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Governor Ritter’s Colorado Promise Transportation
We must always consider the impact that transportation projects have on the environment.
We must design projects that improve mobility, honor the environment and protect the livability of adjacent communities.
Governor Ritter’s Colorado Promise
New Energy Economy
Leading Colorado Towards Self-Sufficiency
- Alternate Energy Promotion
- Cleaner ways of extracting and using fossil fuels
- Rewarding Efficiency and Conservation
Governor Ritter’s Colorado Promise Environment
- Protection of Water Quality
- Protection of Air Quality
- Protection of Colorado’s Wilderness areas,
Waterways and Wildlife habitats
“We also owe it to future generations - generations of Coloradans we will never meet –
to protect our natural resources, our water supplies and our crisp mountain air.”
“We must protect the quality of our air with a greater emphasis on mass transit, renewable energy, new clean coal technologies and more thoughtful growth strategies.”
Protection of water quality is essential to the health of our citizens, the strength of our economy and the preservation of our quality of life.
Governor Ritter’s Colorado Promise
New Energy Economy
Do Our Part to Reduce Global Warming Trends
We can no longer talk about energy without acknowledging the effects of our energy production and use on our environment.
We are not talking about just global warming; we are talking about “local” warming.

How Sustainable is Continued Auto Oriented Development and Continued Highway Expansion?

"With oil prices above $50 a barrel, having risen by 80 percent this year, the West is indeed relying on more Saudi crude. This is delusional says Simmons. Saudi oil output may soon start declining - imminently, in my view, in the next six to 36 months."
"But the conventional wisdom, Simmons says that we can rely on Saudi oil indefinitely is driven only by 'group-think' and vested interests."
"So what of US government claims Saudi will pump 22 million barrels per day by 2025? If by some miracle, they find some huge fields that have defied discovery for 50 years, Simmons says, it might happen. Then again I could be living on the Moon in 2025. I would say the probability of me living on the Moon is higher than Saudi reaching 22 million barrels per day."


SPRAWL

More Roads are Not the Answer
Smart Growth and Affordable Housing
Transportation Choices
Global Warming
Population Growth and Suburban Sprawl
CDOT defines Sustainability as "Toll Roads". CDOT officials believe that toll roads represent a form of economic sustainability that satisfies their 1950/1960's highway only agenda. The CDOT highway agenda deliberately ignores environmental, ecological, social and cultural values that represent the true meaning of Sustainability. Clearly CDOT refuses to embrace foward thinking 21st Century Sustainable Transportation solutions, preferring instead 1950/1960's era highway solutions.
We simply cannot afford, (nor will Colorado taxpayers ever approve!) the highway funding deemed necessary for economic sustainability by CDOT officials and their hired economic Gurus, Move Colorado and the Transportation Commission. The ridiculous highway investment being proposed by CDOT and Move Colorado will be a net loss for Colorado.

Courtesy of the Victoria Transport Policy Institute:
What is Sustainable Transportation?
Sustainability has significant implications for transportation planning, since transport activities tend to be highly resource intensive, have numerous external costs, and frequently distribute impacts inequitably. Sustainable transportation requires using each mode for what it does best, which typically means greater reliance on non-motorized for local travel, increased use of public transit in urban areas, and a reduction (but not elimination) of personal automobile use.
Sustainable planning challenges the assumption that increased vehicle travel reflects legitimate consumer demand, since consumers lack viable alternatives and markets are distorted in ways that underprice driving. While the first increment of motor vehicle travel (measured for example, as average per capita vehicle miles) may provide significant benefits to society, marginal benefits tend to decline with increased use.
Doubling mileage does not double benefits for the simple reason that consumers select their most valuable trips first.
Sustainable planning focuses on outcomes, such as the quality of access (the ability to obtain desired goods, services, and activities), rather than simply measuring quantity of mobility (such as travel speed or total mileage). Mobility is seldom an end in itself. Even recreational travel usually has a destination. Increased movement is not necessarily beneficial, it may indicate inefficiencies that require more travel to meet needs.
John Whitelegg states, “It is the ease of access to other people and facilities that determines the success of a transportation system, rather than the means or speed of transport. It is relatively easy to increase the speed at which people move around, much harder to introduce changes that enable us to spend less time gaining access to the facilities that we need.”
Only by measuring transport in terms of access can options that reduce the need for travel (such as telecommuting and more efficient land use) be properly evaluated. The disciplines of geography and urban economics often measure access, but the analysis tends to be theoretical. The professions that implement transport policies – transport planners and traffic engineers – tend to measure vehicle movement, using indicators such as level of service (LOS), V/C ratios, congestion delay, and average vehicle speeds.
These are inappropriate because:
• It is impossible build enough urban road and parking capacity to satisfy potential demand.
• Motor vehicles impose significant economic, environmental, and social costs.
• Some people cannot own or drive a motor vehicle.

