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ODOT: Our I-5 Rose Quarter safety project will increase crashes

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 Rose Quarter’s Big U-Turn: Deadman’s Curve?

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).

The I-5 Rose Quarter redesign adds a double lane hairpin curve to the I-5 south off ramp. Deadman’s Curve?

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.

I-5 South Bound Off Ramp in Seattle (Youtube Video)

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.


Bike route (white dots) crosses multiple freeway on- and off-ramps.  There is a small, “refuge” (red triangle) in the middle of these multi-lane freeway ramps

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.


ODOT reneges on Rose Quarter cover promises

The soon-to-be released Rose Quarter I-5 Revised Environmental Assessment shows that ODOT is already reneging on its sales pitch of using a highway widening to heal Portland’s Albina Neighborhood.

It trumpeted “highway covers” as a development opportunity, falsely portraying them as being covered in buildings and housing—something the agency has no plans or funds to provide.

The covers may be only partially buildable, suitable only for “lightweight” buildings, and face huge constraints.  ODOT will declare the project “complete” as soon as it does some “temporary” landscaping.  The covers will likely be vacant for years, unless somebody—not ODOT—pays to build on them.

ODOT isn’t contributing a dime to build housing to replace what it destroyed, and its proposed covers are unlikely to ever become housing because they’re too expensive and unattractive to develop.

For years, OregonDOT has been pitching its plan to widen the Interstate 5 freeway through Northeast Portland as a way of repairing the damage it did when it built the freeway through the state’s largest African-American neighborhood in the 1960s.  In theory, freeway covers would provide building sites, for things such as housing.  But there are real questions as to whether ODOT is serious, or whether the covers are deceptive “woke-washing” of the freeway widening.

In the past few days, we have obtained a copy of the soon-to-be released Revised Environmental Assessment for the I-5 Rose Quarter Freeway widening, a $1.45 billion project pitched as “restorative justice” for the Albina neighborhood.  The revised assessment was required because of the project’s substantial redesign in the past two years and  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).

The Revised Environmental Assessment shows that the covers are, at best, a half-baked policy.  Though ODOT has enlarged the size of the covers under its new “Hybrid 3” alternative, it is now making it clear that it won’t do anything to pay the costs of actually building anything permanent on top of the covers.  Instead, that task—and its funding—will be left to some unspecified future time, to be led and paid for by the City of Portland.  This is clear evidence of the hollowness of ODOT’s promises of restorative justice:  they have no commitment to seeing anything actually gets built on these highway covers.

Promises, promises:  A history of misleading images of developed highway covers

ODOT has repeatedly traded on the idea that the Rose Quarter wasn’t so much a freeway as a reparations project.  It has consistently published fictional images of possible housing, commercial buildings, offices and community centers on top of the freeway covers.  ODOT consultants touted the importance of building housing to restore community wealth.  For example, its study of the “Hybrid 3” alternative depicted hundreds of housing units, and buildings housing important community facilities on top of covers.  ODOT’s promotional material, mailed to every household in the project area, prominently featured a fictional “Career Development Center” atop a highway cover—but no illustration of the freeway it intended to widen.  (The brochure itself was replete with typos and misspellings, as well as purely imaginary  and unfunded buildings).

An ODOT Rose Quarter Project Brochure:  A young Black man stands in front of a building labeled a “Career Development Center,” carrying a plaque stating:  “This building constructed by Black artisans in 2022.”  It’s a nice thought, but such a building is not part of what ODOT will build or pay for.  Nor, in fact, are any of these buildings.

ODOT’s highway cover consultants created the illusion that apartment buildings (the yellow legos on this diagram) might be part of the project’s covers. Building such apartments would cost between $160 million and $250 million, and ODOT is providing no funding for any such construction.



