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Utahns for Better Transportation
c/o FRIENDS of Great Salt Lake
Box 2655
Salt Lake City, Utah 84110-2655

Mr. Sam Klemm
Wasatch Front Regional Council
295 North Jimmy Doolittle Road
Salt Lake City, Utah 84116

May 7, 2007

Dear Mr. Klemm,

These comments concern the Draft Wasatch Front Regional Transportation Plan 2007-2030 (2030 RTP) and the Air Quality Memorandum, Conformity Analysis for the Updated 2030 RTP dated March 26, 2007. UBET would also like to incorporate the comments provided by the Utah Chapter of the Sierra Club.

Our comments focus on three main concerns. First, is the underlying assumptions built into the travel model. Second, is the investment strategy for transportation improvements. Third, is the air quality impacts of these investments over the next 23 years. In addition, we have a specific project concern on the Mountain View Corridor transportation improvements as presented in the Draft 2030 RTP.

The Travel Model

The WFRC should be commended on its work updating and improving the model but the model is not up to the task of modeling transit or the actions that would be needed to hold vehicle miles traveled (VMT) growth to the population growth rate. On the first page of the Draft 2030 RTP the overview states, "Population along the Wasatch Front is projected to increase by 42 percent between now and 2030. Weekly vehicle miles traveled is anticipated to increase by 70 percent and average weekly delays will increase by 120 percent." The rising growth of VMT faster than the population growth is the main problem we need to address and plan to avoid. It is what causes long term automobile congestion, causes 65% of our areas' dangerous air pollution, and degrades our quality of life. If we attempt to accommodate the "anticipated" 70 percent increase in VMT while population grows by only 42 percent we will be clogging our arteries and shooting ourselves in the foot.

The travel model used to evaluate the impacts of different transportation improvements was developed to size roads to accommodate automobile flow and access. The model has been notoriously unable to accurately predict transit ridership. The model originally predicted TRAX ridership of approximately 16,000 rides per day and with the addition of the University Line it currently provides over 55,000 rides per day.

Part of the problem with the travel model is the fact that a 1993 Home Interview Survey is still being used for data in the model on the purpose and time of trips (Air Quality Conformity p. 12). This data was collected prior to the implementation of TRAX and should not be used to predict our future.

Investment Plan

Overall capital capacity improvements in transportation infrastructure 2007-2030 favor roads over transit, 3 to 1. The total Highway Project Costs are projected to be $14,418 billion and total Transit Capital Costs are projected to be $4,496 billion.

When the citizens of the Greater Wasatch Area voted in November 2006 to increase their own sales taxes by a quarter cent to build transit networks faster, their action demonstrated a sea-change in their preference away from auto-only dependence and toward a balanced transportation system that would offer more mobility and more choices. The public understands the ongoing dividends from investing in a robust regional transit system first that will provide a convenient, reliable and affordable option to always having to take a car.

In 2005 a planning effort involving public, private and community stakeholders developed Wasatch Choices 2040: A Four County Land-Use and Transportation Vision that identified growth principles and implementation strategies based on integrated land-use/transportation planning. This was the precursor to the 2030 LRP. Two of the key principles for transportation planning from that effort are to Develop a balanced multi-modal transportation system and to Support actions that reduce growth in per capita vehicle miles of travel.

In the Wasatch Choices 2040 process four scenarios were developed to define the configuration and measure the performance of various approaches to growth. The report outlined lessons learned from the scenarios such as:

Mixed-use development reduces driving distances and congestion.
Growth near transit opportunities encourages people to ride transit.
People will walk and bike if the trip is short and the design is right.
Transportation choices help determine where growth will occur.
Transit is a key means to reduce congestion during the all-important rush hour.

The 2030 LRP should adopt an investment plan that integrates transportation investments and land use development to reduce the growth of VMT and improve air quality by doing so.

Air Quality

Our area faces particular challenges with air quality because of our location in a mountain valley with robust population growth. Indeed during this past year, Salt Lake County had some of the worst air in the nation – and that pollution comes from traffic. How we grow and how we behave effects our air quality. The Air Quality Conformity Analysis states that a new standard for PM2.5 emissions was established and "It is anticipated that portions of Weber, Davis, Salt Lake and Tooele Counties will be designated as non-attainment areas " under the new standard, but conformity to the new lower standard will not be required until 2011 (Air Quality Conformity p. 19). Instead of waiting for the regulations to take effect we should do it now for the sake our own health.

Mountain View Corridor

In 2003 Envision Utah facilitated the Mountain View Corridor Growth Choices process to run concurrently with Mountain View Corridor Environmental Impact Statement. On March 10, 2004 the various stakeholders endorsed the Mountain View Corridor Vision and each participant signed the Mountain View Vision Voluntary Agreement with the following Principle of Agreement:

Balanced Transportation

We desire a balanced transportation system for our future that will involve more transportation choices. The phasing and implementation of transportation investments over the next decade will effect land use development patterns and therefore affect future travel needs and the availability and effectiveness of other viable transportation choices. The sequencing of transportation investments needs to be studied to recommend the most effective and cost efficient way to meet future travel needs, reduce the rate of growth of vehicle miles traveled, improve air quality through a better balance between auto, transit, walk and bike trips, and to recommend the best way to encourage the types of land uses throughout the corridor that will support these improvements.

The removal of high capacity transit improvements from 5600 West in the Draft 2030 RTP makes it impossible to measure the impact of doing transit first in this corridor. As was just noted in an article in the New York Times, April 22, 2007, A Rail Line Drives Development in Utah, “The existing and planned rail stations offer developers dozens of opportunities to design and build transit-focused home and business districts.” In other words, transit leads development.

In a time of change, the order in which we do things will affect the overall outcomes. The November 2006 vote of Salt Lake (64%) and Utah County (69%) citizens to raise their own sales tax to speed up the implementation of additional TRAX lines in Salt Lake County and complete the commuter rail from Ogden to Provo was a clear demonstration of the public's commitment to transit. People recognized that sooner would be better than later, to influence development patterns and household behavior to achieve a balanced transportation system.Transporation planners and agencies should respect the mandate of the voters to move forward with an emphasis on transit.

Recently completed medical studies in Southern California document the serious health risks of living and exercising close to freeways. The study, Effect of exposure of traffic on lung development in children from 10 to 18 years of age; a cohort study, W. James Gauderman, January 26, 2007 found that children who live within 500 meters of a freeway have a lung function growth rate 11 percent lower than those children who live at least 1500 meters away from the freeway.

The issue of mobile toxins in the air is especially important when school yards and homes are in close proximity to major roadways. Given that the proposed Mountain View Corridor eight lane freeway is proposed to be immediately adjacent to one high school and two elementary schools and hundreds of residential back yards the analysis of health effects on residents cannot be ignored.

Thank you for the opportunity to comment on these important matters.


Roger Borgenicht

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