A newly revealed ODOT report shows the redesign of the I-5 Rose Quarter project will:

• creates a dangerous hairpin turn on the I-5 Southbound off-ramp
• increase crashes 13 percent
  
• violate the agency’s own highway design standards
• result in trucks turning into adjacent lanes and forcing cars onto highway shoulders
• necessitate a 1,000 foot long “storage area” to handle cars exiting the freeway
• require even wider, more expensive freeway covers that will be less buildable

A project that ODOT has falsely billed as a “safety” project—based on a high number of fender benders—actually stands to create a truly dangerous new freeway off-ramp, and at the same time vastly increase the cost of the project, while making it harder to build on the project’s much ballyhooed freeway covers.

Earlier, we revealed that the redesign of Oregon DOT’s proposed $1.45 billion Rose Quarter Freeway widening project will a hazardous new hairpin off-ramp from Interstate 5, endangering cyclists.

The safety analysis for the project’s Supplemental Environmental Impact Statement confirms our concerns that ODOT is building a “Deadman’s Curve” off-ramp:  The agency estimates the new ramp will increase crashes 13 percent compared to the No-build, and that the design of the off-ramp violates ODOT’s own Highway Design Manual.

As part of its redesign of the I-5 Rose Quarter Freeway project, ODOT has moved the Southbound off-ramp from I-5, which is now located just North of NE Broadway, to an area just next to the Moda Center, and immediately north of the existing I-5 south on-ramp.  The new ramp fits awkwardly into the existing street grid, and the most troublesome feature is a  hairpin turn for traffic exiting the freeway:  I-5 traffic traveling southbound and leaving the freeway has to do a tight 210 degree turn onto Northbound Williams Avenue.  The proposed off-ramp would have two lanes of freeway traffic negotiating the hairpin turn on to N. Williams Avenue (shown as green arrows in this diagram).

Just a week ago we wrote a scathing critique of the Oregon Department of Transportation’s proposed redesign of the I-5 Rose Quarter project.  The agency is building a new and dangerous off-ramp, that creates a hairpin turn on a freeway exit, funnels traffic across a major bike route, and causes longer travel on local streets.  That’s pretty bad.

But the reality is much worse.  Don’t take our word for it.  Take ODOT’s.  Though its shrouded in intentionally opaque bureaucratic language, it’s clear that the engineers at OregonDOT know this is a very unsafe project.  And not just unsafe for bikes and pedestrians on local streets:  the new ramp configuration creates a dangerous, and higher crash rate facility for cars and trucks

The agency’s safety analysis is contained in a technical safety report, dated, August 15, 2022, but publicly released just last week.  It is worth quoting at length:

Under the HSM method, the number of crashes which may occur on a ramp is sensitive to geometric conditions, traffic volume, and length of the ramp. There are no major changes in geometry in the I-5 southbound exit ramp between the No-Build and Build conditions, hence they have similar forecast crash rates. However, as proposed in the Revised Build Alternative, relocating the I-5 southbound exit-ramp connection to the local system from N Broadway to NE Wheeler Avenue would increase the ramp length from approximately 1,000 feet in the No-Build conditions to approximately 2,000 feet in the Revised Build conditions, which would provide 1,000 feet of additional traffic queue storage. The new ramp design also includes wider shoulders than existing conditions. Based on the HSM, the forecast crash rate at this location would be approximately 13 % higher than the No-Build and Build condition. In the HSM, the number of crashes on a facility is highly sensitive to volume and length. As the length of this ramp increases, the forecast number of crashes increases and therefore so too does the crash rate. However, from a traffic operation perspective, the additional storage on the I-5 southbound exit-ramp would reduce the potential for queue spill-back onto the freeway. Under the No-Build Alternative, queue on the exit ramp is expected to propagate upstream onto the freeway mainline, creating a safety concern. The additional storage provided in the Revised Build Alternative would be able to accommodate the queue on the ramp without encroaching onto the freeway. This is particularly beneficial during peak hours and event conditions. In addition, the lengthening of the ramp will allow motorist to decelerate to a safer speed allowing them to safely navigate through the horizontal curve.