Housing and other improvements have disappeared from the new Environmental Assessment

In its revised Environmental Assessment the Oregon Department of Transportation is finally conceding that it isn’t going to do anything to actually build something on the covers.  The pictures of lego housing, wireframe multi-story buildings and “career development centers” it has featured in earlier public relations materials have been erased.  In their place is a vague, impressionistic watercolor illustration, and some evasive bureaucratic prose indicating that somebody else, not ODOT, will actually develop the covers—maybe, someday.

ODOT’s already making it clear that they’re not providing a dime to build anything on the covers, and that they expect the City of Portland to pay.  What ODOT’s planning are covers with a side of greenwash:  They have an artists illustration of the covers with some landscaping and a revealing caption:  Artistic rendering reflects a potential immediate use of the cover should future development led by the City not be ready upon project completion.

Revised Environmental Assessment

They elaborate on this in the text of the Revised Environmental Assessment

ODOT anticipates programming interim uses on the highway cover for the time period between Project completion and when the City-led development process would be implemented

The “interim uses” include a laundry list  of possibilities:  landscaping, plazas, picnic areas, signs and other temporary items which would be removed at some unspecified future time.
Here’s what this means:

  1. ODOT doesn’t anticipate constructing anything permanent on the covers
  2. Even this illustrated use is only an artist’s rendering, not something ODOT is committing to do.
  3. There is no timetable for actual development on the covers
  4. Development and financing said development is up to the city, not ODOT
  5. ODOT regards project completion as occurring when the covers are built:  the buildings on the covers are not part of the project.

Residents of Albina should be familiar with this “somebody else will take care of this later” approach to restoring the neighborhood.  In the 1970s, the city’s urban renewal agency demolished parts of the neighborhood including the commercially vibrant Hill block, for the possible future expansion of Emmanuel Hospital.  For nearly four decades, that block has stood vacant.  A city process begun in 2017 has yet to yield a definitive plan, and the block remains in an “interim” use.  No one should doubt that the same fate awaits the un-funded and difficult to develop freeway covers, if they are ever built.

Not so buildable after all

ODOT has promised that the covers will be buildable, but the Environmental Assessment has a lot of conditions and caveats as to what constitutes “buildable.”  Only a portion of the project would be suitable for buildings taller than 3 stories.  And any buildings anywhere on the covers would be highly constrained.
For example, blocks at the south end of the cover (shaded blue) which could theoretically hold “lightweight” six story buildings are all bisected by busy traffic streets (Broadway, Weidler, Vancouver & Williams).  The cover at the North end of the project (bordered by Flint & Hancock, the two lower traffic streets) is suitable only for 3-story max buildings (and even these also have to be “lightweight”).  Nothing in the Environmental Assessment defines a “lightweight” building.  The caveats also make it clear that building six story buildings would require additional “modifications to bridge type and roadway profiles.”  There’s no indication that these changes would be undertaken as part of the Rose Quarter project.
As a result of these limitations and constraints, the covers themselves will likely be difficult or prohibitively expensive to build anything on.  The text accompanying the report acknowledges that while these structures might somehow be able to support multi-story buildings, it won’t be easy.

The highway cover would be designed to accommodate future multi-story buildings.  Due to span length and site constraints, design would constrain building size, location, type, and use on portions of the cover. Figure 2-7 shows the cover  parameters. Generally, buildings up to three stories could be accommodated throughout the highway cover. Buildings of up to six stories could be accommodated, with strict design constraints, . . .

So, in theory, you could build some kind of multi-story building, but it might have to be small, it couldn’t be built just anywhere on the cover, some kinds of buildings and uses wouldn’t be allowed, plus the building would have to be “lightweight”—whatever that means—and all this would be subject to “strict design constraints.”  But none of this is ODOT’s problem, because it isn’t going to fund or build anything permanent on the covers.

Covers don’t restore the neighborhood

ODOT is trying to peddle the false notion that simply decking over a widened freeway will somehow offset the damage that the freeway has done to Albina.  It won’t.  The covers themselves are likely to be too expensive and too unattractive as building sites.  No one will want housing in the middle of a car-choked intersection.