Courtesy of the Victoria Transport Policy Institute:
Changing Transportation Institutions Sustainable transportation requires fundamental changes in our transportation planning practices. It demands more comprehensive analysis of impacts (including consideration of indirect and cumulative impacts) and consideration of a broader range of solutions than usually occurs. It also requires that the public be involved in determining alternatives to be considered and evaluation criteria. Those are principles of good planning that are particularly necessary for sustainability planning.
Sustainable transportation planning requires public involvement for two reasons. First, because sustainable development reflects a community’s values, the public must be effectively involved at each stage of the planning process. Second, because sustainable transportation often involves changes in community design and residents’ behavior, residents need to feel a stake in decisions if they are to be implemented effectively.

Sustainable development requires that individual transport decisions be subordinate to a community’s long-term strategic objectives. Transport planners must recognize that their decisions can create self-fulfilling prophecies. For example, increasing highway capacity can stimulate automobile-dependent transport and land use patterns, while investments in transit, pedestrian and bicycle facilities can help create multi-modal transportation systems.
Transportation professionals have just as much reason to object to decisions that create automobile dependent land use patterns as they would to the closure of a highway lane or a reduction in transit service, since all result in reduced access.
Transportation planners and engineers receive professional rewards for implementing capacity expansion projects, but are seldom rewarded for finding ways to avoid the need for such projects. Demand management tends to involve skills such as education and marketing that are not traditionally valued in transportation agencies.
Sustainable planning requires that transportation professionals shift from being traffic engineers concerned only with vehicle flow, into “public space architects” concerned with balancing diverse and often conflicting uses of road environments.
Streets are more than just conduits for vehicle traffic, they are part of the public realm, where people meet and interact. Roadway design must not focus on traffic movement objectives at the expense of non-moving and slow-moving uses of streetscapes.
Traffic engineers traditionally describe any increase in road or parking facility capacity as an “improvement,” although from many perspectives (pedestrians, residents, aesthetics, environmental quality) it may represent degradation. Sustainable transport planning avoids language biased in favor of automobile travel, as described in the box below.
Example
Traffic volumes are increasing on a highway between a city and a suburb. Planners extrapolate the growth rate to predict extreme levels of future congestion. They evaluate two solutions: widen the highway or build a rail transit line, each of which could carry 3,000 peak-period commuters. The highway project is predicted to cost $250 million, while a rail option costs $300 million. The planners therefore conclude that the highway investment is most cost effective. However, such an analysis is incomplete and fails to identify the socially optimal option.
First, such predictions of traffic growth are fundamentally flawed. Most traffic models predict future traffic assuming minimal congestion and free roads and parking. This is equivalent to asking how much food a nice restaurant could give away. The results are self-fulfilling outcomes, as increased capacity encourages increased driving which creates “demand” for increased capacity. Travel demand should always be evaluated as a function instead of a point estimate.

