SUMMARY

Wendell Cox Consultancy has analyzed urban transportation around the world and often found high cost rail projects to produce insufficient results. Parsons Brinckerhoff, an international engineering firm, and the Council for Transportation Excellence (CFTE), a non-profit organization with ties to the US public transit industry have produced an attack on Wendell Cox. Parsons Brinckerhoff/CFTE cite 13 statements made by Wendell Cox, characterizing all to be inaccurate, distortions or claims not supported by the facts. In fact in no instance does the Parsons Brinckerhoff/CFTE paper show that the statements of The Public Purpose are "inaccurate, distortions or claims not supported by the facts."

As such, the Parsons Brinckerhoff/CFTE attack on Wendell Cox seems to be unfair and not characterized by the good faith and professionalism that should be the basis of mature discourse.

ANALYSIS OF THE PARSONS BRINCKERHOFF/CFTE ATTACK

Wendell Cox Consultancy is an international firm specializing in public policy, land use policy and transportation, and maintains Internet sites at www.publicpurpose.com and www.demographia.com. Wendell Cox is principal of Wendell Cox Consultancy. He was appointed as the only non-elected official⁽¹⁾ member of the Los Angeles County Transportation Commission (LACTC) three times by Los Angeles Mayor Tom Bradley and served from 1977 to 1985. LACTC had jurisdiction over all public transit and highway development in the nation's largest county (9 million population). During that period, the professional planners of the American Public Transit Association (APTA) elected him as chairman of the APTA Policy and Planning Committee (1982-1984). Transit board members elected him as Chairman of the APTA Governing Boards Committee (1984-1985). During his time on LACTC Wendell Cox authored the amendment that provided the local funding to build the Los Angeles rail system a set aside of 35 percent of Proposition A tax revenues (1980). In 1985, he founded Wendell Cox Consultancy, which adopted the following mission statement:

To facilitate the ideal of government as the servant of the people by identifying and implementing strategies to achieve public purposes at a cost that is no higher than necessary.

Consistent with that mission, Wendell Cox Consultancy has often criticized transit projects that are overly costly and operating methods that unnecessarily limit the amount of service that can be provided. As with virtually all issues, there are at least two sides to the debate in which Wendell Cox Consultancy is engaged.

The effectiveness of the arguments raised by Wendell Cox Consultancy, through its web site, The Public Purpose, has triggered a published attack by interests that hold other views. The paper has been issued under the Parsons Brinckerhoff name on the the Center for Transportation Excellence (CFTE) Internet site.⁽²⁾

Parsons Brinckerhoff is an international engineering firm with 250 offices around the world and nearly 10,000 employees. Among other things, Parsons Brinckerhoff is engaged in developing urban rail systems such as have been critiqued by Wendell Cox Consultancy. CFTE is an organization with ties to the US public transit industry. Parsons Brinckerhoff/CFTE examines a 13 statements published by Wendell Cox Consultancy (The Public Purpose) and concludes:

In every instance, Cox's statements are either inaccurate, distortions or claims not supported by the facts.

In fact in no instance does the Parsons Brinckerhoff/CFTE paper show that the statements of The Public Purpose are "inaccurate, distortions or claims not supported by the facts."

Wendell Cox and The Public Purpose welcomes good faith, mature discussion of issues and has often participated in formal debates and forums, both in person and through publications. It is the view of Wendell Cox Consultancy that the Parsons Brinckerhoff/CFTE is both misleading and inaccurate, as shown below. With respect to the 13 specific Wendell Cox Consultancy statements analyzed (Tables 1 and 2):

Parsons Brinckerhoff/CFTE does not dispute the position of The Public Purpose with respect to eight statements. Parsons Brinckerhoff/CFTE responds by changing the subject --- not responding directly to The Public Purpose statement. Such a tactic does not prove a statement to be "inaccurate," a "distortion" or a "claim not supported by the facts."

On four issues, Parsons Brinckerhoff/CFTE disputes The Public Purpose statement. In these cases, The Public Purpose provides data below to support the accuracy of its statement. None of The Public Purpose statements are "inaccurate," a "distortion" or a "claim not supported by the facts."

In one case there is a difference in judgement. Based upon its analysis of the data, The Public Purpose believes that "little or no unsubsidized development" is attributable to light rail. Based upon their analysis of similar data, Parsons Brinckerhoff/CFTE disagrees. This is not a matter of inaccuracy or distortion, it is a matter of interpretation of available data (the specific issue is discussed below). Differences in professional judgement are inherently matters of opinion and cannot be accurately labeled "inaccurate," a "distortion" or a "claim not supported by the facts."

