City of Sunset Valley Letter Says NO to CAMPO's TMMP & Phase II Tolls.

City of Sunset Valley, Texas
June 16, 2006

To the Members of the Central Texas Area Metropolitan Planning Organization:
We write to express the City of Sunset Valley's comments on the 2006 Texas Metropolitan Mobility Plan Draft 5/16/2006 ("Draft TMMP"), which we understand are due on June 16, 2006.

We offer the following five comments:

. The Assumption that Population Growth Will Continue at the "High Growth" Levels of 1990-2000 Should Be Re-evaluated
. The Assumption that There is Insufficient State Revenue to Build Needed Transportation Infrastructure Should Be Re-evaluated
. An Independent Engineering Evaluation of the Traffic Congestion Index Model Should Be Undertaken
. The Draft TMMP Should Be Revised to Put More Emphasis on Forms of Transportation Infrastructure Improvements Other than Roads
. No decision to implement any of the second phase toll roads identified in the Draft TMMP should be made until the concerns we have raised are addressed
Each of these points is discussed in more detail below.
Comment 1 - The Assumption that Population Growth Will Continue at the "High Growth" Levels of 1990-2000 Should Be Re-evaluated

The assumption concerning area population growth is fundamental to the entire Draft TMMP. This estimate serves as the basis for determining the Total Congestion Index, and the level of additional transportation infrastructure needed to address projected traffic congestion.
The Draft TMMP assumes that population growth will continue for 30 years at the high growth levels experienced between 1990 and 2000. The TMMP Plan states:

"These scenarios assume the high growth rates of 1990 and 2000 will continue." TMMP at 13.
Five years, or approximately 17%, of the time period covered by these projected estimates has now elapsed. During this time period, the area population appears to have grown at a lower rate than the "high growth" levels experienced between 1990 and 2000.

We believe that the forecasts for area population growth need to be re-assessed in view of the population growth data from 2001-2006. If this information is considered, the projected population growth from 1.16 million to 2.75 million may be revised downward, and the overall transportation infrastructure needs for the area may be able to be reduced accordingly.

Comment 2 - The Assumption that There is Insufficient State Revenue to Build Needed Transportation Infrastructure Should Be Re-evaluated.
The assumption that insufficient revenue is available from "traditional funding" sources to build the needed transportation infrastructure is fundamental to the conclusion that "innovative financing" measures, including toll roads, are necessary. TMMP at 37-42. As noted in Comment 1, this assumption may be based on an overstated projection of area population growth. If the projected population growth is re-assessed, overall transportation infrastructure needs may be reduced. This would, in turn, result in a reduction in the projected costs of building that infrastructure.

In addition, we believe that the Draft TMMP may be based on forecasts for state revenue that are out-dated and/or understated. While it is unclear from the Draft TMMP how available state revenue has been estimated, if these estimates are based on revenues received during the 2001-02 time frame, they would most certainly be both out-dated and understated. It is important to ensure that the revenue projections are based on the most up-to-date information and revenue projections that are available. These projections should take into account the State Comptroller's recent announcement that the state currently has a budget surplus of$8.2 billion dollars.

To ensure that estimates of available state funding are based on the most up-to-date revenue information and projections available, we believe that:

1) The Draft TMMP should be revised to include an appendix that details the information and calculations used to project any estimates of "traditional funding" that will be available to build transportation infrastructure.

2) The revenue estimates that underlie the Draft TMMP conclusion that "traditional funding" will be insufficient to support needed transportation infrastructure should be re-assessed to ensure that these estimates are based on the most current financial information and projections that are available, including the recently announced $8.2 billion state budget surplus.


Comment 3 - An Independent Engineering Evaluation of the Traffic Congestion Index Model Should Be Undertaken.

The Draft TMMP indicates that "[c]ongestion is quantified using the Texas Congestion Index (TCI)." Using the TCI, the Draft TMMP has projected that in 30 years the peak period travel time for a commute that currently takes 30 minutes will be 141 minutes if no new roads are built. TMMP at p. 5.

We are concerned that the information provided by the TCI may be inaccurate, and may incorporate incorrect assumptions about area traffic and commuting patterns. For instance, we understand that national studies have indicated that once the population of a metropolitan area reaches 2 million, the average commuting time remains about 30 minutes. This is based on a variety of factors other than the number of roads, such as people moving closer to work, workplaces moving to more accessible areas, and people opting to work from home or telecommute. Does the TCI adequately take into account these other factors which cause shifts in commuting time and traffic patterns?

