Three big flaws in ODOT’s Highway Cost Allocation Study

There are good reasons to be dubious of claims that trucks are being over-charged for the use of Oregon roads.

The imbalance between cars and trucks seems to stem largely from the Oregon Department of Transportation”s decision to slash maintenance and preservation, and spend more widening highways.

ODOT could largely fix this “imbalance” by spending more fixing roads, and less on widening them.

ODOT has illegally included federal funds in its cost allocation study; the state’s law and constitution apply only to state funds.

ODOT has gone out of its way to scapegoat bike and pedestrian projects, which are mostly paid for with federal funds—that aren’t even properly included in the allocation study.

And the highway cost allocation study leaves out huge social, environmental and fiscal costs that cars and trucks impose on society and on the state.

In January, the Oregon Trucking Association filed suit against the State of Oregon, alleging that trucks were being illegally over-charged for their use of Oregon roads. The lawsuit is based on a provision of Oregon law that requires a “fair” division of road costs between trucks and cars, and an arcane report called the “Highway Cost Allocation Study (HCAS).”

The truckers point to the latest version of this biennial study, which in June concluded that trucks were responsible for 26 percent of highway costs, but contributed 36 percent of state highway revenue. The difference, about $200 million per year, they argue represents the amounts that they are being overcharged.

There are, however, several huge problems with this study, which neither the truckers nor the Oregon Department of Transportation are willing to acknowledge.

The imbalance is due to spending less to fix roads and more widening them

The first is the “imbalance” problem is largely due to ODOT’s decision to spend less on preservation and maintenance (re-paving, filling potholes), which are costs attributable primarily to trucks, and to spend more on expanding Portland area highways (which are costs attributable to cars). As we’ve pointed out at City Observatory, ODOT has systematically shortchanged preservation and maintenance to cobble together money for highway expansion projects. And recently, in threatened to slash snow plowing, even as it racked up massive cost-overruns for highway expansion projects. All this is fueling the “imbalance.”

According to HCAS, almost half of the imbalance is due to a “change in project mix.” The HCAS study finds that different kinds of expenditure are differently attributable to cars and to trucks. Expanding peak hour capacity is attributed mostly to peak hour VMT (overwhelmingly cars).

ODOT has cut spending on pavement maintenance and preservation from 24% of expenditures to 15% of expenditures. At the same time, it has doubled the share of its spending on Preliminary Engineering (i.e. planning for a series of freeway widening proejct) from 3% to 6%. (ODOT presentation, Slide 17).

What this means is ODOT could reduce or resolve the cost- responsibility problem by spending more on the highway costs that are attributable to trucks trucks, i.e. repaving roads.

Illegally counting federal funds

A second problem is that the HCAS illegally mingles federal funds with state funds in its calculations.. The HCAS law applies ONLY to state revenues, but ODOT has chosen to count federal funds as well. There is no legal reason why federal funds spent on bike/ped projects, for example, should affect the HCAS allocation, but ODOT pretends they do. And, as you know, for every single project, ODOT knows to the penny how much federal money it spent on that project.

ODOT illegally includes federal funds in the HCAS. Federal funds spent on bikes, transit and pedestrians gets counted as influencing the cost allocation of state funds, which is not consistent with the Oregon Constitution or Oregon Law. ODOT should exclude all federal funds from the HCAS.

Nothing in the law or constitution directs or authorizes including federal funds in the HCAS calculations. The HCAS requirement applies exclusively to state authorized road user fees. The Oregon Constitution is clear that this applies only to state taxes and fees:

(3) Revenues described in subsection (1) of this section that are generated by taxes or excises imposed by the state shall be generated in a manner that ensures that the share of revenues paid for the use of light vehicles, including cars, and the share of revenues paid for the use of heavy vehicles, including trucks, is fair and proportionate to the costs incurred for the highway system because of each class of vehicle. The Legislative Assembly shall provide for a biennial review and, if necessary, adjustment, of revenue sources to ensure fairness and proportionality.