What ODOT’s framing misses is that what destroyed the neighborhood was not merely the construction of the freeway, but the flood of vehicles it produced.  Prior to the construction of the freeway there were hundreds of houses, and that the gridded, walkable fabric of Albina was very much intact.  It wasn’t simply the the roadway and overpasses that transformed the area, it was the flood tide of car traffic that rendered much of the area inhospitable to residential inhabitation.  As we’ve documented at City Observatory, these ODOT highway projects led to the loss of hundreds and hundreds of housing units and led to a decline in population in Albina from more than 14,000 in 1950 to about 4,000 in 1980. This is part of a national pattern in which freeway building led to the systematic depopulation of urban neighborhoods.  Abundant research now shows that building freeways kills urban neighborhoods–and not just by demolishing housing, but by creating car-dominated landscapes:  the closer your city neighborhood is to a freeway the more population it lost in the last half century.  And because ODOT isn’t contributing a dime to actually build any housing, they’re depending on the city or private developers to build housing.  This project doesn’t add anything to their interest or ability to provide housing.  The neighborhood is not limited by a lack of vacant or greatly under-utilized land.  Adding a couple blocks of enormously expensive and difficult to develop land in an unattractive location does almost nothing to change how much housing will be built in Albina.

No one should imagine that the Oregon Department of Transportation is anything other than a group of woke-washing grifters.  Their only real interest in the Rose Quarter is widening the roadway, not repairing the massive damage they did to the neighborhood.  A bare-bones, barely buildable freeway cover does essentially nothing to eliminate the real harm inflicted here:  the eradication of hundreds of housing units and the transformation of a dense-walkable  urban neighborhood into a car-dominated landscape.  That won’t change under this ODOT plan.

Highway officials misrepresent Coast Guard permit requirements

The Interstate Bridge Project falsely claimed to a legislative committee that the USDOT/Coast Guard agreement on bridge permits doesn’t apply to the IBR project.

This is part of a repeated series of misrepresentations about the approval process for bridges and the impact of the Coast Guard’s preliminary navigation determination that a new crossing must provide 178 feet of vertical clearance.

The Coast Guard’s determination is not a mere draft; under USCG regulations—agreed to by USDOT—the effect of the determination is “ruling out any alternatives that will unreasonably obstruct navigationprior to the preparation of an Environmental Impact Statement.

IBR officials have failed to acknowledge that under the USDOT/USCG agreement, they are “proceeding at their own risk” by advancing an alternative that doesn’t provide 178 feet of clearance.

IBR’s plan is to advance only a single alternative, a fixed, 116 foot clearance bridge, and not to submit any alternatives that comply with the Coast Guard’s determination, and to dare the Coast Guard to not approve the DOTs preferred design.  This is the same blackmail strategy that led to years of delay, tens of millions in added costs, and a bridge re-design for the failed Columbia River Crossing. 

US Coast Guard: Protecting America’s Waterways

IBR:  Misleading Statements about the Coast Guard Approval Process

IBR officials have repeatedly made misleading statements about the nature of the Coast Guard determination.  They always emphasize that the Coast Guard’s action is “preliminary”—and never note that the purpose of the preliminary determination is to eliminate un-approvable options from NEPA review.  IBR officials never mention that under the Coast Guard/USDOT agreement that they are “proceeding at their own risk” by advancing alternatives that don’t comply with the Coast Guard’s 178 foot preliminary determination.

And they’ve made it clear that they plan to execute the same blackmail strategy as they did a decade ago with the Columbia River Crossing (CRC), by only advancing one alternative with a 116 foot fixed span.  IBR officials have also falsely implied that the Federal Aviation Administration also regulates bridge heights (it doesn’t; it can only require warning lights on tall structures).  They’ve also mis-represented US Coast Guard approval standards, implying that the Coast Guard’s permitting decision will somehow be required to balance the needs of highway users with those of river users (that’s wrong:  the Rivers and Harbors Act gives priority to water navigation).  They’ve also implied that the Coast Guard can be placated if the IBR project pays off existing river users (the Coast Guard’s navigation determination is based on preserving navigation for future uses).

