Some criticisms of the Cost-Benefit Analysis released by Metro (June 2015)

1) Valuing “Bigness” over anything else by falsely asserting that benefits “are typically examined independently of their relationship to costs.” In fact, if the alternatives were presented in terms of the ratio of benefit to cost, the results would show that the Transportation Systems Management and Transportation Demand Management (TSM/TDM) alternative provides the best ratio of benefits.

2) The Analysis inflates the operating costs of the bus rapid transit (BRT) alternative in a way that degrades its cost-benefit ratio. If the Analysis used the same numbers from the DEIR, the BRT ration would approach the TSM/TDM alternative in performance.

3) The Analysis appears to adopt a model that values the time of car riders over the time of transit riders, without any explanation, and as a result skews the results in favor of the tunnel alternative.

4) The Analysis purposely underestimates the cost of the proposed tunnel by half. Analyses of similar projects, most notably the one for the Sepulveda Pass, are using $1 billion per mile as a budgeting model, yet the 710 DEIR and CBA are using $500 million. This is another example of how the Analysis is skewed in favor of the tunnel.

5) The CBA and DEIR have no provision, plan or budget for the anticipated breakdown of the tunnel-boring machine. The same machine has been stuck in Seattle for over a year and is requiring a four-city block additional vertical tunnel to be excavated in order to free it. While of course we cannot be sure that the same machine would break down in a similar fashion here (despite geology that is, if anything, more challenging than Seattle’s), the lack of any contingency costs (again) skews the Analysis in favor of the tunnel. This is most obvious in that the Analysis uses the same discount rate for all the alternatives, which does not reflect the differential in risk among them.

6) One of the primary concept used in the Analysis, “Net Present Value,” is an inappropriate measure for public infrastructure projects.

7) The calculations used to come up with an employment benefit for the various alternatives is directly correlated to capital cost, skewing the benefits to the most costly alternatives. (Again, this is a fundamental problem of the Analysis, in that it unfairly favors “Bigness.”) Employment benefits are directly correlated to capital expenditures. The disparity in capital costs insures that the higher cost projects will generate more jobs than lower cost alternatives.

“Metro board members and other policy-makers should understand that this so-called Analysis appears to be a continuation of the skewed analysis unfairly favoring the tunnel that was obvious in the EIR,” said Marina Khubesrian, South Pasadena councilmember and Vice Chair of Beyond the 710. “It appears that an independent study of these issues may be necessary to get an unbiased view of whether this tunnel will be worth its huge projected costs. Obviously, we believe otherwise, and that instead Caltrans and Metro should study the Beyond the 710 proposal.”

The Beyond the 710 proposal was released on May 28, 2015. A key insight of Beyond the 710 is to understand that more than 85% of commuters exiting the 710 Freeway at Valley Boulevard are intent on reaching local destinations, and the vision of Beyond the 710’s plan is to use 21st Century planning solutions (such as well-planned transit lines, Great Streets concepts, and traffic mitigation) to reduce congestion and promote smart growth rather than 1960s freeway-oriented approaches.

The Beyond the 710 plan demonstrates that removing the freeway “stubs” at both the 10 and 210 freeways can free up land for smart development, employ transit to connect people to important local destinations and other transit lines, and employ modern strategies for increasing bikeability and walkability.

The plan is available at

Proposed: Six 50-ft tunnel exhaust stacks at the entrance to Old Town Pasadena

Proposed: Six 50-ft tunnel exhaust stacks at the entrance to Old Town Pasadena

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2 Responses to Some criticisms of the Cost-Benefit Analysis released by Metro (June 2015)

  1. April says:

    Whoever you are for putting together this site, thank you. This whole thing is so frivolous. There are so, so many better and more practical alternatives to building a massive ridiculous tunnel. And you are very articulate in your criticisms.

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