Oregon Constitution, Article IX(3a) (Emphasis added)

ODOT is strictly accountable to show that it spends federal funds and state funds only on eligible uses. It legally tracks the use of federal funds for every project separately. There’s no technical reason these can’t be excluded. ODOT includes these funds based on the false claim that federal and state funds are “interchangeable,” something they maintain is impossible in every other context.

State Expenditures. All state expenditures of highway user fee revenues are allocated to vehicle weight classes, as are all state expenditures of federal highway funds (e.g., matching funds). Federal funds are included because they are interchangeable with state user fee revenues. Any differences in the way they are spent are arbitrary and subject to change.

ECONW, 2021-23 Highway Cost Allocation Study, Page 16 (emphasis added)

Any court that takes a close look at the Highway Cost Allocation Study will have to conclude that ODOT has committed a serious error by co-mingling federal funds (which aren’t subject to the HCAS requirement) with state funds (which are). If the study were revised to include only at state funds, which is all the law applies to, there may not be an imbalance at all.

ODOT singles out an increase in spending on bike/ped projects as a reason why the mix of projects it funds are shifting the revenue allocation away from trucks.

A ODOT second slide emphasizes spending on bike/ped projects; there is no comparable slide showing the $622 million allocated for the I-205 Abernethy Bridge project, which is overwhelmingly state funding, and which dwarfs the amount spent all on bike and pedestrian projects.. ODOT has made a conscious decision to scapegoat bikes, while it says nothing about the billions of dollars it is spending on highway expansion projects, which are experiencing vast cost overruns.

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ODOT is including several almost entirely federally funded bike/ped projects to influence the HCAS. There’s no legal or logical reason why amounts of federal funds spent on bikes, pedestrian facilities or transit should affect the allocation of state funding between cars and trucks.

Plenty of other problems with highway cost allocation

The illegal inclusion of federal funds in the cost allocation study is just the tip of the iceberg of questionable assumptions behind the study. Here are three other issues that should be considered.

First, the study doesn’t fully address the social and environmental costs of roads. The HCAS study looks only an road expenditures, and doesn’t look at all the other costs that cars and trucks impose on society, and on state and local government. The cost of pollution, crashes, policing, stormwater runoff, climate change and other costs are not reflected in the study. The US Congressional Budget Office estimates that heavy trucks cause $57 billion to $128 billion in social and environmental cost per year, several times what they pay in all state and federal user fees. If we include all the direct and indirect costs associated with roads, both cars and trucks are massively subsidized, and pay far less than their “fair share” toward the cost of roads.

Second, there are many essentially arbitrary assumptions in the HCAS. Chief among them: the allocation of administration costs. More than a fifth of all spending is treated as “administration.” The study chooses to allocate these solely based on vehicle miles traveled, which disproportionately attributes these costs to cars rather than trucks. Instead, the administrative costs could be just as reasonably allocated proportional to all other costs in the study (this would be essentially neutral between cars and trucks–it would say that administration doesn’t influence the cost allocation.

Third, the HCAS isn’t really a cost allocation study, its an expenditure allocation study. The highway system incurs costs, particularly for deferred maintenance, whether it pays them in any given year or not. Arguably, the imbalance in the current study reflects ODOT’s failure to deal with its substantial maintenance backlog. It has cut spending on fixing roads, and spent more on expanding them—but these costs have not been avoided, they’ve merely been postponed, and likely increased, as a result. A true “cost allocation” study would make an allowance for the annual depreciation and maintenance costs that the system incurs, whether or not ODOT spends money on these items in any particular year. Ironically, this is exactly the approach that ODOT is employing to set its budget for tolled roadways: setting aside funds from tolls to cover future capital replacement, repair, and operating costs. ODOT has shown it can easily apply this basic accounting accounting concept to highways.

