January 23, 1997

Introduction

The following comments are submitted on behalf of Citizens for a Better Environment (CBE). CBE is a regional environmental non-profit research and advocacy organization with over 8,000 members and thousands more supporters in Wisconsin. The vast majority of CBE's Wisconsin members live in the metropolitan Milwaukee area and will be greatly affected by the decisions made as a result of this study.

The public investment decision made as a result of this study is probably the most important decision public officials will make in this region in the next 25+ years. It is certainly the most important decision from an environmental perspective. This decision will greatly affect the environmental quality and economy of the region and residents' quality of life for many years to come.

We support investment in a starter light rail transit system, improved bus transit service, and reconstruction of I-94 within the current right-of-way after rail transit is in place. We strongly oppose expansion of the highway for special lanes. While not considered as part of the study, there has been recent discussion about commuter rail, which we support as complementary to, but not a substitute for, light rail.

As a region, we have spent the last 50 years building an extensive network of highways and will be spending billions of dollars more in the near future to rebuild these highways. What's needed now is an investment in a high quality transit system that will provide people with convenient transportation alternatives. Investing in transit and doing a better job managing growth are the only ways we are going to provide a long-term solution to congestion problems in the east-west corridor and at the same time maintain and improve the livability of our communities.

We have learned that we can't solve congestion problems by continuing to expand highways. This just encourages more driving and sprawl. And trying to solve what is in essence a land use problem by widening highways results in many significant environmental, economic, and social costs, including reduced air and water quality and associated public health impacts, increased traffic accidents, and increased household transportation costs to name a few.

Just like our environment and economy, our transportation system needs diversity and balance to be healthy. The available federal ICE funding represents a once-in-a-generation opportunity to reverse the decades long trend of neglect of our transit system. This money should be used to build light rail and expand bus transit service.

Comments on Public Participation Process

We are extremely disappointed by the lack of meaningful opportunities for public participation provided by the Wisconsin Department of Transportation (WisDOT). Only two sets of public meetings were held and neither occurred during the critical final 18 months of the study when cost estimates, ridership projections, environmental and land use impacts, and other key information was available. The lack of information prevented the general public and the six community workgroups that were set up from making informed comments on the various transportation alternatives.

The participation afforded the two advisory committees--the Technical Advisory Committee (TAC) and the Study Advisory Committee (SAC)--during the MIS/DEIS phase of the study was even more disappointing. The TAC, which CBE served on, did not meet between May 1995 and July 1996. During this time, WisDOT completed a "working draft" of the DEIS without seeking any technical input from the TAC. WisDOT also prepared and widely distributed a "summary report" of the study entitled "Finding solutions for the East-West Corridor." This report presented an extremely biased and sometimes inaccurate and/or misleading characterization of the study results.

TAC members were quite surprised to learn in May 1996 about the completion of the working draft of the DEIS and the summary report, given that the TAC had simply stopped meeting and had not seen any materials for a year and a half. After being criticized for essentially dropping all public participation, WisDOT agreed to reconvene the TAC and provide an opportunity to critique the working draft of the DEIS. Because of alleged time constraints, however, the opportunity to affect changes was quite limited. In fact, several major substantive changes recommended by TAC members dealing with the safety analysis of the highway "modernization" alternative and a new commuter rail proposal were rejected in large part due to time constraints. This was so despite the fact the alleged time constraints were created by WisDOT's failure to seek TAC review earlier in the study process.

Even more disconcerting is the fact that the Study Advisory Committee (SAC), consisting of elected local officials, did not meet at all during the entire MIS/DEIS process. Apparently, WisDOT did not like the comments and recommendations the department was receiving from the SAC and decided to eliminate it. Without input from the SAC, we have no idea how WisDOT plans to make a determination on the "locally preferred alternative."

Comments on Analysis of Environmental and Land Use Impacts of the Alternatives

1. The induced travel and sprawl impacts of constructing special lanes should have been analyzed and factored into the environmental and cost/benefit analyses.

By far the most important environmental issue associated with the study is the vastly different land use impacts of the different alternatives--in particular the "induced travel" and "sprawl" impacts of building special lanes. The failure to take these impacts of special lanes into account undercuts the credibility of the environmental impacts analyses (e.g., air quality and energy consumption) and the cost-benefit analysis of the different alternatives. By not considering these impacts, the benefits of building special lanes are greatly overstated and the costs (e.g., increased traffic accidents, pollution, etc.) understated.

