The Oregon and Washington Departments of Transportation are advancing their $5 billion freeway widening plan based on outdated 15-year-old traffic projections. No new projections have been prepared since the 2007 estimates used in the project’s Draft Environmental Impact Statement,
The two state DOTs are essentially “flying blind” assuming that out-dated traffic projections provide a reasonable basis for sizing and designing and new bridge, and rejecting other alternatives.
The two agencies have spent two years and tens of millions of dollars but not done the most basic preliminary work to accurately predict future traffic levels.
The Oregon DOT has specifically violated Governor Kate Brown’s pledge that new traffic analyses would be done prior to determining the “best solution” for the I-5 bridge project.
The two agencies have no plans to publish new traffic studies until mid-to-late 2022—months after determining a final design and asking for other local sponsors to approve.
The justification for spending upwards of $5 billion on a massive expansion of the I-5 freeway between Vancouver and Portland—a project misleadingly branded as a mere “bridge replacement”—is the notion that there will be a huge increase in traffic between the two cities. That notion is based on traffic forecasts prepared by the Oregon and Washington Departments of Transportation. As with all transportation projects, estimates of how much demand there will be are key to deciding whether projects are needed and justified, for determining how they’ll be designed and what their worth, and critically, assessing their environmental impacts.
Traffic Projections for the I-5 Bridge are based on 15 year old data
When it comes to the “I-5 Bridge Replacement Project,” which has been proceeding for more than two years, there are no new traffic projections. The latest traffic numbers the Oregon and Washington Departments of Transportation are from the project’s Final Environmental Impact Statement, published in 2011. They predict that without the project, traffic on the I-5 bridge will increase to 184,000 vehicles per day, and produce high levels of congestion.
Columbia River Crossing Final Environmental Impact Statement , 2011, Chapter 3, page 3-30.
These numbers are the same as were presented in the project’s Draft Environmental Impact Statement, published in 2008. In fact, the traffic analysis for the project was completed in 2007, and is based on traffic data gathered in 2005.
Columbia River Crossing Draft Environmental Impact Statement , 2008, Traffic Technical Report, page 47
How, it is reasonable to ask, is it possible to plan for a $5 billion project without bothering to update the most fundamental data used to design, justify, and evaluate the environmental impacts of the project?
Traffic Projections are Central to Project Design and Environmental Impact
The basis for any major transportation investment is some sort of careful statistical analysis to project future travel volumes. How many people might travel in a region or a corridor, and what are the various options for accommodating their travel? The statistical models used to generate these data, should, in theory, inform the design of particular alternatives and shape the choices. In particular, traffic forecasts are essential to evaluating the environmental effects of alternatives: which alternative will have lower levels of pollution?
We have many concerns about the quality and biases built into the models used by state Departments of Transportation, but without a doubt, these statistical estimates are in theory, the intellectual foundation for any claims about the need for a project. Without traffic estimates, highway engineers are simply predicating key project decisions on their personal opinions rather than demonstrated facts. In this case, the engineers guiding the I-5 bridge project are engaged in nothing more than faith-based project planning.
For the past two years, the Oregon and Washington Departments of Transportation have been trying to revive the corpse of the Columbia River Crossing, a multi-billion dollar boondoggle that died in 2014. In the process, they’ve told a series of lies, beginning with the false claim that unless they move forward with the moribund project, that they’d have to repay $140 million in federal money spent on planning the original project. (That’s not true!).
In September, the staff of the misnamed “Interstate Bridge Replacement Program” debuted their final and definitive list of project alternatives. Every one of them is centered on a something labeled as a ten lane bridge, with typical illustrations like this:
If the past is any guide, the agency will draw pictures of a ten-lane bridge, but then size it to accomodate 12 or 14 lanes of traffic—exactly what they did with the failed Columbia River Crossing. In reality the project is likely to look like these renderings of the Columbia River Crossing—12- or 14- lane, five-mile long freeway.
In the process, the staff has ruled out a range of other alternatives, like improving transit, instituting pricing, improving local connections, and constructing a supplemental bridge, rather than a replacement. The staff published a series of memos in August, 2021, claiming, based on technical work done by the original CRC process more than a decade ago, that these alternatives “failed to meet the project’s purpose and need,” the first item of which is “growing travel demand and congestion.” Whether any of these alternatives can meet “growing travel demand” and result in lower congestion depends critically on the assumptions one makes about future levels of traffic. Similarly, the as yet un-resolved question of how wide the bridge needs to be also hinges on these same traffic forecasts.
