This is what victory looks like, Freeway Fighters

Bad projects die with a whimper, not a bang

Freeways are promoted with extravagant—and usually false—p.r. campaigns, but their death is just a bureaucratic footnote

Freeway fights are often long, drawn-out affairs, that involve challenging poorly conceived and wasteful projects at a seemingly unending series of public meetings.  In practice, freeway fighters generally lose every single battle—except the last one.  The epitaph for one such freeway project, the half billion dollar widening of I-205 south of Portland, the so-called “Phase 2” project, looked like this:

The notice appears in terse language in an appendix to a report listing changes to Oregon’s federally required “State Transportation Investment Plan” or STIP.  Until this notice came out, the official status of this project was “indefinitely postponed,” but now it’s clearly dead.

“Revenue uncertainty” is a euphemism for “we have no money to pay for this project, and no prospect of finding any.

As we reported two months ago, it finally became obvious that the  the Oregon Department of Transportation  simply lacks the funds to pay for a seven-mile long widening of I-205 just outside of Portland.


Opposition to the project was led by No More Freeways, a grassroots Portland group fighting billions of dollars of freeway widening projects being pushed by ODOT.   No More Freeways celebrated its Sixth Birthday this past month, and marked the passing of the I-205 project, along with its allies “Youth vs. ODOT”–young climate advocates who’ve relentlessly campaigned against these wasteful projects.

No More Freeways filed detailed objections and critiques of the project technical work in comments on its Environmental Assessment. In addition, NMF’s community members submitted over 300 comments in opposition to the I-205 expansion during the public comment period last spring, including technical comments pointing out the explicit violation of federal environmental protection law. 

ODOT’s proposed I-205 expansion was listed as one of the worst transportation projects in the country in USPIRG’s “Highway Boondoggles” report in 2022. 

This is how bad projects die:  Agencies finally, and reluctantly, concede that they don’t have the money to pay for the projects, and that they are so bad that no one can be convinced to appropriate (or borrow) the money needed to move them forward.

We can only hope that this first small victory will signal a turning of the tide in the battle against wasteful and counterproductive highway expansion projects.  Oregon DOT continues to maintain the “extend and pretend” fiction that its now-$1.9 billion Rose Quarter project is still alive, but it too, will have to yield to the fiscal reality that the highway department is essentially broke and doesn’t have the resources to maintain the roads it currently has, much less build enormously expensive new ones.


Gentrification and Housing Supply

New York lost more than 100,000 homes due to the combination of smaller, more affordable apartments into larger, more luxurious homes

When rich people can’t buy new luxury housing, they buy up, and combine small apartments to create larger homes.

This is a negative sum game:  the number of housing units gained by high income households is fewer than the number

If you’re worried about gentrification and displacement, this is a vastly larger problem than new construction–which has been repeatedly shown to lower rents and create more housing opportunities for lower income households.

The obsession with fighting new development reflects a profound cognitive bias in thinking about housing:  we equate new units with unwanted change, while ignoring the effectively invisible destruction of existing units by upscaled combinations.

New York Lost 100,000 Homes to Consolidation

A new study reported in The City finds that over the past several decades, the number of homes in New York has declined by more than 100,000 as smaller apartments have been consolidated into larger homes.  The data come from a thesis prepared by Adam Brodheim of Columbia University.

The effect of unit consolidation has been to partially or totally offset the positive supply effects of new construction.  In some neighborhoods, the number of housing units lost to these combinations dwarfs new construction.  In New York, the largest number of units have been lost in Manhattan and Brooklyn.

Combinations and Gentrification

The demand for consolidation comes from higher income families who want to live in the city but can’t find units that are large enough to accommodate their needs and income.  In a very real sense, the failure to build enough new luxury housing means these higher income households don’t go away, they outbid multiple middle and lower income households for these units.

Do each of these brownstones have four apartments, or only one? (Flickr: Sharona Gott)

Building more high end housing keeps those with high incomes from moving down market and out-bidding those with less income for the existing housing stock, we still hear this argument. For remaining doubters, have a look at Noah Smith’s thought experiment, asking what we think would happen to housing prices  if we suddenly demolished 10,000 units of expensive housing.

This study confirms exactly the Smith’s thought-experiment posed by economist Noah Smith some years ago: The households don’t disappear; they outbid people with less income for the housing units that remain.  Limiting supply doesn’t reduce demand, especially by high income households.  The demand is there whether you supply new larger, luxury units or not, and with no other place to go, it spills over into other parts of the housing market, to the detriment of everyone else lower on the ladder.

And in New York, with these high end-remodeling combinations, the result is actually a negative sum game.  High income households don’t simply displace lower income households one for one:  each new combined unit to house one higher income household displaces multiple households with lower incomes.

If you are concerned about gentrification, you ought to be deeply concerned about these conversions, rather than new construction.  While the knee jerk solution might be to try and block combinations, that misses the fact that the underlying problem is that there are simply too few units and too little space compared to the number of people who want to live in cities.

(We see the same thing happening in Silicon Valley, where an otherwise unremarkable ranch house from the 1950s commands a multi-million dollar price tag–because its so difficult to build new housing there).

An invisible process produces cognitive bias

The process is largely invisible:  Unlike new buildings, which are obvious, public and highly regulated, the combinationof apartments occurs out of public sight, behind closed doors and with minimal regulatory scrutiny:

. . . three previously multi-unit brownstones have been converted into single-family homes over the years — but you’d never know it unless you spotted a construction permit, or noticed multiple buzzers replaced by one doorbell, he said.

“From the perspective of most people on the street, they’re not noticing that seven fewer families are able to live on this block … and this happens all the time,” Brodheim told THE CITY. “Unlike new buildings, which have to go through this huge gauntlet of, often, public opposition to create new units, here you’re able to get rid of apartments without anyone noticing.”

As we’ve noted in our analysis of gentrification, there’s a profound cognitive bias in understanding neighborhood change.  Our research shows that there’s been a dramatic increase in concentrated poverty in US cities, and that poor neighborhoods tend to hemorrhage population.  Fewer than one in twenty high poverty US neighborhoods gentrified over four decades; far more commonly high poverty neighborhoods spread and lost population.  But  these processes occur slowly, over decades, and are imperceptible or simply unperceived by most residents.  In contrast, new construction is obvious, and people understandably associate it with neighborhood change.  Our attention is naturally drawn to those places where an urban transformation is happening the most rapidly; new investment and construction are much more noticeable than the imperceptible processes of neighborhood decline.

Adam Brodheim, 2023. “Bigger Houses, Fewer Homes: Dwelling Unit Consolidation in New York City.” M.S. Historic Preservation Thesis, Columbia University.

Metro’s Climate-Denying Regional Transportation Plan

Portland Metro’s Regional Transportation Plan (RTP) does nothing to prioritize projects and expenditures that reduce greenhouse gases

Metro falsely asserts that because its overall plan will be on a path to reduce GHGs (it wont), it can simply ignore the greenhouse gas emissions of spending billions to widen freeways

The RTP’s climate policies don’t apply to individual project selection;  projects are prioritized on whether they reduce vehicle delay—a failed metric it uses to rationalize capacity expansions that simply induce additional travel and pollution

The RTP environmental analysis falsely assume that ODOT will impose aggressive state charges on car travel, including carbon taxes, a mileage fee and congestion fees than have not been implemented, and may never be, to reduce VMT

The RTP’s traffic modeling fails to incorporate the effect of expected pricing on the need for additional capacity.  Modeling done by ODOT shows that pricing would eliminate the need for capacity expansion, saving billions, and reducing greenhouse gases.

Transportation is the largest and fastest growing source of greenhouse gases in the Portland Area;  every one of the state, regional and local plans to reduce transportation greenhouse gases is clearly failing.  The proposed 2023 Regional Transportation Plan could be a vital tool for prioritizing actions to reduce transportation GHGs.  It isn’t.  It’s a vehicle for justifying a multi-billion dollar wish list of road projects, and pretending that someone else will solve the climate problem.  The plan does nothing to use climate criteria to prioritize spending decisions, and instead, gives a pass to expensive road expansion projects that will encourage more driving and higher levels of greenhouse gases.

Climate denying transportation plans: Golfing at Armageddon

State and regional transportation plans fail to acknowledge the grim reality of increase transportation greenhouse gases (GHGs).  As we’ve documented at City Observatory Metro (and others) have concealed the fact that transportation emissions are increasing by ignoring actual inventory data, and instead, reporting fictional results obtained from their own models, that ignore actual emissions information, and instead make rosy and unsupportable assumptions about future technology, market trends and policy.  In essence, these plans pretend that transportation GHGs are already decreasing, and will decrease even more dramatically in the future.

RTP Priority:  Billions for highway construction and expansion

The Regional Transportation Plan is an official, federally required planning document that spells out how the region will invest in transportation over the next two decades.  This is exactly the time when scientists tell us we must take decisive action to reduce greenhouse gas emissions.  But the largest projects—and the bulk of the expenditures—in the RTP are highway construction and widening that will facilitate more car travel, and increase greenhouse gas emissions.

The RTP document tries to downplay the emphasis on road building with a misleading graphic that shows dots for each project.  The massive Interstate Bridge Replacement is one tiny dot, the huge Rose Quarter widening one tiny dot, the I-205 Abernethy one tiny dot—even though these represent more than $10 billion in capital spending.

The fine print text acknowledges that this is mostly a few big highway projects, but even then substantially understates their true costs.  The Executive Summary fine print says:

. . . the “big three” projects—the I-5 Interstate Bridge Replacement Program, the I-5 Rose Quarter Project, and the I-205 Widening and Toll Project—each cost more than $1B.

In fact, the estimated price tag for the IBR is as much as $7.5 billion, the Rose Quarter project has ballooned to $1.9 billion.  .  The RTP neither reflects the current cost estimates of these projects, nor the likely costs of further cost overruns, which are endemic on major ODOT highway projects.

The RTP spends bulk of its capital on projects that add capacity to freeways—even though a decade old Metro climate plan conceded that these have “low”impact on reducing GHGs.  And in fact, all of the available science on induced demand shows that added capacity increases driving, and increases emissions.

How can Metro square spending billions on highway widening with the climate crisis?  As we pointed out earlier, Metro has ignore the actual inventory data showing increasing transportation greenhouse gas emissions, and substituted its own demonstrably wrong emission modeling to assert we’re on track to reduce greenhouse gas emissions.

Then the policies in the RTP use this umbrella assertion that “this is fine” to simply ignore the greenhouse gas emission effects of individual projects.  The result is a “drive and pollute as usual” approach to  the region’s transportation spending plans and policies.  The bureaucrats assert that because their models show that the overall plan will (based on wildly wrong assumptions) make progress toward the 2050 state goal, that there is essentially no need to rank or prioritize investments based on whether they increase or decrease greenhouse gas emissions.  Meeting the greenhouse gas reduction goal is a criteria applied only (and falsely) to the overall regional plan, and not to any specific projects.

This umbrella claim that the RTP as a whole RTP meets the state climate goals, is spelled out in policy:

Vehicle miles traveled (VMT)/capita will be a controlling measure in both system planning and plan amendments to ensure that the planned transportation system and changes to the system support reduced VMT/capita by providing travel options that are complete and connected and that changes to land use reduce the overall need to drive from a regional perspective and are supportive of travel options.

• For system planning, the final planned system must support OAR 660 Division 44 (Metropolitan Greenhouse Gas (GHG) Emissions Reduction rule) and OAR 660 Division 12 VMT reduction targets.

• For plan amendments, VMT/capita will be used to determine whether the proposed plan amendment has a significant impact on regional VMT/capita that needs to be mitigated or not.

System completeness and travel speed reliability on throughways are secondary measures that will be used to identify needs and inform the development of the planned system.

“Controlling measure” sounds imposing, but this is deceptive.  In effect,  the VMT reduction goals apply only to the overall plan, and to amendments to the plan.  Projects included in the plan are given a pass on whether they increase or decrease VMT (and greenhouse gas emissions).  While VMT is labeled as “a controlling measure” and travel speed is described as a “secondary measure,” the language of the RTP conceals the fact that the secondary measure really determines the priority for spending.  The RTP prioritizes project spending based on travel speed, not reducing VMT or greenhouse gases.

The RTP doesn’t prioritize spending money on projects that reduce VMT.  The RTP contains only  a requirement that plan amendments that increase per capita VMT have to be “mitigated.”  That’s problematic for a couple of reasons.  First:  several huge freeway widening projects are included in the plan itself, and aren’t amendments, so they won’t be mitigated at all.  Second, Metro claims that its models can’t actually detect whether projects—even very large ones, like the IBR or Rose Quarter Freeway widening—increase VMT.  Third, ODOT (falsely) claims that highway expansions  don’t increase VMT.  Metro has not adopted any  objective third party method for assessing per capita VMT effects of projects—like the CalTrans adopted induced travel calculator.  ODOT’s own technical manual simply denies the existence of induced travel and bars its inclusion in ODOT modeling).  Finally, the policy doesn’t limit or ban plan amendments that increase per capita GHG emissions—it only requires that increases be mitigated.  (The RTP fails to say where the mitigation will come from, especially if the region is actively implementing other ways to reduce VMT).

RTP travel speed standards prioritize projects to increase capacity

What the RTP does do, however, is create a rigid standard prioritizing travel speeds on throughways and arterials. Throughways need to provide no less than 35MPH at least 20 hours per day; other “signaled” arterials must provide at least 20MPH no fewer than 20 hours per day. These speed standards do apply to the prioritization of project spending.  While they are labeled as “secondary” these are in fact the “controlling” metrics for project selection and prioritization.



Again, in contrast, the climate standards, calling for a reduction in VMT  effectively only apply to the overall plan, not segments thereof, and only have to “support” possible VMT reductions, not actually result in them.

In sum, individual investments, even ones as large as the multi-billion dollar widenings of I-5 at the Rose Quarter and the Interstate Bridge are effectively exempt from any climate analysis.  Climate simply doesn’t matter for setting regional spending priorities.  The only thing that matters under the terms of the Regional Transportation Plan (RTP) is whether investments speed traffic.  The RTP sets a goal of making sure that area “throughways” travel at no less than 35 MPH 20 hours per day, and that area arterials travel at no less than 20 miles per hour for 20 hours per day.

Projects that speed traffic on highways have been proven to increase travel—a widely documented scientific finding called “induced travel” which means that wider roadways generate more vehicle miles of travel and more pollution.

The Metro RTP criteria give no additional weight or priority to projects that reduce transportation greenhouse gas emissions.  Speed, not greenhouse gases or safety, drives the distribution of resources under the plan.

RTP climate compliance depends on imaginary, unadopted policies

A key climate question is whether the region will reduce VMT.  The RTP contains little, if any information, on which of its investments will reduce VMT.  It makes a sweeping and general claim that providing transit (and other alternatives) “create the conditions” that could reduce VMT; but lower VMT has to come from reflecting back to drivers the true costs associated with their decisions.  When it comes to such actual financial incentives, the bottom line is that Metro assumes that as yet unadopted, and highly speculative state policies, not anything in the RTP, will reduce VMT.

The RTP counts on reduced driving as a result of ODOT and other state policies to make driving more expensive.  There’s an old economist joke, about how to solve the problem of opening canned food when one has no means to do so; the economists waves the problem away, saying “Assume we have a can-opener.”  Metro assumes that ODOT will produce a can opener in the form of a plethora of new fees on driving, including an unspecified carbon tax, a per mile fee of 6 to 10 cents per mile on all driving in the state, as well as a 9 to 17 cent per mile congestion fee for using throughways (limited access roads in Portland), plus tolls to finance the Interstate Bridge and I-205 bridges.  The RTP climate analysis assumes that the state will enact all these fees, and this will reduce driving and carbon emissions.

In effect, the RTP is overwhelmingly dependent on the purely hypothetical actions of others to achieve climate goals:  It depends on state and federal fuel economy, vehicle emissions and fuel policies to reduce emissions per mile driven, and depends on state imposed taxes and fees to reduce vehicle miles traveled.

If the state doesn’t take these actions—and while they would be smart policy, there is no guarantee it will do so—then the hoped for (and modeled) changes in VMT and greenhouses gases simply won’t occur.  But there’s nothing in the plan to pick up the slack, and meanwhile these dubious assumptions will have rationalized spending billions of dollars of irreplaceable public capital on projects that increase driving (just as the climate crisis grows worse).

Failure to include pricing in transportation demand modeling and project evaluation

There’s a profound contradiction in the RTP’s treatment of road pricing.  When it comes to climate strategy, and funding adequacy, the RTP assumes that pricing is a done deal.  When it comes to modeling traffic demand, and especially the need for added capacity, it simply ignores the effects of pricing.

The work that has been done on pricing shows that if the state implements any of the proposed pricing mechanisms (Regional Mobility Pricing or RMPP; tolling on the I-205 Abernethy Bridge or the Interstate Bridge), the region will not need to build any new capacity.  A particularly stark analysis was prepared by ODOT consultants showing that highway pricing (the RMPP) alone—and leaving the Rose Quarter in its current configuration—would be more effective in reducing traffic delays, congestion, VMT and greenhouse gases than spending $1.9 billion widening this 1.5 mile stretch of roadway.  Yet Metro has refused to examine the greenhouse gas implications of these project alternatives, and won’t even apply such tools to project evaluation.

The strategy assumes that the state and region institute a stringent per mile pricing of freeways and arterials for purposes of estimating climate compliance, but the transportation modeling used to justify new project and capacity assumes that the roads are unpriced.

New revenue mechanisms in the STS include a road user charge that levies per-mile fees on drivers, carbon taxes, and additional road pricing beyond what is currently included in the 2023 RTP. These changes are not reflected in the RTP because they are not yet adopted in state policies or regulations, but the climate analysis for the RTP is allowed to include them because these state-led pricing actions are identified in STS and were assumed when the state set the region’s climate targets.
(Emphasis added).

The net effect of including the effects of as-yet-unadopted pricing for climate analysis, but not including it in travel demand analysis for capacity expansion projects, is to create a falsely optimistic picture of climate progress, and a falsely exaggerated picture of the need for additional capacity.

The Cop-Out:  We’re following state rules

Metro’s RTP asserts that “this is fine” for climate because they are following LCDC rules for their land use plan which are designed to address climate change.  LCDC has adopted a “Climate Friendly and Equitable Communities” (CFEC) rule that requires Metro to plan to reduce VMT.  The key problem is that the CFEC rule is based on the same flawed ODOT analysis as the Metro RTP:  making wildly unsupportable assumptions about the rapid adoption of clean vehicles.

Complying with the LCDC rule doesn’t put the region on track to reduce driving or transportation greenhouse gases, and doesn’t demonstrate how we will comply with the legally adopted state goal to reduce greenhouse gases to 25 percent of 1990 levels by 2050:

468A.205 Policy; greenhouse gas emissions reduction goals. (1) The Legislative Assembly declares that it is the policy of this state to reduce greenhouse gas emissions in Oregon pursuant to the following greenhouse gas emissions reduction goals:

     . . . (c) By 2050, achieve greenhouse gas levels that are at least 75 percent below 1990 levels.

Instead, Metro asserts that its RTP conforms to LCDC regulations governing land use plans.  The RTP makes no mention of ORS 468A.205.

Both the LCDC rules and the Metro RTP are based on badly flawed modeling of greenhouse gas levels.  The modeling makes a series of incorrect and unsupported assumptions about vehicle fuel efficiency and emissions reduction technology.  As a result, the modeling wildly understates the actual level of greenhouse gases produced by transportation, and wildly overstates the current and future reductions in greenhouse gases due to greater efficiency.

The 2022 LCDC “Climate Friendly and Equitable Communities” Rule relies on 2016 modeling prepared by former ODOT employee Brian Gregor.  These figures have not been updated, despite a legal requirement that they do so.

Metro claims to have done additional modeling with its “Vision Eval” model.  That modeling assumes that average vehicle ages fall to less than seven years, and that passenger cars make up more than 70 percent of household vehicles.  As we’ve demonstrated both these assumptions are not only wrong, market trends are moving in the opposite direction of Metro’s forecast:  cars are getting older and larger, not smaller and newer (and cleaner) as assumed.

Metro is counting on improved vehicles and fuels for more than 90 percent of greenhouse gas emission reductions.  Appendix J of the RTP projects that the plan (which relies on pricing which is still speculative) will result in an 88 percent reduction in transportation GHG, with 81 percent reduction from fuels and vehicles, and 7 percent reduction from reduced VMT.  That means that 92 percent (81/88) of the reduction in greenhouse gases comes from policies other than those in Metro’s RTP.

These heroic and wildly exaggerated assumptions about improved vehicle fuel efficiency enable Metro to plan for only an extremely modest reduction in VMT.

The RTP is climate denial

Metro leaders talk a good game about climate.  They point to their nearly ten-year old Climate Smart Strategy.  They acknowledge the reality of climate change, and the general need to reduce greenhouse gases.  They’ve listened to national experts who point out the problems with traditional planning approaches.

In spite of all this, the RTP remains what it has always been, a highway-centric spending wish list.  All this version does, is add on an additional layer of rationalization to insist that the region continue building roads on the elaborate and plainly false assumptions that cars will become vastly cleaner, and ODOT will aggressively price roads and carbon.  The plan is still replete with billions of dollars of spending to increase highway capacity, including the $7.5 billion Interstate Bridge Replacement Project and the Rose Quarter.  These highway expansions facilitate continued car dependence and increased greenhouse gas emissions.

Like Metro’s so-called Climate Smart Strategy, the climate provisions in the RTP are a at best an afterthought, and a performative fig-leaf, meant to provide rhetorical cover to a vast investment strategy that is fundamentally at odds with reducing greenhouse gas emissions.

Metro has promised to update its “Climate Smart Strategy” from 2014, but in fact it hasn’t.

Clicking on the “climate smart strategy” link and it takes you to a nine-year old document that hasn’t been updated.  This is what still appears on the Metro website.

Metro’s real climate strategy is “Don’t look up.”

Metro’s RTP needs to examine the travel impacts of tolling and new capacity expansion

Metro claims that its travel modeling can’t really discern the effects of tolling on regional travel patterns, and instead of specific quantitative outputs it simply offers a series of descriptive, generalized statements—”qualitative findings”— about the impact of tolling.

The large-scale, aggregate nature of Metro’s travel model makes it challenging to detail the regional impacts of any single project, even one as potentially significant as tolling. Instead of attempting to isolate the impacts of tolling, Metro staff identified several qualitative findings about tolling’s impacts based on the modeling results for the constrained RTP scenario and on Metro’s experience supporting tolling analyses in the region

System Analysis Public Review Draft 2023 Regional Transportation Plan | July 10, 2023(Chapter 7, p. 7-7-28).

It is, in fact, possible and proven to estimate the effect of new highway capacity on travel patterns and greenhouse gas emission.sIn contrast, California and CalTrans have developed and created tools specifically to analyze the carbon impacts of individual projects:  The Induced Travel Calculator.  This calculator has been adapted to Oregon by the Rocky Mountain Institute.  Metro could use this calculator to estimate the carbon associated with highway expansion projects.  But ODOT, in a bit of science-denial, the Oregon Department of Transportation has specifically banned the used of induced travel analysis in state highway modeling.


The climate fraud in Metro’s Regional Transportation Plan

Metro’s Regional Transportation Plan rationalizes spending billions on freeway expansion by publishing false estimates and projections of greenhouse gas emissions

Transportation is the number one source of greenhouse gases in Portland.  For nearly a decade, our regional government, Metro, has said it is planning to meet a state law calling for  reducing greenhouse gas emissions 75 percent by 2050.

But the latest Metro Regional Transportation Plan (RTP) has simply stopped counting actual greenhouse gas emissions from transportation.

Inventories compiled by the state, the city of Portland and the federal government all show the region’s transportation emissions are going up, not down as called for in our plan.

In place of actual data, Metro and other agencies are substituting fictitious estimates from models; these estimates incorrectly assume that we are driving smaller cars and fewer trucks and SUVs, and rapidly replacing older cars.  None of those assumptions are true.

As a result greenhouse gases are going up; our plans are failing, and Metro’s Regional Transportation Plan, the blueprint for spending billions over the next several decades will only make our climate problems worse

This may be our last, best chance to do something to reduce greenhouse gas emissions from the largest and fastest growing source of such pollution in the state and region. Metro’s federally required Regional Transportation Plan is supposed to reconcile our transportation investments with our social and environmental goals.  Instead the draft RTP simply lies to the public about worsening greenhouse gas emissions, the failure of current efforts, and the inadequate and counterproductive aspects of the proposed RTP.

Portland and Oregon leaders proudly celebrate our acknowledgement of the gravity of the climate crisis and our oft-professed commitment to reduce greenhouse gas emissions.  For the mass and social media, there’s soaring rhetoric.

In the bureaucratic backrooms though, it’s pollution as usual.  No where is this more clear than when it comes to roadbuilding.  Oregon is embarking on the largest and most expensive highway expansion effort in 50 years, proposing to spend more than $10 billion in the Portland area on highways. All of those billion dollar plus highway expansion projects are contained in Metro’s proposed 2023 Regional Transportation Plan.

This, in spite of the fact that transportation is the largest and fastest growing source of greenhouse gases are higher now that they were in 1990, and every one of the state, regional and local plans to reduce transportation greenhouse gases is clearly failing.

State and regional transportation plans fail to acknowledge the grim reality of increase transportation greenhouse gases (GHGs).  Instead, they conceal the fact that our transportation emissions are increasing by ignoring actual inventory data, and instead, reporting fictional results obtained from their own models, and instead make rosy and unsupportable assumptions about future technology, market trends and policy.  In essence, these plans pretend that transportation GHGs are already decreasing, and will decrease even more dramatically in the future.

By steadfastly ignoring increasing emissions, Metro and the State of Oregon have simply ignored pledges made in their original climate planning to regularly measure progress, not in terms of checklists, but in terms of actual, measured reductions in greenhouse gas emissions.

Transportation and Climate:  Plans ignore reality

It’s been a decade since Metro’s first Climate Smart Plan in 2014, which promised to put the region on track to meet state greenhouse gas reduction goal—reducing emissions 75 percent from 1990 levels by 2050.

Since then, the urgency the of the climate crisis has grown manifestly worse, locally epitomized by weeks of suffocating smoke from climate-caused fires; record 116 degree heat that killed dozens (and likely more), and steadily warming oceans and melting glaciers and icecaps.

The clock is ticking; we’ve used up a quarter of the time we have to achieve our 2050 goal.  Now would be a good time to consider whether what we’re doing is working.  This question is especially salient given Metro’s consideration of the 2023 Regional Transportation Plan, which will spell out the course of transportation investment for the next five years (and following decades).  Since transportation is the largest source of greenhouse gases in the city, region and state, this transportation will be crucial to achieving our goals.

All evidence shows that Metro’s “Climate Smart Plan” has failed completely to reduce greenhouse gases.  Every independent inventory of transportation GHGs shows that emissions have increased since the plan was adopted.  The region already emits more transportation GHGs than it did in 1990; and the authoritative DARTE database found that regional transportation emissions are up 20 percent in the past five years.  And bafflingly, Metro’s RTP climate monitoring doesn’t even bother to report on emission trends.

Instead, the plan relies on its own optimistic modeling of future trends.  The problem here is that  the plan itself is founded on wildly unrealistic and already disproven assumptions about the rapid adoption of cleaner vehicles.  State and local transportation officials confidently predicted a decade ago that we’d rapidly replace older, larger, dirtier vehicles with cleaner newer ones.  In fact, the opposite has happened:  The average age of vehicles in Oregon is now up to 14 years, and heavier, dirtier trucks and SUVs make up nearly 80 percent of new vehicles old.  We’re no where near on track to achieve our greenhouse gas reduction goals.

But the plan assumes, falsely, that the average age of cars is about six years, and that two-thirds of vehicles are smaller, cleaner passenger cars.  It uses these assumptions to predict that greenhouse gas emissions will fall rapidly.  And even though reality has shown these assumptions to be wrong, modelers have doubled down on them, and now assume, for example, that cars will be replaced even faster than they thought a decade ago, even as the fleet gets older and older.

We’re failing to achieve our goal:  Transportation GHGs are increasing

Transportation emissions are the largest source of greenhouse gas emissions in Portland and in Oregon.  Transportation emissions account for 41 percent of greenhouse gas emissions in Multnomah County, and 32 percent of emissions statewide.

It’s good to have ambitious plans.  But ultimately, those plans have to work in the real world.  Locally, we have three different real world estimates of transportation greenhouse gases:  The federally sponsored DARTE database, a geographically detailed nationwide estimate of greenhouse gases broken down to 1 kilometer squares cover the entire nation, the Department of Environmental Quality’s annual statewide estimates of Oregon greenhouse gas emissions by source (residential, commercial, industrial, electricity generation and transportation), and Multnomah County’s annual accounting of local greenhouse gas emissions.  Every one of these estimates shows we are failing to reduce transportation greenhouse gases.

When it comes to transportation, we’re not making any progress in reducing our greenhouse gas emissions; in fact, greenhouse gas emissions are higher than in 1990 in Multnomah County (up 3 percent), the Portland Metro area (up 27 percent) and statewide (19 percent).  We’re going in the wrong direction.

 State, regional and local climate plans are failing

And since we adopted city, regional and state plans to reduce transportation emissions (the Portland Climate Action Plan in 2015, the Metro Climate Smart Strategy in 2014, and the State Transportation Strategy in 2013), transportation emissions have increased, not decreased.  From 2013 (the year before these climate plans took effect through 2019 (the last full year prior to the pandemic), greenhouse gas emissions form transportation have risen.

Oregon transportation GHG emissions are up 2.7 percent per year since 2013, Portland regional emissions are up 4.9 percent per year  and Multnomah County emissions are up 1.4 percent year.  Transportation emissions are going up when our plans call for them to be going down.  The result is a yawning and unacknowledged gap between our plans and reality.  The DARTE data show the region going rapidly in the wrong direction.

All of the available independent inventory data for the state, city and region make it clear that our transportation emission reduction plans are failing in monumental fashion to achieve their goals.

Climate plans haven’t been adjusted to reflect reality

Increased transportation greenhouse gases should be triggering stronger efforts to fight climate change. Metro committed to monitor the progress and implementation of its Climate Smart Strategy, and to take additional measures as needed.  This commitment appears in the Climate Smart Plan and is reiterated in the latest draft of the 2023 Regional Transportation Plan.  (RTP 2023 Draft, Appendix J, page 21)

Metro’s RTP fails to report increasing transportation greenhouse gas emissions

Despite these commitments, Metro’s RTP does not accurately report on regional greenhouse gas emission trends. It does not acknowledge that, contrary to the 2014 CSS and the 2018 RTP, transportation greenhouse gas emissions are increasing, not decreasing. The 2023 RTP contains no graph or time series information on transportation greenhouse gases in Portland; in contains only a single reference to the per capita level of greenhouse gas emissions in 2023 and 2045; both of these figures are obtained from Metro’s model, not from actual inventories of greenhouse gas emissions prepared by independent agencies.

We are “deviating significantly” from our earlier projections and plans, but we haven’t acknowledged it, and therefore, aren’t proposing to change our plan.

The RTP substitutes inaccurate models for actual data

ODOT, Metro, and LCDC are substituting flawed and biased models for actual data about carbon emissions.  Transportation greenhouse gas emissions are increasing, yet all these agencies pretend, based on inaccurate models, that they’re making progress toward reducing greenhouse gases.  The actual data show that vehicles on the road today (and tomorrow) are vastly older and dirtier than assumed in the models these agencies use to falsely portray their climate progress.

Both the LCDC rules and the Metro RTP are based on flawed modeling of greenhouse gas levels.  The modeling makes a series of incorrect and unsupported assumptions about vehicle fuel efficiency and emissions reduction technology.  As a result, the modeling significantly understates the actual level of greenhouse gases produced by transportation, and overstates the current and future reductions in greenhouse gases due to greater efficiency.

The 2022 LCDC “Climate Friendly and Equitable Communities” Rule relies on 2016 modeling prepared by former ODOT employee Brian Gregor.  These figures have not been updated, despite a legal requirement that they do so.

For the current RTP, Metro claims to have done new modeling with its “Vision Eval” model.  That modeling assumes that average vehicle ages fall to less than seven years, and that passenger cars make up more than 70 percent of household vehicles.

Both Gregor’s and Metro’s climate modeling assumes we will quickly replace the existing fleet of large, dirty fossil fueled vehicles, with newer, smaller, more efficient vehicles powered by electricity and/or clean fuels.  The modeling asserted that the amount of carbon pollution generated by each mile of vehicle traveled would be 80 percent less than it is today.  Unfortunately, we’re nowhere close to being on this trend.

The key assumptions are average vehicle age and mix of trucks/SUVs Metro and LCDC rely on projections of these emissions that have already been proven wrong.  Metro and LCDC assumed, critically and incorrectly, that the vehicle fleet would turnover more rapidly (dirty, older cars would be replaced more frequently by newer, cleaner ones) and that consumer preferences would shift from larger, dirtier trucks and SUVs to smaller and cleaner passenger vehicles.  Not only are both of these assumptions wrong, exactly the opposite has happened over the past decade:  the average age of automobiles has increased significantly, and the share of light trucks and SUVs has grown to almost 80 percent of new car sales.  The following RTP table summarizes Metro’s assumptions:

Metro’s assumptions are simply wrong:   the average car on the road today is vastly dirtier than assumed in Metro and LCDC modeling.  In essence, the climate modeling assumes that the typical car in today’s fleet is a relatively clean six-year-old Honda Civic, that emits about 257 grams per mile.  In reality, the typical vehicle in today’s fleet is a twelve-year-old quarter-ton pickup truck, that emits about twice as much greenhouse gases—555 grams per mile.

2023 Model assumption:  Typical car is a 2017 Honda Civic; 2023 Reality:  Typical vehicle is a 2010 Ford F-150.

These two mistakes in the Metro/LCDC modeling lead them to understate greenhouse gas emissions from the current fleet by 50 percent.

And these errors also affect future years.  The growing longevity of the vehicle fleet means that the future fleet will be less efficient (and much dirtier) than assumed in Metro’s modeling.  If the average age of vehicles stabilizes at the current 12 years, the median vehicle in 2035 will be a 2023 model year vehicle (eighty percent of which were larger, more polluting SUVs).  Fleet turnover will happen much more slowly, and emission rates will decline more slowly still.

Metro and LCDC projections assume that average emissions of GHGs will fall from about 450 grams per mile to about 100 grams per mile in 2045.  In reality, GHG emissions per mile are falling far more slowly.  In 2021, the average vehicle emitted about 390 grams per mile rather than the roughly 300 grams per mile assumed in Metro and state climate modeling.

The RTP should be based on actual, honest data about greenhouse as emissions

The first step is to accurately report our progress—actually backsliding—in terms of reducing transportation GHGs.  Instead of reporting claims based on models with false and now discredited assumptions, it needs to show that actual GHG emissions are rising, and present a clear case showing why this has happened.  It’s been because we’re keeping cars longer, buying bigger, dirtier vehicles, driving more, and not improving fuel efficiency as fast as excessively optimistic assumptions made a decade ago.  We have to “mark to market” our forecasts:  replace decade old guesses about what our transportation emissions would be with actual data on what we’ve really accomplished.

Once we’ve done that, we’ll see that we need to do much more, and do it far more quickly than we thought.  It’s been nine years since Metro adopted its Climate Smart Strategy in 2014.  Those nine years represent fully one-fourth of the time available to get the region on track to meet its goal of reducing greenhouse gases by 75 percent by 2050.  During those nine years, regional transportation greenhouse gas emissions have actually risen (by more than 20 percent, according to the DARTE inventory).  That means we have a bigger task, and a shorter period of time to accomplish it.  This simply isn’t reflected in the Regional Transportation Plan, in  state land use regulations, or the Oregon Department of Transportation’s “State Transportation Strategy (STS).

Appendix:  Vehicles are older, larger and dirtier than assumed in Metro climate models

The strategy assumes trends in vehicle type, fuel efficiency and fleet replacement that are the opposite of what we’ve experienced.  All of these errors lead to understating GHG emissions.

REALITY:  Average Vehicle Age is Increasing

Slower fleet turnover means that the vehicles on the road are on average, older and dirtier.  State modeling assumes that older vehicles are being replaced quickly; with the average age of a vehicle being 6 or 7 years.  In reality, the average vehicle is more than 12 years old.  The Oregon Department of Transportation reports that the average age of vehicles in Oregon is higher than the national average (14 years) and is increasing.  The climate modeling is wildly off:  the fleet is getting older, and the models assumed it would be getting younger.

The slow rate of fleet replacement is a particularly large problem for the modeling.  With an average age of 12 years, the median vehicle in 2035 will be a 2023 model.  Those vehicles average about 330 grams per mile.  That’s about 80 percent higher than the 180 grams per mile that state modeling assumes for the fleet in 2035.  The increasingly long life of vehicles locks in a high carbon emission rate.

The average age of vehicles on the road has increased to more than 12 years according to IHS Automotive.

REALITY:  Trucks and SUVs make up nearly 80 percent of new car sales. 

Fewer passenger cars, more light trucks and sport utility vehicles.  State modeling assumed that the share of trucks and SUVs would decline steadily, and that 60 percent or more of all private vehicles would be passenger cars, which use less fuel and emit less greenhouse gases.  In reality, nearly 80 percent of new vehicles sold today are light trucks and sport utility vehicles. The climate modeling is off by a factor of three, with passenger cars accounting for 20% of the fleet, not 60 percent.

Rose Quarter: So expensive because it’s too damn wide

The cost of the $1.9 billion Rose Quarter freeway is driven by its excessive width

ODOT is proposing to more than double the width of the I-5 Rose Quarter Freeway through the Albina neighborhood

ODOT could easily stripe the roadway it is building for ten traffic lanes

The high cost of building freeway covers stems from the project’s excessive width

WSDOT plans to cover I-5 in Vancouver for less than $40 million

The fundamental problem with the Rose Quarter project, and the reason why it has blown through its budget is that really a massive freeway widening project.  The agency claims its just adding a couple of “auxiliary” lanes, but in reality, its doubling the width of Interstate 5 in a complex urban environment, and its plans for a much wider roadway are the principal reason the project, and its covers, are so expensive.

A too wide freeway.

What no one seems willing to do is ask basic questions about the Rose Quarter.  Is the project worth $1.9 billion?  Does it even need to be that big and expensive?  Isn’t the skyrocketing cost and ODOT’s growing fiscal crisis a signal that we should consider some other options?

The high cost and prodigious cost overruns of the Rose Quarter are directly related to the excessive width of the project, something that ODOT has gone to great lengths to conceal, characterizing the project as merely adding a single auxiliary lane in each direction. In reality, the project would essentially double the width of I-5 through the Rose Quarter, from its current 82-foot width, to 160 feet (and in some places as much as 200 feet).

A brief chronology shows how ODOT staff have repeatedly concealed or obscured the width of the I-5 Rose Quarter project.  Their initial 2019 Environmental Assessment presented a misleading and cartoonish freeway-cross section that appeared to show that the freeway would be widened to about 126 feet.

City Observatory challenged these claims about the width of the freeway to the Oregon Transportation Commission in December 2020, and the commission directed the staff to meet with us to discuss the issue.  The staff refused to answer any questions during this meeting, and instead later issued a written report obfuscating the actual width of the freeway.

In March 2021, No More Freeways obtained three different internal project documents indicating that the actual width of the roadway would be 160 feet.  These included 2015 engineering drawings, as well as architect’s illustrations and computerized CAD files.

As we’ve pointed out at City Observatory, this cross-section could easily accommodate  10 travel lanes, and regardless of ODOT’s labeling, once built, the road could be re-striped in an afternoon.

Even the project’s Supplemental Environmental Assessment, released in November 2022 conceals the actual width of the project.  Here is the project’s own plan showing the freeway cross-section.  The plan omits measurements, so we’ve added scale markings showing 200 foot widths.

ODOT plans for I-5 Rose Quarter Freeway (200′ scale marking added by City Observatory)

ODOT’s own consultants, the internationally recognized engineering firm ARUP, concluded that the Rose Quarter project was vastly wider than it needed to be.  They pointed out that no comparable urban freeway in any city has the over-wide 12 foot shoulders designed into the Rose Quarter project.  ARUP concluded that the extreme width of the ODOT design was the principal reason freeway covers cost so much, and said the freeway could be 40 feet narrower than ODOT’s design.  ODOT’s own “Cost to Complete” report concedes that a key cost driver is the need to lower the surface of the existing roadway in order to provide the necessary vertical clearance over the much thicker overpass beams that will be needed to span the wider roadway.

Covers alone could be vastly cheaper

If this project consisted simply of building a cover over the existing I-5 freeway, it would be vastly cheaper.  Washington’s Department of Transportation is proposing to build a similar cover over a portion of I-5 in Vancouver as part of the Interstate Bridge Replacement Project; The cover, called the “Community Connector” is designed to re-connect historic Fort Vancouver with the city’s downtown.  It will be about 300 feet wide, and about an acre in size and is estimated to cost $37 million.

Vancouver’s proposed Community Connector cover I-5 for just $37 million

ODOT has never explored simply building a lid over the existing freeway to “re-connect” the community.  If this were simply about building a cover to re-connect the community, it could have been done by now for a fraction of the $115 million ODOT has spent so far, just on planning the Rose Quarter.