Bike Portland Interviews Joe Cortright on the Highway Cost Allocation Study

Jonathan Maus of Bike Portland interviewed Joe Cortright about the highway cost allocation study here

The Week Observed, February 16, 2024

Must Read

The freeway cap mirage.  Don’t like freeways?  Let’s just cover up the problem.  It’s increasingly popular to try to repair the damage done to urban neighborhoods by “capping” freeways:  building a cover so that the road is less visible.  While that’s widely seen as an improvement, some are pushing back that its really a band-aid on a gaping wound that actually doesn’t solve the problem.  Writing at Bloomberg Cities, Benjamin Schneider describes growing opposition to a proposed freeway cover over the Kensington Parkway in Buffalo.  Local activists are suing to stop the project, which papers over the problem, but doesn’t solve it:

But instead of embracing the plan to heal the neighborhood, Ladiana and her husband Terrence Robinson sued the New York State Department of Transportation in an effort to stop it. Transforming the open freeway trench adjacent to their home into green space won’t solve their neighborhood’s problems, the pair say. In fact, it could just make some of them worse.

“They’re not following all of the climate change laws,” says Ladiana. “They’re doing nothing to reduce air pollution. What they’re doing is just pushing all of the pollution out of each side.”

The project has won a $55 million grant from the Biden Administration’s Reconnecting Communities program, but that covers only a tiny fraction of the project’s billion dollar cost.  There are real questions as to whether spending that vast sum on covering a less than a mile of freeway is good investment.

Federal government to stop funding big highway projects . . . in Canada. The Federal Environment Minister Stephen Guilbeault announced that the federal government stop funding large new road projects.  According to the CBC:

Guilbeault said Monday the federal government will be there to support provinces paying for maintenance but Ottawa has decided that existing road infrastructure “is perfectly adequate to respond to the needs we have. There will be no more envelopes from the federal government to enlarge the road network,” Guilbeault said, according to quotes published in the Montreal Gazette. “We can very well achieve our goals of economic, social and human development without more enlargement of the road network.”

The CBC reported that the announcement was greeted with some pushback from pro-highway groups, prompting the Minister to clarify that the ban doesn’t apply to all road projects, just large ones.  Canada’s shift follows a similar declaration last year by the government of Wales.

Surging apartment completions are driving down rents.  We’re getting an object lesson in supply, demand and prices in the housing markets of many metropolitan areas: many new apartments are being completed, and the surge in supply is driving down rents.  While this is a good thing for renters, the picture looks different to landlords, and the business press characterizes the decline in rents as “an onslaught of distress.”  Business Insight reports:

Pricing power across apartment markets in Texas has slipped just as thousands of new units are coming online, sparking concerns that conditions are ripe for an onslaught of distress.

“Pricing power” in this case means the ability of landlords to raise rents.  A study from real estate firm Avison Young looks at 25 large markets across the US and finds that rent growth is weakest in those markets where supply growth has been the strongest.  In Austin, where the number of aparments under construction is highest, rents are down the most.

The strong correlation between higher construction and lower rents is an encouraging sign that we can do a lot to improve housing affordability by building more housing.

In the News

A climate challenge to Portland’s Regional Transportation Plan:  The Portland Oregonian highlighted a legal challenge by No More Freeways against the regional transportation plan adopted by Portland’s Metro regional government. The plan, which allocates billions of dollars for freeway expansion projects, violates state rules requiring Metro to plan for a 35 percent reduction in per capita driving over the next two decades.

Bike Portland quotes City Observatory’s analysis of the flaws in the arcane highway cost allocation formula.  As the state has cut back on maintenance and spent more on highway widening, its created an apparently illegal imbalance in the costs allocated to cars and trucks.