For two years, ODOT has disobeyed Governor Brown’s order to prepare new forecasts first
The need for updated forecasts was recognized when the project was revived in 2019. At the time, Governor Kate Brown promised that a first order of business would be revised forecasts to shape the project. On November 18, 2019, Brown said:
“I think what else is key is that we’re going to be doing a traffic analysis ahead of time to help us determine what’s the best solution for the I-5 Bridge Replacement Project.”
Clearly, Governor Brown envisioned that we would do a traffic study first—”ahead of time”—and allow the data to shape decision. But that’s not what has happened. Let’s turn the microphone over to Clark County Today, which specifically asked the managers of the bridge project the status of their traffic projections, which were originally promised in 2019.
It is now almost two years later. Has the IBRP team conducted a new traffic analysis to determine what’s the best solution for the I-5 Bridge replacement project? Clark County Today asked for the details of any traffic analysis.
“The Interstate Bridge Replacement (IBR) program is currently collecting new traffic data and conducting preliminary traffic modeling that will be used to inform the evaluation of preliminary design options that will be considered to identify the IBR solution early next year,” said Frank Green, IBR assistant program administrator. “More in-depth traffic modeling is expected to be completed in mid to late 2022 as a critical component of the federal environmental review process.”
The IBRP team has no plans to release forecasts until after making design decisions
That timetable was confirmed at the December meeting of the project’s Executive Steering Committee. The project’s schedule calls for developing a resolution defining a “locally preferred alternative” by April 2022, and securing endorsements of that solution by June 2022.
Meanwhile, ODOT and WSDOT have no plans to complete serious traffic modeling—which would address the impact of tolling on traffic levels—for two or three more years. In its November presentation on its tolling plans, the agencies made it clear that they are putting off serious “investment grade” forecasts—like the ones made for the CRC, which showed traffic on I-5 would never recover to pre-construction levels, until 2025.
What this means in practice, is that the only traffic projections that the project has were the ones prepared for its original environmental analysis. These were published originally in 2008, and based on 2005 base year data. As a practical matter, ODOT and WSDOT are planning this bridge based on data that is now more than 15 years out of date.
Pushing for a decision before updating traffic forecasts is engineering malpractice, and violated NEPA
When the project managers say that they need to build a bridge that is at least 10 lanes wide, it’s based on these outdated projections, rather than current, accurate information. This isn’t so much fact-based engineering as it is faith-based speculation. They’ve decided the bridge needs a minimum of ten travel lanes, without first doing a traffic forecast. The I-5 Bridge Project’s Manager has made it clear for nearly a year—well in advance of any technical analyses or any new traffic information—that they’ve already decided what they’re going to do. Clark County Today summarized a January, 2021 presentation by Greg Johnson:
During discussions at Monday’s EAG meeting, Administrator Johnson made the following statement.
“One of the things that I also tell folks, if you’re here and you think we’re going to talk about a third bridge, or we’re going to talk about not doing the Interstate Bridge, you’re in the wrong meeting. The whether we’re gonna do this has been decided. “
John Ley, “Revelations surface from the two ‘advisory’ group meetings on the Interstate Bridge,” Clark County Today, January 28, 2021.
Saying that the project must be ten lanes wide, or claiming that other alternatives don’t adequately meet the project’s stated purpose and need are, in the absence of traffic forecasts, simply arbitrary and capricious. The fact that project managers have repeatedly made definitive statements that no other options will be considered, and that the bridge will be ten lanes wide before even undertaking traffic analysis, shows that they have no intention of allowing the data to drive their decisions, and are signalling that they will cook the modeling to justify this pre-made decision about the project’s size and scope.
Concealing or lying about traffic models is nothing new for ODOT. When it released its environmental assessment for the I-5 Rose Quarter freeway widening project, it entirely omitted any data on “average daily traffic”—the most basic yardstick of travel volumes, and also purposely concealed its modeling assumption that its base year, 2015 traffic volumes were based on the entirely fictional assumption that the I-5 Columbia River Crossing had already been built. As we’ve said, this is the opposite of planning.