In addition, we are concerned that the TCI may not adequately take into account all of the available alternative transportation routes in projecting future commute times. For example, it presently takes about 20 to 25 minutes to traverse the 7.5 mile commute from Sunset Valley to downtown Austin during peak travel periods. Based on the TCI projection that a 30-minute commute would increase to 141 minutes, the TCI projects that the 20-25 minute commute from Sunset Valley to downtown Austin would proportionately increase to about 94 minutes, or over 1 and Y2 hours. We do not understand how the TCI could project a 94 minute commute from Sunset Valley to downtown Austin in light of all of the viable alternative routes that are available for this commute, including MoPac, 1-35, Lamar, South 1st, and Congress Avenue. Accordingly, we are thus concerned that the TCI may not be accurately taking the alternate routes available for making a particular commute into account, and may instead be assuming that all of the cars attributable to the projected increase in population growth will be using a single route.

Finally, we are concerned that the TCI overstates the increase in commute times that will occur if no new roads are built. The TCI projects about a 400% increase in commute time if no new roads are built. This is based on projections that area population will grow from 1.16 million to 2.75 million, or 137%. We do not understand, nor is an explanation provided in the Draft TMMP, how essentially doubling the number of cars on existing roads would result in a quadrupling of commute times.

Because the Draft TMMP, and the need for additional transportation infrastructure, is based solely on TCI projections, it is imperative that we ensure ourselves that the TCI reflects correct assumptions, and that the input data is as accurate as possible. We recommend undertaking an independent engineering evaluation of the TCI model, including the underlying assumptions it uses, to ensure that the estimates of travel time and congestion are not overstated.


Comment 4 - The Draft TMMP Should Be Revised to Put More Emphasis on Forms of Transportation Infrastructure Improvements Other than Roads. [see comments above on revising this]

We are encouraged that the Draft TMMP recognizes forms of transportation other than automobiles, such as commuter rail transit and bicycle/pedestrian travel. We are disappointed, however, that, fundamentally, the Draft TMMP and the CAMPO 2030 Plan are plans to build roads, not broad-based transportation plans. The core "Congestion Relief' component of the plan proposes to build over 13,000 miles of new roads in the three county area. TMMP at p. 6.

Additional Off-road Bicycle Paths Should Be Added in Travis County. The TMMP states that "Pedestrian and bicycle facilities play an important role in the regional transportation system by reducing demand on the roadway system." TMMP at 32. The TMMP notes under "Strategies and Projects" to "Develop a comprehensive pedestrian and bicycle network that connects to transit facilities, retai4 employment and residential centers." Id. Unfortunately, neither the TMMP nor the CAMPO 2030 Plan appears to identify any off-road bicycle paths within 10-miles of downtown Austin, even though there is an extensive network of such trails identified for Williamson County. We strongly encourage CAMPO to consider amending the TMMP and the CAMPO 2030 Plan to add more off-road bicycle trails in Travis County, and particularly off-road trails to downtown Austin. For example, we are aware that an organization in our area has been attempting to create an off-road bicycle trail that extends from the Veloway in Circle C to Town Lake. We believe that more citizens would bicycle to work if they could do it off-road and did not have to cycle on roads where they compete alongside peak-hour automobile traffic.

Future Public Transportation Systems Should Expand Use of Commuter Rail or Some Forms of Public Transportation Other than Busses. The portion of the TMMP discussing "Current and Future Public Transportation System" identifies only two cmmuter rails, one connecting Georgetown and San Antonio, the other connecting Leander to downtown Austin. TMMP at 24. The rest of the public transportation systems involve expanding "bus" services. Id. A plan to serve the transportation needs of an area that may have 2.75 million inhabitants should not rely so heavily primarily relying on road transportation (i.e., cars and busses) Additional commuter rail systems, for example an East-West commuter rail to downtown, and/or feeder lines to transfer stations along the Georgetown/San Antonio main line, should be considered.
In addition, the plans to relocate the Union Rail Freight at a cost of$1.8 billion (TMMP at 7) should involve upgrading this line so that it can be used for commuter trains. This rail line should not be removed and replaced by more roads, particularly if those roads are "managed lanes." The availability of this line presents a unique opportunity to enhance public transportation at a reduced cost. The cost of refurbishing an existing rail line to make it suitable for commuter traffic is bound to be less than the cost of tearing up that track and building a new commuter rail line somewhere else.


