacent streets, thanks to the elimination of on-street parking and stricter parking enforcement on nearby traffic streets. Davis, California, a town of 50,000 people near Sacramento, illustrates a successful full traffic cell system that has cut highway

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use capacity significantly in the vicinity of the University of California (UC Davis) and the town center to increase walking and bicycle use. Bicycle use grew sharply in the 1960s, leading to election of a probikeway city council in 1966. Demonstration bikelanes proved popular and were quickly extended. In addition to the UC Davis traffic cell and bicycle network, the city of Davis now has 59 km (37 mi) of bicycle lanes and 46 km (29 mi) of bicycle paths in an interconnected network. Parking is limited and costs drivers on the UC Davis campus. Bus, van, and commuter rail services offer other alternatives to the automobile. Davis has prohibited development of shopping centers near the freeway, retaining a vibrant pedestrian-oriented downtown commercial area. As a result, 27 percent of UC Davis employees and 53 percent of UC Davis students use bicycles as their primary commute mode; among those who live and work in Davis, 44 percent bicycle to work. The City Planning Department estimates that 25 percent of all person trips in the city are by bicycle. Walk shares in the city are also high—on the order of 10 to 20 percent. Clearly air pollution has been reduced by restricting and reducing highway capacity in Davis. EFFECT OF HIGHWAY CAPACITY ADDITIONS ON METROPOLITAN FORM The report is correct in asserting, “Major highway capacity additions in less developed parts of metropolitan areas, where most growth is occurring, pose a greater risk of increasing emission levels and energy use in those areas. If developable land is available and other growth conditions are present, new capacity is likely to attract more development and related traffic to the location of the improvement. Corresponding increases in emission levels and energy use in these areas are likely” (Chapter 6). Yet the report notes, “Because of the large investment implicit in current metropolitan spatial patterns, it may be years before changes in land use and related traffic patterns induced by the added capacity make a significant difference in regional emission levels and air quality” (Executive Summary), downplaying this potential effect in relation to conformity analysis by following with the statement, “In comparison, . . . EPA predicts further emission

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use reductions for major pollutants on the order of one-quarter to one-third from 1990 baseline levels by attainment deadlines simply from continued vehicle fleet turnover and implementation of CAAA-required vehicular and fuel standards and enhanced vehicle inspection and maintenance programs. Market-based TCMs [transportation control measures], such as increased parking charges and time-of-day tolls, have greater potential for emission reductions. . . .” Most new highway development is likely to have a significant emission-increasing effect within the 20-year planning horizon for conformity analysis unless the region is experiencing no net economic growth or the region 's highway access-dependent periphery is not growing at the expense of its older urban neighborhoods. It is irrelevant whether the highway expansion redistributes growth that would have occurred elsewhere in the region or whether it stimulates productivity gains that result in net new growth (Executive Summary). Most new highway capacity will eventually foster automobile-oriented growth. In either case, increased emissions may break an emissions budget and work against attainment and maintenance of health standards. In regions undergoing rapid development and significant infrastructure investment, major regional impacts on motor vehicle emissions have been observed in relatively short time horizons. Substantial economic growth has not always been accompanied by proportional growth in traffic. Restrained investment in highways accompanied by enhancements of pedestrian, bicycle, and transit access; economic incentives encouraging alternatives to the automobile; and supportive land use policies have resulted in slower growth of traffic despite rising motorization and dramatic economic growth in many European and Asian metropolitan areas, most notably in cities such as Copenhagen, the Randstadt (Amsterdam-Hague-Rotterdam-Utrecht, Netherlands), and in Japanese and Chinese cities. Indeed, there is evidence that such policies enhance growth and economic development (Replogle 1991). This evidence is given no mention in the report, which instead emphasizes that accessibility and generalized travel cost changes are only one factor shaping metropolitan development. However, the report appears to overgeneralize its conclusions regarding the 20-year effects of highway capacity changes on land use patterns, drawing evidence

