Archived by the Puget Sound Public Interest Transportation Forum, www.bettertransport.info/pitf.

September 29, 2000
Norman Abbott
SEPA Responsible Official
Puget Sound Regional Council
1011 Western Avenue, Suite 500
Seattle, WA 98104-1035

Re: Least-Cost Planning Requirement for Metropolitan Transportation Planning

Dear Mr. Abbott:

We are transportation, land use, and other technical professionals who have a strong interest in the application of least/full cost principles to transportation planning in this region. We are writing to express our concern with the apparent intent of your agency to limit the application of least-cost analysis to alternative "packages" and not apply it to the individual components of those packages.

Washington State law (RCW 47.80.030) requires regional transportation planning organizations to develop plans "based on a least cost planning methodology that identifies the most cost effective facilities, services, and programs." The law states that facilities, services, and programs include major roadways, transit and non motorized services and facilities, and noncapital programs such as demand management. The law also requires the plan to "make the most efficient use of existing transportation facilities to relieve vehicular congestion and maximize the mobility of people and goods."

State law clearly mandates that individual components of regional transportation plans be the subject of cost-effectiveness analysis. It also states that these facilities and services should encompass those that are designed to manage increased demand and use the available capacity of the existing transportation system, as well as those that meet demand by adding capacity. And, significantly, it does not suggest that these facilities and services are limited to those that are in current regional plans or policies. It suggests that all feasible alternatives should be analyzed.

The Metropolitan Transportation Plan Alternatives Analysis and Draft Environmental Impact Statement (Destination 2030) issued by your agency on August 31, 2000, indicates that the least-cost planning process your agency will use will have two steps: (1) identification of alternative scenarios or investment packages, and (2) estimation and comparison of the full public and private costs and benefits associated with these different scenarios. (DEIS, Volume 1, page 94)."

We find this approach to be unacceptable. It is contrary to legislative intent and it will not allow the selection of the most cost-effective set of measures within budget constraints. There is, in fact, other language in the document that is at odds with this approach. We refer you to the description of the preferred alternative (DEIS, Volume 1, Executive Summary, page xii): "It is likely that the region’s preferred strategy will ultimately represent a composite of various elements and options from all three alternatives evaluated in this document." We find it difficult to understand how this desirable goal will be accomplished without a cost-effectiveness analysis of each of the separate elements and options contained within the three alternatives. We think that every element in any comprehensive transportation plan should earn its way into the plan based on its cost-effectiveness.

We also have concerns regarding the timing and description of the least-cost analysis and its relationship to the DEIS. The DEIS states (Volume 1, page 198) that a summary report will be forthcoming during the Autumn of 2000. No date certain is specified. Yet we, and other interested members of the public, are required to comment on the alternatives by October 20. We believe that it is impossible to comment fully and effectively when we lack crucial information, namely the relative cost-effectiveness (net social benefit) of the several elements that might comprise a preferred alternative.

The DEIS appears to us to go out of its way to emphasize the difficulty of least-cost analysis. For example: "Many of these costs are not easily quantified or represented in monetary terms (DEIS, Volume 1, page 196)." In our experience, least-cost analysis is not substantially more difficult than all other transportation analysis that requires a modeling estimation of future human behavior. All long-range predictions involve considerable uncertainty. We reference as an example the predicted system performance numbers for the various alternatives as provided in the Table on page xvii of the Executive Summary (DEIS, Volume 1). It is our understanding that the data in this table and the data that will be generated for the least-cost analysis use the same regional model. Yet the system performance data implies a high level of certainty.

Our concerns lead us to the following recommendations:

1. Apply least/full cost analysis to all elements of the three alternatives and to other credible and feasible options that are currently under discussion in the region. These would include an all-bus regional transit network and a monorail system as an alternative to light rail, and transportation-demand measures that would increase the passenger-carrying efficiency of the bus network.
2. Submit the least/full cost analysis for a review by a panel of nationally recognized transportation economists, with the review to be included in the DEIS comments.
3. Provide a new comment deadline for the DEIS that allows a reasonable time period for public review of the least-cost report and the integration of its findings into the conceptualization of a preferred alternative.

Sincerely,

    Dick Nelson                             Emory Bundy

    Michael Godfried                     Richard Harkness

    James MacIsaac                     Richard Morrill

    John Niles                             Charles Prestrud