What to do instead:

ODOT could cap the I-5 freeway at the Rose Quarter without widening it.  And if ODOT is really committed to “restorative justice” reallocate available money for this project as reparations to the Albina community, and allow them to spend it however they see fit to rectify the damage done by the construction of of I-5, Interstate Avenue and the Fremont Bridge ramps.  Oregon routinely spends highway funds mitigating the environmental damage of its freeways, on everything from sound walls to wetlands.  It also has used highway funds to replace displaced structures (the old Rocky Butte Jail), and other states have used federal highway funds to replace housing destroyed by freeway construction.  If we were serious about redressing the harm done to the Albina neighborhood, we’d be looking to reduce the size of I-5, and spend more money improving the neighborhood, and building the housing ODOT destroyed.


Rose Quarter: Death throes of a bloated boondoggle

For years, we’ve been following the tortured Oregon Department of Transportation Plans to widen a 1.5 mile stretch of I-5 near downtown Portland.  The past few months show this project is in serious trouble.  Here’s a summary of our reporting of key issues

Another exploding whale:  The cost of the Rose Quarter has quadrupled to $1.9 billion.  In 2017, the project was sold to the Oregon Legislature based on an estimated price of $450 million.  Since then, ODOT has diverted nearly all of the money earmarked for this project to other freeway expansions.

ODOT’s Plan:  Extend and Pretend.  Governor Kotek forced ODOT to prepare a financial plan for its massive freeway expansion program.  ODOT now admits the Rose Quarter faces a $1.35 to 1.75 billion financial hole, with no identified solution.

Pens Down:  ODOT staff claim it’s too late to question the design of the bloated $1.9 billion Rose Quarter Freeway widening, even though they also say it’s only 30 percent designed, and they have a new design the public hasn’t seen yet.


The Rose Quarter project is so expensive because it’s too damn wide; Just up the road in Vancouver, the Washington Department of Transportation is planning an acre-sized freeway cover over I-5 to connect downtown Vancouver to historic Fort Vancouver for a mere $40 million.

Who sold out the Historic Albina Advisory Board?  ODOT has advertised its freeway widening project as a way to promote restorative justice for the historically Black Albina neighborhood it destroyed with decades of highway construction.  But now ODOT can’t fund the Rose Quarter project, because  for the How ODOT took money from the Rose Quarter project and used it to widen a suburban freeway bridge.

Lying about freeway width:  For years, ODOT has been concealing the actual width the Rose Quarter project, and deceiving the public about its plans for a 10-lane highway.

One-tenth of one-percent:  What Black contractors got from ODOT’s biggest construction project.  While ODOT claims to want to help Black contractors, its current largest construction project, the I-205 Abernethy Bridge, has spent just one-tenth of one percent of its budget with Black contractors.


Extend and Pretend: ODOT’s Zombie Rose Quarter project

The Oregon Department of Transportation is playing “Extend and Pretend” with the $1.9 billion I-5 Rose Quarter Freeway widening project

The cost of the 1.5 mile freeway widening has quadrupled from $450 million in 2017 to $1.9 billion today.

Meanwhile, the agency has diverted money earmarked for the Rose Quarter to other projects, and now faces a $1.35 to $1.75 billion financial hole.

Its finance plan has no concrete steps for paying for the project, aside from hoping for new sources of federal and state revenue. 

“Extend and pretend” keeps $40 to $60 million flowing to consultants but doesn’t answer any of the hard questions about this fatally flawed project. 

Rose Quarter freeway widening cost quadrupled to $1.9 billion

In May, Governor Tina Kotek called a time-out out highway tolling until 2026, and directed the Oregon Department of Transportation to come up with a comprehensive financial plan for its multi-billion dollar package of Portland area highway expansions. The ODOT plan revealed that the I-5 Rose Quarter project, originally approved by the Legislature in 2017 at an estimated cost of $450 million now has a price tag of $1.9 billion.  Every year or so, ODOT has ratcheted up the cost of the Rose Quarter freeway widening.  It was $450 million in 2017, $795 million in March 2020, $1.45 billion in September 2021, and now, $1.9 billion.

Further cost increases are likely

And it looks like they’re not done yet.  The design for the Rose Quarter project is still very much in a state of flux.  The original design was replaced by a “Hybrid 3” alternative, and last year, as part of a “Supplemental Environmental Assessment” ODOT revealed a new freeway exit design with a dangerous (and substandard) hairpin off-ramp.  That design has produced widespread criticism from the City of Portland, and the Portland Trailblazers, who operate the Moda Center adjacent to the freeway exit.  On June 27, ODOT for the first time revealed yet another re-design of the project, now with the second hairpin, this time on a flyover structure over the widened freeway.

ODOT’s latest financial plan is studiously ambiguous about whether the new cost estimates reflect the new flyover exit ramp.  They divided their explanation of the Rose Quarter cost estimates between two different tables, as follows:

Table 2

The notes to the first table say that the estimate reflects the “current Hybrid 3” design, and directs the reader to the second table to understand the “cost progression detail.”   This term ought to make one nervous, given the half-life of ODOT cost estimates.  The second table plainly signals that we will see yet another set of project cost estimates two years from now, when ODOT will be “updating the total project cost estimate to reflect the advanced design and outcomes of the environmental process.”  Translated into English, this means, ODOT is planning yet another round of cost estimates in 2-3 years, and they will undoubtedly be higher than the current figures.

Available revenue:  Almost nothing.

In reality, there is no finance plan.  ODOT staff presented a 23-page document describing its current financial problems.  Overall, the agency concedes that it is Portland area highway projects would cost $3.7 to $4.3 billion, and that the agency has only about $717 million for these projects—unless in is allowed to start levying tolls.   The shortfall has already bled ODOT to effectively cancel plans for the I-205 Phase 2 freeway widening and the I-5 Boone Bridge at Wilsonville. This estimate also doesn’t include likely additional state funding that will be needed to complete the Interstate Bridge Replacement Project; Oregon’s $1 billion commitment is only a down payment toward the total $7.5 billion cost of that project.

This plan is designed to respond to Governor Kotek’s direction and answer key questions about how to pay for the UMS projects in both the short and long term.

It isn’t so much a plan as it is a description of the size of the hole that ODOT faces for the Rose Quarter.  And the hole is huge:  ODOT needs up to $140million  in additional funds just to keep the project design going, and beyond that, a further $1.25 to $1.6 billion to actually construct something:

An additional $100 million to $140 million is needed to ready the project for construction, while an additional $1.25 to $1.6 billion is needed to complete construction of all work packages.

Where will that money come from?  The document says it “could” come from any of a variety of sources:

  • federal competitive grants (though it would be competing with other Oregon projects, notably the Interstate Bridge Replacement)
  • new (as yet un-enacted) state funding.
  • tolling as part of the regional mobility pricing program (which is still in development and years away).
  • re-allocation of the STIP (i.e., taking money from other projects that ODOT has already committed to fund).

Even a casual glance shows this isn’t a plan at all.  There’s no indication that even added together, all these sources could produce the needed $1.35 to $1.75 billion.  Nor is there any indication of what will happen if they can’t find that total amount.

What the Oregon Transportation Commission approved at its June 28 meeting was spending an additional $40 to $60 million on the Rose Quarter project for consultants and planning, in order to bring the project to “30 percent design.”  Beyond its hypothetical and speculative list of funding sources, ODOT has no actual plan to pay for construction.  Consultants will keep getting paid; ODOT will keep beating the drum for the project, costs will continue to rise, and the decision on what the Rose Quarter will look like, and how it will be paid for, which has already dragged on for six years, will continue to drag on even longer.

ODOT’s strategy:  Extend and pretend

In the banking world, this practice known as “extend and pretend.”  When a bank makes a loan to a project that has gone bad, and for which the borrower can’t make repayment, rather than forcing the loan into default (and having to record a loss on the bank’s books), the bank gives the borrower more time to repay (amortizing the loan over say ten years, rather than five)—the extend part—and then revises its cash flow projections to show getting repaid—the pretend part).  The bank’s current profits (and bonuses) are protected, and the can is kicked down the road, to be dealt with at another time.

That’s exactly what ODOT is doing with the I-5 Rose Quarter project:  It’s extending the project’s timeline by at least two or three years, and its pretending that, during that time, someone will find at least $1.35 or $1.75 billion (and likely a good deal more) to pay for the project.  “Its a very important project” all of the members of the OTC solemnly agree.  Maybe so, but what this really signals is that the OTC is going to put off for several more years the question of whether this project is worth its growing cost.  The Rose Quarter will be a zombie project, utterly un-funded, but technically not dead, because ODOT (and its enablers) pump millions into keeping it on life support.


ODOT’s I-205 Bridge: 1/10th of 1 Percent for Black Contractors

The Oregon Department of Transportation (ODOT) is falling short of its own goals of contracting with disadvantaged business enterprises

One-tenth of one percent of I-205 contracts went to Black construction firms

ODOT professed a strong interest in helping Black contractors as a selling point for the
I-5 Rose Quarter project, but instead advanced the I-205 Abernethy Bridge project, which has provided very little opportunities for Black-owned firms.

ODOT has been dangling promises of lucrative construction contracts for Black construction firms if its proposed $1.9 billion I-5 Rose Quarter freeway widening project goes forward.  Not surprisingly, as we reported earlier, these firms and many in the local community were angered to hear that the Rose Quarter project was being delayed, probably indefinitely, because ODOT lacks funds—and shifted the funding it did have to a different project.

ODOT has prominently advertised that it intended to hire Black contractors to undertake a significant portion of the I-5 Rose Quarter project.  Even though the project was, according to the agency, only about 15 percent designed in 2010, the agency signed a contract with a joint venture (Sundt/Raimore).  One of the partner firms, Raimore Construction, is Black-owned.  An article published in The Oregonian quoted ODOT officials as saying that Raimore would be expected to bill more than $100 million in project costs (this when the project’s price tag was estimated at a mere $795 million).

Now it appears that the Rose Quarter project is going nowhere fast.  ODOT’s latest financial plan reports that the agency has almost no money to meet the project’s $1.9 billion construction cost.Par

A lot of this has to do with the project’s exploding cost, but as we noted earlier, ODOT diverted the funding that was originally earmarked for the Rose Quarter (a project in Oregon’s historically Black Albina neighborhood) and instead used it to pay for the I-205 Abernethy Bridge project in the wealthier and much whiter suburb of West Linn.  The members of the Historic Albina Advisory Board, which include Black contractors, have expressed anger that ODOT isn’t moving forward with the Rose Quarter Project—which now as a $1.35 to $1.75 billion funding deficit.

A disparity in Black contracting

The $622 million I-205 Abernethy Bridge project is the biggest source of highway construction contracts in Oregon in nearly half a century, according to ODOT. but so far, African-American construction firms have gotten just one-tenth of one percent of contract payments, according to ODOT reports.  While the I-5 Rose Quarter project was supposed to provide $100 million in contract payments for its lead Black contractor (and likely more for subcontractors), Black contractors have so far gotten just 142,000 of the $126 million disbursed for the Abernethy Bridge.

Apparently, ODOT is only committed to hiring Black contractors when they can provide politically valuable leverage for a project in Northeast Portland.

The one big ODOT highway project that is moving forward has provided only a tiny amount of work for African-American contractors.  ODOT’s I-205 project dashboard shows that the agency is well behind in meeting its diversity goals and that only about one-tenth of one percent of contracted payments have gone to African-American firms.

ODOT set a goal of providing 14 percent of contract revenues with certified disadvantaged business enterprises (which include women-owned and minority-owned businesses).  To date, ODOT has disbursed $126 million to all contractorsand Its current dashboard shows $12 million has gone to certified disadvantaged business subcontractors, only about 9 percent of the total–well below its goal. The bulk of these funds have gone to businesses owned by women, Asian-Americans, and Native-Americans.

Only about $142,000 out of $126 million, a little more than one-tenth of one percent, have gone to African-American businesses.

The $622 million that ODOT plans to spend on the I-205 Abernethy Bridge, makes it the biggest source of contracting opportunities in recent memory.  On its website, ODOT brags:

“The I-205 project is the largest ODOT highway project in 45 years.”

If ODOT were seriously interested in bolstering opportunities for African-American businesses there’s no reason that they should not be able to qualify for contracts.

Who sold out the HAAB?

The members of ODOT’s “Historic Albina Advisory Board” (HAAB) are hopping mad.  As related by Jonathan Maus at Bike Portland, they feel board betrayed by a decision to postpone construction of the $1.6 billion I-5 Rose Quarter freeway widening project.

For years, the staff of the Oregon Department of Transportation have been promising the HAAB a bonanza of community improvements and lucrative construction contracts as part of its I-5 Rose Quarter freeway widening project.  A key part of ODOT’s marketing of the freeway widening is a claim that highway covers (really oversized overpasses) will be instrumental in providing restorative justice to the Albina neighborhood that was ripped apart by three different ODOT highway projects over several decades.

At its June 27, 2023 meeting, ODOT staff dropped the bombshell that after more than five years of planning, ODOT simply doesn’t have the money to pay to actually build the Rose Quarter project.  Members of the HAAB feel they’ve been betrayed.


‘This is not okay’: Black committee members respond to Rose Quarter funding shortfall at emotional meeting


ODOT staff tried to claim that the project’s apparent demise was because of a May  decision to suspend tolling for at least two years, to 2026.  At the HAAB meeting on June 27, Brendan Finn squarely put the blame on Governor Tina Kotek’s decision to postpone tolling in Oregon:

Something’s happening down in Salem that I want to share with all of y’all . . . we have been moving forward on two separate tolling programs.  The Rose Quarter project is intertwined with those tolling programs in that they are supposed to help pay for portions of construction  . .  . we’ve known going through the design process together over the years that this project is under-funded— it was way underfunded.  . . . Governor Kotek came into office   . . . and said to us you got to take a little bit more time with tolling . . . so she delayed the implementation of tolling . . . that has reverberations on all of our projects and the timing of implementation . . . we have put together a a financial plan for for these pieces that takes into account the fact that we are not going to be getting the revenue from tolling.

As a result, Finn conceded, the Rose Quarter project would be put on life support, with barely enough money to keep planning moving forward, and construction delayed for at least two years (and likely much longer).  The members of the HAAB could tell they were in deep trouble, but Finn’s explanation—effectively blaming Governor Kotek’s suspension of tolling—isn’t right.  The actual cause of the project’s demise is much different.  Every step of the way, over the past five years. ODOT has taken actions that undercut the progress of the Rose Quarter project and instead elevated and accelerated another project, a $622 million rebuilding of the I-205 Abernethy Bridge in the wealthy and predominantly white suburb of West Linn, rather than the Rose Quarter (in Portland’s historically Black Albina neighborhood).

Along the way, ODOT:

  • “found” money to move the I-205 project forward when the Legislature appropriated nothing for its construction.
  • diverted state gas tax funds originally earmarked by the 2017 Oregon Legislature for the Rose Quarter to pay for the I-205 bridge
  • Used Rose Quarter funding to enable the I-205 bridge to circumvent federal environmental review (which has delayed the Rose Quarter project)
  • Accelerated signing construction contracts for the I-205 bridge, putting it ahead of Rose Quarter in line for state funding
  • Proceeded with the I-205 bridge even though its cost as increased by 150 percent since 2018, from $250 million to $622 million
  • Officially told the federal government that it wasn’t “reasonably foreseeable” that the Rose Quarter project would be financed by tolling revenues.

As a result of all these decisions, the I-205 Bridge is moving forward, and ODOT, by its own admission is committing to paying for the bridge even if that state raises no toll revenue.  Meanwhile, the Rose Quarter project is languishing, and is no closer to construction than it was six years ago.

It’s baffling that Finn would blame ODOT’s financial woes on Governor Kotek’s recent actions.  It’s been apparent for years that ODOT has lacked the money to actually build the Rose Quarter project, and Kotek has been Governor for just six months.  In 2021, as House Speaker, Kotek voted against the bill that allowed the diversion of funds from the Rose Quarter (HB 3055) and urged ODOT to “right-size” its mega-highway projects.  And in May, as Governor, Kotek finally insisted on injecting a note of fiscal realism into ODOT’s work by requiring this new financial plan for its megaprojects.  As we’ll see, all of the financial problems plaguing the Rose Quarter project pre-date the Kotek Administration and are the direct product of decisions made by ODOT staff, including Finn.

About the HAAB and the I-5 Rose Quarter Freeway Widening Project

The I-5 Rose Quarter project would widen about 1.5 miles of freeway in North and Northeast Portland.  Part of the project involves constructing a partial cover over a portion of the freeway, ostensibly to make up for the damage the freeway did in dividing the historically Black Albina neighborhood.  (Construction of I-5 in the 1960s was actually one of three ODOT projects that divided and helped trigger the decline of Albina.  Facing community resistance to the project in September 2020, ODOT unilaterally disbanded an earlier community advisory group—which was raising uncomfortable questions—and instead created the Historic Albina Advisory Board.  ODOT rebranded the project as contributing to “restorative justice” in part by building the covers, and in part by implying it would hire Black contractors to do much of the work.  In City Observatory’s view, there are multiple fatal flaws with the Rose Quarter project:  it’s vastly too expensive, doesn’t fix any safety problem, won’t reduce congestion, will actually increase pollution, and doesn’t revitalize the neighborhood.  

A 2017 Earmark for the Rose Quarter:  Diverted by ODOT

The Legislature’s landmark 2017 transportation package specifically included the $450 million in funds for the Rose Quarter in the form of a 2 cent per gallon statewide gas tax.  The bill contained no funding the I-205 project.  Even so, in 2018, ODOT used its discretion to divert more than $50 million from a variety of sources to move the I-205 project forward.  Here’s a list of the funds ODOT scraped together to pay for I-205:

Then, in 2021, ODOT convinced the Legislature pass HB 3055, to open up the $450 million set aside for the Rose Quarter project for other projects, including the I-205 Abernethy Project.  ODOT quickly used that discretion to effectively commit all of that money to paying for I-205, rather than the Rose Quarter.

Evading federal environmental review for I-205 by using Rose Quarter funds

ODOT used the Rose Quarter funding diversion to evade federal environmental review of the I-205 project. ODOT assured the Federal Highway Administration that the Abernethy Bridge could be built without any toll revenues, by diverting the funds originally earmarked for the Rose Quarter.  This enabled ODOT to get an exemption from federal environmental review—a CE or “categorical exclusion.” If ODOT hadn’t offered those assurances, FHWA would have had to perform a lengthy Environmental Assessment on the I-205 bridge project (called “Phase 1a”), something that has slowed the I-5 Rose Quarter project.  Here’s the FHWA’s official finding:

Recently signed into law, Oregon House Bill 3055 provides financing options that allow Phase 1a of the I-205: Stafford Road to OR 213 Improvements Project to be constructed beginning in the spring/summer 2022 without the use of toll revenue. . .

As Phase 1a is now advancing as a separate project with independent funding, the 2018 CE decision is being reduced in scope to include only Phase 1a (the “I-205: Phase 1a Project” or “Phase 1a Project”).

[Emily Kline, “Re-Evaluation of the Categorical Exclusion for the I-205: Stafford Road to OR 213 Improvements Project, Federal Highway Administration, May 4, 2022, page 3.]

A key reason for the Rose Quarter’s delay, despite its head-start over the I-205 bridge, is ODOT’s flawed project development process and environmental assessment.  The City of Portland pulled out of the project in 2020 citing a lack of community engagement.  And the Federal Highway Administration rescinded the project’s Finding of No Significant Impact (FONSI), in part because of flaws in the ODOT-prepared Environmental Assessment. Only the personal intervention of then-Governor Kate Brown revived the project.

ODOT gave preferential treatment to the I-205 bridge project

ODOT also chose to launch the Abernethy Bridge construction first, expediting a construction contract, even though the bridge repair came in at double ODOT’s cost estimate. (And in an unnoticed part of ODOT’s new financial plan is an acknowledgment that the Abernethy Bridge Project will now cost $622 million, up from $500 million a year ago).

Now that the Abernethy project is launched, ODOT is dissembling about the role of tolls.  The agency’s finance director flatly contradicted the FHWA finding in his testimony to the Oregon Transportation Commission on June 28.  Brouwer said:

. . . we’ve already put the Abernethy Bridge Project out to bid based on the assumption of being able to toll this and it is under contract, under construction so we have now that the situation where if for any reason tolls on I-205 do not move forward whether that’s due to action at the federal, state or regional level it would punch a significant hole in the finance plan.

As a result, the failure to toll I-205 now will likely jeopardize funding for the Rose Quarter, because ODOT is contractually obligated to pay for the Abernethy Bridge even if tolling doesn’t materialize.

Rose Quarter:  Cost Overruns and No Funding Plan

As we’ve documented, the Rose Quarter has chalked up an impressive string of cost-overruns, with new, and much higher cost figures, arriving every 18 to 24 months.  The project was originally budgeted at $450 million when approved in 2017, jumped to $795 million just two years later, and then to $1.45 billion in 2021, and now $1.9 billion

In September 2021, the Oregon Transportation Commission, shocked by the new cost figures, directed ODOT staff to come back with a new finance plan by December of 2021. As Willamette Week reported, OTC was hoping somebody else would ride to the rescue:

The OTC told ODOT staff to come back with a funding proposal by Dec. 1 that includes significantly more than the $500 million to $700 million available from the state. The commission directed ODOT to include specific information in the funding plan, including (1) an estimate of the amount of dedicated funding needed to build the project and (2) “a discussion of whether a viable plan to secure that dedicated funding from federal, state and/or the city of Portland, Metro, Multnomah County, TriMet and other organizations in Portland is reasonably likely to be authorized and appropriated by July 1, 2023.”

The department completely missed that deadline.  More than 18 months later, in May 2023, the staff showed up at a Commission meeting and asked for yet another year of delay to prepare a financial plan.  This project’s financial woes are not the product of the recently announced tolling postponement; they’re a long-standing dereliction of financial duty by ODOT.

Rose Quarter is now permanently behind an even more expensive Abernethy Bridge.

Now that the Abernethy Bridge has started construction, that project takes absolute priority over the Rose Quarter project. As ODOT Finance Director Travis Brouwer testified to the Oregon Transportation Commission on June 28, because the agency had started the I-205 Abernethy Bridge, that was “locked in.”

. . . we have started on the I-205 Abernethy bridge and so that is locked in . . .

OTC Vice Chair Lee Beyer confirmed that in his comments in the meeting:

. . . one of the fiscal realities is we have to move forward on Abernathy because we’re in the midst of construction we really don’t have an alternative there . . “

But the loss of funding was only part of the problem:  ODOT has badly botched the design of the Rose Quarter project, leading to an escalating series of cost overruns.  The project which was estimated to cost $450 million in 2017, jumped to $795 million in 2018, to $1.45 billion in 2021, and now to $1.9 billion.

Rose Quarter’s Fatal Flaw:  A Too Wide Design

All of these cost increases are driven by ODOT’s decision to build a massively wider freeway.  The current roadway is about 82 feet wide; ODOT plans to double it to 160 feet (and in places 200 feet).  ODOT has got to great lengths to conceal the actual dimensions of the freeway, and claims that it’s adding just one auxiliary lane in each direction.  The reality is its intent on building a roadway broad enough for ten travel lanes (up from four today).

ODOT’s own consultants, the internationally recognized engineering firm ARUP, explicitly said that ODOT was designing an excessively wide roadway, with shoulders in the covered section wider than in any city in North America.  It recommended reducing the width of the roadway by more than 40 feet.

The excessive width of the roadway is the biggest cost driver.  It necessitates huge and expensive columns and girders to carry local streets across the widened freeway.  And because the beams supporting the road (and proposed covers) have to be much taller than current beams, ODOT has to depress the roadbed of the freeway below its current level—excavating at great expense to assure adequate vertical clearance for the new road.

ODOT’s attempt to package the I-5 Rose Quarter project as “restorative justice” for the damage a series of ODOT highway construction projects did to the Albina neighborhood from the 1950s to the 1970.  Grafting elaborate (but still very constrained) covers on to its overly wide freeway is plainly uneconomical.


Testimony to the Oregon Transportation Commission

On June 28, 2023, City Observatory’s Joe Cortright testified to the Oregon Transportation Commission about the agency’s dire financial situation.

Background:  The Oregon Department of Transportation is pushing a multi-billion dollar freeway widening program in Portland, dubbed the “Urban Mobility Plan.” The agency has never fully identified how the plan would be paid for, and recent plans to put tolling on hold for two years, prompted Governor Tina Kotek to direct a new look at project plans and agency finances.  ODOT has cancelled one project (Phase 2 of I-205), and effectively admitted it has no way to pay for another, the I-5 Rose Quarter project.  The new plan reveals yet more cost-overruns on these already bloated projects, and in reality, provides no explanation of how they might be funded.

For the record: Joe Cortright. I’m an economist with City Observatory and a member of No More Freeways. I’m commenting on the Urban Mobility Finance Plan developed by your staff. This isn’t really so much a plan at all as as it is a belated and only partial admission of the deep-seated structural financial problems for which your staff has no serious solution. The “plan” that they are offering is a vague hope that more federal and state funds will magically appear for the projects in the Urban Mobility plan.

The fiscal crisis that ODOT is now in was foreseeable and foreseen to anyone who took a serious look at the at the agency’s finances. Your revenue model and your expenditure processes are broken: the gas tax is already coming in below projections and is projected to decline further. Vehicle miles traveled, according to your own forecasts, are in permanent decline. State climate goals call for a 50 percent decline in gasoline sales which will further reduce your revenue.

And we received notice earlier this month that the Highway Cost Allocation Study shows that because of ODOT spending patterns we’ll have to reimburse trucks and heavy over-the-road vehicles about $220 million per year. So your revenue situation is far worse than you’ve acknowledged.

In the face of this, the Urban Mobility Plan is confronting you with huge cost overruns. We’ve seen that the Rose Quarter Project’s price tag has now ballooned to $1.9 billion —more than four times the $450 million that the Legislature was told that this project would cost when it approved it in 2017.

Despite these cost overruns, there is not one word in this plan about right-sizing any of these projects, which are all over-built. I would note that then-Speaker now Governor Tina Kotek called for right-sizing these projects in 2021 when she voted against House Bill 3055 which authorized the commission to do additional borrowing.

Please take a close look at the scale of these projects, because your staff has concealed exactly how large these projects are. This is the reason they’re so expensive is that the Rose Quarter project is a 10-lane wide freeway project and the Interstate Bridge Replacement is a 12-lane wide freeway project. If these projects were right-sized they would be vastly less expensive.

Finally you’re counting on toll revenues to bail out your financial situation. As an economist I can tell you the effect of tolls will be to reduce traffic, which in many respects is a good thing. But by tolling these roadways to pay for them, you will essentially obviate the need for additional capacity. ODOT’s own studies of the Rose Quarter project show that implementation of Regional Mobility Pricing will be more effective in reducing congestion than the now $1.9 billion cost of widening the roadway through there.

In the past you’ll pursued a piecemeal approach to these projects. ODOT is in the midst of a serious financial crisis: the cost of these projects is exploding. It’s time to take a serious objective look —and I just have to say as somebody who’s been commenting on these projects for more than a couple of decades now— some engagement by your staff in a serious fashion, rather than just two minutes of enduring the comments that we make and then simply ignoring them would be much appreciated. We have technical expertise and would be happy to engage with your staff and assist the commission to deal with the gnarly financial problems that it faces.

Scratch one flat top!

Oregon freeway fighters chalk up a key victory—but the fight continues

On June 26, the Oregon Department of Transportation finally bowed to reality that it simply lacks the funds to pay for a seven-mile long widening of I-205 just outside of Portland.

Predictably, ODOT conceded defeat in the most oblique possible terms; the I-205 project isn’t dead, its officially just “indefinitely postponed.”  This, in exactly the same way that the White Star Lines could still describe the arrival of RMS Titanic as “indefinitely postponed.”

Opposition to the project was led by No More Freeways, a grassroots Portland group fighting billions of dollars of freeway widening projects being pushed by ODOT.  No More Freeways filed detailed objections and critiques of the project technical work in comments on its Environmental Assessment. In addition, NMF’s community members submitted over 300 comments in opposition to the I-205 expansion during the public comment period last spring, including technical comments pointing out the explicit violation of federal environmental protection law. 

ODOT’s proposed I-205 expansion was listed as one of the worst transportation projects in the country in USPIRG’s “Highway Boondoggles” report in 2022. 

In a prepared statement, No More Freeways co-founder Chris Smith said:

“No More Freeways is delighted to learn that the Oregon Department of Transportation proposes indefinitely postponing expansion of Interstate 205 even as the agency acknowledges they simply do not have a path forward to fund the now $1.9 billion Rose Quarter Freeway Expansion. 

These are both massive victories for any Oregonian who enjoys clean air, safer streets, a hospitable planet, and fiscal responsibility from their state government. Now more than ever, No More Freeways continues to insist that ODOT conduct a thorough Environmental Impact Statement on the proposed Rose Quarter Freeway Expansion that studies alternatives to expensive freeway expansion that reduce congestion while bringing clean air and justice to the Albina neighborhood.”

This decision saves Oregon taxpayers more than $400 million that would otherwise be spent on this highway widening project.

Scratch one flat top

In May of 1942, in the darkest days of World War II, American naval aviators struck the first blow agains the previously un-beaten Japanese Navy at the Battle of Coral Sea.  American dive-bombers, led by Lieutenant Commander Robert Dixon, attacked and sank the aircraft carrier Shoho; Dixon famously signaled “Scratch one flattop,” which subsequently became a rallying cry for Allied forces.

We can only hope that this first small victory will signal a turning of the tide in the battle against wasteful and counterproductive highway expansion projects.  Oregon DOT continues to maintain the fiction that its now-$1.9 billion Rose Quarter project is still alive, but it too, will have to yield to the fiscal reality that the highway department is essentially broke and doesn’t have the resources to maintain the roads it currently has, much less build enormously expensive new ones.


Pens down!

The price of ODOT’s trouble plagued Rose Quarter project has quadrupled to $1.9 billion, and the agency has no way to pay for it, because it spent the money the Legislature provided in 2017 on another project.  And agency staff is telling the state Transportation Commission there’s nothing that can be done to consider modifying the project or reducing its cost because they’ve gotten to a “pens down” moment.

At the same time it’s saying “pens down”, the agency is also asking for two more years and another $40 to $60 million to get the project to a level of just “30 percent” design.

ODOT is claiming “pens down” even after it has just revealed a new interchange flyover design that hasn’t gotten public review, city approval or inclusion in required federal environmental documents.

Even though the agency has no money to pay for the Rose Quarter, and hasn’t studied tolling, ODOT insists on moving forward as if $1.9 billion will magically appear, a strategy that can be fairly called “extend and pretend.”

The Rose Quarter debacle illustrates the incompetence and dysfunction of ODOT:  costs can only increase, and the only solution is getting more money for bloated projects.

Newly appointed OTC Commissioner Jeff Baker got his bureaucratic baptism at the June 28 special meeting of the Oregon Transportation Commission.

The Commission was called into a special meeting to review the dire budget situation confronting ODOT’s “Urban Mobility Program”—a multi-billion dollar collection of highway expansion projects proposed for the Portland area.  In May, Governor Tina Kotek announced a delay in tolling plans until no earlier than 2026, and directed ODOT to present a new financial plan.

The key element of that plan was an acknowledgement that ODOT’s revenues were shrinking even as the cost of its projects was growing.  The plan called for effectively cancelling the I-205 Phase 2 project, and indefinitely shelving the I-5 Boone Bridge.  But the big hole in the budget is the exploding cost of the 1.5 mile I-5 Rose Quarter project in Portland.  The Rose Quarter project faces a $1.75 billion funding shortfall, and as we reported earlier, ODOT’s strategy is “extend and pretend:”  keep spending. money on project planning and hope someone will magically find the needed cash.  ODOT’s staff told the commission that was essentially their only option.  But is it?

Pens down, Commissioner Baker

Yes, the cost of the Rose Quarter project just ballooned to $1.9 billion—more than four times the estimate that ODOT gave the legislature when this project was approved in 2017, but according to ODOT staff, now its simply too late to do anything to reduce the costs or modify the scope of the project.  That’s what Urban Mobility Office Director Brendan Finn told newly appointed Oregon Transportation Commissioner Jeff Baker at the June 28 meeting.

Baker asked whether, in light of revenue shortfalls, scope creep and cost overruns, the OTC had an obligation to ask whether it was sensible to move forward. (A longer transcript is below):

I’m just curious about governance.. . . what happens when we get scope creep when we get inflation that reaches a certain magnitude?  At what point do we have an obligation to go back and and relook at decisions that we’ve made in the past—whether it be 205 or or whether it be a Rose Quarter or anything else that that we’ve got coming on—because obviously, this is a it’s important, but it’s becoming increasingly expensive.  And it appears that we’re not done yet in terms of defining what the overall scope of the project is.

Brendan Finn shut that down:

This is the design that we are taking through the environmental process. This is the design that we are seeking federal approval on. I think we’ve come to a “pens down” moment.

Never mind that there’s no actual money for the project.  Never mind that the project is years away from construction, even if the money can be found. Changing the scope of the project is simply an inadmissible question.

Who’s in charge:  The commission or its staff?

Finn’s “pens down” assertion that nothing can be changed is problematic on many of levels.

First, and most importantly, who decides when it’s time to put “pens down?”  Finn works for the Oregon Transportation Commission, not vice-versa.  If the Commission decides it doesn’t want to move forward with the $1.9 billion design, ODOT staff can’t do so.  It is a “governance” issue, exactly as Commissioner Baker framed it.  Nothing in statute authorizes staff to make “all-or-nothing” ultimatums to the commission.  Arguably, asking questions about this project (and others) is exactly the Commission’s responsibility, a point we made when the project’s price tag jumped to nearly $800 million in 2019.

Second, the truth is, ODOT hasn’t put its pen down:  the agency  is very much in the business of re-designing this project, even as it made this presentation to the commission.  It just unveiled a new “flyover ramp” which hasn’t been reviewed or approved by any local or federal partners (See below).  In addition, ODOT’s own presentation concedes the project it will take another two years and an additional $40 to $60 million to get the project to a level of 30 percent designed.  There’s lots ›of ink yet to be spilled on this project.  Apparently, ODOT has made little progress on Rose Quarter design:  Almost two years ago, in September 2021, Brendan Finn told OPB:

Well, the project is still pretty much in its infancy, it’s only being at 15 percent design.

Third, going forward nothing precludes ODOT (or any other state highway agency) from further “refining” the project when it encounters design problems, cost overruns funding shortfalls or changing circumstances.  The federal partners essentially never force a “pens down” moment.  Take for example one of the Biden Administration’s signature infrastructure projects, the $3 billion expansion of Cincinnati’s Brent Spence Bridge.  There, the state DOTs just lopped off 40 percent of the project (to save costs) years after it had completed environmental reviews.  And the City of Cincinnati is pushing further design changes to eliminate off-ramps and free up 30 acres of land for development.  All this more than six months after the Biden Administration approved $1.6 billion in federal funding for the project.  Nothing in the National Environmental Policy Act or the policy or practices of the Federal Highway Administration (the “federal partners”) locks Oregon into an unaffordable project, or precludes designing a more affordable and environmentally sensible alternative.

Fourth, ODOT can’t get federal environmental approval until it pulls together actual funding for the project.  Federal Highway Administration rules prohibit environmental approvals for projects for which funding hasn’t been demonstrated to be “reasonably available,”—a standard the Rose Quarter is nowhere meeting. As just one indicator, the current Regional Transportation Plan allows for a total budget of $375 million for the Rose Quarter, more than $1.5 billion short of the amount needed to pay for the proejct.

In theory, it might be fair to say, “pens down,” if the project had received federal environmental approval (it hasn’t), has been approved by local governments (they just saw the new flyover design for the first time), and if the money for the project were in hand. None of these things are true. ODOT concedes that even if the money could be found, construction on the main part of the project wouldn’t happen before  2028.

Instead of having a serious conversation about whether we can afford this project and whether its still makes sense, and whether something smaller, more useful and actually affordable would be a better idea is off the table.  Instead, ODOT staff is insisting that we “extend and pretend.”

ODOT is still actively redesigning the Rose Quarter Project

And notice that just the day prior to this meeting—for the very first time—ODOT publicly revealed a new, never-before-seen exit ramp design for the project, one that hasn’t been subjected to any environmental review.

The new design adds a flyover offramp (the orange horseshoe-shaped object) from I-5 southbound that creates an elevated hairpin turn midway over the widened I-5 freeway, before the road joins with the existing I-5 NB offramp at Weidler.  The Urban Mobility Finance Plan is vague on the details, but it doesn’t appear that the current price estimate of $1.9 billion includes this new off-ramp configuration, which also is not part of any existing state or city transportation plan.

As Commissioner Sharon Smith put it at the meeting, ODOT is “out of money.”  The only hope for paying for the Rose Quarter is implementing tolling, but the project’s current environmental analysis explicitly says it will not include congestion pricing because tolls “aren’t reasonably foreseeable.”   ODOT staff are saying the OTC is powerless to consider, or even suggest, that a smaller, more affordable project might be the best way forward, or that perhaps we should first implement congestion pricing, and then see, what, if any, additional capacity is needed.

Appendix:  Partial Transcript, Oregon Transportation Commission, June 28, 2023

OTC Commissioner Jeff Baker:

I apologize for being the new guy, asking some naive question here. So bear with me, As it relates to the Rose Quarter, and again I think we’re all feeling that this is an important project on a whole lot of levels, the cost from time the Commission last looked at this in ‘21 versus the cost we’re looking at today has increased by 30 percent.

And I’m just curious about governance. And what happens when we get scope creep when we get inflation that reaches a certain magnitude at what point do we have an obligation to go back and and relook at decisions that we’ve made in the past whether it be 205 or or whether it be a Rose Quarter or anything else that that we’ve got coming on, because obviously, this is a it’s important but it’s becoming increasingly expensive. And it appears that we’re not done yet in terms of defining what the overall scope of the project is. So do we have a responsibility at this point? Is there governance around really taking a look at this or you know, other entities that have a stake in it the Governor’s office, the Commission, or the Legislature?

Brendan Finn, (Director, ODOT Urban Mobility Office)

Madam Chair, Commissioner Baker, I guess I’d say first, the scope creep topic. Obviously, a lot of these changes in came forward through various discussions, various tables. This is the design that we are taking through the environmental process. This is the design that we are seeking federal approval on. I think we’ve come to a “pens down” moment. And we feel that our partners and the community feel that way too. So this this is what we’re carrying forward. Through, obviously, the iterations that we’ve had the conversations with the Commission, and others, so I guess I want to get out in front of that, Commissioner. This is this is the time where we’re putting the pens down and we’re taking this design forward.

Jeff Baker

Okay, so as I understand it, the design is frozen at this point, it’s pens down, no more changes?

Brendan Finn

Well, I will say that we are going through an environmental process right now. We are working with our federal partners, so I don’t want to get out in front of that. Commissioner, we do need to still look at some of the efforts that we’re going to need to put in to get that approval. They have not signaled that yet. So I guess I want to caveat that, but this is this is the this is the design that we’ve been, that we’re putting forward.

Jeff Baker

Okay. You know, I think it’s important that you know, when we look at any project, there’s constraints. And as we’re wrestling with them today, we’ve got financial constraints. We’ve got time constraints, we’ve got other constraints that go into it. So we need to manage them and not let them get away from us because ultimately, time kills projects and cost kills projects, so we have to be really diligent, especially when there’s something as important as this one to really be on top of our game and, and be sure that we we manage it in such a way that it can reach a really great conclusion.

Carmageddon does a no show, again (Philadelphia edition)

On Sunday June 11, a tanker truck caught fire on I-95 and the intense heat caused a section of the freeway to collapse.  I-95 is one of the nation’s principal north-south connections, and carries 160,000 vehicles per day.  It’s expected that repairs to the roadway could take months.

What would commuters and travelers do without this vital chunk of roadway?  Surely, we’re headed for gridlock and carmageddon!

But on Monday morning, despite some localized delays, pretty much nothing out of the ordinary happened.  Local TV station NBC10’s chyron shouted “COMMUTER CHAOS,” but their reporter actually found that traffic was mostly, moving steadily:

With the start of the workweek, following the collapse and closure of one of the city’s busiest thoroughfares, commuters on Monday seemed to handle the issue caused by the fiery collapse of a section of Interstate 95 fairly well.

Even as the about 160,000 vehicles that are estimated to drive along I-95 on any given weekday have had to find an alternate route due to the roadway’s collapse, traffic was moving relatively steadily.

While there were reports of slowdowns citywide, at the start of rush hour at about 7 a.m., the longest delay at the time was about 29 minutes for those headed eastbound along I-476 toward I-676.

Here’s what Monday morning traffic looked like according to Google Maps (h/t to tweet from Daniel Trubman)

Traffic in Philadelphia, Monday June 12, 2023. (Google Maps).

and for comparison, here’s what a typical Monday morning looks like, according to Google’s historical data.  If anything, overall traffic seems to be moving with more alacrity that on a typical Monday, despite a portion of I-95 being closed.

Philadelphia Traffic on a Typical Monday Morning (9AM)

This isn’t an unusual occurrence.  The same scenario is repeated, time and again, whenever a major section of roadway is removed from service, whether by construction, repair, or as a result of crashes.  Just ask Los Angeles, or Seattle, or Atlanta, or Minneapolis, or Portland.  In every one of these cities, a key roadway was taken out of service for days, weeks or months.  In every one of these cities, highway departments predicted calamitous delays and gridlock.  And in every one of these cities, pretty much nothing happened.  Traffic “just disappeared” and driving conditions “weren’t so horrible” and in several cases, congestion was less than usual.

The lesson here is that traffic is not an inalterable and irreducible quantity dictated by nature, its actually very dynamic and elastic.  People readily change their travel behavior in response to the availability of road capacity.  That’s the essential insight behind the science of “induced demand“–the observation that newly expanded roadways quickly fill to capacity.  And this is its mirror image:  “traffic evaporation.”

