As if projects such as the Honolulu rail line aren’t a big enough waste of money, Secretary of Immobility Ray LaHood is seeking to change the Federal Transit Administration’s process for evaluating grant proposals for rail projects. As if to illustrate the slow and cumbersome nature of federal programs, LaHood originally proposed to revise these rules more than two years ago, and now we are only at the stage of having a first draft for public comment.
In any case, the Antiplanner submitted comments arguing that LaHood’s proposal violates the law in three ways. First, the law requires that transit agencies evaluate the cost effectiveness of transit projects by comparing them with a full range of alternatives. But the proposed rules only require that the cost effectiveness of proposed projects be compared with a “no action” alternative. If no other alternatives are considered, no one will know if a project is truly the most cost-effective way of improving transit.
Second, the law requires that projects be judged based on their ability to improve mobility and reduce congestion. Yet the proposed rules actually reward transit agencies for increasing congestion. While the existing rules require that cost effectiveness be calculated in terms of the cost of saving people’s time, including the time of auto users as well as transit riders, the new rules base cost effectiveness solely on the cost of gaining new transit riders. This means that a project that increases congestion, leading some people to ride transit to escape traffic, will actually be scored higher than one that does not increase congestion.
Finally, the proposed rules also allow the FTA to make grants based on environmental benefits, operating efficiencies, and transit-supportive land-use policies. But to this list the proposed rules add several more criteria, including livability, environmental justice, and multimodal connectivity. The law does not authorize the Department of Transportation to make grants based on these criteria.
The Antiplanner concludes that the FTA should scrap its proposed rules and either stick with the current ones or revise the rules in a way that requires transit agencies to assess the cost-effectiveness of a full range of alternatives and then pick the one that is most cost effective at saving people time. Comments on the proposed rules are due March 26 and can be made on line.