The final 250 feet of this ramp includes a horizontal curve prior to the ramp terminal intersection. The proposed curve would not meet ODOT’s HDM minimum radius for exit ramp curves and could also result in truck off tracking that extends outside of a standard travel lane. Therefore, to mitigate these considerations, the design detail of this curve would include wider shoulders and lanes than other sections of the ramp. Adequate delineation, signing, markings and lighting to inform drivers of the sharp curve as they approach the ramp terminal intersection would also be considered. These design treatments would be refined in the design process as the project proceeds. Figure 11 shows the existing N Williams Avenue/ NE Wheeler Avenue/ N Ramsay Way intersection and the lane configuration for the proposed I-5 southbound terminal.

There’s a lot to unpack here, and it’s written in a way as to be opaque and misleading.  Let us translate it into English:

• We’re building a freeway off-ramp with an extreme (210 degree) hairpin turn (“the final 250 feet . . . includes a horizontal curve”).
• That’s going to increase the number of crashes by 13 percent above doing nothing, and our previous design.
• The hairpin turn and crashes will cause traffic to back up on the freeway off-ramp and could jam the freeway, but don’t worry, because we’ve doubled the length of off-ramp (from 1,000 feet to 2,000 feet) so that it will be long enough to serve as a parking lot for those exiting the freeway (“queue on the exit ramp . . . additional storage”)
• The turn is so tight that trucks can’t negotiate it without crossing out of their lane, but don’t worry, because the shoulders will be wide, giving cars plenty of room to dodge wide-turning trucks.  “truck off tracking . . outside a standard travel lane”
• The hairpin turn is so severe that it violates our agency’s own standards for road design (the same standards we use to refuse to build bike lanes and provide pedestrian access). (“does not meet ODOT’s HDM minimum radius for exit ramp curves.”)
• We know the hairpin turn is dangerous, so we’ll think about putting in big warning signs and flashing lights. “Adequate delineation . . . to inform drivers . . .would be considered”).

More Dangerous, More Expensive, and Less Buildable

And there’s one more kicker that isn’t really mentioned here.  Because the I-5 southbound ramp is now Nouth of Broadway and Weidler, moving the ramp South requires that the freeway be widened even further to provide two ramp lanes that reach all the way to NE Wheeler and the MODA center.  Those lanes now have to go underneath Broadway and Weidler.  That means that the additional one-thousand feet of off-ramp length would mostly be underneath one of ODOT’s much ballyhooed highway caps.  In the diagram below, the two extended Southbound on-ramps are shown on the far left (with turquoise cars).

The proposed cost of the Rose Quarter project has tripled to nearly $1.45 billion, chiefly because of ODOT’s additional widening and the concomitant escalation in the cost of freeway caps. The caps are extraordinarily expensive, and their expense increases exponentially with added width.  Routing two thousand-foot long on-ramps under the structure increases the needed with of the structure by at least 30 feet, and likely more.  And that not only increases its cost, but the added width of the structure makes it more difficult to build a structure that could accommodate buildings.  (As we noted earlier, ODOT says this portion of the freeway caps could handle buildings no higher than three stories (and such buildings would have to be “lightweight.”)

We have rules against such things: but they don’t apply to us.

The safety report makes a cryptic reference to something called the “HDM”: saying the dangerous hairpin turn “does not meet ODOT’s HDM minimum radius for exit ramp curves.”  The “HDM” is Oregon’s Highway Design Manual that specifies all of the standards that govern the construction of major roadways and which sets the maximum radius of turns on roadways and off-ramps.  For obvious reasons, tight-corners and blind turns create serious safety hazards.  Freeway design standards are supposed to create roadways where crashes are less likely.  ODOT is proposing to simply ignore its own rules and build this dangerous on-ramp.

ODOT can’t even apply its standards consistently.  It asserts for example that it must build “full 12-foot” shoulders on much of the Rose Quarter project, ostensibly to improve safety.  But its design manual doesn’t require such wide shoulders, and in fact, the agency has gotten recognition from the Federal Highway Administration for its policies that allow narrower shoulders on Portland-area freeways.  In the same breath it touts widening shoulders (not required by its rules) as a safety measure, it gives itself an exemption from its own rules that explicitly prohibit dangerous hairpin turns on freeway off-ramps.

Transportation agencies routinely use their design manuals and similar rules to prohibit others from doing things.  We can’t build a crosswalk or a bike lane in that location, because it would violate our design manual.  That’s the end of a lot of safety improvements.  Just last week, in Seattle, the city transportation department had dawdled for years with an application to a paint a crosswalk at a dangerous local intersection, acted overnight to erase one painted by fed-up local neighbors–citing non-compliance with similar rules.

