CIS Report No.75-21
      AIR QUALITY CONSIDERATIONS IN TRANSPORTATION PLANNING:

 FINDINGS AND RECOMMENDATIONS ON TRANSPORTATION CONTROL PLANNING



                            PHASE II

                          Final Report
                             to the
          United States Environmental Protection Agency
                                by
                 Elizabeth  Bennett,  Greig  Harvey
                Ann  Rappaport,  and Mabelle Bessey
                Center  for  Transportation  Studies
              Massachusetts Institute  of Technology
                    Cambridge,  Massachusetts

                        December  30,  1975

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                                 SUMMARY




DEFINING CONSISTENCY






•  Further clarification of the consistency procedure is desirable




   both to avoid misunderstandings between E.P.A. regional offices and




   transportation agencies, and to provide a key lever for encouraging




   transportation planning to support E.P.A.'s goals.






•  An analysis of the air quality effects of a long range plan is




   necessarily approximate, but should be used for a consistency deter-




   mination where it has already been performed, bearing in mind its




   approximate nature.  Sketch planning techniques are recommended for




   areas with more general long range plans.






•  Underlying assumptions of long range plans should be carefully scru-




   tinized in terms of their potential impacts on consistency.






a  The major emphasis in assessing consistency of the long range plan




   should be on identifying and encouraging the modification of projects




   and groups of projects with adverse air quality impacts, and on




   encouraging the inclusion of projects which could improve air quality.





•  E.P.A. should encourage D.O.T. to require an air quality analysis for




   T.S.M. measures; an adequate process for consideration of air quality




   should be one basis for a finding of consistency.

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•  The Transportation Improvement Program and the Planning Work Program




   should be reviewed for evidence that T.C.P. measures included in the




   3-C plans are proceeding toward implementation or through the plan-




   ning process (for the Work Program) according to the schedule antici-




   pated .






•  Where agreements on consistency at a project level cannot be resolved




   due to uncertainties in analysis, it is recommended that consistency




   be contingent on agreements to monitor the effects of a questionable




   project, and if necessary, to implement operating policies which




   reduce the air quality impacts.







OTHER ASPECTS OF THE E.P.A./D.O.T. INTERFACE






•  E.P.A, offices must establish communication with both regional and




   division F.H.W.A. offices.






•  E.P.A. should provide advice and criticism to transportation




   agencies throughout the planning process, not just at the end.






•  Liaison with transportation agencies should be a full time position




   for one or two people in each regional E.P.A. office..







•  Continuing involvement with transportation agencies will improve




   E.P.A.'s understanding of the informal transportation decision-making




   process and minimize needless conflict.

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•  E.P.A. should recognize and build on efforts of highway agencies




   to develop environmentally sensitive transportation planning




   processes.






«  E.P.A. should recognize that change in transportation planning




   and programs should be carefully promoted and that any movement




   in the right direction should be considered progress.






•  The Intermodal Planning Group meetings provide a forum for dis-




   cussing air quality issues but cannot be E.P.A.'s sole contact




   with transportation agencies.










«  E.P.A. needs a full understanding of each area's transportation




   issues in  order to function  effectively  in  I.P.G. meetings.






a  E.P.A. should send the same  person(s) to attend I.P.G. meetings




   regularly.






»  The Process Guidelines contain  several provisions which should be




   usyd  to strengthen air quality  decision-making processes  in highway




   agencies.






•  E.P.A. and air quality agencies  should review Action Plan sections




   on air quality issues, monitoring, and air  quality agency participa-




   tion  and  should suggest revisions where  appropriate.

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TRANSPORTATION CONTROL PLANS




   T.C.P. revisions can be used as an opportunity for increasing the




coordination between control planning and the ongoing transportation




planning process.  Two ways of accomplishing this are suggested:




   •  maximize the number of shared elements of the plans, particularly




      through the F.H.W.A./U.M.T.A. transportation system management




      elements.







   •  make the T.C.P. procesj^ compatible with the established urban




      transportation planning process.



In addition:




   «  E.P.A.  should urge F.H.W.A.  and U.M.T.A. ro •equire analysis of




      all appropriate T.C.P. measures as a first step in T.S.M.E. deve-




      lopment (in areas with T.C.P.s);  the T.S.M.E. should then include




      all acceptable T.C.P. measures.






   «  In all areas (with or without T.C.P.s) E.P.A. should urge the




      development of a sound process for air quality consideration




      and analysis as part of T.S.M.E.  decision-making, and should urge




      F.H.W.A, and U.M.T.A. to require information exchange with and




      involvement of other' agencies and the public as part of T.S.M.E.




      development.






   •  E.P.A.  should monitor the development of the T.S.M.E. in cities




      having  T.C.P.s; problems arising with T.S.M.E.s may be indicative




      of problems with any short-range transportation planning process.




                                  4

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•  K.P.A. should encourage each agency conducting transportation




   control planning to develop and document a suitable planning




   and decision-making process, including:  identification of alter-




   natives; analysis of environmental, social and economic impact




   of alternatives; involvement of the public and of other agencies;




   and identification of responsibility for planning and implementa-




   tion.






•  E.P.A. should work with other federal agencies (including F.H.W.A.




   and U.M.T.A.) to assist regional planning agencies in developing




   short-range  transportation planning capabilities, including such




   transitional support as:




      -  review  and explanation of relevant laws and regulations




         training  in quantitative techniques for short-range measures




         research  to develop appropriate methodologies for analysis




         and evaluation of short-range measures




      -  dissemination of information on short-range measures from




         T.C.P. experience






•  E.P.A. should reaffirm its interest in transportation control




   planning.

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PARKING MANAGEMENT PLANS




   •  Parking is an element of an area's transportation system and




      should be managed as part of that system to meet  air quality




      goals.






      o  Parking management plans and all other parking measures




         should be made a part of the T.C.P.






      •  Parking management plans should be developed at the  local




         level, with regional controls,  if necessary, in order to get




         cooperation from all cities  in a region.






     - *  E.P.A. should encourage local  interest in parking management,




         regardless of local motives for parking controls.






      •  E.P.A. should fund a parking management demonstration program




         to help  generate  information on impacts of parking controls.






      e  Data  requirements for parking management plans should be




         relaxed  and made  flexible to encourage cities to get their




         programs under way.







CLEAN AIR ACT  AMENDMENTS






   o  Extension of Clean Air Act deadlines should be considered on a




      case by  case basis, and E.P.A. should require showing reasonable




      annual progress in implementing measures to improve air quality




      as a condition for further extensions.




                                   6

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•  it is n . . inn.ondcd that the governor be permitted to select the




   metropolitan transportation planning organization for transporta-




   tion control planning; another agency could he given responsibility




   for non-transportation related air quality planning.






•  The Air Quality Management Plans should include:  discussion of




   alternatives, evaluation of impacts of alternatives, discussion




   of resources, indication of responsibility for planning and




   implementation, specific commitments for implementation, and



   discussion of future planning activities.





a  The  sanction of cutting off federal funds to non-cooperating areas




   should be applied carefully so  that funding is  retained for pro-




   jects which would help meet air quality goals.






•  Language should be added  to the Clean Air Act requiring that




   A.Q.M.A,s submit for approval documents describing  their air




   quality management planning process, and language in the Act




   should briefly describe topics  to be covered in this document.




   These topics include:  identification of alternatives, identifi-




   cation of impacts of alternatives, involvement  of other agencies




   and  general public in the planning process, monitoring effects of




   A.Q.M.P.s, and coordinating them with other ongoing programs.

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FOREWORD




     This final report has been prepared by the Massachusetts Institute




of Technology pursuant to contract 68-01-2476, "Project to Improve the




Integration of Air Quality Considerations into Transportation Planning—




Phase II," with the United States Environmental Protection Agency.  The




report identifies findings of the M.I.T. research effort and presents




recommendations for future E.P.A. programs and activities.




     The authors extend their thanks to the numerous persons in the




Washington, D. C., Boston, San Francisco and Los Angeles metropolitan




areas who spent substantial amounts of time discussing the transporta-




tion and air quality planning issues with members of the M.I.T. project




staff; to the staffs of E.P.A. Regions I, III, V, IX, and X, who pro-




vided information on current transportation/air quality activities and




assisted in identifying further contacts and information; and to the




staffs of the Federal Highway Administration and Urban Mass Transit




Administration of the U.S. Department of Transportation, who devoted




many hours to discussions with M.I.T. on what could be done to increase




E.P.A./D.O.T. coordination.  We are particularly grateful to Joel




Horowitz of the Office of Policy Analysis, E.P.A., and to John Hidinger




and his staff, Office of Transportation and Land Use Planning, E.P.A.,




for their guidance and support.

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   Lance Neumann of M.I.T. prepared Appendices I and II as part of




his Ph.D. research.  In addition, he contributed to the authors'




understanding of current state and metropolitan transportation planning




and programming practices and provided a number of welcome distractions.




Charna J. Garber and Gilbert High prepared the report and provided




valuable editorial assistance.




   While recognizing these contributions, the opinions and conclusions




expressed in this report are those of the authors and are not necessarily




those of the U. S. Environmental Protection Agency or of the persons




who provided information and assistance in the research.  The authors




take full responsibility for any inaccuracies and omissions.

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                               TABLE OF CONTENTS




SECTION                                                             PAGE




SUMMARY                                                               I





FOREWORD                                                              8




TABLE OF CONTENTS                                                    10




I.  INTRODUCTION                                                     13





    A.  BACKGROUND                                                   13




    B.  DESCRIPTION OF THE PHASE II STUDY                            15




    FOOTNOTES                                                        18




II.   DEFINING CONSISTENCY                                            19




    A.  INTRODUCTION                                                 19





    B.  THE LONG-RANGE ELEMENT                                       23




    C.  THE TRANSPORTATION SYSTEMS MANAGEMENT ELEMENT                29




    D.  THE TRANSPORTATION IMPROVEMENT PROGRAM                       31




    E.  PLANNING WORK PROGRAMS                                       33




    F.  PROJECT LEVEL CONSISTENCY                                    34




    FOOTNOTES                                                        36




III.   OTHER ASPECTS OF THE E.P.A./D.O.T.  INTERFACE                   38




    A.  INTRODUCTION                                                 38





    B.  RELATIONS WITH F.H.W.A.                                       40




    C.  E.P.A./U.M.T.A.  RELATIONS                                    44





    D.  THE INTERMODAL PLANNING  GROUP                                 49




    E.  PROCESS GUIDELINES AND ACTION  PLANS                           51







                                  10

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 S1?TION                                                          PAGE

     FOOTNOTES                                                     53

 TV.   TRANSPORTATION CONTROL PLANS                                  54

     A.   INTRODUCTION                                              54

     B.   T.C.P.S   AND T.S.M.E.S                                     55

     C.   IMPROVING THE T.C.P.  PLANNING  PROCESS                      58

     FOOTNOTES                                                     77

 V.   PARKING MANAGEMENT PLANS                                       78

     A.   INTRODUCTION                                              78

     B,   INSTITUTIONAL CONSIDERATIONS IN PARKING MANAGEMENT         8i

     C.   CASE  STUDIES                                             101

     D.   CONCLUSIONS  AND RECOMMENDATIONS                           130

     FOOTNOTES                                                     14!

 VI.   CLEAN AIR ACT AMENDMENTS                                     145

     A.   BACKGROUND                                                145

     B.   EXTENSION OF THE DEADLINES                                147

     C.   DESIGNATION  OF  REGIONAL AIR QUALITY PLANNING ORGANI-
         ZATIONS                                                   149

     D.   DEVELOPMENT  OF  AIR QUALITY MANAGEMENT PLANS               15!

     E.   SANCTIONS                                                 3.55

     F.   PROCESS GUIDELINES                                        157

    FOOTNOTES                                                     159

BIBLIOGRAPHY FOR SECTIONS I-VI                                   160


                                  11

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 SECTION                                                            PAGE

 APPENDIX I:   THE  POLITICAL  CONTEXT  OF  TRANSPORTATION PLANNING       168

     A.   INTRODUCTION                                                168

     B.   MANY  INTERESTS  VS.  THE  "PUBLIC"  INTERESTS                   168

     C.   INSTITUTIONAL STRUCTURE:  FRAGMENTED ROLES AND
         PAROCHIAL INTERESTS                                         173

     D.   THE DYNAMICS OF DECISION-MAKING:  A REVIEW OF THE
         IMPLEMENTATION  PROCESS                                      177

     E.   SUMMARY                                                     181

 APPENDIX II;  A REVIEW  OF EXISTING  PLANNING AND PROGRAMMING
 PRACTICE                                                           182

     A.   INTRODUCTION                                                182

     B.   OVERVIEW  OF THE PLANNING AND PROGRAMMING PROCESS            185

     C.   OVERVIEW  OF CURRENT PLANNING AND PROGRAMMING PROCEDURES     194

     D.   A COMPARISON OF PLANNING AND PROGRAMMING IN CALIFORNIA
         AND MASSACHUSETTS                                           205

     E.   SUMMARY:  KEY PROBLEM AREAS                                 211

 BIBLIOGRAPHY FOR APPENDICES I AND II                                214

APPENDIX III;   DRAFT LANGUAGE FOR THE CLEAN AIR ACT                 218

LIST OF ABBREVIATIONS                                               221
                                 12

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 I.   IJTRODUCTJ.ON


 A.  BACKGROUND


      Over  thirty  American  cities  require  reductions  in automotive


 vehicle  miles  travelled  (VMT)  in  order  to meet  the air quality standards


 developed  pursuant  to  the  Clean Air Act of  1970.   Development of programs


 to  reduce  VMT  —  transportation control plans  (TCPs) - began in 1973.


 It  soon  became apparent  that TCPs were  meeting  stiff opposition in a


 number of  cities, and  almost everywhere their  implementation was slow.


 Lt  now is  likely  that  most major  cities will not meet the standards for


 transportation -  related pollutants by  the  1977 deadline.


      In  fall 1974 and  spring 1975, the  M.I.T. Center for Transportation


 Studies  conducted a program of research for the U.S. Environmental Pro-


 tection  Agency designed  to identify problems arising in the planning and


 implementation of TCPs and to develop recommendations on future E.P.A.


 actions.   Interviews conducted in three TCP areas, Boston, San Francisco,


 and Phoenix-Tucson, and  in Washington provided the basic information

                                2
 for the  study.  The final report  noted that although confusion over


 legislative requirements, tight deadlines, and lack of experience with


 TCP options all contributed to TCP delay and controversy, lack of coordina-


 tion between transportation control planning and ongoing metropolitan


 transportation planning was an overriding problem.  Not only were there


difficulties in coordinating transportation controls with other trans-


portation plans for each area,  but there also were lost opportunities


for tapping planning capabilities and funds for implementation.   Thus,


                                   13

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the major recommendation of the study was to increase the level of




coordination and, to the extent possible, to integrate transportation




control planning with the ongoing transportation planning processes.
                                  14

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B.  DESCRIPTION OF THE PHASE  II  STUDY




    The current nine-month study was designed to follow up on some of the




recommendations developed in  Phase I.  The program of work included five




tasks:




     • assist in developing a workable definition of consistency-




The 1970 Federal-Aid Highway Act requires that highways constructed under




the Act be consistent with applicable portions of the state implementation




plans (which include the TCPs).  However, further clarification of what




consistency means in practice is needed both by E.P.A. and by transportation




officials.  The first task was designed to explore alternative definitions




of consistency and to develop recommendations concerning how and on what




basis consistency decisions should be made.








     • examine the EPA/DOT interface-





The Department of Transportation's Urban Mass Transportation Administration




and Federal Highway Administration fund the planning and development of




significant portions of the nation's urban transportation systems.  Improved




coordination between D.O.T.  and E.P.A.  would provide opportunities to reduce




the implementation problems T.C.P.s are now facing and to achieve greater
                                    15

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consideration of air quality issues directly in transportation planning.




Tliis task was designed to identify opportunities for improving coordina-




tion among D.O.T. and E.P.A. programs.





• develop recommendations for future activities in transportation control




planning  - The need for examination of a wider range of alternatives,




improved impact prediction and clarified assignments of responsibility in




transportation control planning was identified in Phase I.  The purpose




of this task was to provide insights on how the transportation control




planning process might be strengthened.







• develop guidelines on parking management-




Control of parking shows promise for supporting transit use and reducing




the competitive advantage of the automobile.  However, lack of experience




with parking management and the complexity of the institutional controls




over parking have impeded the development of coherent management




strategies.  In this task, some of the issues of parking management plan-




ning were explored.







• assist in developing Clean Air Act Amendments-




Amendments to the Clean Air Act were proposed by the Ford Administration,




various Senators and members of Congress, and numerous interest groups




in 1975.  This task involved the review of draft amendments and the




development of revised or additional language in response to the problems




identified in Phase I.



                                  16

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     The report reflects information and suggestions obtained through


numerous interviews and working meetings at E.P.A., F.H.W.A., and


U.M.T.A. offices in Washington, and through discussions in the Boston,


San Francisco, and Los Angeles metropolitan areas with federal


regional representatives and with state, metropolitan, and local


transportation officials.  In addiiton, the research builds upon other


work done at the MIT Center for Transportation Studies on transportation

                      3
planning and analysis.


     The following sections summarize work performed under each of the


tasks.
                                 17

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                               FOOTNOTES
1. Clean Air Act, as amended, 42 U.S.C.   1857 et seq.

2. Bennett, E.D. et al.,  "The Transportation Control Planning Process:
    Fundings and Recommendations for Improved Decision-Making", Phase I
    Final Report to the Environmental Protection Agency, March 1975.

3. See , e.g., Manheim, M.L., et al., Transportation Decision-Making;  A
    Guide to Social and Environmental Considerations , NCHRP   Report 156,
    1975; Manheim, M.L.,  et al., "Process Guidelines for Consideration
    of Environmental Effects", Final Report to the Federal Highway
    Administration, MIT USL Report No.  72-11, June 1972.
                                 18

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II. DEFINING CONSISTENCY


A.  INTRODUCTION


    The 1970 Federal-Aid Highway Act requires that highways constructed


with federal assistance be"consistent with any approved plan for the


implementation of any ambient air quality standard for any air quality


control region designated pursuant to the Clean Air Act"  (underscoring


added).  Regulations governing the determination of consistency were


promulgated by the Federal Highway Administration (F.H.W.A.) in

               2
December, 1974^  with a heavy emphasis on the consistency of specific


highway projects in the design and location phase, and lesser emphasis


on overall transportation plans and programs.  Further guidance on plan


and program consistency developed jointly by E.P.A. and F.H.W.A. was


published in April,1975.3


    Even after the distribution of these documents, however, considerable


uncertainty over responsibilities and procedures for determining con-


sistency still exists among the field office personnel of both E.P.A. and


F.H.W.A.   In a few cases, differing interpretations of the procedures


for adjudging consistency have precipitated confrontations between the


two agencies.  In many more cases the field offices have been hesitant to

                                                        4
proceed boldly without further guidance from Washington.


    Further clarification of the consistency procedure should receive the


highest priority from E.P.A., not only to avoid misunderstandings between


E.P.A. regional offices and transportation agencies, but simply because


consistency is a key lever for encouraging transportation planning con-


                                 19

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 sonant  with  K.P.A.'s  goals.   Consistency  determinations  can  help  ensure




 that  plans and  projects  with a clear  likelihood  of  having  adverse air




 quality effects are modified or eliminated  at  the earliest possible




 stage of development;  that  good air quality analyses  are in  fact  per-




 formed  as an integral  part  of the  transportation planning  process; and




 that  projects which are  likely to  improve air  quality are  developed and




 implemented.  The  following sections  provide recommendations  on how




 consistency  determinations  should  be  made.




   We feel it is important  to stress  at the outset  that  E.P.A.'s  role




 in consistency  determinations is not  primarily that of decision-maker.




 Primary responsibility still rests with the Federal Highway Administra-




 tion; and F.H.W.A.'s approach to achieving  compliance with its rules




 and regulations is  to  work  with state and local  agencies on a week-




 to-week basis and  "bring them along"  - F.H.W.A.  rarely finds  it necessary




 or appropriate  to  take an unyielding  stand  in  dealing with the trans-




 portation agencies.  Consistency is particularly an area where a  hard-




 line  approach seems inappropriate, since  the existing models  and




 calculation procedures all are  subject to legitimate  challenge and the




 results are heavily dependent on the  accuracy  of underlying assumptions.




   In some cases, with little or no prior discussion  of its dissatis-




 faction, E.P.A.  has taken a  strong last-minute stand  opposing a positive




consistency determination.   In every  such case of which we have knowledge,




E.P.A. has lost  credibility and harmed its relations with  the agencies




involved, and has had very little success in getting  its viewpoint




                                20

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adopted.  On the other hand, where E.P.A. has taken the trouble to




establish a continuing dialogue with federal, state, and local agencies,




frank discussion of E.P.A.'s positions has been possible, and E.P.A.




has had some success in influencing the direction of transportation




studies.




   We recognize that some E.P.A. offices have been following a strategy




of demanding more than they expect to get in order to force some move-




ment toward their point of view; but we feel strongly that this approach




has been generally counterproductive in dealing with transportation




agencies and is particularly unworkable for consistency determinations.




Enforcement of plan and program consistency provides a good example of




this.  F.H.W.A. can enforce the consistency regulations principally by




denying or threatening to deny certification of a metropolitan area's




transportation planning process, an action which cuts off all federal




funds for transportation plans and programs.  Not only is F.H.W.A. loath




to decertify, particularly without giving the Metropolitan Planning




Organization an opportunity to correct the deficiencies, but decertifi-




cation also runs contrary to E.P.A.'s basic interests, since the federal




funding for transportation measures which might have air quality benefits




is thereby cut off.




   Slow implementation of transportation control plans poses another




problem for consistency determinations, especially when the reasons for




delay are lack of funds, inability to obtain required legislation, or






                                21

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evidence of  negligible  air  quality benefits and/or severely adverse




impacts.  E.P.A. has  sometimes  felt  that  its  legal mandate requires




insistence on  implementation even in the  face of  these problems, but




without much effect.  Fighting  these battles  over again under the guise




of consistency determinations offers little likelihood of success.  We




strongly recommend  that E.P.A.  use the consistency requirement to put




pressure on  transportation  agencj.es  to implement TCPs  where delays in




implementation appear to be due simply to foot-dragging, but where the




serious problems cited above exist,  such pressure is bound to backfire.




(In such areas, the round of TCP revisions proposed for 1976 and possible




modifications to the Clean Air Act offer the  greatest promise for




achieving faster implementation of TCPs).   The discussions which follow




reflect our conviction that the cooperative, negotiatory approach taken




by several E.P.A. regions is the sounder one  in all cases and should be




adopted universally.
                                22

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 B.  THE LONG-RANGE ELEMENT





    The long-range plan describes those capital projects and programs




 that an urban area would like to implement over the next 20-30 years.




 Thus, it should indicate the relative emphasis on highways and transit;




 areas where new development or changes in land use are believed to require




 a reorientation of the transit system; and a general indication of the




 growth policies of the area and how transportation will be coordinated




 with those policies.   The long-range plan thus provides an opportunity






 to  assess  the extent  to  which the  evolving transportation and  land use




 patterns will minimize adverse air quality impacts.   It also may permit




 the anticipation  of problem areas,  so  that modifications in plans  and




 other corrective  actions can be taken  to  avoid  air  quality problems  at




 a later  date.




    The current  F.H.W.A./E.P.A.  guidelines  for  analysis  of  consistency




 appear to  require detailed  air  quality analysis  for  the  long-range plan,




with  heavy reliance on modeling (for those  areas with severe air quality




problems).    Such emphasis  on the  long-range plan may create problems




 for a number  of metropolitan  areas who in  recent years have deemphasized




the 20-30 year plan.  Given  the extremely high cost of plan development




and the large degree of  uncertainty in 20-year projections of basic




data such as population  and land use, there is widespread doubt  that the




development of detailed master  plans supported by large-scale modeling
                                23

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is worth the  time and cost required for preparation  .    The widespread

recognition that citizen participation in support of transportation

decisions is  both desirable and necessary for implementation of projects

also has contributed to the increasing focus on shorter term plans and

programs.  Furthermore, difficulties in estimating future costs and

levels of funding have made it nearly impossible to formulate a realisti-
                              Q Q                                   -1 f\
cally budgeted long-range plan ' .   Finally, new D.O.T. regulations

governing the transportation planning process reflect the increased

emphasis on middle- and short-range planning horizons.  In light of these

shifting priorities and shortcomings of traditional long-range planning,

long-range planning efforts have come to put little emphasis on placing

lines on a map, concentrating instead on identifying broad transporta-


tion corridors  based on varying assumptions about population, land use,


etc.; on discussing different mixes of modes and levels of service for

the corridors, and exploring their implications; and on setting broad

policies for  investment priorities.  Needless to say, it is difficult to


do a detailed air quality analysis on so general a plan.

   Even with a long range plan developed in the traditional way, detailed

air quality analysis remains difficult.  Most long-range plans simply

cannot have the necessary precision to permit accurate air quality

determinations; that level of detail is achieved only upon completion


of location, and in some cases, design, studies.  Even with a highly


detailed plan, inaccuracies in traffic, land-use, and population


projections will make it impossible to say definitively what regional


                                24

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VMT will be, and  thus to predict air quality accurately.  Furthermore,




 inclusion  in the  long-range plan is never a guarantee that a particular




project or group  of projects will be implemented at all, in the form




shown, and/or within the projected time frame - political opposition or




lack of funds, for example, can stop a project.




   For all these  reasons, any analysis of the air quality effects of




a long-range transportation plan is necessarily approximate.  This raises




questions about how much time and money should be devoted to making air




quality estimates for 20-30 years into the future.  We are of the opinion




that where the detailed models and plans already are developed they




should be used for consistency determinations, but that the results must




be recognized for what they are - highly uncertain approximations.  In




areas where the long-range plan is a more general goal and investment




priorities—oriented documentj   it is not necessarily desirable to




spend significant portions of the area's planning money on more detailed




modeling and plan specification.  Instead, we would recommend the use




of sketch-planning techniques for both the traffic and air quality




estimates.




   Regardless of which modeling technique is chosen, it will be important




to look carefully at the underlying assumptions of the plan.  In fact^




one of the things EPA can do to improve the long-range plan is to




promote a fuller discussion in the plan of growth assumptions,anticipated




funding levels and sources, assumptions about traveller preferences,




anticipated problems with implementation, and so on.  For example, in




                                25

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reviewing the long-range plan for consistency, the following questions




might be asked:




   •  i.s tliurc a reasonable discussion of the growth implications of the




     plan and of the anticipated changes in VMT resulting from this




     growth?




   • has an estimate been made of the costs of implementing the plan?




     Wliat would the sources of funding be and what is the likelihood




     that the required amont of funding would be available within the




     appropriate time frame?  Are the implications of different levels




     and sources of funding adequately discussed?




   • has full consideration been given to the assumptions which underlie




     the long-range plan, including growth projections, relative prices




     of different modes, and tripmaking behavior?




   By exploring such questions, the agency responsible for air quality




can get some idea of the long-term issues which may affect the long-




range plan.   The air quality agency should be raising questions about




the validity of assumptions and tagging the areas where major uncer-




tainties require that future development be monitored.




   The long-range plan also should be examined for consistency of the




particular elements.  For example, the air quality agency should look




at the balance of highway and transit projects; what is reasonable




depends on the characteristics of the area - the air quality problems,




the existing transportation system, etc.  Any long-term measures for




transportation control or air quality maintenance also should appear in




                                 26

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 the long-range  plan.  Finally,  there should be some consideration,




 wherever appropriate, of operations policies for existing  facilities and




 proposed additions.




   Because many  of the measures  in the  long-range plan may never be




 implemented  in  the anticipated  time, the consistency determination should




 be made for  several possible subsets of the plan.  One way to get started




 is to look at sets of projects based on alternative levels of funding.




 Another way  is  to examine the no -build alternative.




   The major thrust in assessing consistency of the long-range plan




 should be in identifying and encouraging the modification of projects




 or groups of projects with adverse air quality impacts, and in




 encouraging  the  inclusion of projects which could improve air quality -




 in general,  to  foster full consideration of air quality issues in long-




 range planning.  Because the implementation of the plan is so far off,




 there is no real urgency to have immediate inclusion of every possible




detail required  for a complete air quality analysis.  It is more




 important to show yearly progress toward full integration of air quality




 issues into transportation planning.




   Since EPA and the air quality agencies do not have direct enforcement




powers, they will have to rely on their persuasiveness to achieve full




consideration of air quality in the long-range transportation plan.




Consistency is determined by the MPO itself, and any deficiencies are




then reviewed by the F.H.W.A. regional administrator as a factor to be




considered in certification decisions.   The serious implications of






                                 27

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decertification -  it basically  is a negative action which may harm more




than  it  furthers the overall interests of F.H.W.A. - make it a difficult




option for F.H.W.A. to exercise.  F.H.W.A. has other, more subtle methods




for achieving compliance with the rules it considers most important,




including jawboning - threatening to decertify or to delay approval




of projects 5  granting conditional certification, which puts the MPO on




notice to correct  the deficiencies in its planning process; and promoting




these rules through constant contact with regional and state highway




agencies.  Divisional and regional offices review MPO planning processes




for compliance with these priority rules, and frequently contact the MPO's




to provide guidance when rules  are not being followed.  Thus, F.H.W.A.




achieves a certain degree of compliance without employing a drastic




measure  like decertification by interacting closely with the highway




planning agencies  to promote acceptance and implementation.  This implies




that E.P.A. cannot expect to have a limited role in transportation




planning, by undertaking only a yearly review of documents provided by




the planning agency, for example.  E.P.A. must work closely with




F.H.W.A.  at all levels to ensure that consistency becomes a "high




priority" rule in  regional and divisional offices, and E.P.A. itself




must interact closely with the MPO's to promote the consistency guide-




lines.
                                 28

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 C. THE TRANSPORTATION SYSTEMS MANAGEMENT ELEMENT



    The Transportation Systems Management Element (TSME) is a recent



 requirement promulgated jointly by the Federal Highway Administration



 and the Urban Mass Transportation Administration (U.M.T.A.)  .   Under



 the regulations, the metropolitan planning organization is "required to



 investigate ways of improving the efficiency of the existing transporta-


                                                             12
 tion system.  Options recommended for investigation include:



    • traffic operations improvements



    • preferential treatment for high-occupancy vehicles



    9 improved pedestrian and bicycle facilities



    • management and control of parking



    • measures to decrease peak period travel



 U.M.T.A.,  but not F.H.W.A.,  requires  the inclusion  of  some T.S.M.


