On December 12, 2006, Environmental Defense offered their ccomments 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.

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

The Report relies upon input-output modeling to quantify the indirect effects of the TTC on the economy. One problem with applying this type of economic analysis to a single alternative is that the public has no means of evaluating how an investment in the TTC project compares to other potential transportation investments. It is important to note that construction spending by itself does not necessarily bring any net income benefit over the alternative of spending the same money on other transportation investments. If the state or private developer were to invest several billion dollars in public transit, the input-output model would also show positive indirect effects on the economy.  To determine whether the TTC project should be undertaken at all, a benefit-cost analysis of multiple viable project alternatives should have been conducted – not an economic impact analysis of a single alternative.