Rather than reporting, “Over the next decade traffic is predicted to increase 20%,” transport planners should state, “Over the next decade traffic is predicted to grow 20% at current user costs, it will grow 10% if user costs increase by 25%, and there would be no growth if user costs increase by 50%.”
This allows evaluation of pricing strategies (parking charges, road tolls, distance-based insurance, etc.) to address traffic problems.
Traffic modeling often ignores the tendency of traffic congestion to maintain a self limiting equilibrium. As roadways become more congested, motorists adjust by shifting their travel times and destinations, if capacity is expanded motorists take more peak period trips.
Modeling that fails to take this into account tends to overpredict future congestion, and overestimates the benefits of roadway capacity expansion.
Second, the analysis focuses on agency financial costs, while ignoring other important impacts. For example, 3,000 automobile commuters require 3,000 parking spaces, a cost that is avoided if the trips are made by other modes.
Additional automobile commuters increase surface street traffic, so there may be additional costs to deal with “downstream” congestion. The analysis assumed that each commuter has an automobile that will simply sit unused if they use public transit. Accident, pollution and sprawl costs are also ignored.

Third, the analysis is not based on a strategic community plan. Increasing highway capacity tends to make a community more automobile dependent and encourages low density, automobile oriented land use. A major transit investment can provide a catalyst for developing a multi-modal transportation system and higher density, mixed-use development. A transit option may therefore be favored if it supports a community’s strategic vision, even if it costs more from a narrow perspective.
Sustainable development requires significant changes in our transportation system to increase economic efficiency, equity, and environmental security.
This cannot be achieved simply by changing vehicle designs or improving traffic flow. It requires changing the way transportation professionals approach problems, and how individuals behave as citizens and consumers.
The bad news is that there are many barriers to these changes. For all its faults, our current transportation system provides a high degree of mobility to most users, particularly for the classes of people who are most influential in public decision making.

Many industries benefit directly from our transportation system’s inefficiencies. Most North Americans have had little experience with healthy communities that are not highly automobile dependent. As a result, there is resistance to change.
The good news, in terms of achieving more sustainable transportation, is that the marginal benefits of increased driving are diminishing. Most people have little desire to spend more time in their cars, drive further, or devote more resources to vehicles, roads and parking. Increasing roadway capacity is increasingly expensive.
It is possible to justify significant progress toward more sustainable transportation based on conventional economic arguments and informed self-interest. Transportation professionals can contribute by becoming familiar with the full costs of transportation and alternative transport strategies. We can work to create institutions and policies that are less biased in favor of automobiles and urban sprawl. We can develop professional rewards for creating more efficient transportation systems.
Transportation professionals do not need to work for these changes alone.
Other stakeholders – local officials, businesses, neighborhoods, public health advocates, social equity activists, and environmentalists – also have reasons to support sustainable transportation strategies. There are opportunities to develop coalitions to achieve sustainable transportation objectives.
Reframing the Transportation Question
If you ask people, “Do you think that traffic congestion is a serious problem that deserves significant investment?” most would probably answer yes.
If you ask them, “Would you rather invest in road capacity expansion, or use lifestyle changes such as increased urban density and more use of walking, bicycling, car pooling and public transit to solve congestion problems?” a
smaller majority would probably choose the road improvement option. These are essentially how choices are framed by conventional transportation plans.
But if you presented a more realistic description of choices by asking, “Would you rather spend a lot of money increasing road capacity to achieve only moderate and temporary reductions in traffic congestion, and deal with increased personal, municipal, social and environmental costs from increased motor vehicle traffic, or would you rather create a more diverse transportation system to minimize such problems?” the preference for road building would probably disappear.

Implications and Conclusions
Automobile dependency consists of high levels of automobile use, automobile-oriented land use patterns, and limited travel alternatives. Automobile-dependency can impose significant economic, social and environmental costs. Automobile dependency can cost an average household thousands of dollars per year, and increases problems such as congestion, road and parking facility costs, crash damages and environmental degradation.
Automobile-dependent transportation and land use patterns reduce access, which increases the amount of vehicle travel required to maintain a given level of productivity, and reduces travel alternatives, making non-drivers worse off in absolute and relative terms. These costs are disperse through the economy and can reduce productivity.

