The Myth Spreading Larkspur Station Area Plan DEIR

The Myth Spreading Larkspur Station Area Plan DEIR

The Larkspur Station Area Plan Propagates and Spreads Many Myths

The Larkspur Station Area Plan Draft Environmental Impact Report Propagates and Spreads Many Myths

Larkspur represents a focal point for transit in Marin, where the SMART train terminates, the Golden Gate Ferry and the Marin Airporter converge. The area already experiences acute parking issues either in the ferry terminal lot, or in the Larkspur Landing mall. The freeway is a choke-point for traffic – that has yet to be addressed (e.g. by the Greenbrae Corridor Project) and traffic intersections in the area fall  below the targeted acceptable level D.

Special interests have been focusing on pushing through plans that would allow the building of an additional 920 dwelling units, a hotel and 77,000 square feet of commercial space. This week I reviewed the newly published Larkspur Station Area Plan Draft Environmental Impact Report – the precursor document used to inform final decisions to allow such development in the area. The Station Area Plan was funded by MTC and SMART. Here is what I discovered:

Exaggerated Representation of Bike Path Usage

Page 104 of the Larkspur SAP DEIR makes the following statement:

“The most popular bicycle paths around and through the Plan area include the multi-use path along the Corte Madera Creek, the path along the southbound U.S. 101 on-ramp from Sir Francis Drake Boulevard, and the Cal Park Hill Tunnel Multi-Use Pathway. These paths are all heavily used by commuters and recreational users [emphasis added] alike to access such destinations as the Larkspur Ferry Terminal and the shopping centers located south of the Plan area.

Compared to Car Travel, Bike Usage is Very Low

The actual bike counts in the report show the following usage over a two hour period (car numbers to follow are over a 1 hour period):

- Corte Madera Creek – 103 riders per day
- Southbound 101 on-ramp – 7 riders per day
- Cal Park Hill Tunnel Multi Use Pathway – 73 riders during morning commute

[note: figures should not be aggregated as they may count one rider multiple times]

Travel by Car Exceeds Bike Travel Hundredfold

It is important to remember that, tandems aside, bikes typically have one “occupant”, while cars have multiple occupants. The 2009 US Department of Transport National Travel Trends Survey, page 33 table 16, estimates that each car has on average 1.67 occupants. Another key aspect to remember is that the average bike journey is far fewer miles than the average car journey.

Page 130 provides insight into comparable car usage:

- Incremental car traffic generated by the project alone far eclipses the above existing bike usage: “The proposed land uses at Sub-area 1A are anticipated to generate approximately 7,500 daily trips, including 410 AM peak-hour trips, and 460 PM peak-hour trips.” A further 712 trips are generated by Sub-area 1A. This is not-withstanding existing car trips.

- page 118, Table IV.B-9 shows freeway usage of 5,920 vehicles at peak hour (not per day) and up to 7,910. Applying 2009 US DOT National Travel Trends Survey average occupancy of 1.67 this means that the freeway is transporting between 9,886 and 13,209 people per hour. This represents over 100x the usage of bike paths, 200x considering that the bicycle figures span 2 hours and the car figures just one hour.

Bike path volumes are described as “heavily used by commuters” in the DEIR. The DEIR is clearly stating a significant bias to over-emphasize the importance of bike traffic. This demonstrates partiality. Statements regarding bike path usage should be revised to demonstrate the genuine comparative usage of these transport modes versus others; otherwise the report leads to a misleading outcome.

Much of the New Housing is for Senior [Cyclists]?

The DEIR also references an expectation that the additional units will comprise a significant number of units for seniors. However the DEIR makes no reference that bike ridership by this population is significantly less than a comparable age distributed population. This leads to concerning overstatement and implications of expectation of bike usage, when these older residents may have much greater dependence and usage of cars.

Propagating False Advertising About the SMART Train

Page 124 of the Larkspur SAP DEIR is incorrect. It currently states:
“The SMART rail parallels U.S. 101 and will provide an alternative to this already-congested corridor. The rail project is projected to take more than 1.4 million car trips off U.S. 101 annually and reduce greenhouse gases by at least 124,000 pounds per day. SMART’s environmental studies project 5,000 to 6,000 passenger trips per day will be made on the train and 7,000 to 10,000 daily trips will be made on the bicycle/pedestrian pathway. “
There is no possible way that this statement is valid.

Without Ridership Projections, Claims of Reducing Emissions & Displacing Cars are Invalid

SMART does not have valid and approved ridership projections so statements regarding the number of car trips that will be displaced or greenhouse gas reductions cannot be accurately made. Not only are these speculative, they are almost without doubt incorrect and substantial evidence exists that the opposite is true – that the train will increase greenhouse gas emissions.