                                                                        13
 measures  in the annual  element of the Transportation Improvement Program.



    Suggested T.S.M.  measures include  most of the  transportation options



 considered appropriate  for T.C.P.'s  (with the exception of inspection



 and  maintenance,  retrofit,  gas rationing, and other  such measures not



 dealing explicitly with  the  transportation system).  Furthermore, air



 quality is  listed as  one of  the  factors  to be considered in the selection



 of T.S.M.  measures.    Therefore,  this new program offers  considerable



 opportunity  for  fostering  consistency between transportation and air



 quality programs.



   Because this  is a new program, MPO's will  need considerable guidance



on how to develop the T.S.M.,  and  initial efforts at T.S.M. planning




                                 29

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necessarily will be short on detail.  For areas with transportation




control plans, one way  to get started would be to analyze  T.C.P.




measures  for  possible inclusion  in the T.S.M.E.   Consistency of the




T.S.M.E.  could then hinge on whether all the appropriate T.C.P.




measures  had  been included.  If  one or more measures did not appear,




without reasonable justification for omission, the T.S.M.E. would be




found inconsistent with the state implementation plan.  Reasonable




justification might be:




   , a measure does not come under the purview of the T.S.M.E. as




     defined  in DOT guidelines




   • no federal or state programs exist for funding the measure and




     development of such a funding program is unlikely




   • a thorough assessment of political acceptability indicates that




     the  measure would never be  implemented




   . an impact analysis indicates that the measure very likely would




     not  achieve the desired air quality improvement and/or would have




     other highly undesirable effects




   • another  measure is substituted which would achieve the same air




     quality  improvement.




   Whether or not an area has a TCP, E.P.A.  should encourage DOT to




require air quality analyses for T.S.M.  measures, and an  adequate




process for considering air quality in the T.S.M.E. should be one basis




for a finding of consistency.






                                30

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D. THE TRANSPORTATION IMPROVEMENT PROGRAM

   The Transportation Improvement Program, prepared by the Metropolitan

Planning Organization,    consists of:

   • a 3 - 5 year program of projects listing measures from the long-
                                               -/ S r*£
     range element and the transportation systems management element

     which are scheduled for implementation over the next 3-5 years

     (the exact length is at the MPO's discretion), and stating the

     implementation schedule for those projects.

   • an annual element which includes a specific program of projects for

     the next year, with detailed information about work to be performed,

     estimated costs, anticipated revenue sources (which must cover

     projected costs), and the agencies who will perform the work.

   Both parts of the TIP will include all Federally funded projects, as

well as non-federally funded projects recommended from the TSME (for

informational purposes).

   The TIP should be reviewed for evidence that TCP measures included in

the 3-C plans are proceeding toward implementation according to the

schedule anticipated in the SIP.  If such progress is not demonstrated,

and adequate justification is lacking, the TIP cannot be consistent with

the SIP.  Again, adequate justification might include:

   • failure to obtain anticipated project funds, due either to a lack of

     federal appropriations or to failure of the state or locality to

     vote the requisite funds

   • new information about the project indicating that it may not achieve
                                 31

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     the desired goals or may have previously unforeseen negative




     side effects.




It must be cautioned that the TIP is a new program and will have its




share of problems.  In particular, the new requirement for accurate




budgeting (and therefore a realistic appraisal of work to be performed)




initially may be difficult for agencies which are not accustomed to




projecting cost and revenue streams.  Also, political considerations may




make it very difficult to prioritize and pare down the list of proposed




projects in an urban area.  Substantive review of this process should




take place, since accurate budgeting is in the interest of both EPA and




DOT.  Note, however, that a small excess of cost over revenues may be




desirable, so that a project cancelled for extraordinary reasons may be




replaced by another project already in the annual element.  We feel




strongly that extensive air quality analyses should be performed on the




3-5 year program, because the program will have sufficient detail to




support such an analysis and there is a reasonably high probability of




implementation.  It may be worthwhile also to look at subsets of the




program, for example by deleting projects with questionable funding or




acceptability.
                             32

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 E.  PLANNING  WORK PROGRAMS




    The  planning  work  programs  consists of:




    •  a  unified planning work program, listing activities  for which




      planning funds will be expended over the subsequent  one or two year




      period




    •  a  planning  prospectus, detailing the full planning horizon for




      activities  appearing in the unified work program.




 Together these documents describe the anticipated transportation plan-




 ning  activities  for the urban area.




   The  planning work programs should be reviewed for evidence that TCP




measures included in the 3-C plans are moving through the planning




process according to the schedule anticipated by the SIP.  A lack of




such progress without adequate justification would result in a finding




of inconsistency.  Criteria for adequate justification might be similar




to those for the TSME, i.e., changes in funding,  a shifting political




climate, or new information about potentially adverse impacts.
                                   33

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 F.  PROJECT LEVEL CONSISTENCY




    Localized impacts  of highway projects  often cannot  be  determined




 until the details developed in location and  design are available.  There-




 fore,  it  is important to review air  quality  impacts of specific  projects




 in  the later stages of their development.  The methodologies  for




 estimating localized  air quality effects  are relatively straightforward.




 However,  determining  the region-wide effects of a  specific highway




 segment is the  subject of considerable  disagreement among transportation




 professionals.




    One source of difficulty is estimating how much traffic on a  proposed




 facility  is induced and how much simply is diverted from  other facili-




 ties.  Proponents of  a highway facility argue that most of the traffic




 will  be diverted from lower-speed  facilities and   therefore will flow




 more  smoothly and at  a higher  speed  than  previously, while opponents




 argue  that  much  of the traffic will  be  induced  and therefore  will




 cause  a large net increase  in  VMT  and an  overestimation of average




 speeds on  congested facilities.  Since  air pollution generated by the




 facility depends on traffic  volumes  and average speeds, and the  region-




wide effects  depend on levels  of induced versus diverted  traffic, the




 estimation  of these effects  is central  to a  determination of  the air




 quality impacts  of the facility.   The methodologies commonly  used for




estimating  these effects  are so dependent on their underlying




assumptions  that  they  do  not lend  themselves  to overconfidence and,




while they may provide  some  indication  of region-wide  effects, they are




hardly conclusive.

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    Another  problem is  that  the  volumes,  speeds,  and  proportion  of  induced




 traffic  depend  on other  developments  in  the  transportation  system.  For




 example,  traffic  on a  particular  facility  may  depend  on  the level  of




 transit  developments and improvements to other highways  in  the  broad




 corridor.   Volumes and speeds also would be  affected  by  land use develop-




 ments, which  may  themselves be  influenced  by the transportation develop-




 ment  in  question.   Thus,  the assumptions which must be made about  future




 developments  introduce a high degree  of  uncertainty  into estimates of




 regional  air  quality effects for  a particular  facility.




    While  we recommend  that  regional air  quality  effects  be  analyzed, we




 recognize that  uncertainties in the analysis will lead to disagreements




 in  certain  cases  over  whether a project  is or  is not  consistent with




 an  area's air quality  requirements.   Because of  this  disagreement, it




will  be difficult  to prevent the  construction  of some facilities with




 potentially adverse  air  quality impacts  - and  then prevention may be




unnecessary.  Where  disagreements cannot be  resolved  otherwise, we




 strongly  recommend  that  consistency be contingent upon reaching agree-




ments to monitor  the air  quality  effects of  questionable projects and,




where monitoring  shows a  need,  to implement  operating policies which




reduce the  air  quality impacts  (for  example,  placement of  a with-flow




exclusive bus lane on  a  highway whose actual  traffic is above




acceptable  levels.)  The results of monitoring  also should be considered




in updating MPO plans and programs, and in assessing  the validity of




assumptions and models used  to  predict air quality impacts.
                                35

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                      FOOTNOTES  -   SECTION IT
 1.    Clean Air  Act,  42  U.S.C.  1857  et  seq.
 2.    U.S.  Department  of  Transportation,  Federal  Highway Administration,
      "Air  Quality  Guidelines  for  Use  in  Federal-Aid  Highway Programs",
      23  C.F.R.   770.200  -  700.206  Also  published  in the  Federal Register,
      Dec.  24,  1974 (39 FR  44441-44443).

 3.    U.S.  Department  of  Transportation,  Federal  Highway Administration,
      "Guidelines  for  Analysis  of  Consistency  Between Transportation and
      Air Quality Plans and Programs",  prepared jointly by the Federal
      Highway Administration and the Environmental  Protection Agency,
      April 1975.

 4.    These comments are  based  on  interviews and  telephone discussions
      conducted  in  the Fall of  1975  with  individuals  from  EPA Regions I,
      II, III, V, and  IX, and on notes  from a  meeting on December 10, 1975
      at  Region  IX  in  San Francisco, attended  by  EPA  regional employees
      who are involved in consistency deliberations and who have dealt
      with  transportation planning organizations.

 5.    op.cit., U.S. Department  of  Transportation, F.H.W.A., "Guidelines
      for Analysis  of  Consistency....", pp. 6, 7, 9-14.

 6.    Suhrbier,  John H.,  and Elizabeth  D. Bennett (Eds.)."Proceedings of
      a Panel Discussion  on the Interrelation  of Transportation System
      and Project Decisions."   In  consultation with U.S. Department of
      Transportation,  Federal Highway Administration, Office of Environ-
      mental Policy, November 1, 1973.

 7.    ibid.

8.    Neumann, Lance,  Integrating  Transportation System Planning and
      Programming: An  Implementation Strategy Approach,  PhD. Thesis,
     Department of Civil Engineering, Massachusetts Institute of
     Technology, January 14, 1976.

9.    See Appendices I and  II for  some discussion of budgeting problems.
                                  36

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10.  (a)  U.S. Department of Transportation, Federal Highway Administra-
        tion, "Urbnn Transportation Planning", 23 C.F.R.  450.100-
        450.122 plus Appendix.
    (b)  U.S. Department of Transportation, Federal Highway Administra-
        tion, "Transportation Improvement Program", 23 C.F.R. 450.300-
        450.320.
    (c)  U.S. Department of Transportation, Urban Mass Transportation
        Administration, "Urban Transportation Planning", 49 C.F.R.
        613.100.
    (d)  U.S. Department of Transportation, Urban Mass Transportation
        Administration, "Transportation Improvement Program", 49 _C._F_._R.
        613.200, 613.202.  These regulations were promulgated together
        in the Federal Register,  September 17, 1975 (40 FR 42975 -
        42984).

11.  op.  cit., 23 C.F.R.  450.100 - 450.122 and 49 C.F.R.  613.100.
    See especially the Appendix following 450.122 for F.H.W.A.'s
    interpretation of transportation systems management.

12.  Ibid..

13.  op.  cit., 49 C.F.R.  613.202 (40 FR 42984)

14.  op.  cit., 23 C.F.R.  450.100 - 450.122 (40 FR 42978)

15.  op.  cit., 23 C.F.R.  450.300 - 450.320 (40 FR 42979 - 42983)

16.  op.  cit., 23 C.F.R.  450.114 (40 FR 42977 - 42978)
                                  37

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I I J: .   OTJ1KK ASPECTS OF THE K.P.A./D.O.T INTERFACE




A.   INTRODUCTION




     This section examines several opportunities for increasing the co-




ordination between planning for transportation controls and ongoing




urban area transportation planning.  Since better coordination among




programs depends upon building sound working relations between E.P.A.




and the various transportation planning organizations, emphasis is




placed on those areas where opportunities exist to improve interagency




cooperation.




     One difficulty in integrating control planning with ongoing urban




transportation planning is that T.C.P.s often include strategies such




as inspection and maintenance requirements, retrofit programs, and gas-




oline rationing, which are not among the usual responsibilities of




transportation agenices.  On the other hand, because such strategies




are widely viewed as onerous, there is pressure for transportation a-




gencies to assume a greater portion of the air quality improvement bur-




den by implementing the other common T.C.P. measures—carpooling,  auto




restraints,  increased transit use, etc.  A quick look at T.C.P.s in-




dicates that many transportation agencies could, in fact, contribute




more.   Many T.C.P. s, for example, do not yet include all of the area's




transportation activities which might be expected to improve air quali-




ty.   Two factors,  however, appear to make many transportation agencies




reluctant to get deeply involved in T.C.P. development.   Agencies fear
                                38

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the enforcement orientation of T.C.P.s, which state that a project shall




be implemented, preferring to have the flexibility to modify, postpone,




or delay a project should circumstances so warrant.  Also, agencies are




not anxious to be obligated to try to implement projects which have ad-




verse effects or which are highly controversial simply because such pro-




jects would improve air quality.




     Proposed changes to the Clean Air Act (see Section VI) would




alleviate these problems by extending the attainment deadlines, allowing




for more flexibility in strategy selection, and requiring considera-




tion of social, economic, and environmental impacts in addition to air




quality.  The proposed amendments would shift the emphasis in control




planning from attainment at any cost to attainment as soon as reason-




ably possible, a position far more palatable to transportation agencies.




In addition, the proposals would allow for more attention to the process




by which transportation controls are developed and selected, and thus




would bring E.P.A.'s responsibilities closer in line with D.O.T.'s.




     Regardless of the fate of the amendments, however, much can be done




to increase E.P.A./D.O.T. cooperation.  The recent F.H.W.A. - U.M.T.A.




regulations calling for analysis of short-range, efficiency-oriented




transportation options  provide a new "push" for transportation agencies




to consider options which would (among other things) improve air quali-




ty.  D.O.T. agencies also are placing increasing emphasis on tying to-




gether the planning,  budgeting and programming of transportation im-




provements.
                                  39

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 B.  E.P.A./F.H.W.A. RELATIONS


      E.P.A.'s relations with F.H.W.A. sometimes have been strained, but


 personnel in both organization note that there are signifcant areas of


 agreement and opportunities  to enhance interagency cooperation.   The


 need to make determinations on the consistency of highway programs and


 projects with State Implementation Plans requires good working arrange-

                                  2
 ments between E.P.A.  and F.H.W.A.  ;  and as F.H.W.A.  has placed increas-


 ing emphasis on short-range,  low capital transportation options,  compat-


 ibility between the two organizations'  programs has  increased. Since


 F.H.W.A.  is  the guiding force in much of today's transportation plan-


 ning and  implementation,  it is crucial  to E.P.A.  to  take all  reasonable


 steps to  strengthen its relationships with F.H.W.A.   The discussion be-


 low identifies  some of  the  problems  which have  arisen in E.P.A.'s  deal-


 ings  with F.H.W.A.  and  points to areas where coordination  could be


 increased.


      One of  the most commonly voiced  criticisms of E.P.A.  is  that,  in


many  regions, E.P.A. personnel  simply haven't established  sufficient


 ties  to the  transportation  agencies, whether federal,  state or local.


Many F.H.W.A. personnel feel  that the majority of E.P.A.'s difficulties


with transportation agencies  stem from this lack of contact and the


resulting misunderstanding  rather than from inherent, unresolvable con-


flicts.



     In dealing with F.H.W.A., E.P.A. regions occasionally have run into
                                40

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difficulty because they do not fully understand the relationships be-




tween F.H.W.A. region and division offices.  The responsibilities and




degree of autonomy of the division offices vary considerably from region




to region and state to state; in any event, E.P.A. must coordinate with




both levels.  In one state, members of the division office staff re-




marked that E.P.A. never consulted them until E.P.A. wanted their rati-




fication and support; E.P.A. never sought advice from the division but




(as one member of the division office put it) "preferred to go over




[division personnel's] heads to the F.H.W.A. Regional Office."  The




division personnel were only mildly offended by this, but did feel




strongly that since they dealt with the state and local transportation




agencies on a day to day basis (whereas the region office had much less




contact with those agencies), E.P.A. was ignoring a major opportunity to




influence transportation planning.  In another area, the E.P.A. region




dealt  almost exclusively with the F.H.W.A. division office and the




state and local agencies on consistency matters, then asked the F.H.W.A.




region to consider decertification—a request that came out of the blue,




so far as the F.H.W.A. region knew!




     F.H.W.A. personnel also have expressed concern that some E.P.A.




offices actually try to minimize their contact with state and local




transportation agencies, and then, when decisions are imminent, come




forward with objections or  proposed modifications.  The E.P.A. offices




have argued that they have no alternative, since they do not have
                                 41

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 enough staff to stay in weekly communication with all of  the transpor-




 tation agencies in their multi-state regions.   Even so,  criticisms




 raised very late in the planning and decisionmaking process  usually




 are ignored, simply because it is so difficult and expensive to  make




 changes when a study is nearly complete.   More important,  a  number  of




 transportation agencies have voiced strong resentment over this  E.'P.A.




 practice,  feeling that this is an unfair  and unwarranted  tactic.  It is




 strongly recommended that E.P.A. regional offices make clear assignments




 of responsibility to staff members for maintaining contact with  the




 transportation agencies of the region—not just the federal  and  state




 organizations, but also the M.P.O.s and (to a lesser extent)  major




 transit agencies and even the large municipal transportation staffs.




 To the extent possible, transportation liaison should be  a full  time




 position for one or two persons in each region, since when an assort-




 ment  of E.P.A. people are dealing with various aspects of  transportation,




 not only is it difficult for persons outside to determine  who at E.P.A.




 should be  contacted, but E.P.A.  itself loses a lot of information and




 diminishes its ability to deal effectively in transportation.




      A final point is that the Federal Highway Administration and most




 state highway agencies are proud of the fact that they have  developed




 procedures for public participation and analysis  of social,  economic,




 ;md environmental  effects of their plans  and projects.  A  frequent




 complaint  is  that  E.P.A.  personnel appear not  to  recognize highway




 planners'  achievements  in  protecting  the  environment  and in fostering




multi-objective highway  planning.   Some highway personnel counter that
                                    42

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in striving to improve air quality^ E.P.A. has ignored the potentially




adverse effects some of its proposals would have.  It is in E.P.A.'s




interest to recognize and build upon the accomplishments of highway




agencies in developing environmentally sensitive transportation planning




processes and, so far as possible within its legal mandate, to consider




the full range of effects of proposed transportation control measures




in selecting those to be implemented.
                                    43

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C.  E.P.A./U.M.T.A. RELATIONS




     The Urban Mass Transportation Administration shares many objectives




with E.P.A.  U.M.T.A. funds for capital and operating expenses, both




Tor conventional bus and rail transit and for innovative forms such




as Dial-A-Ride, have brought about a resurgence of interest in public




transportation in American cities.  The Administration's goal is to




encourage greater use of public transportation throughout the United




States through development of new transit systems and services, up-




grading and renovations of existing systems, and improvements in tran-




sit management and operations.  In addition, U.M.T.A.'s mandate to in-




crease transit efficiency has led to greater interest in preferential




treatment for high occupancy vehicles, exclusive rights~of-way for tran-




sit vehicles, and other traffic management measures which increase the




competitiveness of public transit vis-a-vis the automobile.




    Despite  this emphasis on  improving transit, results have been




slow  in coming.  At  the federal level, appropriations have not kept




pace  with  local needs; requests under most programs  far outstrip




available  funds, so  that many  localities are disappointed  in




their efforts  to improve transit.  At the local level, rarely  is




 there a continuing source of  funding  producing large enough reve-




nues  to meet matching share requirements, and so funds must be raised




through bonds—which voters have been turning down lately.  Furthermore,




operating  costs still are primarily .1 local responsibility, and, given
                                  44

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the massive deficits incurred by many transit systems, local govern-




ments and taxpayers are wary of entering or expanding their roles in




the transit business.




     Institutional and legal problems also hamper transit service deli-




very.  In many areas, laws and regulations and labor contracts limit




the types of service that can be provided.  In some areas, transit




union rules against split shifts make it infeasible to increase com-




muter services, since off-peak demands cannot support a large work force.




In other areas, work rules prevent the operation of Dial-A-Ride systems;




and state courts have held that government-operated Dial-A-Ride and jitney



services constitute unfair competition with taxi operations.  Some areas




also have difficulty in obtaining certificates of necessity and con-




venience for flexible bus routing.  Management attitude and practices




also can slow transit improvements.  Many transit organizations are




so used to having to fight for survival that the idea of entering new




markets and trying new kinds of service is frightening to them.  The




very complexity of the institutional structure for transit also can




make it difficult to change transit practices.  In some metropolitan




areas, transit is provided, in part, by private companies and, in part,




by one or more public authorities; simply getting routes and schedules




properly coordinated is a major accomplishment.




    Under these circumstances, U.M.T.A. has learned that the only way




transit improvements can occur is through a lot of hard work by every-




one involved and a willingness to accept gradual progress.  U.M.T.A.
                                   45

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 officials recognize that E.P.A.is a potential source of support for tran-




 sit improvements, but have voiced concern that some E.P.A officials




 have not always recognized the delicate balance in which most transit




 achievements hang, have expected too much too soon, and have not develop-




 ed a sufficient understanding of transit problems.  Therefore, while




 U.M.T.A. is anxious to increase its dialogue with E.P.A. and to improve




 coordination between E.P.A. and U.M.T.A. programs, it is cautious about




 openly joining forces with E.P.A.




     In one case, for example, the  regional U.M.T.A. office had prodded




 the local transit agency for months to investigate ways of increasing




 operations efficiency.   After a series of negotiations, the transit




 agency reluctantly agreed to perform a small study.  U.M.T.A.  viewed




 this study as a major victory despite its modest  proportions and aims,




 since  it was the first  sign of transit agency willingness  to consider




 non-capital  improvements in a systematic way.  When the topic  was




 raised in the Interraodal Planning  Group meeting,  however,  the  E.P.A.




 representative - who  knew nothing  of  the previous negotiations -




 expressed doubts about  the  usefulness  of the proposed  study and ques-




 tioned  the priority being given it.  The transit  agency used E.P.A.'s




 lack of  support  as an excuse  to back out of  the study.   This incident




 seriously damaged U.M.T.A./E.P.A.  relations.




    U.M.T.A. officials also have expressed their willingness to  work




with E.P.A. to coordinate the new Transportation  System Management

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Clement with T.C.P. requirements.  This is particularly auspicious for




L.i'.A,, since U.M.T.A.  (but not F.H.W.A.) is requiring programming of




I.S.M. n-.easures.  U.M.T.A. officials are concerned, however, that E.P.A.




will press for i?very T.C.P. measure to be included in the T.S.M.E.,




.'ven when there is serious local objection to a measure.  Since the




T.S.M.K. requirement is new and controversial, U.M.T.A.'s preferred




strategy is to give areas tine to develop competence in short-range




planning and not to require a sophisticated product the first round;




too many demands, it is feared, could sink the program.




    Finally, even though U.M.T.A. legislation and other federal laws




would imply that coordination with E.P.A.'s programs in particular and




air quality  in general should be factors in transit decision-making,




U.M.T.A. officials are extremely reluctant to see this link become




js explicit as F.H.W.A.'s "consistency" requirements.  U.M.T.A. per-




sonnel are concerned that if E.P.A. were given a najor role in transit




decision-making, air quality benefits would be raaxinized to the




detriment of other U.M.T.A. objectives.




    In short, then, U.M.T.A. has shown a willingness to cooperate with




E.P.A. and to promote coordination of E.P.A. and U.M.T.A, programs.




U.M.T.A. is wary, however, about E.P.A.'s single objective orientation




and its inexperience in dealing with transit problems.  E.P.A. could




minimize sone of U.M.T.A.'s concerns if E.P.A. regional offices would




devote more attention to developing a practical understanding of the
                                  47

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transit organizations, transit objectives, and transit problems in the




areas they deal with.  But E.P.A. must recognize and respect the fact




that transit objectives and U.M.T.A.'s responsibilities are not limited




to air quality improvement.

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 n.  THE INTERMODAL PLANNING GROUP




      The Internodal Planning Group (I.P.G.) was established to coordi-




 nate decision-making among the Department of Transportation's modal




 agencies and, to a lesser extent, among D.O.T. and related federal




 agencies,"  E.P.A. is an ex officio member of the I.P.G.  both at the




 federal and at the regional levels,




      The I.P.G.  provides an established,  formal opportunity for con-




 sidering transportation decisions which involve or affect  more than one




 federal agency.   At the regional  level,  the I.P.G.  should  deal princi-




 pally  with  M.P.O.  plans and programs,  providing guidance on the vari-




 ous  processes and  documents required under federal  regulations and  re-




 solving disagreements  among federal agencies  over  interpretation of




 those  regulations.   However,  in many areas, most of the discussion  and




 negotiations  on what metropolitan  transportation agencies  should (or




 can) do goes  on through  informal  channels.  Thus, the I.P.G. meetings




 represent only a small  portion of  the basic dialogue behind transporta-




 tion decision-making.   For  E.P.A,  to be effective, it must  develop the




 same informal lines of  communication and keep abreast of interagency




discussions as they takeplace.  In  fact, to the extent that the  I.P.G.




meeting merely ratifies informally  reached decisions,  it is too  late for




E.P.A.   co try  to  make changes; E.P.A.  will have more influence through




tiie informal channels.





     In working with the I.P.G.,  E.P.A.  Regional Offices must consider

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rarefully the manner in which they assign staff to transportation re-




sponsibliti.es.  Not only should one or more employees be assigned full-




time to transportation issues and given clear instructions to keep in




contact with all the relevant transportation agenices, as discussed in




part B of this section, but the same person(s) should attend the Intermo-




dal Planning Group on a regular basis.
                                  50

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E.   PROCESS GUIDELINES AND ACTION PLANS




     The Process Guidelines  were developed in response to Section




109 (h) of the Federal-Aid Highway Act of 1970, which requires that full




consideration be given to social, economic, and environmental effects




throughout the planning of highway projects, including system planning,




location, and design.  The guidelines, which apply to both metropolitan




area and statewide planning, require each state to operate under an




approved Action Plan which describes assignments of responsibility and




procedures to be followed in planning and decision-making.  Topics




covered in Action Plans include the consideration of alternative courses




of action, involvement of other agencies and the public, identification




of social, economic, and environmental effects, the systematic, inter-




disciplinary approach requirement, and the decisionmaking process.




     Several provisions are of particular importance to E.P.A. and state




and local air quality agenices.  For example, one section of the Guide-




lines requires the state to provide for monitoring the environmental




effects of completed projects, as appropriate;  this could provide an




opportunity to see that highway sections are monitored where there is




debate over air quality effects and VMT.  Other sections are concerned




with the role other agencies play in the development and analysis of




alternatives and in decision-making,  and thus could provide explicit




procedures for E.P.A. and air quality agency participation.




     It is recommended that E.P.A., in cooperation with state air
                                 51

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quality agencies, review Action Plans to identify and assess the com-




mitment each state has made to air quality analysis and monitoring; to




coordination with air quality agencies; and to the inclusion of air




quality as a factor in decision-making.  Since at the time Action Plans




were written, most highway agencies' programs were oriented toward the




location and design of major highways, the technical procedures, impact




assessment methodologies, and participation programs may be directed




primarily to such large-scale actions.  Now that many highway agencies




are finding that an increasing percentage of their activities is




directed toward shorter-term, lower capital transportation measures,




and particularly in light of new requirements for short range planning,




it may be appropriate for highway agencies to revise certain sections




of their Action Plans.  E.P.A. and the state air quality agencies may




wish to suggest such revisions to the state; or E.P.A. may wish to sug-




gest to F.H.W.A. that Action Plans should be revised to reflect recent




requirements in air quality and energy consideration and short-term,




low capital transportation planning.
                                  52

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                       FOOTNOTES - SECTION III
1.  Transportation Improvement Program, U.S. Dept. of Transportation,
    Federal Register, Vol. 40, No. 181, Sept. 17, 1975.

2.  See Saction II for a full discussion of consistency.

3.  See, e.g., the National Environmental Policy Act of 1969; the Inter'
    governmental Cooperation Act of 1968; and 49 U.S.C. 1604(h)(2) and
    1604(1).

4.  Department of Transportation, Office of the Secretary Order 1130.1,
    11-30-72.

5.  23 C.F.R. 795; Federal Register Vol. 39, No. 232 - Monday, December
    2, 1974, pp. 41819 et seq.

6.  23 C.F.R. 795.8(b)(l)(iii)

7.  For example, 23 C.F.R., $795.8 (b)(2)(Iv), 795.9 (b)(5); 795.12
                                  53

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IV.  TRANSPORTATION CONTROL PLANS


A.  INTRODUCTION


     Transportation control plans currently are in effect in some 30


air quality control regions.  Although the plans were expected to re-


duce ambient levels of auto-related pollutants to the national standards


by 1977 at the latest, slow implementation of TCP measures and lower


than estimated effectiveness have made it clear that 10-15 regions


will not meet the standards by the current deadline.   Amendments to


the Clean Air Act which would permit delays in attaining the standards

                    2
are before Congress;  in any event, however, E.P.A. anticipates that


revisions to T.C.P.s will have to be initiated some time in 1976.  Thus,


it is appropriate to investigate the potential for using T.C.P. revi-


sions as an opportunity for increasing the coordination between control


planning and the ongoing transportation planning process.


     There are two major ways to build stronger links between trans-


portation control planning and other transportation planning efforts.


