Archived by the Puget Sound Public Interest Transportation Forum, www.bettertransport.info/pitf.
The following letter was submitted as a public comment on the Draft EIS for PSRC's Destination 2030, with attention to Supplementary Technical Appendix 11 titled Least-Cost Planning Analysis, available full-text in a document linked at the bottom of this page.
November 27, 2000
SEPA Responsible Official
Puget Sound Regional Council
1011 Western Avenue, Suite 500
Seattle, WA 98104
Fax to: 206-586-4825
E-mail to: email@example.com
Re: Least-Cost Planning Analysis: Supplemental Technical Appendix 11, Metropolitan Transportation Plan Alternatives Analysis and DEIS
Dear Mr. Abbott:
We have reviewed the least-cost planning analysis and offer the following comments and recommendations from the perspective of transportation professionals with an interest in cost-effective transportation solutions for our region.
1) Appendix 11 demonstrates that least-cost analysis can be accomplished with available cost and transportation system data, and that it is an important tool for the selection of separate elements of the Metropolitan Transportation Plan. The preferred alternative that is selected will have to be composed of elements, both investment policies and strategies, that effectively address the regionís serious mobility and air quality problems, and that do so within challenging fiscal constraints. Least-cost analysis is the best available instrument to identify the most cost-effective investments and strategies, and state law requires its use. [See PSRC Response LP-5 to this paragraph.]
2) Unfortunately, the least-cost analysis performed so far by PSRC for the 2001 MTP update is limited to alternative system-level planning packages and is not applied to individual plan components as called for by state law. The law (RCW47.80.030) requires that regional plans be "based on a least-cost planning methodology that identifies the most cost effective facilities, services, and programs." We find no analysis of separate facilities, services and programs that could be assembled as a preferred alternative. [See PSRC Response LP-6 to this paragraph.]
3) Appendix 11 recommends as a "Next Step" a policy commitment to further refine the regional plan using the least-cost planning approach, but this does not appear to allow for consideration and analysis of facilities, services, and programs proposed by citizens. In suggesting a further policy commitment to utilize least-cost planning analysis, the appendix refers to a procedure adopted in the 1995 Metropolitan Transportation Plan. This procedure allows capital projects and programs to be advanced from "candidate" to "approved" status through a formal environmental review process. However, according to the 1995 MTP, a candidate project must meet three requirements: is regionally significant, has been endorsed by a sponsor, and has been derived from a formal planning process. Thus it appears that proposals without an official governmental sponsor (i.e., city, county, transit operator, WSDOT, port or special purpose transportation agency) have no opportunity to be analyzed for their cost-effectiveness and considered for inclusion in the MTP. Feasible proposals that originate from non-governmental groups appear to have no standing as a candidate project/program under this process. In the Puget Sound region, serious citizen-initiated transportation solutions like the various monorail proposals and the bus/van-pool proposal from a former Metro Director deserve to be analyzed in a fair, routine process of consideration. [See PSRC Response LP-7 to this paragraph.]
4) The procedure advocated by PSRC as a "Next Step" that applies least-cost analysis to only certain candidate projects after the MTP is adopted is not in compliance with state law. The law clearly indicates that least-cost planning must be the basis for the MTP, and not just a procedure that might be utilized to analyze components added after the MTP is adopted. We understand "based on" to mean precisely what the dictionary meaning for the word "base" suggests: the fact, observation, or premise from which a reasoning process is begun. Thus the law requires that least-cost analysis be applied to all components, not just components that are candidates for inclusion in a previously approved list. Since the law must be fully implemented with any transportation plan adopted after July 1, 2000 (WAC 468-86-080), least-cost analysis must be applied to all 2001 MTP components even though they may have been previously "approved". [See PSRC Response LP-8 to this paragraph.]
5) The purpose and extent of the "Next Step" procedure is unclear. Appendix 11 states that the procedure would "better discriminate among the differences in character and scope of major proposed future modal and system investments and policy and program strategies." The law clearly requires that least-cost analysis be used to determine cost-effectiveness. Appendix 11 does not define "character" and "scope", but these words are far more subjective than "cost" and "effectiveness" and imply a much more limited application of least-cost analysis than the law intended. [See PSRC Response LP-9 to this paragraph.]
6) Further, the procedure outlined in the 1995 MTP would seem to preclude policies and programs requiring the involvement and cooperation of a number of governmental entities, such as those that would meld disparate capacity investment and demand management strategies to encourage more efficient utilization of the existing transportation system. The 1995 MTP speaks of candidate and approved "capital projects/programs" that are sponsored by individual government agencies. It does not recognize that a complex mix of elements, both build and non-build, under various lead agencies could constitute a system efficiency alternative that produces significant transportation and other social benefits. [See PSRC Response LP-10 to this paragraph.]