The redesign of the I-5 Rose Quarter project creates a hazardous new hairpin off-ramp from a Interstate 5

Is ODOT’s supposed “safety” project really creating a new “Deadman’s Curve” at the Moda Center?

Bike riders will have to negotiate on Portland’s busy North Williams bikeway will have to negotiate two back-to-back freeway ramps that carry more than 20,000 cars per day.

The Oregon Department of Transportation (ODOT) is moving forward with plans to issue a  Revised Environmental Assessment (EA) for the I-5 Rose Quarter Freeway widening, a $1.45 billion project pitched as “safety” project and “restorative justice” for the Albina neighborhood.

The revised assessment was required in part because community opponents, led by No More Freeways, prevailed in a lawsuit challenging the project’s original environmental assessment; the project’s earlier “Finding of No Significant Impact (FONSI) was withdrawn by the Federal Highway Administration).

We’ve obtained an advanced copy of the Revised EA, and while it shows expanded freeway covers—it’s also clear that ODOT is backing away from doing anything to assure development.  And in expanding the covers, the project has created an entirely new, and hazardous freeway off-ramp.

To expand the covers, ODOT has moved the Southbound off-ramp from I-5, which is now located just North of NE Broadway, to an area just next to the Moda Center, and immediately north of the existing I-5 south on-ramp.  The new ramp fits awkwardly into the existing street grid, and the most troublesome feature is a  hairpin turn for traffic exiting the freeway:  I-5 traffic traveling southbound and leaving the freeway has to do a tight 210 degree turn onto Northbound Williams Avenue.  The proposed off-ramp would have two lanes of freeway traffic negotiating the hairpin turn on to N. Williams Avenue (shown as green arrows in this diagram).

Could this become “Deadman’s Curve?” The mainline stem of I-5 has a design speed of 70 miles per hour, and the off ramp would force traffic to slow to 25 miles per hour (or less) to make the u-turn on to Williams.  Traffic exiting the freeway crosses a bike lane running along the west side of Williams Avenue (illustrated with red outlines on the diagram).

A similar low speed, hairpin exit ramp from the I-5 freeway in downtown Seattle has been the scene of a series of repeated and spectacular crashes, as documented on Youtube.

A hazard for people walking and biking.

The new Southbound off-ramp abuts an existing Southbound on-ramp at the intersection of Williams Avenue and Wheeler Street.  Williams Avenue is a major bike route from downtown to North Portland, and a bike lane runs along Williams, and would cross both these ramps.  The new configuration creates a traffic maelstrom at the intersection of Wheeler, Williams and the I-5 southbound on- and off-ramps.

At one point cyclists and pedestrians will have “refuge” on a tiny triangular island wedged in between a double-lane I-5 Southbound off-ramp (12,500 vehicles per day) and a double-lane I-5 Southbound on-ramp (9,000 vehicles per day).  On one side, they’ll have cars crossing Williams Avenue and accelerating on to the freeway, and on the other side, they’ll have cars coming off the freeway to negotiate the hairpin turn through the intersection on to Williams Avenue.  Green arrows show lanes of traffic entering and leaving the i-5 freeway.  White dots show the path of the bike route.  The red triangle at the center is the cyclists tenuous traffic refuge.

The Oregon DOT’s Revised EA claims that the project will make conditions better for bikes and pedestrians “on the covers”—but not necessarily elsewhere.  The Rose Quarter project website claims:

Relocating the I-5 southbound off-ramp will reduce interactions between vehicles exiting I-5 and people walking, rolling and biking along local streets on the highway cover.

Notice the qualifier here “on the highway cover.”  What this statement leaves out is the fact that the relocation of the off-ramp will dramatically increase interactions between vehicles and people on streets away from the cover, particularly and Williams and Wheeler.  The new combination of on- and off-ramps here will create many more dangerous interactions, especially for cyclists on Williams Avenue, something that the ODOT Environmental Assessment fails to acknowledge.

The I-5 Rose Quarter project is advertised by ODOT as a “safety” project:  People cycling through this maelstrom of freeway-bound traffic may not agree.

Thanks to Bike Portland for its extensive coverage of the bike and pedestrian problems associated with the Rose Quarter re-design.