One is to maximize the number of shared elements of the various plans;


in particular, the T.S.M.E. holds much promise for compatibility


with the T.C.P.   Another way is to make the process through which trans-


portation control measures are analyzed and selected compatible with


the already established process for continuing metropolitan transporta-


tion planning.  Thse topics are discussed below.
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 15.   T.C.P.s and T.S.M.E.s


      The new F.H.W.A./U.M.T.A.  requirement that M.P.O.s develop  trans-

                                                 3
 portation system management elements (T.S.M.E.s) — comparatively  low-


 cost, short-range transportation measures with the potential for in-


 creasing system efficiency—will lead to planning very like that re-


 quired for T.C.P.  development.   But  D.O.T. officials recognize that


 most M.P.O.s will have difficulty in getting started and will need


 guidance.   E.P.A.  has  a real opportunity to influence D.O.T.'s thinking


 on  what  the T.S.M.E.  should include,  since D.O.T.  is in the midst  of


 formulating its own ideas on what the new requirement actually means.


      We  recommend that E.P.A. urge F.H.W.A.  and U.M.T.A.  to adopt  the


 position that where T.C.P.s exist, the first step in developing  the


 T.S.M.E.  should be to  analyze all appropriate T.C.P.  measures.   F.H.W.A.


 and U.M.T.A.  could require that  the  T.S.M.E.  include an analysis of


 the transportation,  social,  economic,  and environmental—including air


 quality—effects  of  the T.C.P. measures.   The T.S.M.E.  then  should in-


 clude all  acceptable T.C.P.  measures.


      If  certain T.C.P.  measures  are  rejected  after  a thorough analysis,


 the next  step for  the  M.P.O. would be  to  explore new measures from


among  those  suggested  in  the appendix  to  the  joint  regulations.    These


measures should be analyzed for  their potential air quality benefits


and such benefits should be one criterion in  selecting measures.


     In T.C.P. areas one element of the consistency determination
                                  55

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with regard to the T.S.M.E. should be that the T.C.P. was carefully




analyzed; that acceptable measures were approved and recommended for




programming, as appropriate; that the reasons for not including certain




T.C.P. measures in the T.S.M.E. were fully explained; and that the




air quality effects of other T.S.M.E. elements were analyzed and fully




considered in deciding to include them.




     In areas which do not have T.C.P.s, one way to get started on de-




veloping the T.S.M. would be to develop simple measures which can have




air quality and energy benefits as well as transportation system ef-




ficiency benefits.  A prime example is carpooling—every metropolitan




area should be able to develop some form of carpooling program, al-




though the program's sophistication may vary markedly from area to area,




Areas also could be expected to do careful analyses on preferential




treatment of high occupancy vehicles; to review the impacts of their




parking policies and to consider ways of favoring short-term users




(e.g., shoppers) over commuters; and to consider the effects of traffic




operations improvements.  Air quality analysis should be a prominent




component of the studies.




     In all areas, whether or not they have T.C.P.s, E.P.A. should urge




the development of a sound process for air quality analysis and con-




sideration in decision-making as part of T.S.M.E. planning.  The ex-




istence of such a process, and the explicit reflection of air quality




goals in the plans which result, should be a measure of consistency of
                                   56

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the T.S.M.E.



     E.P.A. also should urge the U.M.T.A. and F.H.W.A. to require that




the T.S.M.E.  reflect involvement of, and information exchange with,




other agencies and the general public, to increase the likelihood that




the TSME will be implementable.  Furthermore, E.P.A. should lend its




support to the D.O.T. administrations in urging that the M.P.O.s




plans reflect a careful analysis of implementation issues, including




budgeting and required levels of intergovernmental coordination.




     It is also recommended that E.P.A. monitor the development of




the T.S.M.E.  in cities having T.C.P.s.  Problems arising in developing a




T.S.M.E. should be indicative of the problems likely to arise in the




development of any short-range, efficiency-oriented transportation




program—including T.C.P. revisions.  By following the T.S.M.E. develop-




ment closely, E.P.A. would be able to encourage the M.P.O.s to pay more




attention to air quality issues, and would gain experience and insight




into how transportation control planning ought to be conducted.
                                  57

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C.  IMPROVING THE T.C.P. PLANNING PROCESS




1.  Introduction



    Early transportation control planning efforts were under stringent




time constraints, and often proposed the use of measures that were new




to transportation planning practice.  Given the short time frame and




the lack of information about specific options, most of the early trans-




portation control plans simply enumerated strategies to be applied;




they did not include information about financing, implementation, en-




forcement and evaluation of the strategies.  Problems in implementing




T.C.P.s quickly pointed out that this latter information was crucial.




Developing this information, however, is not a straightforward task.




Even though technical information is available about the measures




commonly included in T.C.P.s, the major problem—how to develop a




coordinated program of short term measures—is still not solved.




Current transportation planning procedures are oriented primarily



toward long-range, high-cost measures for which large expenditures of




time and money are feasible—such procedures often are not transferable




directly to short-range planning.  This problem no longer is unique to




EPA, since the Department of Transportation has made requirements for




consideration of similar short term measures a part of its urban area




transportation planning regulations.




     The following discussion explores some of the major issues which




must be addressed in the development of a process for the planning of
                                  58

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short range transportation management options, from the viewpoint of




transportation control measures.






2.   Basic Issues




     A variety of transportation control measures have been included




or proposed for inclusion in transportation control plans.  Most of




these measures initially received attention because they were judged to




be short range options which would reduce emissions per vehicle mile




travelled, reduce vehicle miles travelled, and/or increase the ef-




ficiency of traffic flow, thus decreasing total emissions.  Most of




these measures are non-capital intensive, and planning and designing




their operational features is relatively straightforward from a techni-




cal viewpoint.  Experience in the formulation of T.C.P.s has indicated,




however, that institutional and political factors (and not technical




ones) may be predominant in determining both what effects the measures




have, and when those effects will occur.




     While it is a priori possible to state that some options are not




short range (e.g., major highway and transit construction), it is im-




possible to determine without a certain amount of study whether other




transportation options, which could be short-range, can in reality be




put into effect quickly.   Furthermore, even measures which can be




started up quickly may not be effective for significant amounts of time.




For example, a. freeze on parking in the core area has been included in




the Boston T.C.P.  It is a simple matter to declare that the number of
                                   59

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 parking spaces in downtown Boston.cannot exceed those in existence as




 of October, 1973, and in that sense, the parking freeze is both quickly




 implementable and would seem to be immediately effective.  It turns out,




 however, that Boston has numerous outdated and underutilized parking




 facilities within the core area.  These spaces are being "banked," to




 be eliminated as new developments requesting parking come along.  This




 practice will permit effective increases in the city's parking capacity




 for a number of years.   Thus, the freeze will have no effect on trans-




 portation until all the city's outmoded parking has been traded off for




 new development—something not expected to occur for several years,




 making the freeze in a  sense a long range measure.




      In this example, we have a  measure which can  be implemented in




 the short-run,  but  will yield results  only in the  long-run.   A second




 case  might  be auto-free  zones, which theoretically  could  be  implemented




 in  the short run, but may  in  fact  be infeasible  in  the face  of organized




 opposition  by local  businessmen.




      The  fact that  institutional considerations  and  political  realities




 may convert  an  apparently short-range option  into one that can be  put




 into  effect  only after long effort, if  at all, necessitates  that the




 planning process incorporate judgments  on the feasibility of imple-




menting each option  and on the length of time needed to bring  it to




fruition.  Such judgments hardly are easy to make.  Former Massachusetts




Secretary of Transportation and Construction Alan Altshuler notes, for
                                    60

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example, that during the first formulation of the Boston Transportation




Control Plan judgments on the acceptability of options were made by a




few men sitting in a closed room and that these judgments always seemed




sound—until they had left the room and entered the larger political




arena outside.




     It is precisely this need to make judgments which will withstand




the critical inspection of the entire political arena which necessitates




the adoption of a process orientation for the formulation of trans-




portation control plans.  Only through consultation with a wide range




of people can sufficient information be obtained about control measures




to facilitate reasonably sound judgments which can stand up to public




scrutiny.




     Although the information base on transportation control measures




has increased significantly since the formualtion of the first T.C.P.s,




most of the information is technically oriented and while necessary, is




insufficient for decision-making.  Some information is being developed




on the effects of T.C.P. measures in communities where such measures




have been tried, and while such  information is indicative of likely




consequences elsewhere, community variations and differences in the




measure's implementation must be accounted for.  Likewise, brainstorm-




ing sessions by decision'-makers, although excellent for developing lists




of alternatives and likely impacts, do not by themselves allow for ade-




quate consideration of the viewpoints of those who would be affected

-------
by the measures.




     It is only through consultation with people—which is the "es-




sence of the planning process"—that information necessary to evaluate




a given option can be obtained.   This consultation assumes critical




importance when implementation of the plan will not be carried out by




the agency which formulated the plan, as is often the case with T.C.P.s.




     More specifically, the objective of the transportation control




planning process should be to develop, through interaction with a full




spectrum of affected groups, information on:




     o How each measure stands on the group's list of priorities and




why this measure would or would not be supported.  A state official in




Massachusetts who played a central role in the formulation of the




Boston T.C.P.s has stated that T.C.P. elements which are successfully




implemented are those that can stand on their own.  The air quality im-




pacts of these measures are not major considerations in their attract-




iveness to local governments.  Thus one of the most important things to




be done in transportation control planning is to careful 1 y select_t_h_pse




measures which meet multiple objectives (e.g., which increase transit




level of service while improving air quality) and support community




goals (e.g., which increase bicycle safety).




      •  How each measure would work.  Many of themeasures proposed for inclusion




 in T.C.P.s are so innovative that even the operational details are not well
                                  62

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understood.  For example, the mechanics of implementing staggered work




hours in an area of a city  (as opposed to just one company) are poorly




defined.  Even when the measure is a more familiar one, however, the




impacts may not be determinable without a careful delineation of




specific details of application and administration.  The parking freeze




example (above) illustrates this need.




     • The locus of responsibility for implementation, operation,




and enforcement.  This task is made more difficult by the recent




origin of many transportation control-type measures.  For many measures,




appropriate lines of responsibility are unknown and the resulting un-




certainties are many.  Where assignment of responsibility is uncertain,




implementation is easily evaded.  For example, if a measure is unen-




forceable it may be infeasible.  Where changes in legislation are




necesary, implementation of a measure may be delayed for several years.




     Many of the problems currently associated with the implementation,




operation and enforcement of control measures may ease up as institu-




tional responsibilities are delineated through experience with short-



range options.




     • Who will pay for the measure.  If there is not a currently bud-




geted source of funds, what is necessary to obtain funding?  Is there




funding for implementation, operation, and enforcement as well as




planning?  What, if any,  are the tradeoffs that will have to be made




if the measure is approved?  These questions must be answered if the
                                  63

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result of the planning process is to be realistic.




     In Cambridge, for example, some of the elements included in the




EPA-developed T.C.P. were on-street parking control measures.  The




Director of Traffic and Parking attempted to get EPA funding for inven-




tories, and later for implementation and enforcement of the parking




programs.  EPA turned down all requests from Cambridge to fund the park-




ing program, and apparently told the Director of Traffic and Parking that




the parking control measures should be funded out of revenues from park-




ing tickets.  Since Cambridge was using those revenues to fund con-




struction of a municipal parking facility, the Director was placed in




the position of having to split revenues between a pet project and the




parking controls promulgated by EPA.  It is not difficult to guess which




project had first priority.




     In Boston, the enforcement of the residential permit program,




another parking measure included by EPA in Boston's T.C.P. is currently




piecemeal or non-existent.  The Boston Department of Traffic and Parking




cannot use ticket revenues, since it receives all of its monies from the




General Fund, and 25 additional meter maids plus an appropriate number




of supervisors and equipment are estimated to be necessary for proper




enforcement of the program.  Whether or not the Department receives money




for the meter maids depends on a complex set of political factors which




is influenced only in part by pressure to see the program enforced.
                                64

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3.   Prospects for Short-Range Transportation Planning by Regional




    Agencies




     During the course of this study, both E.P.A. and D.O.T. have




acted on the evolving conviction that major responsibility for planning




short range transportation measures should reside with regional planning




agencies.  Proposed amendments to the Clean Air Act would shift consid-




erable authority for Transportation-related air quality planning from




the states to the regional agencies; F.H.W.A. and U.M.T.A. recently




issued joint guidelines which require regional agencies to develop




short range transportation option planning and programming abilities.




These developments reflect an awareness that many transportation




measures, such as exclusive bus lanes and bikeways, are regional or




local in scope and impact, and should be planned and implemented by




regional and local agencies, not in remote levels of the state and




federal government.




     The logcial agency to undertake this planning is the existing




metropolitan organization responsible for regional transportation plan-




ning—the Metropolitan Planning Organization (M.P.O.).   The advantages




of M.P.O. planning of these measures are several:




     • it utilizes all of the resources of the existing transportation




       planning agency, including established procedures for public




       participation, an existing data base, in-house analytical capa-




       bility;  contacts with other regional and local planning programs,
                                  65

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       contacts with local enforcement agencies, and available planning




       funds;




     • it prevents wasteful duplication of transportation planning ef-




       forts and avoids the problem of coordinating  parallel planning




       processes.




     • it provides for the consideration of local interests and goals in




       plan formulation; and




     • it opens the TCP measures included in the regional transportation




       plan to a wider range of potential funding.




However, concern exists that the benefits expected from increased re-




gional agency responsibilites may not be realized.  Interviews with




officials in the case study cities have indicated that there is con-




siderable desire to minimize  institutional  problems which might occur




while regional planning agencies develop expertise in short range trans-




portation planning.  In no case was there concern that plans—that is,




the actual documents—could not be produced;  there was concern, how-




ever, that the content of the plans would not meet the expectations




of Washington.  A common opinion is that initial short-range plans




would be quickly assembled by excerpting from existing documents—barring




a major effort by, and new funding from, the federal agencies, the short




range plans simply would not be the results of fresh, new planning




efforts.




     The fact that regional planning agencies are currently oriented
                                  66

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toward long range planning seems to be the largest obstacle in limiting




their ability to effectively develop short range transportation measures.




The effect of the  difference in time horizon between the two types of




planning is more than semantic, since the whole group of analytical




tools that planners have developed over the years is oriented toward




long range predictions of growth and impacts, and is simply not suita-




ble for the short range type of planning envisioned by E.P.A. and D.O.T.




In addition to the fact that methodologies and therefore the data base




for long range planning cannot be readily adapted to short term planning




use, this shift in time horizon necessitates the use of different plan-




ning techniques, and as a result will radically change the job defini-




tions of individuals in the agency who are (re)assigned to short-range




planning.  Many of the concepts behind T.C.P. measures are very different




from the philosophy that has supported most of transportation practice.




Transportation practitioners are accustomed to planning facilities to




meet projected demands, whereas some transportation control measures




are proposing the use of fixed facility size to limit or control demand.




These are not insurmountable problems, but it should be recognized that the




solution involves a reorientation of individual and agency mission from




maximizing mobility to helping achieve a wide spectrum of governmental




goals through sensitive design and management of the transportation




system.  The addition of short range capability to a regional agency




will require a certain amount of institutional change, and as such
                                 67

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 probably  will  encounter  some  of  the  resistance  that  typically  is as-




 sociated  with  change  in  organizations.




      An argument  that is often used  in  favor of combining long range




 and  short range capability  in the  same  organization  is the beneficial




 impact of having  the  two programs  in close communication.  However,




 the  fact  that  two programs  are physically managed within one agency




 does  not  insure that  they are adequately coordinated.  For example, a




 staff memeber  of  Boston's Central  Transportation Planning Staff (C.T.P.S)




 whose employees are on the  Metropolitan Area Planning Council  (M.A.P.C.)




 payroll,  says  that no communication  exists between the people  in M.A.P.C.




 who are working on 3208  water qualtiy studies and those who are work-




 ing on transportation in C.T.P.S.  Not even data is  shared, even though




 both  programs  need the same information on land use, population, in-




 dustrial  and commerical  development, etc.  Whether more communication




will  occur between transportation  groups doing far different work is




 uncertain; but it is  likely that a major effort will be required to




 coordinate the programs  regardless of shared agency  ties,




      Perhaps the most complex transitional problems  that can be expected




 to arise as regional  agencies undertake short range planning inolve




determining the appropriate working relationships with other agencies




having short range transportation planning responsibilities, such as




transit agenices,  highway departments and local traffic engineering de-




partments.  Specifically, there is uncertainty about whether the
                                 68

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regional agency's work could or should substitute for the work of




agencies which have had traditional responsibility for the planning




of some short range transportation measures.  In Boston, the C.T.P.S.'s




efforts in short range planning are viewed as a supplement to the work




done by the traditional planning agencies.  In fact, one C.T.P.S. of-




ficial says that regional agencies should plan only for those short




range transportation measures which have impacts of regional signifi-




cance, because regional agencies lack the resources necessary to do all




areawide short range planning.  Thus, his position is that the primary




role of the regional agency should be to act as a coordinator of the




continuing efforts of the agencies traditionally having responsibility




for each area.  Determining what prelects are regional is no simple mat-




ter, however; and even if agreement is reached on this, the regional




agency's responsibility to iron out conflicts is no easy one.  Further-




more, inaction on the part of local agenices can have far-reaching,




serious effects, even if the ignored responsibility is one assigned to




the local level—and what can the regional agency do in such cases?




The problems become more complex when other organizations with regional




transportation responsibilities—e.g., a transit authority or parkway




commission—continue to operate, in parallel with the M.P.O.  The rela-




tions among these agencies may be strained, and often even legal re-




sponsibilities are confused.   The only apparent solution involves care-




ful and  detailed negotiation  among the agencies to reach agreement on
                                   69

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assignments of responsibility, an overall policy,  and how the inevita-




ble disagreements on specific issues will be resolved.




     Even after the regional agency's responsibilities are delineated,




it still may lack the political clout necessary for successful short




range transportation planning.  Precisely because they are the plan-




ning arms of voluntary organizations, regional agencies (in general)




have no authority to implement or enforce plans, and must rely on mem-




ber governments to carry out plans which are developed.  Thus there is




a tendency for regional agencies to be dominated by the desires of the




municipality most ready to withdraw its membership.  The most effective




sanction which can be made available to regional agencies appears to be




the ability to withhold federal planning monies which are distributed




through the voluntary organization to local governments.




     To some degree, regional decision-making is opposed by all levels




of government except the federal government.  The regional agency must




co-exist with older governmental units which may acknowledge few valid




reasons for its existence.  Several officials interviewed were concerned




that the regional transportation planning process, although it has im-




proved substantially in the recent decade, still floes not always reflect




local interests and goals, often because of lack of participation of




members of the individual locality involved.  They feel that the region-




al planning process may not be receiving enough local viewpoints to




adequately develop goals and objectives which are truly representative
                                 70

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of the region.  The assumption by regional agencies of new responsibili-




ties in short range transportation planning may have the effect of add-




ing fuel to the fire in areas where the increased emphasis on regional-




level responsibility already is resented.




     These problems are not necessarily shared by all regional agencies,




nor are they necessarily of such a magnitude that they seriously limit




the ability of regional agencies to effectively plan for short range




transportation options.  However, one-regional U.M.T.A. official has




stated that many regional planning agencies already have undertaken all




the short term transportation planning they currently are capable of,




that the development of this existing planning capacity has been slow




and arduous, and that  short range planning capabilities must be develop-




ed before the regional planning agencies  can fulfill increased responsi-




bilities.






4.  Summary and Recommendations




     The transportation/air quality planning process is the prime de-




terminant of  the quality of the plans it  produces,  their political ac-




ceptability,  and their potential for  full realization.  A satisfactory




planning process must  recognize uncertainty in  the  data it works with




and  in  the efficacy of the projects and  programs  intended to achieve




the  desired  results;  it must  be  flexible  enough  to  accomodate  and ad-




just  to new  information and changes in  conditions;  and  yet  it  must be




decisive:   implementation  of  proposed projects  and  programs must  occur.
                                   71

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Because of uncertainties and the need for flexibility, there must be




procedures to modjLfy plans (both the parts proposed and the parts al-




ready being implemented, should the latter not be achieving satisfac-




tory results.)  In order to do this effectively,




     • information is needed on all major occurrences which may affect




       the planning process;




     • existing programs should be evaluated periodically to determine




       their effectiveness and to identify their impacts.




     Many potentially promising strategies, projects, and programs may




be time-consuming and costly to plan adequately and to implement.




Therefore, a strategy of implementation  in stages may be desirable.




Finally,  the decision-making process must consider who is going to pay




for  implementation and  who is responsible for implementation and en-




forcement; it  should consider social and economic factors in studying




alternatives,  and it should insure  that  public agencies, private inter-




est  groups, and the public in general have been infortned and encouraged




to participate in the selection of  measures.




      It  is recommended  that E.P.A.  encourage each agency conducting




transportation control  planning to  develop and document a suitable planning




process.  The  agency should identify procedures and assignments of




responsibility for




      • the identification  and consideration of alternative  courses  of




       action;
                                 72

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     • Identification of social,  economic,  and environmental effects




       of the alternatives;




     • involvement of, and information exchange with, other agencies,




       the general public, and affected interest groups throughout the




       planning process;




     • coordination of transportation control planning with other on-




       going planning processes,  and resolution of conflicts among




       programs;




     • monitoring the effects of  T.C.P.s as they are implemented;




     • revising T.C.P.s to reflect changes in conditions or new in-




       formation.




The agency also should identify:




     • the process of reaching decisions on air quality strategies, and




       the authority and responsibility, if any, which other agencies




       or officials can exercise  over decisions;




     • sources of funding and other resources for planning and for im-




       plementation, including any interagency agreements for sharing




       such responsibilities.




     In addition, it is recommended that each transportation control



p_lari should




     • discuss the proposed short- and long-term projects and programs




       to achieve air quality;




     • evaluate these projects and programs as to their social and
                                  73

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      economic effects, public comment, etc;




    • indicate responsibility for planning and implementation (e.g.,




      what agencies);




    • list sources of funding and other resources available for plan-




      ning and implementation;




    • discuss alternatives which were  considered in developing the




      plan and summarize their costs and benefits;




    • make a definite  implementation commitment for the next time




      period, indicating specific responsibilities and funding




      sources;




    • indicate what will be  investigated or planned for over the next




      period, with  responsibilities, funding sources, etc.,  spelled




      out;




    •  indicate what  long-term planning activities will be going on;




    •  state  what will  be done should monitoring  show  that the  imple-




      mented programs  are  falling short of goals.




    While  pursuing these  specific recommendations  on  the  planning  pro-




cess and plan content,  E.P.A. also should consider;




     a)  working with F.H.W.A., U.M.T.A. and other  federal  agencies  as




appropriate to assist the metropolitan  planning agencies  in developing




short  range transportation  planning capabilities.




     For any E.P.A.  transportation programs in which regional planning




agencies will play a significant role,  the Agency should provide for
                                 74

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transitional guidance and assistance.  Such transitional support could




include, in addition to regular support funds and guidance, such pro-




grams as;




     • a review and explanation, for all regional agency personnel




       working in transportation, of laws, regulations, judicial de-




       cisions, and administrative procedures which are relevant to




       short range transportation planning.




     • training in air quality quantitative techniques for short-




       range measures where such capability is deemed desirable by the




       regional agency.  This might be accomplished through courses




       held at Durham, special regional short courses, or evening




       courses at a nearby university.




     • research, possibly jointly sponsored with D.O.T., to develop




       planning methodology appropriate for the analysis and evaluation




       of short range transportation measures.




     • dissemination of information about short-range measures gained




       through experience with T.C.P.s.




     b) giving state, regional, and local agencies an affirmation of




continued interest in transportation control planning.




     This reaffirmation that transportation control plans and air quality




impacts of transportation remain important to E.P.A. is especially de-




sirable at this time because transportation control plans are reaching




or have already entered the implementation stage.  The states, while
                                   75

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legally required to implement the plan, cannot be expected to place a




high priority on T.C.P. implementation if E.P.A. itself does not demon-




strate that T.C.P.  implementation is a high prioirty issue.
                                  76

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                       FOOTNOTES - SECTION IV


1.   See Bennett,  E.  D.,  G.  Harvey et al., "Transportation Control Plans:
    The Potential for Improving State and Local Decision-Making,"
    report prepared  for E.P.A.  by the M.I.T. Center for Transportation
    Studies, March 27,  1975.

2.   See Section VI.

3.   23 C.F.R. 450. - 100 - 450.122.

4.   Appendix to 23 C.F.R. 450.122.

5.   See Section II.

6.   Bessey, May,  "What  is a Short Range Transportation Option?",
    M.I.T. discussion paper,  September 1975.

7.   Altshuler, Alan, The City Planning Process, Cornell University
    Press, Ithaca, N. Y., 1965.
                                  77

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V.  PARKING MANAGEMENT PLANS




A.  INTRODUCTION




     This discussion deals with a number of problems that have been en-




countered in parking management planning under the currently suspended




EPA regulations.  We feel that parking is an element of an area's




transportation system, and as such should be included as an item to




be controlled in managing transportation to meet air quality goals.




     The term parking management refers to both on-street and off-street




measures, except as specifically indicated.  The following list in-




cludes many of the parking controls or measures which have been pro-




posed for use in various cities:






Rate controls




     parking tax




     parking surcharge




     increased rates for parking




     changed rate structure to favor short term parking in business and




       commercial areas






Supply controls—off street




     freeze on off-street spaces in specific area (number of spaces not




       to exceed those in existence as of certain time)—suitable for




       areas having just enough or a small amount of excess off-street




       capacity at time of freeze
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     reduction of off-street spaces—suitable for areas having far too




       much capacity




     restricted growth—suitable for areas needing additional off-




       street capacity






Supply controls—on-street




     ban parking in certain areas (at certain times) eg. an on-street




       ban, or auto free zone




     meter all on-strset spaces in business and commercial areas




     limit meters to 1 or 2 hours




     residential permit program—parking in mixed residential-business




       areas limited to residents only on residential streets






Additional measures




     priority parking for carpools




     park-ride lots for transit




     fringe parking with employer or special shuttle to work




     variety of measures to improve bicycle commuting




     variety of measures to increase transit attractiveness






     This section begins with a discussion of the institutional frame-




work for parking management which explores various parking controls




and the levels of government responsible for them.  The discussion is




followed by brief case studies of parking management in Cambridge,




Boston, Los Angeles, and San Francisco.  The case studies explore many
                                79

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of the institutional issues raised in the first discussion, and bring




out numerous other considerations which have an impact on the effec-




tiveness of parking management.   Conclusions and recommendations are




based on insights from the discussion of institutional issues and the




case studies.
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B.  INSTITUTIONAL CONSIDERATIONS IN PARKING MANAGEMENT




1.  The Emergence of Parking as a Regional Transportation Issue




a) Traditional Treatment of Parking




     Parking always has been primarily a matter of local concern.  In




most states, the cities and towns are empowered, through zoning, build-




ing codes, and other such mechanisms, to regulate parking supply, both




directly and through various incentives.  In addition, cities and towns




have direct control over most on-street parking and over many off-




street lots through municipal parking authorities.  The focus of local




parking management through these programs has been on ensuring an ade-




quate supply of parking; i.e. ensuring that new developments provide




enough parking for the auto travel they will generate and that suffi-




cient parking is provided to maintain the competitiveness of existing




retail and commercial establishments.




     In certain cases, metropolitan or state agencies also have control




over parking (e.g. MDC control over parking on certain major roadways




in the Boston metro area), but their policies invariably have aimed at




achieving narrow agency goals (such as MDPW park and ride facilities




for transit use).




     Finally, metropolitan planning agencies traditionally have con-




sidered parking, not as a basic element of the transportation system,




but as an ancillary service to be provided as travel demand requires.




Hence, models of future travel demand (which include parking supply)
                                 81

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are used to project parking needs for each sub-area of the region,




but no consideration is given to the effect which alternative levels




of parking supply may have on travel demand.




     In summary, parking plans and programs traditionally have been:




          - supply oriented




          - fragmented in both planning and implementation






b) Recent Changes in the Treatment of Parking




     Transportation planners recently have suggested that parking may




play a basic role in the structure of the transportation system; that




increased parking supply itself can be a stimulant to auto travel; that




decreased parking supply can be a deterrent to auto travel; and that,




because of these effects, parking supply can be "managed" to achieve




certain transportation and land use goals, such as decreased auto




travel for pollution control and energy conservation.  Thus, they argue,




management of parking supply should be an integral part of the metro-




politan transportation planning process.  This shift in emphasis recent-




ly has received impetus from two major federal programs—U.S. EPA regu-




lations under the Clean Air Act of 1970, and U.S. DOT regulations for




3-C transportation planning in metropolitan areas, under the Federal Aid




Highway Act, 23 USC  134.






i) EPA Parking Management Regulations




     Under the Clean Air Act of 1970, EPA is required to set standards
                                 82

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for ambient air quality and to designate air quality control regions




(AQCR's — usually corresponding to metropolitan areas)  wherever there




is now or will be a violation of the standards;  the states are re-




quired to develop implementation plans (SIP's) for attaining those




standards throughout the state by 1977 at the latest (the EPA admini-




strator can substitute his own plan if the state fails to submit one




or if the state submittal is inadequate); and EPA is required to promul-




gate guidelines for the development of SIP's.  Among other things, the




Air Act requires that "transportation and land use controls" be in-




cluded, as necessary, in the implementation plans.




     Subsequent court decisions have supported strongly the statutory




requirement for transportation controls, so that EPA has been forced to




provide guidelines for transportation control planning and to ensure




that SIP's include the full range of transportation controls necessary




for achieving  the standards.  Under the assumption that parking is:




     - an  integral part of the transportation system




     - itself  a generator of auto travel




EPA has included  parking in  its  transportation control program.




EPA's  approach to parking has two facets:




     • inclusion  of  specific parking strategies  in  the SIP's




for certain AQCR's,  specific parking control  techniques have been used




as transportation control measures.  Examples are:




     - CBD parking  freeze
                                 83

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     - early morning on-street parking ban




     - airport parking freeze




     - parking price surcharge (EPA's authority to require price sur-




       charges was withdrawn by Congress)




     • requirement for parking management  plans




In addition to transportation controls per se,  EPA also will require




(the regulations were promulgated but currently are under suspension) a




full parking management program in each AQCR which has transportation




controls.  The program must include a pre-construction permitting pro-




cess for parking facilities, to regulate any negative air quality im-




pacts, and a plan for the overall management of parking supply.  The




plan must represent a region-wide strategy for parking management,




based on parking freezes, pricing policy or other measures, and careful




consideration of the impacts of alternative local and regional parking




controls; and it must demonstrate the degree of intergovernmental co-




ordination necessary for implementation of the plan.  If a region does




not establish an acceptable parking management program, the state will




be required to impose its own facillty-by-facility review on the region.




