(Tom Rubin’s comments are identified by TAR: & END TAR)
Land use patterns should be designed to improve pedestrian access, encourage shorter
trips, increase public transit use, enhance the economic viability of public transit
and decrease private motor vehicle use (auto mobility). Therefore zoning, financing,
land-use controls and other policies should:
concentrate employment near transit stations or stops;
provide pedestrian amenities (such as a complete regular pedestrian street grid;
sidewalks on both sides of the road; slow streets [traffic calming], speed limits
and stop signs or lights to keep traffic safe and comfortable for pedestrians; auto-free
town and urban centers; street furniture and
shelters; and buildings that front onto the sidewalk rather than be isolated behind
parking or landscaped areas);
reduce parking requirements and eliminate parking subsidies;
provide adequate parks, natural areas and plantings for humans and wildlife, aesthetic
enhancement, pedestrian protection and building/sidewalk cooling; and
protect land outside presently developed areas from urban sprawl through
urban limit lines or other restraints.
TAR: While I have little objection to any of these in and of themselves, what I
see as the problem is what is missing – any mention of providing for economic vitality
of the region and the economic betterment of the residents and encouraging transit
modes and systems that do not require major public sector subsidies.
I also have issues with public sector land use policies that require large public
sector expenditures to be viable and those which restrict the ability of land owners
to use their lands as they wish, in the absence of very clear and particular damage
By the way, densification often provides for LONGER trips; New York City is by far
the densest city in the U.S. and the Greater NYC urbanized area has, by far the longest
home-to-work travel times. The main reason for this is that it has such a high transit
mode split, and the average transit trip time is over 50 minutes, compares to about
30 minutes for auto trips. These modal travel times, both auto and transit, are
actually very similar to those for greater Los Angeles, but because the transit mode
split is so much lower in LA, the average travel time is also significantly lower.
Some of these should be understood to applicable only where applicable; for example,
while sidewalks on both sides of the road is so important in heavy pedestrian use
areas that it can be difficult to find places where it doesn't currently exist, there
are many roads with less pedestrian utilization, current and potential, that cannot
justify the expenditure of sidewalks on both sides of the road, and there are many
roads, particularly in rural areas, where expenditures for any sidewalks would have
no purpose. Of course, sidewalks on high-speed limited access roads are extremely
contra-indicated for safety and other reasons.
Existing communities should be revitalized or retrofitted, as necessary, to achieve
these qualities and to enhance their quality of life. Planning And Public Participation
Urban transportation systems and land use should be planned for whole regions. Transportation-land
use models should fully project the reduction in driving and increase in transit
experienced when transit is improved and areas are made more pedestrian accessible
(see above); and modelers should provide decision-makers with compact, transit-oriented
TAR: I have no objection to such alternatives being studied and offered to decision-makers
I object strongly to other, often very viable, alternatives NOT being studied, or
to being unfairly made to appear lower performing.
Please be aware that densification of land use can, and often does, increase auto
usage in the specific area, particularly when done outside of the central city. If
one decides to construct a high-rise residential/commercial/retail center around
a suburban train station, for example, it will be very rare for train trips beginning
or ending at this station to approach 10% of all trips – and it is likely that the
total number of trips will increase very significant because of all the new trip
generators – including those people who will be driving to the new center to take
a rail trip elsewhere.
If this increase in automotive passenger trip volume, and the far greater increase
in rubber tire freight movements, is not provided for in the planning of the project-specific
area, there can be major problems.
Indeed, the planning of such centers must consider the very real possibility of far
GREATER parking for trips of all kinds – or the likelihood of success of the project
can be greatly diminished. There is a classic case at an apartment complex near
a Tri-Met (Portland) light rail station, where the planners wanted to put in ground-floor
retail – with NO parking. After the failure of any commercial lender to write a
mortgage on the retail properties – because the lack of parking violated their lending
criteria – the government agency involved financed it.
There is only one occupant – a hair-care shop that serves the apartment residents,
and very few others – that has not failed. The total unsuitability of suburban retail
without parking has now become so well known that no real estate agent will take
the listings and there were not even "for rent" signs on the stores the last time
I was by there.
In this context, the policy statement element, "Transportation-land use models should
fully project the reduction in driving and increase in transit experienced when transit
is improved and areas are made more pedestrian accessible (see above); and modelers
should provide decision-makers with compact, transit-oriented alternatives" – can
lead to much confusion and suboptimal results if decision-makers are taught to automatically
believe that increasing transit means that roads usage and capacity requirements
are reduced; in fact, the opposite is often the case, particularly on a micro-level.