IBR officials misled the Oregon Legislature

These questions about the Coast Guard’s approval process came up at a recent hearing in Salem.  State Representative Khanh Pham asked IBR officials whether the Coast Guard USDOT agreement required them to resolve the navigation height prior to the advancing to a revised Environmental Impact Statement.

On September 23, 2022, Greg Johnson and Ray Mabey testified to the Oregon Legislature’s Joint Transportation Committee that the Interstate Bridge Replacement project was not subject to the new 2014 Coast Guard MOU/MOA on procedures for approval, because it was an extension of the previously permitted Columbia River Crossing project.  Essentially, they implied that it was “grandfathered” under the previous regulatory requirements.  Here’s a machine-generated transcript of that hearing:

Representative Pham:

So I just wanted to clarify my question, because maybe it wasn’t as clear before, and I don’t feel like it was answered. So my question is, doesn’t the memorandum of agreement between the Coast Guard and the Federal Highway Administration require that we resolve this issue before we start the EIS process?
Greg Johnson (IBR Administrator):
It does not. We are we are working with our federal partners. The Federal Highway Administration, as well as Federal Transit Administration are at the table with us. We meet with them weekly. They have signed off on the process that we are in and talking to the Coast Guard so we are not in violation of federal rules or federal processes.
Ray Mabey:
Mr. Johnson, Representative Pham, Rep McClain, if I may,  Ray Mabey, Assistant Program Administrator for the Interstate Bridge Replacement Program,  Yes, that MOU and MOA that was created between the Coast Guard and FHWA, and FTA actually addresses new projects that are entering into the NEPA process. It does not address projects that are midstream that have an existing record of decision that are going through a supplemental and so that’s why we’re continuing to have that dialogue with the Coast Guard and our federal partners and adapting our program into that process as best we can. But yes, it did. We are not held to that same standard, but that’s why we have those ongoing dialogues with them. We know that the previous permit that we achieved, was contingent on a couple of things and that was successful agreements with the impacted users. The Coast Guard has shared with us that they believe that would be another way to achieve a permit contingent upon those agreements as well. So we think we have a path forward. And like Administrator Johnson mentioned, we are entering into dialogue with those impacted users as we speak.

(Emphasis added).

The Coast Guard has a very different view of what is required, and has said so publicly. In a recent article in the Vancouver Columbian, the Coast Guard’s regional bridge administrator explained that contrary to the IBR staff claims the revived project is subject to an entirely new process, and isn’t somehow “grandfathered” under the previous requirements.

The U.S. Coast Guard has authority over the Columbia River and other navigable waterways, with free-flowing river traffic given top priority, and a late-developing conflict over bridge heights was one of the final complications that helped scuttle the project nearly a decade ago.

Officials have learned from the experience.

“The (old) process asked critical navigation questions too late in the process,” said Steven Fischer, Coast Guard District 13 bridge administrator. “The new process gets all those navigation questions answered up front before they even submit an application.”

That new process was implemented in 2014, the year after the Columbia River Crossing fell apart. It came in the form of a memorandum of agreement between the Coast Guard and the Federal Highway Administration to coordinate and improve bridge planning and permitting.