Failing  that, the EPA administrator will conduct his own facility-by-




facility review.  (This is presumably an Incentive for local action).






ii) Parking Management under U.S. D.O.T. Regulations




     DOT's activities in the past have centered mainly on major capi-




tal investments—highways and transit—with very little consideration
                                  84

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of ]ow capital,  short-range,  management and operations-oriented




transportation measures.  But three recent trends signal a shift away




from major investments:




     • construction of the interstate highway system is nearly complete,




so the range of potential major highway investments is narrower now




than at any time in the  past 20 years;




     • many major transit and highway projects have encountered fierce




citizen opposition, have failed to achieve predicted levels of per-




formance and ridership,  or have experienced astronomical cost overruns,




so that the taxpayer's and increasingly the federal government's appe-




tite for major capital investment is sharply diminished;




     • Federal Laws applicable to transportation—the Federal-Aid High-




way Act, the Urban Mass  Transportation Act, etc.—recently have been




amended to require that  DOT ensure "efficient" use of existing trans-




portation resources, both as a general agency goal and as a prerequi-




site to the funding of major capital investments.




     DOT's reaction to this change in the transportation climate has




been to revise its regulations governing metropolitan transportation




planning and programming.  The regulation, which previously required




a "long-range plan" (typically oriented toward major investments) and




several related documents, now requires a second element specifically




oriented toward short-term, low capital options.  This "Transportation




Systems Management Element" (TSME) must address possible action in
                                 85

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each of several different categories, in order to achieve more efficient




use of the existing transportation system.  Included in the categories




are:  shared ride programs (carpooling, etc.); traffic flow improve-




ments; priority treatment for transit vehicles; and. . .parking manage-




ment strategies,  (There are several other categories not mentioned




here).




     Most of the parking management strategies recommended for the TSME




by DOT are also recommended by EPA, e.g., reduced on-street parking to




improve traffic flow, but the emphasis here is less on reduction of auto




usage and more on encouraging efficient use of the automobile (e.g.




parking incentives for carpoolers).  More often than not, these goals




are mutually supportive.






c) Summary




     The parking related programs of EPA and DOT are based on an as-




sumption that parking is not merely ancillary to transportation, but




that in fact parking is an integral part of the transportation system.




     Operating under this assumption, EPA and DOT have identified




numerous aspects of parking policy which they feel can be instrumental




in improving air quality and in achieving more efficient use of the




transportation system.




     And, through their regulations, they have established procedures




at the regional level for management of parking policy, i.e., for the




development of region-wide parking management "plans" which, in theory,
                                  86

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will include a wide range of controls over parking in the metropolitan




area.




     Implicit in this policy is an assumption that parking can and




should be planned at the regional level, yet there has been no careful




study of the feasibility or desirability of this approach.




     In an abstract sense, parking obviously can be planned at the re-




gional level, but the real question is whether it can be planned effi-




ciently and successfully at that level; whether a regional-level agency




can obtain the necessary data, develop the requisite understanding of




parking issues, and orchestrate the degree of intergovernmental co-




ordination needed for successful implementation, in an arena tradi-




tionally dominated by local government.




     To answer this question it is necessary first to look at the range




of available controls over parking and to determine where they are




planned and administered in the spectrum of local-regional-state-fed-




eral governments.






2.  Methods of Controlling Parking




a) Local Control Mechanisms




     Local governments traditionally have exerted a great deal of con-




trol over parking.  Among their powers are:




     • Zoning - A variety of parking control methods are available




through zoning ordinances.  These can be classified broadly into parking




incentives, such as a height bonus for the provision of extra parking
                                87

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space,  and parking disincentives,  such as the classification of




parking as a conditional use subject to case-by-case consideration by




the Zoning Board.




     • Building Codes - The building code also can be manipulated to




encourage or discourage parking, as well as to exercise control over the




design details of parking garages.




     • Planning - The local planning agency frequently doubles as a




development agency under certain urban renewal programs, often with a




fair amount of autonomy from other local agencies and programs.  Hence,




the planning agency may control much of the new parking development in




a city.  A more subtle role of the planning agency is through its ad-




visory capacity for the Zoning Commission, Board of Appeals, and City




Council.  Where this relationship is official or semi-official, the




planning agency may have considerable success in promoting its own de-




velopment-oriented goals.




     • Traffic Controls - The local traffic department usually has con-




siderable control over parking, especially over on-street parking.  It




determines the configuration of on-street parking, the rules governing




use of on-street spaces, pricing policies, and signing for on-street




parking (the latter two areas are much constrained by state laws and




regulations).  In some areas, the traffic department also employs




meter-maids to enforce the parking rules, and in others, it doubles as




a parking authority by operating municipally-owned parking garages.
                                 88

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     • Police - The police issue parking tickets,  otherwise enforce




parking rules, and license (or operate)  towing services for illegally




parking cars.




     • Taxes_ - In some cases, the city council or other local governing




body can levy direct taxes on parking.




     • Mis cellaneous -




     - municipal parking authorities - In some cities, much of the off-




street parking supply is publicly owned and is operated by municipal




parking authorities with significant control over parking policy.




     - special purpose agencies - Certain agencies are empowered to con-




trol or coordinate parking policies for their own special purposes.  The




Boston Redevelopment Authority was one such agency when it had a broad




urban renewal mandate; an air pollution control board might be another




such agency if it were designated the lead agency for transportation




control strategies affecting the city and given power to override the




parking policies of other city agencies.




     - parking policies for municipal workers - Cities are themselves




employers with substantial amounts of controlled parking for people en-




gaged in city business.  Careful municipal regulation of total supply,




of price, and of parking rules for its own spaces can be an important




part of an overall parking management strategy and can set an excellent




example for the private sector.
                                89

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b) Regional and State




     Regional and state agencies typically do not have broad powers to




regulate parking, but in many cases they do control specific aspects of




the parking system.   Several examples are:




     • Regional agencies which control some highways in a metropolitan




area.  The MDC in greater Boston is one such agency.  It operates a sys-




tem of parkways and major arterials, controls all parking on roadways




under its jurisdiction, and further controls parking on certain other




roadways where they intersect the MDC system.




     • Airport parking, which may be operated by a metropolitan agency.




     • Regional transit agencies with authority to site transit-related




parking facilities, often with override power for local objections.




     • State highway agencies which control sign and design standards




for state-maintained highways and, in some cases, for local highways,




too.  Highway agencies often set standards to govern the use of road-




ways for parking (e.g., minimum space dimensions, allowable distances




from intersections and hydrants, etc.).




     • Federal ins tallations.  Wherever the federal government has a




major installation, parking may be provided to its employees.  The ob-




vious and extreme example of this is Washington, D.C., where the federal




government operates parking garages and lots all over the city, but




most cities have federal buildings to house the expanding federal re-




gional bureaucracy and have numerous other special purpose federal in-




stallations.  Depending upon the scope of operation and the extent to
                                 90

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which the feds provide parking directly to their employees, the federal




government may exert a great deal of control over parking policy in a




metropolitan area (i.e., over the operating policy for its own parking




lots).




     • S t a t e ins talla t ions.






c) Summary




     This list of parking control mechanisms and other pressure points




for parking policy is intended to provide some notion of the range of




available parking controls and their distribution between levels of




government and between agencies within each level of government.  It




obviously is not exhaustive—to compile a complete list would require




an entire research effort, with detailed case studies of several metro-




politan areas around the country.




     Three things are clear from this list.  First, there exists a wide




range of government controls over parking, from direct operating




authority over on- and  off-street parking to indirect control through




incentives over parking in new development.  Second, parking control is




extremely fragmented, especially between agencies at the local  level.




Third, most  parking controls are local; i.e., policy is set and imple-




mentation is  undertaken at the local  level.  The implications of  these




conclusions  are discussed  in the following section.
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3.  The Realities of Parking Management




     Given the local orientation and fragmented nature of parking con-




trols, there is some question about how easily regional parking manage-




ment strategies of the types advocated by the federal government will




translate into actual parking policy.  For example, what would be neces-




sary to organize and implement a "CBD parking freeze" advocated by a




regional planning organization?  Among other things, it would be neces-




sary to:




     - assemble sufficient information to provide for a full understand-




ing of the current parking situation (number of spaces, distribution of




spaces, operating policies, etc.) and a complete picture of the steps




necessary for implementation (agencies responsible, applicable laws,




etc.)




     - obtain the cooperation of each city or town affected by the




freeze.




     - obtain the cooperation of each agency involved in the freeze.




     Basic as they may seem, these goals are difficult to achieve.  In




metropolitan Boston, a CBD parking freeze was included as a transpor-




tation control element of the state  implementation plan.  The fate of




this parking freeze  illustrates some of the problems likely to be en-




countered by regional parking policies.  EPA obtained public agreement




from  the elected officials of Boston to support the  freeze, but did not




examine the pre-freeze conditions in Boston and Cambridge in order  to
                                 92

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 determine the effect  of  a  freeze  on  the  city,  or  in order  to develop




 criteria  for  assessing the progress  of the  freezes.   Cambridge  took a




 hard  look at  the  freeze  and decided  that  since development—especially




 retail  development—is the city's top priority, and the city currently




 has insufficient  off-street parking, it could  not implement a parking




 freeze  at that  time.  Yet  the city continues to pay lip service to the




 freeze  while  ignoring it at a substantive level.  Boston viewed the




 freeze  as a reinforcement  of evolving municipal policy against downtown




 auto  traffic.   The mayor requested the Boston  Redevelopment Authority




 to enforce the  freeze and  obtained the necessary changes to zoning rules




 (parking  is now a conditional use subject to zoning board  approval, etc),




 The BRA agreed  to go along  by freezing the number of parking spaces in




 the downtown  area at the current level.  But this has not meant a freeze




 on the  development of new parking spaces.  For each new development




which includes parking, the BRA removes the same number of spaces from




 its pool  of substandard,  under-utilized lots, mostly on the fringe of




 the freeze area.  Thus, effective parking capacity in Boston is not fro-




 zen.  The BRA hints that support for the "freeze" is much less likely




after the pool of substandard parking runs out, at which point the per-




ceived need for parking as an incentive to development will come into




direct  conflict with the  mayor's traffic reduction goals.   To further




complicate matters, Cambridge undoubtedly views Boston's unfrozen effec-




tive capacity as an added justification for ignoring the freeze, since
                                93

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a real freeze in Cambridge (which does not have a trading pool) would




place the city at a disadvantage vis-a-vis Boston in attracting new




development.




     Experience with Boston's parking freeze illustrates the need for




detailed information and full intergovernmental coordination in re-




gional parking management.  EPA's lack of information precluded a pre-




determination of the full potential of a parking freeze in metropolitan




Boston and continues to prevent EPA from assessing the effectiveness of




the strategy as it is implemented; EPA's superficial agreement with




city officials (in lieu of a full analysis of the government actions




necessary) ignored the opposition that one might naturally expect in




any city government to what may be viewed as an anti-development pro-




gram.  These points, and experience gained through other parking manage-




ment programs, may be generalized into a set of observations concerning




the potential of and the limitations of parking management under exist-




ing institutional structures:




     • control over parking is basically local - We have seen that,




whether or not parking management strategies make sense at a regional




level, the programs and regulatory mechanisms through which the strategies




must be implemented are basically local.  Localities control directly




most of the on-street parking and much of the off-street parking through




municipal authorities, and control indirectly the remaining off-street




parking through zoning, building codes, etc.  This locus of control over

-------
parking is not likely to change in the forseeable future, so the coop-




eration of and coordination with local governments are essential to any




attempt at regional parking management.




     • local incentives - The fact that control over parking is basic-




ally local does not mean that locals will never be interested in park-




ing management.  There are numerous incentives for them to embrace




parking management strategies.  For example:  on-street parking limita-




tions are favored by municipal traffic departments for safety reasons




(street-side parking conflicts with through traffic), by fire and




police departments because of the improved access they afford, and by




city residents who often receive special permit parking rights (i.e.,




parking may be limited to city residents only); parking taxes are often




favored because of the increased revenue; and limits on off-street




parking are attractive to cities which cannot accomodate current traf-




fic levels.  Cities often are not aware of the boost parking management




can give  to      civic goals, but many cities which are forced to re-




view their parking policies for one reason or another emerge with an




appreciation of what might be done through conscious management of




parking.  Earlier this year, the City of Los Angeles was requested to




prepare a parking management plan under an EPA financed program.  The




mayor assigned a task force to this project, while expressing doubt




about the workability of any parking management strategy.  By June, the




task force produced a report questioning the air quality potential
                                 95

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of parking management, but listing a host of other potential benefits




to the city and recommending a continuing and coordinated planning




program for parking.  Similarly, in Boston the EPA parking requirements




triggered a complete review of the city's parking-related programs,




revealing regulations of which the mayor's office had not been aware.




The city hopes to adopt a coordinated approach to all of these regula-




tions in the near future.




     • fear of adverse impacts - Local hesitance about parking manage-




ment is based principally on fear of adverse impacts.  Most often cited




is the fear that unilateral action by one city will reduce its competi-




tiveness among the surrounding cities.  Both Cambridge and Boston have




expressed the fear that a freeze will make it even more difficult to




compete with the suburbs for new development.  On the west coast, San




Francisco has much the same anti-auto viewpoint as Boston, yet will not




adopt a parking freeze because of a stronger desire to maintain itself




as the retail and business center of the Bay Area—it lately has been




feeling extreme competition for business from Oakland and San Jose, the




two other large cities in the Bay Area, and for retail trade from numer-




ous suburban shopping centers.




     Cities also fear internal effects of parking management strategies.




San Francisco feels pressure from local interest groups every time




parking management is suggested:  the small businessmen claim that be-




cause their operations depend on rapid turnover of on-street parking,
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any restriction of on-street space would have an adverse effect; and




construction  lobbies argue that the decrease in development they see




as the  inevitable result of a parking freeze would cripple the con-




struction  industry (they often attribute outrageous dollar figures to




the amount  of lost construction).  Such pressure is a powerful disin-




centive to  parking management.




      •  local  administrative problems - A second set of impediments to




local parking management stems from administrative problems in local




government.   As we hinted earlier, local governments often do not know




the full range of their parking-related powers.  The few cities to take




parking management seriously all have found it necessary to begin with




a thorough  review of municipal programs, and often have uncovered in




the process municipal programs and regulations with significant, though




previously  unrecognized, effects on parking.  (Parenthetically, these




program reviews have raised municipal consciousness about parking




management  planning.  A full enumeration of parking-related programs




invariabley reveals implicit, and often conflicting, goals and objec-




tives.   Localities are then motivated to think about their real goals




and examine how the parking programs must be altered to reflect them.




The net result can be a locally developed parking management plan,




based on political and administrative realities.  At very least, this




exercise forces local recognition of parking as an explicit policy




arena in which local actions have significant and wide-ranging impacts.)
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Unfortunately, most localities do not see the need for a clear under-




standing of parking programs, and, even when they do, time and monetary




resources usually are unavailable.




     Local resource constraints affect parking management in another




way as well.  Local government may not have the staff or the money to




plan or to implement any parking strategy which is not cost-free or




self-financing.




     The most critical administrative problem concerns the fragmenta-




tion of authority within local government.  Authority over local parking




control is distributed among numerous agencies of city government.




Some local agencies are staffed exclusively with mayoral appointees




who serve at his discretion and thus are under his control completely.




These agencies do not present an administrative problem for parking




management, providing the mayor is willing to support such a program.




But other local agencies which:




     - consist of independently elected officials;




     - consist of civil service employees; or




     - consist of mayoral appointees whose replacement would be a sensi-




       tive political issue




do not respond necessarily to the mayor's wishes  (in the short term;




over the longer term he could make enough appointments in some cases




to ensure proper representation of his views).  These agencies may have




their own goals—often in conflict with each other—and very little
                                  98

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motivation to coordinate their programs.  Thus, a unified local approach




to parking management is unlikely without the presence of a strong




executive and the evolution of a broad consensus within the city on




what should be done about parking.  This implies locally-developed




plans, or, at least, plans developed with a tremendous amount of local




input.




     • information ab ou t parjcing - Without good information about the




likely effects of parking management, it will be difficult to develop a




local consensus or, in fact, to persuade locals to do anything at all




about parking.  Experience with parking management to date has shown




that insufficient information is the critical factor working against




local support.  In Boston, in San Francisco, and in Phoenix, alarmist




reaction to proposed parking measures could not be countered because




information was not available about such things as the relationship be-




tween parking and development and the proportion of small business




patrons using on-street parking.  Without this kind of information, a




reasonable discussion of opposing views cannot occur.




     More fundamentally, it is not clear that parking management can




achieve many of the goals claimed for it.  Parking is, without question,




a legitimate variable in many transportation and development problems,




and should be planned carefully to regulate its impact in those two




areas.  But the effect of parking on air quality is not well estab-




lished.  It is assumed that parking has a secondary effect on air
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quality through its effects on travel and development;  specifically,




it is assumed that limitations on parking will hold down the demand




for auto travel and thus help to improve air quality.  Even if the pre-




sumed effect on auto travel is true (and that is by no means certain) is




it not possible that increased cruising for parking spaces could offset




any decline in auto travel and possibly worsen air pollution?  That we




cannot answer this question now is a good reason to proceed slowly with




parking management until better information can be developed about the




effects of various parking measures.
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C.  CASE STUDIES


     Case studies in this section are based on interviews conducted in


the summer and fall of 1975, except as otherwise noted.  A list of per-


sonnel interviewed is included at the end of this section.




1.  Boston and Cambridge, Massachusetts


a) Introduction


     The first round of transportation control plans touched off a


series of lawsuits, and in Boston, the South Terminal case decision up-


held the EPA's right to impose such controls as long as they were


justified by the data, but the court declined provisionally to accept


EPA's data.   EPA was also prevented by an amendment to the Clean Air

                                     2
Act from imposing parking surcharges.   These events led to the devel-


opment of a second transportation control plan for Boston, which was


made public in February, 1975, and contained somewhat modified require-


ments for parking management.  Since that time, EPA has indefinitely


suspended its parking management regulations nationwide, pending Con-


gressional determination of the proper role for EPA in parking manage-


ment.


     In spite of EPA's uncertain future in parking management, many


cities  are continuing to implement or plan parking programs.  As will


be seen in both the Boston and Cambridge examples, this is probably


attributable to a recognition (at some levels) that there are benefits


that can accrue to a city from a parking management program which are
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not directly motivated by a desire for clean air.




     Institutional arrangements developed in response to EPA's initial




requirements for parking management strategies are particularly inter-




esting, since parking has typically had an ambiguous status in city




government.  Parking is generally the responsibility of a traffic and




engineering department, or the police department,  or both, and planning,




if any, is typically concerned with providing sufficient capacity.




Parking management, which implies an explicit policy to limit capacity,




and in EPA's case to use scarcity and cost of parking as a disincentive




to auto use, has often necessitated new institutional arrangements or




modifications of old ones to provide the necessary legal powers and




expertise to plan these programs.  The precise arrangements made appear




to have a fairly significant impact on the planning and enforcement




that is actually accomplished, as illustrated by the Boston and




Cambridge examples that follow.




     Both Cambridge and Boston had given consideration to parking




management prior to EPA intervention, and both modified their activities




somewhat in response to EPA requirements.  The approaches taken and the




motives for early parking management differ significantly between the



two cities, and will be explored in detail






b) Cambridge




     In response to mounting difficulties in Cambridge with traffic




circulation, and in reaction to the threat of the Inner Belt to divide
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Cambridge into an MIT half and a Harvard half, the two universities



formed a committee to address the city's traffic problems.  The end



product of the committee's efforts was a piece of legislation that



passed the Massachusetts Legislature in 1961, establishing a Department



of Traffic and Parking in the City of Cambridge.  Very briefly, the



legislation created the position of Director of Traffic and Parking,



which is to be filled by a traffic engineer (member of the Institute



of Traffic Engineers) who serves at the discretion of the City Manager.



The Act also created a three member Board of Traffic and Parking, which



may review any action of the Director upon receiving a petition signed



by fifty registered voters.  The Director may adopt, alter, or repeal



regulations regarding the movement, stopping, standing, or parking of



all vehicles in Cambridge (on city streets) except that he cannot con-


                            3                 /
trol the trackless trolleys.



     In 1972, Cambridge initiated an experimental residential parking



permit program in the Cambridgeport area, where residential parkers had



long been in competition for spaces with area businessmen and those



whose destination was Boston (people parking in Cambridge and taking



subway downtown or walking to Boston University).  Stickers were issued



to residents of the affected streets, when they produced proof that



they had an automobile registered in their name, and that their primary



residence was within the permit area.  The program was considered to be



a success, and with modifications was made permanent, and plans were
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made to extend the residential permit system to other neighborhoods in




the city.  Under the first transportation control plan, the EPA re-




quired an on-street parking ban between 7 and 10 a.m. for Boston, but




not for Cambridge; the City Council requested that Cambridge be included




under the on-street ban, to avoid further problems of people parking in




Cambridge and working in Boston.




     Cambridge had no parking data at all when it first became involved




in parking management under EPA, and unsuccessfully attempted to get




EPA to fund a parking inventory.  Now, as the residential permit pro-




gram is expanded into each neighborhood, detailed parking inventories




are developed.




     Under the current  (second) transportation control plan, Cambridge




is continuing its residential permit program, instituting a 7 to 10 a.m.




ban on on-street parking, and has had its total number of commercial




off-street spaces frozen, so that the number of spaces cannot exceed




those in existence as of October, 1973, with some exceptions, as dis-




cussed later.




     The residential permit program continues under the administration




and control of the Department of Traffic and Parking, and this office




will also administer the on-street parking ban.  While the freeze re-




quirements are within the jurisdiction of the Department, the Director,




George Teso, has shown less interest in that program than the others,




and has made few plans for it.
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     The residential permit program, which pre-dated EPA, is seen as




having positive benefits to residents (although admittedly at the ex-




pense of some businesses and employers)and has been considered a popular




measure in Cambridge.  The program has been modified somewhat from its




original form.  The early version of the program attempted to distin-




guish between residents of different areas of the city; for example, a




person living near Fresh Pond (which had not been brought under the per-




mit system) and driving to work and parking near the Courthouse (which




was posted for residential parking only) was ticketed.  This practice




was successfully challenged in Commonwealth v^ Henry P. Sorett, in




which it was ruled that the action violated the equal protection clause




of the 14th Amendment since it discriminated between residents of




various areas of the city without showing a reasonable and rational




basis for doing so.  As a consequence, any resident of Cambridge may




now park in any area of the city.




     Visitor permits have been issued (two per household) in areas




which are posted for residential parking.  These permits are color coded




for 13 areas of the city and may be used only within those areas.  A




limited number of additional permits have been issued to those with




special needs—physicians whose practice is in Cambridge, for example.




     The residential program has again become the subject of litigation;




two lawyers who reside in other towns and work at the Courthouse (an




area in which the permit system has been implemented and is being en-
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forced) are arguing that the system restricts their right to work and




travel (14th Amendment).  This case is now before the Massachusetts




Superior Court.




     Cambridge has relatively little off-street parking, and the amount




of commercial off-street parking, with the exception of some previously




planned municipal parking facilities, is subject to the freeze.  As a




consequence, many employers have expressed concern about the impending




morning parking ban on the streets, because they feel squeezed from




both sides, the freeze and the ban.  Viewed in this light, perhaps some




of Teso's ambivalence toward the freeze can be understood.  With tran-




sit improvements well in the future, and fringe parking in Cambridge




still  in the planning stage, as well as little off-street parking




capacity to start with, such a freeze may well be premature.  The on-




street parking ban will have immediate positive aspects since it will




facilitate the delivery of city services such as street cleaning and




snow removal; this may also help to explain why this measure seems to




be favored over the freeze.  In recognition of the fact that there will




be some who are substantially negatively impacted by the on-street ban,




the Director is prepared to erect one hour meters in front of affected




businesses, and will issue a limited number of permits to employers for




distribution to employees who cannot find suitable alternatives to




driving.  Prior to granting these permits, Teso has said that he will




review the measures that an employer has used to encourage employees to
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seek alternatives to auto commuting,  and if he is convinced of a sincere




effort on all parts, will issue permits which will allow parking on a




specific street.




     In addition to controlling matters which are strictly parking re-




lated, the Director of Traffic and Parking also has control over stop-




ping of vehicles, which in practice means that the MBTA must receive




approval for all bus stops from Teso.  Perhaps as much as a function of




personality as anything else, Teso appears to have considerable power




in recommending routes to the MBTA, and thereby providing service to




areas otherwise accessible only by automobile.




     Teso's office has been considering other measures to make alterna-




tives to driving in Cambridge more attractive.  These efforts have




centered around finding an appropriate lot for parking on the edges of




Cambridge, and arrangements for MBTA or employer shuttle bus service to




work.




     Perhaps most importantly, Teso's office has control over enforce-




ment of the parking program, in addition to making policy decisions.




The Parking Control Officers work for the Director of Traffic and Park-




ing in Cambridge, rather than the Police Department, giving Teso much




better control over their activities.




     Major problems with the program center around costs and revenues.




Teso has been working on computerization of the residential permit sys-




tem, a costly effort, and right now  the dual system is very labor in-
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tensive.  No new staff are expected to be added for the 7 to 10 a.m.




ban—Teso observed that it was not fair to make the City add people—




apparently distinguishing between this program imposed from the outside,




and the residential permit program, a Cambridge program, for which




staff were added.




     The Department uses revenues from parking tickets to finance major




construction projects, such as the Central Square parking facility, and




can also use these revenues to defray their costs in general (although




it appears that they also are budgeted for City funds like any other




department).  Teso is clearly frustrated by having to rely on the Court




for recovery of fines, both because the system is inefficient (they are




2 to A years behind on summonses) and because clerks and judges void a




substantial portion of the tickets which Teso's personnel issue.  Teso




appears to be concerned about both the loss of revenues and the fact




that those in the courts appear not to share his sense of honesty in




the matter of voiding tickets (Teso uses his privilege to do so very




carefully, sending with each one a written explanation of the circum-




stances, and appears to wish that others could be forced to do the same).




The ticket processing system is scheduled to be computerized by fall




1976, at which time if payment is not received within 30 days, a sum-




mons will be issued automatically.  This may also give some control




over the probelm of voiding.




     In summary, the Director of Traffic and Parking is responsible for
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responding to EPA regulations affecting parking in Cambridge,  interfac-




ing Traffic and Parking operations with the MBTA,  Metropolitan District




Commission (MDC controls some roads in Cambridge,  and intersections




with those roads and Cambridge streets are of concern to both groups)




and the Massachusetts Department of Public Works,  which must approve




all traffic control signs and systems.  In addition, the Director of




Traffic and Parking is responsible for both policy and enforcement.




This centralization of power in one organization has advantages in




terms of its ability to respond quickly to new problems, but it also




seems to place a great deal of importance on the personality of the




Director of Traffic and Parking.




     Teso  is definitely enthusiastic about the effects of the residen-




tial permit program, and will undoubtedly continue to expand and en-




force the  program.  It seems likely that the 7 to 10 a.m. on-street ban




will be implemented, at least on a trial basis, regardless of EPA's




status, although it is hard  to speculate more  specifically on the out-




come of that program because so many factors are  involved.  For example,




if  Boston  implements such a  ban, then  Cambridge is extremely  likely  to,




regardless of  Federal  regulations  or lack thereof.  The  future of




Cambridge's off-street parking freeze  already  looks questionable, and




without EPA  intervention, or concerted pressure on the City Manager, it




does not  seem  likely that such a  freeze will be implemented  in the near




future.
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c) Boston




     Control of parking supply was one of the early recommendations of




the Boston Transportation Planning Review, which Governor Sargent en-




dorsed, and included in a policy statement in the fall of 1972.  As




originally conceived, there was to be a freeze on the number of parking




spaces in the Boston core area.  A detailed study of parking availabili-




ty and characteristics in the Boston area was undertaken by Wilbur




Smith, Inc., which began in 1972, and is still used as the primary data




base for parking policy.  Early efforts to implement Sargent's policy




consisted primarily of zoning changes applicable to the freeze area,




which eliminated the height bonus which was given to developers if they




provided extra off-street parking in their building, and made all park-




ing a "conditional use," subject to approval of the Zoning Board.




     Other freeze efforts had not gotten very far when EPA promulgated




its first Boston transportation control plan in 1973.  Opinions of




those currently working in the Boston Redevelopment Authority (BRA)




and the Mayor's office indicate that the intervention of the EPA was




seen as excellent for the City's freeze objectives since the "blame"




could be shifted to the federal government, thereby removing developer




pressure from the City to its federal scapegoat.  Although the partici-




pation of the EPA has clearly caused some heartache for the City,"* on




balance the effect is seen as positive.  The second transportation con-




trol plan for Boston, the one currently in effect, includes a freeze on
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commercial parking, a 7 to 10 a.m. on-street parking ban (modified in




some areas to 7-9:30 because of prior signing efforts), and a resi-




dential permit program (to allow residents to be exempted from the on-




street ban) .