What City Observatory did this week

In the News

Bike Portland featured City Observatory’s analysis of the I-5 Rose Quarter project in its story on the release of the Oregon Department of Transportation’s Supplemental Environmental Impact Statement.  The public will have until January 4, to provide comments; It appears ODOT has strategically timed the comment period to overlap the holidays to squelch public input on the project.

The Week Observed, and our regular features (Must Read and New Knowledge) will return in December.  Happy Thanksgiving to all.

What City Observatory did this week

Risky bridges.  The Oregon and Washington highway departments are blundering ahead with a $5 billion plan to widen I-5 between Portland and Vancouver, and are making many of the same mistakes they made with the failed Columbia River Crossing a decade ago.  A key difference: last time, there was some adult supervision of the DOTs:  A series of independent, outside experts looked at the project’s engineering and financial details, and found serious errors that needed to be fixed.  The project was delayed because the “open-web” design proposed by state DOTs was found to be unbuildable.  Similarly, outside financial consultants found that toll levels would need to be doubled to pay for a portion of the project.  The revived project hasn’t been subjected to any independent, outside review, yet state and federal authorities are being asked to sign a virtual blank check for this project.  You’d insist on getting an independent, professional inspection before buying a used car or an old house:  Oregon and Washington legislators would be well advised to get similar advice before spending billions.

State DOT misrepresents the Coast Guard Bridge Permit Approval Process.  Two Oregon DOT officials testified to the Legislature that their proposed $5 billion I-5 Bridge Replacement was grandfathered under more old Coast Guard regulations and didn’t have to comply with more stringent rules adopted since the Columbia River Crossing debacle.  The Coast Guard has stated that the new project must meet the new rules, which include addressing the project’s navigation clearance prior to the Environmental Impact Statement.

While state highway officials have claimed that the Coast Guard’s June 2022 preliminary determination that the new bridge would have to have a 178 foot vertical navigation clearance was just an early draft, Coast Guard regulations–that the US DOT has agreed to–make it clear that the determination is meant to exclude non-complying alternatives from inclusion in the EIS, and that the two highway agencies are proceeding “at their own risk” if they submit a design that doesn’t comply.

Must read

Mitigation for freeway widening through cities is lipstick on a pig.  We highlight another tweet-storm from Center for American Progress transportation expert Kevin DeGood.  He looks at how Texas DOT is proposing to offset the damage its multi-billion dollar I-45 freeway project will do to Houston neighborhoods.  The freeway will demolish 1,000 homes, 300 businesses and 2 schools and other facilities.  TxDoT claims it will remedy these harms with some public space (freeway covers, an “event lawn”).  While those are nice amenities, they don’t remedy the damage done to these neighborhoods, DeGood points out:

Neighborhood connectivity and Improving pedestrian and bike facilities is great. It’s also not a meaningful remedy for the harms of the NHHIP (the I-45 highway widening project).

Not only that, but the plan is to have the municipal government rather than the highway department bear the costs of what are advertised as “reparations.”  Again, DeGood:

And how does Central Houston envision paying for these improvements? Tax increment financing (TIF).
Question.
Why should locals shoulder the cost burden to remedy harms created by TxDOT? Shouldn’t TxDOT pay for TxDOT-caused harms?

Simply constructing amenities atop a freeway doesn’t undo the harm done by the wholesale demolition of neighborhoods, or the creation of car-dominated toxic environments around freeways.

The highway building lobby aims to capture the “Reconnecting Communities” program.  As we all know, urban highways have devastated city neighborhoods around the country.  A tiny part of last year’s infrastructure bill dedicated a billion dollars to try and repair that damage.  It could be a source of funding to remove roadways and restore neighborhoods.  But around the country, state DOTs are scheming to use the money to widen or expend highways.  As Streetsblog explains:

Perversely, some agencies are even attempting to expand highways using the program’s funds — while using nominal equity improvements as political cover to justify the additional lanes.

It calls out two projects as particularly egregious: The Oregon Department of Transportation’s Rose Quarter I-5 freeway project, which could as much as double freeway traffic.  Another project in Tulsa calls for a study that would “widen underpasses” for Interstate 244, the roadways the ultimately destroyed the cities famous Black Wall Street district.  “Reconnecting communities” shouldn’t turn out to be a “crime victims compensation” fund that gives the money to the criminals, but that is exactly what could be happening.

In the News

City Observatory’s analysis of the convoluted and dangerous new off-ramp design for the I-5 Rose Quarter project was featured in Bike Portland.

