We will never sell or share your email address.

Blame inflation now: Lying about the latest IBR Cost Overrun

The price of the I-5 “bridge replacement” project just increased by more than 50 percent, from $4.8 billion to $7.5 billion

ODOT and WSDOT are blaming “higher inflation” for IBR cost overruns

As we’ve noted, the Oregon Department of Transportation has a long string of 100 percent cost-overruns on its major projects.  Almost every large project the agency has undertaken in the past 20 years has ended up costing at least double–and sometimes triple–its original cost estimate.

The data don’t support their claim–their own agencies official projections of future construction price inflation show a negligible change from 2020 levels.

Higher construction cost inflation accounts for only $300 million of a $2.7 billion cost increase.

The cost estimate for the I-5 bridges just jumped by 54%, from $4.8 billion to as much as $7.5 billion.  The principal culprit according to the Oregon and Washington highway departments is “higher inflation.”

Project director Greg Johnson lamented to the Portland Tribune:

“Nothing gets cheaper as time goes on. Construction projects across the country are experiencing unprecedented cost increases due to supply chain issues and increasing material and labor costs as well as other factors, and our program is no exception,” Johnson said.

But the project’s earlier projections fully anticipated that there would be inflation—it was no surprise.  The only question is whether the recent spate of construction cost increases somehow account for a greater than 50 percent increase in the total cost of the project in just the three years since its latest “inflation-adjusted” estimate.

The claim that the increase is due to inflation is not borne out by either WSDOT or ODOT’s current official forecasts of future construction cost inflation.  Both Oregon and Washington prepare such forecasts.  The Oregon forecast recognizes a short-term spike in construction costs, but expects construction inflation to settle down to historic levels.  This from their October 2022 forecast

From 2023 through 2031, ODOT expects that construction cost inflation will be about 3 percent per year.

Similarly, Washington’s latest highway construction cost index calls for construction costs to increase in the 2-4 percent range from now through 2030.  WSDOT data show the same spike in 2021, but expect prices to actually decline in 2023, and then stabilize at a little more than two percent per year through the remainder of the decade.

From 2020 through 2030, WSDOT forecasts construction cost inflation of 2.4 percent per year (including the 10 percent increase in 2022).

That represents almost no increase over the inflation that IBR officials said they had used in constructing their earlier forecasts of the IBR cost.  (Keep in mind that cost estimates are made in “year-of-expenditure” dollars and according to their testimony to the Oregon Legislature, they model assumed the same construction time frame as the earlier estimates.  In January of 2021, the IBR team described the methodology they used to construct their estimates and predicted construction cost inflation of 2.2 percent to 2.3 percent per year after 2020:

As with the construction cost inflation factor, the program team used WSDOT’s Capital Development and Management (CPDM) historical and forecast cost indices for Preliminary Engineering (PE), Right-ofWay (RW) acquisition, and Construction activities (CN), using third-party data sources and statewide experience. The values used to escalate fiscal year (FY) 2012 dollars to FY 2020 are based on these indices by the three expenditure types, which include historical data through FY 2019. The overall effect of the three historical cost indices that were used to inflate from FY 2012 to FY 2020 equates to an average annual inflation rate from 2.0% to 2.2%, depending on which capital cost option is selected. Projected inflation rates by year beyond FY 2020 vary, averaging between 2.2% and 2.3% when applied to the expenditure schedules for the capital cost options.

The critical factor here is the increase in expected inflation over the next decade or so between the project’s 2020 estimate and its new estimate.  In 2020, they said the price estimate was based on an expected inflation rate of 2.2 to 2.3 percent.  According to Washington’s official forecast the rate is now expected to be 2.4 percent per year through 2030; and for Oregon, the rate is predicted to be about 3 percent per year through 2031.  This relatively low rate of inflation would do little to raise project costs. Over the next 10 years, 3 percent inflation per year rather than 2.2 percent inflation per year, would be expected to increase a $4.8 billion construction budget by about $300 million.  This hardly accounts for the increase in maximum construction cost to $7.5 billion.

By not showing their work, and describing exactly how their inflation estimates changed between their 2020 project cost estimate and their current 2022 cost estimate, the IBR is exaggerating the importance of inflation, and downplaying its inability to accurately calculate future costs.  Its easy to blame inflation, but if a changed inflation outlook is really the cause of the cost increase, they should use their own agencies official estimates to show exactly how much the change in inflation affects the project’s cost: they haven’t.

IBR officials presented a scary looking, but largely irrelevant chart showing the fluctuation of prices of a number of building materials.  Never mind that at least three of these categories–gypsum, lumber and aluminum–have almost no relevance for bridge construction projects.

Misleading and irrelevant cost indices presented by ODOT.

Why won’t ODOT tell us how wide their freeway is?

After more than three years of public debate, ODOT still won’t tell anyone how wide a freeway they’re planning to build at the Rose Quarter

ODOT’s plans appear to provide for a 160-foot wide roadway, wide enough to accommodate a ten lane freeway, not just  two additional “auxiliary” lanes

ODOT is trying to avoid NEPA, by building a wide roadway now, and then re-striping it for more lanes after it is built

The agency has utterly failed to examine the traffic, pollution and safety effects of the ten-lane roadway they’ll actually build.

The proposed $1.45 billion I-5 Rose Quarter Freeway Project is all about building a wider freeway.  But there’s one question that’s left unanswered in  all of the project’s hundreds of pages of p.r. materials and reports:  How wide a roadway are they actually going to build?

As we’ve repeatedly pointed out, OregonDOT has gone to great lengths to say that they are merely adding “two ‘auxiliary’ lanes” to the existing I-5 freeway.  But they’ve never released clearly labeled, accurately scaled plans that show the actual width of the roadway they’re proposing.  The current roadway has two “through” lanes in each direction as it crosses under NE Weidler Street.  ODOT claims that they’re just adding two more “auxiliary lanes.”  but in reality, they’re building a roadway that could accommodate 10 travel lanes (in addition to lengthy on- and off-ramps for freeway traffic.

That matters, because its a few hours work with a highway paint machine to re-stripe a roadway to get an added lane or two.  And because ODOT’s traffic modeling and environmental analyses are based on the assumption that there will only be two additional lanes, the Supplemental Environmental Assessment doesn’t reveal the true traffic, livability or environmental effects of a likely ten lane roadway.  (ODOT is looking to exploit a loophole in FHWA environmental regulations—which themselves likely violate NEPA—that allow a road to be re-striped without triggering a further environmental assessment).

At City Observatory, we’ve been following plans by the Oregon Department of Transportation to spend upwards of $1.45 billion widening this mile and a half long stretch of Interstate 5 opposite downtown Portland in the city’s Rose Quarter.  As we’ve noted, the agency has gone to great pains to deny that it’s actually widening the freeway at all, engaging in a tortured, misleading and at times absurdist effort.

For more than three years, we’ve e challenged ODOT to reveal the actual width of the project they were proposing to build.  The agency’s 2019 Environmental Assessment (which, by law, is supposed to be a full disclosure of the project’s impacts on the surrounding area) contained just a single crude illustration of a cross-section of the project’s right-of-way.  Using that diagram, we deduced that the freeway was to planned to be at least 126 feet wide–enough, not just for adding a mere two lanes to I-5 existing four, but actually wide enough for eight full travel lanes plus standard urban shoulders.

But that actually understates the true size of the project.  City Observatory later obtained unreleased documents prepared by ODOT and its contractors showing that the agency planned to build a 160 foot wide roadway through the Rose Quarter–easily enough for ten highway lanes.  (We’ve provided a blow-by-blow description of our efforts to pry these secrets from recalcitrant ODOT staff, and copies of the documents we obtained, below).

Still Hiding Freeway Width

In late November, ODOT released its Supplemental Environmental Analysis (SEA) for the Rose Quarter.  It continues ODOT’s strategy of deception and obfuscation about the width of the roadway they are planning to build.  Just as in the 2019 Environmental Assessment, they’ve published a “not-to-scale” drawing of a cross section of the freeway that entirely omits key measurements (while selectively labeling just a few features).

This illustration is plainly deceptive.  The drawing is not to scale, by its own admission.  It appears that there are only 3 northbound and 3 southbound travel lanes (the two central parts of the covered section).  But the actual width of these portions of the project are never disclosed.  By the project’s own admission, each of these spans may be 80 feet (or more), which is easily enough room for five traffic lanes in each direction, with ample provision for shoulders (five travel lanes would occupy only 60 feet of an 80 foot wide covered area).  According the the Supplemental Environmental Assessment, the northernmost third of the freeway cover has spans in excess of 80 feet in length (Figure 2.7, page 19).

Massively wide: 160 to 200 feet of roadway

So how wide is the freeway, really?  ODOT isn’t saying directly, but we can get a good idea by looking at another poorly labeled (but scaled) drawing included in the project’s right of way report.  The diagram (Figure 4 on page 12) shows the existing streets (the grid running North-South and East-West) and the proposed widened I-5 freeway, running diagonally through the Rose Quarter from Northwest to Southeast.  The individual lanes of the freeway are indicated.  This diagram makes it hard to see or measure, so we’ve zoomed in and added a scale (from the original drawing).

This section shows the portion of the freeway as it crosses under the NE Weidler Street Overpass.  Here the freeway is divided into three parts, from West to East a two lane southbound off-ramp from I-5, an eight lane main-line section of freeway, and a two lane North bound off ramp.  Including all the lengthy ramps, the footprint of this freeway is 12 lanes wide.

Again, these lane markings aren’t definitive.  Let’s look at the actual width of the roadway.  We’ve added a 200 foot scale at three points along the freeway.  It’s evident that the freeway is more than 200 feet wide near North Hancock Street (the northernmost scale.  It is nearly 200 feet wide at NE Broadway (the middle scale), and slightly less than 200 feet wide just south of NE Weidler (the southernmost scale).  This width is more than enough to accommodate ten travel lanes, as well as the freeway’s proposed on and off ramps

Violating the National Environmental Policy Act

The purpose of an environmental assessment is to disclose the likely effects of a proposed action, in this case, how a wider freeway will affect the community and the environment.  By concealing the actual physical width of the structure they intend to build, the Oregon Department of Transportation is making it impossible for the public to accurately understand the effects of the project, or gauge the truthfulness of claims made by ODOT that it will only add two “auxiliary” lanes of traffic.  ODOT is in violation of NEPA.  It needs to produce a fully detailed, accurately scaled set of plans showing the actual width of the roadway and the location of all structures.  With that in hand, the public can then gauge the actual size of this proposed freeway widening, and know whether it can trust ODOT’s claims about its impacts.

A short history of ODOT’s Deceptions

We raised this issue at City Observatory, and it was also included in official comments in response to the EIS (March 2019), and in formal testimony to the Oregon Transportation Commission (April 2019).  In response, ODOT said nothing.

In November 2020, the Oregon Department of Transportation and the Federal Highway Administration published a “Finding of No Significant Environmental Impact” or as its known in the trade a FONSI, essentially denying that the project had any environmental effects worth worrying about.  That document, and related supporting materials still failed to answer the basic question about the width of the freeway.