Many of the trips on our roadway are discretionary.  We can choose to take them at other times, take other routes, combine or forego trips, choose new destinations, or travel by other modes.  The traffic we observe at any point in time is not a fixed and inexorable amount that must be “served” but is simply the behavioral response of humans to the set of transportation choices available to them.

The repeated failure of these predicted “carmageddons” to ever occur is powerful evidence that the key tenet of highway planning is fundamentally flawed.  Highway departments claim that if we don’t build more roadways, traffic and congestion will increase without limit and we’ll face hours and hours of delay.  In reality, that never happens because people adapt their travel behavior to the available transportation system.  Widening roads in an effort to reduce congestion isn’t simply futile, its counterproductive.  More capacity generates more travel, more sprawl, more pollution, and ultimately more congestion.  It’s time to get off this treadmill.


What Cincinnati’s Brent Spence Bridge can tell Portland

There’s plenty of time to fix the Interstate Bridge Project

Contrary to claims made by OregonDOT and WSDOT officials, the federal government allows considerable flexibility in funding and re-designing, especially shrinking costly and damaging highway widening projects

In Cincinnati, the $3.6 billion Brent Spence Bridge Project

  • Was downsized 40 percent without causing delays due to environmental reviews
  • Got $1.6 billion in Federal grants, with only about $250 million in state funding plus vague promises to pay more
  • Is still actively looking to re-design ramps and approaches to free up 30 acres of downtown land

For years, the managers of the Interstate Bridge Project have been telling local officials that if they so much as changed a single bit of the proposed IBR project, that it would jeopardize funding and produce impossible delays.  Asked whether it’s possible to change the design, and they frown, and gravely intone that “our federal partners” would be displeased, and would not allow even the most minor change.  It’s a calculated conversation stopper—and it’s just not true.

Across the country, in Cincinnati, local leaders–who’ve already gotten a commitment of $1.6 billion in federal funds—based on a modest down payment and vague commitments to pay more.  Collectively, Kentucky and Ohio still have to figure out where about $1.5 billion in state funding will come from.

The new bridge over the Ohio River could be one of these two designs: cable-stayed or tied arch. Ohio and Kentucky officials pictured these options in a July 2022 presentation about the Brent Spence Bridge Corridor Project.

Last year, in response to local government concerns, the two state DOTs reduced the size of the Brent Spence Bridge by 40 percent from the version that the Ohio and Kentucky DOTs pushed through the environmental review process.  And that change isn’t expected to affect its environmental approvals or timetable.

Not only that, but local governments–led by Cincinnati—are still actively pushing for a major re-design of the bridge’s on- and off-ramps to free up 40 acres of land in downtown Cincinnati for urban redevelopment—something that they believe can be done without jeopardizing the project.

This is an object lesson for Oregon and Washington:  The federal government doesn’t require all local funding to be in place before it makes its commitment, it’s possible to shrink a project even after its gotten its environmental approval, and its also possible, even after getting the federal funding, to make major changes to the project design to lessen its impact on urban spaces.

As Metro President David Bragdon observed, Oregon and Washington DOT officials routinely lie about federal requirements and deadlines to block local officials from designing better and more affordable highway projects.

Leadership at ODOT frequently told me things that were not true, bluffed about things they did not know, made all sorts of misleading claims, and routinely broke promises. They continually substituted PR and lobbying gambits in place of sound engineering, planning and financial acumen, treating absolutely everything as merely a challenge of spin rather than matters of dollars or physical reality.  . . . ODOT management has revived one of its favorite old falsehoods by claiming they are facing an “imminent federal deadline,” and that if local leaders don’t knuckle under to ODOT’s plan–and soon–the region will lose millions or tens of millions of dollars forever.  Creating fictional “federal deadlines” and other federal processes as an excuse for false urgency is a familiar ODOT tactic.

For too long, highway officials have gotten away with their best Jerry Lundegaard impressions, telling state and local officials that their hands are tied, because their manager (in another room) just won’t approve a better deal or not charging for the under-coating.  Cincinnati’s Brent Spence project shows the federal government will allow changes that make highway projects have fewer environmental impacts, become more affordable, and benefit local communities.

Honey:  I shrank the bridge

The original design for the Brent Spence Bridge was approved by the US Department of Transportation in a “Finding of No Significant Environmental Impact, (FONSI)” in 2012.  As originally proposed, the bridge would have been nearly 150 feet wide.  Not only was this design over-sized (and expensive) but it had significant impacts on  the City of Covington Kentucky (the southern terminus of the new bridge).  The project languished without funding for more than a decade.

In 2022, the Kentucky and Ohio Departments of Transportation agreed to significantly reduce the width of the project.  They width of the double-decker bridge was reduced from 145.5 feet to 84 feet.

In June, 2022, the new, much more compact design was announced:

Based on engagement and technical analysis, the announced Friday said, the footprint of the new bridge has been significantly reduced from the alternative approved in 2012. . . . . The new bridge was planned to cover nearly 25 acres and span nearly 150 feet in width. Revised plans show the new bridge at almost half the size of the 2012 footprint – covering approximately 14 acres and 84 feet in width. (emphasis added)

This was a major concession to local leaders:

Covington Mayor Joe Meyer, led the negotiation for the City, called the agreement a monumental victory for Covington residents and businesses.  . . . “Meyer said it will “reduce the width of the driving companion bridge by over 40 %. It’s a 61 and a half foot reduction in the driving width of that bridge.They’ve reduced the additional right of way that was necessary by 10 acres, another 40 plus percent reduction in right of way acquisition.”

The Federal Highway Administration is being asked to “re-evaluate” it s NEPA approval.  The Kentucky and Ohio transportation departments are preparing an updated Environmental Assessment, and FHWA is expected to issue a revised “FONSI” this Fall.  The key argument made by the state transportation departments is that the new, smaller design is within the “footprint” of the already approved 2012 design, and therefore can be expected to have fewer environmental impacts.

Here’s the lesson for Oregon and Washington:  Just because the decade-old plans for your bridge called for a massively wider freeway, nothing in the federal environmental review process precludes you from making the project smaller.  That won’t slow down the environmental review process, and it’s no obstacle to getting federal funding.  For the proposed Interstate Bridge Replacement project, this means that a right-sized bridge, coupled with retaining (rather than replacing) existing interchanges, would likely get FHWA approval.

The bridge is approved:  Now let’s re-design it

The current design for the Brent Spence Bridge is now 40 percent smaller than it was a year ago—but the re-design is not over.  Like the proposed Interstate Bridge Replacement Project, the Brent Spence “Corridor” project calls for an expensive set of on- and off-ramps to connect to the new bridge.  On the Cincinnati side of the river, this spaghetti of ramps and intersections would foreclose the urban use of more than 30 acres of prime real estate in the city’s downtown.  Rather than repeat the devastating mistakes of past freeway construction–which obliterated most of Cincinnati’s historically Black neighborhoods–local leaders are calling for a re-design of Brent Spence’s ramps and connections to restore urban use.


Keep in mind that President Biden announced the approval of federal funding in January of this year.  Right now, in May, 2023, the Cincinnati City Council is pushing forward with plans to re-design the project as it passes through the city. The current Cincinnati Mayor, Aftab Pureval, and two former Mayors, John Cranley and Mark Mallory—have all spoken out in favor of a fundamental re-design of the Brent Spence Bridge to dramatically shrink its complex of interchanges and off-ramps, and free up more than 30 acres of land that were devastated by freeway construction. They’re calling on the Ohio Department of Transportation, and US DOT Secretary Pete Buttigieg, to give them flexibility to re-design the project—something the city has done successfully with other highways in Cincinnati:

We also applaud Transportation Secretary Pete Buttigieg (whom we have both known for many years) for implementing new rules that reward designs that are urban friendly. The federal government now embraces the kind of progressive vision our city showed in redoing Fort Washington Way and the I-71/MLK interchange.

The progressive design build process that ODOT has rightly put in place requires that local input be an official part of selecting a contractor and finalizing with that contractor a design that meets local goals and ambitions. That process has only just begun and any suggestion that it is “too late” to make design improvements isn’t paying attention to recent changes ushered in by Secretary Buttigieg.

A local group, called Bridge Forward, has come up with a plan to reduce the footprint of the onramps, and trigger urban renovation:

The Bridge Forward Plan

This has a direction implication for the Interstate Bridge Replacement Project in Portland and Vancouver.  In their $7.5 billion project, ODOT and WSDOT are proposing to re-create, and rebuild at great expense, seven closely spaced freeway interchanges, which they—and independent consultants they hired—have said are a fundamental cause of the highway congestion and which are a majority of the cost of the bloated project.

As Cincinnati’s experience shows, even after the bridge has been down-sized, and the federal money committed, there’s still the opportunity to get a more sensible, sensitive design.

The Ohio experience with the Brent Spence Bridge shows that, if local leaders are in agreement, we can shrink the size of the project to reduce its cost, and continue to explore designs that are less disruptive to the urban fabric without slowing down the federal funding, environmental approval, or construction contracting processes.

No money down:  The Feds contributed to the project in return for partial state funding and vague commitments, not hard cash

A key talking point of the Oregon and Washington DOTs is that Oregon has to put $1 billion on the table in order to apply for federal funds.  That’s clearly not the case with the Brent Spence Bridge.  Local television news station WKRC reported that President Biden committed $1.6 billion in federal funds for the project’s total cost, estimated at $3.5 billion.  So far the only state commitments are a $250 million pledge from the Kentucky legislature and an vague statement from Ohio Governor that his state would “pay its share:  That leaves more than $1.5 billion that the two states expected have yet to come up with, as WKRC reported:

That leaves another $1.5 billion in costs to be split between Ohio and Kentucky. The Kentucky General Assembly last year pledged $250 million toward the project, with Ohio Gov. Mike DeWine also promising his state would pay its share.
Ohio and Kentucky have gotten the federal government to commit its $1.6 billion from the bipartisan infrastructure law well before nailing down the local revenues for the project.  The lesson for Oregon and Washington is that they should instruct their state transportation departments to proceed to get the federal funding in place, without insisting on a full up-front payment from the states.  Knowing exactly how much the federal government will contribute will tell the states how big a hole they have to fill, rather than signing them up to pay whatever the project ends up costing.
Editor’s Note:  This commentary has been revised to correct errors in the summary (May 10).


Why can’t ODOT tell the truth?

The Oregon Department of Transportation (ODOT) can’t tell the truth about the width of proposed $7.5 billion Interstate Bridge Replacement Project

ODOT is more than doubling the width of the bridge from its existing 77 feet to 164 feet.

The agency can’t even admit these simple facts, and instead produces intentionally misleading and out of scale drawings to make their proposed bridge look smaller.

If engineers can’t answer a simple question about how wide a structure they’ll build, why should anyone have any confidence in their ability to accurately estimate costs or revenues?  

Why is the width of this bridge, and its actual appearance a state secret?

It’s a simple question, really:  How wide is the $7.5 billion”Interstate Bridge Replacement” that Oregon DOT is trying to sell the Oregon Legislature?  Several members of the Joint Transportation Committee put that very question to ODOT leaders, and simply got a gibberish non-answer.

Oregon DOT’s lobbyist, Lindsay Baker wrote a rambling response to the question, which alternately, offered a long digression on the history of the existing bridges, answered a question the legislators didn’t ask (combined the over-water space covered by the bridges, including the space between the bridges), and offered absurd and meaningless statistics (28 percent of structure area would be “dedicated” to transit.). Baker’s response even included a couple of diagrams—which as we will see were purposely altered to conceal the actual width of the proposed bridge, and make it look smaller. Instead, the chief ODOT talking point is that they are merely adding “one auxiliary lane” in each direction to the existing bridge footprint.

Nothing in Baker’s non-response reveals the actual measurements of either the existing or proposed structures.  Let’s cut to the chase, because these are, ODOT obfuscation notwithstanding, simple facts (the kind the real engineers actually excel at).  The existing bridges have a combined roadway about 77 feet wide.  The proposed bridges would have a roadway that is 164 feet wide. ODOT proposes to more than double the width of the roadway across the river.  The existing bridges carry six lanes of traffic (three lanes in each direction).  The proposed structure is easily wide enough to carry twelve lanes—six in each direction.

Old Bridge:  77 Feet Wide; New Bridge 164 Feet Wide

How do we know this?  It takes a combination a two-second Internet search (the existing bridge) and a public records request and some algebra (the proposed bridge). First, for the record, the existing bridges have roadway widths of 38 feet and 39 feet respectively., for a total roadway width of 77 feet. 

It’s harder—much harder—to find the width of the structure ODOT is proposing.  In describing the width of the “locally preferred alternative” at the time it was approved by local governments, ODOT declined to say how wide the actual structure was, instead it cryptically reported that the LPA will be 16 feet narrower than the Columbia River Crossing proposed a decade ago. 

So, in order to know the width of the IBR, you have to know the width of the CRC.  And, the width of the CRC is effectively a state secret.  In its environment impact statement of 2011, ODOT erased all the actual measurements showing how wide that bridge would be—it took a public records request to get them to disclose that it would be 180 feet wide.  Here’s an excerpt of the plans we obtained via public records request, showing the CRC had a minimum width of roadway of more than 90 feet on the top decks of each of its two spans (other portions of the bridge are even wider, to accommodate a horizontal curve, as the bridge crosses the river). 

So the answer to the ODOT bridge width riddle is that the LPA is 164 feet wide:  180 feet (the width of the CRC) minus 16 feet equals 164 feet.  For the record, ODOT is planning two side-by-side, double-decker bridges with 82 foot top decks and 48 foot bottom decks.  That creates 164 feet of roadway on the top-deck of the two bridges.  In addition, there’s even more space on the bottom deck of these double decker bridges; the bottom decks are about 47 and a half feet wide, meaning that there’s a total of 95 feet of additional travel capacity on the two bottom decks.  ODOT’s plan is for the highway to be carried on the top decks of the two bridges, and for light rail to be located on the bottom deck of one bridge, and a bike/pedestrian path on the bottom deck of the second bridge.

Intentionally Misleading Images

In her letter Joint Transportation Committee, ODOT lobbyist Lindsay Baker waxed poetic about the width of the existing bridges, and included a couple of extremely misleading and not-to-scale drawings of the existing bridge and their proposed alternatives.  We’ll focus on the double-decker bridge alternative which ODOT has characterized as the official “Locally Preferred Alternative” (LPA).  Keep in mind, the Interstate Bridge Program has spent tens of millions of dollars on engineering; its predecessor spent $200 million on the nearly identical Columbia River Crossing, and when asked to provide a drawing, ODOT offers up some “not-to-scale” cartoons to answer a simple quantitative question.

Here are the illustrations Baker provided.  Above is the existing bridge, below is the proposed bridge

We’ve added one small annotation—a red bar showing the width of the wider of the two current bridges (39 feet).  We’ve copied that 39 foot measuring stick to ODOT’s drawing.  It seems to show that ODOT is squeezing four lanes of traffic into the same space as the current bridges three lanes.  But of course that isn’t true:  ODOT has rendered the two bridge images at different scales.  The first clue is that the cars and trucks in the lower, IBR drawing are much smaller than the cars and trucks in the upper (existing) drawing).  We printed out and measured their diagrams.  The top diagram is drawn at a scale of about 1:250 (about one inch equals 20 feet).  The bottom diagram is diagram is drawn at a scale of about 1:375 (one inch equals about 30 feet).  The scales are chosen explicitly to make the new bridge seem smaller than it really is.

We’ve corrected ODOT’s drawing by re-projecting their image at a comparable scale.  (This makes the trucks and cars roughly the same size in both drawings).  With this correction it’s now apparent that the ODOT plan is to more than double the width of the current roadway, from a combined 77 feet between the two existing bridges, to a total of 164 feet between the two proposed bridges.

More than Doubling the width of the I-5 highway bridges—Enough for a 12 full lanes

We know, that at a minimum, ODOT’s plan is to increase the roadway width across the Columbia River from 77 feet to 164 feet–more than doubling the width of the roadway.  The new bridge is 164 feet wide.  How wide is that exactly:  well, its almost exactly as wide as a football field (160 feet).

A 164 foot wide roadway can easily accommodate 12 travel lanes.  Standard travel lanes are 12 feet wide.  Twelve twelve foot travel lanes would occupy 144 feet of the 164 feet of roadway that ODOT proposes for its bridge structure—leaving 20 feet for shoulders.  It is not uncommon on urban roadways, especially on bridges, to accommodate shoulders in this area:  ODOT’s plan would allow for 4 foot inside (left) shoulders) on each crossing and 8 foot outside (right) shoulders.  For reference, as part of its $1.45 billion  I-5 Rose Quarter project, ODOT is proposing 11 foot travel lanes and shoulders of between 3 and 6.5 feet on a viaduct section of the project near I-84.  There’s nothing illegal, unusual, or substandard about 11 foot lanes and somewhat narrower shoulders on urban roadways:  In fact, the Federal Highway Administration prominently praised ODOT for narrow lanes and narrow shoulders on Portland’s I-84 Interstate Freeway.  Here is a page of the USDOT report, “USE OF NARROW LANES AND NARROW SHOULDERS ON FREEWAYS: A Primer on Experiences, Current Practice, and Implementation Considerations.” FHWA HOP-16-060.  The narrow shoulders on I-84 are also featured on the cover of the document.

IBR:  A Pattern of mIsleading, “not to scale” drawings.

Lying with pictures is nothing new for the IBR project.  As we’ve noted before, despite spending tens of millions of dollars on planning, and more than $1.5 million to build an extremely detailed “digital twin” of the proposed bridge, IBR has never released any renderings showing what the bridge and its mile long approaches will look like to human beings standing on the ground in Vancouver or on Hayden Island.  And the IBR also released similar misleading and not-to-scale drawings that intentionally made the height and navigation clearance of their proposed bridge look smaller than it actually is.

ODOT’s not-to-scale image to make the IBR look smaller than the existing I-5 bridge

Hiding the actual width of the bridge they intend to build is a scene-for-scene remake of false claim made for the preceding project—the failed Columbia River Crossing (CRC). In 2010, in response to objections from the City of Portland and Metro, ODOT and WSDOT announced they were reducing the size of the CRC bridge from 12 lanes to 10 lanes. But in reality, all they did was change the references in the project documents to that number of lanes, while literally erasing from the Final Environmental Impact Statement every single reference to the actual widths of the bridges and other structures they intended to build. A public records request showed the actual plans for the bridges — which were not published — were exactly the same size (180 feet in width) as they were for the 12-lane version of the bridge.

ODOT seems to be congenitally incapable of revealing the actual width of any of the major projects it is proposing.  As we’ve pointed out at City Observatory, it has gone to great lengths to conceal the width of the proposed I-5 Rose Quarter project, which as it crosses under the Broadway and Weidler interchanges in Portland will be 160 feet wide.  While the project’s Environmental Assessment pretended the project was 126 feet wide (again, based on cartoon “not to scale” images), secret ODOT documents confirmed that the agency has always been planning a 160-wide roadway.




Here’s the full letter from ODOT’s Lindsay Baker to the Oregon Legislature’s Joint Transportation Committee.


A blank check for the highway lobby: HB 2098-2

The HB 2098 “-2” amendments  are perhaps the most fiscally irresponsible legislation ever to be considered by the Oregon Legislature.  They constitute an open-ended promise by the Oregon Legislature to pay however much money it costs to build the Interstate Bridge Replacement and Rose Quarter freeway widenings—projects that have experienced multi-billion dollar cost overruns in the past few years, before even a single shovel of dirt has been turned.

HB 2098-2 amendments would:

  • Raid the Oregon General Fund of $1 billion for road projects
  • Give ODOT a blank check for billions of dollars of road spending
  • Allow unfettered ODOT borrowing to preclude future Legislatures from changing these projects and forcing their funding
  • Eliminate protective sideboards enacted by the Legislature a decade ago
  • Enact a meaningless and unenforceable cap on project expenses.

Oregon’s transportation department is going broke:  Its major source of revenue, the gas tax, is in terminal decline, thanks to growing vehicle fuel efficiency and electrification.  The agency doesn’t even have enough money to maintain current roads, and has been cutting back on maintenance, and yet is set to embark on an unprecedented spending spree.

The “-2” Amendments will serve as a pretext for ODOT to borrow money to get each of these projects started, regardless of how much the projects will actually cost, and whether federal grants for these projects or toll revenues will cover even a fraction of their cost.

The bill does this because it knows that if legislators were asked to come up with the money for these projects today, by raising gas taxes or other road user fees, there’d be no stomach (or votes). So, instead, they’s simply let ODOT max out its credit cards, and sign construction contracts, and come back to the 2025 Legislature with a giant bill that it will have to pay.

“If wishes were horses, beggars would ride”

The Legislature seems bound and determined to enact into law this old Scottish proverb.  Section 3 of the -2 amendments declares the Legislature’s “intent” to borrow $1 billion in General Obligation Bonds, to be repaid over the next couple of decades or more from the state General Fund.  Section 11 of the -2 amendments further declares the Legislature’s “intent” to appropriate whatever it ends up costing to build the I-5 Rose Quarter project, with no reference to a specific dollar amount or source of funds.

The -2 amendments to HB 2098 don’t contain an explicit appropriation of funds, or a new source of revenue, or even a specific authorization to issue new debt.  Instead, we have just vague indications of intent:

“The Legislative Assembly intends to support the Interstate 5 bridge replacement project through an investment of $1 billion . . ”

“The Legislative Assembly affirms its intent to fully fund the Interstate 5 Rose Quarter Project in the 2024 and 2025 regular sessions of the Legislative Assembly.”

It’s far from clear what the legal meaning of these statements of “intent” have.  But the authors of the -2 amendments are trying to have it both ways:  they are trying to appropriate money, without actually appropriating money.  They’re not actually taking the step to spend these funds (and say where the money will come from) but are trying to commit future Legislatures to making those difficult decisions.  It might seem that statements of intent (like legislative resolutions and memorials) are merely legislative window-dressing, with no legal weight.  But it’s clear that the Oregon Department of Transportation has other plans.

“Intent” plus debt:  Committing future Legislatures to pay billions

Superficially, HB 2098-2 might seem like an empty letter—the Legislature often makes sweeping, feel good statements of intent—but the danger with this one is that it could serve as the basis for the Oregon Department of Transportation to pull out its credit card and borrow hundreds of millions of dollars, based on the vague promise that some future Legislature will pay these bills.  And this is no idle speculation:  this is exactly what ODOT did with the I-205 Abernethy Bridge Project.

It’s worth spending a minute to review that project.  In 2017, the Oregon Legislature adopted a major transportation package, which provided $450 million for the I-5 Rose Quarter project (paid for with a $30 million per year increase in gasoline and weight mile taxes).  That package conspicuously did not provide funding for the Abernethy Bridge, but instead the Legislature directed ODOT to come up with a plan to use tolling to pay for I-205 improvements, and to report back with a “Cost to Complete” report that would tell how much this project would cost.  In 2018, the Cost to Complete report came in with a $250 million price tag for the Abernethy Bridge.  The I-205 project languished for a couple of years, and in 2021, ODOT persuaded the Legislature to adopt HB 3055, which made two significant changes.  HB 3055 authorized ODOT to dip into the $30 million per year fund designated for the Rose Quarter project to pay for I-205 (as well as the I-5 Boone Bridge), and also gave ODOT the authority to issue short-term bonds (the public sector equivalent of a payday loan).

In 2022, ODOT used the newly granted authority in HB 3055 to move forward with the Abernethy Bridge Project.  First, it told the FHWA that it could build the project entirely without toll financing—thus evading federal environmental review of tolling on the Abernethy Bridge.  Second, it took advantage of its short term borrowing authority and the HB 2017 Rose Quarter funding to start construction on the Abernethy Bridge, even though the price tag of the bridge had doubled to $500 million from the number it quoted the Legislature.  As a result of ODOT’s action, Oregon is now obligated to pay the full price of the Abernethy Bridge project, presumably through the HB 2017 $30 million appropriation and toll revenues.

It’s likely that the Abernethy Bridge project will use up all of the $30 million per year available from HB 2017, leaving little or nothing to pay for the I-5 Rose Quarter project, which meanwhile, has tripled in cost to as much as $1.45 billion—and which still faces major questions over its design.

A Blank Check for the Highway Lobby

Combining Oregon DOT’s short term borrowing authority from HB 3055 (its basically unfettered ability to get a payday loan of hundreds of millions of dollars), with a statement of “intent” that the Legislature will some day deliver whatever money is needed for the I-5 Interstate Bridge Replacement Project and the Rose Quarter freeway widening is likely all ODOT needs to get these projects started.  It will issue perhaps $500 million in such bonds, covering the initial interest and principal repayments from its current revenue and with the assumption that it will ultimately refinance the balance of the costs in balloon-mortgage fashion with the “intended” funding from some future Legislature.

And when these blank checks are filled in, the numbers will be very large.  The Interstate Bridge Replacement Project’s estimated cost has risen from a supposed maximum of $4.8 billion in 2020, to a new maximum of $7.5 billion today.  Similarly, the cost of the I-5 Rose Quarter project was sold to the 2017 Legislature as being $450 million.  The latest estimate now runs to $1.45 billion–and that figure is already out of date.  And these are just preliminary, pre-construction estimates;  if past experience is any guide, both of these projects will both end up costing significantly more once actual construction begins.

Once started, both the IBR and the Rose Quarter projects are designed in such a way that it may be impossible or prohibitively expensive to reduce their scope.  The IBR is planned as a fixed, high-level crossing that will necessitate lengthy elevated viaducts and the rebuilding of freeway interchanges (which constitute a majority of project costs).  Once the bridge is started to that design, it will be difficult to reduce its cost.  Similarly with the Rose Quarter project, where its 160 foot width dictates excavation costs and drives up the cost of proposed covers.  If ODOT starts these projects, the state will be stuck with bloated, over-sized projects it can’t change.  And that, as we have long said, is the point:  This is the classic Robert Moses strategy of “driving stakes and selling bonds” and putting the Legislature in a position where it has no ability to control what the highway building agency does.  That was tragic and stupid when Moses first did it in New York in the 1930s; it is even more tragic and stupid today, when we know with a certainty that highway widening doesn’t reduce congestion, that it destroys the fabric of urban neighborhoods, and worsens air pollution and climate destruction.

Eliminating the Sideboards

In legislative parlance, “sideboards” are conditions or limits included in legislation to prevent bad things from happening.  In 2013, the Oregon Legislature was considering spending $450 million for the I-5 bridge project, and after lengthy debate, it approved a series of such sideboards, trying to limit the cost of the project (more about that in a minute), and then also prohibiting the state treasurer from issuing any bonds for the project until after the Washington has contributed its share of the project’s costs, the federal contribution to the project was clearly committed, there had been prepared an independent financial plan for the project, and the state had conducted an “investment grade analysis of possible toll revenues.  All of those provisions are still codified in Oregon Law (Section Chapter 4 of Oregon Laws 2013).

And every one of those sideboards is eliminated, without acknowledgement.  Even the amendment’s “Staff Measure Summary” which is meant to disclose to Legislators the impact of the bill only cryptically and opaquely says:

“Repeals sections of House Bill 2800 (2013).”

Project Cost “Cap”–a legal limit from “Camelot”

We already know that a project cost cap is meaningless and unenforceable.  We already have such a cap!  It was enacted into law a decade ago and officially limited the total cost of the IBR to not more than $3.4 billion. 2013 Oregon Laws, Chapter 4, (Enrolled House Bill 2800) reads:

Conveniently, the “-2” amendments to HB 2098, without any fanfare, simply repeal this limit.  In its place, is an entirely new limit, which is worded identically–except of course that now the cost is more than twice as much.

As the Oregonian‘s “Politifact” reporters noted when they looked at the original so-called “cost cap” provisions for the Columbia River Crossing adopted by the Oregon and Washington Legislatures a decade ago, the caps are meaningless and unenforceable.

. . . if legislators greenlight the CRC, the state could ultimately owe more than $450 million on its share of the bridge. But setting a cap on the project or limiting Oregon’s share with legislative riders won’t stop that. And thanks to the agreement between Oregon and Washington to pay for the bridge jointly, if Oregon ever needs to pay more, Washington would need to join in.

PolitiFact Oregon doesn’t do prophecy. We can’t say whether the bridge will be over budget — as much as history might tempt us to offer a guess.

What we can say is that the Washington toll rule won’t matter. The Washington Legislature’s cap won’t matter.

The Legislature has no more ability to prescribe the cost of this project by edict, than it has to regulate temperature or rainfall.  Yet, the author’s of the “-2” amendments are simply performing a refrain from Camelot:

It’s true! It’s true! The crown has made it clear.
The climate must be perfect all the year.
A law was made a distant moon ago here:
July and August cannot be too hot.
And there’s a legal limit to the snow here
In Camelot.
The winter is forbidden till December
And exits March the second on the dot.
By order, summer lingers through September
In Camelot.

Crossing the Rubicon:  Raiding the General Fund for Road Projects

For the better part of a century, Oregon has prided itself on its “user-pays” transportation finance system.  Oregon was the first state to adopt a gasoline tax to pay for roads, and has observed a long tradition of having a “State Highway Fund” that is strictly segregated from other tax revenues and dedicated exclusively to paying for roads.  For the first time, the -2 amendments to HB 2098 would raid the General Fund to the tune of $1 billion to pay for a road project–which we’ve pointed out at City Observatory chiefly benefits residents of Washington State, as 80 percent of daily commuters and two-thirds of all bridge users live across the border in Washington.

Repealed Sideboards from HB 2800.

Here’s the language that would be repealed, featuring the provisions that weren’t disclosed in the text of the “-2” amendments or the Staff Measure Summary.

SECTION 3. (1) As used in this section, “Interstate 5 bridge replacement project” means the project described in section 2 of this 2013 Act.

(2) The total cost of the Interstate 5 bridge replacement project may not exceed $3.413 billion after the effective date of this 2013 Act.

(3) For the purpose of financing the Interstate 5 bridge replacement project, the State Treasurer may not have outstanding, at any one time, bonds in an amount exceeding $450 million of net proceeds, plus an amount determined by the State Treasurer to pay estimated bond related costs of issuance, for the purpose of funding Oregon’s share of the aggregated contribution to the project from Oregon and the State of Washington as described in the Final Environmental Impact Statement submitted to the United States Government for the project. It is the intent of the Legislative Assembly that moneys from the United States Government or toll revenues be used to directly fund the project, be used to repay other borrowings for the project or be pledged alone or with other security to lower the costs of other borrowings for the project

(4) The Department of Transportation may not request and the State Treasurer may not issue any bond to finance the Interstate 5 bridge replacement project unless:

(a) No later than September 30, 2013, the State of Washington has appropriated, authorized or committed sufficient funds to:

(A) Satisfy the United States Department of Transportation requirement for a proposed full funding grant agreement application; and

(B) Meet the requirements of the finance section included in the project’s Final Environmental Impact Statement published on September 11, 2011, and endorsed by the Federal Transit Administration and the Federal Highway Administration in the record of decision dated December 7, 2011;

(b) The United States Department of Transportation has submitted a full funding grant agreement application, in an amount of at least $850 million of Federal Transit Administration funds, for congressional review;

(c) The State Treasurer has participated in and approved the findings of an investment grade analysis of toll revenues associated with the project’s application for a loan from the Federal Highway Administration’s Transportation Infrastructure Finance and Innovation Act program, and provided for ongoing financial analysis of the project;

(d) The State Treasurer has reviewed and approved a comprehensive financing plan for the project, after making written findings that there are sources of funds committed by contract or law or otherwise obligated that are reasonably expected to be available and that will provide sufficient cash flows to pay the estimated costs of the initial phase of the project described in the full funding grant agreement without revenues from borrowings in addition to those described in subsection (3) of this section; and

(e) The United States Coast Guard has issued a general bridge permit for the main channel of the Columbia River for the project.


Proposed Amendments to HB 2098-2

If the author’s of the “-2” amendments were being candid, there’s what their amendments should actually say:

  • This act shall be known as the Blank Check, Pass-the-Buck, Cost-overrun, Send the Bill to our Kids Act of 2023.
  • The Legislature finds and declares that it doesn’t have the guts to pay for any of the billions of freeway widening projects ODOT is pursuing, and that it is unwilling to raise gas taxes to pay for them.
  • The Legislature intends that ODOT borrow billions of dollars based on vague “intentions” that the Legislature will miraculously find the will and the money to pay for these projects two or four or six years from now, and that ODOT should go ahead and borrow the money to get these projects started so that the Legislature will have no choice but to raise money someday in the future.
  • The Legislature intends that it will spend billions of dollars today to widen freeways that will increase car dependence and greenhouse gas emissions, and send the bill to future generations of Oregonians, who will also have to deal with the increasingly devastating effects of climate change.
  • The Legislature finds and declares It is powerless to do anything to limit ODOT cost overruns and that it will simply sign a blank check to ODOT for whatever amount of money it wants to spend on the Rose Quarter project.  that even though it approved the I-5 Rose Quarter project at a cost of $450 million in 2017, and that the cost has tripled to as much as $1.45 billion now, that it will fully fund whatever ODOT decides to spend on this project.
  • The Legislature finds and declares that the reasonable and prudent “sideboards” adopted by the Legislature a decade ago, when the state’s expected contribution to the IBR project was only $450 million, should be eliminated.


IBR’s plan to sabotage the moveable span option

IBR officials are planning to sabotage the analysis of a moveable span options as part of the Interstate Bridge Project

The Coast Guard has said a replacement for the existing I-5 bridges would need a 178 foot navigation clearance.  The highway departments want a 116′ clearance fixed span.

The Oregon and Washington DOTs say they are going to study a “moveable span” as a “design option” but are plainly aiming to produce a costly design that just grafts a lift-span on to their current bridge design.

A moveable span would enable a lower crossing, eliminate the need for lengthy viaducts, and reduce construction costs—but ODOT is refusing to design an option that takes advantage of these features.

And the DOTs have completely ignored an immersed tube tunnel option, implying that the Coast Guard directed them to study the moveable span (which it didn’t).

IBR staff have signaled they have no intention of seriously considering the fixed span, and are engaged in malicious compliance

Our story so far:  Oregon and Washington highway departments have proposed a new, fixed span highway bridge over the Columbia River between Portland and Vancouver as part of their massive $7.5 billion I-5 freeway widening project.  The bridge would have a 116 foot clearance over the river, but that’s not enough to satisfy the Coast Guard–which regulates bridge heights–and says a 178 foot navigation clearance is needed.

IBR simply chose to ignore the Coast Guard’s determination, and decided to move ahead with only the 116 foot clearance fixed span design.

The Coast Guard objected, saying this violated the terms of a 2014 memorandum of agreement between USDOT and the USCG.  (Ironically the MOA was created in the wake of the highway agency’s efforts to subvert and undercut Coast Guard review of the Columbia River Crossing, the previous iteration of this project).

Coast Guard officials wrote the FHWA and FTA to insist that they include an alternative in the project’s supplemental environmental impact statement that complies with the 178 foot height requirement.  The Coast Guard warned that the IBR should not proceed with an environmental impact statement that omitted a 178 foot clearance option:  “Including only one alternative in the Supplemental Environmental Impact Statement (SEIS) introduces risk that no permittable alternative will be evaluated in the SEIS.”

Importantly, USCG did not specify whether this should be a moveable span or a tunnel.

In response, IBR said it would look at a moveable span as a “design option” for the IBR.  That may sound like an “alternative,” but in fact when it comes to complying with environmental review requirements, it plainly is not.  A “design option” means that IBR will build exactly the same bridge it would build if it were a 116 foot fixed span, but they’d simply graft a moveable span (either a lift span or a bascule bridge) onto that very tall structure.  The IBR plan will likely look something very much like this:

“High Bascule”. — Bascule bridge grafted on to IBR’s 116 foot clearance fixed span

A camel is a horse designed by an devious highway engineer

Simply adding a moveable span to a high-level fixed span design eliminates the key design and cost advantage of the moveable span.  Because the moveable span allows tall vessels to pass through a very high (178′ in the case of lift span, or unlimited height, in the case of a bascule) there’s no reason why the remaining fixed portions of the bridge need to be nearly as high as the IBR’s current 116′ design.  The bridge can be built at a much lower level.  Conceptually, a bascule bridge would allow a much lower and shorter bridge structure, roughly like this:

“Low Bascule”. — Bascule bridge at profile of current I-5 bridges

That’s hugely important because the bridge can be much cheaper:  The current high IBR design requires half mile long elevated viaducts on both the North and South ends of the bridge in order to get the I-5 roadway from ground level in Vancouver up to the 150 height of the bridge roadway (the road level of the bridge is about 35′ to 40′ feet above the bottom of the double-deck bridge structure).  Lowering the height of the bridge makes it much cheaper to build; it also eliminates the need to rebuild intersections North and South of the river to reach up to the new higher bridge.  In addition, the lift span will have different and mostly fewer environmental impacts.  Because it will be less tall, it will be less steep, meaning trucks can get over it without slowing (which is a hazard to other traffic), plus all vehicles will burn less fuel (and create less pollution) on a shorter, less steep bridge.

It’s clear, however, that IBR officials have no intention of looking at using the lift span to reduce costs or minimize environmental impacts.  Greg Johnson, the IBR administrator, has fully indicated his intent to sabotage the moveable span design.  It is highly likely that they will specify a moveable span that is impractical and excessively expensive.  Greg Johnson telegraphed as much in his comments to the Columbian

The “movable span” option, which came at the request of the Coast Guard and federal government, will be explored in addition to the program’s original plan of a fixed-span bridge with 116 feet of vertical clearance.
The program will study both a lift span like the current Interstate 5 Bridge and a bascule bridge like the Burnside Bridge in Portland.
Program Administrator Greg Johnson said he believes a fixed-span bridge will ultimately end up spanning the Columbia.
He said a movable span would likely cost $500 million more than a fixed-span bridge and noted that the Columbia River Crossing project received a record of decision from the Federal Highway Administration and Federal Transportation Agency for a fixed-span bridge with the lower river clearance.
“I would be totally shocked if we can’t get to a fixed-span,” Johnson said.

(emphasis added)

The missing tunnel option

Press accounts, fueled by IBR statements, create the false impression that it was the Coast Guard that insisted on the inclusion of a moveable span option.  Oregon Public Broadcasting reported:

Planners in charge of the new, multibillion-dollar overhaul have recently been told by federal regulators they must include plans for “moveable span” on the bridge. Greg Johnson, who is leading the team of planners, said federal regulators made the order in late February.

The Vancouver Columbian reported:

The “movable span” option, which came at the request of the Coast Guard and federal government, will be explored in addition to the program’s original plan of a fixed-span bridge with 116 feet of vertical clearance.

In fact, the Coast Guard made no recommendation as to the kind of option that the project should study.  Either a moveable span or a tunnel under the river could satisfy the Coast Guard’s 178 foot height requirement.  Here’s what the Coast Guard letter, from Rear Admiral M. W. Bouboulis (not included in any press accounts) actually says:

I recommend that the Notice to Supplement clearly state the alternatives to be evaluated in the SEIS to include the no build alternative, the locally preferred alternative (116-foot vertical clearance), and an alternative that meets the 178-foot vertical clearance established in the PNCD. This will ensure that an alternative that meets the initially identified needs of navigation is evaluated in the SEIS and could be adopted by the Coast Guard.

(emphasis added)

This wasn’t the Coast Guard asking for something new in February, 2023–it was actually the Coast Guard repeating pretty much exactly what it asked for in its Preliminary Navigation Clearance Decision in June of 2022.  The Coast Guard made it clear that a 116 foot bridge interfered with river navigation:

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

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

In response to the Bouboulis letter,  IBR (through the FHWA and FTA) replied that it would study a moveable span.  This was IBR’s decision, not Coast Guard’s decision.

What ends up on the cutting room floor, here, is the possibility of an immersed tube tunnel, a technology that is widely used around the word, and which would provide unlimited vertical (and horizontal) navigation clearance.  The immersed tunnel would also remove the visual blight and noise pollution from downtown Vancouver and its rapidly redeveloping waterfront.  To hear the IBR tell it, the reason the immersed tube tunnel isn’t being considered is because the Coast Guard directed them to study a moveable span.  That’s simply untrue.  In its June 2022 preliminary determination of navigation clearance, the Coast Guard specifically identified the tunnel option as one way to comply with its navigation requirements.  It is IBR, not the Coast Guard, that is declining to take a hard look at the immersed tube tunnel.  This seems likely to be a violation of the National Environmental Policy Act, because the immersed tube tunnel would have very different (and much reduced) environmental impacts than the bridge options.

A “Design Option” not an “Alternative”

There’s one other seemingly minor wrinkle in the IBR’s latest gambit.  They’re talking about including the moveable span as a “design option.”  While that might sound like an “alternative” to the layman, it actually has important legal and practical implications.  “Design option” means they’ll look at the moveable span not as a full fledged separate alternative, but rather as just simply one feature grafted on to the existing IBR design.  As noted above, this means we’ll get something that looks almost exactly like the IBR 116′ clearance bridge with a bascule or lift-span “cut and pasted” on it.
The reason for calling it a “design option” rather than an alternative is to escape a requirement that the highway department’s fully evaluate the environmental and other impacts of the moveable span design.  A moveable span would be expected to have very different cost, traffic, and environmental impacts than IBR’s proposed high fixed span.  Under the National Environmental Policy Act (NEPA) the two state highway departments should fully flesh out this alternative, and evaluate those differing impacts.  Treating the moveable span as a design option is a transparent ruse to avoid NEPA scrutiny.  This could turn out to be a fatal legal error by the project:  NEPA is clear that sponsoring agencies have to give a “hard look” to reasonable alternatives, something this “design option” approach is designed to avoid.