What City Observatory did this week

Risky bridges: If you’re going to spend several billion dollars, you might want to get some independent expert advice.  Oregon and Washington are on the verge of committing 5 billion dollars to the construction of the so-called I-5 “Interstate Bridge Replacement” project between Portland and Vancouver.  But they’re doing so largely on the word of the two state transportation departments.

They should have learned from their experience a decade ago when the same project, then pitched as the Columbia River Crossing, failed, despite being subjected to four different independent reviews. This time, there hasn’t been any independent engineering review, like the 2011 panel that showed the planned CRC “open web” design was unbuildable.  And the IBR advocates have steadfastly refused to conduct an independent toll analysis, like the one that showed the CRC would require vastly higher tolls than advertised, and that traffic on the giant new bridge would be permanently lower than the smaller bridge it replaced.  It isn’t prudent to commit to a billion dollar project without seeking unbiased expert advice.

Must read

This week we highlight some images that you may have seen on Twitter.  The Missouri Department of Transportation celebrated the 50th Anniversary of Kansas City’s downtown loop.  But is it a loop . . . or a noose?  The kickoff to this conversation was MoDot’s map of the downtown.

Urbanist twitter wasn’t as excited.  Hayden Clarkin constructed this map showing how much of the city’s downtown was converted to garages (green) or surface parking lots (yellow).  City government spent several hundred million dollars in tax increment financing on subsidizing the construction of downtown parking garages).  The flourishing of parking lots and garages coincided with the construction of area freeways, including the loop.

The net result was that the dense, vibrant Kansas City that existed a century ago has been, in many places, simply eradicated.  These following pictures show approximately the same view of a downtown Kansas City street in in 1893 (before the automobile or freeways) and today.

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Visualizing the city of the future.  Noah Smith publishes a guest column by Alfred Twu with some inspiring and delightful images of what our cities could be like.  Too much of the debate about housing and urbanism revolves around arcane statistics (floor area ratios), inscrutable zoning regulations, or tribal posturing by NIMBYs or YIMBYs.  Its refreshing to show what kind of future our cities might have.  Here’s just one such illustration.

As Smith emphasizes, Twu offers an evolutionary vision of how our current cities could change and adapt to better meet the needs of a changing population and the challenges of climate change and economic transformation.  Twu writes:

The city of tomorrow has many familiar streets and sights of the city of today – after all, it’s a remodel, not a rebuild. While other countries have the option of building new cities or neighborhoods beyond the edge of existing ones, the US already used up most land within commuting distance in the 20th century on low density suburbs. Most of us will live in places that already exist today, but with changes.

Being explicit about the images of the kind of places we want to have is something that needs to play a much larger part in debates about planning, housing, and urbanism.

New Knowledge

Micro-mobility reduces traffic congestion and speeds travel times.  The advent of shared micro-mobility (bikes, e-bikes and e-scooters) has added to the range of urban transportation options.  Most see micro-mobility as a green transportation mode, but skeptics worry that micro-mobility may be largely attracting riders from among existing transit, bike and walking trips, rather than reducing car travel.

Teasing out the net effect of micro mobility on urban transportation typically relies on surveys asking scooter or bike users how they would travel if these options weren’t available, but such studies are often inconclusive.  Some relatively abrupt policy changes to micro-mobility regulation in Atlanta created some natural experiments that researchers were able to harness to estimate the impact of micro-mobility on traffic.  Atlanta officials adopted restricted hours for some e-scooters, banning their use between 9 pm and 4 am.  By looking at changes in traffic speeds before and after the restrictions, the researchers were able to estimate how traffic speeds changed.  Using traffic speed data provided by Uber, the researchers were able to track how travel times in key neighborhoods changed after the ban.  Here are two charts illustrating their findings.

The right panel shows the increase in travel times (in additional minutes per mile) for the curfew in Atlanta’s midtown area, while the right hand panel shows the effect of same policy in areas around MARTA transit hubs. In both cases, travel times in the affected areas (measured in minutes per mile traveled) increased–meaning travel was slower without the availability of micro-mobility devices.  This change represented about a 10 percent increase in typical commute times and a 37 percent increase in travel times during major events.