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use primarily from land use model projections that can be called into question. For example, the committee report discusses the relatively small changes (plus or minus a few percentage points) in regionwide locations of employment and households in built-up metropolitan areas over a 20-year forecast period from systemwide changes in travel time of as much as 20 percent, predicted using commercially available but less-than-state-of-the-art land use models. This is cited as evidence that added highway capacity will have small impacts on regional air quality. However, the land use models cited were generally calibrated on very short time-series data, often 1980–1985 or 1985–1990, when substantial “hot” savings and loan money was diverted into highly speculative and often not economically viable real estate development, leading to drastic over-building in many markets. Indeed, the models used in the United States have mostly failed to represent land and rent values, the variable quality of key public services (education, public safety), and the potential for mixed-use cluster development around nodes of high public transportation accessibility. Moreover, the results of model evaluations have usually been predicated on exogenous constraints related to zoning and limitation of redevelopment, giving little room for differences between transportation investment scenarios to express themselves. In short, the SACTRA report offers more effective statements of our current state of knowledge in these matters, indicating that added highway capacity indeed frequently leads to changes in development patterns that reinforce motor vehicle dependence and use. DATA COLLECTION, MODEL DEVELOPMENT, AND RESEARCH NEEDS There is broad agreement with this report's conclusions regarding the need for improved emission and travel-related data collection and model development. Cost-effective resolution of some of the central questions posed by this study would be well-supported by a cooperative effort of states, local governments, and regions, with federal leadership, to develop broader standards for traffic and travel data collection, the coding of networks and spatial data bases, and

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use transportation-land use monitoring and performance measurement systems. Dozens of uncoordinated, incompatible data systems now hinder the development of effective benchmarks and comparative evaluation frameworks for local and national strategic planning and for theoretical research. The externality costs of transportation and land use investments, such as hidden subsidies, pollution and congestion costs, and accident and health effects, need to be more widely appraised through local measurement and monitoring. A national household travel panel survey is needed to better comprehend the dynamics of travel and activity patterns, vehicle acquisition and use, residential location choice, and commercial development. States should be encouraged to allocate an increased share of surface transportation capital resources to system management and monitoring, planning, and forecasting, to promote long-term, least-cost strategies for community and regional development. The alternative is to continue to pursue costly taxpayer-subsidized, pork-barrel spending unsuited to an era demanding lean government. THE BUILD–NO-BUILD TEST AND REGULATORY BACKLASH New Scientific Uncertainty or Just a New Backlash? This report challenges the “build–no-build” test that has been a key part of transportation conformity under the federal Clean Air Act. This challenge would respond to the distress expressed by many individuals involved in highway development at EPA's November 1993 final transportation conformity rule. Supporters of highway development were generally satisfied with the science of emission speed factor adjustments during the era of EPA's interim conformity rule 1991–1993 and under earlier versions of conformity. During this era, the conformity rule and the emission speed factor adjustments worked together to ensure that new road capacity would be found to increase average motor vehicle travel speeds and reduce vehicle miles traveled and hence reduce air pollution emissions of carbon monoxide (CO) and volatile organic compounds (VOCs) at least by a slight amount (based

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use on EPA's official models), thus sustaining business as usual. However, in 1994, with the final transportation conformity rule, the build-no-build test was extended to also apply to oxides of nitrogen (NOx). NOx generally increase with higher engine speed and efficiency of combustion, thus rising with the higher traffic speeds that usually accompany highway capacity expansion (based on EPA's official models). The final rule thus questioned the wisdom of massive road expansion, especially in areas where NOx controls will be needed to reduce ozone problems. Only now, when emission speed adjustment factors in EPA's emission model have regulatory implications for the addition of new high-speed roadway capacity, are major issues being raised about their scientific basis. There were few complaints when transportation plans passed the test by less than a fraction of 1 percent. Now there is a widespread outcry over transportation plans failing the test by equivalent amounts, although most agencies doing modeling have thus far been able to get around these problems with “just-in-time model enhancements” and the addition of mitigation TDM programs. Now, as this report states about the effects of added highway capacity on the environment and energy use, “No definitive and comprehensive conclusions can be reached . . . the conformity tests . . . will themselves change as the build–no-build test is phased out . . .” (Executive Summary). Indeed, proposals have been introduced in the 104th Congress to repeal part or all of the Clean Air Act including transportation conformity. As the report notes, under current regulations states only need to show that their transportation plan produces emissions less than their adopted transportation emission budget which is part of an acceptable air quality attainment plan. A challenge to the way EPA's build–no-build test has been applied by regional agencies may be deserved. However, millions of Americans with serious respiratory problems that are worsened by motor vehicle-related air pollution breathe unhealthful air 25 years after the first Clean Air Act despite cleaner tailpipes and significant but inadequate progress toward attainment. Our science is adequate to tell us that large-scale highway expansion, even with congestion pricing on new facilities, will not contribute to attainment and maintenance of healthful air compared to alternative investments and policies. This report has gone too far in asserting scientific uncertainty.

