COMMENTS OF THE UTAH MANUFACTURERS ASSOCIATION,UTAH INDUSTRY ENVIRONMENTAL COALITION, UTAH MINING ASSOCIATION, AND UTAH PETROLEUM ASSOCIATION ON THE DRAFT WASATCH FRONT URBAN AREA LONG RANGE TRANSPORTATION PLAN FOR 2002-2030, TECHNICAL REPORT 40 (OCT. 2001)
Friday, October 05, 2001
The Utah Manufacturers Association, Utah Industry Environmental Coalition (consisting of Alliant Techsystems, Brush Wellman, Inc., Kennecott Utah Copper Corporation, Autoliv ASP, Inc. and Questar Corporation), Utah Mining Association and Utah Petroleum Association (collectively "INDUSTRY") appreciates the opportunity to present comments on the Draft Wasatch Front Urban Area Long Range Transportation Plan 2002-2030, Technical Report 40 (Oct. 2001) ("LRTP"). INDUSTRY recognizes the challenge confronting the Wasatch Front Regional Council ("WFRC") to undertake long range transportation planning in one of the fastest growing regions of the country. INDUSTRY commends the WFRC for proposing additional light rail spurs in the Salt Lake Valley and a regional commuter rail system. Utah’s business community as well as its citizenry have been pleased by the extraordinary success of the TRAX system at meeting travel needs and reducing automobile dependency. Nevertheless, INDUSTRY respectfully submits these comments to address aspects of the LRTC which must be improved if meeting future transportation needs along the Wasatch Front is to occur in a way that will not diminish the quality of life and potential for continued economic growth. INDUSTRY notes that these comments are consistent with the position taken by business and industry coalitions in Atlanta, Huston, Phoenix and elsewhere.
The LRTP observes that air quality in the Salt Lake and Davis County airshed has improved over recent years and primarily credits reductions in motor vehicle emission for this improvement. See LRTP at 42 ("Monitoring of air quality in these areas for the last 10-15 years has shown a steady improvement in air quality. No violations of the standards for CO, PM-10 or ozone has occurred for several years. . . . Emission testing and maintenance of automobiles as well as emission standards for automobiles has played a significant role in achieving and maintaining healthy air"). Unfortunately, the LRTP fails to mention that emissions reductions from major stationary sources accounts for the vast majority of improvement in air quality in the region. It is true that emissions on a per vehicle/per mile basis have steadily decreased due to cleaner fuels, inspection and maintenance ("I&M") programs, more efficient engines, and retirement of older, less efficient vehicles. However, the overall contribution of emissions of mobile sources has steadily increased due to the increase in the number of automobiles on the road and corresponding increase in vehicle miles traveled ("VMT") and vehicle hours traveled ("VHT"). There can be no dispute, based on emissions inventories and other data compiled by the Division of Air Quality, that air quality improvements in the last decade have originated largely from emissions reductions from major stationary sources. WFRC’s analysis consistently fail to acknowledge this fact.
More importantly, the LRTP fails to address the grave consequences of the fact that emissions from mobile sources (along with VMT/VHT) have steadily increased at a rate faster than population growth. Indeed, the LRTP is expressly designed to satisfy travel demand that is increasing at rates significantly higher than the population.(Note 1) Because emissions from mobile sources continue to increase in excess of their emissions budget, mobile sources emissions will eventually offset or "consume" the emissions reductions achieved by industry. This could result in violations of the National Ambient Air Quality Standards which could have dire consequences on industry and economic growth. While major stationary sources achieved dramatic reductions in emissions in the recent past, future significant reductions are simply infeasible. Increasing emissions from mobile sources could limit or eliminate the ability of present and future industrial expansion, including construction of additional power generation capacity along the Wasatch Front. Transportation planners appear not to understand this basic concept.
However, the Utah Division of Air Quality and Envision Utah acknowledge these facts. "Currently air quality concerns can be summed up in three words: too many cars. For example, vehicles contribute more than 50% of the pollution emitted along the Wasatch Front. . . . Overall population growth along the Wasatch Front is expected to continue. Added growth without behavioral change will result in increased vehicle use, leading to worsening air quality levels. . . . At the current rate, vehicle use along the Wasatch Front will almost double in the next 20 years."(Note 2) Envision Utah has published similar reports, recognizing that future reductions in emissions cannot come from industry: Envision Utah calls for a growth and transportation strategy that would reduce emissions from mobile sources because industry has already been "very successful in reducing industrial emissions and in helping the region meet the federally mandated air quality requirements. Therefore, further reductions from industry will be minimal and it will be important to achieve further mobile emission reductions . . . to help the region maintain compliance with these standards."(Note 3)
Assumption Concerning Travel Demand
The LRTP calls for an extraordinary expansion of highway capacity to meet projected travel demand (based on the assumption that travel demand will increase at a rate faster than the population rate) without any consideration of means to reduce the rate of travel demand increase. In contrast, the long range transportation plans of most other metropolitan communities include the express objective of reducing automobile dependency and, therefore, travel demand. One academician has noted that since 1992 virtually all urban transportation plans and policies attempt to achieve the "containment or reduction of the total volume of traffic."(Note 4) Other communities facing similar growth patterns have achieved remarkable success in reducing travel demand (VMT) while maintaining a growing population and robust economy.(Note 5) Similarly, Envision Utah calls for a shift in transportation priorities from highway capacity expansion to greater reliance on transit to meet future travel demand and quality growth strategies. The "Quality Growth Initiatives" advocated by Envision Utah would reduce vehicle miles traveled by 3.5%, cut the average commute time by 5.2%, and increase transit usage by 37.5%. Transit system improvements would result in a reduction in road spending of approximately $3.5 billion and an increase in transit spending of $1.5 billion for a net savings of $2.0 billion.(Note 6) Even though citizens and businesses overwhelmingly support these goals and proposals, the LRTP constitutes a de facto rejection -- without explanation -- of Envision Utah’s initiatives.(Note 7) INDUSTRY recommends that WFRC assess the potential reduction in VMT and overall travel demand that will be achieved from planned implementation of Envision Utah’s Quality Growth Initiatives and greater reliance on transit to meet future travel demand.