The National Environmental Policy Act, and the Clean Air and Water Acts should be
complied with fully. Meaningful public participation must take place from the start
of development of state and regional transportation plans. Opportunities for participation
should be enhanced. The participation of environmental, public transit and low income
community groups, including legal help and research, should be publicly funded.
TAR: As long as it is understood that "opportunities for participation should be
enhanced" applies to EVERYONE, fine with me.
By the way, "opportunities for participation" does not mean that people have the
opportunity to speak – it means that they will actually be listed to.
Financing and Subsidies
Federal and local subsidies should be provided to those systems (walking, bicycling,
public transit, passenger and freight railroads and ferries) and equipment that go
further toward achieving accessibility, convenience, efficiency, cleanliness and
equity goals, and denied to the other modes.
TAR: This is stated in the format of a goal, which by definition, is not quantifiable,
and therefore there are no numbers, nor is there any presentation of the proposed
relative scales of the subsidies.
Therefore, as such, this is really just a statement of the status quo:
Walking – which generates no revenues what-so-ever, with the possible exception
of citations for jaywalking and sales taxes on the sales of shoes, is therefore completely,
or almost completely, subsidized. The subsidy percentage is large – generally, 100%
– but the dollar value is generally small.
Bicycling is also almost free of any revenue generation to governments, again with
the minor exception of cycle licenses and the somewhat more significant sales tax
revenues from the sales of cycles, cycling clothing and accessories, etc. On the
other hand, the additional costs of cycling are relatively minor in most regards,
as most transportation (as opposed to recreational) cycling is done on the road network
that was designed for motorized "rubber tire" traffic. Again, we have high subsidy
percentages, but the dollar values per use are generally fairly small for most well-structured,
well-utilized cycling "transportation" projects. (I am referring to "transportation"
cycling projects to differentiate them from "recreational" cycling projects, such
as most off-road cycling. While there is some crossover, in most cases, the best
starting point is to separate project proposals by purpose and to have different
funding and project evaluation methodologies for each.)
Public transit has been substantially subsidized by all levels of government for
decades. The percentages are large – nationally, in the 75-80% range, in total,
with certain types of projects both significantly better (meaning lower taxpayer
subsidy) and below. Certain types of new projects, particularly rail projects and
other non-road projects, can have very high subsidies (for many years, the cut-off
point for Federal evaluation of guideway transit projects for dedicated Federal transit
capital grants was $25 per new rider; there are any number of recent rail transit
projects that have failed to achieve this standard).
Passenger transit – which, because "public transit" is shown as the previous line
item, evidently refers to intercity passenger transit – is also heavily subsidized
by government (or, more properly, by the taxpayers who do not receive direct benefits).
Amtrac, in particular, has never come remotely close to fulfilling the promise that
was made when it was formed of becoming self-sufficient and I know of no one with
any real understanding of the subject who has any expectations that it ever will.
Other intercity rail, which is primarily a state-subsidized function in the U.S.,
is similarly structured to require substantial governmental subsidies for the foreseeable
future. The various proposed high-speed rail projects around the nation are also
projected to require huge construction subsidies, with the requirement for continuing
operating subsidies also a strong possibility in at least some cases. The percentage
subsidies are fairly low compared to other non-auto modes reviewed here, with the
better lines well under 50%, but the per-ride subsidies can be very high, in the
hundreds of dollars for trans-continental service.
There is some question if freight railroads receive governmental subsidies or not,
and this is a discussion that has been on-going for well over a century. At the
current time, it is probably fair to state that, to the extent that governmental
subsidies of freight railroads do exist, they are relatively minor, at least on a
percentage of cost basis, compared to the major modes above, particularly public
transit and passenger rail. It is difficult to compare "subsidy per," because, for
passenger travel, the metric is subsidy per passenger, while for goods movement,
it is subsidy per ton, and there is no generally accepted basis for comparing these
similar, but very different, metrics against each other.