The Week Observed, February 9, 2024

What City Observatory did this week

Three big flaws in ODOT’s Highway Cost Allocation Study.  Some of the most important policy decisions are buried deep in seemingly technocratic documents.  Case-in-point:  Oregon’s Highway Cost Allocation Study.  The state’s truckers are using the latest report to claim that they’re being overcharged, but the real story is very different.  We’ve unearthed three big flaws in the report:

  • The imbalance between cars and trucks seems to stem largely from the Oregon Department of Transportation”s decision to slash maintenance and preservation, and spend more widening highways. ODOT could largely fix this “imbalance” by spending more fixing roads, and less on widening them.
  • ODOT has illegally included federal funds in its cost allocation study; the state’s law and constitution apply only to state funds.
  • ODOT has gone out of its way to scapegoat bike and pedestrian projects, which are mostly paid for with federal funds—that aren’t even properly included in the allocation study.

In addition, the highway cost allocation study leaves out huge social, environmental and fiscal costs that cars and trucks impose on society and on the state. In Oregon, like other states, cars and trucks are increasingly getting subsidized and not paying their own way, something you’ll never find out reading this report.

Must Read

California’s Freeway and Climate Collision:  The LA Times has a terrific article summarizing a spate of freeway and climate news from the Golden State.  The California Transportation Commission (CTC) just voted to approve I-15 Express Lanes that would add capacity to that freeway, mostly to handle truck traffic.  The approval vote reversed a short-handed tie vote in December that temporarily put the project on hold.

The CTC voted to restrict even its commission members to just two minutes of comments, apparently in an effort to block Commissioner Joe Lyou from presenting detailed information showing the project violates state and federal environmental laws.  Lyou’s slides show that state transportation officials argued both that the project would produce no additional truck traffic (exempting it from an air quality review) and that the project would generate 2 million more truck trips annually (to justify economic development funding).  The CTC approved the project in spite of the clear contradiction.  It’s symptomatic of a bigger problem in California–and elsewhere—state policies profess to commit to reduction pollution and greenhouse gases, but state officials routinely vote to widen highways.  And there’s a coda to the I-15 debate, California’s Assembly Speaker replaced Lyou on the CTC with a new member:  a former car dealer.

America Walks spearheaded a national sign-on letter calling for an end to highway expansion projects.  Nearly 200 organizations (including City Observatory) have signed on to a new policy letter calling on the US Department of Transportation to stop funding highway expansion projects. The letter makes the case for a new direction:

We call on our leaders in government to adopt a moratorium on expanding highways and a pause on existing projects until climate, equity, and maintenance goals are met. The highway system we have built in our country is unsustainable, both financially and environmentally, and disproportionately harms low-income and Black and brown communities. We need to remedy these problems with a responsible approach to transportation that centers on community.

The policy stresses four-part priorities to guide transportation investments going forward:  fix it first (prioritizing maintenance over expansion), safety over speed, make transit work and re-connect communities (by removing freeways or replacing them with boulevards).

US DOT rejects grant request to rebuild the Brooklyn Queens Expressway.  A hopeful sign this week from the US Transportation Deaprtment:  they rejected a request for $1 billion in federal funds to hep rebuild the Brooklyn Queens Expressway, a classic Robert Moses project that blights Brooklyn, cutting it off from its waterfront.

In the News

Strong Towns tells a national audience about Portland’s freeway fight over the proposed $1.9 billion I-5 Rose Quarter project, a mile and a half long freeway widening being packaged as a community revitalization effort.

Bike Portland has an in-depth interview with City Observatory’s Joe Cortirght exploring the problems with the arcane cost allocation study the state uses to judge the fairness of highway taxes.

The Week Observed, February 2, 2024

Must Read

How CalTrans cheated on its environmental reporting.  Some months back, former Deputy Director of CalTrans,Jeanie Ward-Waller blew the whistle on the agency’s effort to evade environmental laws and illegally use maintenance funds to widen I-80 between Sacramento and Davis.  Now the National Resources Defense Council has laid out a strong case that the agency’s environmental review is plagued with errors and misrepresentations.