So, on December 1, 2020, I appeared (virtually) before the Oregon Transportation Commission, and again asked them to answer this very basic question (as well as several others).  Members of the Commission directed their staff to meet with me, which we did, again virtually, on December 16, 2020.

The December 2020 “meeting” was an extremely stilted, and one-sided conversation because the ODOT staff in attendance (nine in total), declined to answer any questions during the meeting. Instead, they simply took notes, and said they would respond, later, in writing.

On January 14, ODOT sent their response.  Here, is there response to the question about the width of the freeway.

As you can see, there’s not a single number present.  This, for the record, is an agency that has spent several years, and tens of millions of dollars planning and designing this project, and yet wouldn’t answer this basic question.  And just for clarity about the level of detail of those planning efforts, the agency said with some certainty that it would need to take a couple hundred square feet of on hotel parking lot (the area of one good sized bedroom or one smallish living room), as part of the freeway right of way.

So, how wide is it?

In a separate e-mail to me, ODOT’s Brendan Finn, head of the Office of Urban Mobility that supervises the project, said:

“Regarding the “width of the built right-of-way of the Rose Quarter project, . . . I believe you received a response to the width of the Rose Quarter Project, it being within the EA document.”
(Finn to Cortright, February 12, 2021)

In an email to Willamette Week reporter Rachel Monahan, on January 22, one of ODOT’s public affairs persons said:

“Yes, the right of way as stated in the Environmental Assessment is 126 feet.

For your reference, Figure 2-4, located on page 10 within the Project Description of the February 2019 Environmental Assessment, available at, illustrates the proposed lane configuration which includes an inside and outside shoulder, two through lanes, and one auxiliary lane for the highway in each direction. All shoulders and lanes are 12 feet wide. The anticipated right of way would also provide the opportunity for bus on shoulder use and the space needed for fire, life, and safety requirements and provisions under the highway covers.”

None of this, of course, was actually true.  City Observatory obtained three different sets of documents prepared by ODOT contractors showing the actual width of the roadway to be approximately 150 to 160 feet.  As early as 2016, the project’s contractors drew up plans for a 160 foot roadway–something that was never disclosed publicly by IBR, but which we obtained via a Federal Freedom of Information Act request.  One of the project’s consultant’s drew up a landscape plan for freeway covers, clearly showing at 150 plus roadway (the contractor deleted this image from her website after we published this at City Observatory).  Finally, CAD drawings prepared by the project, obtained by public records request show a 160 foot wide roadway.

What this really means is that the I-5 Rose Quarter project is easily large enough to include a ten-lane freeway.  Here, we’ve adjusted the diagram contained in the original ODOT Environmental Assessment to accurately reflect the number of travel lanes that could be accommodated in a 160 foot roadway.  This illustration contains generous inside and outside shoulders, as well as full 12-foot travel lanes.  (Ironically, ODOT’s own design for the southern portion of the Rose Quarter project calls for 11-foot travel lanes on the viaduct section of I-5 near the Burnside Bridge).


ODOT doesn’t care about covers, again

ODOT’s Supplemental Environmental Analysis shows it has no plans for doing anything on its vaunted freeway covers

It left the description of cover’s post-construction use as “XXX facilities” in the final, official Supplemental Environmental Impact Statement

The report makes it clear that “restorative justice” is still just a vapid slogan at the Oregon Department of Transportation.

In theory, the Oregon Department of Transportation is proposing to spend $1.45 billion on freeway covers to somehow repair the damage it did when highways it built largely destroyed the Albina neighborhood in the 1950s, 1960s and 1970s.

ODOT has invested considerable resources in creating the fiction that highway covers will the the ideal environment for new development.  Never mind the agency isn’t planning to contribute a dime toward building anything on said covers, even though its highways directly destroyed hundreds of neighborhood homes, which it never replaced.

It should be clear to anyone watching that talk of developing the covers is purely a woke-washing ploy:  The agency’s real agenda is a wider highway.  Last year, it sent a typo-ridden mailer to thousands of North and Northeast Portland households featuring a purely fictional “Workforce Development Center” built by African-American Artisans–which doesn’t exist and isn’t a part of the project at all.  Other planning documents have illustrated imaginary housing that might be built (if somebody other than ODOT pays for it). There’s abundant evidence that, beyond fictional illustrations, OregonDOT doesn’t really care about the covers or what happens on them.  It’s designed a roadway so wide that on most of the covers, it will be impossible to building anything other than a “lightweight” building, no more than three-stories tall.  And, as noted, somebody else will have to pay for those buildings.

Mythical, multi-story buildings to be built by someone, not us (ODOT, 2019 Rose Quarter EA).

The latest bit of evidence of ODOT’s profound indifference is in its recently published “Supplemental Environmental Assessment.”  Turn to the “Right of Way” report that is one of the project’s attachments. This is an extremely detailed document which lists every square foot of property that will be acquired for the project (or which will have even a temporary easement associated with construction).  At the very end of the document (page 26 of 28-pages) , ODOT speaks to what will happen on those very expensive covers it develops.

This public review document has a highlighted section which somebody forgot to finish editing that explained what ODOT would do “as an interim measure” when the project is completed.  Whatever these “xxx facilities” are, we can only guess, but it’s apparent that even after years of touting the covers, ODOT has no idea, and certainly no plans to do anything meaningful on the highway covers.  Keep in mind:  This is the official Supplemental Environmental Assessment, not some working draft.

Image of I-5 Rose Quarter SEA Right of Way Report: Yellow-highlighted “xxx facilities” in original.


The preceding paragraph of the section quoted above makes it clear that ODOT has no intention to develop this property, and it is not going to be a picnic for anyone else, either.  ODOT would continue to own the cover, and would insist on some vaguely described air rights and lease agreements.  It also makes it clear that some additional regulatory processes, including further review under the National Environmental Policy Act would likely apply as well.  Developing this property will be vastly more expensive and complex than developing property elsewhere in the neighborhood.

In short, ODOT has no plans to construct covers that will support significant buildings, no plans for any meaningful use of the covers after the highway is complete, and no funding for it (or anyone else) to develop anything on the highway covers.  And if somebody else does have an idea, they’ll have to pursue it with their own money, and they’d better bring lots of lawyers, because it’s not going to be easy.  In the meantime, Albina, enjoy your “XXX facilities”—we’re sure they’ll be special.

ODOT’s I-5 Rose Quarter “Improvement”: A million more miles of local traffic

ODOT’s proposed relocation of the I-5 Southbound off-ramp at the Rose Quarter will add 1.3 million miles of vehicle travel to local streets each year.

Moving the I-5 on ramp a thousand feet further south creates longer journeys for the 12,000 cars exiting the freeway at this ramp each day. 

The new ramp location requires extensive out-of-direction travel for all vehicles connecting to local streets. 

With more miles driven on local streets, and more turning movements at local intersections, hazards for all road users, but especially persons biking and walking, increase substantially.

More driving on neighborhood streets increases local pollution and greenhouse gas emissions.

In an effort to get more space to expand a proposed freeway cover, the Oregon Department of Transportation is proposing to move the southbound off ramp from I-5 at the Rose Quarter nearly half a mile south.  The new location’s awkward location in relation to the city’s established street grid creates a hazardous hairpin turn, and also lengthens the trips freeway exiting travelers will take, regardless of the direction they travel.

The underlying problem is that the major arterial streets leading away from the freeway are all considerably north of the new proposed off ramp location, meaning that all travelers will have to travel further to connect with these arterials than they do today.  Once they transit the hairpin turn, all vehicles have to travel northbound on Williams Avenue as far as N. Weidler in order to go east, and a block further to N. Broadway in order to go west.

We estimate that the additional travel associated with the new off-ramp location will result in more than a million additional miles of vehicle travel in the Rose Quarter neighborhood each year.

Estimating additional travel

Vehicles leaving I-5 can travel in four cardinal directions:  North on Williams Avenue, east on Weidler Avenue, west on Broadway, or south on Wheeler the two-way segment of Williams Avenue.  The new ramp configuration requires a longer and more convoluted routing to reach each of these arterials.

We’ve used Google maps compute distance function to compute the additional distance vehicles must travel from the proposed new I-5 southbound off-ramp to each of these streets.  Eastbound and northbound vehicles exiting I-5 southbound will have to travel an additional 1,000 feet from the new ramp location.  Westbound and southbound vehicles exiting I-5 southbound will have to travel an additional 2,000 feet from the new ramp location.  (We show the computation of the net added travel distances for each route in the maps below).

Data collected by the Oregon Department of Transportation show that about 12,530 vehicles per day exit Interstate 5 at the existing southbound off-ramp (Exit 302A).  ODOT’s data don’t differentiate traffic according to their turning movements subsequent to leaving the freeway.  For simplicity, we assume that one-fourth of this total exits in each of the four cardinal directions, or about 3,100 vehicles per direction.

The following table shows the additional distance traveled due to the proposed new I-5 southbound ramp location.  For example, about 3,133 vehicles traveling northbound travel an additional 1,000 feet each day, for total additional vehicle travel of about 3.1 million feet (or a little less than 600 miles).  Aggregated across all four cardinal directions, the new ramp location leads to an additional 18.8 million feet or 3,600 miles of vehicle travel per day in the Rose Quarter neighborhood.  On an annual basis, this works out to more than 1.3 million additional vehicle miles of travel.

Direction Traffic Added Distance (feet) Total Distance (feet)
North                                 3,133                      1,000              3,132,500
South                                 3,133                      2,000              6,265,000
East                                 3,133                      1,000              3,132,500
West                                 3,133                      2,000              6,265,000
Total                              12,530           18,795,000
Miles/Day                         3,600
Miles/Year              1,300,000


More Traffic, More Turns, More Crashes, More Pollution

Adding 1.3 million miles of vehicle travel to the already congested Rose Quarter area will have predictable negative effects on the environment, safety and walkability.  As we’ve noted, the ODOT’s plans call for closing some crosswalks, and cutting back corners on 13 blocks to create a wider turning radius to speed cars.  Those wider intersection will have longer crossing distances, and pose greater dangers for people walking in the neighborhood.  This problem is amplified by both the additional travel, and the increased number of turns required to leave the freeway to reach any arterial—and each turning movement creates additional dangers for pedestrians and cyclists.  These safety problems are in addition to the likely increase in crashes due to the dangerous hairpin turn exit created by the new I-5 southbound ramp location.

The increase in driving also means an increase in pollution.  Each mile of vehicle travel produces about 411 grams of greenhouse gases.  That means the added driving on local streets in the Rose Quarter will add more than 500 tons of greenhouse gas pollution each year.  There is no indication that the project’s Environmental Assessment contains any analysis of this increase in greenhouse gases as a result of this project.

A convoluted route to the Moda Center

Many Portland residents visit the Rose Quarter to attend concerts and sporting events.  Many of them will have to travel much further, and cope with much more local traffic as a result of the ramp re-orientation.  The new ramp configuration creates a very convoluted route for traffic traveling from I-5 south to the facilities parking garages.  From I-5 South, vehicles have to travel north on Williams, then west on Broadway and then south of Vancouver, traveling a distance of almost half a mile and traveling through five intersections to reach the parking garages.