Coast Guard Letter, February 8, 2023


The Color of Money: Bailing out highways with flexible federal funds

ODOT grabs a billion dollars that could be used for bikes, pedestrians and transit, and allocates it to pay highway bills.

Oregon highways are out of compliance with the Americans with Disabilities Act, and the cost of fixing them can–and should–be paid for out of the State Highway Fund. But instead, ODOT plans to take more than a billion dollars in future federal grant money over the next decade or more, and use it to pay off this highway liability.

What this strategy does is to take money that could be used for a wide variety of different transportation needs and use it only to bail out the State Highway Fund.

By taking this liability out of the State Highway Fund, ODOT can then claim it has plenty of funds for highway expansions. This shell game uses the ADA liability as cover to use flexible federal funds, in essence, to build more highway capacity.

Oregon’s constitution contains a retrograde provision that has been interpreted to require that moneys from gas taxes be used only to build roads, based on a fallacious argument that we have a “user pays” transportation system. The state highway departmetn, ODOT, routinely inovkes that constitutional argument when asked by the public to spend more on things like transit, pedestrian improvements or cycling. We can’t because that money can’t be used for anything other than building roads, they say. As a result, the truly innovative and “multi-modal” uses of funds in Oregon have been paid for disproportionately from federal funds, which are much more flexible. Not only does the Oregon constitutional limit not apply to federal funds, but federal law explicitly allows states to transfer funds among a variety of different categories. You’d think that flexible federal funds would be a key way to diversify our transportation portfolio. But ODOT has hit on a new gimmick to grab these federal funds and use them to bail out the struggling State Highway Fund.

It’s a complex story, and it involves changing the “color of money.”

For decades, the Americans with Disabilities Act has required private businesses and public agencies to provide accommodations for persons with disabilities. For nearly all of that time, the Oregon Department of Transportation has largely flouted that requirement, seldom providing sidewalks and ramps on state highways. As a result, disability advocates hauled them into court, and In 2020 reached a billion dollar settlement, in which ODOT agreed to make the necessary investments to bring highways into compliance with this long-established federal law.

Let’s just talk for a moment about what people in transportation finance call “the color of money.” You may think that all money is green, but in the transportation world, there are different kinds of money, with different strings attached. Funds raised by the state, for example, from the gasoline tax, are governed according to the dictates of state law, and importantly, constitutional restrictions.

ODOT loves to tell advocates it would gladly do more to help promote transit, but its hands are tied by the state constitution: It simply has no choice but to spend these dollars in the roadway.

There’s another color of money in the transportation world, though, “federal money.” Federal money is not governed by the state constitutional restrictions on state taxes. Federal money can be used for a wide variety of purposes, and the federal law gives the state wide flexibility to reallocate money among different categories. It doesn’t all have to be spent on highways.

Consequently, that’s why, when it comes to how we should use federal funds, there’s a lot more debate. In 2022, the Oregon Transportation Commission had a lengthy debate about how to allocate more than $400 million in federal funds coming to the state under the IIJA. Transportation advocates around the state came up with an alternate scenario to allocate about $130 million to local transportation projects. The OTC largely rejected this path.

Transportation Commission makes final decision on $412 million in federal funds

When it comes to getting a different allocation of these highly flexible federal funds, advocates are largely fighting for crumbs—and getting very little.

And ODOT is largely pre-empting any future option to use these funds differently by proposing to use them to repay a huge pile of debt. By pledging to use these federal grants to pay back debt, it will be impossible to use them for other purposes.

So let’s go back to ODOT’s ADA settlement: Under the terms of the deal, ODOT needs to bring its highways into compliance with the Americans With Disabilities Act by spending $1 billion. To be clear, this is a cost of the highway system—these ODOT roads don’t comply with ADA requirements. This spending is plainly a liability and a responsibility of the highway system. There’s no question that it can constitutionally be paid for with state gas tax revenues. But instead of paying for this cost with those monies, ODOT instead is planning to pay these costs by diverting flexible federal funding for the next decade, to the tune of a billion dollars, to pay these costs.  It will issue $600 million in “GARVEE” bonds (grant anticipation revenue bonds), and then use future federal funds to pay the debt service.

In essence, this reduces the amount of money potentially available for alternative transportation investments, unfettered by the state constitutional limits, by a billion dollars. It amounts to tying up a big chunk of potential revenue.

And what’s worse, ODOT is planning to bond against these federal revenues, spending the money now, and paying it back, with interest, over the next decade or more. So that means a substantial portion of those federal revenues are spent on interest payments, rather than on transportation projects.  At 5 percent interest, $600 million in bonds paid back over 15 years would mean that the state would pay about a quarter of a billion dollars in interest.  In the end, the State Highway Fund would be bailed out by more than $1 billion, and there would be that much less flexible federal funding for other projects around the state.

As we’ve said, when it comes to transportation finance, ODOT is the master of three-card monte: It’s ability to move dollars among categories–to change the color of money–systematically advantages its policy priorities (chiefly building more and wider highways) and leaves advocates of other policies fighting over crumbs.

By using flexible federal funds to pay the costs of the state highway system—plus a hefty pile of interest—ODOT is foreclosing the possibility that future decision-makers will have any ability to use these funds for alternatives in the future. It’s literally the priorities of the past dictating the choices of the future. If ODOT paid its ADA liability out of the State Highway Fund, as it legally can, and arguably should, it would have even less money to spend on road expansion projects.

Oregon’s transportation fiscal crisis

Oregon’s transportation finance in crisis:  Testimony to the Joint Ways and Means Committee. 

On March 16, City Observatory’s Joe Cortright testified to the Oregon Legislature’s budget-writing committee about the financial crisis confronting the state’s transportation agency.  The Oregon Department of Transportation’’s traditional sources of revenue are collapsing, and will certainly decline further in coming years.  The agency is failing to maintain existing roads, and has a huge backlog of maintenance, safety, seismic and other needs that continue to grow.  In the face of declining revenues and deferred maintenance, the agency is embarking on an unprecedented spending spree for expensive megaprojects.

ODOT has shown no ability to manage project costs, with every major project incurring massive cost overruns.  The agency is moving to start construction on these projects and commit the state to paying for them without a financial plan in place.  It claims it will use toll revenues to pay for megaprojects, but has no experience collecting or accurately estimating tolls.  It is planning to take on billions of dollars in debt backed by the promise of tolls. It has used short-term borrowing—the government version of a payday loan—to get projects started while avoiding the independent, investment grade analysis that will be required to get long-term financing.  Repaying the debt incurred for these projects will take legal precedence over all other state transportation priorities, leading to further cuts in maintenance and repair, and jeopardizing every other capital construction project in the state.

The Legislature needs to inject some prudence into transportation finance by requiring a “fix it first” policy, telling ODOT to live within its means, right-sizing bloated megaprojects, and securing independent expert financial advice


Housing affordability? Localism is the problem, not the solution

Do we need a federal commission on housing affordability?

Bruce Katz, author of “The New Localism” is calling for a national commission to come up with recommendations for dealing with the nation’s housing crisis.



A truly serious, national discussion of housing affordability, and what we could do to expand housing supply, is a good idea. To his credit, Katz does a thorough and workmanlike job of cataloging the symptoms of our housing market malaise:  a shortage of housing, rising prices and rents, increased un-affordability, rising homelessness.  All these points are inarguable.

But there’s a certain irony hearing this call from the unabashed advocates of localism.  Our historical excess of localism in land use planning is perhaps the principle underlying cause of our national housing crisis.  Left to their own devices due to deference to “local control”—municipalities and neighborhoods have wielded zoning, building codes, parking requirements and similar regulations to make it impossible or illegal to build housing to meet demand in wide swaths of the nation.

We’ve long been skeptical of the over-selling of localism.  Local organizing and solutions are great for some problems, and we’ve been champions of the importance of local distinctiveness as a virtue and asset of cities.  But localism, like any attribute, is never an unmitigated good.  And it’s abundantly clear that in the United States, its the stultifying embrace of localism that’s a major contributor to, if not the the primary cause of our housing affordability problem.

While the authors mention zoning in passing, they mostly downplay or overlook the role of local governments and localism in promoting the exclusion and supply restrictions that generate housing shortages around the nation.  As we’ve written at City Observatory, we’ve created a world where cities and neighborhoods use zoning powers to restrict how much housing can be built, to exclude those of limited means as a way of hoarding civic assets and opportunity.

When it comes to affordable housing, it should be abundantly clear, without convening a national commission, that a solution will require reigning in and proscribing local control of land use.  The crucial policy advances in housing affordability are premised on taking exclusionary powers away from local governments.  State governments in Oregon, Washington and California, for example, have recently enacted legislation reducing the power of cities to use zoning to exclude housing.  Oregon and Washington have legalized fourplexes in nearly all residential zones.  California has mandated “regional housing needs assessments” that assign minimum building targets to even the most exclusive suburbs.  The critical intervention in each of these cases is restricting the ambit of localism.  And even when locals have innovated, it has been the political cover and impetus provided by state reforms that has helped propel these efforts, as Michael Andersen has explained in the case of Portland’s Residential Infill Strategy, which was politically stymied until the passage of state legislation.  It is much easier for local governments to innovate when the state government provides a legal prod and political cover.

Why localism is inimical to housing affordability

The reason we can’t rely on localism is that zoning creates a literal “beggar-thy-neighbor” situation for local governments.  No one local government wants to allow denser development, for fear that other jurisdictions (or neighborhoods) won’t be as permissive, and that all of the burden of accommodating additional growth will fall on the few that allow it.  It’s exactly this dynamic that requires intervention from a higher level of government, where the perspective and the politics are broader.

We identified this issue when we reviewed “The New Localism” when it was published five years ago.  We wrote:

It’s also worth noting that a key aspect of localism that has been effectively exempt from federal control—local control of zoning and land use—has worsened the economic segregation of our nation’s metropolitan areas.  In sprawling metros, separate suburban cities have used the power of land use regulation to exclude apartments, directly contributing to the problem of concentrated poverty that intensifies and perpetuates the worst aspects of income inequality. Cities have been implicated in the nation’s housing affordability and segregation problems, but that’s hardly mentioned in Katz & Nowak. The word “segregation” appears only once in the book (page 40). The word “zoning” occurs on 8 pages. Housing affordability is mentioned just once (page 28).

The root of the problem here is too much localism. The most localized governments have the strongest incentives to exclude neighborhood groups within cities lobby against density. Suburbs within metropolitan areas do the same. Only larger units of government have the incentives and ability to challenge this kind of parochialism.

If anything, it’s been the state and federal government unwillingness to do anything to rein in unfettered localism that is the principal cause of the housing crisis.  Local control isn’t sacrosanct in every policy area.  For example, the federal government is more than willing to strictly limit local discretion:  Federal Communication Commission regulations pre-empt local laws that regulate the siting and appearance of cell-phone and satellite television antenna.  The FCC struck down a Philadelphia ordinance requiring satellite TV companies to remove un-used dish antenna, to avoid driving up the cost of watching TV.  But when it comes to housing, the federal government has done nothing to proscribe local practices that drive up housing costs.  Arguably housing affordability is more important than the cost of TV programming.

How a national commission might help

A big challenge in housing policy is the continued prevalence of false explanations for a lack of affordability.  There’s still a widespread belief that building more market rate housing somehow makes housing more expensive (it doesn’t).  And others would like to blame private property generally, or developer greed in particular, for rising rents and home prices.  Very much in this vein, Katz et al offer an extended and largely gratuitous swipe at institutional investors as the source of the current affordability crisis

 But the housing crisis is not just worse than in the late 1980s; it has structurally changed in important ways due to new technologies, new investors and new corporate landlords. The mismatch between supply and demand has created a new way for private capital to extract higher rents and higher profits with minimal risk or action. A wave of parasitic capital is sweeping the country as investors, large and small, buy single family homes at scale, boosting rents, displacing residents and altering the fabric of entire neighborhoods. A new class of slumlords now occupies the urban landscape.

This scapegoating has been thoroughly debunked by The Atlantic’s Jerusalem Demsas.  A national commission ought to be a vehicle for debunking these misleading myths, but the danger is that NIMBY and localist interests would perpetuate them instead.

That’s not to say that there aren’t some good ideas here, that a national commission my develop.  To their credit, Katz and his co-authors flag our excessive reliance on homeownership as a wealth building scheme, and argue that we need to find ways to build wealth for the 40 percent or so of the population who rent, rather than own their homes.

We can’t help but think of this Internet meme when we hear of the advocates of new localism fretting about housing affordability.




Why does a $500 million bridge replacement cost $7.5 billion?

The “bridge replacement” part of the Interstate Bridge Replacement only costs $500 million, according to new project documents

So why is the overall project budget $7.5 billion?

Short answer:  This is really a massive freeway-widening project, spanning five miles and seven intersections, not a “bridge replacement”

Longer (and taller) answer:  The plan to build half-mile long elevated viaducts on both sides of the river, and the need to have interchanges raised high into the air make the project vastly more complex and expensive.

In November of 2022, the Interstate Bridge Replacement team (a collaboration of the Oregon and Washington highway departments), released a document called the “River Crossing Option Comparison” sketching out the advantages and disadvantages of several different alternatives crossing the Columbia River.  The alternatives examined included tunnels under the river, and a series of bridge designs—two different moveable span bridges, and two fixed spans, a high level and and mid-level (116 foot clearance crossing.)

Here’s the bottom line of the report—buried away on page 50 of a 68-page PDF file—the IBR’s preferred design, a mid-level fixed span, is supposed to cost $500 million.

That’s a fascinating number, because in December, the IBR team released another document, a long-awaited financial plan describing the total cost of the project.  It told a joint committee of legislators from Oregon and Washington that the project’s budget had increased from a maximum of $4.8 billion (estimated in 2020) to a new “maximum” of $7.5 billion (although the two agencies still maintain that they’re trying to bring it in for a mere $6 billion).

All this raises a fascinating question:  Why does this project cost $7.5 billion when the price tag for actually replacing the bridge is only $500 million?

Most of the project cost is highway widening, not the bridge

More recently, the project has offered a few additional details, summarized in the graphic below.  As we’ve noted at City Observatory, the name “bridge replacement project” is clearly misleading.  The IBR is really a five-mile long freeway widening project that requires rebuilding seven closely spaced interchanges.  According to the IBR, the cost of the four major segments of the project is about 1 to $1.5 billion each for the Oregon and Washington interchanges and highway widenings (segments A and D), about 1.3 to $2 billion for the transit portion of the project, and about 1.6 to 2.5 billion for the bridge and approaches (segment C).

At between $2 and $3 billion, it’s clear that the interchange rebuilding and roadway widening is more expensive than the river crossing. And an earlier expert review of the Columbia River Crossing version of this same project, commissioned by the two state highway departments and the behest of the then Governors, recommended strongly that the project eliminate one or more interchanges, to save cost, improve safety and performance, and enable a better bridge design.  By rebuilding these too closely spaced interchanges, the panel warned, the DOTs were repeating–at enormous cost–a decades old design error..

A high bridge requires long, steep approaches

The IBR budget breakdown unhelpfully combines the cost of the “bridge” and its “approaches.”  As this illustration shows, what IBR calls the combined “bridge and approaches”—shown in red—extend for about a half a mile on either side of the river:  to Evergreen Boulevard (more than half a mile north of the riverbank on the Vancouver side of the river, and almost all the way across Hayden Island (a bit less than half a mile) on the Oregon side of the river.

We know from the “River Crossing Options” report that the actual bridge itself—that is the portion between the north and south river banks—would cost approximately $500 million to build.  What the IBR doesn’t talk about is the “approaches” which are actually elevated viaducts that have to reach 100 feet or more into the air in order to connect to the high level crossing.  These are vastly higher (and wider) than the existing bridge approaches, which are fully at grade on the Oregon and Washington sides of the river with the current low-level lift bridge.

The mile of elevated freeway that IBR plans to build to connect its high level bridge to the existing freeway at either end of the red-shaded area is what is driving the cost of this segment of the project. If, as IBR says, the bridge structure costs $500 million, this means that most of the cost of this part of the project—as much as $1.5 to $2.0 billion—are the lengthy, elevated approaches.  What IBR has failed to do is consider how much less expensive the approaches could be if it chose one of the alternate bridge designs (either a moveable span or immersed tube tunnel).  Either of these designs would allow approaches to be built mostly or entirely at grade, eliminating the expense and environmental impact of elevated viaducts.  The lower level would also greatly simplify and reduce the expense of the SR 14 interchange, which currently involves convoluted spiral ramps with grades of 6 or 7 percent.

It’s also worth noting that the IBR project hasn’t itemized the cost of demolishing the existing I-5 bridges.  Because these structures cross over sensitive river habitat, and because the bridges themselves have toxic lead paint and other environmental contaminants, the cost of bridge removal could be enormous.

Engineers gone wild, said then-Congressman DeFazio

Clearly, what’s going on here is that highway engineers at ODOT and WSDOT see this project as their opportunity to build the project of their dreams.  Not just a giant bridge, but massive new interchanges, wider freeway lanes, and if people insist, a short light-rail extension.  The bigger, the better.  The grandiose and costly bias of the state highway departments has been long known to key local leaders.  Former Congressman Peter DeFazio (until last year, Chair of the House Infrastructure Committee), in a characteristically frank admission said:

“I kept on telling the project to keep the costs down, don’t build a gold-plated project,” a clearly frustrated DeFazio said. “How can you have a $4 billion project? They let the engineers loose, told them to solve all the region’s infrastructure problems in one fell swoop… They need to get it all straight and come up with a viable project, a viable financing plan that can withstand a vigorous review.”
(Manning, Jeff. “Columbia River Crossing could be a casualty of the federal budget crunch”, The Oregonian, August 14, 2011).

Later, DeFazio told Oregon Public Broadcasting:

“I said, how can it cost three or four billion bucks to go across the Columbia River?  . . . The Columbia River Crossing problem was thrown out to engineers, it wasn’t overseen: they said solve all the problems in this twelve-mile corridor and they did it in a big engineering way, and not in an appropriate way.”
“Think Out Loud,” Oregon Public Broadcasting, August 18, 2011.

At long last, there are some signs that the problems with their super-sized design are dawning on IBR staff.  Project director Greg Johnson recently let slip that IBR is now looking at a “single-level” design—something they ruled out more than a decade ago.  This may mean the states are actually going to consider a lower level crossing. IBR has also conducted a “Cost Estimate Validation Process” or CEVP—which they’ve declined to reveal to the public.  This engineering review likely highlights the cost and risk of the project’s current bloated design.

There’s no reason a $500 million bridge replacement should cost $7.5 billion.  If this project were right-sized—simply replacing the bridge structure, and maintaining a low-level crossing that could connect to existing approaches, and eliminate the need to rebuild seven different intersections and widen miles of freeway, the cost could be brought down substantially.


More induced travel denial

Highway advocates deny or minimize the science of induced travel

Induced travel is a well established scientific fact:  any increase in roadway capacity in a metropolitan area is likely to produce a proportional increase in vehicle miles traveled

Highway advocates like to pretend that more capacity improves mobility, but at best this is a short lived illusion.  More mobility generates more travel, sprawl and costs

In theory, highway planners could accurately model induced travel; but the fact is they ignore, deny or systematically under-estimate induced travel effects.  Models are wielded as proprietary and technocratic weapons to sell highway expansions.

Induced travel, or as its otherwise known, the fundamental law of road congestion, is a particularly inconvenient fact for highway boosters.  A growing body of evidence confirms what has been observed for decades:  adding more un-priced roadway capacity in urban settings simply generates more and longer trips, and does nothing to eliminate congestion.  Day by day, the popular media are starting to communicate this seemingly counter-intuitive fact to the public.

Highway boosters either simply ignore the entire concept of induced demand, or pretend that it doesn’t exist.  A new chapter in this effort to avoid this inconvenient fact comes from  Arizona State University Professor Steven Polzin, writing at Planetizen.

Polzin isn’t a complete induced travel denier; he’s more an induced travel apologist and minimizer.  It may be a real thing—or might have been in the past, he assures us—but it’s not a big deal and is now adequately being thought about by state highway departments and can safely be ignored.

Induced travel is scientific fact

Polzin derides induced demand as “a popular concept among urbanists” and argues that it’s given too much publicity in the media, by the likes of the New York Times.

But induced travel is not simply a “popular concept,” it’s a well researched scientific fact.  The best available evidence from a series of studies, shows that there’s essentially a unit elasticity of travel with respect to the provision of additional highway capacity.  A whole series of studies supports this estimate, some of which are shown here.

Duranton, Gilles, and Matthew A. Turner. 2011. “The Fundamental Law of Road Congestion: Evidence from US Cities.” American Economic Review, 101 (6): 2616-52.

Hymel, Kent, 2019. “If you build it, they will drive: Measuring induced demand for vehicle travel in urban areas,” Transport Policy, Elsevier, vol. 76(C), pages 57-66.

Hsu, Wen-Tai & Zhang, Hongliang, 2014. “The fundamental law of highway congestion revisited: Evidence from national expressways in Japan,” Journal of Urban Economics, Elsevier, vol. 81(C), pages 65-76.

Miquel-Àngel Garcia-López, Ilias Pasidis, Elisabet Viladecans-Marsal, Congestion in highways when tolls and railroads matter: evidence from European cities, Journal of Economic Geography, Volume 22, Issue 5, September 2022, Pages 931–960,

It’s odd that Polzin, a university professor, provides only a list of popular media articles (which he disbelieves) and provides not  not a single footnote or reference to a peer-reviewed academic study to dispute the notion of induced travel.

Purported mobility gains are an illusion

Sure there may be some induced travel, Polzin argues, but don’t overlook the benefits of greater mobility.  This misses the point that mobility (i.e. driving more and further) is evidence of induced travel, not a refutation.  And mobility tends to be short-lived and costly. Our friend and colleague, Todd Litman of the Victoria Transportation Policy Institute has a compelling rebuttal to Polzin on this point at Planetizen.

Polzin pleads with us to recognize the “mobility” benefits that come from increased highway capacity.  He misses two things here:  first, the key insight from the research on induced travel is that the mobility gains are at best a temporary illusion.  Somewhat faster moving traffic prompts more trip taking and longer trips, which quickly erodes any mobility gains.  And greater mobility simply prompts greater decentralization and sprawl, so even in places where traffic moves faster, everyone has to travel farther—and that comes at a real social, environmental and economic cost.

In effect, Polzin says that traffic growth is just due to population growth, and is inevitable, and good.  But he completely ignores the clear cross-sectional evidence from US metropolitan areas:  Metro areas with fewer lane miles of roads have shorter travel distances.  And far from being economically constrained, metro areas with less roadway capacity sprawl less, reducing public sector infrastructure costs, and creating a “green dividend” for their residents, who don’t have to drive as far.  The average resident of Portland drives about half as far every day as the average resident of Houston.  And, as we’ve documented at City Observatory, people who live in cities where people drive less are happier with their transportation systems.

Predict and provide = Prevaricate and pave

For decades, state highway departments have used their control over opaque and technocratic travel demand models to build a case for ever more highway capacity. Their “predict and provide” approach is the bureaucratic manifestation of induced travel.  Polzin never quite acknowledges this history, but instead suggests that we should simply trust highway planners to build new  traffic models that account for induced demand.

Much of the reporting on induced demand gives the impression that the transportation planning community is oblivious to this phenomenon or is comprised of road-building zealots. Newer activity-based transportation models are designed such that activity generation (trip generation) is sensitive to travel times. Consequently, improvements in travel speed will contribute to predictions of increased trip-making and travel distance. Even without the newest models, scenario testing and careful analysis of changes in demographics, mode choices, and flow volumes and patterns can give insight into the nature of demand on new facilities.

In theory, state highway departments could build models that accurately reflect induced travel.  But the simple fact is that they don’t.  To the contrary, a recent published article on the practice of state highway travel forecasting looked at this specific issue, and found just the opposite:  Induced travel effects are routinely ignored by state highway departments, and induced travel is generally introduced into highway environmental assessments only at the behest of public critics.  Those few state highway efforts that do consider induced demand, wildly understate likely effects.  Highway departments continue to produce models that exaggerate future travel demand growth even in the face of demonstrable capacity constraints, as Norm Marshall puts it “forecasting the impossible.”  And some, like Oregon, simply deny that induced travel is real, and prohibit their modelers from using scientifically based tools that estimate induced travel.

In a similar vein, Polzin solemnly intones that future transportation projects ought to be based on sound projections of future.

Roadway investments in new capacity should be based on up-to-date and sound demand estimates. They can’t just fulfill out-of-date plans or serve as ill-advised opportunities to create jobs or garner state and federal resources for local use. They should not use twentieth-century per capita travel growth rates or chamber of commerce-inspired population growth assumption

But there’s precious little evidence that state highway departments do anything of the sort.  They routinely plan for highway capacity expansions on roads where traffic is declining.  The Oregon Department of Transportation proposes expanding capacity at the Rose Quarter at a cost of $1.45 billion, even though traffic levels on that particular roadway have been declining for 25 years.  Cincinnati’s Brent Spence Bridge is slated for a massive $3.5 billion expansion, even though its traffic has been flat for more than a decade.  And other state highway departments routinely produce “hockey stick” traffic forecasts that are simply never realized.

The underlying problem that highway advocates fail to acknowledge is that road users will typically only use added highway capacity only if they don’t have to pay for it.    In the very limited instances in which drivers are asked to pay for even a fraction of the cost of providing increased road capacity, demand disappears.  The evidence from tolled roadways like Louisville’s I-65 bridge is that most people are unwilling to pay even a small fraction of the cost of freeway widening projects that would save them travel time.  That shows that the only reason people drive on expanded roadways is that someone else pays for them.  That’s pretty much the definition of induced travel.

Polzin’s piece is subtitled: “Induced demand is a popular concept among urbanists, but does its pervasiveness obscure the true costs of mobility?” This is a classic example of Betteridge’s law of headlines, the adage that states: “Any headline that ends in a question mark can be answered by the word no.”  Induces travel is real, and at this point, only highway advocates, and their apologists, like Polzin, are in any doubt about what this means.

The Case Against the Interstate Bridge Replacement

Here are our 16 top reasons Oregon and Washington need to re-think the proposed Interstate Bridge Replacement Project.  The bloated size of the project and its $7.5 billion cost, and the availability of better alternatives, like a bascule bridge, call for rethinking this project, now.

  1. It’s not a bridge, it’s a freeway widening and interchange rebuilding project.  Contrary to the project’s name, it’s not merely a “bridge replacement.”  The bulk of the cost is widening 5 miles of freeway and rebuilding 7 major interchanges.  IBR’s own “River Crossing Options” study says the proposed IBR bridge only costs $500 million.

  2. The budget is out of control: $7.5 billion.  In 2020, the IBR was projected to cost a maximum of $4.8 billion. The price tag for the project jumped 54 percent in December, 2022.  The total cost is now estimated at $7.5 billion, but ODOT has a long history of having its major projects end up costing twice as much as budgeted.  Contrary to claims made by the IBR, recent construction cost inflation accounts for only $300 million of the more than $2.5 billion cost increase since 2020.
  3. A tunnel or bascule bridge would be vastly cheaper, avoiding the need to widen the freeway and rebuild intersections. IBR’s design will allow only 116 feet of navigation clearance, and IBR has refused to seriously consider either an immersed tube tunnel or lower level bascule bridge, both of which would eliminate most or all bridge lifts, and eliminate the need to rebuild intersections on I-5. The I-95 Woodrow Wilson Bridge in Washington DC is recently constructed bascule, and carries twice as much traffic as the I-5 bridges.
  4. Its really a 12-lane wide freeway.  The IBR likes to describe the project as just adding “auxiliary lanes” to I-5, but a close look at its actual plans shows it will build a 164-foot wide highway bridge–enough for as many as 12 lanes.  Once built, ODOT and WSDOT can easily re-stripe this very wide structure as a 12-lane roadway.
  5. ODOT is ignoring the Coast Guard’s direction.  The Coast Guard, which has authority to regulate bridge height–says that IBR’s bridge needs to have a 178-foot clearance over the Columbia River.  With the CRC, the failure to follow Coast Guard guidance resulted in a costly year-long delay as the project was redesigned.
  6. ODOT’s high, fixed span crossing creates dangerous and expensive elevated roadways and steep on-and-off ramps. The IBR would have a main span with a grade of 4 percent, higher than almost every interstate bridge in the US, and ramps would have 6-7 percent grades.  The steep grades will slow trucks and create dangerous conditions in winter weather.
  7. Planned tolls of up to $5.69 each way will permanently reduce traffic to less than 90,000 vehicles per day (from 135K today).  IBR has refused to release its proposed toll rates.  Documents obtained by public records request show IBR is looking at tolls as high as $5.69 each way at the peak hour.  According to the Investment Grade Analysis performed for the Columbia River Crossing in 2013, even $3 tolls would permanently reduce traffic on I-5 to less than 90,000 vehicles per day–dramatically below its current traffic level of 135,000.
  8. High IBR tolls would produce gridlock on I-205.  The IBR project plans to toll the new I-5 bridge, but not the parallel I-205 Glen Jackson Bridge.  The Investment Grade Analysis prepared for the Columbia River Crossing in 2013 concluded that this would divert tens of thousands of vehicles to I-205, producing gridlock on the I-205 bridge.
  9. ODOT has ignored its own expert panel which recommended breaking the project into three independent phases.  In 2010, Governors Kulongoski and Gregoire appointed a panel of national bridge and highway experts to review the Columbia River Crossing.  They recommended that the project be broken into three separate, independent phases, to minimize financial risk.  They also recommended eliminating one or more interchanges to improve traffic flow, reduce cost and simplify bridge design.
  10. IBR traffic projections have been proven dramatically wrong:  They grossly over-estimate future traffic levels on the existing bridge, which is capacity constrained.  The CRC FEIS predicted I-5 traffic growth of 1.3 percent per year; actual growth was 0.3 percent per year through 2019. They also fail to accurately predict future traffic levels.  The independent Investment Grade Analysis in 2013 showed that the IBR forecasts overstated future I-5 traffic levels by about 80,000 vehicles per day, leading to the design of a grossly over-sized project.
  11. IBR staff altered the output of Metro’s traffic models, and increased predicted peak hour traffic on the existing I-5 bridge above that predicted by the Metro model, and in excess of the actual physical capacity of the bridge.  This so-called “post-processing“–which isn’t documented according to ODOT’s own analysis procedures–inflated no-build traffic volume artificially worsened predicted future congestion, and created a false baseline for assessing the need for and impacts of the proposed bridge widening.
  12. The IBR project mostly benefits Washington residents.  According to Census data produced by IBR, approximately 80 percent of daily commuters across the Columbia River are Washington residents.  According to a license plate survey conducted for the two states, twice as many Washington cars use the I-5 bridge as do Oregon cars.  Yet Oregon will have to pay just as much as Washington state, plus pay for the entire cost of the $1.45 billion Rose Quarter project (which is heavily used by Washington commuters).
  13. IBR has falsely portrayed the income, race and ethnicity of typical bridge users.  The median peak hour drive-alone commuter from Clark County Washington to jobs in Oregon has a household income of $106,000.  About 86 percent of these commuters are non-Hispanic whites.  These commuters are whiter and have higher incomes that the rest of the Portland metropolitan area, and are half as likely to be people of color as the region’s population.
  14. IBR has no meaningful cost controls.  ODOT & WSDOT claimed in legislative testimony in December 2022 that future cost escalation would be managed using a “Cost Estimate Validation Process (CEVP)” that they say that had already completed.  A public records request showed that no documentation existed for the CEVP.
  15. IBR has put off doing an “Investment Grade Analysis” which will be required for federal TIFIA loans andtoll bonds.  The investment grade analysis done for the CRC showed that traffic would be dramatically lower, and tolls would have to be dramatically higher than the figures ODOT and WSDOT used to sell the CRC.
  16. A massive IBR will be a visual blight on Vancouver’s revitalized waterfront, and a massive viaduct across Hayden Island.  The elevated approaches required by IBR’s 116 foot high fixed span are the equivalent of three Marquam Bridges side by side as they cross the waterfront in downtown Vancouver. Seattle just spent several billion dollars to remove a similar waterfront eyesore.

What we should do instead.

  1.  Refocus the project on replacing the bridge, not widening the freeway
  2. Re-appraise low cost options to a high, fixed span  (a bascule bridge or immersed tube tunnel) that could use existing approaches and eliminate the expense of rebuilding interchanges and creating massive elevated viaducts.
  3. Right-size the bridge’s capacity to reflect the traffic levels that can be expected with tolling

Note:  This commentary has been updated to include additional images and links.

What new computer renderings really show about the IBR

The Interstate Bridge Project has released—after years of delay—computer graphic renderings showing possible designs for a new I-5 bridge between Vancouver and Portland.  But what they show is a project in real trouble.  And they also conceal significant flaws, including a likely violation of the National Environmental Policy Act.  Here’s what they really show:

  • IBR is on the verge of junking the “double-decker” design its pursued for years.
  • It is reviving a single decker design that will be 100 feet wider than the “locally preferred alternative” it got approved  a year ago.
  • The single deck design is an admission that critics were right about the IBR design having excessively steep grades.
  • The single deck design has significant environmental impacts that haven’t been addressed in the current review process; The two states ruled out a single deck design 15 years ago because it had greater impacts on the river and adjacent property.
  • IBR’s renderings are carefully edited to conceal the true scale of the bridge, and hide impacts on downtown Vancouver and Hayden Island.
  • IBR has blocked public access to the 3D models used to produce these renderings, and refused to produce the “CEVP” document that addressed the problems with the excessive grades due to the double-deck design.
  • The fact the IBR is totally changing the bridge design shows there’s no obstacle to making major changes to this project at this point.

The actual appearance of the proposed $7.5 billion Interstate Bridge Replacement project has been a carefully guarded secret. IBR has finally produced renderings of what the bridge might look like, and they conceal more than they reveal.  All of the renderings are shown from a distant vantage point—probably a mile or so away from the actual bridge—making it look tiny.  And the renderings don’t show how much larger the proposed new bridges are than the existing bridge.  The renderings are also carefully crafted so you can’t tell how tall the bridge will be in relation to the buildings in downtown Vancouver (it will be taller than most of them), nor does it show a lengthy elevated viaduct that will tower over most of Hayden Island. What the renderings do show is that IBR is now almost fully committed to a single-level bridge design.  Whereas prior renderings never showed a single-level bridge, five of the six designs presented on the IBR website are single-level bridges, and only one is the double-decker design the IBR has been pushing for more than a decade.


And none of these renderings show the actual width of either the single- or double-deck versions.  Other ODOT documents—not included with the renderings—show the singe-deck designs will be more than 270 feet wide—nearly as wide as a football field is long.  We know that IBR has developed a sophisticated 3D model—a “digital twin” of the project.  IBR consultants bragged about the state-of-the-art detail of the model in a presentation to a professional group in Seattle earlier this year, but said they couldn’t share the illustrations, because:

 “There is a very detailed 3D model. I was going to try and show it . . . It’s very, very, it’s kept under wraps quite a bit, and I think it’s because of their experience with the first round, trying to tread carefully.” 

We filed a public records request with WSDOT and in response, they claimed that the only “model” was a rendering released in January 20, 2022, and that they are ignorant of this work—even though contractor WSP and software provider Bentley prominently tout this “digital twin” work for IBR on their websites.  And obviously, IBR had this 3D model in place to produce the renderings it released on May 25.  It’s plain that ODOT and WSDOT don’t want people to see what they are planning to build.

Junking the double decker design

What these new renderings signify is  that the Oregon and Washington DOTs are junking the double-decker design they’ve been pushing for the Interstate Bridge Replacement for more than a decade, and instead are planning a much wider single-level bridge.

Since 2008, ODOT and WSDOT have only been looking at a pair of double-decker bridges to replace the existing I-5 crossing.  Each of these bridges would be about 90 feet wide, with room for six highway lanes on the top deck of each bridge, and provision for light rail, bikes and pedestrians on lower levels.

As part of the project’s draft environmental impact statement, the two highway departments considered, and rejected, a single-level design, because it would have had greater impacts on the river (more piers in the river, more cover over the river, and greater visual impacts).  Only the double-decker design was advanced to the Final Environmental Impact Statement, adopted in 2011.

Now, suddenly, IBR is pushing a slew of single-level designs.  We say “suddenly” because IBR made no mention of a single level option until February of 2023—almost a year after it asked all of its local partners to sign off on a “Modified Locally Preferred Alternative” that consisted solely of the double decker bridge.

As we wrote in February, this sudden change of heart vindicates one of the key criticisms of the IBR design—that its high fixed span necessitates very steep grades, both for the mainline highway section, and especially for the bridge’s off-ramps.  The grade for the mainline would be as much as 3.99 percent—well in excess of the DOT’s own guidelines for freeway grades, and among the steepest interstate bridges in the nation.  The grades on on- and off-ramps would be even higher, as much as 6-7 percent.  Notably, each of the single-level designs allow the roadway to be set much closer to the river, enabling shorter structures and shallower grades.

The key factors increasing the grades of the highway section of the project is the combination of its high river clearance (the IBR design calls for a 116′ navigation clearance underneath the bridge), and the proposed double-decker design (with the top highway deck being elevated about 35 feet above the lower transit/active transportation deck).

A Bridge Too Steep and the Secret CEVP Report

What prompted the sudden inclusion of the single deck design?  As we wrote in February, the key intervening event was a project evaluation called the “Cost Estimate Validation Process” or CEVP, which is designed to identify and assess risks to project costs and completion. It seems highly likely that this review identified the steep grades on the bridge and approaches as a cost, schedule and approval risk.  That’s almost undoubtedly what prompted the sudden interest in the single-deck design, after years of exclusion.  We say “almost undoubtedly” because IBR has refused to release the CEVP analysis.  When we first asked, in December 2022 for the CEVP, WSDOT claimed that “no such document exists.”  Subsequently it has released only a cursory and uninformative one-page summary of the CEVP, even though it has subsequently reported that the CEVP consisted of creating a “risk register” that identified more than 200 risks.

A QRA [quantitative risk assessment] was performed for the IBR program based on CEVP methodology. The objectives of the QRA were to provide independent review of program cost and schedule estimates and to quantify the uncertainty and risk associated with those estimates. A risk assessment workshop was held October  10 to 14, 2022, and was attended by IBR program team members, partners, and subject matter experts (SMEs) from WSDOT, ODOT, local agency partners, and industry. A risk register was developed for the program; the register identified specific risks (threats and opportunities) to the program cost and schedule. A total of 201 risks were identified, of which 121 were determined to be significant. Risks were characterized and quantified by consensus (i.e., collective professional judgment) of the SMEs assembled for the workshop.
Financial Plan, March 2023, page 4-2 to 4-3,

It’s not unusual for agency’s to make some tweaks to a project once it has gone through the environmental review process, but the usual claim that the DOTs make is that these tweaks are okay as long as they don’t increase the project’s “footprint.”  That’s a legally dubious assertion, but, in this case, shifting to a single level bridge actually increases the project’s literal footprint by over 50 percent:  According to ODOT’s own estimates, the double-decker bridge design would be about 173 feet wide, while the single-level bridge would be about 272 feet wide.

For four years, the Oregon and Washington highway departments have been pushing a revival of the failed multi-billion dollar I-5 Columbia River Crossing.  Their key sales pitch is that the size and design of the project can’t vary in any meaningful way from the project’s decade-old record of decision, for fear of delaying construction or losing federal funding.

Far from being a minor change, this represents the revival of an alternative design that was ruled out more than a decade ago.  It also shows that the IBR project is effectively conceding that its critics, who’ve alleged that its double-decker “modified locally preferred alternative” has a serious safety and cost problem due to its excessive grade and elevated off-ramps.  Finally, and perhaps most importantly, it shows that warnings that major changes couldn’t be made to the project out of a fear of delays were simply baseless manipulation—a familiar highway department tactic.

Resurrecting a discarded 15-year old alternative

When he first revealed that IBR was considering a single level design in February of 2023, IBR administrator Greg Johnson made a point of claiming that the single-level design isn’t “new.”  It isn’t, it’s quite old, and to have listened to the Oregon and Washington transportation departments, it’s so old that it’s been dead and buried for almost 15 years.

The last official ODOT and WSDOT document featuring a single level crossing design was nearly 15 years ago:  the 2008 Draft Environmental Impact Statement.  It proposed two possible designs for replacement bridges for the current I-5, a pair of side-by-side double-decker bridges (which were chosen as the preferred design), and a trio of single-level bridges, as shown here.

The project’s Final Environmental Impact Statement, issued in 2011, abandoned the single-level option, and chose to proceed only with a pair of double-decker bridges (with transit and bike-ped access placed on the lower level of each structure).  Also:  Notice that the Final Environmental Impacts Statement omitted the notations showing the actual width of the proposed structures—part of an effort to conceal the fact that the bridges would be build wide enough to accommodate 12 full lanes of traffic.


The Final Environmental Impact Statement made a strong series of findings rejecting the single-level three-bridge design, because it would have more in-river impacts, a larger surface area with more runoff, and would have larger visual impact.  [CRC FEIS, Page 2-83]

The single-level design is considerably wider than the two-bridge double-decker design, as shown in this 2007 rendering prepared by IBR.

it’s back. An even wider bridge across the Columbia.