The CalTrans Environmental Impact Report for the I-80 project claims, implausibly, that the widening will result in less travel than leaving the freeway at its current 6-lane width.  As NRDC points out, that’s because the CalTrans model assumes that housing, jobs, and travel patterns will be essentially the same in the “Build” and “No-Build” scenarios.  The NRDC analysis shows that CalTrans assumed a “build” level of traffic between Sacramento and Davis, regardless of whether the freeway was widened or not–and its traffic models dutifully illustrated roads  clogged to capacity, and predicted commuters would take circuitous detours (thus increasing vehicle miles traveld and pollution.

Essentially, CalTrans argued there’d be “induced” demand whether the freeway was built or not.  But that’s the opposite of what we know about induced travel:  the additional trips (and more sprawling development) occur if the freeway is built, but not if it isn’t.  As Carter Rubin of NRDC writes,

Caltrans did not fully disclose and adequately analyze the Project’s impacts. Because the DEIR relied on flawed modeling, Caltrans arrives at erroneous conclusions about traffic impacts, greenhouse gas emissions, air quality, and energy impacts. Next, when it comes to estimating how much additional driving the project will cause, Caltrans still underestimates the impact. The DEIR also fails to adequately measure the additional car-centric sprawl growth that the project will cause.

Exaggerating the volume of traffic in the “No-Build” scenario is a favored DOT tactic, it makes the traffic problem look worse, and falsely creates the impression that traffic and pollution will be less if you build a project. As a growing body of scientific evidence shows, that’s exactly backwards:  more highway capacity generates more travel, more congestion and more pollution.

The “clean cars” shortfall. Across the world, climate strategies are pinning their hopes on a “technical fix” for automobile greenhouse gas emissions. Legislating cleaner cars and cleaner fuels is supposed to reduce greenouse gases from driving.  A new report from the European Union’s Courtof Auditors, reported by the Brussels Times,  shows that the real world reductions in carbon emissions from “cleaner” cars are far less than claimed based on lab results.  The report concludes that EU CO2 emissions reduction targets for new passenger cars are unlikely to be acchieved because CO2 emissions are measured in manufacturer’s laboratory tests do not reflect reality. Real-world emissions from conventional cars have not fallen.

Perhaps the most alarming finding is the dirtier performance of hybrid vehicles.  In theory, plug-in hybrids ought to rely mostly on clean(er) charging, but in practice they get much more energy from the internal combustion portion of the hybrid-powertrain.  The report concludes:

The combustion engine in hybrid cars is used more frequently than expected, in particular for company-owned plug-in hybrids, the auditors explained. . . . “We don’t consider hybrid cars to be low-emission cars and the designation should end from 2025,” the audit team said. “In reality, they don’t pollute less than combustion engine cars and we foresee a phase-out of hybrid cars.”

Several states are counting heavily on hybrid cars to reduce emissions–this report suggests hybrids may do much less that hoped for in reducing greenhouse gas emissions.

New Knowledge

The high cost of crashes.  Road crashes cost Americans more than $340 billion in 2019, according to a new report from the National Highway Traffic Safety Administration.  That works out to a total more more than $1,000 per person per year, and represents about one and a half percent of the nation’s gross domestic product.

The costs get spread to scoiety in many ways–through insurance premiums, taxes, and the costs borne directly by injured people. Traffic crashes cost taxpayers $30 billion in 2019, roughly 9% of all motor vehicle crash costs. This is the equivalent of $230 in added taxes per household in the United States.

The report notes that their were more than 14 million motor vehicle crashes in 2019, which injured more than 4.5 million people, and killed 36,500.

A key risk factor is the amount of driving Americans do each year.  The more we drive, the more crashes, injuries and deaths.  As NHTSA notes,

. . . although the 2019 fatality rate per VMT is unchanged from 2010 the incidence of fatalities and injuries has increased, reflecting added driving exposure . .

Crashes are particularly devastating for pedestrians.  Pedestrians are far more likely to be seriously injured or killed in traffic crashes that automobile occupants.  Overall, pedestrians are about seven times more likely to be killed if involved in an crash.

Reducing driving and reducing car dependence can lower the economic, social and human costs of crashes.