We assess the current use of least cost planning by PSRC to be deficient with respect to state law. We make the following strong summary recommendation which would correct the deficiency:
Least-cost analysis of all potential transportation plan components, whether investments or strategies, whether additions to system capacity or policies that produce more efficient utilization of current capacity, and whether sponsored by a governmental agency or a group of citizens, should be accomplished prior to selection of the preferred alternative and adoption of the MTP. The results of this analysis should serve as the basis for selection of the preferred alternative plan and should be incorporated in the final DEIS.
To be clear, this recommendation means that we believe considerable rework of the 2030 Metropolitan Transportation Plan by PSRC is required before adoption. [See PSRC Response LP-11 to the previous three paragraphs.]
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Following are the PSRC response comments on the above letter, paragraph by paragraph, as published in Volume 1 ó Description of the Preferred Alternative and Environmental Impact/Mitigation Measures of the Final Environmental Impact Statement for the Proposed DESTINATION 2030 Metropolitan Transportation Plan for the Central Puget Sound Region, May 10 ,2001:
LP-4: In the State of Washington, beginning in 2000,Regional Transportation Planning Organizations are required (RCW 47.80.030) to apply least-cost planning analysis to alternative transportation investment strategies. Within Washington Administrative Code (WAC 468-86-030 and WAC 468 -86-080) least-cost planning is defined as ďa process of comparing direct and indirect costs of demand and supply options to meet transportation goals and/or policies where the intent of the process is to identify the most cost-effective mix of options.Ē Least--cost planning attempts to consider all of the reasonably identifiable resource costs associated with alternative investments, and to provide information relevant to decisions about investment selection and prioritization.
LP-5:The Regional Council agrees that least-cost planning analysis, as it relates to metropolitan plan alternatives, is feasible and that "Appendix 11 demonstrates that least-cost planning analysis can be accomplished with available cost and transportation system data."
LP-6:In the State of Washington, beginning in 2000,Regional Transportation Planning Organizations are required (RCW 47.80.030)to apply least-cost planning analysis to alternative transportation investment strategies. Within Washington Administrative Code (WAC 468-86-030 and WAC 468 -86-080) least-cost planning is defined as "a process of comparing direct and indirect costs of demand and supply options to meet transportation goals and/or policies where the intent of the process is to identify the most cost-effective mix of options." Least--cost planning attempts to consider all of the reasonably identifiable resource costs associated with alternative investments, and to provide information relevant to decisions about investment selection and prioritization. Also see response I-167.
LP-7:The objective of current planning work is to update and refine the 1995 MTP. A public scoping process identified the range of alternatives to be analyzed in the EIS. In the future, the region ís transportation plan will be totally re-evaluated. At that time, a larger range of alternatives will be analyzed, including "serious citizen-initiated transportation solutions." These alternatives will be subject to least-cost planning analysis.
LP-8:The Regional Council believes it has complied with state law (RCW 47.80.030); any further refinement and utilization of a least-cost analysis methodology simply provides additional information that can be used in future decision processes as they arise. See also response I-167.
LP-9:See response LP-4.
LP-10:See response LP-8.
LP-11:See response LP-8.
I-167:Washington State DOT has adopted regulations pursuant to RCW 47.80.070 to establish minimum standards for development of regional transportation plans. WAC 468-86-030 defines "least-cost planning " as "a process of comparing direct and indirect costs of demand and supply options to meet transportation goals and/or policies where the intent of the process is to identify the "most cost-effective mix of options." The Regional Council believes that this phrasing supports doing least-cost planning for the "mix of options " rather than on each option separately; if it required a least-cost analysis for each of the components, this phrase would read "the mix of the most cost-effective options."
The Regional Council believes that the best way for the least-cost methodology to "treat demand and supply resources on a consistent and integrated basis " is to put the alternatives into packages based on consistency and integration, and then do a least-cost analysis to see which package is most cost-effective. This was the methodology employed in Appendix 11.It appears that the intent of the statutory amendment (WAC 468-86-080)was for the regional transportation planning organizations to implement least-cost planning methodologies incrementally and for WSDOT to lead the way in how that should be accomplished. The Regional Council ís Destination 2030 plan requires that enhanced benefit-cost analysis be conducted on all future corridor projects before a given project can be "approved " for implementation.
Note: All comments and PSRC responses on Least Cost Planning in Destination 2030 are in a full text PDF document here (3 megabytes).