Table 1 Evaluation of Parsons Brinckerhoff/CFTE Claims
Evaluation	Number	Percentage
PB/CFTE Does not Directly Dispute	8	62%
PB/CFTE Disputes: The Public Purpose provides supporting data	4	31%
Matter of Judgement Based Upon Data	1	8%
Total	13	100%

Table 2 Summary of Issues and Evaluation
#	Issue	Does Parsons Brinckerhoff/CFTE Dispute Accuracy of The Public Purpose Statement?	Disputed Statements: Accuracy of The Public Purpose Statement
1	Light rail carries no more than 1/3 of a freeway lane.	NO
2	No connection between light rail and traffic relief.	YES	DATA PROVIDED TO DEMONSTRATE ACCURACY
3	Fewer than 25 percent of light rail riders are former automobile drivers.	NO
4	Transit market share has dropped in all new light rail urban areas.	NO
5	On average freeways are less expensive to build than light rail per passenger mile.	YES	ANALYSIS PROVIDED TO DEMONSTRATE ACCURACY
6	Little unsubsidized development has been generated by light rail.	YES	MATTER OF JUDGEMENT
7	Light rail fare recoveries are as little as 10 percent.	NO
8	Construction costs have escalated up to 325 percent.	NO
9	Portland is less dense than Los Angeles.	NO
10	Portland sprawls like any other urban area.	YES	DATA PROVIDED TO DEMONSTRATE ACCURACY
11	Atlanta development has been more dense than Portland	NO
12	Portland grants light rail development tax subsidies.	NO
13	Traffic congestion is getting worse in Portland	YES	DATA PROVIDED TO DEMONSTRATE ACCURACY

A brief analysis of the issues follows (Table 3). It should be noted that the "Parsons Brinckerhoff/CFTE Headlines" were designated by Parsons Brinckerhoff/CFTE and in some cases are not reasonable representations of "The Public Purpose Statements" that follow. Only the most notable are noted in the analysis below.

The primary purpose of this response is to evaluate the Parsons Brinckerhoff/CFTE claims of "inaccuracy, distortion or claims not supported by the facts." Readers interested in a more detailed discussion of any issue are invited to review more comprehensive issue oriented documentation at the Wendell Cox Consultancy Internet site (www.publicpurpose.com) and others.