Computing added travel distances

North and East Bound Added Travel Distance:  1,000 feet per trip (net).  Vehicles exiting I-5 and proceed eastbound on NE Weidler must travel an  1,500 feet to reach the intersection of NE Weidler and N.Williams,.  Similarly, vehicles traveling northbound on Williams must also travel an additional 1,500 feet to reach this same intersection.  These vehicles save approximately 500 feet of travel that would otherwise occur traveling south on N. Vancouver and East on N. Weidler to reach this same intersection.  The net additional distance per northbound and eastbound trip is 1,000 feet (1,500 feet via the proposed new ramp location compared to 500 feet for the existing ramp location).

Distances for northbound- and East Bound Trips (New Ramp):   1,500 feet

Distance saved by northbound and eastbound trips (500 feet)


Westbound and southbound added trip distance:  2,000 feet.  Vehicles exiting I-5 and proceed westbound on N. Broadway must travel an  2000 feet to reach the intersection of N .Broadway and N. Vancouver,.  Similarly, vehicles traveling southbound on Vancouver must also travel an additional 1,500 feet to reach this same intersection.  All of this distance is in addition to the distance that those same movements would require at the existing intersection location.  (Note that because all traffic exiting I-5 southbound must travel north on Williams; there is no option to directly continue southbound on NE Wheeler, because that movement is blocked by traffic traveling onto the southbound I-5 on-ramp, immediately adjacent to the new relocated off-ramp).


Flat Earth Sophistry

The science of induced travel is well proven, but state DOTs are in utter denial

Widening freeways not only fails to reduce congestion, it inevitably results in more vehicle travel and more pollution

The Oregon Department of Transportation has published a technical manual banning the consideration of induced travel in Oregon highway projects.

The Oregon Department of Transportation wants to pretend that induced travel doesn’t exist.  Using federal funds, it has written a new handbook on how to plan for highways that makes some preposterous and undocumented claims about the induced travel.  It explicitly prohibits planners and consultants from using peer-reviewed, scientifically based tools, like the Induced Travel Calculator, developed by the University of California Sustainable Transportation Center, and mandated by the California Department of Transportation for the analysis of the environmental effects of freeways.

The tortured denial by the Oregon Department of Transportation engages in some blatant sophistry that tries to create a false distinction between “latent” demand and “induced demand.”  If we just call it “latent demand” then somehow it doesn’t count.

Turn to page 6-79 of ODOT’s newly published “Analysis Procedures Manual“.  The APM is a technical guide to using traffic data to plan future roadways.   Here you find a red-bordered text box with a bold graphic STOP sign, explicitly banning planners and analysts from using the induced travel calculator.  “The use of these calculator types shall not be used to estimate induced and latent demand effects on ODOT-funded projects . . . ”

This kind of foot-stomping, hand-waving denial is reminiscent of the Catholic church’s harrumphing denials of Copernicus and Galileo’s observations of the universe. But induced travel is extremely well-established science, and Oregon DOT shows itself to be modern day a flat-earth science denier.

What the Scientific Literature Shows

The economic and scientific literature on induced travel is unambiguous:  Increasing road capacity, by whatever means, lowers the perceived cost of driving and results in more travel.  The phenomenon is now so well-established that its called the “Fundamental Law of Road Congestion.”

The economics are straightforward: expanding the supply of highways lowers the cost of driving, and faced with a lower cost of driving, people drive more.  In this classic diagram, the supply curve shifts outward (to the right) lowering the cost of driving and increasing the number of miles driven.

The best available science shows that this generated travel follows a unit elasticity:  a one percent increase in roadway capacity creates a one percent increase in vehicle miles traveled.  To claim otherwise is to simply be in denial about the fundamental economics of the price elasticity of demand:  lowering the price of something (in this case the time cost of using a particular roadway) tends to increase the volume consumed.

There have been numerous studies which have all reached similar conclusions about the empirical nature of this relationship.  Two of the leading scholars on the subject, the University of California’s Susan Handy and James Volker present a meta-analysis of studies of induced travel.  Their results are summarized on the following table.  In studies in the US and in other developed countries, there’s a strong and consistent relationship between expanded roadways and additional travel.  In the long run, estimates of the elasticity of induced travel are around 1.0, meaning that a one percent increase in road capacity tends to lead to a one percent increase in vehicle miles traveled.

The authoritative Traffic Engineering Handbook summarizes the literature on induced demand as follows:

. . . the long-run elasticities of VMT with respect to road space is generally 0.5 to 1.0 after controlling for population growth and income, with values of almost 1.0, suggesting that new road space is totally filled by generated traffic where congestion is relatively severe.

Kara Kockelman (2011), “Traffic Congestion,” Chapter 22, Transportation Engineering Handbook, McGraw Hill .

ODOT asserts that it can ignore all this literature.  ODOT argues, in essence, that even thought the consensus is for a unit elasticity, that here in Oregon, contra all this published literature, it believes the real coefficient of these equations is zero:  that a one percent increase in roadway capacity would lead to no increase whatsoever in travel demand.  In essence, the ODOT Analysis Methods Manual tells planners to ignore induced demand entirely.

Latent demand is induced demand.

The apparent justification for this conclusion is that there’s something called “latent” demand that’s different from “induced” demand.

Oregon DOT falsely claims that there is a difference between “latent” demand and “induced” demand.  Here’s what they are saying…

Latent Demand – this is demand for transportation that consumers do not utilize because they cannot afford the cost or it is not currently available. Latent demand responses are typically associated with network limitations, such as capacity constraints . . . Latent demand does not include induced demand.

Induced demand – new demand for travel that did not exist prior to the build scenario. This is above and beyond forecasted and latent demand associated with planned land use, it is demand that is the result of changes in land use (zone changes) or economic conditions that create new trips.

(ODOT Analysis Procedures Manual, June 2022, emphasis added).

Denying that “latent” demand is induced demand is not supported in the literature.  No other study uses these terms in this fashion, or makes this distinction between “induced” and “latent” demand.  This is ODOT’s Through the Looking Glass moment:

“When I use a word,” Humpty Dumpty said, in rather a scornful tone, “it means just what I choose it to mean- neither more nor less.”

Ben and Jerry observe the latent demand for ice cream every year when they drop the price of a cone to zero, and people line up around the block.  These are all people who would love to have ice cream, if only it were free.  The lines around the block are “induced ice cream eating”, as the zero price of ice cream converts “latent demand” into “actual demand.”

But we know empirically that travel changes rapidly in response to available highway capacity.  That’s true both in the case of expansions and contractions in capacity.  People rapidly and radically change their travel distances and trip making in response to changes in capacity.  Predicted “carmaggedons” in the face of reductions of capacity from bridge closures, highway collapses, construction projects, demolitions of highways, and other similar events cause traffic disappearance.

Ultimately, this is pure sophistry:  Whether you call it “latent” demand or “induced” demand, the effects are exactly the same:  Adding more capacity to existing roadways increases the volume of vehicle travel.

Oregon’s Analysis Procedures Manual vs. California’s Transportation Analysis Framework

While OregonDOT has just published its “Analysis Procedures Manual” banning the use of induced travel calculators, its California counterpart, Caltrans has published guidelines that require the use of such a calculator to highway projects in the Golden State.  What leads one state DOT to require the calculator, while the other bans it.  Who is right?

Let’s consider the processes and documentation that went into the CalTrans and ODOT publications.  CalTrans adopted its Framework after a years-long study and review effort.  It brought in outside experts, it conducted and published a thorough literature review, and the Framework itself was the subject of public meetings.  As the Framework document explains:

Caltrans convened an expert panel of academics and practitioners through UC Berkeley Tech Transfer. The panel chair presented the group’s conclusions to stakeholders at a virtual Technical Roundtable prior to finalizing the group’s recommendations. Caltrans and State partners have accepted the panel’s recommendations, which are reflected in the guidance documents.

In contrast, the Oregon Manual has no identified author, cites no academic literature, has not been subject to outside review by persons independent from the Oregon Department of Transportation.  It is an unsubstantiated, unscientific polemic.

It’s also possible (and indeed likely) that even without changes in land use, households and businesses will sort themselves differently among the existing stock of land and buildings.  If travel is fast and free, people may choose to live at housing a great distance from their jobs (or conversely, commute to jobs at great distance from their homes).  If travel is slower or more expensive, they may seek housing nearer their job, or look for jobs only closer to home in order to minimize the time and money costs of travel.  The redistribution of population and employment among existing buildings in response to changes in travel costs is something that ODOT denies is even possible.

What’s deeply ironic about the denial of induced demand is that highway departments have been counting on it to create an unending demand for their services for decades.  Building more and wider roads has led to more driving and more car ownership, which has jammed existing roads to capacity, and led to calls for further widening.  It’s a Sisyphean cycle that leads to ever more traffic and ever more spending on roads, which is just what highway departments and their vendors want.

Induced Demand and Land Use Changes

As Litman points out there are first-, second-, third- and fourth-order effects from highway capacity increases.   Initially travel times get faster (first order). That prompts people to change whether, when, where and by what means they travel.( second order).  The shift in travel patterns and accessibility may then prompt changes in land use (third order).  Finally, the cumulative effect of a shift to sprawl and greater auto dependence may further amplify trip taking (fourth-order).

Roadway expansion impacts tend to include:

First order. Reduced congestion delay, increased traffic speeds. 

Second order. Changes in time, route, destination and mode.

Third order. Land use changes. More dispersed, automobile-oriented development. 

Fourth order. Overall increase in automobile dependency. Degraded walking and cycling conditions (due to wider roads and increased traffic volumes), reduced public transit service (due to reduced demand and associated scale economies, sometimes called the Downs-Thomson paradox), and social stigma associated with alternative modes.

The ODOT view is that the “second order” effects—changing times, routes, additional trip taking, and more miles traveled—somehow don’t count as “induced travel” if no changes in land use happen.  Or, alternatively, if that travel is accurately predicted by a traffic model or anticipated in a plan (i.e. “above and beyond forecasted”) , that it also doesn’t count.

The Land Use Red Herring

But let’s have a look at the second part of the argument:  That the transportation agency can ignore that part of induced demand that results from land use changes in response to the expansion of roadways, and that somehow, because Oregon has a system of land use planning that those effects simply don’t occur here.  ODOT’s rhetorical position is that “Induced demand” can only occur in response to land use changes, and land use changes are impossible under Oregon’s land use system.

The Oregon Department of Transportation likes to pretend that the only form of induced travel that is real is that which accompanies changes in land use.  And they argue that because Oregon has strict land use laws, that investments in travel infrastructure can’t produce changes in land use.

In general, Oregon faces low risk related to induced demand because of the state’s strong land use laws, which exist to prevent sprawl. Changes to land use must be approved by local jurisdictions, so a facility project cannot induce demand just by itself.

ODOT’s reasoning is this:  Induced demand only occurs when there is a land use change that necessitates a change in a land use plan.  Because Oregon has land use plans, transportation projects somehow can’t create induced demand. This reasoning is wrong for two reasons:  First, as we’ve already explained, “latent” demand–changes in transportation behavior in response to a capacity increase–can happen even without any change in land use, and this “latent” demand is, according to all the scientific literature “induced demand.”  The second reason is that Oregon’s land use law doesn’t prevent or preclude changes in land use in response to changes in transportation infrastructure.

