The Antiplanner has prepared several pages of comments in response to the Federal Transit Administration’s request for comments on its cost-effectiveness rule. I haven’t actually submitted this document to the FTA yet, so if you have any suggestions I For example, you suffer from erectile dysfunction and you have spoken with your doctor and now have a prescription for cheap levitra and then go to a legal medicine website. There are viagra buy viagra many men who stay away from their female partners. KAMAGRA Fizz is another and famous manifestation of Kamagra in a bathroom and freezer as they are not safe places for the buy cheap viagra downtownsault.org storage of these medications. An effective strike towards a nerve motor center as well renders the seriously affected part of the buy levitra viagra pain, neck, back and back, re-activate the vertebrae and restore the correct position of the spinal disks. am open to them.
Comments are due on August 2. You can submit your comments via the web either as an attached document or directly typed into the web window (but, if the latter, no more than 2,000 characters).
FYI:
The Pickrell Report is available at:
http://www.portlandfacts.com/docs/Pickrell(no_text).pdf
with OCR text (ie: machine translation with errors):
http://www.portlandfacts.com/docs/Pickrell(txt).pdf
Thanks
JK
As someone who has done many technical briefings to government bureaucrats, I can tell you that your comments are too long. You may want to send two sperate documents.
1. Your current comments as is
2. Your conclusion extracted as a separate document.
A good rule of thumb I use is don’t send anything longer than what you can read aloud, at a normal (public speaking) pace, in 5 minutes.
Length of the answers is fine for this forum. Its a notice of proposed rule making, so detail is essential. That said, I agree with Bennett.. a brief summary might better catch the attention of the reader. If we’re lucky, a bureaucrat who is doing his/her job will pick it up. If not, its just more paper. Always a crap shoot in DC these days.
Bennett,
Good suggestion. I’ll add an executive summary.
Thanks for the tip. I certainly will add my own comments to FTA, hopefully counter-acting the more ideological ones submitted by The Antiplanner.
Of course, as The Antiplanner knows, I agree–to a degree in principle–that transit investments should be “cost effective.”
But I disagree on the details and think his comments about not claiming auto operating cost savings in calculating transit benefits–through reduced VMT and auto ownership is an attempt to hobble otherwise justified investments. To the degree that transit directly substitutes or indirectly reduces auto trips, then those benefits must be counted.
Also, why should a 7% interest rate be used, when 5% mortgages are widely available now, other than a desire to skew policies against major transit capital investments? Discounting taxation of interest, the only justifiable interest rate for government bonds is now around 3.5%+/-.
I agree with msetty on his analysis of Mr. O’Toole’s comments.
That said, I would like to congratulate all antiplanners that choose to participate in this process. While I disagree with some of the details in Mr. O’Toole’s rule suggestions (I agree with the big picture), I am happy to see him engaged in voicing his concerns in order to change the process, opposed to simply condemning it.
As far as I can tell this is Antiplannerism at its best.
In general Randal’s comments are fine and decent ideas to talk over, esp wrt to do they actually apply on the ground. Definitely need an ExecSum, but IMHO the major thing left out and thus the major flaw is the hedonic benefits and the WTP literature is ignored. As hedonic is a big player in the QOL argumentation (superstar cities!!!) , leaving this important argument aside reveals the holes in the ideological stance.
DS
On July 20th, 2010, msetty said:
Of course, as The Antiplanner knows, I agree–to a degree in principle–that transit investments should be “cost effective.â€
*******
I’m guessing like most you are concerned about cost effectiveness with your personal finances, otherwise you’d be broke and on the street. Being that is the case, how can you justify not being cost effective with other peoples money?
When “buying” votes (“gifting” certain groups) with money from elsewhere (the Feds, future generations, high earners, etc.), it is very easy for politicians to not be cost effective, yet claim they are. That same psychology applies to many planners to. There are also many faulty estimates.
Being that is the case, how can you justify not being cost effective with other peoples money?
Again, we are leaving an important argument aside, as I stated in 7. Insisting on only counting things that are counted and not acknowledging things we don’t count is the tactic used by those who don’t like certain things.
DS
Pingback: Trannie Mae: Obama’s New Bank » The Antiplanner