     The fact that the freeze is limited to commercial parking, which




is interpreted by EPA under the second TCP as parking for which con-




sideration is paid, and which is open to the general public, has caused




consternation among those concerned with parking in Boston.  This




definition apparently exempts free parking, parking open to patrons




only   and parking open to employees only.  The free parking and the




employee parking exemptions are the cause of most concern, free parking




for the obvious reason that there is then no disincentive to parking




whatsoever, which runs counter to the object of the freeze in the first




place, and the employee parking because the commuter is precisely the




one that the City feels should be discouraged from driving.  The defi-




nition was developed by Region I EPA and included in the second TCP




because under the first TCP people were defining "commercial" as it




best suited their interest and it represents an attempt at clarifica-




tion.  Apparently no one from the city was consulted in the development




of the definition, and there is no indication that it will be changed




to cover free parking.  BRA staff have observed that rising costs of




construction may cause developers to construct buildings without park-




ing capacity anyhow for purely economic reasons.  A trend in this
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direction hns already started in the South Station Area, where the Blue




Cross/Blue Shield and Stone and Webster buildings have been constructed




with no parking capacity of their own.  It is expected that some por-




tion of the South Station development parking capacity will be used by




tenants of these buildings, but that space would presumably be com-




mercial space and consequently subject to the freeze.  Thus, the ap-




parent exemption of employee parking from the freeze may be compensated




for to an extent by the rising costs of providing parking spaces.




     The freeze is being administered jointly by the Mayor's office, the




BRA, and the Boston Air Pollution Control Commission  (APCC).  All three




are currently involved in developing regulations for the freeze, which




should be made public in December or January.  It is anticipated that




the APCC will be named as the lead agency, or the sign-off agency for




the freeze, taking it away from the political arena of the Mayor's of-




fice, and away from potential conflict of interest problems stemming




from the fact that the BRA is itself a developer in the urban renewal




area.  Specifically, the Governor will designate the City of Boston to




implement the transportation control plan, and the Mayor will propose




to the State that the APCC implement the transportation control plan




for the City.




     The APCC is currently a very small operation, and is headed by




Steve Cohen, a lawyer by training.  Their office has no capability to




perform air quality measurements, and consequently, will evaluate the
                                 112

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 freeze's effectiveness on the basis of  developing an acceptable process,




 rather than in terms of air quality goals.   In a sense this can be




 interpreted as being closer to Sargent's original motivations for pro-




 posing the freeze.   The APCC uses the BRA as its staff in many of the




 freeze matters,  particularly with respect to the establishment and




 anticipated maintenance of a "freeze bank,"  a record of parking spaces




 in the freeze area,  their type and location, and their availability,




 for the purpose of  insuring that  the total number of spaces does not




 exceed those in existence as of October,  1973.   The  Mayor's office plays




 a sort of overseer  role in the process,  trying to insure that all inter-




 ests are represented,  and dealing with  outside groups that can have an




 impact on the success  of the freeze,  like the MBTA.




      Freeze efforts  are complicated in  Boston by the variety of organi-




 zations that have control over parking.   In  addition to the Zoning Board




 which was mentioned  previously, the Real Property Board may lease




 garages to private  operators (but has no authority itself to operate




 them),  the Commissioner of Traffic and  Parking issues licenses which




 specify compliance with certain "house-keeping" measures such as sign-




 ing and  fencing, and a building permit must  be  obtained for any struc-




 ture (or  modification).   In addition,  the  BRA serves  as  an  advisor  to




 the Zoning  Commission  and  Board of Appeal.




     The  on-street ban and  the residential permit  system are being ad-




ministered by the Boston Department of Traffic and Parking.  The re-
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sponsibility for the residential program has been given by BT&P to the




Little City Halls in some neighborhoods, since the bookkeeping involved




is tremendous.  Coordination of the on-street programs with the freeze




is in its infancy, since initial meetings on the subject took place




between BT&P and the three freeze groups, the BRA, the APCC, and the




Mayor's office, in early December, 1975.  The importance of personality




becomes clear in this particular situation, since the Commissioner of




Traffic and Parking has been characterized as "hostile" by representa-




tives of the freeze groups.  Apparently the Commissioner is concerned




primarily with the fact that signing for the two programs will be cost-




ly, and has expressed the opinion that if the EPA wants the job done,




they can pay him to do it.  This philosophy runs counter to that ex-




pressed by the Mayor's office and the BRA, who are eager to do every-




thing  within their power to get cars out of Boston.




     It has been observed that the freeze alone will work to the ad-




vantage of commuters, since they typically arrive earlier than shop-




pers, and will get to the limited spaces first.  In theory, this should




be balanced by the 7 to 10 a.m. on-street ban, which will leave curb




spaces available to shoppers and tourists.  Getting sufficient coopera-




tion from the Boston Traffic and Parking Department is therefore criti-




cal to the overall success of the Boston parking program, since shop-




pers and tourists are the very auto drivers that the City cannot af-




ford to discourage too much.
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Again in theory, there is a simple solution to getting cooperation from




the Department of Traffic and Parking, since the Commissioner is a poli-




tical appointee.  A recent Boston Globe column by Ian Menzies observed




that the Mayor was a poor administrator, and outlined a series of




twelve points to improve the White administration, and the City.  Point




number twelve of the Twelve Point Program for the Mayor was:  "He must




confront the issue of his traffic commissioner, who persists in poli-




cies that will attract more automobiles to the city at the expense of




increased use of mass transit and service improvements."




     A recent conversation with the Deputy Commissioner of Traffic and




Parking revealed that the Deputy Commissioner is eager to get the on-




street program under way, since he is convinced that the fewer cars




there are in downtown Boston, the better off the City will be.  There




was an indication that this may become the Departmental viewpoint in




the near future.




     Even if the Boston Traffic and Parking Department undergoes a




change of heart, it must engage the sympathies of others in order to




get funding for their programs, since all of BT&P's funds come out of




the General Fund.  Ticket revenues go directly into the General Fund.




Additional meter maids will be needed for both the on-street ban and




the residential permit system.  The Police Department must also be in-




volved, since they are responsible for towing illegally parked vehicles;




in addition, Police Department personnel issue parking tickets.  There
                                 115

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is no distinction between Police and meter maid (BT&P) jurisdiction or




territory, it is simply a matter of who gets there first.  Boston's




court system is also behind in the matter of processing tickets, but




the impact is not direct on the BT&P Department, since it receives its




money through the General Fund.




     The city is apparently taking a very restricted view of its re-




sponsibilities with regard to parking management, and fulfilling only




the mandate from EPA.  An exception to this noted by Cohen is that EPA




policy is so narrow that it says nothing about the advisability of lo-




cating parking facilities in areas that are already local "hot spots."




Boston intends to go beyond the EPA requirements in this instance, by  ,




adding a regulation that will prevent the location of a parking facili-




ty in such an area.




     As a result of the freeze, Cohen expects pressure for more spaces




to be designated for handicapped drivers, which the City will be able




to do.  It is also expected that mobility of the handicapped in general




will increase with stricter parking measures, since there will be less




auto traffic to compete with.




     The issue of whether or not the program's potential benefits out-




weigh its potential disbenefits is not within the scope of EPA's man-




date, and hence has not been addressed.  Cohen refers to speculation




and research on economic and other impacts of the program as a "luxury"




which is not allowed for by federal funding.
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     With the exception of spaces for the handicapped,  Boston appears




to be taking a very hard line toward variances to the freeze, and in




fact the BRA was at one point considering inserting the phrase "there




will be no exceptions" in the freeze regulations.  This approach differs




significantly from the one anticipated by Cambridge for the on-street




ban (in which meters will be erected and special permits issued for




hardships) and currently practiced for the Cambridge residential permit




program.  For example, special permits have been issued for such groups




as visiting nurses and Secret Service, allowing them to park in posted




residential parking areas.  At the freeze level, when the concern is




for distributing a fixed number of parking spaces over all proposed de-




velopments, perhaps it is reasonable to expect that the policy can be




strictly adhered to.  It appears that there will be spaces to allocate




to Boston developers in the near future, and perhaps by the time there




are no more spaces, transit improvements will offset some of the nega-




tive impact.  Most importantly, the freeze is concerned with allocating




spaces to developments rather than to individuals.  This appears to




shift the responsibility to lot operators to devise a means of allo-




cating spaces, and pressures on lot operators may well influence dis-




tribution of scarce spaces.




     Boston has also taken a different stand from Cambridge on the mat-




ter of exceptions to parking by non-residents in residential permit




areas.  According to the Deputy Commissioner of Traffic and Parking in
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Boston, anyone may park in a residential permit area for a period of 2




hours or less, a policy which should make granting exceptions unneces-




sary.  It appears that this policy may solve some problems of admini-




stration while creating others.  Aside from the fact that there are un-




doubtedly some groups which legitimately need more than 2 hours to ful-




fill their responsibilities, the 2 hour  criterion seems to make en-




forcement much more difficult, and Boston is already short on enforce-




ment personnel.




     It is difficult to assess the extent to which Boston's program




will be effective, since it is still in the developmental phase.  The




fact that parking controls have been under development for nearly three




years may in itself be a sufficient indicator.  Without the EPA's




backing on the freeze, the Mayor's office has speculated that it will




be possible to implement, but Boston will be forced to make more com-




promises than would be expected under Federal backing.  An additional




aspect of the  freeze that came out of one interview is a claim that




Boston now has sufficient off-street parking spaces to serve major




anticipated developments for the next twenty years by phasing out obso-




lete City mechanical garages and other underutilized facilities and




allocating these spaces against such developments as Park Plaza, South




Station, and other urban renewal area projects.  If this claim is true,




it seems that the effective parking capacity of the City will continue




to increase, as spaces are made more convenient by new developments.
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     Tho future of the cm-street measures seems linked to the future of




Boston Traffic and Parking Department, which at this time is somewhat




unclear.  Both the residential permit program and the 7 to 10 a.m. on-




street ban will require diligent enforcement in order to be effective,




and enforcement is contingent on additional money from the General Fund




for personnel, and on cooperation from the Police Department for towing.




     Effectiveness of the freeze will also depend on effectiveness of




the on-street programs, as was mentioned earlier, so Boston is faced




with major coordination efforts in getting their parking management




program operational.






d) Comments




     Parking has typically not been an issue of major concern to cities,




but recent EPA regulations which tried to force the use of parking dis-




incentives raised a great deal of controversy over the role of parking




in a metropolitan transportation system.  Although the debate over




whether or not parking strategies will actually reduce VMT is far from




being settled, a number of cities are continuing to develop parking




management strategies to serve other motives or goals.




     Those departments or agencies which were initially delegated to




implement parking measures under the EPA reuglations seem to have had




considerable influence in determining the outcome or rate of progress




on the plans.  Each group or department in a city government seems to




have a slightly different view of the world, and this view seems to
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influence the department's assessment of the utility of various strate-




gies, as well as the best way to go about solving the problem.   While




this situation is quite reasonable and understandable, it seems that




watching a new set of requirements being met, as in this parking ex-




ample, serves to graphically illustrate the importance of political




climate, personality, and institutional structure on the outcome of




planning in urban transportation.




     It appears that those groups or departments which feel that they




can gain something tangible in terms of their overall goals from im-




plementation of the measures will implement them; other departments




will wait until they are forced.  The BRA-Mayor's office alliance in




Boston favors getting cars out of Boston as a planning goal, and the




EPA regulations presented a politically viable excuse for getting the




program moving.  A person who views himself primarily as a facilitator,




such as the Director of Traffic and Parking in Cambridge, can see ad-




vantages in delivery of city services from the on-street measures, but




would be less convinced of advantages to be gained from the off-street




freeze, and Teso seems to be conducting his program accordingly.  The




present Commissioner of Traffic and Parking in Boston is apparently




not sympathetic to the overall goal of less auto traffic in Boston,




and has also chosen not to place much value on the benefits to traffic




circulation and congestion that might result from the parking programs;




his stance has been that he will have to be forced to cooperate.  It
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seems that a department's interpretation of self interest in assessing




a program such as parking management can materially affect the way in




which a program is planned and administered.




     These observations have numerous implications for a federal agency




like the EPA which is making demands on local level organizations for




planning and implementation of programs.  First of all, understanding




the institutional arrangements and personal inclinations of the major




actors in each city seems critical.  Without substantial funds to dis-




tribute to people like the Commissioner of Traffic and Parking in Bos-




ton, to entice him into compliance, or without meaningful threats and a




reputation for backing them up, and outside agency like the EPA has no




practical recourse except to play sophisticated power games.  In other




words, a program should be "sold" on its merits to those involved, with




the "sales pitch" appropriately worded in each case to reflect depart-




mental and political interests.  The differences observed between Boston




and Cambridge also reinforce the claims that solutions to parking




management should be unique to each local area, since measures suitable




for one situation may not be applicable to  another situation.  The




parking freeze, for example, seems suitable for Boston, but may be




overly restrictive for Cambridge.




     A final observation on the effectiveness of EPA intervention in the




local planning process centers around the fact that those programs which




show the most promise in each city—the residential permit program in
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Cambridge, and the off-street parking freeze in Boston—are precisely




the programs which were under way prior to EPA intervention.  This




seems to indicate a need on the part of EPA personnel to carefully ex-




amine the process that they are trying to influence, in order to dis-




cover points of advantage and mutual interest.
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2.  Los Angeles, Calif_qrnia_ Area

     The Southern California Association of Governments  (SCAG) is the

3C agency for the Los Angeles area, which is physically huge  (38,528

square miles; making SCAG the largest 3C agency in the country) and ex-

tremely diverse, both environmentally and socially.  There are 6

counties represented in SCAG, and of the 151 cities in the region, 125
                    g
are members of SCAG.

     Originally EPA Regionl IX expected that SCAG would develop a re-

gional parking management plan for the entire area.  SCAG staff ex-

plored the idea, and realized that because of the huge area and the

great diversity in local parking policies, as well as the fact that

there was no regional transit to speak of to tie the area together,

SCAG simply could not produce a regional parking management plan.  In-

stead, SCAG has used a $250,000 grant from EPA via UMTA to fund 4

demonstration programs at the local level, and to fund SCAG for the

development of regional parking management guidelines.  SCAG cites

three reasons for its decision to follow the guidelines course of

action:  "1) SCAG is a voluntary organization and has no legislative

authority to implement or enforce plans, 2) the region is so diverse

that no single program could meet the needs of all the local jurisdic-

tions, and 3) no mechanism existed for allocating or reallocating the

region's staggering number of parking spaces."

     In addition to the reasons cited above for SCAG's reliance on local
                                 123

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level participation in parking management planning is a fourth reason

which undermines, to an extent, the validity of a regional approach.

SCAG studies (based on a CALTRANS model) indicate that parking strate-

gies alone will have very little effect on areawide VMT and photo-

chemical oxidant concentrations; coupled with other programs such as

improved transit, a decrease in VMT might be possible.  Therefore,

SCAG sees the primary usefulness of parking management as local measures

to improve circulation, to minimize CO hot spots, etc.

     The guidelines approach seems to face the realities of parking

management as far as local control that were addressed in our earlier

discussion, but still relies on voluntary compliance of individual

cities.

     The four cities which have been given funds to explore the po-

tential of parking management are:

     Los Angeles - large city          $100,000
        •
     Long Beach - medium city            20,000

     Brea - small city                   10,000

     San Bernardino - county-wide prog.  30,000

 (The remaining $90,000 has been allocated to SCAG for development of

guidelines).  The program has been under way for a year, and draft  re-

ports have been received from Long Beach, Brea, and San Bernardino.

Los Angeles' proposal was approved last July, and since then they have

been fooling around with their work program, and trying to put their
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staff together; they are funded for a 1 year study from the time the




effort gets under way, which it has not done yet.




     Long Beach and Brea have developed plans which are basically park-




ing-transportation management plans, and both cities are expected to




implement their plans, regardless of EPA's future involvement in park-




ing management.  Brea is planning to revamp all of its zoning ordinances




and will make appropriate recommendations to support their parking




measures to meet a variety of civic goals.  Long Beach has plans for a




downtown redevelopment program, and sees parking management as an in-




tegral part of the program.




     San Bernardino went well beyond the limited objectives of the




study and in addition to parking essentially brought in all of air




quality by including such things as VMT minimization measures.  San




Bernardino is located approximately 60 miles east of "downtown" Los




Angeles, and at the time of the last census, was ranked fifth in the




nation in terms of its dependence on automobiles.    Because of the




meteorological patterns in the Los Angeles Basin, many feel that the




potential for air quality improvement in San Bernardino through VMT




reduction measures is limited because the bulk of the pollution is




generated elsewhere.  On the other hand, San Bernardino is not really




in a position to criticize other cities for their lack of action unless




they make an effort themselves.  In any case, San Bernardino is the




only demonstration project so far to have adopted its plan.  However,
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 the  San  Bernardino Board of Supervisors is holding up implementation




 of the entire plan because it is a downwind county, and  it does not




 want to  put  itself at a competitive disadvantage with the upwind




 counties which have not adopted parking management plans.  Les Spahnn




 of SCAG  feels that the chances for obtaining  leverage over the re-




 maining  counties in the area are directly tied to proposed Clean Air




 Act  amendments.  If a regional approach to air quality is included in




 the  Clean Air amendments with  208 (FWPCA)-type legislation, then




 Spahnn feels that there may be hope for getting the necessary regional-




 level control to solve this sort of problem.  Without this type of con-




 trol, there appears to be very little chance  that San Bernardino's




 plan will be implemented.




      Incidentally, there is currently no 208  designation in the Los




 Angeles  area.  SCAG has been fighting to get  designated, but no decision




 has  been made to date.






 3.   San  Francisco, California Area




      The Metropolitan Transportation Commission (MTC) received




 $150,000 from EPA via UMTA, and is funding San Francisco, San Jose




 and  Oakland to explore the potential of parking management.  The re-




 mainder  of the region is being covered by Alan M. Voorhees Associates,




which eventually selected five prototypical (their term)  cities for




analysis:  San Leandro, Walnut Creek, Cupertino, Petaluma, and Vallejo.
                                  126

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Analyses are to cover development of parking strategies and a scheme




for evaluating the effectiveness of the strategies.  In addition, in




the Voorhees study, a measure of political acceptability of each




strategy was determined, using the Delphi technique.




     The cities involved have apparently completed their data acquisi-




tion and are now in the process of working toward a draft report.  It




is not expected that any real planning will be done under this contract,




since lack of EPA regulations removes the real driving force behind




parking management planning.  MTC has been characterized by those in




EPA Region IX as having failed to take a leading role in parking




management even before the suspension of EPA regulations, and having




been pushed to take every step that they did take.  John Warren of MTC




feels that the issue of whether or not parking management is effective




in meeting its air quality objectives is an important one which has




not been satisfactorily addressed.  The contract that MTC had was not




sufficient to allow them to explore the problem.




     Parking planning has proceeded far enough in the Bay Area for a




number of problems to have surfaced.  According to MTC one of the




major problems is that cities do not have the authority to control the




operation of privately owned parking facilities (California courts have




not interpreted regulation of private parking facilities as part  of the




city's police powers).    Taken at face value this does indeed seem to




preclude efficient parking management; however, the fact that San
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Bernardino, Long Beach, Brea, and San Diego have developed parking




management plans would indicate that the problem is not as large as it




initially appears.  First of all, it seems that MTC's reference must




be directed only at control over rates or rate structures of private




facilities, since cities clearly have other kinds of control over all




types of parking.  As mentioned in our previous discussion, existing




parking can be taxed by cities, and zoning ordinznces, through "condi-




tional use" and other categories, can require periodic justification of




a facility's existence, and therefore provide a basis for phasing out




existing facilities.  Those cities which have been studied which have




parking programs under way, Boston and Cambridge, do not rely on con-




trol of parking facility rates as a major control strategy.  In fact,




the only control concerning rates known to us is that the BRA will be




able to specify rate structures  (for example to favor short term park-




ing) for parking facilities within the urban renewal area in Boston.




It is not possible to tell whether MTC is using this rate control




problem as an excuse for inaction, or whether they are genuinely una-




ware that parking management can be achieved in any way other than




through control of parking rates.




     Other problems that MTC has cited are lack of regional authority




over parking matters (which has been discussed previously), leading




MTC to encourage individual cities to proceed on their own.  This of




course has led to a San Bernardino-like situation,  in which some cities
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have indicated a willingness to do parking management,  but only if they




can get assurances that adjacent cities will also manage their parking.




Another problem cited by MTC is that much of the area currently has




excess parking capacity, although this is not true quite so much for




San Francisco.
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D.  CONCLUSIONS AND RECOMMENDATIONS




     Based on the preceeding discussion and on the case studies, we




can formulate a number of conclusions and recommendations about parking




management:








1.  Parking Management and Planning Should be Viewed as Transportation




Planning.




     No analysis which has been made known to us has been able to




demonstrate that parking management alone is an effective VMT reduction




measure.  This single factor seems to have contributed significantly to




the lack of seriousness with which parking management has been treated




in some areas.  On the other hand, most people seem willing to agree




that in cooperation with other transportation measures, parking manage-




ment may be effective.  This situation would seem to imply that parking




management (or parking measures) should be included as part of the TCP,




and not as a separate entity which needs additional justification.




Parking measures have been included in some TCPs, included in the




indirect source requirements, and also included in the parking manage-




ment plans.  Inclusion of all parking measures in the TCP will eliminate




unnecessary duplication, and will group parking with the other transporta-




tion measures where it most reasonably belongs.




     It is recommended that in areas where it is appropriate, the TCP




should specify that parking should be managed or that a parking

-------
 management  plan  be  developed  and  implemented, rather  than  specify  the




 measures  to be implemented.   The  requirement  for a plan should result




 in  a  more satisfactory  end product because it will enable  local develop-




 ment  of the plan, and thus will more accurately reflect local  interests




 in  parking  and have a greater probability of being carefully enforced.




      The  requirement for  parking  management in the TCP should  be




 worded in such a way as to parallel the  requirement for consideration




 of  parking  management in  the  joint FHWA-UMTA Transportation System




 Management  Element.  In this  way  the EPA and FHWA-UMTA programs




 will  clearly be  mutually  supportive in action, regardless  of the motiva-




 tion  for  actually performing  the  parking management.  This will have




 the additional advantage  of making parking management eligible for




 funding under UMTA  sections 3 and 5 and  for Federal-aid highway funds.




      Inclusion of parking management as  an element of an area's ongoing




 transportation planning efforts as the above paragraph suggests will have




 the effect  of focusing  attention  on parking as a single element of the




 overall transportation  system.  In this  way parking controls may be




 seen  as fitting  in  with and supporting an area's transportation and




 land  use  goals.  Parking  management is difficult to justify when it




 is  set apart  from other transportation elements by separate regulations




 requiring separate  plans, particularly in view of its questionable




 impact on VMT.   However,  it is relatively easy to argue that the




 transportation system as a whole can be managed to produce VMT




reductions;  since parking  management  is one element of that system it
                                131

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should also be managed.





2.  Parking Management Flans Should Be Developed at the Local Level, with




Regional Controls.




     As the previous discussion has indicated, it is unrealistic to expect




a regional transportation planning agency to produce a workable parking




management plan, because:




     i) parking controls almost exclusively are local;




    ii) a regional agency would have difficulty in assembling sufficient




information to make a good plan, especially in understanding subtle




details of local institutional structure;




   iii)  a consensus must be developed among opposing groups in each city




(as well as between cities).  This is hard to do on a regional level,




since it would require an enormous staff to keep abreast of all the




issues.




     In addition to the fact that under current legal structure, most




parking controls are local, most of the benefits of parking




management are also expected to be experienced at the local level.




However, because of the disincentive nature of parking controls,




regional participation seems necessary in some cases in order to




insure that benefits from local parking management can be realized. The




case studies clearly indicate, for example, that separately developed local




plans are acceptable to the town developing them only if adjacent towns




or counties do the same, so that the area managing its parking does
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 not place itself at a relative disadvantage.   (The issue of  potential




 loss of retail sales due to parking management is one that has yet  to




 be satisfactorily explored; since there is little information on the




 subject,  loss of retail sales is generally used as an argument




 against parking management.)  It seems clear  that in some areas, local




 governments will need a concrete means of influencing one another to




 implement parking plans, and the most reasonable (or at least readily




 available) forum is through the regional agency.  Other areas in




 which only a few cities are involved and have compatible goals, such




 as Boston and Cambridge, may not find it necessary to work  through the




 regional agency.  Regional agencies in different areas would have




 different levels of involvement in parking management, depending on




 the ability of local governments to reach the necessary agreements to




 enable each city to implement its parking management plan.




      The Los Angeles example indicates that providing guidelines for




 plan development and a forum for discussion may, in some cases, not




 provide sufficient incentive to get all local governments in a diverse




area to implement parking management plans.  In such cases,  the regional




 agency should be empowered to seek compliance  through:







      - conditioning planning grants on conformance with regional




 guidelines or goals




      - conditioning the approval of other transportation projects on




 conformance with regional guidelines or goals (e.g.the regional agency
                                    133

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might refuse to recommend projects desired by localities not in compliance

with regional goals or guidelines).



It should be emphasized that regional goals or guidelines should

not necessarily be rigid, detailed documents.  Guidelines might, for

example, contain a listing of parking strategies and recommend that
           }
they be used, but if not used state why not.  In such a case a reasonable

negative response might be:  "City A will not implement an off-street

parking freeze since it has only 2000 off street spaces, and the real

parking problem in the city is on-street parking."  While guidelines

might describe a procedure for local governments to follow in the

development of a parking plan, it should be recognized that parking

controls are primarily in the developmental stage, and such steps as

inventories, while useful, are costly and are less needed than some

experience with implementing various parking measures.  Areas proposing

to implement a parking tax, for example, should be encouraged to pick

a tax rate and try it for a certain amount of time, and adjust it

periodically to achieve the desired effect, rather than perform inventories

and try to figure out elasticities for parking and estimate the tax

level based on those calculations.  Disincentives of this type are not

well understood, and it seems desirable to get some parking programs

under way - voluntarily or with varying degrees of pressure from

regional agencies  - in order to determine their impacts, thereby

settling many of the lack of information issues raised elsewhere in
                                 134

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in this discussion.









3. EPA Should Promote Local Interests in Parking Management, Regardless




of Local Motives.




     Although parking management is primarily a disincentive measure, it




has received support at the local and regional level.  Parking management




has or is being proposed as a means for meeting diverse local goals




including:  improving local traffic circulation, decreasing the number




of vehicles downtown in conjunction with urban renewal projects,



facilitating the delivery of municipal services such as snow removal and




garbage pickup, reserving streets in residential areas for parking by




residents only, and increasing the city's tax revenues.  However, it is




not reasonable to expect total agreement from all parts of a city govern-




ment on the desirability of parking management, or on the correct




parking measures to use if there is substantial agreement.  While these




decisions are largely political, a federal agency like the EPA can




participate in the political process to its advantage by identifying




and lending support to those in city governments in favor of parking




management, regardless of the city's motive for parking management.




For example, advice might be sought from those supporting or already




developing parking measures if definitions are developed or regulations




changed.  Establishing this type of communication should work to the




advantage of the EPA, since it will reveal political peculiarities of




the area explaining why some approaches are more reasonable than
                                 135

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others, and it should work to the advantage of the groups within the city




to have federal support behind their programs.  In addition, this communi-




cation should be helpful when EPA makes critical definitions or changes




in regulations, so that a city's efforts will not be inadvertently under-




minded by a change in emphasis by EPA.




     Parking management has proved to be controversial in many areas,




due in part to the fact that it is a disincentive measure, and also in




part to the blast of negative publicity surrounding the early parking




schemes (like color coded stickers for each car, and substantial




federally-imposed surcharges).  On the other hand, there is support for




parking measures in many cities, which could benefit from sensitive federal




involvement to help promote their programs.  It is recommended that EPA




develop an understanding of the local political climate and seek




opportunities to promote federal objectives through local political




channels.





4.  EPA Should Fund A Parking Management Demonstration Program





     A factor that will continue to plague parking management for some




years is the huge number of unresolved issues which are associated with




the impacts of parking controls.  In order to put these questions




to rest, and to generate good will and various other desirable side




effects, EPA should fund a demonstration program.




     Although some cities like Cambridge have parking programs fairly




well under way, they may never provide the type of information that
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reluctant cities seek.   In Cambridge, for example, there is only one air




quality monitoring station (Science Museum),  located in a remote corner




of the city at the intersection of numerous superhighways.  It is improbable




that parking measures implemented in Cambridge will have any impact on




readings at that site,  and most importantly,  that site is not represen-




tative of the areas in which most people in Cambridge reside.  If an




improvement in air quality can be demonstrated to be attributable to all




TCP measures together (the approach mentioned under #1) or to parking




management alone, then EPA will be in a greatly improved position.




Demonstrating to city residents that these measures are effective may




be an immense step forward in getting local cooperation for parking




management planning, but will probably require special monitoring and




evaluation efforts.



     In addition to the air quality issues, a demonstration program could




be devised to monitor social and economic impacts of parking management,




if that proves unfeasible, then of TCP measures as a group.  Prior to




suspension of the parking management regulations, EPA placed itself in




the position of demanding that parking management programs be developed  .




separately from TCP's with very little information about  the VMT




impacts, social and economic effects and other implications of parking




management.  Since EPA is forced to  rely on local governments to develop




and implement these programs, and  EPA has no direct controls over local




government, it is recommended that EPA make every effort  to gain the




sympathy of local governments by attempting to develop more information
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on the effects of parking controls.   Even if local governments are forced




to develop parking plans, they cannot be made to enforce them effectively.




EPA's best approach to getting parking managed at the local level appears




to involve showing that it works and can have beneficial impacts, and




then carefully lending support to those in local governments who favor




parking controls.  The best way to show that parking works would seem




to be through a well designed demonstration program.








5.  Some Requirements_ _in Parking Management Plans Should be Relaxed




     The enumeration of minimum information to be contained in parking




management plans dated August 22, 1974 appears to be inadequate in




two main aspects 1) the fact that it apparently refers only to management




of parking in parking facilities (elsewhere defined as an area used to




park 250 or more vehicles) and 2) it is not clear that some of the




information required is necessary for effective parking management.




     Regarding the first point, it seems only reasonable that on




street parking controls be included under parking management, so that




the entire parking portion of the area's transportation system can be




dealt with at once.  This can be accomplished with no overlapping of




programs if all parking considerations are included in the TCP, as




recommended previously.