What this misses is that the land use system is a permissive framework, and within that legal framework many possible patterns of population and employment are possible.   For example, new housing can be built in infill locations (near transit, and proximate to more jobs) or it can be built at the urban periphery.  Both outcomes are possible under the Oregon land use system.  The key point about induced demand is that more investment in transportation infrastructure will make lower density, more far flung development even more attractive.  And, importantly, a significant part of the demand for Oregon roadways comes from places not subject to the Oregon land use system (i.e. suburban Clark County Washington).  Investing in more transportation capacity across the Columbia River will facilitate more low density sprawl in Washington, and added automobile trips on the I-5 and I-205 bridges as large fractions of these suburban and exurban households live and shop in Oregon.

A lobbying campaign to deny induced demand

There’s little question that ODOT officials are uncomfortable with the science of induced travel.  And they’re eager to do anything they can to minimize or misrepresent or discredit the application of this scientific fact to transportation planning.  For example, in 2021, ODOT sought funding through AASHTO (the lobbying organization of state highway agencies) to get a project funded to dispute induced demand.  Bike Portland reported that its proposal made it clear that the agency was primarily interested in generating talking points to push back against application of induced demand to metro area freeway expansion projects.

“While the road building era of the 1950s freeway networks is essentially complete, even minor strategies and investment intended to optimize existing roadway system assets are increasingly facing opposition in the name of “induced demand”…”

Even as it is busily ignoring or denying the science of induced travel, the Oregon Department of Transportation regularly repeats the discredited myth that idling in traffic is a significant source of greenhouse gas emissions that can be reduced by widening roadways.

Traffic Projections that Deny Induced Travel Lack Scientific Integrity

To the extent that ODOT’s guidance limits what is included in a federally required environmental impact statement, it’s steadfast refusal to cite any sources for its claims, and its consistent ignorance of published scientific literature on induced travel constitutes a violation of the scientific integrity requirements of NEPA.

§ 1502.23 Methodology and scientific accuracy.

Agencies shall ensure the professional integrity, including scientific integrity, of the discussions and analyses in environmental documents. Agencies shall make use of reliable existing data and resources. Agencies may make use of any reliable data sources, such as remotely gathered information or statistical models. They shall identify any methodologies used and shall make explicit reference to the scientific and other sources relied upon for conclusions in the statement. Agencies may place discussion of methodology in an appendix. Agencies are not required to undertake new scientific and technical research to inform their analyses. Nothing in this section is intended to prohibit agencies from compliance with the requirements of other statutes pertaining to scientific and technical research.

Chuck Marohn, writing at Strong Towns explains that traffic engineers treat travel demand as a fixed and immutable quantity–they’ve build models and a world view that pretends that people will travel just as much whether they build a project or not.  This view helps justify building ever more roads, but doesn’t reflect reality and ought to be treated as professional malpractice:

The concept of “travel demand” is where traffic engineers have stunted their own intellectual development more than perhaps anywhere else. And they’ve done so for two reasons. First, it makes their models easier to run. It’s really difficult (impossible, really) to create models that factor in the behavioral responses of humans. Better to just assume a static level of demand, even though that assumption is a farce (remember, traffic models are all about justifying projects, not actually modeling what is going on in the world).

Second, it allows traffic planners and engineers to position themselves and their craft as responding to demand, not creating it. That’s an important distinction because it allows them to be confident in what they do without having to struggle with the underlying reasons that things aren’t working.  . . .

Engineering in the auto age is about building—build, build, build—and not about optimizing or managing systems. When your ethos is merely to build more stuff, you develop myths and models that support that ethos. That’s what you’re seeing in the patently absurd assertion that additional capacity does not generate more trips. . . .

In 2022, denying how highway expansions induce people to drive more should be considered professional malpractice.

US Secretary of Transportation Pete Buttigieg clearly endorses the science of induced demand.  In a recent television interview, Buttigieg told Chris Wallace:

. . . here’s an entire science to this. And we have a lot of research partners. We have our own research institution called the Volpe Institute, which is in Cambridge, Massachusetts. . . . one of the challenges we have right now is you got more and more people in the country more and more people on the road. Just how to be smart about that. For example,it turns out that sometimes when you just want to get a lot of traffic on the roadway, and you just added lanes to it, all you get is more traffic, because it actually makes more people want to drive on that road and then you’re right back where you were.

The IBR project: Too much money for too many interchanges

The real expense of the $5 billion I-5 bridge replacement project isn’t actually building a new bridge over the Columbia River:  It’s widening miles of freeway and rebuilding every intersection north and south of the river.  A decade ago, an independent panel of experts convened by OR and WA governor’s strongly recommended to ODOR and WSDOT that they eliminate one or more intersections.

The panel concluded that 70 percent of the cost of the project was rebuilding 7 interchanges in five miles.

The experts told ODOT and WSDOT that project interchange spacing violates both federal and state design standards.

The expert panel concluded that eliminating interchanges would reduce project cost, improve safety, and improve traffic flow.

Failing to look at removing or simplifying intersections after getting this expert advice is arbitrary and capricious; ODOT and WSDOT are violating the National Environmental Policy Act’s requirement that they take a hard look at reasonable alternatives

Bridge Review Panel:  A totally new bridge design; eliminate interchanges

Today’s “Interstate Bridge Replacement” project is a warmed-over version of the failed Columbia River Crossing of a decade ago.  Like the current effort, the CRC was controversial and highly criticized.  The Governors of Oregon and Washington intervened and appointed to special, independent review panels of national experts, both of which spotted errors in project.  The first, a 2010 Independent Review Panel, determined that ODOT and WSDOT’s proposed “open-web” design for the river crossing was “unbuildable.”  That led the two governors to appoint another panel, the bridge review panel, to come up with an alternative design.  That panel, also chaired by Tom Warne, issued its 146-page report in 2011.

In addition, to coming up with a buildable bridge design, the Bridge Review Panel recommended that reducing and simplifying the number of interchanges in the project area, rather than repeating and expanding each of the existing interchanges would reduce costs, and make the project function better.  Their comments are worth quoting at length:

The panel concluded that improvements to the functionality of the overall roadway network in the project limits should address urban design issues. The use of a collector/distributor system was found to be unworkable, but reducing and simplifying the number of interchanges would significantly improve both functionality and cost.

Substandard Interchange Spacing and Project Impacts
In the project corridor, seven interchanges in less than five miles results in interchange spacing that does not meet state or federal minimum requirements of one mile for interstates in urban areas. In some circumstances, interchange spacing is half the minimum required. It is not unusual in urban areas to have substandard interchange spacing. However, it is unprecedented that all seven interchanges on a project corridor have less than minimum spacing. Not only are safety and operations an issue, more than 70 percent of the project budget is associated with these interchanges. Minimum interchange spacing is necessary for operational efficiency and user safety. Substandard interchange spacing in the project corridor can be expected to negatively impact both. Interchanges adjacent to the Columbia River and North Portland Harbor also increase environmental impacts and detract from the visual quality of the shoreline and the character of a signature bridge.
It is the view of the panel that some consolidation of the interchanges on the project corridor is warranted. This consolidation would have the following direct benefits to the project:
  • Improved safety and operations.
  • Significant reduction in capital costs.
  • Reduced environmental impacts.
  • Enhanced viewsheds along the Columbia River.
  • Improved opportunities for a signature span, from budgetary, logistical, and performance perspectives.
With respect to interchange spacing, the panel offers the following secondary recommendation:

Review all interchanges, ramps and other geometric features to simplify the overall corridor design for substantial cost savings and to improve safety and corridor operations.

Bridge Review Panel Report, 2011, Page 96 (emphasis added)
The panel reiterated this point in its conclusion, indicating that they felt strongly that much more work needed to be done, and that contrary to what most states are doing (removing closely spaced interchanges), that Oregon and Washington are simply perpetuating a bad design at huge cost.
. . . the panel does feel strongly that much work remains to be done to improve the ramps and interchanges throughout the project and that simplification of these elements will bring about a better and more functional solution. In fact, the panel is struck by the fact that most states are working to remove congested interchanges and ramps rather than building their way towards such a condition: as is occurring here. In addition, the volume of interchange access is not in harmony with state or Federal guidelines. The BRP recommends further study to address interchange geometrics and operations. In addition, the whole corridor would benefit from a more comprehensive urban design review
Bridge Review Panel Report, 2011, (emphasis added)
In spite of this clear advice, ODOT and WSDOT are doing just the opposite: planning for elaborate and expensive reconstructions of each of the seven interchanges in the project area.
IBR project director Greg Johnson testified that the complex Marine Drive interchange would be the second most costly pat of the project after the river crossing itself; Bike Portland reported that the vast majority of the project price tag is due to multi-lane interchanges.  And it’s likely that the cost of these interchange could escalate dramatically, because the current crossing is designed only with a 116 foot clearance, far less than the 178 clearance called for by the US Coast Guard. Raising the bridge and the intersections would make the project even more costly.

Not just forgetful:  Arbitrary, capricious and a violation of the National Environmental Policy Act

As far as ODOT and WSDOT are concerned, the work of the Bridge Review Panel has simply gone down a memory hole.  A decade ago, Oregon and Washington spent about $1.5 million on these independent, expert, outside reviews of the Columbia River Crossing Project.  Their own hand-picked national experts, looking at the proposed project with fresh eyes, said:  If you’re problem is too much weaving because of too many interchanges in too short a distance, then the obvious—and preferred—solution is to eliminate some of those interchanges.  The experts went further, saying that eliminating interchanges would make the project safer, perform better, look better, have fewer environmental impacts, and even be cheaper.  But here we are, a decade later, and the IBR project hasn’t seriously considered  these recommendations.  They’ve completely ignored them.
Why?  We can’t know for sure.  But there’s strong evidence that the real reason ODOT and WSDOT want this project is not so much to replace the bridge, as to gin up support for spending billions to widen the freeway on either side of the river.  They know that freeway widening, if called out as a separate project, wouldn’t generate any public support.  By tying the intersection rebuilds and freeway widening to the “bridge replacement” they avoid any serious public scrutiny of that decision.  And make no mistake:  the wider roadway and rebuilt intersections are nearly twice as expensive as the bridge itself.
This also explains why the two states are wedded to a high fixed span as a replacement for the existing low level crossing.  If they have to rebuild the bridge with a 116 foot (or if the Coast Guard’s guidance prevails, a 178 foot) vertical navigation clearance, the project will require building long elevated approaches on both the North and South of the River.  Interchanges will have to be lifted high into the air to reach the elevated approaches.  Downtown Vancouver and Hayden Island will both have half mile long elevated roadways towering over their communities.  This likely why the DOTs so adamantly oppose either a tunnel or a lower-level crossing with a moveable span:  those designs wouldn’t require rebuilding every intersection, and would demolish their case for wrapping the freeway widening costs into the bridge project.
The failure to consider eliminating or consolidating some intersections is a plain violation of the National Environmental Policy Act.  NEPA requires that sponsoring agencies take a hard look at reasonable alternatives that could potentially meet the project’s purpose and need with fewer environmental impacts.  That’s exactly what this expert review panel—hired by the DOTs—said should be done a decade ago.  Willfully ignoring this information, and not including a serious appraisal of such alternatives in the project’s Environmental Impact Statement rises to the level of an “arbitrary and capricious” decision by the DOTs.  Ordinarily, and for good reason, courts have been loathe to second guess agencies on technical matters.  But this is the kind of egregious and willful disdain for the facts that it rises to a violation of the law.

