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.
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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.
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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
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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
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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
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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,
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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.
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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
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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.
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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.
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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.
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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-
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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
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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
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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.
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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
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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
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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
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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
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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.
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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.
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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.
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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,
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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
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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
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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
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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
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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
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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.
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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;
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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
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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
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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
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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.
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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.
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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
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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)
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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
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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
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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
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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
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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,
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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
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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.
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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.
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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.
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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.
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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
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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
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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.
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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.
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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
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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.
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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-
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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.
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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
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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-
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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
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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.
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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
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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.
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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;
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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.
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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.
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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.
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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
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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)
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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).
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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
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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).
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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).
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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.
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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
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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.
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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).
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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.
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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) .
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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).
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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.
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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-
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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-
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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.
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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
-------
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
-------
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
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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
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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-
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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.
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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
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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
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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-
fectiveness of the Highway Program," prepared for California De-
partment of Public Works, 1972.
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.,
Cambridge, Mass., 1975.
NCHRP, "Statewide Transportation Planning: Needs and Requirements,"
Synthesis of Highway Practice 15, Washington, D.C.: Highway
Research Board, 1972.
Neumann, Lance, "Time-Staged Strategic Approach to Transportation Sys-
tems Planning," unpublished Masters Thesis, Cambridge, Mass.:
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.
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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:
University of California Press, 1973.
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.:
Highway Research Board, 1972.
Roberts, Paul 0., "Model Systems for Urban Transportation Planning:
Where Do We Go From Here?", Highway Research Record 309, Washing-
ton: Highway Research Board, 1970.
Roos, Daniel, Wayne Pecknold, et al., "Procedures for Transportation
Project and Systems Planning: Summary Report and Recommendations
to the Massachusetts Department of Public Works," Cambridge,
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-
portation Systems," in Urban Travel Demand Forecasting, proceed-
ings of conference, December, 1972, Special Report 143, Washing-
ton, D.C.: Highway Research Board.
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,
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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
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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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