Blincoe, L., Miller, T., Wang, J.-S., Swedler, D., Coughlin, T., Lawrence, B., Guo, F., Klauer, S., & Dingus, T. (2023, February). The economic and societal impact of motor vehicle crashes, 2019 (Revised) (Report No. DOT HS 813 403). National Highway Traffic Safety Administration.



Housing: Missing Middle or Missing Massive?

Gradually, more people and elected leaders are admitting that more housing density is needed if we’re to tackle housing affordability, and provide equitable opportunities to live in great cities and neighborhoods.

But like a swimmer cautiously dipping a toe in a fresh stream, we’re proceeding slowly:  It’s been (relatively) easy to talk about “missing middle” housing–duplexes, triplexes and other small-scale multi-family.  We can get on board with “gentle density”

While missing middle reforms are a long-overdue step in the right direction, they don’t go far enough.  In many places, if we’re going to tackle this problem at scale, we need to be thinking much bigger.  At the 2024 Yimbytown Conference, Alex Armlovich tweeted out a provocative, only slightly tongue in cheek call for us to prioritize “Missing Massive” housing.


We don’t need massive housing everywhere, but in urban locations with great transit, amenities, solid infrastructure and economic opportunity, it makes sense to build more, not less.  One advantage of higher density is, by definition, that it requires less land, and therefore requires less disruption than adding an equivalent number of homes by replacing single family homes with duplexes or triplexes.

As we wrote a while back, like Roy Scheider’s character in Jaws, once we get a close look at the problem, we’ll realize we’re going to need a bigger boat.

In the words of Sheriff Brody (Roy Scheider), “You’re going to need a bigger boat.”

At City Observatory, we’re excited as anyone that there seems to be a growing groundswell of support around the nation for eliminating exclusively single-family zoning.  Minneapolis has garnered national headlines by legalizing duplexes and triplexes in zones once reserved for detached housing. Oregon has adopted a measure that bans exclusive single-family zoning in cities over 10,000 statewide.

These measures are an important step forward to facilitating some of the “missing middle” housing types that provide a range of affordable housing and greater income diversity, in what otherwise might be exclusive and expensive neighborhoods.  This is an important symbolic and rhetorical advance for the YIMBY movement, and a key breakthrough in changing the way we talk about neighborhoods and housing:  single family zoning is no longer sacrosanct and politically untouchable.

But, it must be said, this is only a first step.

Legalizing accessory dwelling units, duplexes, triplexes and fourplexes does hold the promise of adding to affordability while injecting some very “gentle density” into single family neighborhoods. But it is far from up to meeting the scale of our housing affordability problems. For that, we need to build larger multi-family buildings, including apartments.

Row houses vs. apartments

Consider two buildings, both built on similar sized lots, just three blocks apart on Northeast Seventh Avenue in Portland. Both were completed in the last two years.  Both are on relatively large corner lots that were purchased by developers in 2014.  At the corner of Seventh Avenue and Thompson Street, a developer tore down a small existing home on a 12,500 square foot lot and built four adjoining row houses called the “New Albina Rowhouses.”

Just down the street, a second developer demolished a derelict 1920s era gas station on an 18,250 square foot lot, and built a six story, 68 unit apartment building, called “The Russell.”

Both of these projects added more housing in a high-demand area.  It’s worth comparing their cost and their impacts on the supply and affordability of housing in the neighborhood.

The fourplex is a great example of “missing middle” development, and relatively low-impact in-fill, while the six-story apartment building is an exemplar of the kind of development that neighborhood associations love to hate and indeed, neighbors protested strongly against this building when it was proposed. (As a sidelight, because the site was zoned for apartments, under Oregon’s land use laws, the developer was able to proceed with the project essentially by-right, in spite of neighbors objections.)