Pricing works better than spending $1.45 billion to fix I-5 traffic

A recently disclosed ODOT memo shows that congestion pricing would do a better job of fixing I-5 congestion than spending $1.45 billion widening the I-5 freeway at the Rose Quarter

Congestion pricing would would be more than a billion dollars cheaper, would make traffic on I-5 move faster, and would produce less pollution than widening the freeway.

Widening the I-5 freeway would produce 3 million more annual peak hour car trips than if simply implements congestion pricing.

Greener and safer:  Pricing would dramatically reduce traffic in the Rose Quarter, reducing pollution and greenhouse gas emissions, cutting the number of crashes and improving safety, especially for bikes and pedestrians.

ODOT has failed to analyze how congestion pricing would affect Rose Quarter traffic, or to treat it as a reasonable alternative to freeway widening—a clear violation of the National Environmental Policy Act.

ODOT’s congestion pricing model results directly contradict claims made in the Environmental Assessment that freeway widening wouldn’t induce additional traffic and pollution.  The sensitivity analysis modeling shows freeway widening would increase traffic and pollution by 7 to 14 percent compared to a “No Build” scenario.  The modeling also shows that freeway widening would result in slower southbound speeds than the No Build in the morning peak hour.

For decades, economists and transportation scholars have known that peak hour congestion is a product of our failure to accurately price roads.  Under priced roadways lead to congestion and delay–just as Ben and Jerry’s “Free Ice Cream Day” leads to lines around the block.  Highway departments have been in desperate denial of this economic fact, but a secret memo from the Oregon Department of Transportation (ODOT) shows that even highway engineers acknowledge pricing would work much better than expensive expansions.

This is a critical question for the proposed $1.45 billion I-5 Rose Quarter freeway widening project.  This project’s Environmental Assessments have steadfastly maintained that pricing of area freeways is “unforeseeable”–even though the agency is counting on toll revenues to pay for the project.  As a result, ODOT has almost completely omitted any analysis of tolling from the project’s environmental review.  But there is one exception—this July 21, 2022 memorandum from ODOT, looking at how congestion pricing would affect I-5 traffic levels.

A bit of background:  The 2017 Oregon Legislature directed the Oregon Department of Transportation to develop a plan for value pricing for I-5 and I-205 between Wilsonville and the Columbia River.  Around the world, road pricing has proven to be an effective tool for shifting travel demand and reducing congestion.  More than four years ago, ODOT consultants testified that congestion pricing would provide just as much congestion relief in the Rose Quarter as widening the freeway–a finding that this new secret memo confirms.  Despite clear legislative direction to implement pricing, and unequivocal analysis from its own experts, ODOT has simply ignored how congestion pricing could be used to reduce traffic in the Rose Quarter.  ODOT has dragged its feet in implementing this plan (its already been five years since the Legislation direction pricing was signed into law).

This memo summarizes the results of traffic modeling that look at traffic levels in the Rose Quarter area depending on whether the I-5 freeway is widened (or not) and whether road pricing is implemented.  Road pricing has yet another new name in this memo (RMPP-ICPC:  “Regional Mobility Pricing Project/Initial Congestion Pricing Concept”.  The idea is that ODOT will charge time-based tolls (that vary hourly) to regulate traffic on I-5 and I-205 in the Portland area.  This modeling shows how that very basic pricing program will affect traffic levels depending on whether ODOT widens the I-5 freeway or leaves it just as it is.

Here’s a key table summarizing the results for the section of I-5 North of the Broadway-Weidler interchange and the Fremont Bridge.  This is at the very heart of the area affected by the Rose Quarter project.  The two left hand columns (RMPP No Action) correspond to no pricing of I-5 and I-205; the two right hand columns (RMPP ICPC) correspond to variable time based tolls.  Each pair of columns corresponds to either not building (not widening) I-5 or “RQ Build” spending up to $1.45 billion to widen a 1.5 mile stretch of the freeway.

Let’s focus in on the PM peak hour.  Look at the difference between the “price but don’t build” scenario.  Average travel speeds are 42-43 miles per hour with pricing—even if you don’t spend a dime widening the freeway.  This is noticeably faster than if you widen the freeway but don’t implement pricing (in which case traffic moves at 35-39 miles per hour).  In short:  pricing I-5 would result in a bigger improvement in highway speeds on this key segment of I-5 than spending $1.45 billion to widen it.  Of course, if you widen the road and price it, you get even higher speeds (45-46 miles per hour—but thats only a 3 mile per hour increase in peak hour speeds for spending $1.45 billion.

Here’s another way to look at it.  Let’s consider two possible alternatives for 2045:  Road pricing the existing (No-build) roadway or spending $1.45 billion to widen I-5 but not implement pricing.  How does traffic performance change between the “No build with pricing” and the “Widen with no pricing”? It turns out that pricing alone is far more effective in speeding traffic than widening alone.  Pricing results in vastly lower peak hour traffic and faster peak hour speeds that widening the freeway and not pricing it.  This table shows how traffic volumes and speed change from the “No Build” scenario with two different alternatives: widening the freeway (without pricing), and just implementing congestion pricing.


If congestion pricing were treated as an alternative (which it should be) in the Environmental Assessment, it would dramatically outperform the freeway widening alternative.  To see why, let’s compare traffic speeds and traffic volumes in 2045 between the two alternatives.  Congestion pricing alone would reduce traffic by 6,500 vehicles in the two peak hours compared to the no-build, while freeway widening increases traffic by 2,000 vehicles in the peak hours.  The difference between the two alternatives is dramatic:  In 2045, if we implement congestion pricing but don’t widen the freeway that means there would be  8,500 fewer  vehicles transiting the Rose Quarter in the peak two hours.  Thats over 3.1 million fewer vehicles per year traveling through the Rose Quarter during just two peak hours.

At the same time, congestion pricing results in higher speeds on I-5, than  widening the roadway.  Congestion pricing would increase speeds on I-5 by about 12 miles per hour on average during peak hours, about twice as much as widening the freeway–widening the freeway, but not pricing it increases average peak hour speeds by only about 6 miles per hour.  The data here clearly show what economists have been saying all along:  Only by pricing roadways can you reduce congestion and improve travel times. Wider roads are less effective in speeding traffic than road pricing.

But wait, there’s more: Smarter pricing would work even better

This memo reports that ODOT used a fairly “dumb” system of road pricing:  rates that would vary hour-by-hour, but wouldn’t fluctuate with traffic levels.  The most sophisticated pricing systems use real-time traffic flow information to adjust toll levels down and up to keep traffic flowing smoothly.  If ODOT had modeled this kind of real-time variable pricing instead of a fixed hourly schedule, its almost certain than the pricing-only scenarios would have performed even better.

The ODOT modeling also reports travel speeds for the segment of I-5 between I-84 and Broadway-Weidler.  Here pricing speeds traffic, but is less dramatic than for the segment between I-5 and the Fremont Bridge.  But there’s an obvious reason:  the RMPP-ICPC applies only to I-5 and I-205 and not to I-84.  There’s a whole lot of I-84 traffic that isn’t tolled, and therefore is unmetered, and ends up clogging the Broadway-Weidler interchange.  It’s remarkable that traffic speeds fall so sharply South of Broadway-Weidler—but this is most likely an artifact of what roads are tolled and which aren’t.

Missing Toll Levels

The ODOT Memo is silent about a key feature of the tolling:  What level of tolls would be charged under the RMPP-ICPC.  They clearly can’t have done the modeling without knowing what the level of tolls would be, but their memo conspicuously avoids revealing this key detail.  Technical work done for ODOT in 2018 developed the concept of the RMPP, and proposed tolls of 17 cents to 38 cents per mile for I-5.  But ODOT doesn’t want to tell anyone whether that’s the toll level that’s assumed in this modeling.

Violating NEPA

The National Environmental Policy Act requires a careful analysis of reasonable alternatives.  ODOT’s own analysis shows that road pricing would be a reasonable and effective solution to traffic congestion at the Rose Quarter.  It’s time for them to treat this as an alternative, or even more realistically, incorporate pricing into its estimates of “No-Build” traffic levels.

It is apparent from ODOT’s communication that they aren’t considering pricing as either an alternative or part of the “No-Build.”  They continue to maintain that congestion pricing isn’t “reasonably foreseeaable,” even though its been mandated by state law, and ODOT and the federal government are actively working on implementation, and the Chair of the Oregon Transportation Commission has said the state can’t afford the Rose Quarter project without implementing tolling.

The newly disclosed “sensitivity” memorandoum makes it clear that adding road widening to congestion pricing would result in vastly greater driving and carbon emissions:  at least 3 million more peak hour miles driven on I-5

In its review of the Draft EA, City of Portland staff asked how the analysis of pricing was to be  interpreted:  “What is the conclusion of the Sensitivity analysis related to the traffic analysis? What do you do with it?”

ODOT’s Theresa Rolfhs responded:

ODOT has received questions about whether both the RQ project and congestion pricing are both needed to address congestion on I-5. Findings from this sensitivity analysis show that both the RQ project and RMPP are needed to reduce congestion on I-5 to acceptable levels.

K19071 I-5 Rose Quarter Improvement Project, Supplemental EA City of Portland Report Review Log, I5RQ_Traffic_Tech_Report_City_of_Portland_Comment_log_Responses

Actually, ODOT’s sensitivity analysis shows that either pricing or widening the freeway achieve approximately the same improvements in freeway travel speeds, and that both, together, perform somewhat better.  But the claim that “both are needed to reduce congestion to acceptable levels” is not valid:  while traffic flow may be somewhat faster with both measures implemented, ODOT has never defined a level of congestion it deems “acceptable.”  If anything, widening the freeway actually undercuts the benefits of congestion pricing by adding about 3 million peak hour annual vehicle trips to the Rose Quarter. In addition, if congestion pricing is essential to the project being successful (as this statement implies) than pricing needs to be included in the traffic projections for the EIS. It is likely that because traffic flows would be reduced with pricing, that the size and impacts of the project could be reduced from the size needed for the unpriced roadway that ODOT has purportedly studied in the EA.

Bottom line:  The reason we have traffic congestion is that peak hour road capacity is underpriced, encouraging more people to drive than the roads can handle.  If we implement value pricing, road congestion eases dramatically.  Even the highway department’s own technical studies show this is true.

Pricing:  Less traffic, fewer deaths

As we’ve pointed out, the Oregon Department of Transportation has falsely and cynically portrayed the I-5 Rose Quarter freeway widening as a “safety” project.  There’s no evidence that this is a valid claim, and this sensitivity analysis shows that by reducing car traffic in the area, pricing would actually contribute more to safety, especially for vulnerable road users (those walking or cycling near the freeway on- and off-ramps).  The traffic volume estimates provided in the Sensitivity Analysis show that road pricing would significantly reduce automobile traffic in and through the Rose Quarter.  This is important for understanding the environmental, safety and community impacts of the project.