New or expanded highways attract trips from other routes, times, and transportation modes (i.e., diverted trips). By reducing travel times, they also encourage longer trips. In the long term, highway improvements also encourage auto-oriented sprawl development and reductions in transit service and walking and bicycling opportunities which increase driving, automobile ownership, and reduce travel alternatives. This results in increasing automobile dependency. These combined impacts are called "generated traffic" or "induced travel." (See attached table describing the various traffic impacts of roadway improvements.)

The existence of generated traffic has been proven both theoretically and empirically. For example, U.S. EPA Region IX commissioned a study looking at freeway capacity increases in the San Francisco and Sacramento areas. Among the findings of the study were:

1. Air quality analyses done for the freeway capacity increases contained significant flaws. 2. Traffic projections at the time of freeway planning and construction significantly under-predicted the observed actual volumes following construction. Induced trips or latent demand, "unexpected growth," and other factors were assumed to be the causes. 3. Overall, freeway capacity increases appear not to have had the predicted short-term regional air quality benefits, but instead have likely worsened air quality.

Despite the widespread recognition of generated traffic, most transportation agencies still fail to take generated traffic into account when analyzing the costs and benefits of proposed transportation improvements.

In analyzing proposed transportation improvements, consideration of generated traffic is extremely important for three reasons. First, it erodes much of the predicted congestion reduction, and in the long run can actually increase congestion. Second, the increased travel increases transportation costs such as: traffic accidents; congestion on other roads; parking needs and subsidies; noise, water, and air pollution; and energy consumption. The total of these "external" costs has been estimated at $0.61 cents per mile for urban peak hour travel. Third, generated traffic produces relatively less benefits (for drivers) than existing trips (since these are trips people are willing to forego under more congested conditions).

The amount of generated traffic from increased highway capacity is very large. Research indicates that in most cases only about 50% of travel time savings predicted for highway expansion projects exists within ten years after construction. In highly congested urban areas, half of added capacity can be filled within two years and nearly all new capacity can be filled within twenty years. A National Highway Institute transport investment guide recommends a default value of -0.5 for the elasticity of highway travel demand with respect to user costs (i.e., the percent change in demand due to a percent change in travel time or financial cost). Based on the available research, Litman has prepared the following graphic illustrating the likely range of generated traffic on a highway after a capacity increase:

Generated traffic impacts occur regardless of whether the additional traffic lanes are for "high occupant vehicles." HOV lanes increase capacity and therefore stimulate additional driving. And because HOV lanes benefit primarily long distance commuters, they encourage housing and job choices that require long commutes.

A 1992 study by the U.S. EPA analyzed the effects of construction of a 334 mile HOV system in the Washington, D.C. metro area and concluded that even in the short run it would result in an overall reduction in vehicle miles traveled (VMT) of only 0.5%. A 1988 report by the Institute of Transportation Engineers (ITE) on U.S. HOV lanes does not make any claims that new HOV lanes actually reduce VMT. The agencies that operate the twenty (20) HOV facilities studied claimed VMT reductions or air quality improvements only for those facilities that were converted lanes or were bus- or bus- and van-only facilities (unlike the carpool/bus lanes proposed by WisDOT).

In Houston, construction of HOV lanes has not resulted in any improvement in traffic flow--traffic volumes on the general purpose lanes are higher now than they were before addition of the HOV lanes. I-394 in the Twin Cities area was carrying traffic at levels predicted for the year 2000 within a few weeks of opening in 1992 after construction of HOV lanes. Even though the transportation modeling cannot fully account for induced demand, WisDOT's own data show that travel times in the general purpose lanes would be longer in 2010 if special lanes were built than if the highway was reconstructed as is with only spot improvements.

To its credit, WisDOT did undertake an analysis of the positive land use development impacts of the light rail alternatives. Their analysis concludes that investing in light rail could produce up to 11,000 new jobs and 1,200 new residential units in areas surrounding the rail transit stations.

WisDOT, however, does not make any attempt whatsoever to address the generated traffic impacts of the special lane alternative. WisDOT merely makes a few statements about the possibility of special lanes increasing development pressures in areas not planned for future urban development. WisDOT says it is simply a matter of local land use policy whether such planned development is permitted. This standard response ignores the fact it is almost impossible for local governments to effectively enforce land use controls in the face of strong development pressures caused by the increased accessibility of undeveloped land due to new or widened highways. In practice, land use management techniques are seldom completely effective.