Apartments are more affordable due to lower land costs per unit

Both lots sold for almost the same price prior to development in 2014, according to property tax records: one sold for $35 per square foot, the other for $36. This has a straightforward implication for affordability.  Households who want to live in the fourplex have to buy about ten times as much land to accomodate their housing unit as households who want to live in the apartments. Each row-house needs about 3,175 square feet of land (at $35 per square foot, about $113,000 of land), while each apartment needs just 268 square feet of land (or about $9,400 of land per unit).

From the standpoint of housing supply, there’s about a ten-fold difference between the two projects.  The fourplex  provides four housing units (a net gain of three from the previous small, single family home of the site).  The six-story apartment building provides 68 housing units on a lot about 50 percent larger. (All of these were a net gain as the site had no housing previously). On a per square foot basis, the apartments provide about ten times as many housing units for the neighborhood.  That means the apartments soak up ten times as much demand, which would otherwise lead to households bidding up the price of housing in the neighborhood and elsewhere in the city. To accomplish the same increment to housing supply, you’d need to build about twenty fourplexes in place of existing single family homes, as each fourplex yields a net gain of 3 housing units.

Apartments mean less widespread disruption and demolition

The space efficiency of apartments is actually a boon if you’re looking to avoid widespread neighborhood disruption and minimize demolitions of existing homes.  In contrast to a four-plex for single family in-fill process, every “Russell” that we build avoids about 20 demolitions of single family homes. The “Russell” has a bigger impact on adjacent properties than the a single row house project, but you’d need 20 more row house projects, somewhere, to provide as much housing as the Russell.

The great thing about apartments is you don’t need a lot of land to build much, much more housing. There are plenty of gas stations, parking lots, under-utilized strip malls and similar properties to accomodate thousands of apartments in every city in the US–if the zoning and development approval processes allow it.

There are significant opportunity costs to underbuilding density in prime urban locations.  Both the Russell and the Albina row houses will likely still be standing in fifty or 100 years. It probably won’t make economic sense to demolish the row houses and build apartments on that site any time.  So committing that site to a fourplex, rather than a Russell-sized building forecloses that possibility for many decades–and means that either apartments (or many more fourplexes) will have to be built on less desirable sites in the meantime.

There’s a good argument to be made that we’re underbuilding density in many locations where it makes sense.  Neighborhoods with great transit, a mix of commercial uses, and high levels of walkability may justify more than just a duplex or triplex on a particular site.  We ought to be think about the long term, what the demand for the neighborhood is likely to be in 2050 or even 2075, rather than in terms of the 20 year time horizon of most housing affordability analyses.

Given that the average lifetime of a building is 50 or 100 years, building a duplex now may foreclose building 12 or 20 or 50 units on the same site for several decades. And cities and neighobrhoods don’t tend to grow my incremental changes to the density of buildings, i.e. with single family buildings in one decade, giving way to duplexes in the next decade, fourplexes in the following decade, garden apartments in the next decade, and mid-rise apartments later.  It’s far more economic to replace one or two single family homes with several dozen apartments, and leave the rest of the neighborhood untouched. Not to mention more politically palatable.

It’s helpful to remember that most of the neighborhoods that exhibit a mix of housing types, including duplexes, triplexes and fourplexes were originally built that way, because early zoning codes (especially prior to World War II) didn’t prescribe only single family buildings. It’s rare to see a neighborhood completely retrofitted with just slightly higher density. Allowing duplexes, triplexes and fourplexes is the sort of thing that is mostly likely to promote affordability and mixed income in peripheral or suburban or greenfield locations than it is in built up urban neighborhoods.

None of this should discourage us from celebrating the important political, rhetorical and practical victory of ending the long established bans on duplexes, triplexes and fourplexes in most residential areas. That’s a huge step forward. But dealing with housing supply and affordability will inevitably require a strategy to make it easier to build apartments in more places. We’re going to need a bigger boat.

Climate: Our Groundhog Day Doom Loop

Every year, the same story:  We profess to care about climate change, but we’re driving more and transortation greenhouse gas emissions are rising rapidly.