(Emphasis added)

The basis for the Coast Guard’s statement is contained in two 2021 letters between the Coast Guard and US DOT officials which confirm that the IBR project would have to apply for an entirely new bridge permit under the newly adopted 2014 MOU/MOA.  An October 13, 2021 letter from the commander of the 13th Coast Guard District, Rear  Admiral M. W. Bouboulis, informed the USDOT that:

In accordance with the MOU, it is the responsibility of the Department of Transportation Operating Administration to prepare a Navigation Impact Report (NIR) for USCG review prior to or concurrent with the National Environmental Policy Act (NEPA) scoping process. The NIR informs a USCG Preliminary Navigation Clearance Determination (PNCD), which informs the applicant’s NEPA alternatives by ruling out any alternatives that will unreasonably obstruct navigation.
[Emphasis added]
Rear Admiral Bouboulis added:
. . . we want to ensure the IBR team understands the changes to the USCG bridge permit process since the 2012 Columbia River Crossing (CRC) project and understands a new bridge permit application must be submitted in accordance with the 2016 BPAG.
In reply on November 23, 2021, the two federal partners representing the FHWA and FTA, replied that they agreed with this determination, writing:
As the federal co-leads, we are committed to working with the USCG and the IBR Team to ensure USCG requirements and the processes and procedures outlined in the above referenced MOU and MOA are met.

These two letters make it clear that Johnson and Mabey’s claims that the MOU didn’t apply to the revived bridge project, and that there was no requirement to address the vertical navigation clearance issue prior to the EIS are simply wrong.

New Regulations in 2014 require resolving the navigation height before NEPA

The Coast Guard clearly learned its lesson from the CRC experience.  They revised their permit requirements, and in 2014 entered into a new Memorandum of Agreement (MOA) with the US Department of Transportation on bridge permitting (which is binding on state highway departments as well).  Henceforth, highway builders like ODOT and WDOT are required to do the navigation analysis before they undertook their final environmental impact statement.  The Coast Guard would render a preliminary determination of the project’s allowable height in advance, so that both agencies would know what would be allowed, and they could avoid wasting money on plans that couldn’t be approved.  (And plainly, Coast Guard was intent on keeping highway builders from delaying this step to gain more political leverage.)

The MOA between the two departments specifically provides that the preliminary determination is used to eliminate alternatives that don’t meet navigation requirements from the NEPA process.  It says:

“advise which bridge designs unreasonably obstruct navigation and therefore do not require environmental analysis.

Coast Guard makes it clear that if a highway agency proceeds with plans for an alternative that doesn’t comply with its preliminary determination, that it does so “at its own risk.”  (The US Department of Transportation’s responsibilities are listed in the left-hand column; the Coast Guard’s in the right-hand column).

In June, 2022, when it issued its preliminary determination, the Coast Guard made it unambiguously clear that alternatives that didn’t provide at least a 178 foot vertical navigation clearance did “unreasonably obstruct” river navigation.  It wrote:

Our PNCD concluded that the current proposed bridge with 116 feet VNC [vertical navigation clearance], as depicted in the NOPN [Navigation Only Public Notice], would create an unreasonable obstruction to navigation for vessels with a VNC greater than 116 feet and in fact would completely obstruct navigation for such vessels for the service life of the bridge which is approximately 100 years or longer.

B.J. Harris, US Coast Guard, to FHWA, June 17, 2022, (emphasis added).

From the Coast Guard’s perspective, the entire reason for accelerating the navigation impact report, and making the navigation determination now is to avoid a situation where the NEPA process studies alternatives that can’t be approved under the Rivers and Harbors Act.  But the Oregon and Washington DOTs are acting like this determination has no meaning whatsoever.

Appendix:  Correspondence between Coast Guard and USDOT

2021-11-23 Final USCG Letter - Response - FHWA-FTA


The Week Observed, November 18, 2022

What City Observatory did this week

The Rose Quarter’s Big U-Turn: Deadman’s Curve?  The redesign of the I-5 Rose Quarter project creates a hazardous new hairpin off-ramp from Interstate 5.  This  supposed “safety” project may really creating a new “Deadman’s Curve” at the Moda Center.  A key part of the project’s re-design is moving an off-ramp about a quarter mile south, but in doing so, the route now requires southbound freeway traffic to do a 180 degree (really 210 degree) turn and travel Northbound on local streets before connecting to arterials that lead to other destinations.  In addition to more vehicle travel and circuitous routing, the new hairpin off-ramp creates hazards for those not traveling in cars. 