It would be difficult to underestimate the economic and social benefits of basic access, that is, the ability of people and industry to reach the goods, services and activities they need. To the degree that automobile use provides basic access it supports economic and social development. But additional automobile use provides little economic development, and is economically inefficient to the degree that it results from market distortions.
There is both theoretical and empirical evidence that excessive automobile dependency reduces economic development.
The theoretical evidence includes the principle of diminishing marginal benefits, which means that increased driving provides ever smaller incremental benefits; the observation that a significant portion of automobile dependency can be explained by market distortions which favor automobile use; the fact that many perceived benefits of increased automobile use are economic transfers rather than true productivity gains; and the tendency of automobile dependency to create less efficient transportation and land use patterns.
Empirical evidence also indicates that excessive automobile dependency reduces economic development.
Although automobile use often increases with wealth, there is little evidence that automobile dependency causes economic development.
Economic growth rates tend to be highest before a region becomes automobile dependent, after which growth rates usually decline. Automobile dependency can be considered a luxury consumer good which does not itself increase productivity or economic development.
International comparisons indicate that beyond an optimum level (which appears to average about 7,500 annual kilometers of vehicle travel per capita, but may vary depending on conditions), increased driving reduces economic development. Excessive automobile dependency may reduce productivity due to increased facility costs, congestion, accidents, more dispersed land use, and less efficient travel alternatives.
Automobile expenditures provides less economic benefit than most other consumer purchases, and far less than public transit expenditures. This is to be expected since automobile and petroleum production are capital intensive with little labor input, and because vehicles and fuel are largely imported goods in most regions.

Although historically vehicle manufacturing was an important contributor to economic development in some regions, the automobile industry is now mature, not very profitable and highly competitive. Except where automobile production is already established, other industries are likely to provide greater economic returns. Economic development associated with automobile dependency results primarily from exporting vehicles and fuel.
There is no indication that inceased domestic consumption of automobiles and fuel increases economic development.

Regions that already have adequate paved highways are unlikely to see major economic development benefits from increased road capacity.
Alternative investments and management strategies that lead to more efficient use of the existing transportation system are likely to provide greater economic benefits. Many benefits associated with roadway capacity expansion are economic transfers rather than true productivity gains.
Roadway improvements can have negative as well as positive impacts on a local economy, for example by encouraging consumers to shop elsewhere.
Automobile dependency is particularly burdensome to developing countries that do not produce vehicles or petroleum. In such countries, vehicles and petroleum often account for a major portion of import value. This weakens the value of their currency and constrains investments that could increase productivity.
Market-based transportation reforms are likely to significantly reduce automobile dependency, increase economic development, and make consumers better off overall.

These include changes in transportation planning and investment practices, pricing reforms and changes in land use development policies. There is currently political and institutional resistance to such reforms, in part due to various interests that benefit directly from automobile dependency, and in part because many consumers have little experience with a balanced transportation system and are skeptical that they could benefit from less automobile use. These reforms may become more acceptable as they are better known, and as consumers realize the diminishing benefits of increased driving.
A number of European and Asian cities are making progress developing more balanced transportation systems and appear to be benefiting economically as a result.