     Second, an inventory of average daily vehicle miles  traveled, and




information concerning the VMT reduction to be achieved through the plan
                                   138

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 seem  to be meaningless bureaucratic exercises which are totally unrelated




 to  the potential  impacts of the plan.  VMT inventories are not




 inventories,  they are estimates, and as such may contain substantial




 inaccuracies.   Information concerning VMT reduction to be achieved through




 the plan must necessarily be  fictional, since so many assumptions must




 be  made about changes in the  rest of the transportation/land use system




 that  changes  in traveler behavior attributable to this single policy cannot




 be  reliably determined.




      Inventories  of existing  parking facilities can be expected to




 be  constructive only if limited to type, location and capacity for




 off-street facilities and for on street capacity, to contain an  estimate




 of  the amounts  of  legal and illegal curb space.  Requirements for




 extensive inventories including occupancy rates, and use by category




 (eg. business,  work, shopping, etc.) tend to be very costly, and are not




 always useful.  The important point with regard to much of this in-




 formation is that  it requires relative sophistication— parking controls




 do not.  Parking controls are still in the "shooting in the dark" stage




 because of the  huge amount of local variation that can be expected




 and because there  has been very little actual experience with parking




management.  Local areas interested in parking management should be




 encouraged to consciously plan for parking as one more element of




 their transportation system;  they should not be overwhelmed by large




data requirements.  As has been argued elsewhere in the recommendations,
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it seems that the most reasonable solution to parking management problems




is to.  work with people and get them doing it.




     If the parking management plan is developed in the context of the




area's transportation plan, then it will automatically include community




participation, development of alternatives, discussion of impacts, etc.




The most important unique elements of the parking management plan seem to




be details of implementation and enforcement, and mechanisms for




communicating with all of the groups in an area that can impact the




effectiveness of parking management, including transit operators, police




department, traffic and parking department, etc.




     It seems that a more relaxed approach in parking management is




desirable since present information requirements are largely artificial—




it is difficult to know what is really necessary until parking controls




have been applied in a few more areas.  Cambridge was able to proceed




on its parking plans and develop its detailed inventories simultaneously;




it seems that individual approaches such as this should be encouraged to




get parking into transportation system planning.  More sophisticated




approaches and requirements can then be developed as parking controls




are better understood.
                               140

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                               FOOTNOTES



1.  South Terminal Corporation, 6 ERG 2025, 1974.

2.  Clean Air Act, 42 U.S.C, 1857 et seq.

3.  Chapter 455 of the Acts of 1971, An Act Establishing a Department
    of Traffic and Parking in the City of Cambridge, reproduced in
    "Program and Financial Requirements for Enforcement of Clean Air
    Transportation Control Plan", Report by City of Cambridge, Mass.
    to U.S. Envrionemntal Protection Agency, June 28, 1974.

4.  An Access Oriented Parking Strategy for the Boston Metropolitan
    Area, Final Report, prepared by Wilbur Smith, Inc. for the
    Massachusetts Department of Public Works, in cooperation with
    USDOT and FHWA, July, 1974.

5.  An example which was cited by many participants in the freeze is
    referred to as the Rouse case.  In order to secure financial backing
    from banks, developers are often required to produce proof that all
    necessary permits and licenses have been obtained.  In this case
    a developer of an urban renewal parcel which included parking spaces
    requested from the BRA clarification on the status of the freeze
    (this was between TCPs) in order to comply with such a request from
    his bank.  To make a long story short, BRA tried repeatedly to
    get such an answer out of the EPA, then tried for any response at
    all (they requested a letter saying that EPA had received their
    letter), and finally settled for the best that EPA would come up
    with— a photocopy of BRA's original letter with a "received" stamp
    on it.  While the EPA may actually not have known the status of the
    freeze, since it was a subject of litigation, even a response to that
    effect would have helped influence future intergovernmental relations.

6.  Wilbur Smith, Appendix B, Legal Context for Parking Management, July,
    1974.

7.  "12 Point Program for Mayor", Boston Globe, column by Ian Menzies,
    December 3, 1975.

8.  "The Development and Implementation of Parking Management Programs in
    California's South Coast Air Basin:  A Transportation and Air Quality
    Improvement Effort", Nancy L. Chinlund, Robert A. Doty, Leslie S. Spahnn,
    presented at The Workshop on Parking Management Regulations of the
    Environmental Protection Agency, May 1, 1975.
                                 141

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 9.  Ibid.

10.  Interview with George Visbal, Caltrans, San Bernardino 8/12/75.

11, "San Francisco Bay Area Regional Parking Management Plan Guidelines",
     Summary of Results, Alan M. Voorhees and Associates, Inc., December
     3, 1975.
                                  142

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          Boston and Cambridge Interviews - Parking Management

Boston Air Pollution Control Commission 11/12/75
     Steve Cohen

Boston Redevelopment Authority 11/14/75
     Jane Algrain
     Alf Howard

Central Transportation Planning Staff 11/25/75
     Alan Simon  (by telephone)

Department of Traffic and Parking, Boston 12/5/75
     Paul Foster, Deputy Commissioner   (by  telephone)

Department of Traffic and Parking, Cambridge 11/14/75
     George Teso, Director

EPA Region I, Air Branch 12/8/75
     Don White

Mayor's Office, Boston 11/17/75
     Sue Clippinger
     Emily Lloyd

MIT Planning Office 11/10/75
     Rennie Thompson
                                    143

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                California Interviews - Parking Management

EPA Region IX  12/5/75
     Fred Leif (telephone)

Metropolitan Transportation Commission
     Jose del Rio  8/19/75
     John Warren 12/10/75 (telephone)

Southern California Association of Governments 11/26/75
     Leslie Spahnn (Telephone)

State of California Department of Transportation

     Charles Boyer, Los Angeles, 8/11/75
     George Visbal, San Bernardino 8/12/75
     George Wehmayer, Sacramento 8/18/75
                                    144

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VI.  CLEAN AIR ACT AMENDMENTS




A.  BACKGROUND




     Several amendments to the Clean Air Act of 1970 were proposed




during 1975.  One part of the M.I.T. research effort was to review and




critique the transportation-related portions of the proposed legisla-




tion and to suggest modifications or alternatives.  M.I.T. prepared de-




tailed commentaries on the relevant sections of several draft amend-




ments; met with E.P.A. personnel to discuss how transportation controls




should be treated in the Clean Air Act; participated in a briefing of




the staff of the Subcommittee on Environmental Pollution of the U.S.




Senate Public Works Committee; and prepared proposed wording and support




material for use by E.P.A.




     The proposed changes to the Clean Air Act include:




     • an extension of the deadline for attainment of the air quality




       standards;




     • governor designation of "areawlde" (regional) air quality plan-




       ning organizations;




     • required development of air quality management plans (A.Q.M.P.s),




       specifically including transportation control strategies,  for




       each region with serious air quality problems; and




     • sanctions for failure to produce and agree to implement an ac-




       ceptable A.Q.M.P.,  in particular, cutoffs of certain federal




       funds.
                              145

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     Because the specifics of the proposed amendments have changed con-




siderably from draft to draft,  it is inappropriate to discuss these de-




tails in this report.  Instead, the discussion focuses on the four




topics listed above and on the major addition proposed by M.I.T., a




requirement for guidelines on the air quality management planning pro-




cess.
                                146

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B.  EXTENSION OF THE DEADLINES



     The Clean Air Act currently requires attainment of air quality


                                2
standards by 1977 at the latest.   By current estimates, however, at



least 15 cities will be unable to meet the standards for those pollu-



tants caused primarily by the automobile—unless they resort to drastic



measures to curtail auto use (e.g., gasoline rationing, limitations on



gasoline sales, periodic bans on driving).  Because there is general



agreement that such drastic measures should not be put into effect, ex-



tensions of the deadline for meeting the standards have been proposed,



the suggested extensions take several forms:



     • a simple postponement in the attainment year (alternative dates



       have been proposed);



     • extensions of the deadline for those areas unable to meet the



       current date with regard to particular pollutants, the length of



       the extension to be determined on a case by case basis; some-



       times with a cut-off date for all areas;



     • extensions for particular areas as above, with required demon-



       stration of progress in moving toward full compliance with the



       standards; sometimes with a cut-off date.



     Although there is clear need for extension of the deadline, sim-



ply moving the attainment date back is unlikely to cure the problems



now being encountered.  For one thing, some areas (most notably Los



Angeles) would find it difficult or impossible ever to attain the
                             147

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standards by any of the deadlines seriously being discussed.  The single




deadline would provide more time than needed for some areas, and not




enough time for others.  Therefore, we prefer setting deadlines for




attainment in those areas missing the 1977 date on a case-by-case basis.




     More to the point, however, a major problem has been that areas




have slow to get started on implementing measures for air quality.




Without some requirement that the areas show progress, any extension of




the deadlines could just mean more delay.  It is our recommendation




that annual showing of reasonable progress in implementing measures to




improve air quality be required as a condition for further extensions.




Reasonable progress could mean, for example, completion of studies on




implementation or partial implementation of particular strategies,




creation of necessary legislation and regulations to implement control




programs, hiring of additional police officers for enforcement, and so




on.  Each area could be required to submit a brief proposal of activi-




ties over the next year, and EPA could impose conditions.  Failure to




show reasonable progress, unless justified, would lead to imposition




of sanctions.  In this way, EPA could assure steady movement toward




compliance.




     Regardless of the conditions imposed on attainment, it will not




be possible to assure compliance unless effective sanctions are availa-




ble to EPA.  Sanctions are discussed in E., below.
                                 148

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C.  DESIGNATION OF REGIONAL AIR QUALITY PLANNING ORGANIZATIONS




     Proposed amendments require the governor of each state to desig-




nate an air quality planning agency in each region with serious air




quality problems.  This agency would take responsibility for the devel-




opment and implementation of all air quality strategies not retained




at the state level.




     This is a positive development for transportation control planning,




since transportation in metropolitan areas traditionally has been




planned at the metropolitan level.  In fact, transportation plans and




projects generally must be approved by the Metropolitan Planning Or-




ganization in order to be eligible for federal funds.  Thus, placing




responsibility for most transportation control measures at the regional




level provides a remarkable opportunity to eliminate many of the inter-




agency coordination problems that have arisen under the current Act.




     However, several drafts of the amendments have required that the




agency designated for 208 water quality planning, where it exists, also




be designated as the air quality planning agency.  This stipulation




apparently is the result of a desire to concentrate federal programs




for environmental protection in one agency, and so stem proliferation




of federally mandated regional planning bodies, which has come under in-




creasing criticism in recent years.  In some cases, the 208 agency and




the MPO are the same; in others, however, they are not.  We feel strong-




ly that, whenever possible, the regional agency planning for transporta-
                                 149

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tion controls should be the designated metropolitan transportation




planning organization.  Otherwise, parallel transportation planning




processes will exist at the metropolitan level, with wasteful duplica-




tion and potentially disastrous results.  Designation of the MPO also




would serve the federal goal of utilizing existing agencies in new pro-




grams.  We therefore recommend that the governor be given latitude in as-




signing responsibility for air quality planning to the agency or agen-




cies with requisite capabilities.  It is strongly urged that the desig-




nated agency for Transportation Control planning be the M.P.O.  We see




no reason why an additional agency could not be given responsibility




for any non-transportation related (i«e., stationary source) air quality




planning which is not retained at the state level.




     It is also recommended that the EPA Administrator be given the




power to approve or disapprove agency designations.  Approval should be




granted upon a showing that each designated agency has or will have




within a reasonable time all of the capabilities necessary for success-




fully carrying out the planning responsibilities assigned it.  This would




give  EPA limited control over agency designation but would enable the




Administrator to reject an agency clearly unqualified to carry out its




assigned responsibilities.
                                  150

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D.  DEVELOPMENT OF AIR QUALITY MANAGEMENT PLANS




     Proposed amendments would require the development of an air quality




management plan (AQMP) for each area having serious air quality problems.




The major difficulty with, the proposals as written is that they do not




specify clearly the relationships between the proposed AQMP and existing




planning documents such as the state implementation plan, the transporta-




tion control plan, and the air quality maintenance plan.




     It is crucial that duplication of planning activities be avoided.




Therefore, we recommend that the proposed legislation be clarified and




interpreted as follows:




     • Governor designations of regional agencies should have the effect




of transferring responsibility for the appropriate portions of SIPs,




including TCPs, to the regional agency.




     • Thereafter, the designated agencies would have full responsi-




bility for plan revision and updates, and implementation.




     • The regional agencies also would have responsibility for any




air quality maintenance programs related to their assigned responsibili-




ties.




     • The state would retain full responsibility for all portions of




the state implementation plan not transferred to the regions, including




any maintenance programs related to the retained portions.




     Thus, for example, the state could assign an MPO responsibility




for all portions of the TCP except for inspection and maintenance
                                 151

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programs.  Thereafter, the MPO would be responsible for implementing




and revising the TCP as appropriate, and for all further studies on




transportation controls.  The state, however, would have responsi-




bility for any further I and M planning, for implementation, and for




any related maintenance programs.  In this example, the state also




would retain responsibility for stationary source control.  The air




quality management plan for each region would then be the relevant




portion of the state's plans plus the plans developed at the regional




level.




     The purpose is to maintain continuity in air quality planning




and to avoid duplication.




     The air quality management section of the proposed Amendments




also contains a list of control strategies and a requirement that each




be studied.  Some versions also require that such strategies be in-




cluded in each plan.  While we support the investigation of a wide




range of alternatives we strongly oppose the idea that each area must




implement some version of each alternative, since many of the options




listed could be expected to be unworkable in numerous areas.  We also




believe that such a requirement would defeat the purpose of the pro-




posed requirement for impact analysis.  The purpose of impact analysis




should be to identify beneficial and adverse effects of the alternatives




under question, thus indicating whether or not an alternative is ac-




ceptable.  Although adverse impacts often can be mitigated to some ex-
                                  152

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tent, there will be many occasions when the benefits are marginal


and/or unavoidable adverse impacts are significant.  In such cases,


the appropriate action is to reject the alternative, not to implement


its least objectionable form.


     The document submitted as a plan should include discussion of al-


ternatives considered, evaluation of alternatives, specific commitments


to implementation, and discussion of future planning activities — i.e.,


what has been considered; what has been selected, and why; how the


selected options will be put into effect; and what will be done next.


Without the inclusion of this information, adequate evaluation of a


plan is impossible.


     Thus, an air quality management plan should


     • discuss the proposed short- and long-term projects and programs


       to achieve air quality;


     • evaluate these projects and programs as to their social and


       economic effects, public comment, etc;


     • indicate responsibility for planning and implementation (what
                                                                \

       agencies, etc.);


     • list sources of funding and other resources available for


       planning and implementation;


     • discuss alternatives which were considered in developing the


       plan and summarize their costs and benefits;


     • make a definite implementation commitment for the next time
                                  153

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  period, indicating specific responsibilities,  funding sources,




  etc;




• indicate what will be investigated or planned for over the next




  period, with responsibilities,  funding sources,  etc., spelled




  out;




• indicate what long-term planning activities will be going on;




• state what will be done should  monitoring show that the imple-




  mented programs are falling short of goals.
                            154

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E.  SANCTIONS


     The proposed amendments provide that any area not in compliance


with the requirements for maintenance planning and implementation


would be denied certain federal funds.  This represents a major change


from the current Act, under which EPA is required to produce acceptable


plans for states failing to do so themselves, and enforcement of plans


is left to court action.


     The requirement that EPA develop air quality plans has been an


onerous one.  It has stretched EPA's resources thin, and has resulted


in plans having little support in the areas upon which they were im-


posed.  Thus, the EPA plans requiring state and local governments to take


certain actions have met with considerable resistance.  Such plans also

                                                4
have been challenged successfully in the courts;  the majority of cir-


cuits that have ruled on the issues have rejected EPA's claims of


authority to require the states to spend money or pass legislation.  If


these decisions stand, EPA will be left only with the authority to


actually implement control strategies itself, i.e., run its own in-


spection and maintenance programs, carpooling programs, etc.  Even if


EPA does have the right to require that the SIP be implemented by the


states, the current sanctions—injunctions and contempt orders against


state officials—are so drastic as to be unusable.


     The sanction of cutting off certain federal funds from an area not


in compliance with needed air quality plans is the most workable one to
                                  155

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appear thus far.  However, care should be taken not to cut off funds




which would be needed to implement desired plans.  It is recommended




that the sanction be as follows:




     • No federal funds from the specified program could be expended in




a non-complying area on any plan or project which is inconsistent with




the area's air quality needs.




     • One element of this consistency determination would be whether




first priority had been given to all planning and projects necessary




for attainment and maintenance of air quality standards in the area.




     Thus, for  acaraple, an area not in compliance with its TCP would




be eligible for federal transportation funds for its TCP elements, but




would be eligible for other transportation funds only upon a finding




by EPA that such expenditures would not delay attainment or interfere




with maintenance of the air quality standards.  This would not shut




down federal programs, but would limit them in a recalcitrant area un-




til such area was in compliance.
                                 156

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F.  PROCESS GUIDELINES




     A proposed amendment requires each air quality management plan-




ning organization to set up "a continuing air quality management plan-




ning process" within one year of the designation.  Little is said, how-




ever, about the desired attributes of the planning process.  Yet this




process is the prime determinant of the quality of the plans it pro-




duces, their political acceptability, and their potential for full




realization.




     It is recommended that language be added requiring that within one




year of designation, each AQM agency submit for the Administrator's




approval a document describing its air quality management planning pro-




cess.  In addition, language should be inserted which briefly specifies




topics to be discussed in this document.  For example, the document




should describe procedures  and assignments of responsibility for




     • the identification and consideration of alternative courses of




       action;




     • identification of social, economic, and environmental effects of




       the alternatives;




     • involvement of, and information exchange with, other agencies,




       the general public, and affected interest groups throughout the




       planning process;




     • coordination of AQM planning with other ongoing planning pro-




       cesses, and resolution of conflicts among programs;
                                  157

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     • monitoring the effects of AQMPs as they are implemented;




     • revising AQMPs to reflect changes in conditions or new infor-




       mation.




The document also should identify:




     • the process of reaching decisions on air quality strategies,




       and the authority and responsibility, if any, which other agen-




       cies or officials can exercise over decisions;




     • sources of funding and other resources for planning and for




       implementation, including any interagency agreements for sharing




       such responsibilities.




More detailed guidelines could be left to administrative regulation.
                                  158

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                       FOOTNOTES - SECTION V^


1.   See Appendix III,

2.   Clean Air Act, 42 U.S.C. 1857 et seq.

3.   Federal Water Pollution Control Act Amendments of 1972, 33 U.S.C.
    1251 et seq.

4.   District of Columbia v. Train, 8 ERC 1289, October 28, 1975.
                                 159

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                      BIBLIOGRAPHY FOR SECTIONS I - VI
                               General
Kulash, Datnian J., "Parking Taxes as Roadway Prices:  A Case Study of
the San Francisco Experience," Working Paper 1212-9, The Urban Insti-
tute, December, 1973.

Alan M. Voorhees & Associates, Inc., "Field Testing of Parking Manage-
ment Guidelines:  Los Angeles, San Francisco, Boston" prepared for U.S.
Environmental Protection Agency, contract #68-02-1388, July, 1975.

Southern California Association of Governments, "Preliminary Thoughts
on Regional Guidelines for Local PMP's," SCAG PMP Working Paper //3,
March 11, 1975.

	, "Questions, Issues and Problems Concerning a PMP," SCAG
PMP Working Paper #2, January 6, 1975.

Manheim, Marvin L. et al , "Transportation Decisionmaking:  A Guide to
Social and Environmental Consideration," National Cooperative Highway
Research Program Report #156, Transportation Research Board, National
Research Council, 1975.

    	, "Community and Environmental Values in Transportation
Planning," Vols. I-VII, Urban Systems Laboratory Report #72-2, Massa-
chusetts Institute of Technology, prepared for State of California
Division of Highways and Federal Highway Administration, U.S. Depart-
ment of Transportation, June, 1972.

Hagevik, George, Daniel R. Mandelker, Richard K. Brail, Air Quality
Management and Land Use Planning:  Legal, Administrative and Methodo-
logical Perspectives,  (New York:  Praeger Publishers), 1974.

"Issues in Statewide Transportation Planning," TRB Special Report #146,
Transportation Research Board, National Research Council, 1974.

"Urban Transportation Planning:  General Information," Federal Highway
Administration, U.S. Department of Transportation, March, 1972.

Atherton, Terry J., William A. Jessiman, John H. Suhrbier and Anne
Marie Zerega, "The Use of Disaggregate Travel Demand Models to Analyze
Carpooling Policy Incentives," Cambridge Systematics, Inc., and Federal
Energy Administration, August, 1975.
                                  160

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Stolwijk, Jan A. J., et al, "Evaluation of the Clean Air Act Amendments
of 1970," study funded by the Chrysler Corporation, June, 1975.

Harbridge House, Inc., "Key Land Use Issues Facing EPA," National Tech-
nical Information Service //PB-235 345, February, 197A.

"Transportation Programming Process," TRB Special Report #157, Trans-
portation Research Board, National Research Council, 1975.

Bennett, Elizabeth, et al, "The Trnasportation Control Planning Process:
Findings and Recommendations for Improved Decision-Making," Phase I
Final Report to the U.S. Environmental Protection Agency, Center for
Transportation Studies, Massachusetts Institute of Technology, March
27, 1975.

Reichart, Barbara K., "Improving Urban Mobility Through Better Trans-
portation Management," Federal Highway Administration, U.S. Department
of Transportation, May, 1975.

Krzyczkowski, Roman, et al, "Joint Strategies for Urban Transportation,
Air Quality and Energy Conservation," INTERPLAN Report 7346 R, prepared
for U.S. Environmental Protection Agency, Federal Energy Administration,
and U.S. Department of Transportation, contract //N00140-74-C-6062,
December, 1974.

National Commission on Urban Problems, Building the American City, Part
III, "Codes and Standards," 1968.

Metropolitan Washington Council of Governments, National Capital Region
Transportation Planning Board, "Parking Management Policies and Auto
Control Zones," Draft final report prepared for U.S. Department of
Transportation, Report //DOT-OS-400045-1, May, 1975.

"Parking as an Alternant to the Traffic Pattern," Highway Research
Record // 474, Highway Research Board, National Research Council, 1973.

Alan M. Voorhees and Associates, Inc., "Estimating the Effectiveness of
Alternative Parking Control Measures in Changing Travel Behavior and
Hydrocarbon Emissions," Technical Memorandum, San Francisco Bay Area
Regional Parking Management Plan Guidelines, November 13, 1975.

"A Proposal for Development of a Parking Management Plan for the City
of Los Angeles, Office of the Mayor, City of Los Angeles, June 4, 1975,

District of Columbia v. Train. 8 ERC 1289, October 28, 1975.
                                  161

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Movement Against Destruction v. Trainor, 7 ERG 1902, March 17, 1975.

Proposal for Analysis of Costs and Administrative Support Essential to
Implement Transportation Controls under the Clean Air Act, submitted to
U.S. Department of Transportation by Cambridge Systematics, Inc.,
RFP DOT-OS-50151, August 4, 1975.

"Air Pollution Controls for Urban Transportation," Highway Research
Record #465, Highway Research Board, National Research Council, 1973.

Meyerson, Martin, and Edward C. Banfield, Politics, Planning and the
Public Interest, (Glencoe, Illinois:  The Free Press), 1955.

"Transportation and Community Values," HRB Special Report #105, Highway
Research Board, National Research Council, 1969.

"Highways and Air Quality," HRB Special Report #141, Highway Research
Borad, National Research Council, 1973.

"Citizen Participation in Transportation Planning," HRB Special Report
#142, Highway Research Board, National Research Council, 1973.

"Multidisciplinary Education in Transportation," TRB Special Report
#150, Transportation Research Board, National Research Council, 1974.

"Intermodal Transportation Planning at the State, Multistate, and
National Scale," Highway Research Record #401, Highway Research Board,
National Research Council, 1972.

"Transportation Systems Planning and Analysis," Highway Research Record
#435, Highway Research Board, National Research Council, 1973.

"Planning and Evaluation of Transportation Systems," Highway Research
Record #348, Highway Research Board, National Research Council, 1971.

"Citizen Participation and Social Indicators," Highway Research Record
#470, Highway Research Board, National Research Council, 1973.

"Federal, State, and Local Roles in Transit Planning," Highway Research
Record #475, Research Board, National Research Council, 1973.

"Organization for Continuing Urban Transportation Planning," HRB
Special Report #139, Highway Research Board, National Research Council,
1972.
                                   162

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Massachusetts Institute of Technology, "Proceedings of a Panel
Discussion on Community Involvement in Highway Planning and Design",
in consultation with U. S. Department of Transportation, Federal
Highway Administration, Office of Environmental Policy, Washington,
D.C., January 26, 1973.

Massachusetts Institute of Technology, "Proceedings of a Panel
Discussion on the Systematic Interdisciplinary Approach in Highway
Planning and Design," in consultation with U. S. Department of
Transportation, Federal Highway Administration, Office of Environmental
Policy, Washington, D.C., March 21, 1973.

Massachusetts Institute of Technology, "Interrelation of Transportation
System and Project Decisions", in consultation with U. S. Department
of Transportation, Federal Highway Administration, Office of Environ-
mental Policy, Washington, D.C., November 1, 1973.

Massachusetts Institute of Technology, "Consideration of Alternatives
in Highway Planning and Design", in consultation with U. S. Department
of Transportation, Federal Highway Administration, Office of Environ-
mental Policy, Washington, D.C., December 4, 1973.
                              163

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                 Legislation, Regulations, Guidelines


Clean Air Act, as amended, 42 U.S.C. 1857 et seq.

Federal-Aid Highway Act of 1970, 23 U.S.C. 101 et seq.

Urban Mass Transportation Act of 1964, as amended, 49 U.S.C. 1601 et seq.

Federal Water Pollution Control Act Amendments of 1972, 33 U.S.C. 1251
et seq.

National Environmental Policy Act of 1969, Public Law 91-190, January 1,
1970.

"Environmental Impact Statements," 23 CFR 771.

"Process Guidelines (for development of Environmental Action Plans),"
23 CFR 795.

"Air Quality Guidelines for Use in Federal-Aid Highway Programs," 23
CFR 770.

"Transportation Improvement Program," 23 CFR 450 and 49 CFR 613.

"Air Quality Control Regions, Criteria, and Control Techniques,"
40 CFR 81.

"National Primary and Secondary Ambient Air Quality Standards," 40 CFR
50.

"Requirements for Preparation, Adoption, and Submittal of Implementation
Plans," 40 CFR 51.

"Approval and Promulgation of Implementation Plans," 40 CFR 52.

"Indefinite Suspension of Parking Management Regulations," Federal
Register, Vol. 40, No. 136, July 15, 1975.

"Maintenance of National Ambient Air Quality Standards:  Requirements
for Preparation, Adoption, and Submittal of Implementation Plans" (Pro-
posed amendments to 40 CFR Part 51), Federal Register, Vol.  49, No.  203,
October 20, 1975.
                                164

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 "Approval and Promulgation of Implementation Plans:  Proposed Amendments
 to Parking Management Regulations" (Proposed amendments to 40 CFR Part
 52), Federal Register, Vol. 39, No. 164, August 22, 1974.

 "Establishment of Intermodal Planning Groups", Department of Transporta-
 tion Order //DOT 1130.1, November 30,  1972.

 "Guidelines for Analysis of Consistency Between Transportation and Air
 Quality Plans and Programs", prepared jointly by Federal Highway
 Administration and Environmental Protection Agency, April,1975.

 "Guidelines for Metropolitan Planning Organizations' Preparation of
 Overall Work Program" prepared by Intermodal Planning Group - Region IX,
 Department of Transportation,  Revised November, 1975.

 "Guidelines for Air Quality Maintenance Planning and Analysis", Volume 1-
12, U. S Environmental Protection Agency, EPA - 450/4-74, August,  1974.

 "Guidelines for Areawide Waste Treatment Management Planning", U.S.
 Environmental Protection Agency, August, 1975.

 Draft Clean Air Act Amendments,  June  26, 1975.

 Clean Air Amendments of 1975,  Staff Working Print  #51,  Senate Public
 Works Committee,  November 5,  1975.

 Clean Air Act Amendments,  Staff  Working Print #31,  Senate Public  Works
 Committee,  August 8, 1975.

 Air  Quality Planning - Proposed  Amendments, Staff Working Print #21,
 Senate Public Works Committee, July 23,  1975.
                                  165

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                         MIT Working Papers
Attanucci, John P., "Analysis of Carpooling Behavior and the Formu-
lation of Carpool Incentive Programs," Master of Science thesis,
Transportation Systems Division, Department of Civil Engineering, M.I.T.,
September, 1974.

Neumann, Lance A., "Integrating Transportation System Planning and
Programming: An Implementation Strategy Approach", Doctoral Thesis,
Transportation Systems Division, Department of Civil Engineering, M.I.T.,
January 6, 1976.

Harvey, Greig W., and Elizabeth Deakin Bennett, "State and Local Roles
in Transportation Control Planning", Center for Transportation Studies,
M.I.T., August, 1975.

Bessey, May, and Ann Rappaport, "Parking Management/TCP Notes from
California Trip, September 17, 1975.

Harvey, Greig, "The Effect of Local Controls on Regional Parking
Management", December, 1975.

Rappaport, Ann, "An Investigation of Areawide Waste Treatment Manage-
ment Planning as a Legislative Model for Transportation Control
Planning", May 15, 1975.

"Transportation Control Plans: The Potential for Improving State and
Local Transportation Decision-Making" prepared by Transportation and
Community Values Project, Urban Systems Laboratory, M.I.T., September
19, 1974.

Rappaport, Ann, Mabelle Bessey, Greig Harvey, Elizabeth Bennett,
"Comments on Proposed Amendments to Clean Air Act", June, 1975.

Bennett, Elizabeth and Greig Harvey, "Proposed Additions to Section 110
of the Clean Air Act" Initial Draft, July, 1975.

Bennett, Elizabeth and Greig Harvey, Discussion Paper for EPA Meeting,
November, 1975.