In my experience, much of the existing "subsidies" to freight rail are in the form
of infrastructure improvements to track and other facilities to allow the operation
of passenger rail on freight rights-of-way (which often provide significant benefits
for freight movements), grade separation of road crossings to reduce the safety hazards,
and intermodal freight connections, particularly improving freight railroad access
to ports with public dollars. (What I do not understand is why there is a need to
subsidize what is organized in the U.S. as a for-profit business, and is operated
as such. The shippers, acting as surrogates for their ultimate customers, the buying
public, appear to be willing to pay a fair market price for moving freight on rails
when rail is the superior option. If the for-profit business is being asked by a
public sector body to do something that has no direct benefit to the business and
its owners, then the business should be adequately compensated for this. However,
if the "payment" is in the form of a capital improvement to allow someone else to
use the rail line and that improvement also provides benefits to the business, then
this may reasonably be considered as a subsidy, depending on the details of the particulars.)
Although air transportation is not specifically mentioned in this section, its inclusion
in other portions of this statement makes me believe that it may be one of the modes
the author(s) had in mind for the "other" modes that were to be denied subsidies.
For air transport, while the vast majority of the costs are paid out of user fees,
here there does appear to be significant dollar value of subsidies. In recent years,
much of this has been driven by security concerns, particularly those post-9/11.
I agree that there should be direction to make air transportation revenue-neutral
to taxpayers, which, in my opinion, can be achieved in larger part through more efficient
functioning of the governmental end of air transport (getting the FAA and its various
systems to the point where air traffic flow is not delayed by system shortcomings
– or there is serious consideration of replacing the public sector with the private
for this purpose; more cost-effective approaches to security) and by proper application
of market pricing of airport gates, chiefly by period usage fees driven by demand.
Once complicating factor here is that the nation's air transportation system is
used for both passenger and freight transportation, which would appear to require
segregation of subsidies, to the extent they do exist, between passenger and freight
transportation, which cannot be done precisely to the extent of general acceptance.
In general, the percentage subsidy for air transportation -- both passenger and
freight -- is small compared to most of the other modes. The subsidy per passenger
or per ton is high compared to some other modes, but when the subsidy is computed
on a passenger-mile basis, it tends to very low. Subsidies per ton-mile tend to
be higher, primarily because air transportation tends to be used primarily for high-value,
Again, I note certain significant transportation modes are not mentioned, including
water transportation (except for the rather minor case of passenger ferries – which
are proposed for government subsidies, ignoring the far more significant water freight
movements), pipelines, and electronic information transmission. (I'll skip the examination
of subsidies for these, which quickly gets rather complex for the instant purpose.)
The most prominent government operated transportation system, the U.S. Postal Service,
is also unmentioned, but it has been rechartered to operate as a break-even enterprise,
which it appears to be at or approaching.
This leaves the road transportation system, which is recommended for no subsidization
by government. I concur in the overall recommendation, with note taken that this
should not be understood to mean that this test should be applied to the road system
in total, not to each individual road or class of road; in fact, certain roads, particularly
multi-lane freeways with high usage, tend to be "money-makers," while less utilized
residential and urban roads are generally not. It should also be understood to focus
on "hard" costs and to specifically exclude many of the more exotic proposed soft
From my personal research on the subject, it appears that, taken as a whole, the
"hard costs" of the U.S. road system, is not only not subsidized, but is actually
a significant "money-maker" for governments. The best data on this is from FHWA
Highway Statistics series, which in recent years tends to show that the user fees
collected for road use, mainly "cents per gallon" charges for fuel, tend to be approximately
70% range of road expenditures. Unfortunately, the FHWA reports do not comprehend
certain important governmental revenues from road use, particularly sales taxes on
fuel and autos, auto parts, etc., unless they are dedicated to transportation at
their source, which is only a minor portion of such fees. When such user fees are
included, it appears that road users are paying their hard costs, and then some.
(This is not to say that there are no direct governmental subsidies for roads. In
almost every jurisdiction, there are property taxes or other taxes utilized to support
local roads, particularly those lighter used residential and rural roads I mentioned
above. This subsidy has been somewhat lightened in recent years by the move to require
new developments to either have the initial road infrastructure provided by the developers
and/or the payment of impact fees, which I also support. However, while local roads
are frequently supported by non-road user fees, the amount paid in road user fees
appears to significantly larger.