It’s not too late to make fundamental changes to the plan

Greg Johnson has cried “wolf” about making serious changes to the IBR project, even as its budget has ballooned by 54 percent in a little over two years, to a total price tag of as much as $7.5 billion.  But this latest—and very late—change to the project design is an indication that it’s not too late to fix the fatal flaws in this project.  Right now the fatal flaws revolve around its bloated design and price.  The reason the project is so expensive has little to do with the bridge structure itself, but rather the extravagant plans of ODOT and WSDOT to widen I-5 for miles on either side of the Columbia River, and rebuild, at much greater expense than the bridge itself, seven different freeway interchanges.  If this were simply a bridge replacement—as its name claims—the project would be vastly simpler, less expensive, and likely not controversial.

For the past four years, IBR has maintained it’s far too late to make any design changes to the IBR project.  Ever since he took the job of IBR administrator Greg Johnson has been warning elected officials not to make any significant changes to the project design included in the 2011 FEIS for fear of delaying it further.  An immersed tunnel?  More consideration for climate?  A lift-span?  A narrower freeway?  None of these can even be studied, or advanced into the environmental review process, for fear that it will cause some additional delay.

But now, what about that inviolable “Modified Locally Preferred Alternative” that you couldn’t touch in any way without endangering the project’s schedule and jeopardizing federal funding?  Well, IBR staff have unilaterally decided it won’t actually work, and their pushing ahead with an entirely new and much wider design, any trying to shoehorn it into the federal environmental review process without honestly disclosing the major changes they’ve made.

More than six months after theoretically getting buy-off from all of the project’s eight partners for this untouchable design, and spending tens of millions of dollars defining the “modified locally preferred alternative,” Johnson has suddenly decided that he can unilaterally inject back into the discussion an alternative that the project ruled out more than a decade ago. And make no mistake, changing from double-decker bridges to a single level crossing has significant impacts.  It almost certainly means more piers in the Columbia River, and more real estate disruption, particularly on the steadily redeveloping Vancouver waterfront.

For the record this isn’t the first, or even the second, time the engineers at ODOT and WSDOT have screwed up the design of the proposed river crossing.  In 2010, an Independent Review Panel appointed by Oregon Governor Ted Kulongoski and Washington Governor Chris Gregoire found that the “open web” design the agencies proposed was “unbuildable.”  It was replaced by the double-decker truss.  And then, in 2011, the bridge had to be re-designed again to achieve a river clearance of 116 feet, because the two highway departments couldn’t bludgeon the Coast Guard into accepting their preferred 95 foot clearance.  Both these engineering errors delayed the project and raised its cost—something you’ll never hear ODOT and WSDOT admit.

Why now? 

The problems with the bridge grade were first identified more than a decade ago, when the Coast Guard objections let ODOT and WSDOT to hastily redesign the Columbia River Crossing to provide a 116-foot navigation clearance (21 feet higher than what the two highway agencies were then planning).  ODOT and WSDOT never resolved the questions that were raised about the project’s excessive grade, particularly concerns that steep bridge grades would cause large trucks to slow and impede traffic flow.  Following Johnson’s insistent demand that no changes be made to the project defined in the Columbia River Crossing FEIS, IBR has stuck to the steep, double-deck design, never questioning the grade.

But late last year, IBR has had to produce a new cost estimate.  Embarrassingly, the cost of the IBR project has ballooned by 54 percent to nearly $7.5 billion.  To deflect criticism about higher costs, IBR officials testified in December that the project was also subjected to a “Cost Estimate Validation Process,” or CEVP, which the state DOTs advertised as a sure-fire cure for future cost escalation.  As we pointed out at City Observatory, no documentation exists for that claimed CEVP.  The Washington Department of Transportation responded to a public records request for copies of the CEVP by saying “no documents exist.”  Because the agencies have shrouded this process in secrecy we can’t say for sure, but it seems likely that a CEVP meeting likely identified the bridge grade, and expense of elevated interchanges as major cost, schedule and design risks to the project.  That would explain why, more than six months after locking down a double-decker “modified locally preferred alternative,” that Johnson and the IBR team are suddenly reviving the discarded single-level bridge plan.

IBR’s Stacked Highway Bridge Alternative (2021)

For reference, we’re providing details of the alternative designs that have been considered by the IBR in the past decade.  As noted above, the last time any of the project’s documents mentioned a single-level crossing was in the 2008 Draft Environmental Impact Statement.  Most recently, in October 2021, when it last listed the alternative bridge designs it was studying, IBR made absolutely no mention of a “single-level bridge”.  In fact, the only alternative design they showed was pretty much the opposite:  a single and larger stacked bridge, with highway lanes on the upper and lower levels of the double-decker bridge, and with transit and bike-pedestrian routes cantilevered on the sides of the lower level of the double decker.  And now, when it comes time to produce actual renderings, the single bridge stacked alignment has simply disappeared without a trace.


IBR floats new bridge design, proving critics right

For four years, the Oregon and Washington highway departments have been pushing a revival of the failed multi-billion dollar I-5 Columbia River Crossing.  Their key sales pitch is that the size and design of the project can’t vary in any meaningful way from the project’s decade-old record of decision, for fear of delaying construction or losing federal funding.

Months after choosing a “locally preferred alternative” and after years of warning people that moving away from the 2011 design of the CRC would cause enormous delays, IBR is moving to resurrect a bridge design it ruled out more than a decade ago.

A single level crossing would be significantly wider than the current proposal for a pair of double-decker bridges.  Instead, the project would consist of two or three side-by-side, single level bridges, carrying multiple lanes of traffic, light rail trains, bikes and pedestrians all one one level.

The single level crossing would dramatically increase the I-5 footprint, particularly where it crosses the shoreline into downtown Vancouver.

The sudden decision to revive this long-discarded alternative clearly vindicates criticisms raised by independent engineers that the proposed double-decker bridge is too steep; the single level design enables a lower bridge grade.  It also shows that the highway department’s claims that the project’s design can’t be changed are simply false.

IBR Suddenly Announces a New Bridge Design

On February 9, 2023 IBR Administrator Greg Johnson off-handedly slipped this little gem into a routine briefing for the project’s community advisory group.

He told them:  “We’re looking at a bridge configuration of a single level.”

And Johnson immediately interjected, “that is something that is not new.”

He went on to explain that this gives them added choices for “bridge types and bridge aesthetics.”

Here’s the full quote, and following it a link to the meeting video:

Right now we are on target, we’re on task. And the team is driving forward with technical reports that will go out to the cooperating agencies and partners. We’re also working on within the supplemental we’re working on different technical aspects to make sure that we are covering potential design elements. We are looking at a bridge configuration of a single level. So that is something that is not new, but it is something that we wanted to make sure within the draft Supplemental Environmental Impact Statement so folks can see the potential impacts of, of what having all of the modes on one level rather than having transit underneath the lane and having the Bike Ped underneath the lane, we have an option that shows them all at one level. So once again, it’s something that we’re studying the impacts of and we will have those two bridge configurations going forward. We know that one level gives us some some some interesting options as far as bridge types and bridge aesthetics that we don’t get with having transit underneath and having Bike-Ped underneath. So we will be looking at that and you will be seeing at an upcoming meeting some renderings that display these potential configurations.


Far from being a minor change, this represents the revival of an alternative design that was ruled out more than a decade ago.  It also shows that the IBR project is effectively conceding that its critics, who’ve alleged that its double-decker “modified locally preferred alternative” has a serious safety and cost problem due to its excessive grade and elevated off-ramps.  Finally, and perhaps most importantly, it shows that warnings that major changes couldn’t be made to the project out of a fear of delays were simply baseless manipulation.

Resurrecting a discarded 15-year old alternative

As we mentioned, IBR administrator Greg Johnson made a point of claiming that the single level design isn’t “new.”  It isn’t, it’s quite old, and to have listened to the Oregon and Washington transportation departments, it’s so old that it’s been dead and buried for almost 15 years.

The last official ODOT and WSDOT document featuring a single level crossing design was the 2008 Draft Environmental Impact Statement.  It proposed two possible designs for replacement bridges for the current I-5, a pair of side-by-side double-decker bridges (which were chosen as the preferred design), and a trio of single level bridges, as shown here.


The project’s Final Environmental Impact Statement, issued in 2011, abandoned the single level option, and chose to proceed only with a pair of double-decker bridges (with transit and bike-ped access placed on the lower level of each structure).


The Final Environmental Impact Statement made a strong series of findings rejecting the single level three-bridge design, because it would have more in-river impacts, a larger surface area with more runoff, and would have larger visual impact.  [CRC FEIS, Page 2-83]

The single-level design is considerably wider than the two-bridge double-decker design, as shown in this 2007 rendering prepared by IBR.

it’s back. An even wider bridge across the Columbia.

Apparently we can reconsider the design of the crossing, even at this late date.  Ever since he took the job of IBR administrator more than three years ago, Greg Johnson has been warning elected officials not to make any significant changes to the project design included in the 2011 FEIS for fear of delaying it further.  An immersed tunnel?  More consideration for climate?  A lift-span?  A narrower freeway?  None of these can even be studied, or advanced into the environmental review process, for fear that it will cause some additional delay.

But now, more than six months after theoretically getting buy-off from all of the project’s eight partners for this untouchable design, and spending tens of millions of dollars defining the “modified locally preferred alternative,” Johnson has suddenly decided that he can unilaterally inject back into the discussion an alternative that the project ruled out more than a decade ago.

And make no mistake, changing from double-decker bridges to a single level crossing has significant impacts.  It almost certainly means more piers in the Columbia River, and more real estate disruption, particularly on the steadily redeveloping Vancouver waterfront.

A bridge too steep

While Johnson claims that the single level design is allows some more aesthetic options, that’s simply misdirection.  The real reason that IBR is changing its design at this extremely late date is that it has suddenly realized that one of its most persistent critics was right, all along.  For years, engineer Bob Ortblad—who advocates for an immersed tube tunnel crossing—has been pointing out that the proposed IBR bridge design has a dangerously steep grade (nearly 4 percent).  This would make it one of the steepest interstate highway bridges in the country.  Just to hammer the point home:  the Biden Administration just approved a grant of $150 million toward the reconstruction of the I-10 bridge in Louisiana, currently the steepest interstate, to reduce the grade of the bridge to improve safety.  It’s also worth noting that the current IBR bridge design violates ODOT’s own standards for interstate highway bridge grades, and would require a design exception.  In addition to the safety hazard caused by the bridge grade, the extreme elevation of the roadway requires very steep on- and off-ramps, especially those connecting the bridge with Washington State Route 14, which runs very near the riverbank.   Those ramps would have even steeper and more dangerous grades than the bridge itself, a point Ortblad has made graphically:

Proposed IBR would have 4% mainline grades and 6-7% ramp grades (B. Ortblad)

What Johnson didn’t say—and what’s plainly the real reason for a single level crossing—is that it enables the engineers to lower the roadway by as much as 30 and 35 feet, consequently reducing the overall grade, and importantly, lowering the height of on- and off-ramps at either end of the bridge crossing.  The current LPA design calls for a minimum river clearance of 116 feet for the bottom level of each double-decker bridge.  The roadway would be on top of the double-decker, about 30-35 feet higher.  A single level design could lower the maximum height of the bridge by about 30-35 feet, enabling a lower grade.

Of course, the last thing IBR officials want to do is concede that Ortblad was right—that would damage their disinformation campaign about the merits of the immersed tube tunnel.  Instead, they’re suddenly concerned about bridge type and aesthetics.

Why now? 

The problems with the bridge grade were first identified more than a decade ago, when the Coast Guard objections let ODOT and WSDOT to hastily redesign the Columbia River Crossing to provide a 116-foot navigation clearance (21 feet higher than what the two highway agencies were planning).  ODOT and WSDOT never resolved the questions that were raised about the project’s excessive grade, particularly concerns that steep bridge grades would cause large trucks to slow and impede traffic flow.  Following Johnson’s insistent demand that no changes be made to the project defined in the Columbia River Crossing FEIS, IBR has stuck to the steep, double-deck design, never questioning the grade.

But in the past two months, IBR has had to produce a new cost estimate.  Embarrassingly, the cost of the IBR project has ballooned by 54 percent to nearly $7.5 billion.  To deflect criticism about higher costs, IBR officials testified in December that the project was also subjected to a “Cost Estimate Validation Process,” or CEVP, which the state DOTs advertised as a sure-fire cure for future cost escalation.  As we pointed out at City Observatory, no documentation exists for that claimed CEVP.  The Washington Department of Transportation responded to a public records request for copies of the CEVP by saying “no documents exist.”  Because the agencies have shrouded this process in secrecy we can’t say for sure, but it seems likely that a CEVP meeting likely identified the bridge grade, and expense of elevated interchanges as major cost, schedule and design risks to the project.  That would explain why, more than six months after locking down a double-decker “modified locally preferred alternative,” that Johnson and the IBR team are suddenly reviving the discarded single level bridge plan.

It’s not too late to make fundamental changes to the plan

Greg Johnson has cried “wolf” about making serious changes to the IBR project, even as its budget has ballooned by 54 percent in a little over two years, to a total price tag of as much as $7.5 billion.  But this latest—and very late—change to the project design is an indication that it’s not too late to fix the fatal flaws in this project.  Right now the fatal flaws revolve around its bloated design and price.  The reason the project is so expensive has little to do with the bridge structure itself, but rather the extravagant plans of ODOT and WSDOT to widen I-5 for miles on either side of the Columbia River, and rebuild, at much greater expense than the bridge itself, seven different freeway interchanges.  If this were simply a bridge replacement—as its name claims—the project would be vastly simpler, less expensive, and likely not controversial.

IBR’s Stacked Highway Bridge Alternative (2021)

For reference, we’re providing details of the alternative designs that have been considered by the IBR in the past decade.  As noted above, the last time any of the project’s documents mentioned a single level crossing was in the 2008 Draft Environmental Impact Statement.  Most recently, in October 2021, when it last listed the alternative bridge designs it was studying, IBR made absolutely no mention of a “single-level bridge”.  In fact, the only alternative design they showed was pretty much the opposite:  a larger stacked highway bridge, with highway lanes on the upper and lower levels of the double-decker bridge, and with transit and bike-pedestrian routes cantilevered on the sides of the lower level of the double decker.

Nothing but double deckers in 2011 in the Bridge Review Panel Report of 2011

In 2010, an expert review panel appointed by Governor’s Kulongoski and Gregoire found that the proposed “open-web” design being pushed by ODOT and WSDOT was “unbuildable.”  That led to the appointment of a “Bridge Review Panel” to quickly come up with a new alternative.  They recommended three possible alternatives in their 2011 report:  the composite truss design (which became the locally preferred alternative), and two other designs:  a cable stayed bridge and a tied arch bridge.  All three designs shared a common feature:  they were double-deckers with the transit component on a lower level of the bridge.  The cable stayed and tied arch designs had elevated bike-pedestrian paths in the center of the bridge, between the north and south bound highway lanes.

Here’s the Bridge Review Panel’s illustration of the cable stayed bridge.  The two dotted outlines in the center of the bridge structure on the cross-section illustration are the profile for the light rail transit.

Here’s the Bridge Review Panel’s illustration of the tied arch bridge.  Again, the two dotted outlines in the center of the bridge structure on the cross-section illustration are the profile for the light rail transit.




Why should Oregonians subsidize suburban commuters from another state?

Oregon is being asked to pay for half of the cost of widening the I-5 Interstate Bridge.  Eighty percent of daily commuters, and two-thirds of all traffic on the bridge are Washington residents.  On average, these commuters earn more than Portland residents.

The 80/20 rule:  When it comes to the I-5 bridge replacement, users will pay for only 20 percent of the cost of the project through tolls.  Meanwhile, for the I-205 project in Clackamas County, users—overwhelmingly Oregonians—will pay 80 percent (or more of the cost in tolls).

Meanwhile, state legislators are looking—for the first time—to raid the state’s General Fund (which is used to pay for schools, health care, and housing) to pay for roads by subsidizing the Interstate Bridge Replacement Project to the tune of $1 billion.

The proposal for Oregon to fund half of the cost of the Interstate Bridge Replacement is a huge subsidy to Washington State commuters and suburban sprawl.

A draft proposal currently circulating in the Oregon Legislature—the so-called “-2” amendments to HB 2098—would have Oregon General Fund taxpayers contribute $1 billion to the cost of the proposed Interstate Bridge Replacement Project.  That’s a huge break from established tradition.  For the better part of a century, Oregon has theoretically had a “user pays” transportation system, which pays for roads out of the State Highway Fund.  The state’s constitution supposedly draws a hard line around the state highway fund (which is filled from gas taxes, weight mile fees and vehicle registration charges) to pay for the cost of building and maintaining roads.

But the HB 2098 “-2” amendments would, for the first time, use General Fund money to subsidize road construction.

The Oregon Constitution contains provisions that have been interpreted to limit the State Highway Fund revenues to only road expenditures, a key part of a “user pays” system that the state has ostensibly had for nearly a century.  This would be a massive break from that philosophy, taking money from the general fund—something that is used to pay for schools, for health care for the poor, and for social services for the homeless.

Twice as many Washington cars on the bridge as Oregon cars.

On any given day, twice as many Washington residents cross the Columbia River as Oregon residents.  These data are from a license plate survey conducted in 2012 for the Oregon and Washington Departments of Transportation.

Four-fifths of all commuters on the I-5 and I-205 bridges are from Washington State.

The Census Bureau regularly surveys Americans about their commuting patterns.  We very detailed data on who commutes within the Portland metropolitan area, and these data confirm what everyone already knows:  vastly more Washington residents commute to jobs in Oregon than vice-versa.  These data show that 80 percent of all commute trips across the Columbia River are Washington residents; only 20 percent are Oregonians commuting to jobs in Washington.

The real reason for expanding the I-5 bridge is to deal with traffic congestion, and especially peak afternoon traffic congestion in the Northbound direction:  specifically, Washington residents driving home from their jobs in Oregon.  The I-5 bridges are typically not congested in the off-peak direction—because there are far fewer Oregonians driving to jobs in Washington than vice-versa. The highest levels of traffic congestion are Southbound in the morning peak hour (Washington residents commuting to jobs in Oregon), and Northbound in the afternoon peak hour (Washington residents returning home from their Oregon jobs).  In a very real sense, the cost of the I-5 bridge expansion is to serve these commuters.  There is no need to expand capacity on the I-5 bridges for Oregon workers because their commutes are not congested.

Washington Commuters have higher incomes than Oregonians

Peak-hour, drive alone commuters from Washington state to jobs in Oregon have average household incomes of $106,000 according to Census data—about 25 percent higher than for residents of the Oregon side of the Portland metropolitan area.  Clark County’s median household income of $80,500 is higher than for the region ($78,400) and for the City of Portland ($76,200).

Much of the traffic across the river is Washington residents driving to Oregon to evade Washington State sales tax.  Estimates are that the average Clark County household avoids more than $1,000 in state sales taxes each year by shopping in Oregon.  Collectively Clark County households avoid $120 million in state sales taxes per year, and this tax evasion accounts for 10 to 20 percent of traffic across the I-5 and and I-205 Columbia River Bridges.

A tale of two counties, and two toll bridges

Why do Washington residents get a big taxpayer subsidy from Oregon, and Clackamas County residents get a high toll bill?

There are two toll bridge projects before the Oregon Legislature right now.  One is the I-5 bridge, which as noted above, largely serves Washington residents, and the other is the I-205 Abernethy Bridge and I-205 freeway widening project in Clackamas County.  The I-205 project serves mostly Oregon residents, and most of them live in Clackamas County.  There’s a world of difference between how these two projects are going to be financed.

Oregon is being asked to pay for half the cost of the I-5 bridge, even though 80% of commuters and two-thirds of users are from Washington.  Oregon, of course, will pay for all of the cost of the I-205 projects.  And both projects will be paid for in part with tolls, but the tolling policy of the two projects couldn’t be more different.  The IBR project will ask users to pay only about 20 percent of the total cost of the project (about $1.5 billion of a total $7.5 billion price tag).  Meanwhile, users of the I-205 project will be asked to pay 80 percent or more of the cost through tolls.  The Oregon Department of Transportation estimates that tolling will cost the typical Clackamas County family in the project area about $600 per year in toll payments.

ODOT currently says that the I-5 bridge tolls will be as high as $3.55, while the tolls for using I-205 will be $4.40.

A key part of the reason that the tolls will be lower on I-5 is that Oregon is being asked to chip in $1 billion for the Interstate Bridge Replacement, with a HB 2098 “-2” amendment saying that money will come from General Funds.  So while Clark County commuters are getting a $1 billion subsidy from Oregon for their new bridge—and enjoying lower tolls that cover only 20 percent of the cost of the project, Clackamas County drivers on I-205 will get little or no subsidy from the State, and bear 80 percent or more of the cost of this new project.

If we’re going to ask Oregon residents, especially those from Clackamas County to pay tolls to cover nearly all of the cost of new Tualatin River and Willamette River Freeway Bridges, which are we requiring Oregon taxpayers to pay half the cost of the I-5 bridges?  Put simply:

  • Clackamas County residents will be asked to pay a $4.40 toll to cover the cost of a $1 billion project.
  • Clark County WA residents will be asked to pay a toll of $5.60 (or as IBR claims, $2-3) to cover the cost of a $7.5 billion project.
  • ODOT’s plan will charge much relatively much higher tolls to Clackamas County residents for I-205 than it proposes to charge Clark County residents for the I-5 bridges. (I-205 is $4 of toll per billion dollar of project cost; I-5 IBR is $1 of toll per billion of project cost).

It’s hard to understand why the Oregon Legislature would treat Oregon voters and constituents in Clackamas County so much less generously than  it is proposing to treat the people in Clark County, Washington.

Subsidizing Sprawl

The effect of building more road capacity to Clark County is essentially to encourage more people to live in Clark County.  And Washington’s land use laws are far less strict that Oregon’s, meaning that much of that growth is car-dependent sprawl.  When we look at the pattern of urban growth over the last couple of decades, its apparent that Clark County Washington has grown substantially through ex-urban sprawl.  While most new growth on the Oregon side of the Columbia occurred within the Urban Growth Boundary, Clark County Growth sprawled widely.

Why should Oregon taxpayers subsidize yet another round of exurban housing development in Washington?

Fairness and the User Pays Principle

For nearly a century, Oregon has relied on the “users pays” principle to guide road finance.  In theory, gasoline consumption is roughly proportional to miles driven, and apportions to users the costs of the system in direct relation to how much they drive.  Raiding the Oregon General Fund is a dramatic break with that principal, and deserves to be questioned in any event.  But its really hard to understand why Oregon taxpayers should take money that could be used to educate children, care for the sick, or address homelessness, and use it to subsidize commuters (and shoppers) from another state.  And it’s doubly hard to understand why we’d do that, while we’re asking another group of Oregonians, those living in Clackamas County to pay for almost the entire cost of fixing another bridge.

As Governor Tina Kotek said, the financing plan for the I-5 bridge shouldn’t unfairly burden low income Oregonians.

. . When the bridge that we have now across the Columbia, the I-5 bridge, that was tolled at some time to create that bridge. I’m going to always be honest with Oregonians. We have to figure out how to pay to maintain and modernize our system of bridges and roads. And the plan right now to pay for the the improvements on the Abernathy bridge on I 205 and to pay for new I-5 bridge is planned on tolling. Now I’m open to other ideas but I think we should be honest, if we need those types of infrastructure. We’re gonna get as much money as we can from the federal government, and we have to have a conversation about how to pay for it locally. My goal is to make sure whatever we do, it does not unfairly burden our lowest income Oregonians who need to be on those roads. We have to figure out how to modernize and maintain our infrastructure.

Governor Kotek interviewed on KOIN-TV February 24, 2023 (Emphasis added)

But that’s exactly what this proposal does.  It keeps tolls low for Washington residents (they cover only 20 percent of the cost of the bridge they use) while it charges high tolls to Oregon residents (who pay 80 percent or more of the cost of their bridge).  And the HB 2098 “-2” amendments propose to take money that is key to helping low income Oregonians (the State General Fund) and use it to subsidize out of state travelers.

It’s worth keeping in mind that the original bridge (built in 1912) and the parallel second span built in 1958, were both paid for entirely with toll revenues. In theory, we have a “user pays” transportation system—although that’s increasingly become a myth, as nationally we’ve bailed out the federal highway trust fund with general revenues to the tune of more than $200 billion, and we grossly subsidize heavy, over-the-road freight trucks that cause vastly more damage to roads, the environment and people.  Tolling is a “user pays” system:  If 80 percent of the peak hour users of the I-5 bridge are Clark County commuters, and we’re expanding the capacity of the bridge to meet their peak hour travel choices, its incredibly fair and reasonably to ask them to pay for most of the cost of the project.  Washington taxpayers are getting a great deal:  even though they account for roughly twice as much bridge traffic as Oregonians, Oregon is going pay just as much as they are toward the bridge.




CEVP: Non-existent cost controls for the $7.5 billion IBR project

Oregon DOT has a history of enormous cost overruns, and just told the Oregon and Washington Legislatures that the cost of the I-5 Bridge Replacement Program (IBR) had ballooned 54 percent, to as much as $7.5 billion.

To allay fears of poor management and further cost overruns, IBR officials testified they had completed a “Cost Estimate Validation Process” (CEVP).  They assured legislators they had consulted independent subject matter experts and assessed more than 100 risks.

But asked for copies of the CEVP under the public records law, agency officials reported “no records exist” of the CEVP.

And the supposedly “nationally recognized” CEVP process has been around for more than a decade, was judged inadequate and error-filled for the Columbia River Crossing, and failed to detect key cost and schedule risks.

ODOT and WSDOT are more interested in deflecting criticism than in being accountable for—and correcting—runaway project costs.


IBR, December 2022 Legislative Testimony:  “A CEVP was recently completed.”

IBR, January 2023 response to public records request for the CEVP:  “No records exist.”


The Oregon and Washington highway departments are pushing forward with something they call the “Interstate Bridge Replacement Project.”  As we’ve pointed out at City Observatory, this project, which is actually a clone of the Columbia River Crossing that died a decade ago, is really a 5 mile long freeway widening project.  And its one whose cost has ballooned to as much as $7.5 billion, according to estimates revealed in December 2022. This is part of a consistent pattern, 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—ts original cost estimate.

While the agency wants to blame recent construction cost inflation for the increase, that’s simply wrong.  The transportation 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 over their 2020 estimate.

Don’t Worry About Cost Overruns, We did a CEVP™!

At the December 12, 2022 meeting of the Joint Oregon-Washington I-5 bridge legislative oversight committee, IBR administrators tried to buffer concerns about rising project costs by invoking a Cost Estimate Validation Process  or “CEVP “process as a way to diagnose and prevent further cost escalation.

IBR administrator Frank Green testified:

Its a process that enables us to identify costs . . .we also go through a process where we bring subject matter experts to identify, on a program like this, what are some of the potential risks that we may encounter as we’re moving through development of the program.
. . . as we produce our CEVP report and publish it, it will show the list of risks, well over a hundred, that our team and our partners and our subject matter experts identified. It’s important to understand that we also identified strategies, that we as a team and our partners can take to minimize the potential impact of these risks.

Joint I-5 Committee Meeting, December 12, 2022 

This explanation of the Cost Estimate Validation Process was also posted to the IBR project website (emphasis added):

A Cost Estimate Validation Process (CEVP) was recently completed to provide independent review and validation of project cost and schedule estimates.

A CEVP is an estimation process that analyzes risks specific to the project to quantify the impacts and possible mitigation strategies in seeking to limit the impacts of costs and or delays. Cost risks identified for the IBR program are primarily tied to possible schedule delays, although market uncertainties, changes during construction, and design modifications can all pose a risk to cost escalation. Some specific risks identified in the CVEP include:

▶ Possible legal challenges of program environmental process

▶ In-water work complexities during bridge construction

▶ Delay in state matching funds

“No Records Exist” of a current CEVP

Intrigued to learn more, City Observatory filed a public records request with WSDOT (one of IBR’s two parent state agencies) asking for copies of the CEVP.  We were told that there were no written or electronic records pertaining to the CEVP, and that none would be available before March of 2023—more than ninety days after the IBR testified to the Legislature that the CEVP was “completed.”  Their official response to our request—”No Records Exist”–is shown here:

At this point, there’s simply no evidence that WSDOT undertook any kind of analysis.  They just gravely intoned the words “CEVP” and assured that this would insulate the project from future costs and risks.  If there’s no documentation, no electronic files there’s simply nothing to substantiate that any kind of analysis was actually performed.  It’s hard to see how such an insubstantial or poorly documented process  will do anything to prevent or manage future cost overruns.

One has to believe that IBR, according to its own testimony, generated (and analyzed) a list of more than 100 risks, and reviewed them with subject matter experts, without creating a single document, electronic file or other public record.

Apparently, just as former President Donald Trump can declassify a document just by thinking about it, WSDOT and ODOT can perform a CEVP without creating a single document or electronic file.  This strongly suggests that the real purpose of a CEVP is to distract legislators, not identify or prevent budget or schedule risks.

Deja Vu All Over Again:  The CEVP has proven a failure at predicting or preventing cost-overruns for this very project

Whether a CEVP actually exists as a tangible object or not is an open question. An equally important question is whether a CEVP, if one existed, would do anything to accurately predict, or prevent further cost escalation and schedule delays.  Unfortunately, the history of CEVP with exactly this project shows it did nothing to forestall mistakes, delays and cost increases.

It’s too bad that none of today’s Oregon legislators were on hand the last time they were discussing a huge and risky bridge over the Columbia River, because “CEVP!” is exactly what ODOT officials claimed would avoid cost overruns, when they were asking for funding for the then $3 billon failed Columbia River Crossing (CRC) project (which has been revived as the IBR).  Twelve years ago, in 2011, ODOT consultant and gubernatorial advisor Patricia McCaig confidently told Oregon Legislators that they had a handle on project costs, because of Washington’s CEVP process.

“There is a cost estimating validation process called CEVP from Washington, that is a nationally known model that is applied to the Columbia River Crossing and we will spend as much time as you as like to go through that with you.”

Hearing on HJM 22, House Transportation and Economic Development Committee, March 30, 2011

Despite these assurances that CEVP didn’t head off either delays or cost-overruns on the CRC.  An Independent Review Panel for the CRC appointed by Oregon Governor Ted Kulongoski and Washington Governor Christine Gregoire found that there was a “significant risk” that CEVP “was not accurate enough” for financial purposes, and that “the reliability of the final outputs for cost and schedule are seriously suspect.” 

And the panel’s warnings proved correct: Critically, the CEVP prepared for the Columbia River Crossing completely failed to predict the schedule and cost risk from the project’s intentional—and ill-advised—decision to ignore the Coast Guard’s direction about the appropriate height for the bridge.  In 2012, the Coast Guard blocked the project’s record of decision, forcing a year-long delay as the project was re-designed to provide a higher navigation clearance, a change delayed the project a year and added tens of millions of dollars to the project’s cost.  The CEVP also failed to predict that the original design for the project, a so-called “open-web” was unbuildable, and had to be scrapped, causing a year-long delay.

Then, as now, the vaunted “CEVP” exists primarily as a fig-leaf and a talking point to insulate the two DOTs from criticism, and deflect attention from their consistent record of enormous cost-overruns.

In addition, an honest “cost estimate validation process” would reveal that the project is taking huge financial risks by failing to advance either a moveable span or an immersed tube tunnel as full options in the environmental review process.  By ignoring the National Environmental Policy Act’s requirements to fully and fairly appraise such alternatives, it is IBR that is adding considerable cost and schedule risk to the project–an a transparent attempt to force adoption of its preferred massive mega-project.






What the City of Portland said about the Rose Quarter

City of Portland raises big questions about the I-5 Rose Quarter freeway widening project (translated). 

Last month was the deadline for comments on the supplemental environmental analysis for the proposed $1.45 billion I-5 Rose Quarter freeway widening project.

Our friends at Bike Portland got a copy of the city’s comment letter, signed by then Portland Bureau of Transportation director Chris Warner (who’s since moved on to a position in the Oregon Governor’s office).

At City Observatory, we’ve documented the myriad problems with the project, including increasing pollution, worsening safety, failing to solve congestion, and further undermining neighborhood livability.  The City of Portland’s official comment letter echoes many of these concerns, but in a stilted bureaucratic dialect that may not be intelligible to all readers.  As a public service, City Observatory offers its translation; City of Portland comments are shown in quotes, our accompanying translation is in italics.

  • CITY:  “Revisions to the project are needed for alignment with city policy as it relates to prioritizing people walking, rolling, bicycling, and taking transit.”
  • Translation: The project is designed to speed cars on and off the freeway, and on local streets, with dangerous double turn lanes, wide radius corners, and other features that endanger non-car travelers.
  • CITY:  “Lack of clarity in how commitments made as part of the Independent Highway Cover Assessment are provided for. Specifically, how the design will accommodate the community vision to develop a highway cover that can be catalytic in the restoration of high-quality land and provide opportunities for community wealth for generations to come.”
  • Translation:  ODOT promised buildable covers, but is providing no money for their development, and foisting this off on the city.  Plus, the covers are designed only for “lightweight buildings.”  “Lack of clarity” means “you haven’t told us where the money will come from for the promised redevelopment.”
  • CITY:  “Traffic analysis needs to be completed that reflects that the project area is designated as a Multimodal Mixed-Use Area, which provides flexibility for determining significant effects of land use actions, by lifting mobility standard requirements at ODOT facilities while still applying transportation standards such safety and multimodal access.”
  • Translation:  ODOT has designed the freeway for a 70 mph design speed, and prioritizes car movements over local use; this will block the city’s plans to make the area safe for people biking and walking, and attractive for development.<

  • CITY:   “. . .traffic design must consider the impact of pricing on I-5 and the potential for the planned Regional Mobility Pricing Program to change or lower vehicle travel demand in the area.”
  • Translation:  ODOT exaggerated traffic forecasts, and failed to consider that planned road pricing (which is needed to pay for the project) will reduce traffic levels and congestion. (ODOT’s own studies show this would eliminate the need to widen the freeway)
  • CITY: “The project must develop traffic management that provides safe and efficient movement of freight and event district traffic management, including safe and cohesive local and regional access and circulation for all modes.”
  • Translation:  ODOT’s plan would create a dangerous hairpin off-ramp on I-5, which trucks can’t navigate, and which creates a circuitous connection to local streets and the the Moda Center, which will add more than a million miles of driving to local streets.
  • The letter signals some real concerns with the already troubled I-5 Rose Quarter Freeway widening project.  Unfortunately, the subtext of the letter leaves it open to the interpretation that these are minor tweaks the be addressed later in design.  That’s far from the case:  the problems (the width of the freeway, its dangerous hairpin off-ramps, questionably buildable covers, and  traffic inducing size, and hazards to those traveling by bike and on foot are baked into the current design.  The only meaningful way to address these significant impacts is through a full environmental impact statement, something ODOT is desperately trying to avoid by seeking a “finding of no significant impact,” a claim that’s impossible to square the the facts laid out in the city’s letter.

    I-205 tolls will cost you $600 per year

    ODOT’s planned I-205 tolls will cost the average local household $600 annually.

    Regular commuters on I-205 will have to pay $2,200 per year in tolls under the ODOT plan

    The Oregon Department of Transportation is proposing to pay for its widening of the I-205 Interstate South of Portland by charging tolls.  These tolls will represent a significant increase in transportation costs for households living in the southern part of the Portland metropolitan area.

    As we reported at City Observatory earlier, ODOT’s planned tolls will vary by time of day, and will charge users as much as $4.40 to drive I-205 between Oregon City and Wilsonville.

    The project’s Environmental Assessment, just released, shows how these tolls will affect households in this part of the region. These data come from the project’s Economics Technical Report, part of the project’s Environmental Assessment.

    The report uses travel modeling data and Census data to estimate how much a typical household in the I-205 area will pay in tolls each year. The I-205 project would impose tolls of $2.20 (at peak hours) for cars driving across the I-205 Abernethy Bridge over the Willamette River and the I-205 bridge over the Tualatin River.  Most of the people driving across these two bridges live in Clackamas County; the affected area (which the report calls the “Area of Potential Impact” (API) includes parts of Southeast Portland, Washington County and Northern Marion County.  All or nearly all of the cities of West Linn, Gladstone, Lake Oswego, Oregon City, Canby and Wilsonville are included in the API.


    Live inside the red line?  ODOT says you’ll be paying an average of $600 a year in tolls for using I-205.


    About 125,000 households live inside the “API,” roughly one-in-seven of the households in the Portland Metropolitan Area.

    According to the Economics Technical Report, the average household in this area will pay $600 per year in tolls. The net effect of tolling will be to increase the amount of money each household spends on transportation from 7.9 percent of their household income to 8.7 percent of their household income.

    Commuters will pay as much as $2,200 per year in tolls

    Of course, $600 is just an average.  Some households living in this area may travel on these freeways only once or twice a week, and travel at off-peak hours when tolls will be lower.  But regular commuters using the freeway at peak hours will pay much more.  If you drive every day on I-205 through both toll points, you’ll pay $8.80 per day to use the roadway.  Driving five days a week 50 weeks a year, your total tolls would be $2,200 per year.


    Another flawed Inrix Congestion Cost report

    Sigh. Here we are again, another year, and yet another uninformative, and actively misleading congestion cost report from Inrix.

    More myth and misdirection from highly numerate charlatans.

    Burying the lede:  Traffic congestion is now lower than it was in 2019, and congestion declined twice as much as the decline in vehicle travel.

    Today, Inrix released its latest “Global Traffic Scorecard,” which purports to rank US and Global cities based on traffic congestion levels.Over the years, we’ve reviewed Inrix annual traffic scorecard reports.  They’re monotonous in their sameness.  Congestion, we’re told, is very bad and very costly.  But little of this is true or more importantly, actionable.  The estimates of supposed congestion “costs” simply aren’t true because neither Inrix (nor anyone else) has specified how they’d eliminate congestion at a cost less than the supposed dollar value of time lost.  Without a clear idea of how one could go about eliminating these costs, the information simply isn’t actionable.  As we’ve explained in our “Reporter’s Guide to Congestion Cost Studies,” these reports are rife with conceptual and methodological errors.  Today’s Inrix report is still marred by these same problems.

    There are a couple of improvements in this report from the rest of the literature. Inrix spends some time on traffic crashes and deaths, and notes the troubling increase in crashes despite the decline in vehicle miles traveled. To their credit, Inrix this year has carefully avoided claiming or implying that expanding highway capacity would somehow reduce congestion.  That claim has been definitively and scientifically debunked.  We know that, thanks to the fundamental law of road congestion, that more road capacity will simply induce more car travel, fully offsetting any supposed congestion-busting benefits.  But that won’t stop many Inrix clients, notably state highway departments, from pointing to Inrix data as the reason they should be given tens of billions of dollars to widen roads.  And that’s apparently the real purpose of the Inrix report, to curry favor with potential highway department clients.

    Most of what we’ve said about previous Inrix congestion reports apply with equal force to this one.  We’ll highlight a few points.

    First, if you read closely, you’ll learn that time lost to congestion in the US is still lower than it was three years ago, prior to the pandemic.  Inrix reports that congestion time losses were 20 percent lower in 2022 than 2019, 4.8 billion hours, down from 6 billion hours.  This is good news.

    Second, that reduction in congestion should be celebrated, and should also be a teachable moment. If we’re so concerned about congestion, then the experience of the past few years ought to be studied to see if we can learn something.  Right off the top, there’s a really important fact that’s buried in the Inrix report: While congestion declined by 20 percent from 2019, traffic (vehicle miles traveled or VMT) went down by just 9 percent.

    The fact that congestion declined more than twice as much as VMT is a critical observation:  It means that demand management can reduce congestion, and that modest changes in travel volumes produce disproportionately large improvements in transportation system function.  If instead of managing demand with a pandemic and lockdowns, we did something a little more nuanced, like road pricing, we could achieve real and lasting congestion reductions.  That’s exactly the sort of actionable information that ought to be in this report, but which is missing.

    Third, there are a whole bunch of other important things that are missing as well.  If you search through the latest Inrix report, here are some words you simply won’t find:  “sprawl,” “pollution,” “emissions,”  “carbon,” “climate,”  “induced demand,” “pricing,” and “tolling.” Trying to talk about urban transportation systems without considering their effects on these other pressing problems is a measure of how detached the UMR is from the reality of the 21st century.  Transportation is the leading source of greenhouse gas emissions in the US, and these emission are increasing. The Inrix report exists solely to feed an overriding obsession with speed and congestion as the. criterion for setting transportation policy.

    Fourth, in reality the city rankings are meaningless.  The measure Inrix uses totally ignores the differences in distances among Metro areas.  The fact that you have to drive twice as far, on average, in Houston or Atlanta as you do in Chicago or Boston, doesn’t figure in to the “cost” of commuting.  As we’ve shown, this particular measure inaccurately penalizes compact cities where people make shorter trips, because it looks only at the difference between peak and non-peak travel times.  Cities with shorter travel distances generate less car travel (vehicle miles traveled), emit much less greenhouse gas emissions, and save their residents billions of dollars in avoided travel costs compared to sprawling, car-centric metro areas.  The best way to reduce the cost of transportation, and time lost is to have more compact development, something we’ve demonstrated in in our previous analysis.  And while the Inrix report spends a lot of time talking about the added burden of high gas costs, it completely leaves out the fact that higher gas prices are much more burdensome in cities and neighborhoods where people have to drive long distances.

    Fifth, the Inrix rankings are a profoundly car-centric view of the world. Inrix likes to tout its “big data” noting that its estimates are drawn from billions of data points.  But those data points are almost entirely cars and trucks.  There’s an old saying “if you don’t count it, it doesn’t count.” They leaven their reporting with a handful of statistics on bikes and pedestrians, but these are drawn from the rare reports compiled by cities, not from Inrix data. The car and bike data, and the actual variation in commuting distances, simply don’t figure into the Inrix rankings.  In short, if you don’t travel by car, you really don’t count in the Inrix rankings.