In June 2011 the following was stated at the SMART Board meeting, this is documented in TAM meeting notes:
“Commissioner [and Marin Supervisor] Arnold noted that although the updated ridership projections don’t seem to match original projections, a joint review of the Dowling report between SMART, MTC and Dowling resulted in agreement that the numbers were incorrect.”
The Dowling ridership projections are the only projections that exist. They are clearly disputed not only by the authors of the projections, MTC and SMART. No subsequent projections have been published or approved. Therefore any statement regarding ridership, and consequent reduction in car trips or greenhouse gas emissions is reckless speculation, and serves to paint an inaccurate understanding of the impact of the train and associated impact at Larkspur. Such claims should be struck from the record and accurate statements regarding the true likely emissions impact stated.

Claims SMART Reduces Greenhouse Gas Emissions are Invalid

SMART’s emissions are documented on page 15, table 3 of the SMART Vehicle Technology Assessment Final Draft Report.
6,825 g CO2 per vehicle mile
1.1 mpg (diesel powered)
However without an average ridership number it is impossible to arrive at emissions per passenger mile, and therefore make any claim that greenhouse gases will be reduced.

Calculating Train Emissions via National APTA Numbers

Looking at the 2011 American Public Transportation Association Factbook 2011, Table 35 on page 39 we can see national figures for hybrid rail trains like SMART:
-70,000,000 passenger miles
- 1,100,000 gallons of diesel fuel
= 63.6 passenger miles per gallon

Using UnitJuggler and converting from CO2 per km to per mile this converts to
157.6 g CO2 per mile

Transit Emissions Change Over Time

Analysis of Transit vs. Car Emissions Over time; Higher is better (lower emissions)

Analysis of Transit vs. Car Emissions Over time; Higher is better (lower emissions)

Analysis of transit emissions over extended periods demonstrates that transit emissions are not improving over time, they are remaining steady.  In contrast, emissions from cars are steadily improving:

An article in the LA Times dated Dec 12, 2013:  New vehicles set record fuel economy in 2012, EPA reports
“new vehicles hitting an all-time high of 23.6 miles per gallon, according to a new report released by the EPA. That average is a 1.2 mpg increase over 2011 vehicles, a jump that is the second highest in the last 30 years”

Car Emissions Are 50% Lower than Trains

In August 2012 the Obama administration enacted a historic 54.5 MPG fuel efficiency standard. This mandates that new cars achieve 54.5 mpg by 2025. These cars will be common-place and representative by the year 2031.

Cars must be assessed in this timeframe due to the planning horizon. SMART will be in place in 2016 with locomotives having a lifespan of 30 years. So we must consider an operational midpoint at the year 2031.
The average car has 1.67 occupants
See: Table 16, page 33

So this translates to 91 passenger miles per gallon.
Assuming gasoline engines, this means that cars emit 96.5 g CO2 per passenger mile

To summarize cars emit 50% less per passenger mile than hybrid trains such as SMART.
- cars emits 96.5 g CO2 per passenger mile
- hybrid rail emits 157.6g CO2 per passenger mile

Given the above facts, it is mathematically impossible that the SMART train can reduce greenhouse gas emissions.

Note: This excludes all consideration of additional emissions caused by construction of the rails, and transportation of heavy diesel multiple units from manufacture in Tokyo, assembly in Illinois and final delivery to Marin County.

How Should the Larkspur SAP EIR Be Updated

The EIR should be updated as follows:

1) Avoid Stating that the SMART Train Will Reduce Emissions
Please strike from the Final EIR any statement that SMART will reduce emissions and instead clearly state based on a true assessment (not currently provided) that SMART will considerably increase emissions.

2) Clarify that SMART Does Not Have Valid, Approved Ridership Projections
The final DEIR should clarify that SMART does not have any valid, approved ridership assumptions. The most recently published projections are disputed not only by Dowling, the author of the figures but also MTC and SMART itself.Therefore no emissions figures specific to this particular line can be arrived at – only generic figures based on national reported emissions (as provided above).

3) Remove Claims that SMART Will Remove Cars from 101
The final EIR should not make any claim that the SMART train will remove cars from the 101 corridor. Such a claim can only be made should valid, approved ridership numbers exist – they clearly do not and this EIR is propagating misinformation by including such a claim.

Providing Your Feedback to Larkspur’s Planning Department

Whether you live in Sonoma or Marin, we all need to take responsibility for this critical nexus of transit that so many of us pass through daily which can have so much impact on our quality of life. I encourage all to:

2) Submit Your Comments 

It’s very easy to submit comments, but you must do so no later than 5pm on June 2nd.
Neal Toft, Planning and Building Director
City of Larkspur
400 Magnolia Avenue
Larkspur, CA 94939
Be sure to state your name and where you live. If you do nothing more, consider simply sending an email stating “No Project”.