Given the widespread acceptance in the professional transportation planning and engineering communities concerning the induced travel and sprawl impacts of expanding highways, the available research, and the policy and planning directives of ISTEA, it is simply unacceptable for WisDOT to continue to ignore this issue in environmental reviews of major highway expansion projects.

WisDOT's failure to undertake any type of land use impacts analysis of special lanes contrasts sharply with the recently completed EIS/Supplemental EIS for the Highway 12 project in Dane and Sauk Counties. Due to pressure from federal and state agencies and interest groups, WisDOT undertook a relatively sophisticated analysis of the potential land use impacts of expanding the highway from two to four lanes. This included a commuter distribution analysis, a travel time analysis, and a regional growth analysis. The results indicated that expanding the highway would increase sprawl development in the study area by 4% over projections made by the Wisconsin Department of Administration.

We believe the analysis of the indirect land use impacts from the Highway 12 project was flawed in several respects and therefore greatly underestimates the impacts. The important point, however, is that WisDOT recognizes in the Supplemental EIS that some sprawl development impacts will indeed occur and that methodologies do exist for estimating the range of those impacts. Why then was the issue brushed aside in the East-West Corridor Study EIS?

What little discussion there is in the EIS of "secondary and cumulative impacts" focuses entirely on the corridor. Yet the impacts will be felt well beyond the corridor. By expanding the capacity of the highway and initially reducing travel times, the special lanes will increase the "commuter shed area" into Waukesha and Milwaukee County job centers and thereby increase exurban development pressures in much of Waukesha County and parts of Jefferson, Washington, and possibly Dodge Counties as well.

A recent major UK study, which led to a drastic scaling back of proposed highway improvements there, concludes, among other things, that land use changes consequent on improved access are likely to lead to changes in the patterns of travel, car dependence, and the volume of travel. The UK study found that induced traffic is of greatest importance in the following circumstances, among others:

(1) where the network is operating or is expected to operate close to capacity; and (2) 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.

This is precisely the situation in the Waukesha-Milwaukee east-west corridor. Based on this finding, the study states that transportation agencies should be most careful in analyzing induced travel and land use impacts for road improvements in and around urban areas, among others. Again, this is the situation in the east-west corridor. The study goes on to say:

Studies we have reviewed demonstrate convincingly that the economic value of a [highway improvement] scheme can be overestimated by the omission of even a small amount of induced traffic. . . . 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 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.

The "fixed demand approach" is precisely the approach that SEWRPC and almost all MPOs use, because they do not have land use allocation models which predict land use changes due to changes in accessibility of areas. Therefore, future land use is simply treated as a given (i.e., fixed) in the transportation modeling process. This, along with the short time horizon for evaluation, are the reasons WisDOT can claim that special lanes (Alt. 6) reduce vehicle miles traveled (VMT) the most of any of the alternatives.

In the long run, however, building new or widened highways does not result in time savings for people, because they simply use the temporary time savings to travel further (e.g., choosing to live further from their job) and make more trips. This is evidenced by the fact that total per capita vehicle and passenger hours are much higher in U.S. and Australian cities (where average road network speeds are high) than in European and Asian cities where traffic is much more congested. It is also evidenced by an exhaustive study done by Newman and Kenworthy, which found free-flowing traffic does not lead to savings in fuel or time, or lowering of emissions in a city overall.

2. The air quality impacts analysis is incomplete and is flawed by the failure to consider generated traffic.

The air quality analysis is flawed due to the short-term time horizon used (Year 2010) and the failure to factor in generated traffic (i.e., use of the fixed demand approach). The analysis also does not factor in emissions from auto trips to park-n-ride lots.

The microscale air quality analysis only estimates CO concentrations at various locations. The DEIS fails to mention that light rail, because it is electric, will greatly improve microscale air quality in the city, especially for particulate matter (PM). This is particularly important given the new data on the health impacts of PM and the new EPA proposed health standards for PM (2.5).

The DEIS fails to analyze greenhouse gas (GHG) emissions at all despite increasing interest and concern over this issue. For example, the Wisconsin Department of Natural Resources (WisDNR) is finishing up a GHG study, looking at potential state policy initiatives.

3. The energy analysis is flawed by the failure to consider generated traffic.

As with the air quality analysis, the energy analysis is flawed by the failure to consider generated traffic. This greatly overstates the benefits of the special lane alternatives and understates the benefits of the light rail transit and no build alternatives.

