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says it has no funds with which to do so.68

Dunphy concluded that cities now contemplating light

rail "are not well served by unduly positive reviews" given

by rail proponents.  "Light rail is expensive," he noted,

adding that it "will not reduce traffic congestion."  But he

optimistically (or perhaps cynically) points out that "con-

gestion relief should be one of the best sales tools, since

few residents will use transit but all would gain benefits

from less congestion."69

The Problems of Alternatives

ISTEA requires regional planning.  And as a prerequi-

site to securing federal funds, local planners must file

environmental impact statements (EISs).  A review of dozens

of those statements reveals many omissions by planners and

shows that, even by their own standards, rail is not a good

transportation bargain.

Nearly all rail EISs consider an identical range of

alternatives:

· A "no-build" alternative that contemplates no change

from current transit operations;

· A "transportation systems management" alternative

that contemplates low-cost improvements in bus service

and actions that might promote carpooling, cycling,

walking, or other alternatives to single-occupancy

vehicles; this is generally the baseline alternative

with which other alternatives are compared;

· One or more alternatives for building exclusive

busways or high-occupancy vehicle lanes; and

· One or more alternatives for building rail lines.

The most recent EISs usually come out in three ver-

sions:

· A draft EIS that considers a variety of rail routes,

· A draft supplemental EIS that narrows the routes to

just one option, and

· A final EIS that usually contains little or no new

information other than public comments.