We find that after about a week, users partially account for the policy change in their travel planning and habits. This behavioural response suggests that as riders pivoted from micro-mobility devices back to personal cars or ridesharing, the congestion effect following the ban stabilizes to a mean treatment effect of 0.25 minutes per mile after five weeks

While this study adds strong evidence that micro-mobility does reduce car trips, there’s a deeper issue that is overlooked:  By their nature, micro-mobility trips add to and enrich the accessibility of urban spaces.  By giving people more choices, especially non-car choices, micro-mobility is and enhancement and amenity to urban spaces.  Making urban living, consumption and experiences more accessible and attractive likely helps increase density and lowers overall trip making and vehicle miles traveled.  The “substitution” argument is implicitly a “lump of travel” fallacy:  assuming that there is a fixed and pre-ordained amount of trips to be made, and that providing additional modes only re-distributes travel among other modes.  The reality is more nuanced and complex, especially in the long run:  If the availability of micro-mobility makes urban living more attractive, more people are likely to live in cities, and ultimately own fewer cars and drive less.  Its these long-term, second- and third-order effects of expanded transportation options that deserve our close attention.

Asensio, O.I., Apablaza, C.Z., Lawson, M.C. et al. Impacts of micro-mobility on car displacement with evidence from a natural experiment and geofencing policy. Nat Energy (2022). https://doi.org/10.1038/s41560-022-01135-1

(Hat tip to the prolific David Zipper!)

State DOT officials have crafted an Supplemental Environmental Assessment that conceals more than it reveals

The Rose Quarter traffic report contains no data on “average daily traffic” the most common measure of vehicle travel

Three and a half years later and ODOT’s Rose Quarter’s Traffic Modeling is still a closely guarded secret

The new SEA makes no changes to the regional traffic modeling done for the 2019 EA, which was done 7 years ago in 2015

The report misleadingly cites “volume to capacity ratios” without revealing either volumes or capacities

ODOT has violated its own standards for documenting traffic projections, and violated national standards for maintaining integrity of traffic projections.

In theory, the National Environmental Policy Act is all about disclosing facts. But in practice, that isn’t always how it works out. The structure and content of the environmental review is in the hands of the agency proposing the project, in this case the proposed $500 million widening of the I-5 Rose Quarter freeway in Portland. The Oregon Department of Transportation and the Federal Highway Administration have already decided what they want to do: Now they’re writing a set of environmental documents that are designed to put it in the best possible light. And in doing so, they’re keeping the public in the dark about the most basic facts about the project.  In the case of the I-5 project, they haven’t told us how many vehicles are going to use the new wider freeway they’re going to build.

A traffic report without ADT is like a financial report without $

To take just one prominent example, the Project’s “Traffic Technical Report” which purports to discuss how the traffic will affect the flow of vehicles on the freeway—which after all, is the project’s purpose–conspicuously omits the most common and widely used metric of traffic volume:  average daily traffic or ADT.

How common is ADT?  It’s basically the standard yardstick of describing traffic. ODOT uses it to decide how wide roads should be.  It’s the denominator in calculating road safety. Average daily traffic is also, not incidentally, the single most important variable in calculating how much carbon and other air pollutants cars will emit when they drive on this section of road. ODOT maintains a complicated system of recording stations and estimation, tracking traffic for thousands of road segments on highways. ODOT’s annual report,  Traffic Volume Trends details average daily traffic for about 3,800 road segments statewide.  It also turns out that predicted future ADT is an essential input into the crash modeling software that ODOT used to predict crash rates on the freeway (“ADT” appears 141 times in the model’s user manual). ODOT uses ADT numbers throughout the agency: Google reports that the Oregon DOT website has about 1,300 documents with the term “ADT” and nearly 1,000 with the term “average daily traffic.” Chapter 5 of ODOT’s Analysis Procedure Manual, last updated in July 2018, contains 124 references to the term “ADT” in just 55 pages. “Average daily traffic” as fundamental to describing traffic as degrees fahrenheit is to a weather report.

