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 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 unrealistically assumes that the TTC project will generate financial returns "comparable to those observed in the early stages of the interstate highway system".[1] The Report explains that the basis for quantifying TTC financial returns comes from two studies prepared for the Federal Highway Administration (FHWA).[2] However, a close review of those studies provides convincing evidence that the assumption that TTC impact will resemble that of the interstate highway system is seriously flawed. As illustrated in the chart below, the rate of return on highway capital has plummeted since construction of the interstate highway system during 1950’s and 1960’s.

 

Source: M. Ishaq Nadiri and Theofanis P. Mamuneas, Contributions of Highway Capital to Industry and National Productivity Growth, Federal Highway Administration, Office of Policy Development, September 1996

The Report attempts to justify its assumption claiming that "because the TTC represents a fundamental and innovative change in the infrastructure complex of the state in areas with substantial congestion," the project will somehow be able to break the historical cycle of reduced returns on highway capital investment. At a minimum, this assumption should be peer reviewed by qualified transportation finance experts.