    Sixth, there’s no evidence that driving faster makes us happier.  Inrix and other congestion reports prey on our sense of annoyance and victimization about traffic congestion.  It’s all these other people who are slowing us down, and we’d be better off if they were gone and we could drive faster.  But cities that are optimized for speed simply sprawl further and require more driving, making us more car dependent and costing us more money.

    Finally, it’s truly disappointing that such a rich and detailed source of information should be used largely for car-based propaganda.  Reports like these aren’t really designed to help diagnose or solve problems, but simply to generate heat.  They’ll be used in predictably misleading ways by road-widening advocates.  More or bigger data doesn’t help us solve our problems when its filtered through this incomplete and biased framework.

    Our reviews of previous Inrix Scorecards

    In 2018, we lampooned the predictable alarmist tone of the congestion report:

    Cue the extreme telephoto shots of freeways!

    Wallow in the pity of commuters stuck in traffic because of all those other people!

    Wail that congestion is getting worse and worse!

    We noted that the 2017 Inrix report adopted a new and more expansive definition of congestion costs which further inflated its estimates.

    Older studies like TTI, estimated dollar costs based on the additional time spent on a trip due to congestion: So if a trip that took ten minutes in un-congested traffic took a total of 15 minutes in a congested time period, they would monetize the value of the five minutes of additional time spent. The Inrix report appears to monetize the total value of time spent in congested conditions, i.e. anytime travel speeds fell below 65 percent of free flow speeds.

    In 2016, we gave the Inrix report card a “D” 

    In 2015, we pointed out that the Inrix study had a number of contradictory conclusions, and that Inrix had “disappeared” much of its earlier data showing that high gas prices had demonstrably reduced traffic congestion in US cities.

    For more information and analysis about the conceptual and methodological problems in these “congestion cost studies,” see our Reporter’s Guide.




    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.

    Driving between Vancouver and Wilsonville at 5PM? ODOT plans to charge you $15

    Under ODOT’s toll plans, A driving from Wilsonville to Vancouver will cost you as much as $15, each-way, at the peak hour.

    Drive from Vancouver to a job in Wilsonville?  Get ready to shell out as much as $30 per day.

    Tolls don’t need to be nearly this high to better manage traffic flow and assure faster travel times.  The higher tolls are necessitated by the need to finance ODOT’s multi-billion dollar highway spending spree.

    ODOT is telling everyone to get ready for tolls, but they’re being close-mouthed about how much tolls will be.  Here’s what they’re planning, according to documents obtained by City Observatory.

    • Tolls on the I-205 Abernethy and Tualatin River Bridges will be $2.20 each at the peak hour. (Orange)
    • Tolls on the I-5 Interstate Bridge will be up to $5.69 (Green)
    • In addition to these tolls, drivers on I-5 and I-205 will pay tolls of 17 cents to 38 cents per mile during peak hours.  Twenty miles of driving on I-5 or I-205 will cost you between $3.40 and $7.60. (Blue)
    • People who don’t have transponders will also pay a $1.77 processing fee per transaction

    ODOT’s planned tolls for Portland area bridges and highways

    Here’s what your bill could look like for a trip from Wilsonville to Vancouver in just a few years.

    Of course, you have the option of taking I-5, rather than I-205, but if you do, your bill will be pretty similar:

    Why are the tolls so high?  ODOT claims that the tolls are needed to manage congestion, but actually they’re planning on charging toll rates that are vastly higher, and that are poorly designed to actually manage traffic.  The reason:  ODOT is planning to go deeply in to debt to spend billions widening area freeways, and high tolls will be needed to pay back the bonds ODOT issues.  ODOT has already decided to issue $600 million in short term debt (a kind of bureaucrat’s pay-day loan) to get the I-205 projects started.  In the case of the IBR, ODOT and WSDOT will need a huge amount of toll revenue to pay for their super-sized $7.5 billion project.

    If the tolls are set at levels that would just manage traffic they could be much lower at the peak hour, and could be zero in off-peak hours.  The purpose of tolling should be to encourage people to travel at times when the highway system has adequate capacity.  Most peak hour travelers don’t have alternatives, but a good proportion (20 to 30 percent, at least) do have the option of taking their trip at a different time, taking a different route, or using transit.  Moving just a small portion of peak hour traffic off the freeway system means we’ll get much better service and travel times.  But tolls could be much lower than those that would be required to pay off billions of dollars in bonds.  There’s actually no reason to charge tolls overnight, and during most off-peak periods; freeways could still be “free” then, to encourage people to shift their trips to these less busy times, lowering peak hour congestion and avoiding the need for expensive road-widening projects.

    Lower tolls would work better and be more equitable.  Some people are concerned that tolling is inequitable to the poor. Research has shown that because higher income people drive more, drive farther, and are more likely to drive at the peak hour, that tolls fall more heavily on high income households. And even that low level of inequity can be lessened by setting toll levels at the lowest rates consistent with getting free traffic flow (and not high enough to fund super-sized highways).  In addition, very low or zero off-peak tolls make the system more equitable because lower income people are much less likely that high income people to drive at peak hours.  Finally, we ought to use toll revenues to fund a “transportation wallet” for low income households to offset their transportation costs however they choose to travel.  Toll exemptions require you to buy a car to get any benefit, and do nothing to help those who don’t own cars or can’t drive.

    I-205 Bridge Tolls:  $2.20 each way on Abernethy & Tualatin Bridges

    ODOT has been reticent to say what the tolls will be on I-205, but KGW-TV reporter Pat Dorris broadcast testimony at a recent Yamhill County Commission meeting in which ODOT staff revealed that tolls will be $2.20 on each of the two bridges on I-205.

    According to the KGW story, ODOT will charge $2.20 peak hour tolls on the I-205 Abernethy Bridge between Oregon City and West Linn, and an additional $2.20 peak hour toll on the bridge over the Tualatin River between Stafford Road and West Linn.  Those driving from Wilsonville to Oregon City would pay a $4.40 total toll at the peak hour.  Look for ODOT to erect toll gantries over the I-205 roadway with license plate reading cameras and toll-taking transponders:

    I-5 Interstate Bridge Replacement Tolls:  $5.69 each way on the I-5 Bridge

    Similarly, the Interstate Bridge Replacement project has not publicly said what toll levels it is looking at, saying opaquely that this will be decided later.  But tolling is integral to the planning for the bridge:  ODOT can’t estimate the volume of traffic likely to use the bridge without a good idea of what tolls it will charge (the higher the tolls it charges, the fewer vehicles will cross the bridge).   City Observatory has obtained internal WSDOT and ODOT planning documents that show that the IBR project is looking at peak hour tolls of up to $5.69 each way at the peak hour for the new interstate bridge.  Here is an April 4, 2022 email from Jennifer John (a transportation modeler for the IBR project) to Aaron Breakstone (a transportation modeler for Metro).  It explains that they are studying tolls on way, peak hour tolls of $4.45 (in 2010$).

    For analytical convenience, we’ve computed the current, inflation-adjusted value of a $4.45 toll in 2010 dollars–that is equal to $5.69 in today’s (2022 dollars) using the Bureau of Economic Analysis Implicit Price Deflator for Personal Consumption Expenditures (IPD/PCE)–the preferred method of making such comparisons.

    Congestion Pricing Charges:  $10-12 from Wilsonville to Vancouver at Rush Hour

    But bridge tolls aren’t the only road pricing that’s coming:  Oregon DOT is also developing a “Regional Mobility Pricing Program (RMPP).  ODOT’s plan is to institute per mile tolls on Interstate 5 and Interstate 205 between the Boone Bridge in Wilsonville and the Columbia River.  The agency has kept the exact amount of tolls a closely guarded secret.  Planning documents prepared in 2018 said that tolls of 17 cents per mile to 38 cents per mile would be needed to manage traffic under value pricing, the project now called the Regional Mobility Pricing Program.

    Shhh!  Toll levels are a deep secret.

    The typical ODOT line is something like the following:  “Tolls will be set about six months before the project opens; tolls will be determined by the Oregon Transportation Commission, after public hearings.”  Here’s the typical shine-on as reported by the Portland Tribune:

    According to ODOT, the exact toll rate pricing will be based on congestion relief goals, revenue needs and public input. The exact pricing is expected to be announced about six months before tolls begin.

    That non-answer begs the question about what toll levels will be.  And for both financial and traffic forecasting reasons, ODOT has to know the approximately level of tolls well in advance.  If it doesn’t know the toll level, it not only doesn’t know how much money tolling will provide toward the cost of the project, and critically, because tolls will depress traffic levels, it needs to know how high tolls will be to accurate forecast traffic (which determines the need for the project) as well as the amount of revenue.  As a practical matter, ODOT staff and consultants have already developed working estimates of tolls, they’re just not making them public.  (Notice the word “exact” appears twice, and that tolls will be “announced” six months in advance.  Make no mistake:  ODOT will decide the approximate level of tells well in advance; in reality, they likely already know).

    City Observatory has obtained ODOT emails showing the agency is trying to keep the exact level of toll charges a secret–even from the Metro regional government and the City of Portland.

    ODOT has resisted releasing any documents showing the exact level of tolls used in their traffic modeling.  In October, 2022, City Observatory requested information on proposed toll levels and was told it would be charged over $2,000 to provide such information.

    Regional Mobility Pricing Program Tolls

    The regional mobility pricing program will charge drivers based on the distance they travel on I-5 and I-205, with rates varying by time of day.  To illustrate the approximate range of expected tolls along I-5 and I-205, we’ve used Google Maps to compute the distance between the Boone Bridge in Wilsonville and the two freeway bridges across the Columbia River.  The I-5 route between Wilsonville and the Interstate Bridge is 29.5 miles long.  At 17 cents per mile, the toll would be $4.45; at 38 cents per mile the toll would be $9.96.The I-205 route between Wilsonville and the Interstate Bridge is 32.5 miles long.  At 17 cents per mile, the toll would be $5.53; at 38 cents per mile the toll would be $12.35.

    This calculation assumes that the Regional Mobility Pricing Program (RMPP) fees for the segment of I-205 between Stafford Road and Oregon City are in addition to the tolls charged at the Abernethy and Tualatin River I-205 bridges.  ODOT has not revealed how RMPP tolls will interact with bridge tolls.  If ODOT does not charge an RMPP toll on this segment of the freeway, the toll for a Wilsonville-Vancouver trip would be $1.19 to $2.26 less than these estimes.

    Additional Fees for vehicles without transponders.  $2 more each time if you don’t have a transponder.

    For both bridge tolls, and for the congestion pricing system, OregonDOT is planning on barrier-free all-electronic tolling.  Cars and trucks would pass under a toll-gantry, and antennae would communicate with in-vehicle transponders–small windshield stickers.  Cars that didn’t have transponders would have their license plates photographed, and would be billed by mail.

    Washington charges those without transponders an additional $2.00 when they travel through downtown Seattle’s tolled SR 99 tunnel:

    Those who are billed by mail would pay an additional surcharge to cover the costs of billing.  Again, ODOT isn’t revealing how much that surcharge would be.  Estimates prepared for the Columbia River Crossing said that the surcharge for “pay-by-mail” would be $1.77 per transaction.  In addition, City Observatory has obtained more recent ODOT planning documents indicating that the surcharge would be $2.00 per transaction, just as in Washington.

    Higher tolls for trucks:  3 to 5 times higher than for cars.

    For I-205, ODOT told KGW that trucks would pay higher tolls—but declined to reveal how much higher.  KGW’s Pat Dooris reports:

    Currently, the planning model includes large trucks being charged higher toll rates than passenger vehicles.

    A 2013 study paid for by ODOT for the Columbia River Crossing said that  tolls for 18-wheelers would be four- or five-times higher than tolls charged to passenger cars.  One-way peak hour tolls for 18-wheeler trucks would be $14.65.  Trucks without transponders would pay another $2 for “pay by mail” processing.”  We’ve obtained, via public records request, a 2022 ODOT study showing that trucks traveling on I-205 would pay four times the passenger car rate, or $17.60, one way, at peak hours—plus a $2.00 surcharge, if they didn’t have a transponder.


    Where toll rate data comes from

    As we’ve said, ODOT has been very secretive about toll levels.  We obtained the toll level estimates from a variety of ODOT documents.  They include the following:

    I-5 Bridge Replacement Tolls:  Memorandum from Jennifer Johns of IBR to Aaron Breakstone of Metro, April 22, 2022. (Obtained via public records request).

    Regional Mobility Pricing Program Tolls:   Oregon Department of Transportation,, (2018). Portland Metro Area Value Pricing Feasibility Analysis Final Round 1 Concept Evaluation and Recommendations Technical Memorandum #3, 2018.

    Surcharges for those without transponders and Truck Rate Multiplier:  2013 CDM Smith Investment Grade Analysis of Columbia River Crossing.

    I-205 Abernethy and Tualatin River Bridge Tolls:  KGW TV reports.

    WSP for Oregon Department of Transportation, I-205 Toll Project, Level 2 Toll Traffic and Revenue Study Report, Revised October 2022 (obtained via public records request).

    We have made multiple public records requests to ODOT for the latest information on planned tolls  ODOT has declined to provide data on IBR and RMPP tolls.  If ODOT would like to provide more accurate information, City Observatory will revise this commentary to reflect those data.



    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).


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

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

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

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

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

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

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

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

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

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

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

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

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

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

    More Dangerous, More Expensive, and Less Buildable

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

    A hazard for people walking and biking.

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

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


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

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

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

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

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


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


    ODOT reneges on Rose Quarter cover promises

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

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

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

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

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

    In the past few days, we have obtained a copy of the soon-to-be released Revised Environmental Assessment for the I-5 Rose Quarter Freeway widening, a $1.45 billion project pitched as “restorative justice” for the Albina neighborhood.  The revised assessment was required because of the project’s substantial redesign in the past two years and  in part because community opponents, led by No More Freeways, prevailed in a lawsuit challenging the project’s original environmental assessment; the project’s earlier “Finding of No Significant Impact (FONSI) was withdrawn by the Federal Highway Administration).

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

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

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

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

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



    Housing and other improvements have disappeared from the new Environmental Assessment

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

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

    Revised Environmental Assessment

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

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

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

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

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

    Not so buildable after all

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

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

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

    Covers don’t restore the neighborhood

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

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

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

    A Toll Policy Primer for Oregon

    Oregon doesn’t have tolls on any of its major roads or bridges.  But faced with stagnant gas tax revenues, and with an appetite for huge freeway expansion projects, the Oregon Department of Transportation has committed itself to using tolls to generate billions of dollars in revenue.

    And let’s be clear, as economists, we support the idea of congestion pricing:  our urban transportation problem exists primarily because we don’t reflect back to road users the costs of providing the infrastructure they use.  We try to run the state highway system like every day is “Free Ice Cream” at Ben and Jerry’s–people are lined up around the block and we don’t have enough money.

    Before the state heads down the toll path, there are a few things it should know about tolling, and the risks and consequences of the approach that’s being pursued by ODOT.  We’ve tried to reduce the key lessons down to this baker’s dozen of essential points.

    1.  The Oregon Department of Transportation thinks it has a capacity/congestion problem on Portland area freeways (I-5, I-205, I-84, 217).  In reality this is a peak hour congestion problem (or peak several hours) and results from the fact that roads aren’t priced.  (And also that WA essentially pays people to travel to Oregon to shop). These roads, and all others, have plenty of capacity most hours of the day.

    2.  ODOT’s traffic forecasts incorrectly predict that traffic will continue to grow on these roadways, and that congestion will get worse and worse.  (In fact, that isn’t true.  Congestion is limited by capacity, and bottlenecks like the I-5 Columbia River Bridges meter traffic on I-5 (esp. in the AM).  Volumes across the I-5 bridges can’t grow—according to ODOTs own toll consultants, because there isn’t enough capacity.

    3.  ODOT is using these exaggerated forecasts of future growth in travel to justify the size of new roadways (10 lanes at Rose Quarter, 12 lanes for the I-5 Bridge and approaches, as well as additional lanes for the Boone Bridge and Abernethy/I-205. ODOT describes these as “bridge” projects (interstate bridge, Abernethy bridge, Boone bridge) but then all of them involve widening miles and miles of freeway on either side of the bridge.  It’s a conscious tactic to mislead. A project that is actually just “replacing” a bridge, like the proposed Burnside Bridge project in Portland, doesn’t raise these issues, because its not really a highway-widening masquerading as a bridge replacement.

    4.  ODOT will issue billions of dollars in bonds to pay for all these projects.  And bonds will be issued before the projects are started. ODOT will also put off charging tolls until after construction is started, or until after the projects are completed.  This will require capitalized interest (i.e. borrowing money in excess of the construction cost and using it to pay interest before tolls are collected).  The giant projects will be committed and the debt obligation put in place before there’s any actual experience with tollling.

    5.  Traffic volumes on tolled roads will be lower, not just lower than ODOTs excessively optimistic forecasts, but lower than before the projects were built.  On average, we can expect even modest tolls to produce a 20% to 40% reduction in traffic from un-tolled levels.  Those estimates are borne out in the Pacific NW based on the experience of tolling previously un-tolled roads (i.e. Highway 99 Tunnel in Seattle) and on removing tolls from previously tolled facilities (in 2017, BC eliminated tolls on the Port Mann and Golden Ears Bridges).

    6.  These widened roadways and bridges will have excess capacity.  The classic example of this happening is the I-65 Ohio River Bridges project in Louisville, KY.  It is nearly identical to the proposed CRC/Interstate Bridge Replacement.  KY & IN paid $1 billion to double the I-65 bridges from 6 lanes to 12, and AFTER they were completed imposed a toll (which works out to $1 each way for regular commuters).  That caused traffic on I-65 to drop by about half from 130,000 ADT to about 70,000.  The twelve lane bridge looks almost empty even at PM peak hours.  Here’s the I-65 bridge on a Monday afternoon at seven minutes past 5 PM.



    7.  There’s related issue of toll design.  Congestion pricing focuses on using tolls to manage traffic, i.e. lowering toll rates when traffic volumes are low, and raising them when traffic volumes are high.  In contrast, with a fixed debt obligation under HB 3055 “build/borrow/then toll”) approach, ODOT will likely want to capture revenue from all road users, even in off-peak hours.  This was exactly reflected by the final changes to the CRC tolling strategy in 2013, which doubled off-peak tolls:  the project’s Final Environmental Impact Statement claimed said minimum tolls would be $1.30; the project’s investment grade analysis (IGA) raised them to $2.60.  Originally, peak tolls were more than double off-peak tolls; in the IGA there was just a 65 cent difference, so you end up losing much of the time-shifting incentive. Also:  to show the project was “justified” in terms of demand, and in order to maximize revenue, ODOT has strong incentives NOT to raise peak period toll rates so high that they shift traffic to off-peak periods because they will get less money from motorists.   If we just used tolls to manage demand, rather than finance over-sized construction projects, tolls could be much lower, and off-peak tolls could be set to zero, effectively created a low cost travel alternative when we have abundant capacity.

    8.  ODOT will likely have to raise toll rates over time to generate more revenue.  This is already happening in Washington State, where tolls have been increased, and further increases are planned for SR 99, SR 520 and Tacoma Narrows Bridge.   These toll increases have the effect of further depressing traffic growth, and at some point, it’s impossible to get significant additional revenue by raising tolls. Even with the toll increases, there isn’t enough to pay back the bonds.

    9.  Toll based projects will need to be bailed out from other sources.  WA is currently making “loans” from its motor vehicle account to bail out the Tacoma Narrows Bridge, and the SR 99 tunnel.  Tolled roadways in CA, FL, and TX have defaulted debt payments, been bailed out, and been forced into bankruptcy.  In OR, under HB 3055, ODOT would be required to divert monies from state taxes and federal grants to make bondholders whole, which would mean foregoing other projects and cutting maintenance and operations.

    10.  None of these projects are actually fully funded by tolls.  Tolls usually cover 20-40% of project costs.  For example, toll backed bonds covered less than 10 percent of the cost of Seattle’s SR 99 tunnel  Toll backed bonds were a minority of the revenue for SR 520 as well.  Tolls would have been about a third of the proposed CRC, when its budget was about $3 billion. There’s no guarantee that toll revenue will be sufficient to cover a significant portion of project costs. With the I-205 Abernethy project, ODOT is going ahead with building the project without doing an independent, investment grade analysis that will assure that tolls are sufficient to cover capital costs.

    11.  The issuance of toll-backed bonds creates strong financial incentives for ODOT to maximize traffic on tolled roadways.  Once bonds are issued, measures that decrease VMT on tolled roads reduce the  stream of revenue to repay bondholders and force ODOT to take money from other projects and/or reduce maintenance expenditures.  If you applied a “climate lens” to this policy, you would see that this is exactly the reverse of the incentives that should apply to ODOT.  In short, if we don’t increase traffic on widened tolled Portland area freeways, we’ll be forced to cut back spending on everything else ODOT spends money on.  From a climate perspective, that’s simply perverse. Toll based capacity expansions are inherently in conflict with out stated climate objectives.  They create the financial necessity of maintaining or increasing VMT, and with it, GHG, in order to avoid cutting other projects.

    12.  The fact that fewer people use these roads than today if they’re tolled even modestly means people will drive on these expanded roadways only if someone else pays their cost.  The value provided by the roads to the people who would actually drive on them isn’t so high that they would pay the costs.  Spending money on these roads is a value-destroying proposition:  It costs the people who bear the costs to spend more on the roadway than its services are worth to those who use it.  Even with tolls, users aren’t being asked to pay anything approaching the actual cost of the capacity (see #9).  In a very real sense, we’re using scarce public resources to pay people to drive more.

    13.  Viewed in the context of climate and generational change, this policy is tragic and perverse.  It builds more roads now and sends the bill for these roadways to future generations.  They will not only have to repay the financial debt, they’ll also have to bear the environmental burdens from worsening climate chaos.  And the more future generations figure out ways to reduce travel and GHG emissions, the larger will be the debt that has to be repaid by slashing other transportation projects.

    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.

    ODOT’s safety lie is back, bigger than ever

    Oregon DOT is using phony claims about safety to sell a $1.45 billion freeway widening project

    People are regularly being killed on ODOT roadways and the agency claims that it lacks the resources to fix these problems

    Meanwhile, it proposes to spend billions of dollars widening freeways where virtually no one is killed or injured and labels this a “safety” project.

    A wider I-5 freeway will do nothing to improve road safety in Portland.

    On October 4, Sarah Pliner  was killed at the corner of SE 26th and Powell Boulevard, when she and her bike were crushed  by a truck.  Pliner was a chef at a Southeast Portland restaurant; she was cycling to work. This was no accident:  this intersection is one of the deadliest in Portland, having killed or maimed many over the past several years.  Powell Boulevard (aka US 26) is owned and managed by the Oregon Department of Transportation.  Pliner’s tragic death is just the latest example of the carnage on Oregon roads:  in the past year, pedestrian deaths in Oregon are up 61 percent.

    Sarah Pliner (Bike Portland)

    Powell is one of the multi-lane arterial highways ODOT operates that are the deadliest roads in the Portland metropolitan area.  Recently, ODOT has agreed to transfer another of its deadly arterials (a portion 82nd Avenue, aka Oregon highway 213) to the City of Portland, so that the City can implement a traffic calming and safety strategy.  That’s been in the works for years, but the hang up has been getting enough money to finance the improvements before the city can take over management.  Several years ago the city and state estimated it would cost $31 million to address the safety issues on this part of Powell Boulevard, but little has been done.  ODOT routinely pleads poverty when asked to fix these killer roads.

    ODOT’s main priority is widening area freeways.  They’re proposing to spend as much as $1.45 billion widening about a 1.5 mile stretch of Interstate 5 in Portland’s Rose Quarter.  And they’re cynically and deceitfully packaging this spending as a “safety” project.  We’ve call out this lie time and again, but ODOT still repeats a false claim that this is the worst crash location on the Interstate.

    That isn’t true—other stretches of Portland area interstate have higher crash rates, as shown by ODOT’s own data—it’s an intentionally misleading and calculatedly cynical talking point, crafted by the agency’s PR team.  And it’s beside the point.  Interstate freeways are relatively very safe, with few fatalities and serious injuries.  What “crashes” do happen are overwhelmingly minor fender benders, bad for a car’s bodywork, and sometimes a source of traffic delays, but not something that routinely kills and maims Portlanders.  ODOT loves to pretend it cares about safety by ginning up “crash” numbers, while ignoring serious injuries and fatalities. Meanwhile, it studiously ignores the deaths that occur on the arterial roads in operates, like Powell Boulevard, that regularly kill people like Sarah Pliner.

    But that doesn’t stop ODOT from claiming that the Rose Quarter project is really all about safety.  Just weeks before Pliner was killed on ODOT’s Powell Boulevard, the agency sought legislative approval to apply for federal funding for the Rose Quarter, labeling it an important safety project.  The request for federal funds comes after the agency has allowed the project’s budget to more than triple from $450 million to as much as $1.45 billion—meaning that the Rose Quarter will consume a billion dollars that could have been used to fix roads like Powell.  Here’s what Kris Strickler said in a letter to legislators.

    This Rose Quarter section of I-5 . . . has the highest crash rate of any section of interstate within Oregon. The project adds new ramp-to-ramp connections (also known as auxiliary lanes that connect one entrance ramp to the next exit ramp) and adds full shoulders to I-5 to improve traffic flow and reduce the frequency of crashes. Also included in the project is the construction of a highway cover over I-5 that will create new community spaces and enhance safety and connections for people walking, rolling, biking, riding transit, and driving on local streets. [emphasis added]

    The claim that the “cover” over I-5 will enhance safety for pedestrians and cyclists is spurious and misleading.  By bringing even more cars into the Rose Quarter, the freeway widening increases the threats to vulnerable road users.  And as we’ve noted at City Observatory, a key part of the project’s design is widening the radius of curvature at many intersections, increasing the turning speed of traffic and lengthening the distance pedestrians must travel to cross the street, both of which are guaranteed to make the area more dangerous, not safer.  The entire purpose of this project is more and faster cars, something that we know will hurt safety, not help it.

    ODOT’s own statistics from its Environmental Assessment make it clear that there haven’t been any fatalities, or even any serious injuries on I-5 in the five year period for which it reported data.  Their data also show that most crashes happen during the mid-day (9am to 4pm) not during peak hours.

    ODOT is currently in the process of updating its Environmental Assessment to sell its now $1.45 billion project.  It hasn’t bothered to update any of the crash or safety data, and is relying on information that is at least seven years old to bolster its rationalization that this is somehow a “safety” project.

    Claims that widening the freeway will make the region safer are simply wrong.

    Over the past several years at City Observatory, we’ve dug deep into the claim that a wider freeway will somehow be safer.  A range of studies, some prepared by ODOT, confirm that the I-5 Rose Quarter project will do essentially nothing to improve traffic safety in the Portland region:

    Metro’s Regional Transportation Plan  officially categorizes the purpose of the  the Rose Quarter widening as “reducing minor or non-injury crashes.”

    After ODOT widened a nearby stretch of I-5, the crash rate went up, not down.

    The “ISATe” methodology ODOT used to claim that crashes would go down as a result of widening doesn’t apply to freeways with ramp-meters—which I-5 has.

    After years of badgering ODOT to stop making blatantly false claims that the Rose Quarter was “the #1 crash location in Oregon”—we got them to drop that claim from the project’s website.

    ODOT narrowed its proposed freeway widening at the South end of the project to avoid encroaching on the Vera Katz Esplanade, with 11 foot lanes and narrow shoulders, yet its own analysis showed this would make only a trivial difference to the crash rate.

    As Canadian planner Brent Toderian says, “The truth about a city’s aspirations isn’t found in its vision. It’s found in its budget.”  ODOT may claim to care about safety, but is only real interest is wider freeways, and more and faster car traffic—something that’s been repeatedly shown to lead to even more crashes, injuries and deaths, not fewer.

    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.


    Two out of three candidates for Oregon Governor are climate denialists

    The Republican and Independent candidates for Oregon Governor are happy to spout a convenient myth that we can fight climate change by widening highways.

    That myth has been completely disproven:  wider roads encourage more driving and more greenhouse gases

    Advocating for more and wider roads is climate change denial

    Oregon has been one of the nation’s leaders in recognizing the dangers posed by climate change.  The state enacted a first-in-the-nation goal of cutting greenhouse gas emissions by 75 percent from 1990 levels by 2050.  While we’ve been frequent critics of the efficacy of some of the steps in the state strategy, each of Oregon’s last several Governors have made it clear they support strategies to address climate change.

    In the November 2022 election, voters will choose between three competing candidates:  Democrat Tina Kotek, Republican Christine Drazan and Independent Betsy Johnson.  (Incumbent Governor Kate Brown is term-limited).  All are former state legislators.  Recently Oregon Public Broadcasting interviewed each of the candidates on their position on climate change.

    Left to Right: Tina Kotek, Betsy Johnson, Christine Drazan:  One will Oregon’s next Governor (OPB).

    To their credit, OPB focused the discussion on transportation emissions, which are the largest source of greenhouse gases in the state, and which have been increasing in recent years.


    I support widening our highways, by building more lanes. I believe we can both reduce traffic times and reduce emissions from idling engines.


    Of course I would increase highway capacity when necessary to more efficiently move vehicles through our highways. The more we maintain efficient flow, the less emissions will be released.

    Tina Kotek, at least, didn’t repeat the “wider highways mean less idling and will reduce emissions” canard.  She also reiterated her support for Governor Kate Brown’s Executive Order directing state agencies to plan for reductions in greenhouse gas emissions (something the other two candidates say they would rescind).

    As we’ve pointed out before at City Observatory, the claim that wider roads, faster traffic and less idling means lower greenhouse gas emissions has been scientifically disproved.  And some of the best science on the subject comes from Oregon, specifically Portland State University.

    This myth has been repeatedly debunked

    The science on this question is unequivocal and uncontested:  making traffic move faster in urban settings, whether by expanding capacity or “operational improvements” to increase traffic flow tends to induce more traffic.  The higher volume of traffic causes congestion to quickly return to previous levels, and the combination of more vehicle miles of travel and no long term change in congestion, means that greenhouse gas emissions actually go up.  The literature refers to this as “the fundamental law of road congestion.”  The most definitive study of the question was completed right here in Oregon, by transportation researchers Alex Bigazzi and Miguel Figliozzi, in a paper published by the Transportation Research Board,. Their work showed that increasing capacity on congested roads to allow traffic to move faster and more smoothly actually increases total emissions.

    For those who are interested, here’s a link to the video of Alex Bigazzi presenting the findings of his research at Portland State University in 2011.  The takeaway:  greenhouse gases are tied to how much and how far we drive, not to the speed of traffic or the time spent idling.  There’s no relationship between overall traffic congestion and carbon emissions.

    It’s great that all three candidates for Oregon’s Governor are willing to acknowledge the scientific fact of climate change.  But the science doesn’t stop there:  repeating the myth that speeding traffic or reducing idling will lower greenhouse gas emissions is simply flat-earth thinking and climate denial.

    Falsely claiming that reduced idling will lower greenhouse gases is a popular lie among highway advocates.  Current Oregon DOT director Kris Strickler made this a centerpiece of his confirmation testimony in 2019.  But repeating this lie doesn’t make it true.  What it does do is further delay taking action that would really address the climate crisis.

    Highway officials misrepresent Coast Guard permit requirements

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

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

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

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

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

    US Coast Guard: Protecting America’s Waterways

    IBR:  Misleading Statements about the Coast Guard Approval Process

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

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

    IBR officials misled the Oregon Legislature

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

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

    Representative Pham:

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

    (Emphasis added).

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

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

    Officials have learned from the experience.

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

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

    (Emphasis added)

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

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

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

    New Regulations in 2014 require resolving the navigation height before NEPA

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

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

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

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

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

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

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

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

    Appendix:  Correspondence between Coast Guard and USDOT

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


    ODOT’s “Fix-it first” fraud

    ODOT claims that its policy is “fix-it first” maintaining the highway system.

    But it is spending vastly less on maintenance and restoration than is needed to keep roads and bridges from deteriorating

    It blames the Legislature for not prioritizing repair over new construction

    But it chooses to advance policies that prioritize spending money on new construction ahead of maintenance

    It diverts funds that could be used for maintenance to pay for cost overruns on capital construction projects.

    ODOT pleads its maintenance backlog as a “bait and switch” to get more revenue that it then spends on capital construction rather than fixing roads

    A proclaimed “Fix-It First” policy.

    The Oregon Transportation Commission (OTC) which directs the activities of the Oregon Department of Transportation, has clearly claimed to prioritize maintenance.  In its 2020 Investment Strategy, OTC proclaims it prioritizes maintenance of existing roads:

    Oregon is a fix-it first state. The Oregon Transportation Plan and Oregon Highway Plan focus on preserving the system; highway improvements are focused on enhancing efficiency and the capacity of existing facilities rather than building new ones. . . . Funding to preserve state highway assets is not adequate, resulting in a triage approach to preservation, rehabilitation, and repair, and maintaining status quo conditions requires more than doubling current funding.

    The Oregon Transportation Commission has adopted the Oregon Highway Plan’s policy 1G for Major Improvements which says it will prioritize maintaining the highway system over expanding capacity.

    Since road construction is very expensive and funding is very limited, it is unlikely that many new highways will be built in the future. Instead, the emphasis will be on maintaining the current system and improving the efficiency of the highways the State already has. The Major Improvements Policy reflects this reality by directing ODOT and local jurisdictions to do everything possible to protect and improve the efficiency of the highway system before adding new highway facilities.

    Policy 1G: Major Improvements

    It is the policy of the State of Oregon to maintain highway performance and improve safety by improving system efficiency and management before adding capacity.

    A huge and growing maintenance backlog

    So how is Oregon doing in implementing this policy:  Every report and inventory from ODOT shows that we have a major maintenance gap, and it’s getting worse.

    ODOT’s June 2022 federally required Transportation Asset Management Plan (TAMP) reports that Oregon is spending $329 million annually less than is needed to keep roads and bridge at their current state of repair>  The state is spending less than half of what it would need to ($156 million of an estimated $320 million) just to “maintain current conditions” of Oregon bridges.  It is also spending only about 40 percent of what it needs to retain existing conditions on Oregon roads ($112 million of an estimated annual need of $273 million).  Bridges would require an additional 164 million and roads an additional $165 million, each year, in order to simply maintain current conditions.

    ODOT’s Investment Strategy, adopted in 2020 admits it is dramatically underspending on maintenance, and that Oregon roads and bridges will deteriorate.  The state has other manifold needs that aren’t funded.

    • ODOT’s plans say we need to spend $5.1 billion seismically retrofitting hundreds of Oregon Bridges:  It currently has funding for just 30 of 183 high priority “Phase I” bridges–the balance are unfunded.
    • ODOT says we need to be spending $50 million per year to achieve compliance with the Americans with Disabilities Act on Oregon highways
    • ODOT says we need to be spending $53 million per year to provide or repair walking and biking facilities along state highways.

    In the face of a tight budget, ODOT has chosen to cut its operations and maintenance, but still expects an even larger shortfall.  In the years ahead.  ODOT’s January 2022 Budget Outlook predicted a widening budget shortfall:

    ODOT now projects that the funding gap has shrunk to $144 million in 2027,   due to stronger revenue growth and larger fiscal year 2021 ending balances through budget discipline. However, revenues and expenditures remain out of alignment, and without additional revenue or expenditure reductions the gap will grow quickly. By 2029 the gap is projected to grow to $515 million.

    In short, we’re not spending enough to maintain the current system, we’re cutting operation and maintenance budgets and are facing an even larger shortfall in maintenance funding in the years ahead.  And in the face of this, ODOT is marching forward with unfunded plans for huge construction projects that will plunge the state into debt for decades.

    Blaming the Legislature

    ODOT blames the Legislature for this policy choice.  In a 2020 memo to employees, published by the Oregonian, ODOT Director Kris Strickler says the reason the agency has to slash operating costs and maintenance is because the Legislature short-changed the agency.  Here’s the Oregonian’s coverage:

    “Many will wonder how ODOT can face a shortfall of operating funding after the recent passage of the largest transportation investment package in the state’s history,” Kris Strickler, the agency’s director, said in a Wednesday email to employees, stakeholders and other groups, citing the 2017 Legislature’s historic $5.3 billion transportation bill. “The reality is that virtually all of the funding from HB 2017 and other recent transportation investment packages was directed by law to the transportation system rather than to cover the agency’s operating costs and maintenance.”

    The public and likely the Legislature will be surprised to know that “directing money by law to the transportation system” somehow precludes ODOT from spending money to maintain those roads.  The truth is that ODOT’s deceptive cost estimates and discretionary reallocation of funds are really what’s short-changing operations and maintenance.

    Constantly proposing new construction and under-estimating its cost

    While ODOT blames the Legislature, it is the agency advancing hugely expensive new capacity projects, including the I-5 Rose Quarter (1.45 billion), I-5 Bridge Replacement/freeway widening ($5 billion+), I-205 Abernethy Bridge ($700 million) and Boone Bridge (not revealed).

    The Legislature approves these projects based on cost estimates provided by ODOT and then ODOT treats this as a mandate to pay whatever cost-overruns the project incurs.  In the case of the I-5 Rose Quarter project, the Legislature was told it would cost $450 million in 2017; the current price tag is now estimated at as much as $1.45 billion.  ODOT told the Legislature the I-205 Abernethy Bridge would cost $250 million; its price tag has doubled to nearly $500 million.  These cost overruns directly reduce funding available for maintenance.  By failing to correctly estimate costs, and by always paying for cost-overruns, ODOT’s actual policy prioritizes new capacity construction over maintenance.

    Diverting maintenance funds to new construction

    ODOT routinely diverts funds allocated to and available for maintenance to fund capital construction projects.

    It used interstate maintenance discretionary funds to pay for the planning of the failed Columbia River Crossing project.  It diverted funds that could otherwise be used for maintenance to pay for the Interstate Bridge Replacement project.  It routinely prioritizes capital construction in the use of “unanticipated federal funds” and “project savings.”  It cobbled together just these funding sources to pay for the initial work on the I-205 Abernethy Bridge before the Legislature authorized any funding for the project.  Each year it gets a tranche of what it calls “unexpected” federal funds (federal money that is unspent from nationally competitive programs that is allocated to the states).  At its July, 2022 meeting ODOT recommended (and the OTC approved) using this money, which could be applied to the maintenance backlog, to fund $10 million towards the Interstate Bridge Replacement project.

    This bias toward highway expansion at the expense of maintenance will be amplified by ODOT plans to issue massive amounts of debt for new highway construction. ODOT is pursuing a risky bonding strategy for billions of dollars of Portland-area freeway expansion projects, that effectively pledges to use maintenance monies to repay bond-holders.  HB 3055 allows ODOT to pledge all of its state and federal funds to the repayment of toll-backed bonds.  If toll revenues are less than projected–which happens frequently–ODOT would be legally obligated to cut funding for maintenance statewide to pay back bond holders.

    Bait and switch

    For years, ODOT has come to the Legislature, pleading poverty:  It doesn’t have enough money to maintain our roads, therefore, we need to increase gas taxes, weight-mile taxes and registration fees.  Then, when the Legislature authorizes higher taxes, ODOT uses this money not to reduce the maintenance backlog, but instead to fund giant new construction projects.  When these projects go over budget, it cannibalizes funds that could be used for maintenance, and comes back to the Legislature, again pointing to its self-created backlog of funding needs to fix potholes and preserve bridges.  In reality, Oregon is a “fix it last” or “fix it never” state:  the maintenance spending backlog is just a perpetual excuse to force the Legisalture and taxpayers to give the agency more money, which it will then plow into expanding roadways.



    A bridge too low . . . again

    Ignoring the Coast Guard dooms the I-5 Bridge Project to yet another failure

    The Oregon and Washington DOTs have again designed a I-5 bridge that’s too low for navigation

    In their rush to recycle the failed plans for the Columbia River Crossing, the two state transportation departments have failed to address Coast Guard navigation concerns

    State DOT PR efforts are mis-representing the approval process:  The Coast Guard alone, decides on the allowable height for bridges, and only considers the needs of navigation.  

    Make no mistake, the Coast Guard officially drew a line in the sand–actually, 178 feet in the air above the Columbia River–and has essentially said that the two state DOTs “shall not pass” with a river crossing that doesn’t provide that level of navigation clearance.

    What the preliminary determination is intended to do is signal to the DOTs the kind of structure that the Coast Guard will likely approve.  But the Oregon and Washington DOTs aren’t taking the hint.  Instead, they’re pretending that this “determination” is really meaningless, and that if they just show that the height restriction would be inconvenient or expensive for them to comply with, that they can somehow force the Coast Guard to let them build a bridge with a lower navigation clearance.  That’s a clearly wrong reading of the law, and more importantly it means the two State DOTs are embarking on a risky strategy that’s likely to doom the current effort to build a new Columbia River Bridge.

    Prolog:  The failure of the CRC

    As we’ve pointed out, this is deja vu all over again.  The Columbia River Crossing project similarly ignored Coast Guard signals that a low bridge would be unacceptable.

    More than a decade ago, the Oregon and Washington DOTs advanced a plan for a new fixed-span I-5 bridge with a navigation clearance of 95 feet.  The DOTs did their own analysis of shipping needs, and claimed that, in their opinion, 95 feet would meet the reasonable needs of river users.  The trouble is, that determination isn’t up to state DOTs:  it’s the exclusive legal province of the US Coast Guard, which is charged by Congress with protecting the nation’s navigable waterways.  (Despite the moniker “Department of Transportation” state DOTs have essentially no legal or policy responsibility for commercial water traffic.