Table 3 Evaluation of Issues
ISSUE	Evaluation of the Parsons Brinckerhoff/CFTE Claim
Issue #1: Parsons Brinckerhoff/CFTE Headline: Light rail ridership does not even equal a freeway lane? The Public Purpose Statement: "An analysis of actual US data on all new light rail systems indicates that no system carries more than 1/3 of the volume of a single freeway lane."	Parsons Brinckerhoff/CFTE does not directly address The Public Purpose. statement and instead changes the subject. Parsons Brinckerhoff/CFTE replies by noting that Portland's East Side light rail line carries 120 percent of a freeway lane during rush hour. Ridership during rush hour is not the subject of The Public Purpose statement, which relates to all day ridership. Note: Even if a light rail line carries more people than a freeway lane for a short period, it is not likely to remove a lane of traffic, because many light rail riders are former bus riders, former car pool passengers and riders who would not otherwise travel. To remove traffic requires attracting automobile drivers. Comparatively few automobile drivers switch to light rail, at exorbitant costs to the public. Conclusion: Parsons Brinckerhoff/CFTE does not dispute The Public Purpose statement.
Issue #2:. Parsons Brinckerhoff/CFTE Headline: No traffic congestion relief from rail? The Public Purpose Statement: "There is no connection whatever between new urban rail and traffic relief."	Parsons Brinckerhoff/CFTE cites one example of traffic congestion relief from light rail. Recent data disputes this claim. Parsons Brinckerhoff/CFTE claims that the Portland West Side light rail line has reduced traffic volumes. However, recently released Oregon Department of Transportation counts indicate that freeway traffic in the Portland West Side corridor has increased at a greater rate than on any other downtown oriented Portland freeway.(3) Parsons Brinckerhoff/CFTE also cites the intention of local officials to reduce traffic congestion through light rail. As a litany of planning reports has demonstrated, light rail removes few cars from the road, and these expectations are unlikely to be achieved. Conclusion: Parsons Brinckerhoff/CFTE disputes The Public Purpose statement. The Public Purpose statement is supported by the facts.
Issue #3: Parsons Brinckerhoff/CFTE Headline: Minimal impact since there are few new rail riders? The Public Purpose Statement: "The impact on traffic congestion is even less, since on average fewer than 25 percent of light rail riders are former automobile drivers."	Parsons Brinckerhoff/CFTE does not directly address The Public Purpose statement and instead changes the subject. Parsons Brinckerhoff/CFTE provides information on "new riders." of light rail systems. This is not the subject of The Public Purpose statement, which related to the percentage of total riders (not new riders) who were former automobile riders. Moreover, as was noted in Issue #1, not all new riders are former automobile drivers, such as former bus riders and former car pool passengers. Finally, light rail ridership surveys virtually never attempt to identify the number of former bus riders driven away from transit because of the time loss and inconvenience of being forced to transfer from a bus to light rail to complete a trip. Conclusion: Parsons Brinckerhoff/CFTE does not dispute The Public Purpose statement.
Issue #4: Parsons Brinckerhoff/CFTE Headline: Light rail hurts transit ridership? The Public Purpose Statement: "Average public transport market in urban areas served by light rail dropped from the year before light rail opened and in 1997." (This is a misquote. The Public Purpose statement related to "market share.")	Parsons Brinckerhoff/CFTE does not directly address The Public Purpose statement and instead changes the subject. Parsons Brinckerhoff/CFTE claims that ridership on new light rail systems has increased. This is not the subject of The Public Purpose statement, which relates to "market share," not ridership (Parsons Brinckerhoff/CFTE misquotes The Public Purpose). Market share is the amount of travel (percentage of travel) on transit in relation to total travel in the urban area. Market share can decline if automobile use is rising at a faster rate than transit ridership. This is what has occurred. Parsons Brinckerhoff/CFTE's headline mischaracterizes The Public Purpose statement. The Public Purpose does not claim that light rail hurts transit ridership. The Public Purpose simply notes that light rail does not materially impact traffic congestion. Conclusion: Parsons Brinckerhoff/CFTE does not dispute The Public Purpose statement.
Issue #5: Parsons Brinckerhoff/CFTE Headline: Freeways are cheaper to build? The Public Purpose Statement: "On average the cost to build and operate motorways, including private auto costs, are 1/7th that of light rail per passenger kilometer."	Parsons Brinckerhoff/CFTE does not directly evaluate The Public Purpose statement, which contains the important modifier "on average." Instead, Parsons Brinckerhoff/CFTE provides a single example of a light rail line purported to be less expensive than a freeway. Even so, Parsons Brinckerhoff/CFTE's single example supports the general case that highways are less expensive to build than light rail. Parsons Brinckerhoff/CFTE indicates that a 21 mile light rail line can be built in the Portland area for $1.5 billion, while a six lane freeway one-half that length would require $3.24 billion. But it is invalid to simply compare the costs of transport facilities in a vacuum. An appropriate comparison must include the volume of traffic carried. The freeway would move many more passenger miles (passenger kilometers) than the light rail line. Based upon Portland light rail and highway volumes, it is estimated that the Parsons Brinckerhoff/CFTE cited freeway would cost less to build per passenger mile than the light rail line. This does not take into consideration the much higher costs of operating light rail. It should also be noted that the Parsons Brinckerhoff/CFTE cited freeway would be among the most costly ever built in the United States. Conclusion: Parsons Brinckerhoff/CFTE does not directly address The Public Purpose statement.
Issue #6: Parsons Brinckerhoff/CFTE Headline: Little unsubsidized development has occurred. The Public Purpose Statement: "Little unsubsidized, market based light rail development has occurred."	Parsons Brinckerhoff/CFTE claims that there has been unsubsidized development along the Dallas light rail line. Parsons Brinckerhoff/CFTE also cites development along Washington's rail system, which is not light rail (Parsons Brinckerhoff/CFTE does not comment on whether or not it was subsidized). With respect to The Public Purpose statement on subsidization of light rail related development, Parsons Brinckerhoff/CFTE's only dispute relates to Dallas. The Public Purpose believes that the much larger and more significant expansion of the adjacent North Central Freeway is the more likely cause than light rail. Moreover, similar central city developments are occurring, both near and far from light rail lines throughout many major cities of the nation. Further, as is discussed below, Portland, which has one of the nation's most highly regarded light rail systems, has implemented a subsidy program for developers willing to build near light rail stations. Conclusion: Parsons Brinckerhoff/CFTE and The Public Purpose have a professional disagreement over the extent to which light rail generates unsubsidized development.
Issue #7: Parsons Brinckerhoff/CFTE Headline: Missing The Public Purpose Statement: "As little as 10 percent fare recovery for light rail."	Parsons Brinckerhoff/CFTE does not directly address The Public Purpose statement and instead changes the subject. Parsons Brinckerhoff/CFTE claims that Washington Metro's fare recovery ratio is 74 percent. This is not the subject of The Public Purpose statement, which relates to the overall minimum fare recovery ratios in the nation. Further, Washington Metro is not a light rail system. Conclusion: Parsons Brinckerhoff/CFTE does not dispute The Public Purpose statement.