The sensitivity analysis shows, contrary to statements in the EIS, that building the Rose Quarter project would increase traffic on I-5 compared to the No-Build.   Peak hour traffic would be between 7 percent and 14 percent higher under the “RQ Build” option than under the RQ No Build option, assuming the RMPP program isn’t implemented.  (This is relevant because this is what ODOT says is the assumption for the project’s Environmental Assessment).



Second, the sensitivity analysis shows that implementation of the regional mobility pricing program would significantly reduce traffic on I-5 if the Rose Quarter not widened.  Table 2 shows that traffic between the Broadway-Weidler Interchange and I-405 would be more than 20 percent less if pricing is implemented and the Rose Quarter project isn’t built.

This reduction in travel is important for many reasons:  It means that there will be fewer cars traveling through the Rose Quarter, reducing pollution emissions in the local area.  Lower levels of car traffic mean lower levels of emissions.  Reducing car traffic on I-5 is also likely to reduce to reduce the number of cars entering and exiting the I-5 freeway, and lower car traffic in turn lowers risks to vulnerable road users.

Contradicting claims made in the Environmental Assessment

The Rose Quarter Environmental Assessment, released in 2019, made the preposterous claim that widening the I-5 freeway wouldn’t increase traffic or emissions compared to the No-Build.  ODOT never released detailed traffic data or modeling to support this conclusion, and still hasn’t released data on average daily traffic (ADT) the most fundamental measure of traffic volume.  And in its traffic technical analysis for the Revised Environmental Assessment, dated June 2022, the agency has indicated that its standing pat on that dated (and still largely secret) traffic modeling.

But the newly released data in the sensitivity analysis memo flatly contradicts the claims made in the original EA modeling.  Ignoring the pricing scenarios, the sensitivity memo shows that widening the Rose Quarter freeway will produce more traffic on I-5:  In the two peak hours for which traffic data are revealed, the build scenario increases traffic by 13 percent (AM) and 7 percent (PM).  This is plainly evidence of the effects of induced demand:  expanding freeway capacity leads to more driving.  Widening the I-5 freeway results in nearly 1,300 more vehicles in the AM peak hour and 700 more vehicles in the PM peak hour.

This traffic analysis is also not consistent with claims made in the Revised EA that the project will have a trivial net impact on vehicle related emissions in the project area.


The truth about Oregon DOT’s Rose Quarter MegaFreeway

The Oregon Department of Transportation (ODOT) desperately wants to build a mega-freeway through NE Portland, and is planning to double the freeway from 4 lanes to 8 or 10 lanes.  But it has hidden its true objective, by claiming only to add two “auxiliary” lanes to the existing 4 lane freeway, and arguing (falsely) that these lanes won’t increase traffic.  But when you look closely at its sketchy information revealed in its Environmental Assessment, it’s actually building a 160 foot right of way, easily wide enough to accommodate 8 or 10 full traffic lanes. Recent modifications to the I-5 project design on a viaduct section of the project, where ODOT is going to re-stripe the freeway rather than widen the viaduct to add a lane, shows that ODOT can easily squeeze 8 or even 10 lanes into the project.  That’s important because the project’s environmental assessment has neither considered the traffic and pollution from an eight lane freeway, or explained why the right of way needs to be vastly wider than needed to accommodate the supposed 6 lane configuration the agency says it is building.

  • The Rose Quarter freeway widening is now  narrower, which shows ODOT has wide discretion to re-stripe lanes and shoulders to add capacity
  • To avoid intruding on the Eastbank Esplanade, ODOT has dropped its plans to widen the viaduct overhanging the pathway, but will squeeze in another lane of traffic by re-striping the existing 83′ wide viaduct.
  • At the project’s key pinch point, the Weidler overpass, ODOT is engineering a crazy-wide 160 foot wide roadway ostensibly for just for six travel lanes.  But this roadway is more than enough to fit 8 or even 10 lanes of traffic, just by striping it as they are now planning to stripe the viaduct section of the project.
  • ODOT’s environmental analysis has violated NEPA by failing to consider this “reasonably foreseeable” eventuality that ODOT will re-stripe the project to 8 or more lanes, which would produce even more traffic, air pollution and greenhouse gases, impacts that are required to be disclosed.
  • ODOT has also violated NEPA by failing to consider a narrower right of way: 96 feet would be sufficient to accommodate its added “auxiliary lanes” and would have fewer environmental impacts and lower costs.
  • ODOT’s safety analysis for its narrowing of the viaduct section shows that narrower lanes and shoulders make almost no difference to the crash rate, and further show that the project’s claims that it would reduce crashes on I-5 by 50 percent are exaggerated by a factor of at least seven. The analysis also shows that the project has a safety benefit-cost ratio of about 1 to 200, meaning it costs ODOT $2 for 1 cent of traffic crash reductions, about 2,000 times less cost-effective that typical safety projects.
  • The safety analysis also confirms that ODOT made now allowance for the effects of induced demand:  It makes it clear that the project assumed that traffic levels would be exactly the same in 2045 regardless of whether the freeway was expanded or not.

In a seemingly innocuous appendix to its Finding of No Significant Impact (FONSI), ODOT has tipped its hand:  It’s really building the right of way for an 8- or 10-lane freeway at the Rose Quarter.  The reason this project’s budget has ballooned from $450 million in 2017 to $1.45 billion today is because they’re not simply adding a single so-called “auxiliary” lane, but instead are doubling the freeway’s footprint as it cuts through North Portland.

ODOT narrows part of its proposed I-5 freeway to protect a park

ODOT had a problem with the Eastbank Esplanade. It’s a linear parkway that between  the Willamette River and I-5.  The original proposal for the freeway widening project called for this section of freeway, which rises on a viaduct, to be widened into the park.  Unlike other requirements of NEPA, which are essentially procedural, and only require disclosure of impacts, provisions pertaining to parks have real teeth.  Expanding highways onto public park lands has to comply with tougher requirements under what is called Section 4(f).

ODOT initially tried to conceal the intrusion of the widened freeway viaduct onto the Esplanade.  The agency didn’t publish detailed design drawings as part of the Environmental Assessment.  It produced these preliminary engineering plans only after threat of legal action (and after denying that they even existed). The plans became available only days before the deadline for public comment on the project EA. Even then, it took sleuthing by project opponents to discover and document the widened viaduct.

A widened viaduct would have extended over the Eastbank Esplanade. Illustrations produced by Cupola Media from data suppressed by ODOT.  (Bike Portland)

Recognizing that they were unlikely to meet the 4(f) requirements, or would be dramatically delayed by doing so, ODOT project engineers decided to simply lop off the viaduct-widening portion of the project.  Instead of widening the viaduct section to 105 feet, ODOT will simply re-stripe the existing 83 foot wide viaduct section with narrower lanes and narrower shoulders. (Lane width data calculations shown in Appendix, below). And apparently, they decided this very recently:  The safety analysis for the new narrower viaduct section memorandum is dated October 6, 2020 and was last revised on October 23, 2020, only a week before the FONSI decision (dated October 30, 2020).  (This document now appears in the Rose Quarter Library here).

Because it is not widening this 1,200 foot stretch of the I-5 freeway, but wants to add another travel lane to I-5, ODOT has now decided that it can have both narrower shoulders and narrower vehicle travel lanes on this stretch of the freeway. Here is its description of current conditions (the No Build-83′), the revised plan (“Scenario 1”-also 83′), and the widened viaduct originally proposed in the EA (“Scenario 2”-105 feet).

This decision and its supporting analysis proves two key points:

First, that ODOT can and will re-stripe existing roadways to provide more capacity, and there’s nothing about their regulations, engineering practice or concerns about safety, that preclude them from doing so.  The memorandum essentially argues that there’s only a minor increase in crashes as a result of the lane and shoulder narrowing, and that this is acceptable.  It also notes that a “design exception” will be required, but that’s in no way a barrier to undertaking this action.  (In essence, if it’s necessary to avoid an environmental impact, ODOT believes it has complete flexibility to make an exception to its design standards to narrow both lanes and shoulders).

Second, the safety analysis presented here undercuts all of the overblown claims that widening I-5 is a “safety project”—time and again, ODOT officials have cited the inadequate width of the freeway and its narrow shoulders as safety problems.  All this is was a big lie, as we and other independent observers have documented..  And ODOT has even conceded that we were right in our critique.  But this new analysis shows that the crash reduction from wider roads is trivial.  The analysis estimates the value of crash savings from the project $400,000 per year. (Never mind, for a moment that these estimates are almost certainly wrong because they are computed using an ISATe model that explicitly says that it cannot be used to compute crash rates for freeways with ramp metering, which this section of I-5 has).  Even relying on ODOT’s own calculations, the safety benefits of this project are negligible, so much so, that ODOT has no trouble narrowing both lanes and shoulders in a significant section of the project.

Why is this 6 lane freeway 126 feet wide? ODOT’s real plan for an 8-lane freeway

Nearly two years ago, we called out ODOT for failing to disclose that what it was proposing to build at the Rose Quarter was really a massive, eight-lane freeway. It was engineering a broad right-of-way, that with a few gallons to paint, could easily be striped to provide 8 full travel lanes, four in each direction, essentially doubling the capacity of the roadway through the Rose Quarter.

Forget for a moment the labels ODOT attached to lanes, and look, simply at the actual width of the highway right of way they are proposing to build. Take out your tape measure, and follow along.  From curb to curb at the NE Weidler overpass, they’re planning to widen the freeway’s footprint from 83 feet to 126 feet. It’s actually a challenge to figure out how wide the freeway is and how much wider it’s going to be, because ODOT consciously chose to exclude that data from most of the project’s Environmental Assessment.

Currently, most of the corridor is 83 feet wide.  This image, taken from Google Maps, show cross-section of the existing I-5 freeway, just south of the key Weidler overpass, As Google Maps scale measure indicates, this freeway cross sections is approximately 83 feet wide.

I-5 at NE Weidler Overpass. Width 83 feet (Google Maps)

ODOT has not released detailed cross-sectional plans of what it proposes to build.  The project’s Right of Way technical report, has this crude illustration of existing and proposed widths. Note that in the “Existing conditions” section, ODOT has left out the width of inside and outside shoulders (“varies”), which obscures the exact width of the overall cross section, which we know from Google maps to be 83 feet at the Weidler overpass.

The proposed width of the I-5 freeway can be calculated (roughly) from the ODOT diagram.  If we add together the travel lanes, the shoulders and an allowance for the width of the median barrier, we get roughly 126 feet—six 12-foot travel lanes, four 12-foot shoulders and an additional six feet for the width of the barrier (72+48+6=126).  (See Appendix below for additional detail).

Why, might you ask, has ODOT selected 12-foot inside and outside shoulders?  No explanation is provided for this exact choice in the EA.  (ODOT asserts that wider shoulders are needed for “safety”—more about that claim below—but that doesn’t explain the choice of 12 feet.  In fact, 12 feet is vastly wider than any shoulder width on an urban stretch of I-5 anywhere in the City of Portland.  Typical shoulder widths are 4-8 feet.