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use Real Problems with Build–No-Build As typically applied, the build–no-build test assumes that building major new highways will have no effect on land use patterns, time of day of travel, and often even travel mode or choice of destinations. This is the “fixed demand ” approach to analysis decried by SACTRA. A computer simulation is performed that assumes a fixed pattern of vehicle trip making in a region and two alternative transportation networks: the region 's road system with and without a set of road improvements. The predictable result is that the computer simulation shows that adding lanes or new roads will alleviate congestion; provide shorter, faster travel routes; and reduce the number of miles of driving compared to not building the improvements. Average travel speeds will go up at least slightly with the improvements. And if one believes the speed adjustment factors of EPA's MOBILE emissions model, with the road improvements VOC and CO emissions will go down and NOx emissions will go up, in most cases by much less than 1 percent. It is predictable that most agencies have found “very small differences between the two alternatives [confirming that] current forecasting models cannot reliably estimate differences to that degree of accuracy (Hartgen et al. 1994)” (Chapter 6). Highlight Near-Term Model Reform Needs Indeed, most transportation models in use are little changed in architecture or policy sensitivity from those of the 1970s and 1980s and are generally designed to overestimate the benefits of both highway and transit investment. They ignore urban design, walking and bicycling, hidden transportation subsidies and user costs, the way people plan trip itineraries and make decisions about travel and vehicle use, and the time of day of travel effects. Although some agencies have made improvements to travel models in the past several years on their own, many more have moved only slowly in response to pressure from local and national environmental groups or federal agencies. Few agencies are expeditiously moving toward best practices in the field, such as Portland, Oregon, which is undertaking new activity-based surveys, stated preference surveys, and development of yet more policy-sensitive analysis tools.

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use The committee report might have highlighted the short- and mid-term fixes available to support better conformity analysis. Good discrete choice models based on recent surveys—including total personal travel rather than just motor vehicle trips, with formal or informal accounting for the effects of highway capacity increases on land development, time of day of travel, mode and destination choice—can be developed in any metropolitan region in the span of a year or two with an investment representing a fraction of the cost of a single freeway interchange. Such “better practices” analysis tools can be used to perform far more policy-sensitive build–no-build tests in the near term, which will not be highly accurate or certain, but at least will be more likely to point in the right direction than current analyses. The state-of-the-art of modeling is advancing rapidly in this area, and data collection and research are warranted today for most metropolitan transportation planning agencies to prepare for the next generation of microsimulation-based analysis tools. The SACTRA panel offers useful recommendations for modeling and analysis, including issuance of general advice on good practice in developing models, the auditing of strategic transport demand models to ensure their satisfactory sensitivity “to estimate all the important demand responses to road provision, including trip frequency and choice of time of travel” (SACTRA 1994, 191). Emission models are in critical need of redevelopment with support for research at the national level. Recent EPA and California Air Resources Board (CARB) research shows that the federal test procedure and other drive-cycle based emission estimation approaches do not well match current driving conditions. Significant variability exists in emissions between vehicles undergoing similar speed changes and in the same vehicle under different load conditions. There is consensus within the committee that modal-based emissions models need to be developed to improve the evaluation of the effects of changes in speed, acceleration, and traffic system management, such as ITS, and some work is under way, but could be accelerated. As this report notes, “current models significantly underpredict emissions of some pollutants” (Executive Summary). This is yet further reason to place greater emphasis on the analysis of the emissions impacts of growth in travel demand likely to be induced by highway investment, instead of continuing to focus analysis solely or primarily on emissions impacts