Courtesy of the Sierra Club
Sustainability
A. Many of NEPA’s requirements and purposes – trustee of the environment for future generations, beneficial uses of the environment without degradation, a balance between population and resource use, promote efforts which will prevent or eliminate damage to the environment and biosphere – are encompassed within the overarching term “Sustainability”.
The U. S. Department of Transportation and others are translating that broad concept into more specific goals, practices and applications.
The Sierra Club policies and practices and the following few comments from the vast literature on sustainability are in accord, especially as regards automotive emissions, greenhouse gases, and energy conservation.
B. Irreversible or irretrievable commitments of resources are inherent in sustainability and are in CEQ regulations:
“40 CFR Sec. 1502.16 Environmental consequences.
This section forms the scientific and analytic basis for the comparisons under Sec. 1502.14. It shall consolidate the discussions of those elements required by sections 102(2)(C)(i), (ii), (iv), and (v) of NEPA which are within the scope of the statement and as much of section 102(2)(C)(iii) as is necessary to support the comparisons. The discussion will include the environmental impacts of the alternatives including the proposed action, any adverse environmental effects which cannot be avoided should the proposal be implemented, the relationship between short-term uses of man's environment and the maintenance and enhancement of long-term productivity, and any irreversible or irretrievable commitments of resources which would be involved in the proposal should it be implemented. This section should not duplicate discussions in Sec. 1502.14. It shall include discussions of:
(a) Direct effects and their significance (Sec. 1508.8).
(b) Indirect effects and their significance (Sec. 1508.8).
(c) Possible conflicts between the proposed action and the objectives of Federal, regional, State, and local (and in the case of a reservation, Indian tribe) land use plans, policies and controls for the area concerned. (See Sec. 1506.2(d).)
(d) The environmental effects of alternatives including the proposed action. The comparisons under Sec. 1502.14 will be based on this discussion.
(e) Energy requirements and conservation potential of various alternatives and mitigation measures.
(f) Natural or depletable resource requirements and conservation potential of various alternatives and mitigation measures.
(g) Urban quality, historic and cultural resources, and the design of the built environment, including the reuse and conservation potential of various alternatives and mitigation measures.
(h) Means to mitigate adverse environmental impacts (if not fully covered under Sec. 1502.14(f)).
[43 FR 55994, Nov. 29, 1978; 44 FR 873, Jan. 3, 1979]”
The Draft PEIS does not comply with this regulation.
I.5.1 Greenhouse Gases and Global Warming

The Sierra Club and the environmental community in general consider global warming and greenhouse gas emissions to be one of the greatest, if not the greatest, threat to the well-being of future generations and the biosphere.
A policy-level EIS is sadly defective if it does not consider how various alternatives impact greenhouse gas emissions (GHG) and global warming. As a simple example, rapid rail transit emits far fewer greenhouse gases per passenger-mile. Hence, at a PEIS Tier 1 level rail transit is preferable to a highways-only alternative that results in an increase in Vehicle Miles of Travel and resultant emissions of greenhouse gases. Albeit the gas reductions in this 144 mile corridor if transit is instituted effectively are small in the scope of global greenhouse gas emissions, the Sierra Club is of the opinion that the term “significant” is indeed applicable to decision-making in the I-70 Mountain Corridor as input in deciding between the alternatives.

One can argue that a single project will not have a significant effect in changing the amount of greenhouse gases in the atmosphere or in altering global warming and climate change. However, global warming is caused by one power plant after another, one energy-inefficient car after another, one energy-inefficient building after another. Similarly, it can be favorably impacted by the use of one hybrid car after another, one “green” house or office building after another, one development of transit after another.
One can also argue that, because the Federal Government has no policy to reduce greenhouse gas emissions, a PEIS or EIS can ignore such gases, global warming and the information in Appendix A herein. The Sierra Club holds that any PEIS or EIS based on the phraseology and intent of the Draft PEIS is not in compliance with NEPA.
To substantiate the need to implement transportation modes and policies that reduce GHG, several documents selected from the vast literature on the subject are presented here.
It is noted that even the U.S. Department of Defense and many major oil companies are seriously concerned about global warming and depletion of non-renewable energy resources. For CDOT and FWHA to continue to assume that the future will continue to be viable if past policies and practices are not changed is not a responsible or defensible posture.