The DEIS should also at least mention that analysis only deals with long trips on arterial roads and short (walk, bicycle) trips are excluded from the analysis. These trips are not insignificant given the projected potential development around the light rail transit stations.

The assumption in the analysis of improvements in motor vehicle fuel efficiency by 2010 is very questionable, given recent trends.

4. The analysis of visual impacts does not adequately describe and illustrate the impacts of the highway modernization and special lanes alternatives.

The DEIS seems to downplay the negative visual impacts of the highway modernization and special lane alternatives. This seems to be due in large part because the new and/or expanded highway will follow along the existing right-of-way. However, the special lane alternative will substantially increase the size of the highway and increase the height and mass of the interchanges. The DEIS fails to adequately describe or illustrate the negative impact of highway modernization and special lanes on properties along the corridor. Comments Concerning the Alternatives and the Special Lanes Demand Analysis

1. The DEIS fails to consider the alternative of not rebuilding I-794, but instead turning the elevated expressway into one or two high-volume, one-way, at- grade boulevards.

Several members of the Technical Advisory Committee and various public officials asked WisDOT to undertake a preliminary traffic engineering study to look at the feasibility of converting the elevated I-794 expressway into a high volume, at-grade boulevard. WisDOT refused to make any effort at all to explore the boulevard proposal, despite the potentially huge cost savings and the positive long-term property value, redevelopment, and job creation benefits for the City of Milwaukee and region as a whole. This proposal should be examined prior to initiation of preliminary engineering on the Marquette interchange reconstruction project.

The boulevard idea originated out of a design studio project and subsequent workshop conducted by Peter Park, a former design consultant and adjunct professor at the University of Wisconsin-Milwaukee School of Architecture who is now the Director of Planning for the City of Milwaukee. The studio project and workshop explored the transportation, urban design, redevelopment, tax base, and job creation issues associated with the boulevard proposal. Following this analysis, a variety of detailed corridor redevelopment scenarios were prepared. (See attached cover, table of contents, and preface of the report. The preface is a reprint of a newspaper article written by Peter Park that appeared in the Milwaukee Journal Sentinel.)

The boulevard proposal is not farfetched by any means. It certainly deserves at least a preliminary investigation rather than being dismissed out of hand. High traffic counts at the Marquette interchange (35,130 ADT eastbound, 38,390 ADT westbound) drop off sharply east of the interchange (11,870 ADT eastbound, 14,110 westbound) as most traffic follows I-43 north or I-94 south. The boulevard proposal has the potential to actually relieve congestion problems by creating multiple access points and distributing traffic closer to points of origin and destination. If necessary, an alternative to a single boulevard is two 3-4 lane one-way boulevards.

2. The expanded bus alternative is unrealistic and distorts the analysis of the other alternatives.

We share the concerns of the Alliance for Future Transit (AFT) that the expanded bus option--Alternative 2--is highly unrealistic and would not be cost effective. The alternative calls for a 59% increase in revenue vehicle miles and a 46% increase in revenue vehicle hours in the seven-county SEWRPC region. The additional annual operations and maintenance costs of this huge bus service increase would be $42 million in 2010--almost three times the total for light rail. Three-quarters of the bus service expansion would occur outside the east-west corridor.

Use of this unrealistic bus expansion alternative makes evaluation of the build alternatives difficult and prejudices the light rail alternative in particular. Sensitivity analyses done by SEWRPC using more realistic bus expansion alternatives show that Alt. 2 produces a negative impact on light rail ridership and an extremely positive impact on special lanes ridership.

3. The assumptions about future carpool demand for the special lane alternative are highly questionable.

In estimating future special lanes ridership, WisDOT assumes that 10-15% of all non-transit vehicles using the highway will be carpools. This range is used despite the fact that the percentage of carpoolers decreased from 23% to 10% from 1980 to 1991. Given this decrease and the sharp decline in carpooling projected for 2010 (606,000 to 506,000) even with construction of HOV lanes, there is no justification for using carpooling numbers that meet or exceed today's levels.

WisDOT also assumes that only 20% of the existing carpool vehicles would remain in the general purpose lanes following special lane construction. No analysis was done to arrive at this number. Because of the limited ability for vehicles to access the special lanes from western Milwaukee County to downtown, the 20% figure appears to be very low.

The benefits of the special lane alternative is also skewed by the addition of a new bus route--"Route A"--for that alternative to connect low-income "reverse commuters" from Milwaukee to jobs in Waukesha County. It appears that this bus route was put in to make special lanes appear better from a transportation and an environmental justice standpoint. However, special lanes are not needed to justify this bus service.