The real reason for these excessively wide shoulders is to allow ODOT to re-stripe this section of freeway at some future date to allow eight lanes of traffic.  Here’s how.

A 126 foot right of way can easily accommodate 8 lanes of traffic.  Here we’ve juxtaposed ODOT’s illustration of the proposed freeway cross-section with six traffic lanes from the EA, with a revised version that adopts the shoulder widths ODOT has adopted for the revised viaduct section.


These shoulder and lane width measurements for this potential future re-striping  are taken directly from ODOT’s own memorandum describing its revised design for the viaduct section of the I-5 freeway.  We’ve simply applied these same measurements—6.5 foot outside shoulders, 4 foot inside shoulders and a mix of 11 and 12 foot travel lanes—to this 160 feet of right of way.  We even have about 8 feet of roadway left over.  The point is that ODOT has proposed to construct a roadway that could easily be reconfigured to carry eight or ten lanes of traffic with a few gallons of paint.

Re-striping for 8 or 10 lanes is a reasonably foreseeable event

Not considering the possibility that a wider I-5 could be re-striped for 8 or 10 lanes of traffic is a violation of the National Environmental Policy Act’s requirement that the agency disclose and evaluate the cumulative impacts of reasonably foreseeable future events.

ODOT’s analysis of the environmental effects of the Rose Quarter project is based on the premise that there are only six lanes of freeway capacity through the Broadway-Weidler section of the I-5, and that widening the road to from four to six lanes in this area will have no effect on freeway traffic volumes. (This flies in the face of what we know about induced demand).

But more to the point:  the EA failed completely to consider the traffic and environmental effects of an eight- or ten-lane freeway.  And because the project is constructing a 160-foot right of way, it has more than enough room to increase the freeway to 8 or 10 full travel lanes with even wider shoulders than it is proposing on the re-striped viaduct section.  This is important because, having built such a wide right-of-way, it is in fact “reasonably foreseeable” that in the future, ODOT will fire up its paint trucks and re-stripe this section of the freeway—just as it has effectively done with the revised plan for the viaduct section.

It doesn’t matter whether ODOT has “no current plans” to widen the freeway to 8 or 10 travel lanes or not.  The agency’s intent is not the legal standard. The standard instead is whether it’s reasonably foreseeable that an agency might do so.  Given that they designed a right-of-way easily wide enough to handle eight or ten lanes, and that the agency’s own analysis shows neither lane widths nor shoulder widths make much difference to safety, and that the agency is willing to re-stripe an existing section of the same roadway to accommodate more traffic, and that the sponsoring agency, FHWA, regards such restriping projects as a “best practice”—even holding up ODOT’s work as a national example—it’s quite clear than one can reasonably foresee that once this project is built at its much larger scale, with wider shoulders than found anywhere else on the urban sections of I-5, that in the future the agency may re-stripe it to eight or ten through travel lanes.

What NEPA then requires is that ODOT evaluate the likely environmental impact of an eight- or ten-lane freeway in this area—something it simply hasn’t done.  If it analyzed the impact of an 8- or 10-lane roadway here, it would get much higher traffic counts, many more vehicle miles traveled, more air pollution and greenhouse gases.  These are exactly the kinds of impacts that ODOT is required to reveal as the likely “cumulative impact” of their chosen project—and they have not done so.  This omission alone should force the agency to conduct a full Environmental Impact Statement.

Why build 160 foot freeway?  Why not much narrower and less disruptive?

ODOT has also violated NEPA for failing to consider a narrower right of way through the project area.  What remains completely unexplained and unexplored in the EA is why, assuming it needed only six lanes, the agency elected to build a 160 foot wide right of way.  This will be extremely expensive, both for additional land acquisition and construction costs.  If it were truly interested in only a six-lane cross-section, the right of way, using ODOT’s own standards (from the viaduct section), would only need to be 96 feet wide (See Appendix for calculation).  That smaller cross-section would be cheaper to build and would have fewer environmental impacts, both because it would be less disruptive to existing adjacent uses like Harriet Tubman Middle School, but also because it would foreclose the future risk of the freeway being widened to eight lanes.  ODOT’s own engineering consultants, ARUP, have said that the project could be at least 40 feet narrower than what ODOT is proposing if the need is for a total of six travel lanes.  Again, the purpose of NEPA is to force agencies to consider a range of options, and present objective information on the relative environmental consequences of different options. By not looking at a 96-foot (or similarly narrower) right of way for the widened freeway, ODOT has violated NEPA.

In addition, the much wider freeway right of way makes it much more difficult and expensive to construct freeway covers that would support buildings, as some in the community are calling for.  The reason is that a 160 foot freeway footprint would require spanning a 80 foot clear area (assuming that supports are built on the side and in the median of the freeway).  If the freeway were only wide enough for 3 lanes, plus the type of shoulders ODOT is now proposing for the viaduct, the clear span distance would be about 50 feet. It would also reduce the cost of the project—less excavation would be required, overpasses and other structures would not have to be as large.

Widening the I-5 Rose Quarter does virtually nothing for safety

In theory, one reason that ODOT could argue that they need a 160 foot right of way for the Rose Quarter is safety.  But this new safety memorandum disproves that point.  It argues that shoulder widths of as little as 4 feet and narrower travel lanes make almost no difference to the safety level of I-5.

ODOT’s consultants say they have used the “Enhanced Interchange Safety Analysis Tool (ISATe)”  model to estimate crash rates under the No-Build scenario, and for the original and modified build alternatives (i.e. with and without a widened viaduct section).  This analysis claims that narrowing the lanes on the viaduct section would actually increase crashes on that section of the highway, increasing annual damages by about 6 percent over No-Build levels.  Implicitly, ODOT is saying that when there are environmental concerns—in this case the intrusion of the freeway onto the Eastbank Esplanade—safety is here is no big deal and it’s perfectly justifiable to shrink the freeway shoulders and lane widths.

It’s also important to note in passing, that the ISATe model is not valid for making estimates of crash rates or crash changes on I-5.  The model’s methodology explicitly states that it does not apply to freeways with ramp-metering.  Ramp meters smooth traffic flow and tend to dramatically reduce crash rates.  ODOT and its consultants erred in using this model to estimate and make claims about the I-5 project.

Overall, the safety memo concludes that the $1.45 billion dollar project in total reduces the dollar value of crashes in the area by about 7.5 percent, from about $5.9 million per year to about $5.4 million per year.   Not only is this a very small (and speculative) reduction in the economic cost of crashes on I-5, the magnitude of these crash losses is tiny, especially relative to the cost of the project.  Total savings of the project with the modified design are about $432,000 per year, compared to a project cost of roughly $1.45 billion.  At a 5 percent discount rate, the $432,000 in annual crash savings has a present value of about $6.6 million, meaning that this project has a benefit cost ratio of less 1 to 200, i.e. you have to spend 2 dollars to get one cent in benefits. This is an extraordinarily poor return on investment.


This analysis shows that ODOT made false claims about the safety effects of the project.  Project materials claim that the project will reduce crashes by up to 50 percent. The Project’s website claims that the project’s added lanes and wider shoulders will speed the flow of traffic and concludes:

Adding these upgrades is expected to reduce crashes up to 50 percent on I-5 . . .

It has gotten this same claim repeatedly published in the media by Willamette Week, The Columbian, and the Portland Tribune, and ODOT officials have testified to the same to the Oregon Legislature.

These data show that the change in crashes will be less than 10 percent. This means that ODOT’s claims that the project will reduce crashes by as much as 50 percent overstate the reduction by a factor of seven (a 7.4 percent reduction is roughly one-seventh of a 50 percent reduction).

In addition, these crashes are overwhelmingly non-injury fender-bender crashes.  They’re not the crashes that regularly occur on ODOT highways in the Portland area that maim and kill hundreds of Oregonians each year.

Judged as a safety project, the Rose Quarter is an incredible waste of resources.  ODOT runs a competitive safety grant program “All Roads Transportation Safety (ARTS)“.  Typically the projects that are awarded funding have benefit cost ratios well above one.  The top nine Region 1 projects awarded in 2018 had benefit/cost ratios of more than 10 to 1, meaning they are about 2,000 times more cost effective than the Rose Quarter freeway widening as a “safety” project.

Proving ODOT failed to consider induced demand

The ODOT safety analysis sheds some light on an issue that ODOT has long concealed:  whether the project considered the effects of induced travel.  A robust and growing body of scientific literature has confirmed the “fundamental law of road congstion”: expanding urban roadways tends to encourage more driving.  The best estimates are that a one percent increase in freeway capacity leads to a one percent increase in vehicle miles traveled.  ODOT has made vague claims that its modeling somehow dealt with this issue, but the safety report shows that ODOT either completely discounted or ignored induced travel.  At two points, the safety report states that traffic levels on the viaduct section of the Rose Quarter project will be the same whether one lane is added, or whether the freeway stays its current width.  In three separate locations, the memorandum states:

AADT [annual average daily traffic] is the same for all scenarios

Here’s a screenshot that explicates this assumption:

What the safety analysis is saying is that whether the freeway has five lanes or four in this cross-section it will carry exactly the same number of vehicles.  That’s contradicted by the induced travel science, which suggests that a 50 percent increase in freeway capacity (from two lanes to three) will likely lead to a 50 percent increase in vehicle travel.  This is important, because if traffic volume increases, that will more than offset the gains from the small reduction in the rate of crashes.  By ignoring induced travel, the safety analysis understates the number of crashes associated with the build alternative.

Appendix:  Analysis of Freeway Width, I-5.

The following table shows the estimated width of the I-5 freeway, as currently built, and as proposed to be constructed as part of the I-5 Rose Quarter freeway widening project.  These data are estimated from the EA Right of Way Report, the Predictive Safety Analysis Memorandum and Google Maps as described in the text above.


While it has done this analysis for the viaduct section, the EA has no analysis of an alternative with a narrower cross section through the Broadway-Weidler section of the project.  If ODOT were to narrow this section of the project to 96-feet from 126 feet, it would reduce the impact on adjacent properties.



The Week Observed, December 16, 2022

Editor’s Note:  Public Comment on the I-5 Rose Quarter Freeway Project

Between now and January 4, 2023, the public will be asked to weigh in with its comments on the proposed I-5 Rose Quarter Freeway Widening project.  If you’re interested, you can make your voice heard.  For more information on how to comment, we urge you to visit No More Freeways’ website.  For the rest of this month, City Observatory will be presenting a synopsis of its independent research on the project.

What City Observatory did this week

Blame inflation now: Lying about the latest IBR Cost Overrun.  The price of the I-5 “bridge replacement” project just increased by more than 50 percent, from $4.8 billion to $7.5 billion.  ODOT and WSDOT are blaming “higher inflation” for IBR cost overruns. As we’ve noted, the Oregon Department of Transportation has a long string of 100 percent cost-overruns on its major projects.  Almost every large project the agency has undertaken in the past 20 years has ended up costing at least double–and sometimes triple–its original cost estimate. The data don’t support their claim–their own agencies official projections of future construction price inflation show a negligible change from 2020 levels.