We are of the opinion that the Tier 1 analysis and content of this Draft PEIS are deficient in respect to sustainability and the NEPA principles and terms encompassed therein, and that Sustainability factors should be used to compare the alternatives in the Draft.
The standard definition of sustainable development from the Brundtland Commission is creatively ambiguous: “Humanity has the ability to make development sustainable – to ensure that it meets the needs of the present without compromising the ability of future generations to meet their own needs.” This malleability allows programs and institutions of government, civil society, business, and industry to create their own emphases on what is to be sustained and what is to be developed, but over time a consensus has emerged around three pillars of sustainable development: economic, social, and environmental. Sustainable development is also defined through the goals it seeks to achieve, through the indicators by which it is measured, through the values that support it, and through the practice by which it is attained. (“What is Sustainable Development? Goals, Indicators, Values, and Practice”) Kates, Robert W., Thomas M. Parris, and Anthony A. Leiserowitz. 2005 Environment: Science and Policy for Sustainable Development 47(3): 8-21.
http://sustainabilityscience.org/ists/docs/whatisSD env kates 0504.pdf)
DOT has defined five strategic goal areas covering safety; mobility; economic growth and trade; human and natural environment; and national security. For each goal a set of strategic outcome goals and a number of more specific performance measures are defined for use in the annual performance planning. The four strategic outcome goals for the environment are qualitative:
1. reduce the amount of transportation-related pollutants and greenhouse gases released.
2. reduce the adverse effects of siting, construction and operation of transportation facilities.
3. improve the sustainability and livability of communities through investments in transportation facilities; and
4. improve the natural environment and communities affected by DOT-owned facilities and equipment.
(USDOT- 2003 Performance Rep. 2004 Performance Plan, Washington, D.C.
^http://www.dot.gov/PerfPlan2004/index.html&)
If sustainability is defined primarily in terms of energy consumption and air pollution emissions, the best solution is more efficient and cleaner vehicles. Hybrid cars are now commercially available that are three times as fuel efficient as the fleet average and produce minimal air emissions. But driving such a vehicle does not reduce congestion, road and parking facility costs, most consumer costs, accident costs, mobility problems facing non-drivers, or the environmental impacts of roads and sprawl; in fact, by reducing vehicle operating costs, it tends to increase these problems (Litman, Victoria Transport Policy Institute, 2004a). When all impacts are considered, strategies that improve travel options, create more accessible land use patterns, and reduce total automobile travel are generally most sustainable. Table 1 (of the Litman Report) compares benefits of impacts of efficient vehicles, shift to transit and ridesharing, shifts to non-motorized modes; and examines benefits of planning objectives:
Ø Energy and Emissions Reductions
Ø Congestion Reduction
Ø Road & Parking Cost Savings
Ø Crash Reductions
Ø Improved mobility for non-drivers
Ø Increased Public Fitness
Shifting to more efficient vehicles helps achieve one or two planning objectives. Shifting modes and reducing total vehicle travel achieve many objectives. (Source: “Well Measured: Developing Indicators for Comprehensive and Sustainable Transport Planning: By Todd Litman, Director, Victoria Transport Policy Institute, 5 April 2005.)
With the transportation sector responsible for significant emission of greenhouse gases and likely to be affected by the changing climate, making the transportation system more sustainable will require addressing both mitigation and adaptation.
Ø The US needs to begin to limit emissions in the near term as it develops and implements a long term plan in order to increase the likelihood that important detrimental climatic thresholds will not be exceeded.
Ø To ensure attention is paid to the likelihood of adverse impacts from climate change, NEPA analyses should include consideration of resilience to the range of expected changes in the climate.
“Climate Change and Sustainable Transportation: The need to End Our Addition to Fossil Fuels” Michael C. MacCracken, Senior Scientist for Climate Programs, Climate Institute, Washington DC July 12, 2002 Introducing Sustainability into the Transportation Planning Process Transportation Research Board
(http://trb.org/conferences/sustainability/MacCracken.pdf)
Preparing for climate change can improve overall resilience to multiple stresses and reduce the likelihood of many adverse impacts. Addressing the potential impact of climate change in the context of other stresses has the potential for most efficiently reducing overall vulnerability and limiting exposure to multiple stresses.
Appendix A, a report by the International Energy Agency, is included as part of this text but is located as an Appendix for formatting clarity. It is but one of countless reports and studies that are relevant.
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