Three and a half years ago, we searched through the original “traffic analysis technical report” prepared for the Rose Quarter project.  It had absolutely no references to ADT:  The Rose Quarter I-5 Traffic Analysis Technical Report.  We searched the PDF file of the report for the term “ADT”—this was the result:

ODOT just made public its “Traffic Analysis Supplemental Technical Report” for the Rose Quarter project’s Supplemental Environmental Assessment.  We repeated our experiment and found . . . still no references to average daily traffic:

ADT is just the very prominent tip of much larger a missing data iceberg.  There’s much, much more that’s baked in to the assumptions and models used to create the estimates in the report that simply isn’t visible or documented anywhere in the Environmental Assessment or its cryptic and incomplete appendices.  The advocacy group No More Freeways have identified a series of documents and data series that are missing from the report and its appendices, and has filed a formal request to obtain this data. In March, 2019, just prior to the expiration of the public comment period, ODOT provided fragmentary and incomplete data on some hourly travel volumes, but again, no average daily traffic data. The new traffic technical report does not contain this data or updates of it.

No New Regional Modeling

The Traffic technical report makes it clear that ODOT has done nothing to update the earlier regional scale traffic modeling it did for the project.  ODOT claims it used Metro’s Regional Travel Demand Model to generate its traffic forecasts for the i-5 freeway—but it has never published that models assumptions or results.  And in the three years since the original report was published, it has done nothing to revisit that modeling.  The traffic technical report says:

. . . the travel demand models used in the development of future traffic volumes incorporated into the 2019 Traffic Analysis Technical Report are still valid to be used for this analysis.

In its comments on the 2019 EA, a group of technical experts pointed out a series of problems with that modeling.  Because ODOT made no effort to update or correct its regional modeling, all of those same problems pervade the modeling in the new traffic technical report.

Hiding results

The supplemental traffic analysis presents its results in a way that appears designed to obscure, rather than reveal facts.  Here is a principal table comparing the No-Build and Build designs.

x

Notice that the tables do not report actual traffic volumes, either daily (ADT) or hourly volumes.  Instead, the table reports the “V/C” (volume to capacity) ratio.  But because it reveals neither the volume, nor the capacity, readers are left completely in the dark as to how many vehicles travel through the area in the two scenarios.  This is important because the widening of the freeway increases roadway capacity, but because ODOT reveals neither the volume nor the capacity, it’s impossible for an outside observer to discern how many more vehicles the project anticipates moving through the area.  This, in turn, is essential to understanding the project’s traffic and environmental impacts.  It seems likely that the model commits the common error of forecasting traffic volumes in excess of capacity (i.e. between I-84 and Weidler) in the No-Build.  As documented by modeling expert Norm Marshall, predicted volumes in excess of capacity are symptomatic of modeling error.

ODOT is violating its own standards and professional standards by failing to document these basic facts

The material provided in the traffic technical report is so cryptic, truncated and incomplete that it is impossible to observe key outputs or determine how they were produced.  This is not merely sloppy work. This is a clear violation of professional practice in modeling.  ODOT’s own Analysis Procedures Manual (which spells out how ODOT will analyze traffic data to plan for highway projects like the Rose Quarter, states that the details need to be fully displayed:

6.2.3 Documentation

It is critical that after every step in the DHV [design hour volume] process that all of the assumptions and factors are carefully documented, preferably on the graphical figures themselves. While the existing year volume development is relatively similar across types of studies, the future year volume development can go in a number of different directions with varying amounts of documentation needed. Growth factors, trip generation, land use changes are some of the items that need to be documented. If all is documented then anyone can easily review the work or pick up on it quickly without questioning what the assumptions were. The documentation figures will eventually end up in the final report or in the technical appendix.

 The volume documentation should include:

• Figures/spreadsheets showing starting volumes (30 HV)

• Figures/spreadsheets showing growth factors, cumulative analysis factors, or travel demand model post-processing.

• Figures/spreadsheets showing unbalanced DHV

• Figure(s) showing balanced future year DHV. See Exhibit 6-1

• Notes on how future volumes were developed:

    o If historic trends were used, cite the source.

    o If the cumulative method was used, include a land use map, information that documents trip generation, distribution, assignment, in-process trips, and through movement (or background) growth.

o If a travel demand model was used, post-processing methods should be specified, model scenario assumptions described, and the base and future year model runs should be attached

This is also essential to personal integrity in forecasting.  The American Association of State Highway and Transportation Officials publishes a manual to guide its member agencies (including ODOT) in the preparation of highway forecasts.  It has specific direction on personal integrity in forecasting.  National Cooperative Highway Research Project Report, “Analytical Travel Forecasting Approaches for Project-Level Planning and Design,”  NCHRP Report #765—which ODOT claims provides its methodology— states:

It is critical that the analyst maintain personal integrity. Integrity can be maintained by working closely with management and colleagues to provide a truthful forecast, including a frank discussion of the forecast’s limitations. Providing transparency in methods, computations, and results is essential. . . .  The analyst should document the key assumptions that underlie a forecast and conduct validation tests, sensitivity tests, and scenario tests—making sure that the results of those tests are available to anyone who wants to know more about potential errors in the forecasts.