Comment 5 - No Decision to Implement Any of the Second Phase Toll Roads Identified in the Draft TMMP Should Be Made until the Concerns We Raise Here Are Addressed.

The Draft TMMP Plan identifies a number of second phase tollway projects, including "US 290E, 183 S, SH71E, SH45 S, and US 290 WISH 71 W in Oak Hill." The Draft TMMP does not provide sufficient information from which to conclude that the second phase toll roads are necessary to address immediate traffic congestion concerns or that any of these toll roads promote the goals stated in the Draft TMMP. No decision to second phase toll roads are necessary to address immediate traffic congestion concerns or implement any of these roads should be made until the concerns we raise here are addressed and it can be adequately demonstrated that a particular toll road: 1) will further the goals stated in the Draft TMMP and 2) must be built now to address immediate traffic congestion concerns instead of waiting to build the road as a freeway.

Public Opinion Has Been Strongly and Consistently Opposed to Toll Roads. When CAMPO voted for the current toll plan in 2004, over 93% of the public comments it received were against toll roads. The 2004 CAMPO Transportation Issue Survey Summary Report ("2004 Survey") further confirms that the public does not want toll roads. The Survey indicates that the public was given an opportunity to rank 8 different suggestions for traffic improvements. Synchronizing traffic lights, more east-west thoroughfares through Austin, and more toll-free roads and freeways received the top three rankings. Toll roads received a ranking of 7 out of 8. 2004 Survey at p. 28. The survey thus indicates that toll-free roads and freeways are strongly preferred over toll roads, and that toll roads have occupied a near bottom ranking since 1997.
The Draft TMMP Does Not Provide Sufficient Information From Which To Conclude That The Second Phase Toll Roads Are Necessary To Address Immediate Traffic Congestion Concerns. The rationale that has consistently been advanced in support of the toll roads is that roads need to be built right away, and toll roads are the only viable way to get these roads built now. At least the following fundamental assumptions underlie this rationale: 1) that roads must be built right away to alleviate immediate or imminent traffic congestion concerns, and 2) that the state does not and will not have enough funds to build these improvements. As discussed in Comments 1-3 above, we are concerned that the future need for transportation infrastructure improvements may be overstated, that the funds that are and will be available to build roads may be understated, and that the TCI which is being used as the basis for recommending transportation infrastructure improvements may not be providing accurate traffic congestion information.

In addition to these concerns, we are concerned that the immediacy of the need to build additional roads may be overstated. CAMPO's 2004 Survey indicates that between 2001 and 2004, the average commute time for this area has not appreciably increased. 2004 Survey at 6. It also reveals that less than 1 % of survey respondents (10 out of 1601) indicated that they have changed their travel mode due to "traffic." Id. at p. 15. This information suggests that no significant change to peak period travel times occurred between 2000 and 2004, and that congestion is not causing anyone to change their mode of travel. Accordingly, there appears to be no immediate need to build new roads to alleviate imminent traffic congestion concerns. The Draft TMMP further confirms that there is no immediate need to build roads to alleviate any significant traffic congestion.

The Draft TMMP indicates that the goal is to reduce the TCI from its current 1.21 to 1.09. TMMP at 5. Even assuming the TCI is based on correct assumptions and provides the most accurate congestion information available, the Draft TMMP indicates, at most, that there is a current need for some additional transportation infrastructure to lower the commute time from 36 minutes (or 6 minutes over the free-flow time) to 33 minutes (or 3 minutes over the free-flow time). TMMP at 5. We do not understand how a goal of reducing congestion by 3 minutes on a 30 minute trip demonstrates that there is an immediate need to build roads to alleviate traffic congestion. In any event, the Draft TMMP does not include any analysis to demonstrate that available funding from traditional sources is insufficient to build the infrastructure required to reduce current commute times by 3 minutes.