Comments Concerning Operational and Safety Issues

1. The safety analysis of the highway modernization alternative is inadequate.

The transportation modeling shows the highway "modernization" alternative increases travel times compared to the "rebuild with spot improvements" alternatives. Thus, the only justification for investing the necessary $575-998 million to completely "modernize" the highway rests with the alleged safety improvements.

We agree with the comments of AFT concerning the gross inadequacy of the safety analysis done for the complete modernization alternative. Since the alternative will not increase the spacing between interchanges--one of the most important causes of high accident rates--there are serious questions concerning WisDOT's projected safety improvements. The generalized sort of analysis done without looking at actual I-94 accident data is simply not sufficient given the huge potential cost involved. In addition, there is no way to determine the safety benefits of the spot improvements and other measures (such as better signage) compared to the complete modernization alternative.

2. The traffic impacts during highway reconstruction are not adequately addressed.

We agree with the concerns raised by AFT in their comments about the inadequacy of the analysis of traffic impacts during highway reconstruction.

Reasons Why Light Rail Transit Should be Selected Over the Special Lanes Alternative

1. Special carpool/bus lanes simply don't work and are not cost-effective.

"High occupancy vehicle" (HOV) or "special" lanes are promoted as a way to lure motorists into carpools. However, the potential 5-10 minute time savings is not sufficient incentive for most people to give up solo driving. Even that modest time savings is usually lost due to the time involved for gathering and dispersal trips of carpoolers at both ends of the commute. This is supported by the travel forecasting done for the study.

Even without addressing the issue of generated traffic, the DEIS concludes that special lanes are the least cost effective of the different alternatives in terms of generating new transit riders and in terms of travel time savings--almost three times less cost effective than light rail.

According to the transportation modeling done by the Southeastern Wisconsin Regional Planning Commission (SEWRPC) for the study, construction of special lanes (Alternative 6) would result in a seven (7) minute travel time savings compared to the general purpose lanes over the entire twenty (20) mile route (STH 16 to Lincoln Memorial Dr) in the year 2010. The vast majority of people not traveling the entire distance on the special lanes would obviously experience less time savings than this. It is estimated that this time savings would attract 1,000 more carpool passengers over the "base case" scenario (Alternative 2) with improved bus service only. While the number of new carpoolers is quite small, even this estimate is questionable, given that the extra time for gathering and dispersal trips is not factored in. Overall, carpooling is still expected to drop significantly from 606,000 in 1990-1991 to 506,000 in 2010 even if the special lanes are built.

One of the criteria that the Federal Transit Administration (FTA) uses to determine whether investment in HOV lanes is justified is whether the lanes result in a one minute per mile time savings for carpoolers. The study shows this criterion is not even close to being met even when adding the additional forecasted traffic between now and 2010. This raises a serious question of whether the FTA would approve funding for the HOV lanes, even if Alternative 6 was selected as the locally preferred alternative.

Because of limited time savings from their HOV lanes, officials in Minneapolis have had to resort to highly subsidized downtown parking ($10/month) in an attempt to lure people into carpooling.

Because carpoolers and "freeway flyer" bus riders rely heavily on park-n-ride lots for gathering of carpoolers and bus access, households must still generally own a car for every member that works. In the case of transit, this means people must pay for transit and an extra car (at an average cost of $3,000 to $6,000 per year) for transit. Experience has shown that once people get into their cars it is difficult to get them out.

It should be noted that the Federal Highway Administration has insisted in the past that construction of 2+ occupant HOV lanes (the policy proposed for I-94 HOV lanes if built) "accomplishes little more than rearranging traffic in lanes according to the number of occupants" because, while vehicles using the HOV lane may increase, "this is offset by a decrease in the average vehicle occupancy in the other lanes."

WisDOT and other HOV lane proponents claim that the required number of carpool passengers can be raised in the future (from 2+ to 3+) if the HOV lane becomes congested. This is highly problematic, however, as it penalizes those who complied best with the original goals. We are not aware of any cases where a more restrictive HOV policy has been instituted. It is always the reverse. In addition, it is much more difficult to arrange 3+ carpools due to the longer time for gathering and dispersal trips which often wipe out any time savings.

2. HOV lanes provide only limited short-term congestion reduction benefits in contrast with the multiple long term benefits of rail transit.

