Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Save to My Library
Look up keyword
Like this
1Activity
0 of .
Results for:
No results containing your search query
P. 1
HSRA14B - Alexis Declaration - Final

HSRA14B - Alexis Declaration - Final

Ratings: (0)|Views: 231|Likes:
Published by Stuart M. Flashman
Declaration of Elizabeth Alexis, financial consultant and computer model user, about discovering flaws in high-speed rail modeling done for high-speed rail authority
Declaration of Elizabeth Alexis, financial consultant and computer model user, about discovering flaws in high-speed rail modeling done for high-speed rail authority

More info:

Published by: Stuart M. Flashman on Aug 05, 2010
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

08/04/2010

pdf

text

original

 
 
11
 
D
ECLARATION OF
E
LIZABETH
G
OLDSTEIN
A
LEXIS IN
S
UPPORT OF
P
ETITION FOR
W
RIT OF
E
RROR
ORAM 
 N 
OBIS
 
123456789101112131415161718192021222324252627282930LAW OFFICES OF STUART M. FLASHMAN
 
STUART M. FLASHMAN (SBN 148396)5626 Ocean View DriveOakland, CA 94618-1533TEL/FAX (510) 652-5373e-mail: stu@stuflash.comAttorney for Petitioners and Plaintiffs Town of Atherton
et al.
 
(Exempt from filing fees – Gov. Code §6103)
 
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIAIN AND FOR THE COUNTY OF SACRAMENTO
TOWN OF ATHERTON
et al
.,Petitioners and Plaintiffsv.CALIFORNIA HIGH SPEED RAILAUTHORITY, a public entity, and DOES 1-20,Respondents and Defendants
 
No. 34-2008-80000022
filed 8/8/08
Judge Assigned for All Purposes:HONORABLE MICHAEL P. KENNYDepartment: 31
DECLARATION OF ELIZABETHGOLDSTEIN ALEXIS IN SUPPORT OFPETITION FOR WRIT OF ERROR
CORAM  NOBIS
 Date: August 20, 2010Time: 9:00 AMDept. 31Judge: Hon. Michael P. KennyI, Elizabeth Goldstein Alexis, declare as follows:1. I am a resident and citizen of the City of Palo Alto in Santa Clara County. I am acertified financial planner and a founding member of Californians Advocating Responsible RailDesign (“CARRD”), a group of professionals living on the San Francisco Peninsula with aninterest in promoting open and rational discussion of rail service options for California. I havepersonal knowledge of the facts set forth in this declaration and am competent to testify as tothem if called as a witness.2. I received my BA degree from Yale University in 1991 with a joint major in Mathematics& Economics and History. I attended graduate school at Stanford University from 1997 to 2001in a Ph.D. program focused on Econometrics and Industrial Organization.3. Between 1991 and 1998, I was employed by Bankers Trust Company doing financialwork relating to its investment and trading activities. From 2004 to the present, I have been
 
 
22
 
D
ECLARATION OF
E
LIZABETH
G
OLDSTEIN
A
LEXIS IN
S
UPPORT OF
P
ETITION FOR
W
RIT OF
E
RROR
ORAM 
 N 
OBIS
 
123456789101112131415161718192021222324252627282930employed by Alexis and Palmer Financial Advisors LLC providing investment advisory andportfolio management services to clients. In both of these jobs, I have had extensive experiencein developing, evaluating, and working with mathematical models used in the financial servicesindustry.4. The models used in my field of study, microeconomics, are conceptually very similar tothose used in transportation planning. In particular, the methodologies used in testing andevaluating models are essentially the same, regardless of what is being modeled.5. I first became aware of the high-speed rail program in January 2009 through participationin a local neighborhood group. As a consequence of my familiarity with mathematicalmodeling, I took a particular interest in the modeling being done in connection with theCalifornia High-Speed Rail Project in California. Beginning in September 2009, I beganstudying the ridership and revenue modeling being done for the California High-Speed RailAuthority (“Authority”). My initial review of the publicly available ridership and revenue modelinformation led me to have some concerns about the studies.6. I attempted to follow up on these concerns through contacts with the Authority and theCalifornia Department of Transportation (“Caltrans”). Based on information in the minutes of the August 2009 CHSRA Board meeting, I believed that Caltrans was working a new ridershipstudy as part of a Statewide Travel Model that was being developed by UC Davis, under aCaltrans sponsored program.7. I contacted Professor Mike McCoy, the principal investigator for the modeling effort atUC Davis, and learned from him that UC Davis was not moving forward with the modelingstudy. However, his comments about the high-speed rail modeling study deepened my concernsabout that study.8. On November 2, 2009, I sent a brief summary of my concerns via email to Mr. ChadBaker, the person heading that effort at Caltrans. A true and correct copy of that e-mail isattached hereto as Exhibit A. Mr. Baker forwarded my concerns to Mr. Dan Leavitt at theAuthority.9. When the Authority released its 2009 Business Plan in December 2009, I discovered thatthe business plan contained new ridership estimates, presumably using the same model. At thatpoint, I decided to make my concerns public, because it appeared the Authority was continuingto rely on a model that I thought had serious deficiencies.
 
 
33
 
D
ECLARATION OF
E
LIZABETH
G
OLDSTEIN
A
LEXIS IN
S
UPPORT OF
P
ETITION FOR
W
RIT OF
E
RROR
ORAM 
 N 
OBIS
 
12345678910111213141516171819202122232425262728293010. On or about December 22, 2009, I contacted Mr. George Mazur, the lead person on theridership modeling project at Cambridge Systematics, Inc. (“CS”). Through my review of Authority documents, I had learned that CS had actually developed the ridership model undercontract with the Authority and the Metropolitan Transportation Commission (“MTC”). WhileMr. Mazur was already familiar with my concerns and had apparently received copies of myprior e-mails to the Authority, he refused to provide me with copies of his responses to those e-mails, indicating that I would have to seek those responses from the Authority.11. On or about December 23, 2009, I contacted Mr. Nick Brand, a consultant to theAuthority, to see if I could obtain Mr. Mazur’s responses. We discussed meeting in person afterthe holidays to talk about modeling and cost issues. I also sent Mr. Brand an e-mail requesting acopy of Mr. Mazur’s response to my earlier comments. A true and correct copy of that e-mail isattached hereto as Exhibit B.12. On or about December 30, 2009 I was contacted by Mr. Jeffrey Barker, a deputy generalmanager at the Authority. Mr. Barker asked that we meet to discuss my concerns.Approximately one week later, I discussed a meeting with Mr. Barker by phone and I againexpressed to Mr. Barker that I wanted to receive a copy of Mr. Mazur’s e-mail comments, aswell as a copy of the final model coefficients, and made that a condition on my willingness tomeet with the Authority and CS.13. As I continued to review the published information on the ridership modeling, I came torealize that the results could not have been obtained with the model included in the Authority’spublished reports. Among other things, my attempts to recreate a key data table in one of themodeling reports based on the published model information failed. In particular, some of thetable values differed from my calculations by a factor of ten, indicating that the figures had beenentered by hand, allowing typographical errors to occur. This also meant that data manipulationcould have occurred. In addition, the high degree of headway sensitivity shown in the results didnot appear explainable based on the published model parameters.14. On or about January 14, 2010, I sent an e-mail to Mr. Barker, again requesting Mr.Mazur’s responses to my comments on the model, as well as a copy of the model itself. A trueand correct copy of that e-mail is attached hereto as Exhibit C. On or about January 20, 2010 Isent another e-mail renewing my requests or, in the alternative, asking that the Authority direct

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->