Bennett, Elizabeth and Greig Harvey, Discussion Paper for FHWA Meeting,
November, 1975.
                                 166

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Bennett, Elizabeth and Greig Harvey, Draft Phase II Final Report,
November, 1975.

Bessey, May, "Guidelines for Improving the Short-Range Transportation
Planning Process" S.M. Thesis in progress.

Rappaport, Ann, "Organizing for Parking Management Planning", S.M.
Thesis in progress.
Rappaport, Ann, "Parking Management: Highlights of the Boston and
Cambridge Experience", December 10, 1975.
Bessey, Mabelle, "What is a Short Range Transportation Option?",
Discussion paper, September, 1975.
                                 167

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APPENDIX I;   THE POLITICAL  CONTEXT OF TRANSPORTATION PLANNING




A.   INTRODUCTION




      The comprehensive  planning approach has been  the  subject of much




criticism over  the  past decade or more.  Much  of this  criticism has




focused  on the  technical analysis tools and methodologies used for de-




veloping alternative  plans,  forecasting traffic and other impacts, and




evaluating plan alternatives.  However, a more fundamental criticism,




and  one  that  in large part  motivates the search for improved methodolo-




gies has been that  the  master plan simply does not reflect how deci-




sions on transportation improvements will actually be  made.  The impli-




cations  of  this criticism go far beyond mere improvements in technical




analysis tools  to the very  nature of the planning process, the defini-




tion of  what  a  plan should  be, and the emphasis placed on technical




versus non-technical  factors.




B.   MANY INTERESTS VS.  THE  "PUBLIC" INTERESTS




      A basic  tenet of comprehensive planning is that there is an identi-




fiable public interest  or set of goals and objectives  for regional or




state transportation  (and land use, etc.).  This public interest is




assumed  to  transcend  the more parochial interests of particular groups




defined  either as other  political jurisdictions (e.g. local governments)




or simply some segment  of the population (e.g. business interest,  transit




users, etc.).




      The reliance on  the concept of a homogeneous and consistent public
                                168

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interest is a critical limitation of the master planning approach.




Ironically, the most substantial support for such an approach came from




reform groups reacting against the piecemeal and partisan land-use




and transportation development policies of big city machine governments




during the 1920's and 30's.   Later, elements of these same groups




turned against the master plans that were adopted because they didn't




reflect the reformer's vision of the public interests.




     From a theoretical point of view, Arrow (1963) demonstrated the




impossibility of developing a social welfare function, or a calculus




for determining the public interest, except under the most stringent




conditions.  Unless all individuals had identical welfare functions or




the same relative preferences for all objectives, the concept was un-




workable.




     From a more pragmatic point of view Altshuler (1965) suggested




that regardless of the existence of a common public interest in theory,




the political implementation of that interest might well be impossible




in any case.  The assumption that common interests were preeminent con-



flicted with the benefits of the established democratic traditions of




placating specific interest groups, majority rule, and interparty con-




flict.  In fact, Downs (1957) had suggested much earlier that survival




at the ballot box rather than pursuit of some common interest was the




most important motivation for politicians and political parties.





1Caro (1974)
                                 169

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Altshuler's case study of planning in Minneapolis confirmed the notion



that the political decision-making process did not operate with a uni-



fied view of the public interest in mind and that an operational defi-



nition of such an interest might be impossible.



     Similarly, Braybrooke and Lindbloom (1970) critique the "rational



model" of decision-making and the use of a social welfare concept for



evaluating policy alternatives as simply beyond the capability of the



political decision-making process.  Most policy decisions are incre-



mental and a key reason is the need to recognize not only multiple



and conflicting values but the fluidity of these values as well.



     A number of studies, which document the organizational and pro-



cedural problems of specific metropolitan comprehensive planning ef-



forts, cite the lack of any real consensus on area wide goals and ob-



jectives as a key frustration of the planners and prime reason that


                                                        2
plans for the most part were adopted and then forgotten.   A more de-



tailed review of the methodologies and technical analysis involved in



several metropolitan planning studies found statements of goals and ob-


                                                  3
jectives were simply too general to be meaningful.   These general



goals led to plan alternatives which were not particularly distinguish-



able given the evaluation criteria and methods employed.



     During the time the usefulness of the master plan concept was being
2See Zettel and Carll (1962) and Levin and Abend (1971).



3See Boyce, Day, and McDonald (1970).
                                 170

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debated and tested, a related debate was occurring in the field of




urban politics.  The issue was not whether there existed a single




public interest transcending all groups, but rather which group's in-




terests were reflected in the complex political decision-making pro-




cess.  In an epic study of Atlanta, Hunter (1953) determined that an




economic elite ruled that city's politics.  In contrast, Dahl (1961),




in a study of New Haven, found the political process to be pluralis-




tic with different interests involved in various public policy issues




with no one group dominating.




     Hunter was criticized for his "reputational" methodology which




seemed to preordain a finding of an elite.  Bachrach and Baratz (1962)




felt Dahl, by focusing on explicit policy decisions, ignored the po-




tential influence of an elite in limiting the political agenda to safe




and acceptable issues.  Though the debate has never been settled con-




clusively, it focused on an issue with great significance for planning.




Whether an elite or a set of pluralistic interests currently has entre




to the decision-making process, it seems clear that different interests




have different objectives in each area of public policy including trans-




portation.  Furthermore, in a democratic system each of these groups




should at least be guaranteed access to the decision-making process.




     Haar (1959) raised the issue of whether a master plan could reflect




effectively many interests particularly in an adversary process such




as litigation on zoning variances.  Davidoff's (1965) call for advocacy
                                 171

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planning recognized planning as merely one technique for persuasion in


an overtly partisan political process.  Later work calling for citizen


participation also sought to safeguard the legitimacy of many points of

     4
view.   These calls for open planning and subsequent Federal laws, plan-


ning regulations, and court rulings reflect to some extent an institu-


tionalizing of a situation already precipitated by grassroots citizen


organizing efforts such as the Boston case.


     Currently, transportation planning recognizes the potential exist-


ence of many interests and their right of access to the decision-making


process.  In fact, Altshuler (1974) in a recent paper, while not re-


treating from his support of participation, argues that the mechanisms


available to citizen groups may have diluted the locus of power to such


an extent that implementing public works, and particularly large capital


projects, is almost impossible.  The smallest minority may thwart, or at


least endlessly delay, a project benefiting a vast majority given the


legal channels available and the legal precedents already established.


     Whether the pendulum has swung too far is not crucial to the dis-


cussion here.  Rather, it must be recognized that many groups with dif-


ferent interests, will continue to be involved in transportation decision-


making in the future.
     Manheim et al. (1971) and Reno (1972).


5See Lupo,Colcord, and Fowler (1971).
                                 172

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C.  INSTITUTIONAL STRUCTURE:  FRAGMENTED ROLES AND PAROCHIAL INTERESTS




     The previous section described a major flaw of the master planning




approach as the implicit assumption that the decision-making process




would focus on one public interest rather than many conflicting inter-




ests.  Part of the reason for this misconception and another problem




with many planning efforts at both the local and metropolitan scale is




the position of the agencies conducting those studies within the for-




mal institutional structure for transportation decision-making.




     Metropolitan transportation studies generally are conducted under




the aegis of voluntary Councils of Governments or metropolitan com-




missions without implementation powers or real authority over local




governments or implementing agencies.   Similarly, at the local level,




the planning commission, without a direct tie to the executive branch,




is a major source of impotence of the city master plan.




     Thus the formal structure of institutions involved in the transpor-




tation decision-making process is a key determinant in the actual imple-




mentation of any plan.  Institutional structure affects both the distri-




bution of formal authority as well as the channels of communication




through which that authority is exercised.  However, since institutional




arrangements are but one of many factors affecting the nature of the




decision-making process, different institutional arrangements may be
6See Levin and Abend (1971) and Colcord (1971).




7See Altshuler (1965).
                                 173

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 required in different metropolitan areas for accomplishing the same
         Q
 purpose.   Similarly, effective planning at the local level may occur
                                               9
 under both reform and machine style government.

      In general, the existing institutional arrangements for trans-

 portation decision-making at the regional and metropolitan level can

 be characterized as extremely fragmented.  Different levels of govern-

 ment (local, metropolitan, state, and Federal) are involved, or in-

 volved in different ways, in the planning, implementation, and operation

 of the various modes.  While institutional structures vary from state to

 state and region to region a few generalizations are possible.

 Traditionally, multi-modal planning has been an activity carried out at

 the metropolitan level though increasingly both states and the Federal

 government have become more involved.  Major highway planning and con-

 struction has been primarily a state function.  In contrast, transit

 planning, implementation, and operation has been a responsibility of

 local government or metropolitan authorities.  In addition, many ports

 and airports are planned and operated by quasi-public authorities with
 8A study by Colcord (1972) of different regions in California suggested
  different institutional arrangements were required in each.

 ^See Rabinovitz (1967) and Linasberry and Sharkansky (1971).

l0Chapter 6 of the Neumann thesis describes in detail the institutional
  arrangements for transportation in the San Francisco Bay Area.
                                 174

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bonding power and considerable insulation from public opinion.




     While the authority for planning and implementing highways and




transit (in terms of project approval powers) is slowly being shifted




to the metropolitan level, many institutional actors remain active in




the decision making process.  The effect of this fragmentation is to




add another level of complexity to the implementation process.   The




previous section suggested that many groups have vested and .often con-




flicting interests in transportation decisions.  Added to these groups




must be the multitude of agencies at all levels of government involved




in transportation.




     Increasing attention is being given to the role of public bureau-




cracies and the often parochial interests they represent in the de-




cision-making process.  Both Blau (1957) and Downs (1967) focus in




detail on the internal forces and interests shaping the behavior of




bureaucracies.  While to some extent outside forces can influence such




organizations, their size, operating procedures, and longevity repre-




sent significant constraints to any change in policy.  Rather than




viewing "red tape" as a necessary inefficiency of bureaucratic opera-




tions, such procedures and bureaucratic behavior in general can be




seen as carefully tailored mechanisms for achieving specific organiza-




tional goals.  In many cases these goals may be quite distinct from




the original rationale and purpose for which the specific bureaucracy




was created.  Schon (1971) draws a similar conclusion and laments the
                                 175

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inability of current organizational structures to respond dynamically




to new problems.




     Both Allison (.1971) for international policy, and Dye (1972) for




domestic policy, develop "models" explaining policy development and im-




plementation as largely the output of various organizational actors.




Each organization possesses a set of parochial interests and perceptions




and standard operating procedures which limit the range of policy out-




comes .




     In short, given the multitude of agencies at all levels of govern-




ment involved in transportation, it is important to recognize each of




these organizations as distinct actors in the decision-making process,




each with a set of  interests which may be quite different from their




official function.  While current Federal planning regulations are fo-




cusing on the programming and budgeting process as a key lever for




agency coordination, there is a limit to the cooperation that can be




expected.  As Pressman and Wildavsky (1973) note, if a common interest




and ignorance are present, coordination merely requires pointing out a




reasonable joint action.  Rowever, if conflicting interests are present,




coordination is synonymous with coercion and a play of power and bar-




gaining will result.
                                 176

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U.  THE DYNAMICS OF DECISION-MAKING:  A REVIEW OF THE IMPLEMENTATION




    PROCESS




     In addition to ignoring the complexity of the interests, including




the institutional interests, involved in transportation decision-making,




the  master plan approach reflects a very simplistic view of the dyna-




mics of the decision process itself.  The master plan implies that the




decision process is capable of, and willing to make a one shot choice




on a comprehensive development plan for a twenty year period.  In fact,




approval of a master plan is but the first preliminary decision, and




often not a very significant one, in what is a time consuming, complex,




and incremental implementation process.




     Recognizing the need for policy analysts to pay more attention




to the implementation process, Allison (1971) estimated that only 10%




of the work of achieving a desired governmental action is done when the




preferred analytic solution has been identified.  Increasingly the com-




plexity of successful implementation is being viewed as a key area for




research with implications for both the type of programs that are de-




sirable as well as how to accomplish them.




     A case study of several Economic Development Administration pro-




jects in Oakland discovered that even the implementation of projects




with a very high degree of initial acceptance can be frustrated.
  See Pressman and Wildavsky (1973).
                                177

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What EDA staff hoped would be merely details of the Implementation pro-



cess, in the end turned out to be key determinants in both the ultimate



design of the projects and their implementation prospects.  Among the



problems encountered were multiple clearance points, changing actors,



dissolution of initial agreements, and the inability to move fast


enough to take advantage of agreements while they lasted.  The need



for joint action among agencies with different priorities and perspec-



tives produced endless procedural and legal problems.  Inflation,



changes in Federal and city administrations, and the steady erosion of



the sense of urgency which launched the projects initially further



compounded the delays.  In the end only a fraction of the initial pro-



gram was implemented.



     The woes of trying to implement a proposed policy or project are



familiar to both practicing planners and operating agency personnel.



However, to a large extent the problem has been assumed to be poor im-



plementation efforts.  Thus in response to ever increasing delays in



highway construction the California Division of Highways commissioned a


study to shorten project lead times.  However, the failure to implement



a project may reflect either poor implementation efforts or an ill-con-


                                  13
ceived or a too ambitious project.
12Safdie (1970) chronicles similar frustrations in trying to implement

  an innovative modular construction system for urban housing.



13Pressman and Wildavsky (1973) conclude that the Oakland project was in

  fact too ambitious given the maze of actors involved and time con-

  straints.
                                  178

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Reflecting the dynamics of the implementation process in both the de-



sign of policies or plans and the manner in which they are carried out



is extremely important in the transportation field.  In almost every



case transportation plans and projects face multiple decision points



and long lead times.  While this is especially true for capital pro-



jects, it holds for policy and operational changes as well.



     In particular, a comprehensive twenty year master plan faces In-



numerable decision milestones.  The implementation of any element of



such a plan is hardly guaranteed by anything so illusory as approval of



a plan.  In fact, successful implementation depends on each project or



plan element proceeding through a long series of decision hurdles and



often within a specific time frame.



     A particularly important decision point is the allocation of funds



in the budgeting process.  However, the budgetary process for public


                                                             14
bureaucracies is extremely incremental and non-comprehensive.    Given



the complexity of the budget, many items are accepted with little analy-



sis and few alternatives are considered.  The negotiating process is



generally only concerned with allocations and impacts occurring within



the next one to two years.  While the PPB system provides a framework



for increasing the time frame of budgetary decisions, it provides little



guarantee that budget decisions are consistent with longer range
  See Downs  (1967) and Linesberry and Sharkansky (1971) .
                                 179

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         15
programs.



     Of particular importance in the budget process is the previous



year's budget.  An agency's budget represents how the bureaucracy be-



haved and is an enormous capital investment in time, energy, and manpow-



er.  The major portion of.any budget represents the results of previous



negotiations and tolerable status quo if not 100% agreement.  Thus cur-



rent budget negotiations focus on incremental changes to previous allo-



cations or completely new allocations and generally do not risk re-



opening questions on a majority of items.



     Thus, as Federal regulations are beginning to reflect, the budget,



rather than a long range plan, is the key driving force and focus of



negotiation for the decision-making process.  While there are many other



important decision points such as environmental clearances, the budget



process offers an ongoing pressure point for redirecting the overall



program of an agency and is the best indicator of a change in direction.
l5See Novick (1967).
                                 180

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E.  SUMMARY




     Originally, planning, and particularly production of a master




plan, was viewed as the first and a quite necessary step in a rational




decision-making process.  The basic argument supporting this view is




that if there is no long range goal or end state toward which to direct




current decisions a very piecemeal and myopic transportation system or




development pattern will result.




     However, the master plan approach implicitly assumes a decision-




making process that in general doesn't exist for transportation.




Rather than being strictly "rational," the process involves many con-




flicting interests, including institutional actors at different levels




of government.  Rather than focusing on master plans, decisions tend




to be incremental and focus on budget negotiations and the stream of




other implementation decision points that each plan element or project




must face.
                                 181

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APPENDIX  II.  A REVIEW OF EXISTING PLANNING AND PROGRAMMING PRACTICE




A.   INTRODUCTION




     There has been an increasing awareness on the part of many planning




agencies  about the nature of the decision-making process and the need




to develop plans which are more responsive to that decision-making en-




vironment.  Similarly, the nature of the transport system and its impacts




and  interaction with other activity systems is better understood and




stimulating a search for improved planning methodologies.  As a result,




significant changes in the nature of the planning process are occuring




in many states and metropolitan areas.




     For  many years, states approached the issues and problems facing




them with a sequential view of planning.  System studies identified




areawide  financial constraints and corridor specific networks and the




development of specific programs followed.  Finally, particular project




studies successively took each corridor study through location and de-




sign phases to right-of-way acquisition and finally construction.




     The  sequential view has its roots in the era when states were pri-




marily concerned with highway captial improvements which had a rela-




tively stable and dedicated funding source.  Perhaps more than anything




the  1973  Highway Act indicates how much the "ballgame" has changed.




The Act provides increasing flexibility to shift funds between highway




and transit,  and,  for the first time at the Federal level, separates a




state's allocation for a portion of the fund in urban areas from par-
                                 182

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Licuiar projects.  As a result, states can begin to be less concerned




with getting specific projects through the "pipeline" and focus more on




the effective management of a cash flow and on providing transportation




as a "service."




     Similarly, the creation of state departments of transportation is




resulting in more active state involvement in modes previously the re-




sponsibility of local governments, regional authorities, or the private




sector. On  the  other hand, in response to the need for both more effective




participation by a diverse group of interests and coordination among




modes and functions (e.g. planning, implementation and operation)  many




states are assigning more responsibility to regional planning agencies




in the development of overall statewide plans and policy.  The response




has varied from state to state, and even within a state.  The balance




that evolves between a "top down" and a "bottoms up" approach will de-




pend on the specific capabilities and interests of each state at the




regional and state levels.




     A number of additional changes to the planning process have occurred




in response to both state and Federal environmental policy.  State and




metropolitan transportation planning agencies must monitor the consis-




tency of programs and projects with respect to such issues as open




space, air quality, noise regulations, and civil rights.  In addition,




states preparing plans are in many cases producing environmental impact




reports for the entire plan.  Other state agencies having state environ-
                                  183

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mental, economic and agricultural responsibilities have an increasing




concern for transportation policy and how it supports or disrupts their




own program.
                                 184

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B.   OVERVIEW OF THE PLANNING AND PROGRAMMING PROCESS

     A complete description of the transportation planning process in a

particular state or region involves a complex set of factors from or-

ganizational and legal structures to specific technical activities and

procedures.  Such descriptions are provided in a number of sources for

different states and regions.   The focus here is on describing the

general activities involved in planning and implementing transportation

improvements.  The current scope of these activities in most state and

metropolitan transportation planning agencies remains a major barrier

to improving the effectiveness of transportation plans in addressing

the issues raised in the previous chapter.

     Figure 1 displays the major activities to be discussed here.  The

specific activities shown, such as system planning, program development,

project planning, etc., are most frequently discussed for major capital

improvements.  However, the more general activities of planning, pro-

gramming, implementation and operation occur for non-capital options as

well.

     Financial planning includes the forecasting of revenues, often for

both the short and long run and the analysis of alternative revenue

sources such as bonding, user taxes, or general funds.  A key issue is

the distribution of costs that a particular revenue source places on
 	 Mead  (1973), Krejci (1973), and Neumann (1972) for more detailed
 description of the overall planning process in California, Massachu-
 setts and Georgia.
                                   185

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    Figure   1  Major Activities in Transportation Planning
 Financial
 Planning
             System and Policy
             Planning
^^^ ^^^K ^^A ^^K ^A flte
Program
Development and
Evaluation
              Scheduling
                 and
              Budgeting
                                I	1
                     Pre-Implementation
                     or Project Planning
   Operation and
   Maintenance of the
   Existing System

Planning
                                                      Programming
                                                     Implementation
                                     Operation
                           186

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users and  non-users or different income groups.  Naturally in many cases




funding sources are severely constrained and any change may require




new legislation.  In addition, financial planning is concerned with the




allocation method by which funds are distributed to various jurisdic-




tions, modes, functional systems or functional uses (e.g. interstate vs.




primary, capital vs. operating, etc.).




     System and policy planning includes the generation of potential




capital, operating, maintenance and policy changes and an analysis of




the potential impacts of such changes.  While there are many sources




for proposed improvements, master planning, needs studies, and suffi-




ciency inventories are the most widely used approaches for generating




capital projects.  Generally less formalized and more "ad hoc" proce-




dures are used to generate short  range non-capital options.  Currently




concern for energy conservation and air quality regulations are the




prime stimuli in the search for non-capital projects.




     Programming takes the output of the financial and system planning




activities and produces a tentative sequence for implementing those op-




tions identified and approved in the planning phase.  Given the long




lead times and many pre-construction development phases for capital




projects, a set of well-defined procedures have been developed for




capital investment programming.  These procedures include priority




setting and scheduling.  However, the matching of resources for imple-




mentation and a proposed schedule of implementation occurs for all op-
                                  187

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tions even though formal documentation of a program of policy and oper-




ating changes often has not been developed.  Naturally programming




whether formal or not must reflect the myriad political, legal and




financial constraints that exist for different types of improvement




options.




     Scheduling and budgeting are essentially refinements to the pro-




gramming activity for the near-term portion (one to two years) of a




program.  For capital projects, scheduling accounts for detailed man-




power assignments and adjustments to the sequence of projects due to




unforeseen delays and fund shifts, etc.  Similarly, budgeting produces




a one to two year detailed account of expenditures using up to date and




short range revenue estimates not required to scope out an initial pro-




gram.




     Pre-implementation and project planning include those activities or




development phases necessary to prepare an option for actual implemen-




tation.  For capital projects, there is a well defined set of development




phases including location and environmental impact studies, design,




right-of-way acquisition and construction.  Again, however, non-capital




projects generally face a similar though less well defined and repeti-




tive set of development phases.  For example, policy changes may re-




quire drafting and lobbying for legislation, a public referendum, or




small scale demonstration applications, etc.




     Operation and maintenance involves repairing and operating the
                                  188

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 existing transportation system and may be the activity most affected by

 policy and non-capital improvements.

      Naturally,  each of the activities described above may involve

 agencies and actors at many levels of  government.   Also,  as mentioned

 previously, there is a tendency to treat  the activities as strictly

 sequential, while actually  they often  occur  in parallel or iteratively.

 Figure 2 is intended to represent  the dynamic nature of these activities

 in most states,  with information flowing  between various  levels  of gov-

 ernment.   While  the diagram is typical of a  state  such as California

 or Connecticut,  which place strong emphasis  on regional plans and  pro-

 grams,  it clearly over-simplifies  the  process.   The levels of interac-

 tion,  amount of  information and degree of regional-state  responsibili-
                                    2
 ties will vary by state and region.

     As the figure shows, a similar set of activities  occur  at the

 state and regional levels with periodic interaction between  levels.

 Typically,  both  state and regional plan alternatives are  developed.   In

 California,  state  plan  alternatives were  not prepared  until  there was

 substantial  progress on  the preparation of regional plans.   Conflicts

 between state and  regional objectives were resolved by negotiation,

 identified as an issue  to be resolved in  future plan updates, or sub-

mitted  to  the State Transportation Board  for final resolution.
 2^                   —
 A more detailed description of process dynamics among state and re-
 gional levels can be found in Neumann  (1972) for California and in
 Krejci  (1973) for Massachusetts.
3
 This latter mechanism was avoided during  the first  cycle  of plan devel-
 opment in California.
                                  189

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    Figure   2  Interaction of State and Regional Levels  in Transportation Planning
State Level
           -State Issues
           -System and Policy
              Studies
           -Plan Review
Regional Level
           -Regional Issues
           -System and Policy
              Studies
           -Plan Oevel ..Review
-Program Funding
   Guidelines

-Projects of State
   Interest
 -Regional Program
   Development
   -Priorities
   -Schedules
- State Program

    Development
- Budget Guidelines
Regional Budget

Preparation
                                                                        i
                                                                Operations and
                                                                Maintenance
                                           Pre- Implementation
                                                 and
                                           Project Planning
                   •>> Time

-------
     Once plan alternatives are adopted program funding guidelines are




produced at the state level for each region and used as budget con-




straints to develop regional programs.  In California, for the highway




mode, the regional plan alternative (a target system statement of facil-




ity needs) partially determines the level of funds each region receives.




Regional programs must reflect local priorities and lead time con-




straints as well as fund guidelines.




     A statewide program must reflect up to the date fund information




including the current status of Federal reimbursements.  Thus, pre-




paring the state program generally involves adjusting regional pro-




grams to insure inter-regional consistency and reflect current fund




estimates and state priorities.  State budget guidelines provide each




region with a detailed 1-2year fund estimate and regional programs are




adjusted prior to funding specific project studies or operating and




maintenance activities.




     Over the past few years a number of significant changes have oc-




curred in the overall planning process and specifically the system




planning, programming, and project or pre-implementation planning activ-




ities.  First public participation has increased dramatically parti-




cularly during project planning but also during system planning and




increasingly due to recent Federal regulations in programming as well.




The attention being given environmental and social concerns has also




increased.  Due to NEPA, specific project studies have been the focus
                                 191

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of initial efforts at detailed environmental analyses but increasingly

state and regional system plans are also reflecting these impacts.

     Due largely to Federal funding practices and the integration of

UMTA and FHWA planning regulations, coordination of planning and pro-

gramming activities for each mode is increasing among state, regional,

and local levels of government.  Also, due primarily to the Clean Air

Act provisions the consideration of non-capital and short range options

is beginning to be coordinated with longer range and predominantly

capital system plans.

     Finally, within modes, better integration among system and project

planning is also beginning to occur.  For transit the primary impetus

is UMTA capital grant criteria which stress analysis of a project as a

stand alone incremental improvement as well as a portion of some longer

range plan.  For highways court rulings have rejected the practice of

segmentation (e.g. construction of major improvements in a long series

of staged segments) without an assessment of environmental impacts of
                                                           4
both the segment and the more major long range improvement.

     All of these changes represent significant improvements and in-

crease the potential for planning to be responsive to the decision-
 U.S. Rt. 7 in Connecticut, Massachusetts and Vermont has been the sub-
 ject of a "segmenting" ruling and more recently 1-93 in New Hampshire
 has been similarly affected.
                                  192

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making environment.  However, to a large extent these changes still




represent untapped potential.  In particular the process, the procedures,




and a style of planning which would allow both a focus on short range




programs, budget decisions, and non-capital options and also the longer




range implications of these choices have not evolved.  System studies




still are dominated by a master philosophy.  Regulations focusing on




short range programs and project increments provide no real mechanism




to tie these choices to long range planning and a sequential view of




these activities remain.




     Part of the problem is a reluctance to view the entire range of




planning activities in Figure 1 as a very dynamic and iterative set of




tasks.  The illusion of stability provided by a comprehensive long range




plan is very seductive.  However, plan-making alone does not begin to




characterize a state or region's range of involvement in transportation.




In fact, plan-making only can serve to punctuate a complex iterative,




and incremental implementation process and is but one mechanism for pro-




viding coordination among a diverse set of state, regional and local




actors.
                                  193

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C.  OVERVIEW OF CURRENT PLANNING AND PROGRAMMING PROCEDURES




     The previous section described the key activities involved in the




planning process and the interrelationships among them.  The purpose of




this section is to examine the proceudres used in a number of these




activities to address the technical issues (e.g. budget constraint,




impact dependencies, etc.).  In particular, the procedures used in sys-




tem planning and programming are of interest since the other activities




(with the exception of capital project planning) are less formalized




and represent less of a constraint to new planning approaches.




     In theory as Pecknold (1970) notes it is possible to describe an




analysis framework which addresses all of the relevant technical issues




in terms of the general sequential decision model.  However, in practice,




it is simply impossible to identify a consistent set of operational




models or procedures which can address all these issues simultaneously




for anything but the most trivial problems.  Thus it is not surprising




that existing procedures focus on only one, or some subset, of the




technical issues of concern.  However, the manner in which these issues




are fragmented by current system planning and programming methodologies




represents a constraint to realizing the potential improvements em-




bodied in current Federal planning regulations.






1.  System Planning




     Traditionally,system planning has involved long range capital
                                 194

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 facility planning.   More  recently,  short-range and  non-captial  options

 have received increasing  attention  due both  to methodological advances

 in demand forecasting and the  emerging policy issues  dealing with  energy

 and air quality.   Since a number  of extensive reviews of  current metho-

 dology are available, the discussion here  only briefly surveys  the more

 widely used approaches for plan development, network  analysis,  and plan

 evaluation.

      The most popular techniques  for plan  development  during the  1960's

 were the "plan-form" approach  (e.g.  linear-city, satellite city, etc.)

 and the use of transportation  and land use models to  generate land-use

 patterns given transportation  policies or  vice versa.   These techniques

 were found to be too aggregate to deal with many policy issues  and

 often were insensitive to  the  issues  they  explicitly  tested.  Thus many

 different  network configurations could serve the same basic land-use

 pattern.   While part of the problem was lack of good  evaluation methods,

 the  differences hypothesized for different master plans were overstated.

Despite  this shortcoming some  recent metropolitan studies have  employed
 More detailed surveys can be found in Pecknold (1974) and NCHRP "Syn-
 thesis of Highway Practice #14" (1972).
6See Boyce et al. (1970).
                                 195

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similar techniques.

     Other techniques used to generate long range plans or to update al-

ready adopted master plans are needs and sufficiency studies.  These

techniques are widely used at the state level for the highway mode

and need studies have been conducted at the Federal level for all modes.

Sufficiency studies are inventories of current structural, capacity,

and safety deficiencies on the road system and require a set of stan-

dards for measuring these factors.  Need studies are similar and based

on prescribed levels of service.  Where service levels are not met

there is a deficiency and the improvement needed to restore or maintain

the service levels is identified.  Need studies and to a lesser degree

sufficiency studies suffer a number of major weaknesses.  By assuming

service levels, needs studies inhibit the examination of environmental

and social impacts and treat all user groups equally.  In fact, needs

are relative, not absolute, and vary significantly for different groups.