HOV lanes provide at best only short-term peak hour congestion reduction benefits. According to the study, the proposed HOV lanes on I-94 wouldn't even do that. Travel times on the general purpose lanes would be longer. HOV lanes do little or nothing to promote downtown revitalization, encourage more efficient and less auto-dependent land use patterns, improve community livability, and offer attractive transportation choices for people without access to a car. In fact, in the long run HOV lanes tend to work at cross purposes with all of these goals. A Houston study found that their 25-mile HOV lane system there has had no significant positive impacts on land use around stations.

In contrast, light rail, in combination with supportive land use policies, can promote compact, mixed-use development around transit stations. These "transit-oriented developments" (TODs) offer many benefits, including: neighborhood revitalization; increased property values; retail opportunities; affordable housing opportunities; increased accessibility; and creation of focal points for community life. Because light rail is electric and much quieter than buses, it is also the most compatible with active pedestrian environments. For examples of TOD possibilities, see CBE model development plans for the Capital Court Shopping Center and the West Campus area of the Milwaukee Regional Medical Center.

The DEIS estimates that development around light rail stations could provide up to 11,000 new jobs and 1,200 new residential units in these areas. HOV lanes are not expected to have any significant positive land use development impacts.

3. HOV lanes benefit only long distance commuters, primarily those living in suburban and rural Waukesha County.

Drivers must save at least ten minutes on a trip before bothering with carpooling. Trips must be generally 30 miles or more to save that much time. This means the people who will primarily benefit from HOV lanes are commuters living in suburban and rural Waukesha County. In other words, HOV lanes will add yet another to the long list of current subsidies for sprawl to which city and inner suburb residents contribute.

"Reverse commuters" going to jobs in Waukesha County would realize limited benefits from special lanes if bus service were initiated to service these trips. However, central city residents and the poor would benefit much more from light rail construction and improved bus service. These transit improvements will offer a transportation alternative for many more trips to many more places for over 80% of the downtown and west side residential households which own one or no cars.

4. HOV lanes provide a benefit only for some work trips, while light rail would offer an attractive transportation alternative for trips at all times of the day and on weekends.

HOV lanes serve almost exclusively commute trips--a declining percentage of overall tripmaking--and provide little benefit for trips at other times of the day, including weekends, and for special events. By contrast, the DEIS estimates light rail would attract an additional 3,700 daily transit trips due to special events and "non-home-based" tripmaking (e.g., from work to lunch or to do errands).

In the Twin Cities area, some HOV lanes are restricted only three hours each workday or fifteen hours per week. Thus, they serve as a general capacity increase 91% of the time. HOV lanes reduce congestion during special events only marginally, if at all, since carpooling to such events has always been common. The result is still congestion, pollution, and accidents.

5. Construction and operation of HOV lanes will be more expensive than rail transit alternatives.

The DEIS estimates capital costs for the entire 22-mile light rail system (Alternative 3-LRT A) at $607.3 million (or $27.6 per route mile). This is probably high, given capital costs of other systems. The St. Louis starter light rail system was built for around $19.5 million per route mile, including shops and cars. The cost of the Sacramento and San Diego systems was even less. Costs could be cut dramatically if a hybrid commuter/light rail system were constructed as proposed by Alliance for Future Transit (AFT). Despite the inflated price tag, light rail is still a bargain compared to special lanes, which are projected to cost around $1 billion!

Combined with the many benefits light rail provides that special lanes don't and the negative community and environmental impacts of special lanes, light rail is a much more cost effective and productive investment. The cost-effectiveness of light rail in attracting new transit riders--the annual cost-effectiveness index (CEI)--is $38.14 per additional rider compared with $102.13 for special lanes. Sensitivity analyses done indicate the CEI for light rail could be as low as $25.38. The extremely high CEI for special lanes is one of several reasons the FTA is unlikely to approve federal funding of them.

The operational and maintenance (O/M) costs of light rail also compare favorably with special lanes when one factors in the estimated $7 million in lost property tax revenues due to construction of special lanes. (Construction of light rail would cause some lost property tax revenues, but most of the projected loss would occur only if light rail were routed along Fond du Lac Ave., which is highly doubtful.) The DEIS estimates annual O/M costs for the light rail option (LRT A) of $151.3. Special lane costs are estimated at $146.1. Adding the $7 million lost property tax revenue boosts that up to $153.1 million. These figures don't include the hefty private costs of driving (44-67 cents per mile). While this cost doesn't translate into increased taxes, it is nonetheless a real cost for the region's households and businesses and it hurts the region's economic competitiveness.

