March 25, 2024
San Mateo County Transportation Authority (SMCTA)
Via email: board@smcta.com
City/County Association of Governments of San Mateo County (C/CAG)
Via email: Mima Crume, Clerk of the Board, mcrume@smcgov.org
Re: San Mateo 101 Managed Lanes Project North of I-380 to San Francisco border Freeway Expansion vs Lane Conversion
Dear SMCTA Chair Ramirez and Members of the Board and C/CAG Chair Hurt and Members of the Board,
The Sierra Club is opposed to freeway expansions such as adding a new lane, for an Express Lane, on Interstate 101 from I-380 to the San Francisco border. High occupancy vehicle (HOV) and high occupancy vehicle/toll (HOT) lanes should come from converting existing highway lanes rather than constructing new lanes.
The empirical evidence shows that expanding the capacity of roadways – at least freeways, highways, and major arterials in metropolitan areas – induces VMT. It’s not merely a hypothetical impact. Induced travel will often be the largest source of project-related VMT. New HOT lanes also become mixed-flow part of the day, or are converted to full-time mixed-flow after construction. In addition, we note the following:
- Per CalTrans “Evaluating Transportation Impacts of State Highway System Projects” Section 5.1.1 of the Transportation Analysis under CEQA- conversion of existing general-purpose lanes (including ramps) to managed lanes or transit lanes or changing lane management in a manner that would not substantially increase vehicle travel would not likely lead to a measurable and substantial increase in VMT. However, a project that adds a new HOV lane could induce as many vehicle miles traveled (VMT) as a new GP lane would. (Emphasis added)
- We also point out that the California State Transportation Agency’s Climate Action Plan for Transportation Infrastructure, adopted on July 12, 2021, is opposed to freeway expansion by adding new lanes. The plan states Research over the past several decades has demonstrated that highway capacity expansion has not resulted in long-term congestion relief and in some cases has worsened congestion, particularly in urbanized regions. [. . .] We are in the middle of a climate crisis. Climate change is exacerbating natural disasters, with California facing extreme heat and increasingly devastating wildfires. The Administration has been focused on the need to act intentionally and through collaboration among state agencies, local and regional governments, and other interested stakeholders to combat and prepare for climate change. Because the transportation sector is the largest contributor to California’s greenhouse gas emissions (GHG), reducing emissions from transportation is urgently needed. (Emphasis added)
Sierra Club and many neighborhood and advocacy organizations oppose adding lanes to highways, and support reducing GHG, prioritizing cleaner air for improved health results, especially for resident communities and workers along freeways, improved transit access, safer frontage roads, additional sound walls, improved vegetation, and other priorities. In addition the Bay Area, and San Mateo County in particular, are the most vulnerable areas in the US to climate-change-induced sea level rise. For all these reasons, we commend the growing commitment of the California State Transportation Agency to consider climate change in its decision making.
We hope that SMCTA and C/CAG will also take all these issues under serious consideration and avoid freeway expansion, adding a new lane to I-101, for this project.
Respectfully submitted,
Gita Dev
Chair, Conservation Committee
Sierra Club Loma Prieta Chapter
Cc Bd of Supervisors, San Mateo County, spurewal@smcgov.org
David Canepa, MTC Commission, dcanepa@smcgov.org
Gina Papan, MTC Commission, GPapan@ci.millbrae.ca.us
CalTrans District 4 caltrans_d4@dot.ca.gov
California Air Resources Board, arbboard@arb.ca.gov