(It is also important to recognize that many of the user fees paid by road users
do not go for roads. The most obvious example is the $.184 Federal gasoline/$.244
Federal diesel charge, over 15% of which is directed to Federal transit subsidies,
not even considering the exemption of transit vehicles operating on roads from paying
such fees. Obviously, if such road user fees are shifted to transit – not to mention
the various programmatic allocations and "earmarks" of gas/diesel road use fees for
"transportation" purposes that often appear to have little, if any, actual transportation
purpose other than incidental – they are not available for road maintenance and construction,
which is one of the reason why the shortfall in road infrastructure has reached the
current crisis stage. There are many similar allocations of road user fees to non-road
uses at the state and local level, such as the nickel of the Texas $.20/gallon charge
that goes for schools.)
I am very much in favor of higher per gallon charges for road use, with the understanding
that road use fees should go for road maintenance and expansion. I am a strong supporter
of transit, which should be considered a "general fund" expenditure of government,
along with an understanding that the taxpayers deserve that transit expenditures
should be for productive and cost-effective transit systems that are designed to
provide mobility for users, with the primary focus on those who have limited mobility
options due their age, physical condition, and/or economic status.
Shifting gears for a moment, the purpose of public transit is the provision of mobility.
While there are certainly secondary benefits of transit, when there are attempts
to design transit systems around these secondary benefits, it generally turns out
that this is not productive, wastes taxpayer funds, and often significantly hurts
the people who are most dependent on transit for its transportation benefits. In
any case, the best way to maximize the secondary benefits of transit is to focus
on the mobility aspects of transit; for example, transit best contributes to air
quality improvement by increasing mobility for those economically-challenged individuals
that would otherwise be getting their mobility by driving "junkers" – which are often
100, or even 1,000, times as dirty as current generation rubber tire vehicles. Interestingly,
one of the best ways to increase transit use – and to do it quickly – is to reduce
fares, something that has had great success, but is very little used by transit planners
and public officials that would rather "build something" – even if that would be
far less productive and cost-effective utilization of taxpayer transit subsidies.
I find it troubling that the stated rationale for the above policy proposal – "accessibility,
convenience, efficiency, cleanliness and equity goals" – are presented as if the
modes proposed for subsidy are superior to those that are proposed to be denied subsidies,
when, in actuality, the reverse is very often the case. Indeed, the very reason
that the modes proposed for subsidies require subsidies is that they have been proven
by the workings of the marketplace to be significantly lower performing on several
of these goals to the modes that are being "looked down on" by this policy. The
reason that transit carries approximately 2% of the U.S. passenger trips – and, of
course, virtually none of the freight movements – is that the auto has proven to
be far superior in terms of accessibility, convenience, and efficiency, and, to be
kind, it is often very questionable if transit is superior in cleanliness and equity,
even for that small percentage of U.S. trips where transit is even an option. (By
way, the problem with attempting to make transit an option for more trips is that,
while transit is generally not very competitive with the auto on most trips where
transit service now exists, the places where transit now exists are pretty much where
it works best; expanding transit to other areas where it does not currently exist
means, in most cases, that the new service will be less cost-effective and productive
than the existing service, in some cases, significantly so. Attempts to provide transit
service that will be competitive with the auto on the criteria which are most important
to the potential riders –accessibility, speed of travel, wide coverage, high frequency,
etc., etc. – often produces costs that are so high that very little such service,
adding very few additional riders, is possible.
So my message is clear, I am most certainly not saying that there are no opportunities
for providing new and valuable transit services in this nation, nor for improving
existing services; a significant portion of my professional practice involves exactly
this concept. What I am saying is that expectations for such have to be reasonable,
in light of what transit is capable of doing. If the objective is to increase transit
use in a specific urban area by, say, 10%, over a period of a few years, that is
often well within the realm of possibility.
If the objective is to double transit use in a large urban area over a decade, my
response is that traditional transit thinking, which focuses primarily on expensive
new capital projects, has never achieved anything remotely close to such a result;
indeed, the urbanized areas that have come the closest to such results (I'm thinking
primarily Las Vegas, but mention should be made of Los Angeles increasing transit
ridership over 40% in three years) did so by improving, expanding, and/or reducing
the fares on conventional bus service.
Such subsidies are especially needed to correct the history of heavy subsidies to
motor vehicles, including trucks.
TAR: The "history of heavy subsidies to motor vehicles" is presented as a fact.
While a policy statement of this type is generally not expected to include the detailed
support for such statements, it is generally accepted that there documentation of
In this case, I find the statement so remarkable that it cannot be accepted at face
value. As I have stated above, I find that, at the present time, road users generally
pay more than all of the direct costs of the roads that they use.