In the long-term, O/M costs for expanded rail service will compare even more favorably to a bus only system with special lanes serving low density, auto-oriented development in the outer suburbs.

From an operational cost standpoint, rail transit is generally less costly to operate than bus transit. For example, the 1994 Federal Transit Administration Section 15 data shows rail moves people at 38% less cost than bus. Rail vehicles also have a much longer vehicle life. Part of the cost difference is the higher ridership usually generated for rail vs. bus service. In Pittsburgh, which has a busway and a light rail line, light rail ridership increased substantially every year while busway ridership decreased. The rail gains stopped when they put a penalty fare on peak light rail travel to keep the buses from running empty. The higher rail ridership was not due to better routes. The rail line had much higher "annual rides per capita" than any of the bus lines the same distance from downtown.

6. Special lanes will require huge amounts of new concrete, displace more businesses, and reduce property values along the route.

"Modernization" of the interstate and construction of the special lanes will require a significant amount of land and massive amounts of concrete. Many businesses and jobs will be displaced. The increased noise, higher structures, etc. will reduce the property values of land along the corridor.

Light rail, on the other hand, will substantially increase the value of properties near the transit stops. A 1995 report by Economics Research Associates documents significant increases in property values for apartments and condominiums and commercial retail properties located near rapid transit stops. Rents for office and retail businesses increased substantially the closer the building was to a transit stop. A 1987 study by the Joint Center for Urban Mobility Research at Rice University looked at ten cities and found that the total increase in land value due to the introduction of rapid transit had been significant, in many cases exceeding the total construction costs of the transit system investment.

7. HOV lanes provide at best limited benefits to the transit system and may actually reduce ridership.

Special lanes on expressways do not work well for transit. Because they are on the expressway, they miss areas of high transit demand. Picking up and discharging passengers at either end of the commute requires buses to enter heavy general purpose traffic. HOV lanes provide limited passenger pick up points. Stops offer little passenger convenience and safety. Most are too difficult and unpleasant to walk or bicycle to.

The advantages of bus-only lanes are significantly reduced or lost when they are opened to carpoolers. Upon opening of HOV lanes, transit ridership has often dropped with former bus riders becoming carpoolers. For example, a 20-year Sacramento, CA study of new HOV lanes found that an average of 8.4% of actual HOV lane users in 10 HOV lane projects previously rode transit. In contrast, rail transit can reduce bus service costs, particularly in suburban areas, by having buses feed into it.

HOV lanes also tend to increase operational costs for transit systems. The longer "freeway flyer" routes are often the worst money-losers for transit agencies. They depend on the shorter local routes which have a much higher farebox recovery. For example, the subsidy per passenger for buses that use Houston's HOV system was over twice that of the city's regular transit bus service. Funding for the long routes ends up siphoning off money from the short routes--used by many urban residents, especially the low-income, which receive little, if any, benefit from expressway HOV lanes. Bus-only curb lanes on arterial streets and other transit priority measures are the most helpful to these routes.

While the benefits of constructing HOV lanes are largely dependent on bus transit service improvements, WisDOT has indicated it will not assist in funding any of these costs of improved bus service. It is easy for WisDOT to push construction of an enormously expensive special lane system (with lots of federal dollars) while relying on local governments to come up with the funding for costly long haul bus service in years to come.

The problems and negative impacts to the transit system associated with HOV lanes are the reasons why both the Milwaukee County Transit System and the transit union favor the rail transit alternative.

8. HOV lanes face constant pressure to be opened to general traffic all the time, and there is no way to prevent this from happening.

HOV lanes face constant pressure of being opened up to general purpose traffic (at non-peak times or all the time), and there are no currently available mechanisms to ensure against such "backsliding." Such "backsliding" has occurred in a number of cities, including Atlanta, San Francisco, and San Diego. In Atlanta, an extensive HOV system was planned back in the 1970s. In the end, none of the new expressway lanes built were made HOV. On the Dulles Toll Road in Virginia, HOV lanes were converted to general use lanes within a month after opening.

9. Enforcement for HOV lanes is costly and difficult.

Violation rates have been very high (45% to 80% in some cases) in many cities with HOV lanes, such as Minneapolis and Orlando. The usual policy of allowing general purpose traffic on HOV lanes increases enforcement problems. The DEIS projects HOV lane enforcement costs of $80,000 annually based upon experience in other cities. It is not clear how much of this enforcement cost would have to be borne by Milwaukee and Waukesha Counties. Even aside from the issue of cost is the issue of whether the political will exists to support the strict enforcement and heavy fines necessary to achieve a high level of compliance.

