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May 12, 1997
Ms. Marie L. Pang, Environmental Manager
Peninsula Corridor Joint Powers Board
1250 San Carlos Avenue P.O. Box 3006
San Carlos, CA 94070-1306
Subject: Draft Environmental Impact Statement/Report for the
CalTrain San Francisco Downtown Extension Project
Dear Ms. Pang:
Bay Area Air Quality Management District (BAAQMD) staff have reviewed the Draft Environmental Impact Statement/Report (DEIS/R) for the CalTrain San Francisco Downtown Extension Project. The DEIS/R examines the potential impacts to the environment of extending CalTrain commuter rail service to the site of the Transbay Terminal in downtown San Francisco, of expanding parking lots at suburban stations and of fully electrifying the system.
The BAAQMD firmly supports the main project objective of providing direct CalTrain service to downtown San Francisco. This improvement will make CalTrain service vastly more attractive by putting it within walking distance of a very large number of employment, retail and entertainment opportunities and also by enhancing its links to other major transit systems. These features will facilitate a range of other commendable objectives that include improving regional air quality, enhancing transportation alternatives, accommodating growth in travel demand without costly highway expansion, and supporting local economic and land use development goals.
We are interested in a project that will optimize air quality benefits by maximizing CalTrain ridership, enhancing intermodal opportunities and instituting operational changes that reduce air pollution. With this goal in mind, BAAQMD staff offer the following views on the proposed project.
1. Despite its high costs, full system electrification would be optimal because it would significantly reduce air pollution from the locomotives. According to the DEIS/R, emissions of reactive organic gases, for example, would be less than one lb/day with full electrification compared to 159 lb/day under diesel/electric propulsion systems; in another example, emissions of nitrogen oxides would decrease from 4,669 lb/day to only 79 lb/day. In addition to the above, electric locomotives are less noisy and have superior acceleration characteristics. 2. For the Townsend Street alignment, the "Center" and "South Side" options are preferable to the "South Subway" alternative because only they provide a station to serve the future Mission Bay development and the Giants Ballpark. Also, those two options cost approximately $112 million less because they include a shorter underground segment.
3. BAAQMD staff support grade-separated pedestrian structures when their primary purpose is to enhance connections among land uses and transportation modes for those on foot. For this reason, we encourage CalTrain to provide the proposed optional underground walkway between its new terminal and the Embarcadero BART/Muni station. Similarly, the new CalTrain terminal should be connected to the replaced Transbay Terminal via escalators, elevators or an underground walkway.
4. We understand that CalTrain is not the lead agency for the Transbay Terminal replacement project. However, since options for the project are evaluated in the DEIS/R we would like to state our support for the provision of retail mentioned under replacement options A and B. Retail space would make transit more attractive by increasing the convenience of transit users. On the other hand, we discourage the provision of the optional 600-car garage under option A because it will encourage driving. We concur with the DEIS/R's conclusion that the displacement of 900 parking spaces by the CalTrain extension project would result in greater public transit use and would not require mitigation because of San Francisco's "transit-first" policy.
5. The BAAQMD is disappointed by CalTrain's plan to expand parking at 13 suburban stations. Providing enough parking to meet future demand based on current mode shares is self-fullfiling because once parking is provided people are discouraged from seeking alternative modes. Parking expansion will negate the air quality benefits of the extension project because most of a car's pollution is produced during its "cold" start. In the affected suburban communities, parking expansion will congest local streets, worsen air quality, encourage driving, make walking and biking less pleasant, displace several business and cause lost property and sales tax revenue. This is precisely the opposite of what the extension project attempts to achieve in San Francisco.
Each parking space, which will likely be used by only one train rider a day, will cost $19,336. We believe these funds could be spent far more effectively encouraging ride-sharing, transit use, walking and biking to CalTrain stations. If, as stated, the goal is to maximize ridership, CalTrain could attract new riders by using the funds for fare discounts and also by providing a range of in-station conveniences including a magazine kiosk, cafe, mail and copy center and flower stand. Given the exceptionally high demand for CalTrain's low-cost bike lockers and bikes-on-board program, CalTrain should include efforts to accommodate cyclists as part of its mitigation for parking demand impacts. Provisions should be made to increase the number of bikes allowed on each CalTrain run, and additional lockers or attended bike parking should be provided at stations. (Attended parking at high-demand stations could even be expanded to include minor repair services and to sell commonly used bike supplies.) We strongly encourage CalTrain to abandon its parking expansion plans and work with the affected cities to develop strategies for alternative access to CalTrain stations.
I want to reiterate our enthusiastic support for extending CalTrain service to downtown San Francisco. If you need further statements of support from the BAAQMD or if you have any questions regarding our comments, please call Niko Letunic, Environmental Planner on my staff, at (415) 749-5170.
Air Pollution Control Officer
BAAQMD Director Randy Attaway
BAAQMD Director Donald Gage
BAAQMD Director Jerry Hill
BAAQMD Director Trixie Johnson
BAAQMD Director Susan Leal
BAAQMD Director Gillian Moran
BAAQMD Director Michael Nevin
BAAQMD Director Mabel Teng
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Last updated: June 20, 1997
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