    Early on in the bridge design process–in 2005–the Coast Guard signalled its likely objections to a mere 95-foot river clearance.  But state DOT officials blundered ahead, insisting that their own analysis was sufficient to justify the low design.  At the time it issued its record of decision in December 2011, the Coast Guard filed a formal objection, noting that the two state DOTs had not provided sufficient information for the Coast Guard to make the determination as to the needed clearance.  The Coast Guard wrote:

    . . . the Coast Guard’s concerns with the adequacy of the Final Environmental Impact Statement (FEIS) have not been resolved . . . As previously stated, the Coast Guard cannot determine if the preferred 95-foot bridge clearance will meet reasonable navigation requirements based on the information provided for review.

    In addition, the Coast Guard noted that the FEIS failed to consider the environmental effects of different bridge heights:

    The FEIS does not address current and future impacts to navigation/waterway users as a result of proposed decreased vertical clearance, nor does it study alternatives to a vertical clearance other than 95 feet.

    As the bridge permitting agency, the Coast Guard determines the reasonable needs of navigation when acting upon a permit application.

    Only after completing the FEIS and getting a ROD did the two state transportation departments start applying for the needed Coast Guard bridge permit.  In December 2012, the Coast Guard made it clear that the proposed 95-foot clearance would not be sufficient.  Ultimately, the Coast Guard insisted on at least a 116-foot river clearance.

    Here we go again

    Even though they’ve been working on reviving the Columbia River Crossing since 2018, the two state DOTs only submitted a new navigation report to the Coast Guard in November 2021.  For more than three years they’ve been operating under the assumption that the Coast Guard will go along with a 116-foot navigation clearance.  But in its “Preliminary Navigation Clearance Determination” the Coast Guard has said that won’t be nearly enough.

    The Coast Guard is crystal clear about its approval standard:

    “Generally the Coast Guard does not approve bridge proposal with vertical navigation clearances below the ‘present governing structure’ when the existing VNC has been and is currently needed unless there is a compelling navigational reason to do so.” (Harris to Goldstein, June 17, 2022, p. 2)

    The real takeaway from the Coast Guard letter is that the I-5 bridge needs to provide 178 feet (or more) of vertical navigation clearance.

    . . .  the Columbia River (specifically the section of the Columbia River immediately east of the existing I-5 twin bridges) has and needs to continue to provide VNC equal or greater than the existing I-5 twin bridges of 178 feet. Our PNCD concluded that the current proposed bridge with 116 feet VNC, as depicted in the NOPN, would create an unreasonable obstruction to navigation for vessels with a VNC greater than 116 feet and in fact would completely obstruct navigation for such vessels for the service life of the bridge which is approximately 100 years or longer. (Emphasis added)

    The implication is that if the two DOTs can work out a financial deal with existing river users it can get Coast Guard to approval a lower bridge clearance.  But Coast Guard’s past comments and current review indicate that it is not merely looking out for the interests of current river traffic and industry, but is intent on protecting the current navigational channel for future industry and activities.

    The reasons for the Coast Guard’s decision are clearly laid out in its June 17, 2022 letter:

    • Current users need to move structures and vessels with a clearance of between 130 and 178 feet.
    • Vessels and their cargos are growing larger over time.  Marine industries need the flexibility to accommodate larger structures in the future.
    • There are no alternative routes for waterborne traffic to reach areas East of the I-5 bridges; in contrast their are many alternate routes for terrestrial traffic (cars, trucks and trains).
    • Water access to the area East of the I-5 bridges, including PDX airport and the Columbia Business Center marine industrial area in Vancouver may be needed in the event of a natural or national emergency
    • Historically, the Columbia Business Center has been a preferred site for shipyard activity (it housed the Kaiser Shipyard in World War II) and may be needed again for this purpose in the future

    The Coast Guard’s conclusion makes it clear that it is strongly committed to maintaining the existing river clearance, that it won’t approve a 116 foot bridge, and that the economic effects of this would be unacceptable.  It also pointedly directs the two state DOTs to evaluate either a tunnel or a moveable span to meet its 178-foot requirement:

    The Columbia River System is an extremely important interdependent-multimodal supporting national and international commerce critical to local, national and global economies. Reducing the capability and capacity of the Columbia River System would severely restrict navigation. IBR’s proposed bridge as depicted in Public Notice 02-22 with its 35% reduction of VNC from 178 feet to 116 feet is contradictory to the U.S. Coast Guard’s mandate from Congress to maintain freedom of navigation on the navigable waters of the U.S. and to prevent impairment to U.S. navigable waterways. As new structures are built, navigation clearances should be improved or at a minimum maintained. Any proposed new bridge should have a VNC of greater than or equal to that of the existing I-5 twin bridges of 178 feet or preferable, unlimited VNC, as well as a HNC as permitted during the final USACE 408 permit. There are alternative options to accomplish this VNC to include a tunnel or a high-level lift bridge or bascule bridge, which would provide an unlimited vertical clearance. A modern similar successful project is the Woodrow Wilson Bridge over the Potomac River in Washington, DC that was completed in 2009. It is a higher-level double bascule lift bridge on an interstate (I-95) with transit. The added height of the new bridge reduced the number of bascule bridge openings for vessel passage by 76%. (Emphasis added)

    The DOT Strategy:  Maximum Risk

    Once again, the state DOTs have delayed as long as possible confronting the issue of the navigation clearance.  This time, having learned from its prior experience, the Coast Guard has insisted that the navigation issue be addressed prior to the environmental impact statement.

    Still, the DOTs are equivocating, implying that the Coast Guard decision has no weight, and arguing that the legal standard for review involves some kind of balancing of DOT interests in a convenient and cheaper low clearance bridge and implying that the DOTs and not the Coast Guard are the ones who determine the minimum navigation clearance.

    The best way to minimize risk is to advance a series of possible alternative solutions through the SEIS process.  At a minimum, these should include a lower level bridge with a lift span, and some kind of tunnel.  In the event that the Coast Guard sticks to its preliminary determination, which is a strong possibility, if not a very high probability, this will mean that the project will be able to move forward.  The DOTs solution, to move forward with only a fixed span, runs the risk that the Coast Guard will hold firm to its announced intention to require a minimum 178 feet of clearance, meaning that two or three years from now the project will be back to square one with no legally buildable, environmentally reviewed project.  All of the project sponsor’s supposed concern with being able to compete for funding will be jeopardized by this reckless decision to look only a fixed span.

    USCG PNCD IBR 17June2022

    Oregon and Washington DOTs plan too low a bridge–again.

    The Coast Guard has told Oregon and Washington that a new I-5 bridge must have a 178-foot vertical clearance for river navigation–vastly higher than the 116-foot clearance the state’s have proposed

    A fixed span with that clearance would be prohibitively expensive and would have to be huge–nearly 2 miles long, and would have steep grades. 

    An easier solution would be a new bridge with a moveable span, such as that built for I-95 in Washington DC, yet IBR officials tell falsely claim an I-5 liftwapan would have to be “the world’s largest”

    Three Portland area bridges have bascule spans of comparable size to that needed for the I-5 bridge, and much larger bascule and vertical lift bridges have been built elsewhere.

    Our story so far:  For the past three years the Oregon and Washington Departments of Transportation have been trying to revive their plans for the failed Columbia River Crossing, a massive freeway expansion project between Portland and Vancouver.  The project would require replacing the existing I-5 bridges over the Columbia River, and the height of these bridges will be determined by the US Coast Guard.  In June, the Coast Guard issued its “Preliminary Navigation Clearance Determination” (PNCD) saying that the bridges would have to at least preserve the current navigational clearances (178 of vertical space.  That immediately threw a wrench into the DOT plans to build a fixed span with just 116 feet of clearance.  The Coast Guard declared unequivocally:

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

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

    The Interstate Bridge Replacement Project is hoping to get the Coast Guard to back down, in part by asserting that it would be impossible to build a lift span to provide the Coast Guard’s requirements.

    IBR Administrator Greg Johnson testified to the Joint Oregon-Washington I-5 Bridge Committee, that if the Coast Guard required the I-5 bridge to be built with a lift span, it would be the largest such structure in the world.

    Here’s a transcript of that meeting, from approximately minute 18 of the audio-video recording created by the Oregon Legislature.  IBR Administrator Greg Johnson describes the impact on the project of going to a lift span:
    .  . .  a cost of putting what would in essence be the largest lift span in the world. We’re talking about an additional $400 million in that way. So, these are the trade offs that we have to look at the viability of a lift span that large which has never been operated at that size before . .  .
    (emphasis added)

    That’s simply not true.  In fact, there are other lift spans in the Portland area that are as large, or larger, than would be needed to include a lift span on the I-5 bridges, as we document below.

    But Administrator Johnson’s claim is both ominous and vague.  How large would the navigation opening in a lift span need to be?   That determination will be made by the US Coast Guard.  The current bridge has a vertical navigation clearance of 178 feet. The 2012 Navigation Impact Report prepared for the Columbia River Crossing documented the existing navigation clearances of the I-5 bridges, which are 178 feet vertically and 263 feet horizontally.  The bridge also has a barge navigation channel with a maximum horizontal clearance of 511 feet, but this barge channel has a vertical clearance of from 46-70 feet.  The Coast Guard’s preliminary navigation report said that a new bridge should at least preserve both of the current horizontal and vertical clearances.

    Needed Navigation Clearances:  178 feet high, 263 feet wide

    Here’s the text of the Columbia River Crossing’s navigation report, showing existing bridge clearances.  Keeping the existing main shipping channel, shown on the left, would require a vertical clearance of 178 feet and a horizontal clearance of 263 feet.  The Army Corps of Engineers authorized navigation channel under the I-5 bridge is 300 feet wide, but the actual horizontal clearance under the bridge is 263 feet.  .

    In addition, maximum river channel on this stretch of the Columbia River is already constrained by the next downstream bridge, which is the Burlington Northern “9.6” bridge (less than a mile West of the I-5 bridges).  This railroad bridge has a swing span with an opening width of about 230 feet. In order to provide a 263 foot wide channel, the I-5 bridge would need two bascule leaves with a length of 135 feet each.

    One does not have to look far in the Portland Metro area to find such bridges.  There are three in the center of downtown Portland, the Morrison Bridge and the Burnside Bridge.  The Morrison Bridge (1958) has two bascule lift sections, with an opening of 284 feet.  The Burnside Bridge (1926) also has  two bascule lift sections, with an opening of 252 feet.  The Broadway Bridge (1911-12)–a slightly different kind of bascule–has an opening of 278 feet.

    The Burnside Bridge, 1926:  252 foot wide opening.

    The Morrison Bridge (1958):  284 foot wide opening

    The Broadway Bridge (1911-12):  278 foot wide opening

    Nor is the width of the needed roadway an obstacle.  The Morrison Bridge has a roadway width of 90 feet—exactly the same as the width proposed for each of the two aborted Columbia River Crossing bridges.

    Woodrow Wilson Bridge:  A modern busy Interstate with a lift-span

    But can we have lift spans on Interstate highways?  Actually, the answer is yes.  I-95, the one of the nation’s busiest freeways connecting the major metro areas on the East Coast has a lift span in Washington DC.  The Woodrow Wilson Bridge, opened in 2009, has a modern double leaf bascule bridge that carries 12 travel lanes and 250,000 vehicles per day across the Potomac River.  Also, there’s some question about the width of the roadway on the bascule bridge.  For the record, the Woodrow Wilson Bridge has two separate sets of “leaves” for the north and south bound sections of I-5 (i.e. it’s like two bascule bridges side by side).

    Woodrow Wilson Bridge

    The Woodrow Wilson Bridge allows for a relatively low level crossing of the Potomac River, minimizing the height and footprint of interchanges on either side of the river (shown above)

    Rather than towering over the Vancouver waterfront, and requiring lengthy elevated roadway sections across downtown Vancouver and over Hayden Island, a bascule lift-span bridge could be built at a much lower level, eliminating the need to rebuild intersections high into the air to meet a fixed span high enough to clear 178 feet.

    In contrast, a fixed-span high-level bridge violates both the pledges to respect the environment and promote equity.  It hurts the environment, because the high bridge requires vehicles to climb over a much higher elevation, leading them to consume more fuel and emit more pollutants than would be the case with a lower elevation lift-span crossing.  This is especially true for heavy trucks that will struggle to climb the high bridge’s steep grades, and which will create a safety hazard for faster moving cars.  The high bridge is also inequitable for those who are not traveling by car:  those who walk on bike or on foot will find the steep grades associated with the high bridge much more taxing the motorists, who will simply have to press harder on the accelerator pedal.

    Not the world’s largest lift bridge

    Contrary to what IBR staff imply, there’s nothing unusual about the size of the possible lift-span for the I-5 bridge.  Large bascule bridges are not uncommon.  The Rethe bridge in Hamburg Germany, built in in 2016, has an opening of about 308 feet.  The Erie Avenue Bridge in Lorain, Ohio, built in 1940, has an opening width of 330 feet. The Market Street Bridge in Chattanooga, has an opening that is 358 feet wide.

    Rethe Bridge, Hamburg:  308 foot opening

    An I-5 lift span meeting the Coast Guard’s requirements would not only not be the largest lift-span in the world; it wouldn’t be even the largest lift span in the neighborhood  That particular honor belongs to the Burlington Northern Willamette River Bridge 5.9, which has a vertical clearance of over 200 feet, and a moveable span that is more than 500 feet long–higher, and almost twice as wide as the needed opening for a new I-5 moveable span meeting Coast Guard requirements.

    The Burlington Northern Willamette River Bridge: 200 feet high, 500 foot opening.

    The Sauvie Island Bridge arch is barged under the BN Willamette River railroad bridge
    This lift span was paid for by the federal government in 1989 and has a lift span that is 516 feet long and it provides a vertical clearance of 200 feet.  The lift span was added to the existing bridge in place of a swing span  for a cost of less than $40 million (about $125 million in today’s construction expense).

    Repeating Past Mistakes:  Planning a Bridge Too Low

    A decade ago, the Oregon and Washington Transportation Departments tried to force the Coast Guard to agree to a fixed Columbia River Crossing I-5 bridge with a height of just 95 feet over the river, arguing (exactly as they are now) that this lower level best balances the needs of different forms of transportation.  Balancing needs of road users, though, is not the legal standard applied by the Coast Guard, which following federal law, prioritizes the needs of river navigation.  As the Coast Guard said in its review, road users have many alternate routes for crossing the Columbia River; waterborne commerce has none.


    The two DOTs attempt to force the Coast Guard to agree to a lower bridge height added more than a year of delays to the CRC process (which ultimately failed) as well as millions of dollars in added planning costs.  The IBR team has no plans to seek a bridge permit before 2025, and thereby seems intent on repeating this mistake–moving forward with attempts to convince the Coast Guard to approve a lower navigation clearance, while spending tens of millions of dollars planning a bridge that may not meet the Coast Guard’s legal requirements.


    Price Indexes for highway construction.
    • Federal Highway Administration (1989-2003).
    • FHWA, Highway Construction Cost index (2003=1)  2021Q4=2.19
    Coast Guard Preliminary Navigation Clearance Determination

    Risky Bridges: Deja vu all over again

    Needed:  An independent review of technical mistakes that could cost billions

    The proposed multi-billion dollar Interstate Bridge Replacement is shaping up a repeat of the Columbia River Crossing (CRC) fiasco because the two states haven’t done anything to independently verify the work of their staff.

    Oregon DOT and WSDOT are repeating all the key mistakes that caused the Columbia River Crossing (CRC) to fail a decade ago:

    • Designing an oversized project
    • Kicking the can down the road on hard financial decisions
    • Ignoring engineering and regulatory warning signs
    • Not developing a plan to break the project into affordable phases
    • Rebuilding too many closely spaced interchanges.
    • Not getting Coast Guard approval of bridge height until after spending tens of millions designing a bridge

    Critically, the Interstate Bridge Replacement project is not being independently reviewed to determine whether its engineering design, traffic plans, travel projections, revenue forecasts and budget are reasonable.  In the case of the CRC, a series of outside experts were called in, and spotted problems that were created or ignored by state DOT staff.  Project officials for the IBR project are making the same errors, but haven’t been subjected to any real scrutiny from disinterested, outside experts.

    In the case of the Columbia River Crossing, four different times, outside experts were called in to independently examine the work of the Oregon and Washington transportation departments:

    • 2010:  Independent Review Panel
    • 2011:  Bridge Review Panel
    • 2010:  Bain Traffic & Revenue Forecast Review
    • 2013:  CDM Smith Investment Grade Analysis

    Every time, they found costly errors that could have potentially doomed the project that needed to be fixed.  The two states spent millions of dollars on these independent reviews ($1.2 million for the two independent review panels, and another $1.5 million for independent traffic and toll revenue projections).  These expenditures were money well-spent because they avoided even costlier mistakes.  (We detail each of these reports below).

    Say you’re looking at buying a used car.  While the owner assures you its it good shape, you’d definitely want to check things out.  You’d be well-advised to spend a few bucks and get an independent mechanic to look it over, and you’d probably spend a few bucks getting a “CarFax” report to see the vehicles history. Same thing about buying a house:  you’d want to have a thorough inspection by an impartial expert.

    Oregon and Washington leaders would be well-served by taking similarly prudent steps to check out the validity of the work being done for the Interstate Bridge Replacement project.  The history of the project clearly shows why:  The failed Columbia River Crossing collapsed in significant part because of errors and sloppy work done by the two state departments of transportation.  A decade ago, reviews by independent experts hired by the two states show that the traffic and financial projects were flawed, the schedule was unreliable, the chosen bridge design was “unbuildable;” plus the initial design for the bridge was too low to qualify for Coast Guard approval.  Independent experts also found that the project was making overly optimistic financial assumptions, failed to create a reasonable contingency plan (including phasing the project), and was perpetuating traffic problems (and driving up costs) by not removing one or more interchanges.

    Before Oregon and Washington move forward with the latest version of the CRC, now called the “Interstate Bridge Replacement,” (IBR) this project, which current estimates say could cost as much as $5 billion (and which past history has shown to be a significant understatement), they would be wise to hire some independent experts to check out the quality of the work done.  So far, decision-makers are being asked to simply trust the two agencies, something that led to the epic failure of the Columbia River Crossing a decade ago.  As we pointed out, ODOT pre-construction cost estimates for major highway projects have routinely been way too low, with the typical project ending up costing more than twice as much as its initial estimate.

    The proposed IBR would be more expensive, more complex, and more financially risky than any other project ODOT has ever undertaken.  The likelihood of errors is high, and the necessity for quality control checks on ODOT and WSDOT is critical.  And recall, these are agencies that have repeatedly made false claims about key project issues, for example, falsely saying that if the two state’s didn’t move forward with the project they’d have to repay the federal government the $140 million spent planning the failed Columbia River Crossing.

    1.  Independent Review Panel findings:  “unbuildable,” “not accurate”, “problematic”, “seriously suspect”

    In 2010, Governors Ted Kulongoski and Christine Gregoire appointed an  Independent Review Panel (IRP) to audit every aspect of the Columbia River Crossing project.  The panel spent months studying the project, meeting with project staff, carefully studied the “open web” bridge structure the two DOTs designed, and in their report declared it “unbuildable” and directed that a new design be selected.  The Panel of experts from around the country looked at every aspect of the project’s design, management, and financing had issued a 317-page report

    The Independent Review Panel warned that the project finances were tenuous and uncertain, just as they are with today’s IBR.  The panel of national experts warned:

    “As currently envisioned development of the CRC is counting on full funding from multiple sources, including tolling which will be new to the community and unproven in its revenue generating potential. Failure to achieve one or more major sources of funding can make the entire project unmanageable or unaffordable in the present.”

    The IRP had harsh criticism of the sketchy and inconsistent project budget and schedule.  Their report flagged numerous problems, saying the budget and schedule had:

    • “significant risk”
    • “not accurate enough”
    • “the reliability of the final outputs for cost and schedule are seriously suspect”
    • “the credibility of the cost basis is . . . problematic”

    2.  Bridge Review Panel:  A totally new bridge design;

    One direct outcome of the 2010 IRP was a determination that the 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.  

    The Bridge Review Panel described themselves and their work as follows:

    This 16 member panel was comprised of national and international bridge experts, plus key representatives from federal, state and local partner transportation agencies. The mission of the BRP was to examine the current design and potential bridge types given current project constraints and including scenarios where constraints are relaxed or modified. Issues such as meeting current environmental project commitments, sound technical and engineering approaches, aesthetic statements and cost effectiveness were also key considerations.

    The panel’s report concluded that any of three different bridge designs could work, including both a cable-stayed and tied-arch designs, which would be considerably taller than the design selected for the IBR.  They determined that these taller designs had no insurmountable conflicts with aviation at Pearson field.

    In all, Oregon and Washington spent nearly $1.2 million on consultant services specifically for the two panels.  This doesn’t include the costs of staff time for the two state transportation departments, or the time of other consultants already hired for other tasks, who provided information to the panels.

    Independent Review Panel and Bridge Review Panel Expenses
    Consultant Amount Description (per CRC)
    John Clark         210,003.56 Participated on Bridge Expert Review Panel
    Tom Warne         184,745.20 Led Independent Review Panel & Bridge Review Panel
    Public Knowledge         141,921.40 Governors Expert Review Panel Administrator
    Pegasus Global Holdings          99,439.44 Participated on CRC Independent Review Panel
    Cascadia Law Group           85,825.52 Participated on CRC Independent Review Panel
    Lenhardt, Andra & Partner           82,643.64 Participated on Bridge Review Panel
    ERF           79,711.36 Participated on CRC Independent Review Panel
    Aecom Technical Services           68,547.57 Participated on CRC Independent Review Panel
    TY Lin International           58,367.04 Participated on Bridge Review Panel; CEVP
    URS           47,191.48 Participated on Bridge Review Panel
    Ralls Newman           45,522.99 Participated on Bridge Review Panel
    Stephan Thoman Consulting           41,121.30 Participated on Bridge Review Panel
    Mary Lou Ralls           26,012.50 Participated on CRC Independent Review Panel
    Michael Meyer           16,983.50 Governors Expert Review Panel Member
    Total      1,188,036.50
    Source:  Columbia River Crossing

    3. The Bain Report:  Flawed traffic projections

    Accurate traffic projections are crucial for designing the correct size for the bridge and approaches, and for correctly estimating potential revenue from tolling.  The Oregon and Washington transportation departments have poor track records in traffic projections. Washington’s state treasurer raised alarms about CRC toll financing after revenues for the newly built Tacoma Narrows toll bridge came in well under WSDOT projections.  In 2010, concerns about the inadequacy of ODOT and WSDOT’s CRC travel projections led Oregon State Treasurer Ted Wheeler to hire international toll finance expert Robert Bain to review their work.  Bain’s review found:

    • Traffic and revenue analyses prepare for the CRC were “not suitable” for credit analysis
    • CRC traffic projections were “confusing” and “outdated”
    • Authors of the traffic projections failed to examine historical data or verify their models against actual trends
    • Diversion estimates to I-205 were “worrying.”
    • Overall, the CRC appears to have overestimated traffic.

    4.  The CDM Smith Investment Grade Analysis:  FEIS Toll Traffic & Revenue Analysis Wrong

    In 2013, two years after the issuance of the Final Environmental Impact Statement and the Record of Decision, the Columbia River Crossing finally got the results of the Investment Grade Analysis (IGA) prepared by its consultants, CDM Smith. The Oregon and Washington Departments of Transportation paid CDM Smith more than $1.5 million to develop their traffic modeling for the Investment Grade Analysis.  The results were dramatically different than portrayed in the FEIS, and confirmed the flaws that the Bain report identified in the earlier modeling.  The CDM Smith report said tolls would have to be at least twice as high (a minimum of $2.60, rather than $1.35) and that the level of traffic that could be expected on the new widened I-5 bridge would be perpetually lower than that volume carried on the old I-5 bridge, because tolls would reduce and divert traffic. In short, the investment grade analysis confirmed what critics had been saying all along:  that a tolled bridge would need no more capacity than the existing structure.

    That history should be powerful proof to current decision-makers that they should insist on seeing an investment grade analysis before deciding on the size of the “replacement” bridge.  But project manager Greg Johnson obstinately told the Metro Council in January 2022 that the investment grade analysis would not be used to size the bridge.

    . . . the question regarding the investment grade traffic study. That’s one that we’re going to have our folks look deeply into as far as the timing, but I do want to want to correct a misnomer. That investment grade traffic study is not to size the bridge. What sizes the bridge is the data that we take from the regional models that are a part of Metro and RTC . . .

    Reflect for a moment what that means:  Johnson is saying he’ll disregard objective expert third-party information about how much money (and traffic) a tolled bridge will generate in deciding how big the bridge should be.  But economics and practical experience tells us a tolled bridge will have dramatically less traffic than the current structure.  Louisville, Kentucky’s tolled I-65 bridges, identical in many respects to the IBR, resulted in a 50 percent decline in traffic—and a huge revenue shortfall.  The IGA prepared for the Columbia River Crossing by ODOT’s own consultants, CDM Smith, said a tolled I-5 bridge would carry only about half as many vehicles when finished as did ODOT’s less sophisticated (and frankly, biased) models.

    Coast Guard Rejection of the low fixed spans

    Even with two independent external reviews that considered engineering, and a much trumpeted “Cost Estimate Validation Process” designed to catch and prevent risks, the project failed to adequately address a key issue:  navigation clearance.  A crucial element of any river crossing on a navigable waterway is allowing sufficient room for shipping traffic, a determination that is made by law,by the US Coast Guard.  The current I-5 bridges have a 178 foot river clearance under their lift span.  Then, as now, the state transportation departments are Ignoring or downplaying the Coast Guard’s sweeping authority to regulate bridge heights.

    A decade ago, with the CRC, ODOT and WSDOT willfully ignored early advice from the Coast Guard that a 95-foot navigation clearance would be insufficient.  As early as 2006, the Coast Guard signaled it would need 115 or 125 feet of navigation clearance; the CRC project decided on its own that 95 feet ought to be enough.  The two state DOTs attempted to bludgeon their way to Coast Guard approval, but since the USCG has clear and independent statutory authority to regulate all structures over navigable waterways, it held firm and in 2011, reached its own determination that the CRC would have to clear at least 116 feet.  That led to a year of delays and tens of millions in additional costs to re-engineer the bridge to have a higher clearance.  Importantly, this was not a risk that was identified or provided for in the projects schedule or cost management system, showing a clear failure to manage risks on this large project.

    The IBR seems hell-bent on repeating this blunder once again.  A Coast Guard preliminary determination has found that a new bridge over the Columbia needs to have a navigation clearance of 178 feet.  Despite the Coast Guard’s ruling, the project is proceeding with its proposal for a 116 foot navigation clearance, and steadfastly refusing to look at alternatives, like a moveable bridge span or a tunnel, that would enable a lower and far less expensive and disruptive crossing.  WSDOT and ODOT would like to pretend that the preliminary determination doesn’t really mean anything, but under the agreement between the US DOT and the Coast Guard, alternatives that don’t meet the preliminary determination are supposed to be excluded from further NEPA review.  When the two state DOTs disregard the 178-foot clearance determination, interagency agreement says they are “proceeding at their own risk.”

    Deja vu all over again

    The same errors that doomed the CRC are being repeated now by the Oregon and Washington transportation departments.  They’ve designed their bridge with a 116 foot clearance, assuming that this will meet approval by the Coast Guard.  But their USCG-bridge permit expired years ago, and they will need to apply for a new one, and go through an entirely new permitting process, which will likely end up mandating an even taller bridge—one that the project hasn’t considered.

    Even the IBR’s proposed 116′ high bridge poses major and as yet unanswered questions.  To reach that height, the bridge will require extremely steep approaches on the Oregon and Washington sides of the river.  In Oregon, the roadway grade exceeds the design standard for Interstate freeways, and will require an exception.  The steep bridge grades have led one local engineer to argue that the bridge will be particularly dangerous in icy weather.  The project calls for rebuilding every one of the seven closely spaced interchanges that cause congestion, contrary to federal design standards and the recommendations of the bridge review panel.  Unlike with the CRC, there hasn’t been any independent review of this design.

    The project has yet to produce a definitive financial plan.  The project hasn’t developed any contingency plans if one or more of the project revenue sources doesn’t materialize.  It hasn’t prepare a plan for project phasing.  In fact, the selected high bridge design may be difficult or impossible to phase, because the extreme height of the proposed new river crossing  will make it impossible to access the new structure from existing approach ramps.

    The project has no plans to undertake an independent, investment grade analysis of the project until 2025.  Just as before, the project mades optimistic assumptions about toll revenues—its current traffic forecast uses minimum tolls of $1.35—only half of what the 2012 CDM Smith Study said would be necessary to provide a $1.3 billion tolling contribution to the project’s finance plan.

    Now, as before, the project is proposing to rebuild every single interchange in the project area, even though outside experts (and their own problem statement) show that’s a substandard design approach that leads to traffic problems and needlessly increases the cost of the project.

    In many ways, the re-named IBR project is a scene-for-scene remake of the disaster film that was the Columbia River Crossing.  A key difference to date is that its controversial and questionable engineering, traffic forecasting and financial decisions simply haven’t been vetted by outside experts, as was done with the CRC.  The rush to move forward to a decision to select a “locally preferred alternative” without getting this kind of professional advice magnifies the risks that like its predecessor, the IBR project will also collapse when one or more of these unexamined risks strikes.

    Eyes wide shut

    The proposed IBR project is a big and risky endeavor.  What’s lacking is any independent verification of the assertions made by the project staff.  Last time around, with the Columbia River Crossing, state leaders took the prudent steps of asking a few basic questions before moving forward with the project.  They hired independent engineers and experts to assess the project design, budget, schedule and phasing.  They hired an international toll bond expert to study its traffic projections.  They conducted an investment grade analysis.  The federal government hired a “project management oversight consultant” to ride shotgun on the project.  With the IBR, none of these safety steps have been taken.

    Even the Legislature has been complicit in this failure to put in place basic safeguards and oversight.  In 2017, as part of its major transportation funding legislation, the Legislature created a “Megaprojects Task Force” and directed it to study and report on the state’s process for selecting and managing large projects.

    SECTION 121. (1) The Task Force on Mega Transportation Projects is established. For the purposes of this section, a “mega transportation project” includes transportation projects, as defined in ORS 367.010, that cost at least $360 million to complete, that attract a high level of public attention or political interest because of substantial direct and indirect impacts on the community or environment or that require a high level of attention to manage the project successfully.  . . . (11) The task force shall submit a report in the manner provided by ORS 192.245, and may include recommendations for legislation, to the Joint Committee on Transportation established under section 26 of this 2017 Act no later than September 15, 2018.

    The legislation set a September 2018 deadline for the Task Force to file its report, but the task force met only twice (after its deadline), never filed any report, and sunsetted, at the end of 2018.  It turns out that even the Legislature, which is expected to make up the shortfalls and pay for the overages when ODOT makes a mistake, isn’t willing to try and learn from past experience.  In the case of the $5 billion (and probably much more) Interstate Bridge Project, that could be a very expensive outcome.


    Bain Report, Bain_CRC_Report_July4

    Independent Review Panel Report IRP_Report_July30

    Bridge Review Panel Report

    CDM Smith ReportCDM_SMith_2013

    Coast Guard Bridge Permit

    Editor’s Note:  An earlier version of this commentary had incorrectly attributed appointment of the Independent Review Panel; it was appointed by Governor Ted Kulongoski.


    ODOT’s Reign of Error: Chronic highway cost overruns

    Nearly every major project undertaken by the Oregon Department of Transportation has ended up costing at least double its initial estimate

    As ODOT proposes a multi-billion dollar series of highway expansions, its estimates pose huge financial risks for the state

    ODOT refuses to acknowledge its long record of cost-overruns, and has no management strategy to address this chronic problem

    Costs are escalating rapidly for more recent and larger projects, indicating this problem is getting worse

    The Oregon Department of Transportation is proposing to move forward with a multi-billion dollar series of highway expansion projects in the Portland metropolitan area, including the $5 billion Interstate Bridge Replacement project, the $1.45 billion Rose Quarter freeway widening project, the likely $1 billion I-205/Abernethy Bridge/I-205 widening project and an as yet un-priced Boone Bridge project.  Collectively, these projects would be by far the most expensive infrastructure investment in department’s history.  But the quoted prices for each project are just the tip of a looming financial iceberg.

    A quick look at the agency’s history shows that it has invariably grossly underestimated the actual cost of the major projects it has undertaken in the past two decades.  Using data from ODOT’s own records and other public reports, we’ve compiled data on the initial project costs estimates (those quoted before construction commenced) and compared them with the latest estimates (either the actual final amount of spending in the case of completed projects, or the latest cost estimates for projects that have not yet been finished).  In every case, the ultimate price of a project was more than double the initial cost estimate.

    This is important because ODOT is asking for permission to undertake a series of highway expansion projects, which, once started, will create a huge financial liability for the state of Oregon.  For three projects (the I-5 Bridge Replacement, the Rose Quarter and the Abernethy Bridge I-205 widening), ODOT is planning to sell toll-backed bonds to pay for part of project costs.  But if toll revenues are insufficient to pay bonds, or if costs escalate beyond current estimates, the state is fully liable to repay all these costs, and debt service on bonds, and these payments will take precedence over all other expenditures from state and federal transportation funds.  The failure to accurately forecast project costs for Portland freeway expansions, coupled with an unavoidable obligation to repay bondholders means that all other state transportation priorities, including even routine maintenance, would be in jeopardy.

    Here is a closer look at seven major ODOT construction projects undertaken in the past twenty years.  Every one has experienced enormous cost overruns.

    The Interstate 5 Rose Quarter Freeway project would widen a 1.5 mile stretch of freeway in Portland and was originally represented to the 2017 Oregon Legislature as costing $450 million. The latest estimates from the Oregon Department of Transportation are that the project could cost as much as $1.45 billion.   

    The Legislature directed ODOT to prepare a “cost to complete” report for the I-205 Abernethy Bridge project.  The bridge connects Oregon City and West Linn, and would be widened and seismically strengthened.  ODOT’s 2018 report said the bridge would cost $248 million.  When the agency put the project out to bid in 2022, the actual cost came in at $495 million–essentially double ODOT’s estimate.

    ODOT estimated the 5 mile long Highway 20 Pioneer Mountain-Eddyville project would cost $110 million when the project completed its environmental reviews in 2003 (Federal Highway Administration and Oregon Department of Transportation. (2003). Pioneer Mountain to Eddyville US 20, Lincoln County, Oregon, Draft Environmental Impact Statement, Executive Summary).  After years of delay, and including a design-build contractor withdrawing from the project, and ODOT having to demolish bridge structures and redesign significant parts of the project, its total cost was $360 million.


    The Newberg-Dundee Bypass has been under consideration for almost two decades; a portion of the project was completed five years ago.  The initial estimate of the project’s total cost was $222 million (Oregon Department of Transportation. (2005). Newberg-Dundee Transportation Improvement Project Location (Tier 1) Final Environmental Impact Statement (News Release 06-132-R2).  The latest estimate of the cost of completing that full bypass project is now $752 million (Federal Highway Administration and Oregon Department of Transportation. (2010). Newberg Dundee Bypass, Tier 2 Draft Environmental Impact Statement (FHWA-OR-EIS-10-0-1D). Salem: Oregon Department of Transportation.

    In 2002, the Oregon Department of Transportation told the City of Portland that rebuilding the Grand Avenue Viaduct (Highway 99E) in Southeast Portland would cost about $31.2 million (Leeson, Fred, “Council Backs Long Bridge in Viaduct’s Spot”  Portland Oregonian, July 19, 2002) .  The project was completed seven years at a total cost almost three times higher:  $91.8 million (ODOT, ARRA Project Data for ODOTas of 8/31/2010) .

    When proposed in 1999, it was estimated that the I-5 South Medford Interchange would cost about $30 million  (Rogue Valley Area Commision on Transportation meeting notes, September 13, 2005).   In 2013, after the project was completed the agency said the cost was $96 million.


    The original cost estimate for the I-5 Woodburn interchange project was $25 million in 2006 (FHWA & ODOT, Woodburn Interchange Project, Revised Environmental Assessment, November 2006).  The completed price was $68 million.

    It’s always possible to make excuses for cost-overruns on any single project.  And if cost-overruns had happened only once, or maybe twice, it might make sense to dismiss them as aberrations.  But as the record of these seven projects makes abundantly clear, major ODOT highway projects almost invariably ending up costing twice as much as the original price quoted at the time the project is approved.  Cost overruns are a systematic and predictable feature of ODOT’s approach to highway building, not an aberrant bug.

    No Accountability for Cost Overruns

    In an attempt to quell concerns about the ODOT’s managerial competence, in 2015, Governor Kate Brown directed that the agency hire an outside auditor to examine its performance.  ODOT did nothing for the first five months of 2016, and said the project would cost as much as half a million dollars. Initially, ODOT awarded a $350,000 oversight contract to an insider, who as it turns out, was angling for then-ODOT director Matt Garrett’s job.  After this conflict-of-interest was exposed, the department rescinded the contract in instead gave a million dollar contract to McKinsey & Co, (so without irony, ODOT had at least a 100 percent cost overrun on the contract to perform their audit.)

    McKinsey’s work consisted mostly of interviews with agency-identified “stakeholders” and a superficial analysis of ODOT date.  Its report focused on largely meaningless or trivial indicators such as “average time needed to process purchase orders.”  One part of the report purportedly addressed the agency’s ability to bring projects on time and under budget.  McKinsey presented this graphic, showing the variation between initial and finished costs for a series of mostly small projects.

    There’s a striking omission, as revealed in the fine-print footnote:  McKinsey excluded data for the Highway 20 Pioneer Mountain Eddyville project.  This project, the single most expensive project that ODOT had undertaken, had a 300 percent cost-overrun, which the McKinsey report both failed to report correctly and which it described  as “performed 27 percent higher.”

    The Oregon Department of Transportation doesn’t accurately forecast the cost of its projects, and refuses to be held accountable for a consistent pattern of errors.  Relying on ODOT’s cost estimates exposes the state to enormous financial risk, something that is likely to be magnified as the department moves ahead relentlessly with plans for billions of dollars of freeway expansion projects in the Portland area.



    How ODOT & WSDOT are hiding real plans for a 10- or 12-lane I-5 Bridge Project

    Ignore the false claims that the Oregon and Washington highway departments are making about the number of lanes on their proposed I-5 project:  its footprint will be 164 feet—easily enough for a 10- or 12-lane roadway.

    This commentary was originally published at Bike Portland, and is re-published here with permission.

    If you followed Tuesday’s Portland City Council work session or have been reading press reports about the Interstate Bridge Replacement project, you’ve probably noticed claims that the size of the project has somehow been reduced to adding “just one auxiliary lane” in each direction to I-5. The implication is that they’re only building enough capacity to expand the existing I-5 bridge from its current six lanes (three in each direction) to eight lanes (three plus a so-called “auxiliary” lane in each direction).

    This claim is false.

    A close look at the materials prepared by the Oregon and Washington departments of transportation shows they plan
    to build a new I-5 bridge at least 164 feet wide — easily enough for ten or even twelve traffic lanes.

    A close look at the materials prepared by the Oregon and Washington departments of transportation shows they plan to build a new I-5 bridge at least 164 feet wide — easily enough for ten or even twelve traffic lanes. While the glossy materials describing the project prominently talk about “one auxiliary lane” (in each direction), they almost completely omit a description of the actual width of the bridge. The IBR documents show only crude and misleading cartoon-like drawings of the bridge, without any actual measurements. That’s intentional: because they don’t really want you to know how wide a structure they’re planning.

    But in a cryptic note in their presentation, they do refer to the width: The so-called ten lane bridge (two auxiliary lanes each direction) is said to have the same “footprint” as the 2013 Locally Preferred Alternative (LPA, a step in the federal NEPA review process). For the record, that footprint is 180 feet. For the so-called eight lane bridge (one auxiliary lane in each direction), the footprint is described as “2013 LPA Minus 16 Feet” which works out to 164 feet wide.

    The broader context is this: the so-called “bridge replacement” is really a five-mile long, ten or twelve lane wide highway widening project that will cost $5 billion, and potentially a lot more.

    ODOT’s actual plans for a 180′ wide CRC obtained by public records request.

    This is a repetition of the false claim made for the preceding project — the failed Columbia River Crossing (CRC). In 2010, in response to objections from the City of Portland and Metro, ODOT and WSDOT announced they were reducing the size of the CRC bridge from 12 lanes to 10 lanes. But in reality, all they did was change the references in the project documents to that number of lanes, while literally erasing from the Final Environmental Impact Statement every single reference to the actual widths of the bridges and other structures they intended to build. A public records request showed the actual plans for the bridges — which were not published — were exactly the same size (180 feet in width) as they were for the 12-lane version of the bridge.


    The limited materials released by the IBR project to date make it clear that they are engaged in exactly the same deception.

    With standard-width 12 foot wide freeway lanes, this 164 foot wide bridge would accommodate ten traffic lanes (120 feet), with 11 foot shoulders on either side of the travel lanes, or as many as twelve travel lanes (144 feet) with five foot shoulders on either side of the twelve travel lanes). (Alternatively, the 164 foot width would allow construction of 12 travel lanes with 2 foot wide left shoulders and 8 foot wide right shoulders, which would be common, if not generous for an urban bridge.)

    While they’re calling it an eight-lane bridge, it’s really a 10 or 12 lane bridge.

