On December 12, 2006, Environmental Defense offered their comments on the Moving Into Prosperity Report. In a three-page memorandum they discussed numerous concerns with the Report and gave reasons why the Report should be subject to extensive peer-review before it is used for decision-making purposes.

Here are the key points:

• The Report Fails to Evaluate Reasonable Strategies For Actively Managing Existing Roadways to Maximize Their Functional Capacity.

• The Report’s Economic Analysis Methodology Fails To Provide A Useful Benchmark for Determining Whether the TTC Project Should Be Undertaken.

• The Report’s Assumption That the TTC Project Will Generate Financial Returns Comparable To Those Observed In The Early Stages Of The Interstate Highway System Is Seriously Flawed.

• The Report’s Relies Upon A Discount Rate That Does Not Accurately Reflect The Actual Opportunity Cost of Capital To Private Road Developers.