Higher construction cost inflation accounts for only $300 million of a $2.7 billion cost increase.  

The Oregon Department of Transportation’s Empty Promises for a Rose Quarter Freeway Cover.  ODOT’s Supplemental Environmental Analysis shows it has no plans for doing anything on its vaunted freeway covers. It left the description of cover’s post-construction use as “XXX facilities” in the final, official Supplemental Environmental Impact Statement.  So maybe, a strip club or an adult book store on the freeway cover?

The report makes it clear that “restorative justice” is still just a vapid slogan at the Oregon Department of Transportation. In short, ODOT has no plans to construct covers that will support significant buildings, no plans for any meaningful use of the covers after the highway is complete, and no funding for it (or anyone else) to develop anything on the highway covers.  And if somebody else does have an idea, they’ll have to pursue it with their own money, and they’d better bring lots of lawyers, because it’s not going to be easy.  In the meantime, Albina, enjoy your “XXX facilities”—we’re sure they’ll be special.

A million more miles of traffic on local streets thanks to Rose Quarter Freeway Widening.  ODOT’s proposed relocation of the I-5 Southbound off-ramp at the Rose Quarter will add 1.3 million miles of vehicle travel to local streets each year.  Moving the I-5 on ramp a thousand feet further south creates longer journeys for the 12,000 cars exiting the freeway at this ramp each day.

The new ramp location requires extensive out-of-direction travel for all vehicles connecting to local streets.  With more miles driven on local streets, and more turning movements at local intersections, hazards for all road users, but especially persons biking and walking, increase substantially. More driving on neighborhood streets increases local pollution and greenhouse gas emissions.

In the News

Willamette Week featured comments by Joe Cortright on the 56 percent increase in the cost of the proposed Interstate Bridge Replacement project to $7.5 billion, noting we had predicted the price increase six months ago:
Today’s increase did not surprise Joe Cortright, the Portland economist who has closely followed this iteration and the earlier version of the same effort, the Columbia River Crossing Project. In a May piece for City Observatory, Cortright wrote, “The IBR is likely to be a $5-7 billion project.”

The Week Observed, December 2, 2022

Editor’s Note:  Public Comment on the I-5 Rose Quarter Freeway Project

In the next month, the public will be asked to weigh in with its comments on the proposed I-5 Rose Quarter Freeway Widening project.  If you’re interested, you can make your voice heard.  For more information on how to comment, we urge you to visit No More Freeways’ website.  For the rest of this month, City Observatory will be presenting a synopsis of its independent research on the project.

What City Observatory did this week

Why won’t ODOT tell us how wide their freeway is? After more than three years of public debate, ODOT still won’t tell anyone how wide a freeway they’re planning to build at the Rose Quarter. ODOT’s plans appear to provide for a 160-foot wide roadway, wide enough to accommodate a ten lane freeway, not just  two additional “auxiliary” lanes.  In reality, ODOT is planning a 10 lane freeway.

ODOT is trying to avoid NEPA, by building a wide roadway now, and then re-striping it for more lanes after it is built. The agency has utterly failed to examine the traffic, pollution and safety effects of the ten-lane roadway they’ll actually build.

Exposing the black box calculations that highway builders use to sell their projects.  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.

Oregon Department of Transportation admits its re-design of the I-5 Rose Quarter project will create a dangerous, substandard freeway exit and increase crashes.  Earlier, City Observatory pointed out that a new design of Portland’s $1.45 billion I-5 Rose Quarter freeway widening will construct a dangerous hairpin turn for vehicles exiting the I-5 freeway into Northeast Portland.

The project’s own Supplemental Environmental Assessment confirms our analysis.  This 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

Must read

USA, USA!  Number one . . . for traffic deaths.  A terrific data-driven story from the New York Times’ Emily Badger and Alicia Parlapieano points out an unfortunate area of American exceptionalism:  traffic deaths.  The US now has a higher death rate from traffic crashes that almost every advanced economy.  And while the rest of the world has been steadily reducing crash deaths, they’ve been going up, especially for vulnerable road users.  The key findings are spelled out in a compelling chart showing the number of traffic deaths per capita for major countries.

There have been some counter arguments that the US death rate isn’t so high if you compute it on a “per mile traveled” basis, rather than per capita, but that misses two key points.  First, America’s excessive auto dependence is what forces Americans to drive long distances; and every mile traveled is an additional risk, both to the person traveling and to other road users.  And second, even after adjusting for miles traveled, the trend is still in the wrong direction:  the US is getting significantly less safe that other industrialized nations, something we’ve pointed out for years at City Observatory.

Widening that freeway won’t lessen congestion, it will increase pollution.  Austin’s LMT Online responds to the plaintive cries that I-35 is congested with exactly the right tone:  so what?  Highway apologists at the Texas Transportation Institute call the highway one of the busiest in Texas, but time and again, experience has shown that widening roadways actually doesn’t reduce congestion, it just prompts more people to drive further and fuels more sprawl and car dependence.  TXDOT is proposing a $5 billion widening of I-35 through Austin.  The city’s residents will get a chance to weigh in on that decision when they choose a new Mayor soon:  one candidate favors the freeway, his opponent is against.  We’ll watch to see if Austin is learning, or if it continues to believe that just one more lane will fix things.

In the News

The Portland Mercury quoted Joe Cortright’s analysis of induced demand from the I-5 Rose Quarter Freeway widening project.

Traffic is declining at the Rose Quarter: ODOT growth projections are fiction

ODOT’s own traffic data shows that daily traffic (ADT) has been declining for 25 years, by -0.55 percent per year

The ODOT modeling inexplicably predicts that traffic will suddenly start growing through 2045, growing by 0.68 percent per year

ODOT’s modeling falsely claims that traffic will be the same regardless of whether the I-5 freeway is expanded, contrary to the established science of induced travel.

These ADT statistics aren’t contained in the project’s traffic reports, but can be calculated from data contained in its safety analysis.

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

As we’ve noted, the Oregon Department of Transportation claims it needs to widen the I-5 freeway to meet growing traffic demand.  But the agency has been utterly opaque in either presenting its data or describing the methodology it used to reach that conclusion.  Neither its draft or supplemental environmental analyses contain any presentation of “average daily traffic” presently or in the future; and ADT is the most basic and widely used measure of traffic.  Asked about its methodology, the agency makes vague references to a 40-year old traffic forecasting handbook.  This opaque approach to fundamental data both violates NEPA, and the agency’s only standards for professional and ethical practice.

At City Observatory, we’ve found ODOT data—material not included in the project’s Traffic Technical Report—which show that traffic levels on I-5 in the Rose Quarter have been declining for a quarter century, and that the project is assuming that the next twenty five years will suddenly produce a surge in traffic.

Traffic Trends in the Rose Quarter

ODOT maintains a traffic counting program that tracks the number of vehicles traveling on every major roadway in Oregon.  We examined the on-line versions of ODOT’s Traffic Volume Tables for the years 1996 through 2019 (i.e. the last full year prior to the Covid-19 pandemic) to establish the historical trend in traffic.  We looked at data for the section of I-5 at NE Holladay Street (in the middle of the proposed I-5 Rose Quarter freeway widening project.  In 2019, the average daily traffic (ADT) in this section of the Roadway was 118,900 vehicles. That volume of traffic was lower than every year from 1996 through 2017.  As the following graph makes clear, the long-term pattern in traffic on this portion of I-5 is downward.

From 1996 through 2019, the average annual change in traffic on this stretch of I-5 was -0.55 percent per year.  That downward trend also holds for the last decade:  from 2009 through 2019, the average annual change in traffic was -0.30 percent per year.  Contrary to the claims of ODOT that this stretch of freeway is seeing more traffic, traffic has actually been decreasing.  Nothing in the historic record provides any basis for a claim that traffic on this section of freeway will increase if its capacity is not expanded.

ODOT’s Hidden ADT forecast

As we’ve noted multiple times at City Observatory, the traffic reports contained in ODOT’s Environmental Assessment (EA) and Supplemental Environmental Assessment (SEA) do not contain any references to Average Daily Traffic.  The project’s safety report, however, does contain an indirect reference to average daily traffic.  This report uses a safety handbook to compute the number of crashes that are likely to occur on this section of freeway.  The handbook method relies on applying a crash rate of a certain number of crashes per million vehicle miles traveled on a stretch of roadway.  While ODOT’s safety report doesn’t reveal the ADT figures used, we can use algebra to compute the ADT.  ODOT reports the number of crashes and the crash rate per million miles traveled and also the total number of lane miles of freeway included in the analysis.  From these three bits of information, we can work out that the average daily traffic for this section of the I-5 freeway is estimated to be 142,000 in 2045.  Here are our calculations:

We estimate the implied annual vehicle miles traveled in millions by dividing the predicted crashes by the predicted crash rate.  We then estimate daily vehicle miles traveled by dividing annual VMT by 365.  Finally, we computed average daily traffic by dividing VMT by the number of miles in the subject roadway segment (1.4).  This produces an estimate of approximately 142,000 ADT for this segment of I-5 in 2045.

This future traffic level forecast implies that traffic will increase by about 22,000 vehicles per day between 2019 and 2045.  This works out to an annual growth rate of 0.68 percent.  In essence, ODOT is predicting that even though traffic has declined by 0.55 percent per year for the past quarter century, it will over the next quarter century grow by 0.68 percent per year.  How or why this is likely to happen is never explained or documented in the EA or Supplemental EA.

Also, as we’ve noted before, ODOT’s traffic forecast for the I-5 Rose Quarter, according to its safety analysis, is for the same level of traffic in 2045 in both the Build and the No-Build scenario.  This claim flies in the face of what we know about the science of induced travel:  the construction of additional lanes creates added capacity, which will induce more trips in the corridor—if the project is built, but not if it isn’t. The prediction of higher traffic levels for a build scenario may be plausible, but for a no-build scenario it is unlikely that there would be any traffic growth, especially given the established 25-year trend of declining traffic on this portion of I-5.  By over-estimating travel in the No-Build scenario, the EA conceals the increased driving, pollution and likely crashes from widening the freeway.

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 $1.45 billion 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.

No New Regional Modeling

The Traffic Technical Report of the Supplemental Environmental Assessment makes it clear that ODOT has done nothing to update the earlier regional scale traffic modeling it did for the 2019 Environmental Assessment.  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.

What ODOT has never done is “show its work”—i.e. demonstrate how its estimates and modeling turned a highway that was seeing declines of 0.55 percent per year for a quarter century into one where we should expect 0.68 percent increases in traffic ever year for the next quarter century.  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

ODOT has gone to great lengths to conceal its actual estimates of future average daily traffic on I-5.  Neither the 2019 Environmental Assessment, nor the 2022 Supplemental Environmental Assessment’s traffic reports contain any mention of average daily traffic.  As illustrated above, ODOT also expunged the actual ADT statistics from the safety report as well (even though its calculations make it clear that it is assuming that this stretch of freeway will have 142,000 ADT.  And when you look at what is presented, ODOT has purposefully excluded any indication of actual traffic levels.  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.


Appendix:  Expert Panel Critique of Rose Quarter Modeling

RQ Model Critique

Updated December 2, 2023