In view of Comments 1-3 above and the preceding paragraph, there currently appears to be no basis for concluding that toll roads are necessary to fill an immediate need for roads that cannot be funded by available revenues. Before any such conclusion is reached, we believe that, at minimum, there should be: 1) a re-evaluation of the area population growth projections that serve as the basis for determining the need for transportation infrastructure improvements, 2) a re-evaluation of the availability of "traditional funding" for needed transportation infrastructure improvements, 3) an independent evaluation of the TCI model; and 4) an assessment of the transportation infrastructure improvements that are currently necessary to reduce peak travel times by 3 minutes, and a determination as to whether traditional funding is sufficient to implement these improvements.

The Second Phase Toll Roads May Be Contrary to the Goals Stated in the Draft TMMP. The adopted goals of the Draft TMMP are stated to be to "Relieve Congestion," "Improve Safety," "Improve Air Quality" and "Improve Quality of Life." TMMP at p. 10. We are concerned that the second phase toll roads in the Draft TMMP may actually be contrary to these goals.
The Second Phase Toll Roads May Increase Traffic Congestion Instead of Relieving Traffic Congestion. The Draft TMMP does not describe how any of the proposed second phase toll roads are going to relieve congestion. It does not automatically follow that adding a tolled lane, as opposed to a free lane, to an existing set of free roads will alleviate traffic congestion. Toll roads can actually add to congestion, for instance, by creating congestion at toll booths, and by creating congestions at entry and exit points where a tolled lane merges with the non-tolled portion of the existing road. Any positive impact a proposed toll road may have on congestion must be weighed against the negative impact on congestion to assess the actual net impact on traffic congestion. We have seen no study, and the Draft TMMP provides no information, that indicates there will be a net positive impact on traffic congestion from any of the proposed second phase toll roads. Absent such information, we are concerned that one or more of the second phase toll roads may actually lead to an increase in traffic congestion instead of furthering the stated goal of relieving congestion.

The Second Phase Toll Roads May Decrease Traffic Safety Instead of Increasing It. We have been informed that toll roads pose an increased safety risk for drivers, particularly at toll booths. Some states are currently moving away from toll roads due to these safety concerns. The Draft TMMP does not describe, and provides no information from which we can conclude, that the second phase toll roads will not result in decreased safety for commuters. Absent such information, we are concerned that the second phase toll roads may actually lead to an increase in traffic accidents and a decrease in traffic safety instead of furthering the stated goal of increasing traffic safety.

The Second Phase Toll Roads May Decrease Air Quality Instead of Increasing it. We are concerned that if the second phase toll roads are built, there will be a significant back-up of cars at the toll booths. While these cars are in-line waiting at toll booths, they will be idling, which causes increased emissions. Although the Draft TMMP projects that there will be some small decrease in emissions when the TMMP Network is implemented as opposed to an alternative with "no innovative financing," (TMMP at 20), no information is provided as to the basis for any conclusion that the second phase toll roads will actually reduce emissions. Absent such information, we are concerned that the second phase toll roads may actually lead to a decrease in air quality instead of furthering the stated goal of increasing air quality.
The Second Phase Toll Roads May Decrease Quality of Life for Area Residents Rather than Increase It. If any of the second phase toll roads actually result in a net increase in congestion, or a decrease in air quality, a decrease in the quality 0 f life for area residents would also result. Aside from this adverse impact, we are concerned that the second phase toll roads may decrease the quality of life for many area residents who do not have sufficient means to pay the tolls. If the second phase toll roads are implemented, those that are wealthy enough to afford to pay tolls will be able to travel from place to place with shorter commute times, at least between the entry and exit point of the toll road, Those that do not have sufficient means to pay tolls, however, will be relegated to existing "free alternatives." At best, their commute times will remain unchanged, and at worst, their commute times may increase because of the toll road. The second phase toll roads may not only decrease quality of life for those residents who cannot afford to pay the tolls they may decrease the quality of life for all area residents by further dividing those who have means and those that do not based on a perceived commuting time privilege for the wealthy.
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We thank you for the opportunity to comment on the Draft TMMP, and look forward to working with CAMPO and other area governmental bodies and agencies to enhance and improve transportation in the Central Texas area. Should you have any questions or need further assistance, please contact us at your convenience.

Signed by:

Mayor Cat Quintanilla Councilmember Robb Buchanan

Councilmember Robert Garrett Councilmember Susan Jung

Councilmember Jeff Mills Councilmember John Moore