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use related to harder to estimate changes in vehicle speeds that are modified by highway investments. Performance-based funding that gives states flexibility in expending federal funds contingent on meeting key objectives is in place under CAAA and ISTEA with the transportation conformity and management system requirements. Although evaluation tools like MOBILE 5.1 are imperfect, they should continue to be used with caution as the best analysis models currently available to support ongoing public policy making. When needed, ad hoc project-specific methods should be used to complement these tools until better data and software are available. Sound transportation and environmental policy making should focus air pollution control strategies on cost-effective technological controls, such as inspection and maintenance of vehicles and reformulated gasoline, in addition to strategies that reduce the growth in vehicle trip starts, VMT, and motor vehicle dependence. Until we get our emission models more refined, we should focus less on strategies that depend on demonstrating emission reductions on the basis of changes in traffic speed. We should not abandon the analysis of the emissions impacts of alternative transportation investments and policies because of uncertainties about emission changes with respect to speed, accelerations, and other factors. We should improve the quality of performance measurement, analysis, and forecasting systems and expand the range of alternatives considered in the evolving new regional transportation planning process. REFERENCES ABBREVIATIONS OTA Office of Technology Assessment RCEP Royal Commission on Environmental Pollution SACTRA Standing Advisory Committee on Trunk Road Assessment Cambridge Systematics, Inc., et. al. 1992. The LUTRAQ Alternative/Analysis of Alternatives: Interim Report. 1000 Friends of Oregon, Portland, Oreg., Oct., pp. 82, 97–101. Cambridge Systematics, Inc. 1994. Short-Term Travel Model Improvements. FHWA, U.S. Department of Transportation.

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EXPANDING METROPOLITAN HIGHWAYS: Implications for Air Quality and Energy Use Harvey, G. 1993. A Manual of Improved Modeling Practice. Environmental Protection Agency Region IX, Sacramento, Calif. Hook, W., and M. Replogle. 1995. Motorization and Non-Motorized Transportation in Asia: Transport System Evolution in China, Japan, and Indonesia. Land Use Policy (forthcoming). National League of Cities. 1979. Transportation and the Urban Environment. Washington, D.C., p. 32. Newman, P., and J. Kenworthy. 1992. Winning Back the Cities. Pluto Press, Leichhardt NSW, Australia, pp. 39–40. Quoting C. Hass-Klau (ed.), New Ways of Managing Traffic, Built Environment, 12 (1/2), 1986 and T. Pharoah and J. Russell, Traffic Calming: Policy Evaluation in Three European Countries, Occasional Paper 2/89, Department of Planning, Housing, and Development, South Bank Polytechnic London. OTA. 1994. Saving Energy in Transportation. U.S. Congress, July. Parsons Brinckerhoff Quade and Douglas, Inc. 1994. Making the Land Use Transportation Air Quality Connection: Vol. 4B, Building Orientation. 1000 Friends of Oregon, Portland, Oreg., May. Project for Public Spaces. 1992. The Effects of Environmental Design on the Amount and Type of Bicycling and Walking. National Bicycling and Walking Study. FHWA Case Study 20. FHWA-PD-93-037. FHWA, U.S. Department of Transportation, Oct., p. 15. Replogle, M. 1991. Sustainability: A Vital Concept for Transportation Planning and Development Journal of Advanced Transportation, Vol. 25, No. 1, Spring, pp. 3–18. Replogle, M. 1993a. Improving Transportation Models for Air Quality and Long Range Planning Presented at 72nd Annual Meeting of the Transportation Research Board, Washington, D.C. Replogle, M. 1993b. Bicycle and Pedestrian Policies and Programs in Asia, Australia, and New Zealand. National Bicycling and Walking Study. FHWA Case Study 17. FHWA, U.S. Department of Transportation. Replogle, M. 1994. Transportation Conformity and Demand Management: Vital Strategies for Air Quality Attainment. Environmental Defense Fund. Washington, D.C. Replogle, M., and H. Parcells. 1993. Improving Bicycle/Pedestrian Linkage to Transit. National Bicycling and Walking Study. FHWA Case Study 9. FHWA, U.S. Department of Transportation. RCEP. 1994. Transport and the Environment. London, United Kingdom, Oct. SACTRA. 1994. Trunk Roads and the Generation of Traffic. Department of Transport, London, United Kingdom, Dec. U.S. District Court for the District of Northern California. 1990. Declaration of Dr. Peter R. Stopher in Support of Sierra Club's Objections to MTC's Proposed Conformity Assessment. Civil No. C-89-2044-TEH and C-89-2064-TEH (consolidated), Aug. 20 San Francisco, Calif.