By assuming standard solutions where deficiencies exist, need studies

result in capital intensive plans and inhibit the search for alterna-

tives.  Finally, by treating projects independently need studies assume

unlimited resources are available.

     A recent proposed approach provides a mechanism for introducing

the budget constraint in developing and evaluating multi-modal target
 For example, in California, San Diego has adopted what is essentially
 a land-use and transportation master plan using the PLUM land-use model
                                  196

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           Q
year plans.   In a recent application of economic analysis techniques,

California "down scoped" the traditional needs study for highways to ob-
                                           9
tain a somewhat more realistic master plan.   However, whether or not

the resource constraint is explicitly considered, most state and region-

al plan development efforts still reflect the master plan philosophy.

     Due to the complexity of the technical issues discussed and the

lack of suitable methodology, most long range planning impact analysis

has focused on ne twork analysis.  Implicit in this approach is the as-

sumption that network dependencies are very important and affect both

network configuration and link or project design.  Traditional approach-

es also imply that these effects can be considered in a one shot manner

for a target system.  Thus timing dependencies, due to budget con-

straints and uncertainty are assumed to be negligible relative to net-

work effects or are assumed likely to affect only the sequence of imple-

mentation (e.g. a programming issue) and not the target system itself.

     The traditional methodology for network analysis has been widely

criticized for internal inconsistencies, lack of policy sensitive varia-

bles, cost, and data requirements, etc.    No elaboration of these
Q
 See Creighton, Hamburg, Inc. (1972).

9See McKinsey and Co. (1974).

 Critiques of transportation models can be found in Roberts (1970),
 Manheim (1973) and good summary Is in Pecknold (1974).  The weaknesses
 of the land-use and transportation models are discussed by Lee (1973)
 and Boyce et al. (1970).
                                 197

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critiques is required here other than to repeat that such techniques

emphasize network dependencies at some target year while ignoring the

other technical issues.  Recent efforts  to streamline the use of large

network analysis techniques have focused on the development of "sketch

planning" tools.  Such techniques offer a more flexible and less costly

(both in time and data) approach to network analysis.    However, the

techniques used in most states still are the more cumbersome large scale

network models.  In a few states these aggregate models are being coupled
                                                  12
with models to predict other flow related impacts.

     More promising at least for the trip generation, distribution and

mode split portions of network analysis, are disaggregate techniques.

Results from the application of these models have been reported widely
                                               13
and are beginning to be used in actual studies.    Disaggregate tech-

niques offer a more behavioral and policy sensitive analysis tool while

at the same time reducing cost and data requirements.  The emergence of

of this approach has coincided with an increased emphasis on short range,

non-capital options due to air quality and energy considerations.  Dis-
  Sketch planning techniques are discussed extensively by Mergel (1974)
  and Landau (1975).

12
  Wachs (1972) recommends a concentration on local link analysis, acces-
  sibility parameters, and disaggregate equity considerations.

13
  Fecknold (1974) surveys the current status of the disaggregate ap-
  proach.  A key issue in using such techniques for prediction is the
  consistent aggregation of the disaggregate results; see Koppelman
  (1975).
                                 198

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aggregate models offer a great potential for introducing short range

options into system planning studies.  In addition, recent work suggests

a disaggregate approach can also be applied to longer range mobility

choices involving residential location, household type, mode choice to

                         14
work, and auto ownership.

     Where other impacts, and particularly land use, environmental and

social effects have been examined in system studies, they have been

analyzed in a one shot manner for different target systems.    Thus it

is not surprising that formal plan evaluation approaches have empha-

sized aggregate criteria and have not been particularly successful.  In

many cases, little formal evaluation at all has occurred during many

system studies.


2.  Programming

     Similar to system planning, only some subset of the technical issues

have traditionally been addressed in programming.  The major issue ad-

dressed is the budget constraint, though often projects have been
14See Lerman (1975).

  As Pecknold (1974) discussed the relationship of transportation to
  many of these impacts is still not well understood and good analysis
  tools for long range system effects are not available.  Schiff (1973)
  surveys impact techniques.

  See both Boyce et al.  (1970) for an overall review and Barton
  Aschman (1972) for a critique of specific evaluation methodologies
  considered for recent regional planning efforts in California and
  elsewhere.
                                  199

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  scheduled in a myopic  fasion.   Sometimes  timing  effects,  impact  de-



  pendencies,  uncertainty  and  a  broader  range  of priority criteria have

                                                                    i

  also been considered;  but  generally programming  has  been  viewed  as



  merely  the somewhat  mechanical process  for implementing a long range



  master  plan.



       Traditionally,  there  have been two basically  different approaches



  to  highway programming  until  recent  Federal regulations required  a  mini-



  mum of  a  3-5  year program  for  metropolitan areas  (it can  have a  longer



  time frame).   The first  approach, popular in many  predominantly  rural



  states, though also  characteristic  of some urban states such as Massa-



  chusetts,  involves informal  negotiations over project priorities and



  schedules  utilizing  few  if any systematic analysis procedures.   Such



  an  approach obviously  can account for subjective factors  and political



  differences.    However, it can  also  degenerate to simply a "pork barrel"



  operation with no systematic method of addressing budget  or impact de-



 pendencies, or using explicit priority criteria.   It  is also impos-



 sible for anyone not privy to negotiations to know what factors have



 been considered and  thus  can frustrate attempts  at broad based parti-



 cipation in what are key  policy and  project  decisions.



      The second approach  relies on explicit priority  criteria  along
                                                      i


with some mix  of  formal or  informal  procedures for  developing project



schedules in light of these priorities and other factors.  Most states



are  currently utilizing some priority criteria for highways,  though
                                  200

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other modes still tend to be handled in a more informal fashion.  In




1973, reacting against the political nature of the state's highway pro-




gramming process, the Arizona legislature established a highway priority




commission charged with developing a formula for highway priorities.




While few states have gone to this extreme, most have adopted similar




approaches.




     The following discussion of programming techniques only applies to




states which have explicit and well defined programming approaches.  In




addition, the techniques deal only with capital projects, since for the




most part the programming of other improvements is less formalized.




     The most popular approach to programming currently is the use of




some set of priority indices based on user benefit, structural, safety




and other factors to rank projects within each funding category.  In




some cases overall "scores" are calculated as in Arizona, Tennessee,




and Wisconsin.  In California, separate indices are not combined.  Also,




some states such as Arizona combine technical and non-technical factors




while California updates technical priority lists in a more subjective




manner.




     While the individual priority measures can often be useful, the




practice of computing overall scores conceals more than it illuminates




and has been widely discredited.    Unfortunately, new and ever more
l7See Manheim  (1975) and Cohen  (1976).
                                  201

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 elaborate  priority scoring  techniques continue to be pttfposed as "ob-

                                1 8
 jective" scheduling procedures.     In addition, some of these procedures


                                                               19
 include a  measure of community  preference  in the score as well.



     More  recently, a number of states have applied benefit cost analy-



 sis  to highway capital programs.  Utilizing such a technique, California



 has"down .scoped" district programs  to reflect lower revenue projections


                             20
 and  increasing project costs.    Similarly, Massachusetts and Michigan



 have operational benefit-cost and capital  budgeting packages which can


                                  21
 be utilized for project selection.    While restricting attention to



 traditional user benefits,  such techniques offer one method for dealing



 with multiple funding constraints, multiple time periods, and multiple



 project design scales (e.g. mutually exclusive project alternatives).



     Though capital budgeting techniques must rely on extensive project



 data bases, many states collect much of the required data as part of the



 National Transportation Study.  Currently, FHWA is in the final stages



 of developing an investment analysis and programming package using needs
18See General Analytics and Comsis (1973) and Mak (1973).



19Again see Mak (1973).

on
  See McKinsey and Co. (1972).



21See Juster (1974).
                                 202

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                                                           22
study data and aimed at application at the statewide level.    In



addition, a recent study done for NCHRP represented a preliminary at-



tempt to define benefit-cost criteria appropriate for multi-modal



economic evaluation.



     A class of techniques which have proved extremely useful for pro-



gram development are computer based information systems.  Such systems



allow quick response to a variety of issues and can provide summaries



(cost, phase of development, etc.) of the projects in different geo-



graphic areas, funding categories and functional systems.  The finan-



cial effects of program additions and deletions can be readily moni-



tored and produced in formats appropriate to meet a variety of periodic



state and Federal reporting requirements.  The sophistication and capa-



bilities of such systems vary greatly.  For example, Massachusetts is



utilizing a relatively simple and inexpensive system to monitor "active"



projects and provide lists of projects by functional system, jurisdic-



tion, phase of project development, etc.  California utilizes a system



with video consoles which allow the user an interactive capability of



adjusting project schedules, budgets and displaying the effect on county



and district programs.  Other approaches are geared toward more detailed



project scheduling and manpower assignments.
22
  The FHWA methodology is known as the Highway User Investment system

  (1975)



23See Creighton-Haraburg (1972).
                                  203

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     In a period where program development and review is being empha-




sized as a mechanism for coordination among modes, levels of govern-




ment, and short and longer range plans, expansion of project informa-




tion systems .can be instrumental in providing information to a complex




negotiating process.  Such systems can support a very flexible schedul-




ing process without relying on economic efficiency or other simplistic




criteria to generate initial programs.
                                  204

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D.  A COMPARISON OF PLANNING AND PROGRAMMING IN CALIFORNIA AND

    MASSACHUSETTS

     The review of current planning and programming practice in the

previous sections recognized that significant variations exist in both

the planning process and the procedures used from state to state.  In

many cases, these variations imply that different changes are required

to Improve system planning and programming in different states.  In

other cases, the basic change may be the same but the tactics for im-
                                                    24
plementing that change may vary' from state to state.    To identify some

of the key differences among states the current practice in two basical-
                                                                       25
ly different states, California and Massachusetts, are summarized here.

     In recent years, both California and Massachusetts have increased

the role of regional planning agencies (RPA's) in the transportation

planning process.  While current Federal regulations are making a shift

of some authority to regional agencies mandatory, both states already

had taken steps in this direction.   Beyond this increase in the role for
f\ t
  It is also recognized that significant variations can occur from re-
  gion to region within a state.  However, such variations are not dis-
  cussed here.  See Colcord (1972) for a review of regional differences
  in transportation decision-making in California.

25
 A more detailed description of the California planning process as it
  relates to the San Francisco area is contained in Neumann (1976).
                                  205

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regional agencies, there are few similarities between current planning
                           p£
practice in the two states.

     The sy_stem_ planning process in California is very decentralized

with major differences occurring in the political culture of the state's

diverse metropolitan areas.  No one region dominates the state and most

of the substantive planning work for all modes occurs in the eleven

California Department of Transportation (Caltrans) district offices,

regional planning agencies, or special regional authorities for transit,

ports, and airports.  The civil service at all levels of government in

California is very professional and of high calibre.

     In contrast, Massachusetts is dominated by the Boston area with

planning for that region, and throughout the state, centralized at the

state level.  State agencies have a controlling vote on the committee

overseeing  the designated metropolitan planning staff.  However, Massa-

chusetts does not have a state department of transportation comparable

to Caltrans and institutional relationships are extremely fragmented.

The civil service system is a. haven for political outcasts and much of

the substantive planning work is contracted to consultants.

     The dynamics of the planning process in California are punctuated
  It should be mentioned that California has significantly increased
  the authority of RPA's in large part due to the political power of
  local cities and counties.  Massachusetts, on the other hand, has
  only granted RPA's some additional review powers.  In California cit-
  ies and counties have a veto power over major highway improvements
  while no comparable authority at the local level exists in Massachu-
  setts.
                                 206

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by a number of well defined decision points or documentation require-




ments.  For highways, a statewide needs study is conducted every four




years along with a report recommending revisions to the state highway




system (256 Report).  In addition, multi-modal plans for the entire state




and for each of the 41 regions are to be submitted to the legislature in




January, 1976.  These plans are to be reviewed and updated biennially.




     Again in contrast, system planning in Massachusetts has no well




defined cycle of activities and is largely undocumented.  Project lists




are submitted periodically by each Department of Public Works district




when "jobs" are needed.  These lists are not released to thepublic and




nothing like the California needs study or the state and regional plans




are an integral part of planning in Massachusetts.  The most recent




and well publicized planning exercise in the state, the Boston Transpor-




tation Planning Review (BTPR) , did represent something of a "watershed"




in Massachusetts planning.  However, while the BTPR has led to some new




ongoing planning activities, it was largely a "one-shot" effort from




which a number of specific facility planning studies have spun off.




     In terms of funding structure, both states have dedicated highway




funds.  California diverts half of these funds directly to cities and




counties and both local and state road improvements are financed on a




"pay as you go" basis.  In Massachusetts, a much smaller percentage of




funds are reserved for local improvements and the state retains some




discretion in their use.  Major highway construction is financed by
                                  207

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bond issues every 2 or 3 years and some fuel taxes support state de-



partments with no direct connection to transportation.



     Both states provide support to transit; California by a fuel sales



tax and diverting fuel taxes from highways and Massachusetts used gen-



eral funds to pay half the deficit of the metropolitan Boston transit



system.



     The most important difference in funding structure between the two



states is the method used for the jtllocationL_p_f funds to regions and



specific improvements.  In California there are significant legislative



constraints on the distribution of funds  to regions and counties within



the state.  Allocation of highway funds depends to some extent on re-



gional lists of highway needs and state funds for transit go to the



county of origin.  Also, an 8 to 12 year tentative schedule of alloca-



tions to specific projects is developed.



     In contrast, Massachusetts has much less well defined restrictions



on the allocation of funds to regions or projects.  Regions are given



no indication of the funds they can expect when proposed projects are



submitted to the state.  No explicit program of projects has ever been



produced and the legislature passes accelerated highway program bond is-



sues every 2 to 3 years without any public documentation of the projects


                        27
proposed to be financed.
27
  For a pending accelerated bond issue the legislature requested a

  listing of proposed projects but the secretary of transportation has

  resisted making such commitments public.
                                  208

-------
     Not surprisingly, the programming process in each state reflects



the differences mentioned above.  Thus in California statewide program-



ming for highways has been explicit and long range in nature.  As men-



tioned previously, an 8-12 year planning program is produced as well



as a 5 year financial plan and a yearly budget.  While program decisions



reflect many subjective and undocumented factors, a number of technical



priority indices are used as well as a more comprehensive economic analy-



sis methodology.



     In Massachusetts explicit programming is almost non-existent de-



spite an increase in the technical tools available to the state in recent


      28
years.    Program decisions are arrived at by a closed negotiating pro-



cess with the results often undocumented and available publicly only on



a year to year basis.



     In summary, while both California and Massachusetts are attempting



to improve transportation planning, the results in each state strongly



reflect  political and planning traditions.  In California, the planning



process is explicit, public, and well defined.  While local government



has a strong voice in decision-making a highly professional civil ser-



vice has had a tendency to view the planning process as predominantly



a technical activity.



     Any continuing planning activity in Massachusetts is very diffi-
9ft
  A proposed approach to programming as well as specific technical tools

  have been provided to the state as a result of a recent study.  See

  Roos and Pecknold. et al. (1974).




                                 209

-------
cult to define either in terms of a cycle of activities or periodic




documentation.  A closed political process predominates and it is often




difficult to determine the influence of various interest groups includ-




ing local governments.  A poor quality civil service and technical analy-




sis capability reflects this tradition of viewing planning as an acti-




vity to be conducted behind closed doors.
                                  210

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E.  SUMMARY:  KEY PROBLEM AREAS




     The review of planning and programming practice, in general, and




the specific comparison between California and Massachusetts provided




an overview of the nature of the current process and procedures used as




well as an indication of the variations in practice from state to




state.  Recently the planning process has become more public and to some




degree more responsive to a broad range of social and environmental con-




cerns.  To a large extent, these improvements are due to state and Fed-




eral legislation and planning regulations as well as continual pressure




from well organized citizen groups.




     Similarly the improvements in technical analysis tools required




to support a more public and multi-objective planning process are be-




ginning to be developed.  In some cases, improved techniques have been




applied in a variety of states.  Other improved analysis procedures are




not only beginning to be implemented but offer much potential for im-




proved planning practice.




     While improvements occurring to current practice are increasing




the responsiveness of planning to an open political decision-making pro-




cess, several key problem areas remain.  First, while a number of fac-




tors are shifting the focus of planning activities to short range pro-




grams and non-capital options, the mechanism for relating short range




decisions to longer range plans has not evolved.  Program review, air




quality standards and energy considerations can be effective in encourag-
                                 211

-------
 ing  planning  efforts  to  recognize the short range nature of  the decision-




 making  environemnt.   However,  unless ongoing  long  range planning activi-




 ties are  carefully  integrated  with  these short  range efforts valuable




 information will  be lost to  the  decision-making process.




      For  example, the Environmental Protection  Agency  (EPA)currently is




 considering whether to use project  by project review or a long range




 "3C" plan certification  process  to  assure that  metropolitan areas main-




 tain or improve air quality  standards.  With  a  project by project ap-




 proach  it is  difficult to consider  other actions which may  make the cur-




 rent project  more or  less acceptable at some  point in the future.  How-




 ever, certification of a long  range plan provides no assurance that all




 elements  of the plan  will in fact be implemented or implemented on sched-




 ule.  Some combination of short  and long range  review is required.




      Similarly, the Metropolitan Transportation Commission  (MTC) staff




 in San Francisco has  focused predominantly on short range project ap-




 provals and fund allocations.  However, MTC staff is frustrated by their




 lack of ability to  affect the  types of improvements that are being pre-




 pared to  be submitted  for project approval.   Again, some combination of




 a short range and long range focus  is required.




     A significant barrier to  developing a more integrated  long and short




 range planning approach  is the fact that both the process and methodolo-




 gies  in wide spread use  in state and regional planning efforts enforce




a sequential review of long range system planning and programming.  Dif-
                                 212

-------
ferent options, impacts, and issues are addressed in planning and pro-




gramming.   The master plan philosophy remains prevalent and explicit




consideration of uncertainty and system plan revision is ignored.




     Also, no one methodology or consistent set of technical models is




likely to be sufficient for the analyses required in a more integrated




approach for planning and programming.  This conclusion is based on two




considerations.  First, no methodology which addresses all of the rele-




vant technical issues in a broad analysis framework (e.g. more compre-




hensive than current economic analysis approaches) is likely to prove




feasible for complex regional and statewide planning problems.  Second,




given a set of models or procedures which emphasize a specific issue,




or set of issues, the techniques which are appropriate will vary.  In




short, analysis cannot be geared simply toward producing a plan.




Rather different information (amount, type, and level of detail) will




be required at different points in the process.
                                   213

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                BIBLIOGRAPHY FOR APPENDICES I AND II
Allison, Graham T., Essence of Decision, Boston, Mass.: Little, Brown
     Co., 1971.

Altshuler, Alan, The City Planning Process; A^ojLitical^ Analysis,
     Ithaca, New York: Cornell University Press, 1965.

Altshuler, Alan, "The Changing Environment of Urban Development Plan-
     ning: Shared Power or Shared Impotence?" paper presented at the
     57th Annual Conference of the American Institute of Planners,
     Denver, Colorado, October 1974.

Arrow, Kenneth, Social Choice and Individual Values, New York:  John
     Wiley & Sons, 1963.

Bachrach, Peter and Morton S, Baratz, "Two Faces of Power," The Ameri-
     can Political Science Review, December, 1962.

Barton-Aschman Associates, Inc., "State of the Art in Metropolitan Plan
     Evaluation," prepared for San Diego County Comprehensive Planning
     Organization, 1972.

Blau, Peter, Bureaucracy in Modern Society, New York: Random House, 1956.

Boyce, David E., Norman Day, and Chris McDonald, Metropolitan Plan
     Making, Philadelphia: Regional Science Research Institute, 1970.

Braybrooke, David and Charles Lindblom, A Strategy of Decision, New York:
     The Free Press, 1970.

Caro, Robert A., The Power Broker, New York: Random House, 1974.

Cohen, Harry, "The Evaluation of Project Level Transportation Alterna-
     tives," unpublished PhD. thesis, Department of Mechanical Engineer-
     ing, M.I.T., February 1976.

Colcord, Frank, "Transportation Systems Planning in California: Insti-
     tutional Arrangements of State and Local Governments," Research
     Report 72-7, Urban Systems Laboratory, M.I.T., 1972.

Colcord, Frank C., "Urban Transportation Decision Making, 3: San Fran-
     cisco," Cambridge, Mass: Urban Systems Laboratory, M.I.T., 1971.
                                   214

-------
Creighton, Hamburg,  Inc., "Comparative Economic Analysis of Alternative
     Multimodal Passenger Transportation Systems," prepared for NCHRP,
     Highway Research Board,  Contract //HR8-9, Washington, D.C., 1972.

Dahl, Robert A., Who Governs?, New Haven: Yale University Press, 1961.

Downs, Anthony, Economic Theory of Democracy, New York: Harper & Row,
     1957.

Downs, Anthony, Inside Bureaucracy, Boston: Little, Brown & Company,
     1967.

General Analytics, Inc. and Comsis Corp., "Objective Priority Program-
     ming Procedures," prepared for FHWA, Washington, D.C.: FHWA,
     March 1973.

Haar, Charles M., "The Master Plan: An Inquiry in Dialogue Form," in
     Land-Use Planning; A Casebook on the Use, Misuse, and Re-use of
     Urban Land, Boston: Little, Brown & Co., 1959.

Hunter, Floyd, Community Power Structure, Chapel Hill: University of
     North Carolina Press, 1953.

Juster, Richard, "A Methodology for Statewide Programming of Transporta-
     tion Investments," unpublished Masters Thesis, Cambridge, Mass.:
     Department of Civil Engineering, M.I.T., 1974.

Krejci, Mark, "Programming of Transportation Investments: An Analysis
     for a State Transportation Agency," unpublished Masters Thesis,
     Cambridge, Mass.: Department of Civil Engineering, M.I.T., 1973.

Landau, Uzi, "Sketch Planning Heuristics," in Urban Systems Laboratory
     Report 75-2, M.I.T., Cambridge, Mass. 1975.

Lee, Douglass B., Jr., "Requiem for Large Scale Models," A.I.P. Journal.
     American Institute of Planners, May 1973.                 '

Lerman, Steven R., "Towards Behavioral Modeling of Urban Residential
     Location," PhD. dissertation, Department of Civil Engineering,
     M.I.T., Cambridge, Mass., 1975.

Levin,  Melvin and Norman Abend, Bureaucrats in Collision; Case Studies
     Area Transportation Planning. Cambridge, Mass.:  M.I.T. Press,  1971.
                                  215

-------
Linesberry, Robert and Ira Sharkansky, Urban Politics and Public Policy,
     New York: Harper and Row, 1971.

Lupo, Alan, Frank Colcord and Edmund Fowler, Rites of Way; The Politics
     of Trar^sj>ortationj.n Boston and the JJ.S. City, Boston: Little,
     Brown & Co., 1971.

Mak, King Kuen, "Priority Analysis for Ranking of Transportation Im-
     provement Projects - A Proposed Procedure," prepared for Georgia
     Department of Transportation, August 1973.

Manheim, Marvin, "Practical Implications of Some Fundamental Properties
     of Travel Demand Models," Highway Research Record 422, Washington,
     D.C.: Highway Research Board, 1973.

McKinsey and Co., "Summary of Diagnostic Phase Improving the Cost Ef-
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Mead, Kirtland C., "Design of a Statewide Transportation System Plan-
     ning Process: An Application to California," unpublished PhD.
     Thesis, Department of Civil Engineering, M.I.T., Cambridge, Mass.,
     1973.

Mergel, Joseph, "Functional Specifications of a Comprehensive Modeling
     Framework," Masters Thesis, Department of Civil Engineering, M.I.T.,
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NCHRP, "Statewide Transportation Planning: Needs and Requirements,"
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     Research Board, 1972.

Neumann, Lance, "Time-Staged Strategic Approach to Transportation Sys-
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     M.I.T. Department of Civil Engineering, 1972,

Neumann, Lance, "Integrating Transportation System Planning and Pro-
     gramming; An Implementation Strategy Approach," unpublished PhD.
     Thesis, M.I.T. Department of Civil Engineering, Cambridge, Mass.,
     January, 1976.

Novick, David (ed.), Program Budgeting, Cambridge, Mass.: Harvard Uni-
     versity Press, 1967.
                                 216

-------
Pecknold, Wayne M.,  "The Evolution of Transport Systems: An Analysis of
     Time-Staged Investment Strategies Under Uncertainty," unpublished
     PhD. Thesis, Department of Civil Engineering, M.I.T., Cambridge,
     Mass., 1970.

Pecknold, Wayne M.,  "Resource Paper: System Planning and Programming
     Methodology - Passenger Travel," in TRB Special Report 146,
     Washington, B.C.: Transportation Research Board, 1974.

Pressman, Jeffrey and Aaron Wildavsky; Implamentation, Berkeley:
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Rabinovitz, Francine, City Politics and Planning, Chicago: Aldine
     Publishing Co., 1969.

Reno, Arlee T., "Interaction Procedures in the Transportation System
     Planning Process," Highway Research Record 394, Washington, D.C.:
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Roberts, Paul 0., "Model Systems for Urban Transportation Planning:
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Roos, Daniel, Wayne Pecknold, et al., "Procedures for Transportation
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     Mass.: Department of Civil Engineering, M.I.T., 1974.

Safdie,  Moshe, Beyond Habitat, Cambridge, Mass.: M.I.T. Press, 1970.

Schon, Donald, Beyond the Stable State, New York: Random House, 1971.

Wachs, Martin, "Social, Economic, and Environmental Impacts of Trans-
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Zettel,  Richard and Richard R. Carll, "Summary Review of Major Metropol-
     itan Area Transportation Studies in the United States," Berkeley:
     Institute of Transportation and Traffic Engineering, University
     of  California, 1962,
                                   217

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APPENDIX III.  DRAFT LANGUAGE FOR THE CLEAN AIR ACT






     Sec. 	 For the purpose of encouraging and facilitating the




development and implementation of areawide air quality management plans-




AGENCY DESIGNATION




     A.I) The Governor of each State shall, within [          ], and




after consultation with the appropriate elected and other officials




of local governments, designate for each air quality control region or




portion thereof a single organization capable of developing effective




air quality management plans for such area.




     A.2) In the case of an air quality control region which is located




in two or more States, the Governors of the respective States, after




consultation with each other and with the appropriate elected and other




officials of local governments of their respective States, shall coop-




erate in designating, within [       ], a single organization capable




of developing effective air quality management plans for such area.




     A.3) If a Governor, or in the case of an interstate region, the




Governors, do not designate a planning organization within the times




required by paragraphs 1) or 2) (whichever is applicable), the chief




elected officials of local governments within an air quality control re-




gion or portion thereof  may by agreement designate a single organiza-




tion capable of developing effective air quality management plans for




such area.




     A.4) The Organization designated under paragraph A.I), A.2), or
                                 218

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A.3) shall be a) an existing regional agency, except when the designat-




ing official or officials determine and demonstrate to the Administrator




that no such agency capable of air quality planning exists; b) an agency




composed of elected officials or their designees from each local govern-




ment represented by such agency; and c) an agency capable of entering




into binding agreements with other agencies for planning and for im-




plementation of approved programs.




     A.5) Designations under this paragraph shall be approved by the




Administrator unless he determines that such designated agency does




not meet the requirements established under subparagraphs A.I to A.4




of this paragraph.




     A.6) For all portions of a State which within [       ] are not




designated under paragraph A.I), A.2), or A.3), the State shall act as




an air quality management planning organization.






PROCESS GUIDELINES




     B.  Not later than [     ], the Administrator, after consultation




with appropriate Federal, State, and local officials, shall submit to




Congress, and not later than 90 days after such submission, promulgate




guidelines for the development by each air quality management agency of




a document describing its planning process.  Such guidelines shall re-




quire, at a minimum, that such document describe procedures and as-




signments of responsibility for




     1) the identification and consideration of alternative courses of
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action;




     2) identification of social, economic, and environmental effects



of the alternatives;




     3) involvement of, and information exchange with, other agencies,




the general public, and affected interest groups throughout the plan-




ning process;




     4) coordination of air quality management planning with other on-




going planning processes, and resolution of conflicts among programs;




     5) monitoring the effects of air quality management plans as they




are implemented;




     6) revising air quality management plans to reflect changes in




conditions to previous plans based on new information, monitoring, or




other changing conditions and circumstances.




     The Administrator shall not approve any plan 1) for which imple-




mentation did not occur as specified for the preceding period, unless




the submitting agency demonstrates that the failure to implement was




due to reasons or causes not forseeable at the time of submissions, and




2) which does not meet the criteria specified in the preceding para-




graph.




     Federal funds shall not be approved for a project that is not con-




sistent with an approved air quality management plan.  An approved




plan shall be required before any finding of consistency may be made.
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                          LIST OF ABBREVIATIONS
A.Q.C.R.     Air Quality Control Region
A.Q.M.A.     Air Quality Management Area
A.Q.M.P.     Air Quality Management Plan
B.R.A.       Boston Redevelopment Authority
C.B.D.       Central Business District
C.F.R.       Code of Federal Regulations
D.O.T.       U. S. Department of Transportation
E.P.A.       U. S. Environmental Protection Agency
F.H.W.A.     Federal Highway Administration
F.R.         Federal Register
M.D.C.       Metropolitan (Boston) District Commission
M.D.P.W.     Massachusetts Department of Public Works
M.I.T,       Massachusetts Institute of Technology
M.P.O,       Metropolitan Planning Organization
N.C.H.R.P.   National Cooperative Highway Research Program
S.I.P.       State Implementation Plan
T.C.P,       Transportation Control Plan
T.I.P.       Transportation Improvement Program
T.S.M.       Transportation Systems Management
T.S.M.E.     Transportation Systems Management Element
U.M.T.A.     Urban Mass Transportation Administration
U.S.C.       United States Code
V.M.T.       Vehicle Miles Travelled
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