A More Balanced Transportation System Will Help Safeguard Our Economic Strength
The asset of highest value which Utah has to attract and retain business is our quality of life, combined with economic strength and educated workforce. That quality of life and our economic strength will be jeopardized if we fail to maintain or improve air quality, and provide our citizens with viable transportation options. Other similarly situated communities have achieved a more balanced transportation system. By 1997, Denver’s transit system had achieved a commuter ridership of 30% (even before Denver constructed its new light rail spur in the southeast corridor).(Note 8) The Denver metropolitan area is geographically far more dispersed and, therefore, less suitable for transit systems than the linear configuration of the Wasatch Front. Yet, WFRC and state highway planners recently estimated that a mere 12% of commuters along the Wasatch Front’s north corridor will use transit by the year 2020.
Again, INDUSTRY commends WFRC, Utah Transit Authority ("UTA") and the Utah Department of Transportation ("UDOT") for the highly successful TRAX system, but recommends that WFRC undertake the following analysis as part of the LRTP as part of an effort to increase transit ridership, and to reduce travel demand (and, therefore, reduce VMT and emissions from mobile sources):
Robust Transit. What kind of regional transit system would be needed to achieve ridership levels similar to those achieved by Denver?
Integration. Determine how existing and future transit and highway systems can be integrated. For example, currently no park and rides exist or are planned for the highways in the north corridor despite the popularity of express buses. Similarly, park and rides for the existing TRAX system are undersized, likely resulting in a significant loss of ridership. WFRC should include in the LRTP adequately sized park and rides for current and future transit and highway systems. The LRTP includes insufficient analysis of whether connector roads and intermodal facilities have been and will be co-located with transit and highway systems to optimize transit usage.
Timing. WFRC should include in the LRTP an analysis of the optimum timing and sequencing of future transit and highway projects to encourage transit oriented development and reduce VMT.
INDUSTRY applauds the past work of WFRC, UDOT and UTA, and recognizes that new road and highway construction must occur to accommodate our growing population. However, INDUSTRY strongly encourages WFRC to embrace a more balanced and pragmatic approach to solving future travel demand. The LRTP should include the objective of reducing the rate of increase of VMT and include specific features to achieve this goal. The LRTP should factor in and advance Envision Utah’s Quality Growth Initiatives as viable means of reducing automobile dependency and travel demand. The LRTP should look to transportation solutions of other cities, such as Denver and Portland, which have pursued more aggressive transit solutions and achieved more balanced transportation systems. We in Utah must do the same to ensure our economic growth and strength -- we owe as much to future generations who will live along the Wasatch Front. INDUSTRY respectfully requests that WFRC and other state and local transportation planners and government leaders engage with them in a dialogue regarding these issues prior to finalization of any LRTP.
Note 1: Accordingly to the LRTP, "[w]hile population is projected to increase by 71 percent between 1996 and 2030, person trips are projected to grow by 77 percent over the same period." LRTP at 45. WFRC has indicated that in the short term, the disparity between population growth and the increase in VMT is even more dramatic. WFRC has estimated that between 1995 and 2020, Wasatch Front population will grow by 60%, while VMT will grow by 81% and vehicle trips will grow by 80%. WFRC, Travel Demand Model (Dec. 1999); WFRC, Planning Projections, Technical Report No. 30 (1996); 2020 LRTP.CONTINUE READING
Note 2:DAQ, Public Annual Air Quality Report for 1996 & 1997 (attached hereto).CONTINUE READING
Note 3:Envision Utah, Quality Growth Strategy and Technical Review (2000).CONTINUE READING
Note 4:See Phil Goodwin, "Unintended Effects of Transportation Policies," 114 Transport Policy and the Environment (1998).CONTINUE READING
Note 5:For example, by investing in primarily transit rather than in highways, Portland succeeded in limiting the increase in vehicle miles traveled to a 1.5% increase even while the population increased by 26% and employment grew by 43%. See Arthur C. Nelson, The Georgia Regional Transportation Authority and Its Role in Managing Growth in Metropolitan Georgia, 35 Wake Forest L. Rev. 625, 640-42 (2000).CONTINUE READING
Note 6:Envision Utah, Quality Growth Strategy and Technical Review at 11 (2000).CONTINUE READING
Note 7:Failure to consider the LRTP’s effect on achieving the goals of Envision Utah also appears inconsistent with the requirements of the Intermodal Surface Transportation Act. See 23 U.S.C. § 134(f)(4) ("In developing transportation planning plans and programs pursuant to this section, each metropolitan planning organization shall, at a minimum consider the following: (4) The likely effect of transportation policy decisions on land use and development and the consistency of transportation plans and programs with the provision of all applicable short and long-term use and development plans").CONTINUE READING
Note 8:Transportation Research Board, Highway Capacity Manual (3d ed. 1997).CONTINUE READING