10. HOV lanes create safety traffic problems.

HOV lanes are typically located in the median. This requires users to cross several lanes of traffic--which are likely to be seriously congested--to enter and exist the highway system where separate on and off ramps are not provided. The need for this type of vehicle movement is the same reason WisDOT claims all of the left exit and entrance ramps must be removed.

HOV lanes that are not barrier-separated have higher accident rates than general purpose lanes. While WisDOT currently proposes barrier-separated lanes, the high cost of such design has led WiDOT to say this design may be scrapped. There is nothing preventing WisDOT from doing so if the HOV lane alternative is selected. Barrier-free HOV lanes substantially increase enforcement problems and the possibility the lanes will be opened to general purpose traffic. Once opened up, any benefits of the lanes in terms of promoting carpooling and transit use are lost.

11. Other carpooling incentives will be more effective and much less costly.

As part of its regional transportation plan, SEWRPC has recommended installation of metered ramps with HOV bypasses for more than twenty years, along with other traffic management strategies. However, only a small fraction have been constructed. Yet at least one demonstration project in California found that HOV bypass lanes, in combination with the timing of ramp meters to which general purpose traffic was subject, gave more time savings to HOVs than did the converted freeway lanes themselves. This led to construction of hundreds of such queue bypass lanes in southern California.

Ramp meters, parking policies, employer programs, and other demand management techniques provide a much more cost effective solution for encouraging carpooling. Surveys indicate that most people who use HOV lanes do so because ridesharing saves them money, not because HOV lanes speed their commuting.

12. The market for ridesharing is likely to continue to decline.

For many reasons, the market for ridesharing is likely to continue to decline. The extra mileage and time involved in picking up passengers makes carpooling inconvenient. This problem will get worse with continuing low density, single-use, decentralized land use patterns--something special lanes will actually encourage. Ridesharing requires adherence to a rigid schedule--often making it the least flexible transportation alternative. Staggered work hours--another strategy to reduce peak hour congestion--would interfere with the formation of carpools. Another serious obstacle to promoting carpooling is the need for carpoolers to know and feel comfortable with the driver and other passengers. Carpoolers are reluctant to rideshare with someone they don't know and feel comfortable with.

For these and other reasons, there has been a sharp decline in carpooling. Nationally, between 1980 and 1990, 2-person carpools decreased 10%, 3-person carpools decreased 40%, and 4-person carpools declined by over 50%. During the same period, public transit lost only 100,000 riders nationally compared with 4 million lost carpoolers. Under the "no build" alternative, daily carpool use in southeastern Wisconsin is expected to drop from 606,000 to 506,000 passengers in 2010, while transit ridership is expected to decrease a small amount from( 154,000 to 139,000 daily trips).

13. Construction of HOV lanes rather than a starter rail transit system will leave commuters without a convenient transit alternative during the years of reconstruction of the interstate.

Construction of a starter rail transit system in the east-west corridor would provide a fast, convenient transit alternative for commuters during the estimated 10+ years of work reconstructing I-94 and the interchanges. Without a rail alternative, it will be very difficult to lure commuters onto buses since they will still be stuck in the same traffic congestion with all the motorists. WisDOT estimates that a west light rail line would attract a minimum of 3,000 additional transit riders compared with a bus only system during I-94 construction. Many may choose to continue taking light rail after highway construction is finished.

14. Use of available funding for HOV lanes will allow public officials to evade a serious commitment to a high quality public transit system and redevelopment goals for another generation.

The available federal funding for the east-west corridor represents a once in a lifetime opportunity and a huge public investment. The decision on how to use the money will have a huge impact on future growth and quality of life in the region. Investment in HOV lanes would mean continuing the current direction of sprawl, auto dependency, environmental degradation, central city and suburb decline, and loss of regional economic competitiveness. Investment in rail transit represents a decision to change current sprawl trends and make a serious commitment to: continue revitalizing downtown; redevelop "brownfields"; provide people with true transportation, housing, and neighborhood choices; enhance the livability of existing communities; improve air and water quality; and promote efficient development all of which will guarantee the long-term economic competitiveness of the region.

Respectfully Submitted,

William Schaefer, Staff Attorney/Planner Citizens for a Better Environment 152 W. Wisconsin Ave., Suite 510 Milwaukee, WI 53203 PH (414) 271-7280 FAX (414) 271-5904