Issue #8: Parsons Brinckerhoff/CFTE Headline: Construction costs have soared above projections. The Public Purpose Statement: "In some cases (construction costs) have increased by as much as 325 percent compared to original projections."	Parsons Brinckerhoff/CFTE does not directly address The Public Purpose statement and instead changes the subject. Parsons Brinckerhoff/CFTE claims that some rail systems have achieved their cost projections. This is not the subject of The Public Purpose statement, which was to indicate that some systems have increased in cost by as much as 325 percent. Conclusion: Parsons Brinckerhoff/CFTE does not dispute The Public Purpose statement.
Issue #9: Parsons Brinckerhoff/CFTE Headline: Los Angeles denser than Portland The Public Purpose Statement: "Even Portland, Oregon, with its mythical transit orientation, is nothing more than a sprawling metropolis barely half as dense as Los Angeles."	Parsons Brinckerhoff/CFTE does not directly address The Public Purpose statement and changes the subject. Parsons Brinckerhoff/CFTE acknowledges the accuracy of The Public Purpose statement that Los Angeles is more dense than Portland (and all other US urban areas). Parsons Brinckerhoff/CFTE claims, however, that Portland has higher density concentrations, compared to more uniform densities than in Los Angeles. This is incorrect. Not only is Los Angeles more dense, but it has much higher density concentrations than Portland. Los Angeles, measured in overall and corridor densities is far more dense than Portland (Figure 1): The most dense census tract (1990) in Los Angeles has approximately 80,000 persons per square mile 3.5 times Portland's 23,000. More than 900,000 people in Los Angeles live in census tracts with densities higher than the highest density census tract in Portland. The most dense 1 percent of Los Angeles land area has 34,200 persons per square mile, 2.9 times Portland's 10,700. The most dense 10 percent of Los Angeles land area has 18,400 persons per square mile, 2.5 times Portland's 7,300 (Table 4). The Los Angeles case is emphasized by The Public Purpose because Los Angeles was the nation's first large automobile oriented urban area. Despite its high density, transit provides under two percent of travel in the Los Angeles area. The prospects for transit in other areas are even more daunting. Conclusion: Parsons Brinckerhoff/CFTE does not dispute The Public Purpose statement and erroneously claims that Portland has higher corridor densities.
Issue #10: Parsons Brinckerhoff/CFTE Headline: Portland sprawls like any other US city. The Public Purpose Statement: Portland is not unique. It sprawls like any other U. S. urban area."	Parsons Brinckerhoff/CFTE disputes this characterization by The Public Purpose. But, if Portland were not a typical sprawling metropolis, then it would consume less land per capita than virtually all other urbanized areas. But among the 34 urbanized areas with more than 1,000,000 population, Portland consumes more land per 1,000 persons than all but 16, ranking in the middle (Table 5).(4) Indeed, renown New Urbanist (so-called "smart growth") Architect Andres Duany expressed a similar sentiment: To my surprise, as soon as I left the prewar urbanism (to which my previous visits had been confined), I found all the new areas on the way to the urban boundary were chock full of the usual sprawl one finds in any U.S. city(5) Conclusion: The Public Purpose statement is supported by the facts and by the personal judgement of Andres Duany (cited because of his high regard among Portland planners and the so-called "smart growth" movement). Parsons Brinckerhoff/CFTE fails to prove any allegation.
Issue #11: Parsons Brinckerhoff/CFTE Headline: Atlanta is denser than Portland. The Public Purpose Statement: "data indicates that new development has been twice as dense as Portland's since 1982."	Parsons Brinckerhoff/CFTE does not directly address The Public Purpose statement and instead changes the subject. Parsons Brinckerhoff/CFTE responds with data suggesting that the density of new development in Portland has been higher than that of Atlanta since 1990. This is not the subject of The Public Purpose statement, which relates to the period since 1982. Federal Highway Administration data continues to show the density of new development in Atlanta from 1982 to be higher than that of Portland (1982-1997). Further, recently released 2000 census data indicates that the core Atlanta counties of Fulton and DeKalb have densified at a faster rate than the Portland core county of Multnomah.(6) Parsons Brinckerhoff/CFTE's headline significantly mischaracterizes The Public Purpose statement. The Public Purpose statement indicated that new development had been more dense in Atlanta, not that Atlanta is more dense than Portland. Conclusion: Parsons Brinckerhoff/CFTE does not dispute The Public Purpose statement.
Issue #12: Parsons Brinckerhoff/CFTE Headline: No transit oriented development without subsidy. The Public Purpose Statement: "Faced with the reality of little development, the City of Portland now grants 10 years of tax abatement for developments within walking distance of light rail stations."	Parsons Brinckerhoff/CFTE does not directly address The Public Purpose statement and instead changes the subject. In its response, Parsons Brinckerhoff/CFTE confirms the accuracy of The Public Purpose statement: "Portland now grants 10 years of tax abatement for developments within walking distance of light rail stations." Parsons Brinckerhoff/CFTE claims that the value of new development along the light rail line is far greater than the Portland light rail tax abatement, the accuracy of which they acknowledge. This is a different subject. It is the position of The Public Purpose that if light rail were an effective generator of development, tax abatements and subsidies would not be necessary. Conclusion: Parsons Brinckerhoff/CFTE does not dispute The Public Purpose statement.
Issue #13: Parsons Brinckerhoff/CFTE Headline: Portland's congestion is getting worse. The Public Purpose Statement: "Portland is not winning the battle against traffic congestion. Since 1982. Portland's FHWA Roadway Congestion Index has risen 33 percent, nearly equal to Atlanta's 36 percent."	Parsons Brinckerhoff/CFTE disputes The Public Purpose statement, using unreliable data. Parsons Brinckerhoff cites data to support its contention that traffic trends are worse in Atlanta than in Portland, citing a report containing a 1990 to 1995 trend analysis of Oregon and Georgia. The Public Purpose statement was not about Oregon and Georgia, it was about Portland and Atlanta. In fact, as The Public Purpose indicates, Portland's traffic congestion is worsening comparatively rapidly, based upon data from the US Federal Highway Administration Roadway Congestion Index project.(7) Countering Parsons Brinckerhoff/CFTE's claim that recent traffic trends in Portland are more favorable is the latest Federal Highway Administration data (subsequently published) indicates that Portland's roadway congestion index has risen 54 percent from 1982 to 1997 (from 0.79 to 1.22), compared to 45 percent in Atlanta (from 0.85 to 1.23). Parsons Brinckerhoff/CFTE adds comments on recent positive transit ridership trends in Portland. Nonetheless, traffic congestion has continued to worsen, rendering Portland's Roadway Congestion Index even higher than that of the New York area. Transit's market share is so small in Portland that substantial ridership gains have little or no impact on traffic congestion. Conclusion: Parsons Brinckerhoff/CFTE disputes The Public Purpose statement. The Public Purpose statement is supported by the facts.