ODOT:  A history of hiding facts from the public

This shouldn’t come as a surprise to anyone who has followed the Rose Quarter project. ODOT staff working on the project went to great lengths to conceal the actual physical width of the project they are proposing to build (it’s 160 feet wide, enough for a 10 lane freeway, something they still don’t reveal in the new EA, and which they don’t analyze in the traffic report).  And an Oregon judge found that ODOT staff violated the state’s public records law by preparing a false copy of documents summarizing public comments on the Rose Quarter project.  ODOT falsely claimed that a peer review group validated its claims that the project would reduce air pollution; the leader of that group said ODOT hadn’t provided any information about the travel modeling on which the pollution claims were based, and that the group couldn’t attest to their accuracy.

This kind of distortion about traffic modeling has a long history:  the Oregon Department of Transportation has previously presented flawed  estimates of carbon emissions from transportation projects.  During the 2015 Oregon Legislature, the department produced estimates saying that a variety of “operational improvements” to state highways would result in big reductions in carbon.  As with the Rose Quarter freeway widening, the putative gains were assumed to come from less stop and go traffic. Under questioning from environmental groups and legislators, the department admitted that its estimates of savings were overstated by a factor of at least three. ODOT’s mis-representations so poisoned the debate that it killed legislative action on a pending transportation package. What this case demonstrates is that the Oregon Department of Transportation is an agency that allows its desire to get funds to build projects to bias its estimates. That demonstrated track record should give everyone pause before accepting the results of an Environmental Assessment that conceals key facts.

Not presenting this data as part of the Environmental Assessment prevents the public from knowing, questioning and challenging the validity of the Oregon Department of Transportation’s estimates. In effect, we’re being told to blindly accept the results generated from a black box, when we don’t know what data was put in the box, or how the box generates its computations.

This plainly violates the spirit of NEPA, and likely violates the letter of the law as well.  Consider a recent court case challenging the environmental impact statement for a highway widening project in Wisconsin. In that case, a group of land use and environmental advocates sued the US Department of Transportation, alleging that the traffic projections (denominated, as you might have guessed, in ADT) were unsubstantiated.  The US DOT and its partner the Wisconsin Department of Transportation (WisDOT) had simply provided the final outputs of its model in the environmental report–but had concealed much of the critical input data and assumptions. A federal judge ruled that the failure to disclose this information violated NEPA:

Statistical errors are common and can easily lead to wrong conclusions

Maybe, just maybe, the Oregon Department of Transportation has a valid and accurate set of data and models. But absent disclosure, there’s no way for any third party to know whether they’ve made errors or not.  And, even transportation experts, working with transportation data, can make consequential mistakes. Consider the recent report of the National Highway Traffic Safety Administration (another arm of the US Department of Transportation) which computed the crash rate for Tesla’s cars on autopilot.  In a report released January 2017, NHTSA claimed that Tesla’s autopilot feature reduced crashes 40 percent.

That didn’t sound right to a lot of transportation safety experts, including a firm called Quality Control Systems. They asked NHTSA for the data, but were unable to get it, until the agency finally complied with a Freedom of Information Act (FOIA) request two years later.  The result:  NHTSA had made a fundamental math error in computing the number of vehicle miles traveled (which is actually an analog of Average Daily Traffic).  Rather than being relatively safe, the corrected calculation showed that the auto-pilot feature is significantly more dangerous that the average of all human drivers.

What QCS found upon investigation, however, was a set of errors so egregious, they wrecked any predictive capability that could be drawn from the data set at all. In fact, the most narrow read of the most accurate data set would suggest that enabling Autosteer actually increased the rate of Tesla accidents by 59 percent.

A government agency hiding key data is putting the public behind the 8-ball

Without the opportunity to look at the data, there’s no way for anyone to check to see if ODOT has made a mistake in its calculations. A black box is no way to inform the public about a half billion dollar investment; you might say, it put us behind the 8-ball. It makes you wonder:  What are they hiding?

Appendix:  Expert Panel Critique of Rose Quarter Modeling

RQ Model Critique