 For example, bike riders on Portland’s North Williams bikeway—one of the city’s busiest—will have to negotiate two back-to-back freeway ramps that carry more than 20,000 cars per day.  The $1.45 billion highway widening is advertised as a “safety” project, but it’s likely to make this part of Northeast Portland more dangerous for many travelers.

ODOT reneges on Rose Quarter cover promises.  In the 1950s, 1960s and 1970s, the Oregon Department of Transportation built three highways through Portland’s predominantly Black Albina neighborhood, destroying hundreds of homes and leading catastrophic population loss.  Now ODOT is back promising that a freeway widening project will somehow repair this damage because it will include “capping” 3 blocks or so over the freeway.  The caps have been advertised as way to heal the neighborhood, but the project’s recently released Supplemental Environmental Impact Statement shows the agency is reneging on its glib sales pitch.

It trumpeted “highway covers” as a development opportunity, falsely portraying them as being covered in buildings and housing—something the agency has no plans or funds to provide. The covers may be only partially buildable, suitable only for “lightweight” buildings, and face huge constraints.  ODOT will declare the project “complete” as soon as it does some “temporary” landscaping.  The covers will likely be vacant for years, unless somebody—not ODOT—pays to build on them. ODOT isn’t contributing a dime to build housing to replace what it destroyed, and its proposed covers are unlikely to ever become housing because they’re too expensive and unattractive to develop.

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.


The Week Observed, November 11, 2022

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).
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.

The Week Observed, November 4, 2022

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.


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).

(Hat tip to the prolific David Zipper!)

The black box: Hiding the facts about freeway widening

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.


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:

In the present case, the defendants [the state and federal transportation departments] have not explained how they applied their methodology to Highway 23 in a way that is sufficient for either the court or the plaintiff to understand how they arrived at their specific projections of traffic volumes through the year 2035. They do not identify the independent projections that resulted from either the TAFIS regression or the TDM model and do not identify whether they made any adjustments to those projections in an effort to reconcile them or to comply with other directives, such as the directive that projected growth generally cannot be less than 0.5% or the directive to ensure that all projections make sense intuitively. For this reason, the defendants have failed to comply with NEPA. This failure is not harmless. Rather, it has prevented the plaintiffs from being able to understand how the defendants arrived at traffic projections that seem at odds with current trends. Perhaps the defendants’ projections are accurate, but unless members of the public are able to understand how the projections were produced, such that they can either accept the projections or intelligently challenge them, NEPA cannot achieve its goals of informed decision making and informed public participation.

1000 Friends of Wisconsin v. U.S. DOTCase No. 11-C-054, Decision & Order, May 22, 2015

Why this matters

The entire rationale for this project is based on the assumption that if nothing is done, traffic will get much worse at the Rose Quarter, and that if this project is built things will be much better.  But the accuracy of these models is very much in question.

This is also important because the Environmental Assessment makes the provocative claim that this project–completely unlike any other urban freeway widening project in US history–will reduce both traffic and reduce carbon emissions. The academic literature on both questions is firmly settled, and has come to the opposite conclusion. The regularity with which induced demand swamps new urban road capacity and leads to even more travel and pollution is so well documented that it is now called “The Fundamental Law of Road Congestion.” The claims that freeway widening projects can offset carbon emissions by reduced idling have also been disproven:  Portland State researchers Alex Bigazzi and Manuel Figliozzi have published one of a series of papers indicating that the reverse is true:  wider roads lead to more driving and more carbon pollution, not less.  And in addition to not providing data, there’s nothing in the report to indicate that the authors have produced any independent, peer-reviewed literature to support their claims about freeway widening. The agencies simply point at the black box.

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