BATWG Critiques Valley Link Draft Environmental Impact Report

For almost a year BATWG has struggled to find the transportation logic behind the frantic effort to push the $3,000,000,000 + Valley Link proposal to the front of the line for federal funding.

Background:  Valley Link is a proposed 42-mile commuter rail service with a significant portion to be operated in both directions on a single track. The line would run from the East Dublin BART station via the north edge of Livermore and Tracy to North Lathrop in San Joaquin County. On 9.24.20, $400,000,000 in Alameda County sales tax funds were unaccountably diverted from their voter-approved intent of improving transit connections between BART and the Tri-Valley to the Valley Link proposal (hereinafter VL.)

On 12.2.20 the Draft Environment Impact Report (DEIR), estimated to be at least 5,000 pages long was finally released, with public comment due by 1.21.21. During the ensuing 40 days BATWG critiqued the document which we believe fails to meet CEQA, Alameda County Measure BB and AB758 requirements in a number of significant ways. Our critiques were submitted to the sponsoring agency before the deadline. Here is part of what we found.

Project Alternatives:  CEQA requires that major infrastructure projects include viable alternatives to compare against the “preferred alternative”. Not a single one of the some 30 so-called “alternatives” listed in the DEIR come anywhere close to meeting this CEQA requirement. There were and are other options available. Here are two, either of which could serve local and regional travel needs better than VL would. Both have so far been ignored:

Read More Here

The ACE/VL Alternative: The proposed VL alignment through the Altamont Hills is much less direct than the existing Altamont Corridor Express (ACE) route and therefore would unnecessarily slow down VL travel.

Serious consideration should be given to creating a joint ACE/Union Pacific/VL operation along a straightened out and otherwise upgraded two-track system using the UP/ACE right-of-way, thereby providing higher speeds and greater comfort to both ACE and VL riders. Two parallel low-use passenger rail lines running through the low-density Altamont Hills makes no sense.

The All-Bus Alternative:  A well-integrated network of comfortable and upgraded long distance buses (modeled after the successful Silicon Valley hi-tech bus operations) traveling out of traffic congestion would be far cheaper to build and operate, quicker to implement and yet provide a service that is both more flexible and comprehensiveness than a largely single-track rail line to North Lathrop. Properly laid out and implemented, a first class bus service that was comfortable, safe, reliable, frequent, fast, convenient and understandable would significantly improve travel within the Tri-Valley as well as to points north, west, southwest and east.

Project Schedule: Identifying hoped-for rail service start-up dates many years in the future accomplishes nothing. The DEIR should include a detailed implementation schedule.

Projected Ridership: The Valley Link DEIR states that the initial Valley Link segment (from the East Dublin BART Station to either Greenville Road, Southfront Road or Mountain House) would attract 8,372 to 11,101 weekday riders when it begins service, presumably in 2028. In 2040, when the remainder of the line to North Lathrop is projected to be up and running, it is estimated that the weekday ridership of the line would rise to between 31,710 and 32,993.

The odds that these rosy ridership predictions would actually be realized are extremely low. Evidence from well over 100 ridership studies of forecasted future riders vs. actual riders conclusively demonstrate that rail riderships are consistently wildly overestimated. One major analysis1 showed that the projected riderships of 9 out of 10 rail projects were overestimated, by an average of 106%.

With respect to the VL proposal these forecasting uncertainties, are compounded by generally deficient ridership forecast modeling framework and inadequate documentation set forth in Appendix F of the DEIR.

It goes without saying that an accurate and carefully-prepared ridership forecast is essential to the proper evaluation of the merit and feasibility of a proposed transit development. An overstated ridership projection can lead to both lower than acceptable project cost-effectiveness and higher future operating and maintenance costs. In addition an overstated future ridership invariably reduces such important benefits as greenhouse emissions and eased highway traffic backups. For these reasons the VL team’s failure to provide substantiation for VL’s ridership projections is unacceptable. (More on the DEIR’s ridership forecasting lapses in the next edition of this newsletter).

1  “How (In)accurate Are Demand Forecasts in Public Works Projects?…..The Case of Transportation”:
Bent Flyvbjerg, Mette K. Skamris Holm, and Søren L. Buhl; See

Effect on Traffic:  With a probably overstated projected 2040 ridership of 32,993 riders a day, VL has been widely heralded as the solution to I-580 gridlock. The inconvenient truth is that traffic on I-580 is projected to increase from last February’s pre-COVID level of 200,000 vehicles a day to 350,000 a day by 2040. The promoter’s claim that VL with its “best case” projected weekday ridership of 32,993 a day would ease I-580 congestion is patently false.

Capital Costs:  By using 2018 dollars in all of its estimating, the promoters of the project have greatly understated its actual cost. Expressed in 2021 dollars the total cost of the project would be well over $3 billion. The mid-point of construction of the first 12 miles of construction is estimated to be 2025. The mid-point of construction of the remaining 30 miles of construction is projected to be 2035. If expressed in the dollars at the mid-points of the two respective construction periods, the total would come to over $4 billion. The promoters’ claim that the entire project could be completed for less than $3 billion is preposterous.

Annual Operating and Maintenance (O&M) Costs: The elements that go into making up an O&M cost estimate are listed but there is no cost breakdown. In fact it appears that VL’s estimated O&M cost was determined solely based upon the average O&M costs of two existing DMU systems elsewhere in the country deemed by the Consultant to be similar to the VL system. From the information presented in the DEIR it is not possible to verify the reliability of the O&M figures.

Cost-Effectiveness Mandate Ignored: AB758 stipulated that the intent of the Legislature is to establish the Tri-Valley-San Joaquin Valley Regional Rail Authority to plan and help deliver a cost-effective connection from the San Joaquin Valley to the BART East Dublin station and the Altamont Corridor Express in the Tri-Valley. Nowhere in the DEIR is there any documentation to support the connection or any mention of, or reference to, cost-effectiveness.

Conclusion:  The DEIR is fundamentally flawed because no serious consideration was given to other project alternatives. Nor was there any substantiation of the ridership projections, or any attempt to escalate the 2018 dollars used to estimate capital cost to a more reasonable figure, or a sound basis for calculating O&M costs. As it stands the proposed low ridership, $3 billion + Valley Link line has much more to do with pleasing an assortment of eager housing developers than in providing attractive and cost effective transit connections for the benefit of  Tri-Valley and San Joaquin County residents.  For additional information see individual DEIR critiques by Donna Cabanne ( biological resources/ impacts/ proposed mitigation); Tom Rubin (overview of the DEIR); Jim Schmidt and Jerry Cauthen (violations of CEQA, AB758 and Measure BB, ridership, lack of viable alternatives and costs; and Vaughn Wolffe.


2 thoughts on “BATWG Critiques Valley Link Draft Environmental Impact Report

  1. No kidding. You should know by now that it’s not about cost-effective transportation. It is about payoffs to consultants and construction companies. There is precedent-look at all those projects in your chart above.


  2. Can’t argue with you there! But that kind of thing is hard to prove.

    We intend to continue to expose the dismally low results of transportation expenditures, and give causes when we can. Your interest is appreciated.

    Gerald Cauthen
    Pres. BATWG


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