Oregon is stuck in an endless loop of lofty rhetoric, distant goals, and zero actual progress

Case in point:  Portland’s Regional Transportation Plan:  It claims to do something about climate, but is ignoring the continuing increase in transportation GHGs and is planning to spend billions subsidizing more driving.

And Portland Metro is keeping two sets of books:  one that pretends to meet climate goals, while another rationalizes increasing driving by 5 million miles a day.

Every February 2, City Observatory takes a moment to consider whether we’ve made any progress in our stated goal to do something about climate change.  And once again, we find, like Bill Murray in the movie Groundhog Day, we’re stuck in an unchanging doom loop.


Groundhog Day. (Source: Bard).

We’re coping with the climate crisis—and our failure to take it seriously—with a kind of second-order denial, not pretending that climate change isn’t real, but instead pretending that we’re actually doing something to solve it, or more precisely, pretending that the things that we are doing are not ineffectual.

Don’t Look Up:  Failing to acknowledge that we’re losing ground on transportation GHGs

Oregon leaders are caught in the trap of yet another allegorical movie: “Don’t Look Up.” On paper, the region pledged a decade ago to implement a “Climate Smart Strategy” that would put the region on track to meet a state-adopted goal of  reducing emissions by 80 percent from 1990 levels by 2050.  As is true nationally, transportation, mostly driving, is the single largest source of greenhouse gases in Metro Portland. In the Portland area, per capita greenhouse gas emissions from transportation have increased more than 14 percent since 2013, by about 1,000 pounds per person. Total greenhouse gas emissions from transportation have increased by about 1.6 million tons per year over that time.


A “Climate Smart” Transportation Plan that Rationalizes More Driving

The Portland region is supposed to meet its climate goal through the implementation of its Regional Transportation Plan, which spells out how we’ll spend billions of dollars and hopefully reducing driving and car dependence.  But there are glaring problems with the RTP:  For starters, the Metro RTP simply fails to look to see whether greenhouse gases from transportation are declining, as the plan calls for.  They aren’t: state, regional and federal inventories all show that despite nearly a decade of “climate smart” policies, Portland produces more transportation greenhouses gases now than before it implemented its strategy.

What’s worse, the adopted Regional Transportation Plan actually calls for policies and investments that will make greenhouse gas emissions worse.  It proposes spending billions of dollars widening area freeways, something that will lead to more driving and greenhouse gases.

A close look at the technical analysis that is the foundation for the RTP shows that Metro has two completely different sets of “books” for assessing transportation.  When it comes to demonstrating compliance with state climate laws and regulations, Metro has produced a set of projections showing we’ll hold total driving in the Portland area to its current level—in spite of increase population—by reducing per capita driving by almost a third.  But when it comes to sizing the transportation system—and in particular—justifying investments in added highway capacity, Metro has a second set of books, that assume per capita driving doesn’t change at all, and that as a result, we end up driving about 5 million miles more per day in the Portland area than assumed the climate analysis.  These two estimates are completely contradictory, and they mean that the Regional Transportation Plan doesn’t comply with state climate laws, and that if we actually followed through on our stated climate strategy of holding driving to its current level of about 20 million miles per day, we wouldn’t need to spend any more on expanding highway capacity.  In reality, the greenhouse gas reductions promised by regional leaders only exist as hypothetical quantities in a separate appendix of the regional transportation plan, one that is divorced from actual spending plans, which contemplate spending billions on road widening.

Deja vu all over again’

If it seems to you like you’ve read this before, you have:  The Oregon Global Warming Commission’s latest report reads like its predecessors.  It chronicles the growing climate crisis, yet again declaring the state’s adopted goal to have lower carbon emissions by 2050, and presenting the data showing that we’re utterly failing to make meaningful progress. Here’s the key takeaway from the report:  The yellow lines show the state’s stated goals, the dotted orange lines show the path we’re on.  And if you look at the black (“actual”) line, you’ll see that emissions have actually increased since 2010.  In short, in no way are we on track to meet our adopted goals.