1. Under California state law, the members of the Los Angeles County Transportation Commission (effective 1977 through the early 1990s) were the Mayor of Los Angeles, the five county supervisors (county commissioners), the mayor of Long Beach and council members from two other cities in the county (elected by the League of Cities). The Mayor of Los Angeles was also given two additional appointments. Throughout the period one of the appointments was the City Council President and the other was Wendell Cox, whose appointment required city council confirmation.

2. The Parsons Brinkerhoff Portland, Oregon office, through a Mr. G. B. Arrington has widely distributed a paper entitled "Responding to Wendell Cox" on e-mail. Another similar or identical version has been circulated widely by others under the title "Council for Transportation Excellence: Responding to Wendell Cox," shown as a "draft" dated August 2000. The document has now been posted to the www.cfte.org Internet site.

3. www.publicpurpose.com/ut-porwest.htm

4. Calculated from 1990 US Census data (latest available Census Bureau urbanized area data).

5. "Punching Holes in Portland," by Andres Duany, The Oregonian, December 19, 1999.

6. www.demographia.com/db-poratl2000.htm

7. Texas Transportation Institute

8. Los Angeles: Los Angeles and Orange counties and Portland: Clackamas, Clark, Multnomah and Washington counties. All census tracts with more than 500 persons per square mile included in the analysis.