    ODOT and WSDOT will no doubt say they’re “only” adding two lanes, and point to the supposed safety benefits of wider shoulders; but nothing prevents them, after building a 164-foot wide bridge, from coming back with a paint truck and re-striping it for ten or twelve lanes. In fact, they’ll claim that they can do that without any further environmental analysis under a “categorical exclusion” to the US DOT claims to the National Environmental Policy Act.

    This isn’t an aberration or an accident, it’s an intentional strategy to evade environmental review: ODOT and WSDOT did this a decade ago on the failed Columbia River Crossing. It did the same thing with the I-5 Rose Quarter project, again claiming it was merely adding one auxiliary lane in each direction. Meanwhile its actual plans (which it kept secret and didn’t include in the Environmental Assessment) showed it planned to build the I-5 Rose Quarter project to be 160 feet wide, easily enough to accomodate 10 lanes of traffic.

    The highway builders know — though they refuse to admit — that more lanes induce more traffic and more pollution. That’s why they’re engaging in this highly deceptive process of claiming they’re just adding a single “auxiliary” lane, when in fact, they’re engineering structures that can be repainted in a day to be vastly wider. This subterfuge enables them to claim minimal environmental impacts now, and then with no further review, create exactly the wider roadway they wanted all along.

    Ten unanswered questions about the IBR Boondoggle

    In the next month or two, regional leaders in Portland are going to be asked to approve the “modified locally preferred alternative” for the I-5 Bridge Replacement (IBR) Project, an intentionally misnamed, $5 billion, 5 mile long, 12-lane wide freeway widening project between Portland and Vancouver, Washington.

    There’s a decided rush to judgment, with almost many of the most basic facts about the project being obscured, concealed, or ignored by the Oregon and Washington Departments of Transportation.  As with the failed Columbia River Crossing, they’re trying to pressure leaders into making a decision with incomplete information.  Here are ten questions that the IBR project has simply failed to answer.  We’ve offered our own insights on the real answers, but before the region’s leaders take another step, they should satisfy themselves that they know the real answers to each of these questions.

    1. How much will it cost?

    Conspicuously absent from IBR presentations is any clear statement of what the project is likely to cost.  Almost two years ago, the project released a warmed over version of the cost estimates from the Columbia River Crossing indicating the project could cost $4.8 billion.  But this estimate is based on an update of old CRC estimates, rather than a new, bottom-up cost estimate of the current project.  Already, the IBR team has decided to rebuild the North Portland Harbor bridge which will add an estimated $200 million to the project.  Moreover construction inflation has accelerated in recent months; bids for the Abernethy Bridge project in Portland came in almost 40 percent higher than forecast.  Similar cost overruns on the IBR would add more than $2 billion to the price tag.

    Real Answer:  The IBR is likely to be a $5-7 billion project

    2. Who will pay for it?

    Also missing from the IBR presentation is a definitive statement of the sources of funds to pay for the project.  For starters–and just for starters–the project says Oregon and Washington will each be expected to contribute $1 billion.  There’s a considerable amount of vague hand-waving about federal support, but most federal money in the Infrastructure bill is allocated by formula, and comes to the two states whether they build this project or not; and so spending this money on the IBR, rather than fixing the multi-billion dollar backlog of other bridge repairs, comes at a real cost to the states.  What is clear is that a third or more of the IBR’s costs will have to be recouped by charging tolls to bridge users, and that the two states, and no one else, will be on the hook for any cost overruns and any revenue shortfalls.  And cost overruns are hardly conjecture:  The I-5 Rose Quarter Freeway widening project, estimated to cost $450 million five years ago, is now likely to cost as much as $1.45 billion according to ODOT.

    Real answer:  Oregon and Washington have unlimited liability for project costs including cost overruns and toll revenue shortfalls.

    3.  How high will tolls be?

    IBR staff have said next to nothing about what level of tolls will be charged for bridge users.  Studies prepared for the Columbia River Crossing showed that tolls would have to be a minimum of $2.60 for off peak users and $3.25 for peak travel, plus surcharges for those who don’t buy transponders, which would push peak period car tolls over $5.00 each way.  Trucks would pay 5 times as much as cars, with peak period tolls topping $18.  Knowing what the toll levels will be is essential to understanding the economic impacts of the bridge, as well as accurately forecasting future traffic levels.  Experience in other states has shown that even an $1 or $2 toll could permanently reduce traffic to half of its current levels, eliminating the need to add any capacity to the I-5 crossing.  Before they move ahead with the project, shouldn’t the public and its leaders know how much will be charged in tolls?

    Real answer:  Tolls will be $2-3 each way, and highest at peak hours, costing regular commuters more than $1,000 per year.

    4  Will other bridges and highways be tolled to avoid gridlock?

    If just the I-5 bridges are tolled, ODOT and WSDOTs own consultants predict that this will produce gridlock on I-205.  IBR staff have made vague statements claiming to have looked at tolling other roadways at the same time.  But unless parallel routes like the I-205 are also tolled, the traffic claims made for the IBR are simply invalid.  If the region is serious about tolling and avoiding gridlock, it needs to adopt a comprehensive tolling strategy before it commits to a multi-billion dollar freeway widening project.

    Technical work done for the CRC project, reported on page one of the Oregonian in 2014, indicated that tolling I-5 would produce gridlock on I-5.  

    Tolling will dramatically affect the traffic levels on I-5 and I-205.  The best evidence is that tolling the region’s freeways would virtually eliminate the need for additional capacity expansion.  ODOT’s own congestion pricing consultants showed that a comprehensive system of road pricing would eliminate most metro area traffic congestion, without the need to spend billions on added capacity.  We know from experience in other cities that tolling after adding capacity simply leads to wasting billions of dollars on roadways that aren’t used because travelers don’t value them.

    Real Answer:  Unless we toll the I-205 bridge as well, the I-5 bridge will be under-utilized, and I-205 will have gridlock. The region needs to decide on a toll system before its squanders billions on un-need highway capacity, and goes deeply into debt to repay bonds for capacity that isn’t used.

    5. What will it look like?

    Despite spending more than two and a half years and tens of millions of dollars on designing the project, the IBR has yet to produce any renderings showing what the project would look like to human beings standing on the ground in Vancouver or on Hayden Island.  The bridge will be 150 feet tall as it crosses the Columbia River and will have lengthy approach ramps, and extensive elevated freeway sections over Vancouver and Hayden Island, with substantial visual and noise impacts.  But you would never know it from the project’s presentations, which if they show the bridge and freeway expansion at all, show it from an aerial view that could be seen only from flights over Portland International Airport.  The project’s presentation to a joint legislative committee in April contains no illustrations of what is to be built at all.

    City Observatory has obtained, via public records request, the 3D models created by IBR to show the size and location of the proposed I-5 Bridge.  The following image shows what the proposed I-5 bridge would look like, compared to the existing bridge.  It would be dramatically taller and wider, and would loom over downtown Vancouver.  It’s relatively easy to produce images showing how the replacement bridge would affect Vancouver.  Why hasn’t the IBR with its extensive budget produced any such images?

    Real Answer:  The I-5 replacement bridge and approaches will tower over downtown Vancouver and Hayden Island.

    6. How long will the trains take?

    A key part of the project is a plan to add light rail service between Portland’s Expo Center and downtown Vancouver.  The IBR project asserts that there will be huge demand for travel on light rail.  But light rail is relatively slow.  Unless light rail is faster than car travel or express buses, it’s unlikely to attract many riders.  Currently, Tri-Met’s Yellow line takes 29 minutes to get from the Expo Center to downtown Portland.  The CRC FEIS projected that it would take light rail trains about 6 minutes to get from Mill Plain Boulevard across a new I-5 bridge to the Expo Center; together this means it will take at least 35 minutes via light rail to reach downtown Portland from Vancouver.  That’s more than 10 minutes longer than it takes current C-Tran express buses, traveling in morning, peak hour traffic, to travel between 15th and Broadway in Vancouver to SW 5th and Alder in Portland—a 7:56 AM bus leaving Vancouver reaches downtown Portland at 8:20.  Also:  with added capacity on I-5 and tolling of I-5, future express buses would travel even faster than they do today, so light rail would likely be at an even greater time disadvantage than it is now.  The information provided by the IBR contains no explanation of how a slower train is going to attract more riders than a faster bus or why BRT would perform worse than LRT in this corridor.

    Real Answer:  The LRT extension to Vancouver will be considerably slower than today’s buses.

    7. How can traffic models predict more no-build traffic on a bridge that is already at capacity?

    The I-5 bridges reached capacity almost two decades ago, and can’t handle additional traffic, but ODOT’s model apparently predicts that traffic will continue to grow across the bride even though there’s no capacity.  This is a classic example of a broken model that in the words of national modeling expert Norm Marshall “forecasts the impossible.”  ODOT’s own consultants, CDM Smith, said in 2013 that the I-5 bridge could handle no more peak traffic due to capacity constraints:

    Traffic under the existing toll-free operating condition on the I-5 bridge reached nominal capacity several years ago, especially considering the substandard widths of lanes and shoulders on the facility. The I-5 bridge has little or no room for additional growth in most peak periods, and capacity constraints have limited growth over the last decade.

    The IBR’s own modelers admitted that traffic growth on I-5 has been limited due to the bridge being at capacity and congested.  Yet they’ve created a fictitious “no build” scenario in which traffic continues to increase, essentially because it has no meaningful feedback loops to adjust travel demand to reflect how humans actually respond in the face of congestion.

    Real Answer:  ODOT is using flawed models that overstate no-build traffic and pollution, and conceal the true environmental impact of freeway expansion

    8. How wide will the bridges be?

    The IBR team describes the I-5 Bridges adding either two or four so-called “auxiliary lanes” to the existing six freeway lanes on I-5 through the project area.  But the project hasn’t revealed how wide the structures are that its actually building.  In the project’s last iteration, the “Columbia River Crossing”, the project said they reduced the size of the bridge from twelve lanes to ten in response to objections to its width from local leaders, but in fact, public records requests showed that they didn’t reduce the physical size of the bridges (or other structures) at all.  The supposed “ten lane” bridge was 180 feet wide, just as was the proposed “twelve lane” bridge.

    The cryptic information provided by the IBR says that its so-called 10-lane bridge would be just as wide as the CRC (180 feet), and the so-called 8 lane bridge (“one auxiliary lane”) would be just 16 feet narrower (“2013 LPA Minus 16 Feet”), which works out to 164 feet wide.  With standard-width 12 foot wide freeway lanes, this 164 foot wide bridge would accommodate ten traffic lanes (120 feet), with 11 foot shoulders on either side of the travel lanes, or as many as twelve travel lanes (144 feet) with five foot shoulders on either side of the twelve travel lanes).  (Alternatively, the 164 foot width would allow construction of 12 travel lanes with 2 foot wide left shoulders and 8 foot wide right shoulders, which would be common, if not generous for an urban bridge).

    When it comes to bridges or freeway capacity, ignore how many “lanes” ODOT and WSDOT claim they’re building, and look at how wide the structures are.  They’ve repeatedly used this deceptive tactic to intentionally conceal the true width and environmental impact of their projects.

    Real Answer:  Regardless of how many lanes IBR claims its building, its actual plans provide capacity for more, in this case a 10 or 12 lane bridge.

    9. How many cars will use the bridge?

    The primary argument for the IBR is that it is needed to carry a growing number of vehicles crossing the Columbia River.  But completely absent from any of the project’s materials is any specification the volume of traffic the bridge will carry.  The project makes claims about travel times and traffic delay, but can’t possibly have come up with those estimates without coming up with estimates of the number of cars that will use the bridge.  It specifically suppressed this information to undercut the public’s ability to understand–and ask questions about and criticize the modeling.  And we know that the project’s earlier modeling done for the Columbia River Crossing was simply wrong.  It predicted that traffic would grow by 1.7 percent per year on I-5 between 2005 and 2030; in fact, through 2019, traffic grew by only 0.3 percent per year.   This chart shows the average daily traffic on I-5 as predicted by the CRC (blue: no-build, red build) and actual, from ODOT’s own traffic records (black).  We can’t see how IBR’s new modeling compares to these figures, because they’ve simply refused to publish any average daily traffic totals.

    The models used by IBR systematically over-estimate travel in the No-build scenario and underestimate, if not completely ignore, the additional traffic induced by adding more lanes.  It’s impossible to assess the project’s claims about traffic performance, environmental impacts, or financial viability with out transparent and accurate estimates of the number of vehicles that will use the bridge.

    Real Answer:  IBR uses flawed models which overstate the need for freeway capacity to justify un-needed and expensive freeway widening.

    10. How will a wider freeway reduce carbon emissions?

    The IBR material makes the specious claim that it will result in lower emissions, based on the false claim that decreasing traffic congestion will reduce vehicle idling in traffic, and that the bridge will have a higher share of transit passengers (something which it cannot explain–see #6 above).  The RMI Shift induced travel calculator estimates that adding lanes to the I-5 bridge could increase greenhouse gas emissions hundreds of thousands of tons per year.

    Real Answer:  Expanded freeway capacity leads to more driving and more greenhouse gas emissions.

    What are they hiding? Why highway builders won’t show their $7.5 billion freeway

    Oregon and Washington are being asked to spend $7.5 billion on a giant bridge:  Why won’t anyone show pictures of what it would look like?

    The Oregon and Washington highway departments are using an old Robert Moses trick to make their oversized bridge appear smaller than it really is.

    The bridge will blot out much of the reviving waterfront and downtown in Vancouver, and put Hayden Island in the shadow of a half-mile long viaduct.

    The IBR has distributed misleading and inaccurate images of the proposed bridge, attempting to make it look smaller.

    The agency is spending $1.5 million to create a “digital twin” computer model of the IBR, but is keeping it secret to avoid public scrutiny of its design.

    Computer visualizations, complete with human-scale animations, are cheap and common for construction projects, such as Vancouver’s proposed waterfront public market–but ODOT and WSDOT have steadfastly refused to provide such visualizations for the IBR.

    The proposed Interstate Bridge Replacement Project would be the largest and most expensive public works project in the Portland metro area’s history.  You’d think that if you were spending $7.5 billion, you’d be proud to show the public and elected officials what it will look like.  But in the case of the IBR, you’d be wrong.  What do the Oregon and Washington highway department’s have to hide?

    While the IBR project has only released distant aerial photos that make the project look tiny, we obtained a copy of a preliminary version of their 3D computer model, and used it to show how the view from Hayden Island changes with the construction of the new bridge.  (You can use the slider to show how the view changes between the current bridge (on the left) and the proposed IBR (on the right).

    The striking difference in the height and scale of the two bridge images shown above contrasts sharply with the official image crated by IBR from the same digital model.  They use the well-worn trick of showing the bridge, not from anywhere on the ground, or where humans are likely to see it, but from a point suspended in the sky, high above the project.

    The very, very short and small Interstate Bridge Replacement.

    You’d have to be several thousand feet in the air to get this view of the IBR.  This false perspective makes the bridge look tiny.  It’s simply impossible to compare the height of the bridge, for example, to the height of buildings in downtown Vancouver, or get a sense of how much taller the freeway viaducts across Hayden Island are than any of the other structures on the island.

    Blotting out the Vancouver waterfront

    The proposed bridge will have a river clearance of at least 116 feet—the Coast Guard is asking for 178 feet—and the structure itself is a double-decker that will be between 35 and 40 feet tall, making the overall structure roughly 150 feet tall over much of the river.  Because of that elevation, the bridge requires half-mile long viaduct approach ramps to get traffic from ground level north and south of the river, up to the high level of the crossing (the lengthy viaducts and elevated intersections are more costly than the bridge itself).  This giant structure will tower over the Vancouver waterfront, which in the past decade has been the site of a remarkable urban redevelopment, with offices, shops, housing, and hotels.

    Yet ODOT and WSDOT, who’s massive project will completely remake this part of the city has yet to provide a single illustration showing how the city would be affected.  Again, using the IBR’s crude digital model, we were able to produce this image showing how the view along Vancouver’s riverfront will change if the IBR is built.

    Just as a point of reference for local residents, the proposed IBR river crossing will be the size of three of Portland’s I-5 Marquam Bridges side-by-side.  The massive new IBR bridge will tower over the waterfront, with associated noise and pollution.  In addition, the viaducts leading to the bridge will be as high, and in some cases higher than adjacent downtown and waterfront buildings.  Seattle just spent more than a decade and $3 billion to remove the Alaskan Way viaduct that blighted the city’s waterfront for more than half a century.  Vancouver appears to be signing up to create the same kind of roadway scarred landscape that Seattle is trying to fix.

    Using manipulated drawings to make the new bridge look smaller

    The IBR project has purposely avoided providing an elevation, or profile view of the proposed bridge, in order to keep its height and bulk a secret. But a year ago, it did produce a profile drawing, but one that was purposely inaccurate.   In March, 2022, when IBR as part of a navigation report with the US Coast Guard’s bridge permitting process, it produced an intentionally misleading drawing comparing the existing bridge and the new IBR.  The image was dutifully published by the Vancouver Columbian (March 25, 2022):

    Original drawing: IBR project. As published in the Columbian, March 25, 2022). Yellow annotations: Bob Ortblad.

    The diagram of the navigation clearance of the new bridge and old bridge, shown one-over-the-other uses different vertical scales to make the new bridge appear smaller and shorter than the old bridge.  See this from CRC (yellow markings and red text are added by Engineer Bob Ortblad).  The broad yellow band superimposed on the top diagram shows the true height and size of the new bridge.  Notice that the top panel says “not to scale” and while the diagrams use the same horizontal scale, they use different vertical scales.  This is intentional distortion.

    A $1.5 million “digital twin”

    This agency has no need of crude, not-to-scale drawings.  It has detailed plans, and what’s more, buying a state-of-the-digital model of the bridge. IBR is spending $1.5 million to build a so-called “digital twin“—a deeply detailed computer model of every aspect of the proposed bridge, that will be used for design, construction, monitoring and maintenance.  What, you might reasonably ask, is a digital twin?  It’s not a mere computer model, it’s really much more complicated (and expensive) than that.  IBR explains:

    A digital twin, as envisioned in this project, is a portal (a 3D model of the bridge and other associated visual dashboards), through which authoritative data and information about the bridge and related road network can be accessed efficiently and quickly by authorized users along its entire lifecycle—from early project planning to real time operations. It is expected to not only serve as a digital record of the physical structure but also as a process twin whereby future “what if” scenarios related to design decisions, constructability, construction or maintenance activities, emergency operations, etc. can be simulated to a very high degree of precision

    The contractor IBR hired to build the “digital twin,” WSP, touts its modeling as being an example of the “metaverse,” essentially a digital alternate reality:

    Also today, we can use IoT and artificial intelligence [AI] to add data to visualizations and make decisions across departments; we can put ourselves inside of the virtual model of a city, for example, and interact with it—a process now called the metaverse; we can better relate the design to the context of the world around us We can test and validate elements of infrastructure—bridges, roadways, transit, and buildings—before construction;. we can create dynamic models that simulate and predict how these assets will perform in real-life contexts. Three-dimension reality models provide the basis for visualizing, collaboratively managing, and monitoring changes to infrastructure during the project and when the asset is in operation. (Emphasis added)

    WSP has been working on the digital twin of the IBR for nearly three years, since at least June, 2020, according to company documents.  WSP’s software vendor, Bentley, also flogs the IBR digital twin work in its promotional material, saying modeling tasks that formerly took months and months to do, can now be done instantly. In theory, the “digital twin” ought to be a way for the public to see exactly what the project will look like, from any angle,  It is fully possible with such a model to create realistic, on-the-ground images and “walk throughs” of the project that convey exactly what it will look like.  But that’s just a theory, because IBR has explicitly chosen not to create or share such images or visualizations with the public.

    The digital twin is a secret

    But IBR is doing its best to keep the “digital twin” and the images it would show of the IBR project a secret.  At a March 16, 2023 meeting of a construction industry group in Seattle, IBR’s consultant, WSP, admitted that they were being told to keep the project under wraps so as not to provoke public outcry about the design:

    Last night at Construction Management Association of America NW Chapter meeting Kevin Gilson, Director of Design Visualization at WSP USA, presented 3D/4D modeling. When he was asked about a 3D model for the Interstate Bridge Replacement (IBR), he said “Yes, but it isn’t public yet. There is a model on the website. It’s being produced by the communications team. There is a very detail 3D model. I was going to try and show it, but I am not working on that project. It’s very, very, it’s kept under wraps quite a bit, and I think it’s because of their experience with the first round, trying to tread carefully.”

    Personal communication from Bob Ortblad, who attended this meeting, March 17, 2023 (Emphasis added).

    City Observatory has filed a public records request to obtain a copy of the model.  IBR officials have declined to provide that model until no earlier than the end of April, 2023.

    Concealing images of the proposed giant bridges is a calculated PR strategy

    The Interstate Bridge Project has contracted for nearly $10 million in public relations and communications consultants, and they’ve kept a tight lid on project images. A little over a year ago, the IBR project showed its first sketchy images of what the IBR project might look like.  At the time, one of their public relations consultants, Millicent Williams, described the project’s desire to control the dissemination and interpretation of the images:

    Thank you, Commissioner Berkman.  I will share that the communications team has discussed,  first of all the fact that once images like this get shared, there will be the opportunity for people to develop a narrative and we’re working to manage that— making direct contact with media outlets to ensure that they have the accurate information and are clear about what these images represent.  Additionally we have asked that disclaimers drafts watermarks all the things that could make sure that folks know that this is not final.  This is concept.

    We recognize that there is the possibility that someone might have taken a screenshot of what we just shared and so hopefully, um, we can manage that messaging as well,  and i’m sure that the team is prepared to do that but um that those are things that we’ve thought long and hard about because we want to make sure that we are not stymieing the process or the progress based on our failures to fully disclose where we are in the process and what these images represent.

    IBR Executive Steering Group, January 20, 2022 (at 39:54)

    Much smaller projects have sophisticated visualizations

    Computer graphic simulations of new buildings and construction projects are commonplace—often as a sales and promotion tool.  Developers want to let potential investors and local governments know what a project will look like before it gets built.  That’s exactly what’s happening on the Vancouver waterfront—just not for the IBR project.  The Port of Vancouver is building a new public market building—its take on Seattle’s Pike Place Market—at Terminal One (site of the now demolished Red Lion Hotel).  The port’s architects prepared a detailed model of the public market building and the surrounding area, complete with a video “fly through” showing what the area will look like when the project is complete in a couple of years.  You can even see the current I-5 bridge in their computer video.

    The Vancouver waterfront in a computer rendering showing a forthcoming public market–but not the proposed $7.5 billion IBR. (Youtube: Click image to view video)

    The total cost of the public market is on the order of $10 million—roughly the same as what the IBR project has spent on public relations in the past few years.  Yet even though the IBR will cost about 750 times as much, and has such a copious budget for communication, it has not produced a comparable computer rendering, much less a human-level fly-through of the project.

    Ironically, the public market modeling doesn’t include the new Interstate Bridge, which will slice through and tower over the Vancouver waterfront.  It will likely go right over the top of this particularly bucolic native garden:

    Computer rendering of Vancouver’s forthcoming Public Market site: “Native plantings throughout bolster the project’s connection to the environment. . . The site’s design was guided by LEED-ND requirements.”  No mention that a 180-foot wide concrete freeway will tower ten stories above the garden.

    The Columbia River Crossing images were hidden as well.

    Hiding the images of what they are planning to build has been going on for more than a decade.  In 2010, Columbian reporter Eric Robinson wrote a front page story for the Vancouver paper, noting that the project had done virtually nothing to show the visual impact of the giant new bridge on downtown Vancouver and its waterfront.  He wrote:

    Stand for a minute along Columbia Street near the railroad berm in downtown Vancouver.

    Now look up.

    A massive steel and concrete structure that today exists only in technical engineering schematics will materialize high above Vancouver’s riverfront within the decade if the proposed Columbia River Crossing sticks to its current schedule. The Interstate 5 bridge will deliver thousands of cars, heavy trucks and light rail trains into the city at roughly the height of an eight-story building.

    Washington-based bridge architect Kevin Peterson is appalled.

    “It looks like a big damn freeway crossing a railroad staging yard,” he said.

    Vancouver Mayor Tim Leavitt acknowledged the new bridge will cast a long shadow.  . . . 

    “It’ll be a monumental structure,” he said.

    Yet, you’d scarcely know it by the tenor of public discussion.

    Robinson, Erik, “Casting a long shadow.” Columbian; Vancouver, Wash. 01 Aug 2010: A.1.

    City officials asked for a ground-level eye-view of the project, but were told it would be too expensive, and no renderings were produced. CRC official Carley Francis (now Southwest Washington WSDOT regional administrator), told Robinson that there was no guarantee they’d produce a street-level simulation of project before construction began in 2012, chiefly because the project—which at the time had spent about $134 million on planning—had “limited resources” to produce such a rendering.

    Jonathan Maus, writing at Bike Portland (in 2013), reported much the same when he tried to find realistic and detailed images of the multi-billion dollar bridge project, as Oregon and Washington were being asked to fund the project:

    You’d think that with all the support for the Columbia River Crossing down in Salem, lawmakers and their constituents would have a good idea about what their votes — and their tax dollars — will be going toward. But for some reason, CRC and ODOT staff have hidden the project from public view. Despite spending nearly $170 million on consultants and planning thus far, detailed renderings and/or visualizations of key elements of the project are nowhere to be found.

    This is not typical of other large infrastructure projects across the country and it begs the question of whether or not CRC and ODOT staff are purposefully pulling the wool over our eyes. (emphasis added)

    Our own work at City Observatory shows that the two state DOTs have been going out of their way to conceal what they’re planning to build, and to avoid showing how it will affect downtown Vancouver. For example, it took a public records request to learn that after promising to reduce the width of the CRC highway bridge from 12 lanes to 10 lanes, all the two DOTs did was erase all the references to the actual physical width of the bridge from the project’s environmental impact documents, while leaving in place plans to build a 180 foot wide highway bridge–enough for 12, or even 14 14 travel lanes.

    At one point, the Oregon and Washington highway departments actually built a physical 3D model of the bridge.  Photographs of the model were published by a local television station.  But there are no photographs or other evidence of this physical model on the IBR or CRC websites.

    A physical model of the Columbia River Crossing (now disappeared). This is the original shorter 95′ vertical clearance version of the bridge, not the final 116′ clearance. (KGW)

    The Long History of Using Misleading Images to Sell Urban Highways

    Using this kind of illusion  and creatively mis-representing the visual impact of a new construction has a long history in the world of selling highways. Robert Moses famously skewed the illustrations of his proposed Brooklyn Battery Bridge (which would have obliterated much of lower Manhattan and Battery Park); we turn the microphone over to Moses’ biographer Robert Caro, from The Power Broker:

    Moses announcement had been accompanied by an “artist’s rendering” of the bridge that created the impression that the mammoth span would have about as much impact on the lower Manhattan Landscape as an extra lamppost. This impression had been created by “rendering” the bridge from directly overhead—way overhead—as it might be seen by a high flying and myopic pigeon. From this bird’s eye view, the bridge and its approaches, their height minimized and only their flat roadways really visible, blended inconspicuously into the landscape. But in asking for Board of Estimate approval, Moses had to submit to the board the actual plans for the bridge. . . .

    The proposed bridge anchorage in Battery Park, barely visible on Moses’ rendering, would be a solid mass of stone and concrete equal in size to a ten-story office building. The approach ramp linking the bridge to the West Side Highway, a ramp depicted on the rendering as a narrow path through Battery Park, would actually be a road wider than Fifth Avenue, a road supported on immense concrete piers, and it would cross the entire park—the entire lower tip of Manhattan Island—and curve around the west side of the island almost to Rector Street at heights ranging up to a hundred feet in the air. Not only would anchorage and piers obliterate a considerable portion of Battery Park, they—and the approach road—would block off much of the light not only from what was left of the park but also from the lower floors of every large office building they passed; because the approach ramp was really an elevated highway that would dominate the entire tip of Manhattan, it would depress real estate values throughout the entire area.

    Sprawl and Tax Evasion: Driving forces behind freeway widening

    Sprawl and tax evasion are the real forces fueling the demand for wider freeways

    Highway widening advocates offer up a  a kind of manifest destiny storyline: population and traffic are ever-increasing, and unless we accommodate them we’ll be awash in cars, traffic and gridlock.  The rising tide of cars is treated as a irresistible force of nature.  But is it?  Look more closely and its apparent that rising traffic levels aren’t inevitable, they’re the product of other forces.  And far from solving traffic problems, widening roads makes these problems worse.

    In the case of Portland’s proposed $5 billion 5-mile long freeway widening project—the mis-named Interstate Bridge Replacement project—the real forces behind the project aren’t pre-destined levels of car traffic, but instead, are much more prosaic, and questionable:  sprawl and tax evasion.

    Sprawl:  Cause and consequence of wider roads

    While Oregon has some of the tightest land use controls in the nation, Washington State is still far more accommodating to rural and exurban residential development.  As many critics of the I-5 bridge project have noted, precious few commuters from Washington State to jobs in Oregon use transit, despite the fact that their are good express bus services from Vancouver to Oregon job centers.  (Prior to the pandemic, express buses carried only about 3,000 people per weekday between Oregon and Washington, compared to more than 250,000 vehicles per day crossing the river). A key reason for this auto-dominated travel pattern is that housing growth in Clark County has been driven by exurban sprawl, and workers commuting from these locations travel overwhelmingly by car.  Here’s a map prepared by Seattle’s Sightline Institute showing the comparative patterns of population growth in the Oregon and Washington portions of the metropolitan area between 1990 and 2000.  While Oregon has had little population growth outside its urban growth boundary–a testament to the policies effectiveness–Washington has experienced a rash of exurban development.

    Sightline Institute

    This exurban sprawl is both the source of demands for expanded highway capacity on I-5 and elsewhere, and in turn, widening roads simply encourage more such sprawl—a pattern that is repeated in metropolitan areas across the country.  The technical analysis done for the proposed Columbia River Crossing (predecessor of the IBR) estimated that 93 percent of the growth in peak hour trips on I-5 between 2005 and 2030 would result from additional population growth in the suburban fringe of Clark County (i.e. even more purple dots).

    Tax evasion fuels traffic growth

    While sprawl is one contributor to traffic growth, a second is tax evasion.  Here’s the short story:  Oregon has no retail sales tax; Washington charges its residents one of the nation’s highest rates (over 8 percent).  As a result, Washington residents regularly drive across the Columbia River on one of two Interstate Bridges to shop tax-free in Oregon.  They spend over $1.5 billion per year in Oregon, and effectively evade more than $120 million in sales taxes by doing so.  The average Clark County family of four evades about $1,000 of sales tax each year.

    But all these sales tax evasion produces a lot of traffic on the two bridges that cross state lines:  We estimate that between 10 and 20 percent of all the trips crossing the I-5 and I-205 Columbia River bridges are Southwest Washington households driving to shopping centers in Oregon to evade Washington sales tax.  Conveniently, there are major shopping centers at Jantzen Beach and Hayden Meadows (on I-5) and on Airport Way (I-205), both just across the Columbia River into Oregon.   The parking lots of these retail centers are chock-a-block with Washington vehicles.

    Jantzen Beach Home Depot parking lot (City Observatory)

    Far from being inexorable and inevitable forces of nature, the factors driving the growth of traffic between Portland and Vancouver are actually symbolic of dysfunctional and environmentally destructive trends.  Rather than accommodating them, and encouraging more sprawl and tax evasion, we should be making choices that are consistent with our stated values.

    A Universal Basic income . . . for Cars

    California is the first in the nation to establish a Universal Basic Income . . . for cars

    One of the most widely discussed alternatives for tackling poverty and inequality head-on is the idea of a “Universal Basic Income”—a payment made to every household to assure it has enough for basic living expenses.  While there have been a few experiments and a lot of political hyperbole, it hasn’t really been tried at scale.  But now, California is on the verge of enacting a Universal Basic Income, but instead of being for people, it’s for cars.

    It’s a symptom of our deep car dependence thant faced with somewhat higher gas prices (still lower, in inflation-adjusted terms than a decade ago), politicians are falling all over themselves to insulate cars and driving from their real costs.  It speaks volumes that we’re so quick to allocate resources to cars and so reticent to have similar energy when it comes to tackling poverty.

    High gas prices are a potent political issue for car-dependent Americans, and that’s prompted elected officials to scramble to come up with ways to ease the pain.  California Governor Gavin Newsom has proposed giving California car-owners a $400 debit card for each car they own, at a total cost of an estimated $9 billion.  It’s effectively a universal basic income (UBI), but for cars.

    In an ironic parallel, the City of Oakland is reporting the results of its own recent experiment with a kind of UBI for transportation.  Oakland gave $500 households $300 debit cards that they could spend on a range of transportation services, like bus travel, bikes, scooters and ride-hailed trips.  They then surveyed participants to see how their travel patterns changed.  Overall, about 40 percent of participating households reported reducing their single occupancy car trips.  The idea of a flexible transportation allowance is great way to directly address the equity concerns of our transportation system, especially as we begin using road pricing as a way to make the transportation system function more efficiently.  But it’s striking that while a universal basic mobility allowance merits only a tiny and tentative $150,000 experiment, a universal car allowance worth nearly $10 billion is likely to move forward with little, if any consideration of its social and environmental effects.

    Other states have taken a different approach to reducing transport costs, with a similar car bias.  New York Governor Kathy Hochul is proposing a gas tax holiday (which may or may not save motorists money, depending on whether oil companies pass along the savings to customers).  Of course, the cost of paying for maintaining the state’s roads will just be shifted to others, so the savings mostly an illusion.

    There’s a good argument that Newsom’s debit cards directly undermine the state’s climate goals, especially by handing out money based on the number of cars a household owns. Both the California and New York plans give fiscal relief to car owners.   You have to own a car to get a California debit cards, and somewhat perversely, households with two cars (who tend to have higher incomes) get twice as much relief as families with a single car.   But the incentive effects of the tax cut are even worse than California’s debit card approach:  people will save in proportion to how much gas they buy.  Those who don’t drive much, drive fuel efficient vehicles, or who don’t own or drive cars at all, will get no relief.  The big winners will be those who own fuel inefficient vehicles and drive a lot.  At least with the California debit card approach, families don’t have to buy more gasoline to get more relief.  They can spend the $400 on anything else they like, including for example, a bus pass or part of the purchase price of a new bike.

    Gas tax holidays and California’s universal basic income policy for cars are emblematic of the fundamental inequity of our current transportation policy.  Measures, like a universal basic mobility allowance, which would help those most in need and incentivize more sustainable transportation are subject to protracted experimentation at trivial scale.  Meanwhile, rising gas prices prompt sweeping and ill-considered policies that will send most benefits to those who drive the most, and which will further incentivize more driving and environmental destruction.

    Flying blind: Why public leaders need an investment grade analysis

    Portland and Oregon leaders shouldn’t commit to a $5 billion project without an investment grade analysis (IGA) of toll revenues

    Not preparing an IGA exposes the state to huge financial risk: It will have to make up toll revenue shortfalls, 

    The difference between an IGA and ODOT forecasts is huge:  half the traffic, double the toll rate.

    There’s no reason to delay preparing the investment grade analysis:  The federal government and financial markets require it, and all of the needed information is available

    If you don’t prepare an IGA before making a commitment to this project, you are flying blind


    Portland are a leaders are being asked to greenlight the so-called Interstate Bridge Replacement Project, which is projected by its proponents to cost as much as $5 billion.  But they’re being asked to give a project a go-ahead with only the sketchiest financial information.  The project’s cost estimates are slightly warmed over versions of decade old estimates prepared for the failed Columbia River Crossing.  Ominously, the details of where the money will come from—who will pay and how much—are superficial and vague.

    One thing project advocates grudgingly admit is that the I-5 bridge replacement can’t be financed without tolls.  Program administrator Greg Johnson and Oregon Transportation Commission Chair Bob Van Brocklin have repeatedly said as much.  But how much money tolls will produce and how high tolls will be are never clearly mentioned.  Johnson has said tolls will provide “about a third of project costs.”

    Knowing how much money tolls will produce, and how high tolls will have to be to produce that revenue is the central financial question.

    Currently the I-5 bridge carries about 130,000 vehicles per day.  But that volume is predicated on the bridge being free.  Charging people to use the bridge would dramatically reduce the number of crossings.  As we’ve documented at City Observatory, when tolls were added to a similar crossing, the I-65 bridges across the Ohio River in Louisville, traffic levels fell by half.

    Because tolling depresses traffic, you can’t accurately estimate how much toll revenue a bridge will produce without a detailed model that accounts for this traffic depressing effect.

    The models routinely used by state highway departments don’t accurately account for the effect of tolling on traffic volumes.  They tend to dramatically over-predict the amount of traffic on tolled roadways, which has led to over-built facilities that don’t generate enough toll-paying traffic to cover their costs.

    Financial markets and the federal government, who are asked to loan money up-front (with a promise to be repaid by future tolls) simply refuse to believe state highway department traffic forecasts.  Instead, they insist that states pay for an “investment grade” traffic and revenue forecast.  You can’t sell toll-backed bonds on private financial markets, and you can’t even apply for federal TIFIA loans, without first getting an investment grade forecast.  In January, Portland’s Metro Council adopted a statement of Values, Outcomes and Actions governing the I-5 project, directing the Oregon Department of Transportation to prepare an Investment Grade Analysis of the project:

    As the part of the finance plan, engage professionals with expertise in financing massive complex transportation infrastructure construction projects to conduct and deliver the results of an investment-grade traffic and revenue study of the design options.

    That’s a critical step to making and informed decision.

    What is an investment grade analysis?

    Investment grade forecasts are generally prepared by one of a handful of financial consulting firms.  These studies start with the traffic models used by state highway departments, but make much more realistic assumptions about future population and employment growth, the likelihood of economic cycles, and critically, the effect of tolling on levels of traffic.  As a result, investment grade analyses invariably predict lower levels of traffic that the models used by state highway departments.  Because traffic levels are lower, tolls have to be higher to produce any given amount of revenue.

    And the differences between investment grade analysis and highway department forecasts are not trivial:  they are huge.  The Oregon and Washington highway departments prepared traffic and toll estimates for the Columbia River Crossing’s Final Environmental Impact Statement published in 2011.  Those estimates were that the I-5 bridges would carry 178,000 vehicles per day in 2030, and that minimum tolls would be $1.34 to pay for about one-third of the cost of the project.  The Investment Grade Analysis for this project, prepared by CDM Smith on behalf of the two agencies in 2013 estimated that in 2030, the I-5 bridges would carry just 95,000 vehicles per day in 2030, and that tolls would be a minimum of $2.60 each way in order to cover a third of project costs.  In short, the initial highway department estimates overstated future traffic levels by double, and understated needed tolls by half.

    The starkly different figures in the investment grade analysis called into question the size of the project, which was predicated on the exaggerated highway department forecasts.  If a tolled bridge would carry dramatically fewer vehicles than the existing bridge, there was no justification for building an expensive wider structure and approaches.  The money spent expanding capacity on the bridge would be wasted because fewer vehicles would use it.  Also, the dramatically different traffic figures also meant that the environmental analysis contained in the FEIS was simply wrong.

    Investment Grade Analyses are required for financial prudence

    The reason that the federal government and financial markets insist on the preparation of an investment grade analysis is so that they don’t get stuck holding the bag when traffic levels, and toll revenues fall short of the excessively optimistic expectations of state highway departments.  Around the county dozens of toll roads and bridges have failed to produce expected revenues, leading to delinquencies, defaults, and bankruptcies.

    If anything, state lawmakers have an even larger financial stake in the IBR project than do financial markets or the federal government.  Financial markets, for example, will insist on additional state guarantees, besides repayment just from the stream of toll revenues.  They’ll require states to pledge other revenues to repay bonds, in addition to insisting on the investment grade analysis.  The 2021 Oregon Legislature passed HB 3055, which authorizes ODOT to pledge state gas tax revenues and future federal grant monies to repay holders of state-issued toll bonds.

    Because the state is ultimately liable for any toll-revenue shortfalls, it has an even higher stake than private lenders or the federal government  in knowing the true level of future toll revenues as would be disclosed in an investment grade analysis.

    Why ODOT doesn’t want the public to see the IGA first

    ODOT and WSDOT are greatly resisting calls to prepare an investment grade analysis.  Their current project schedule doesn’t call for conducting the analysis until 2024 or 2025–well after the design of the bridge is settled and too late to consider a smaller or cheaper alternative.  The highway departments variously claim that its “too expensive” or “premature” to carry out the IGA.

    There’s no technical reason it can’t be prepared now.  The base transportation data have been gathered, and the regional model exists.  The agencies say the IGA is expensive, but it’s far less costly than what the agency has spent already on public relations, and the money has to be spent anyhow.  And the IGA will continue to be valid for several years—and can easily be updated once it is complete, if that becomes necessary.  You can’t save any money by delaying.  The only real reason to put off preparing an IGA is because it will show that the IBR will carry vastly less traffic than the DOTs predict, and that tolls will have to be much higher than they’re implying.  In short, the DOTs don’t want the IGA because it will present a definitive case against the over-sized project that they’re building.  Financial markets and the Federal government will insist on the IGA before they make their decision:  the only ones being denied access to this vital financial information are local leaders and state lawmakers who will have to pay for the project.  According to DOT plans, they’ll find out the results of the IGA only after it’s too late to do any good.

    Their plan is clearly to convince local and state leaders  irrevocably commit to the construction of a much larger project than could possibly be  justified it anyone saw the results of the investment grade analysis.  It’s obvious from the project’s unwillingness to do anything other than advance a single alternative (a 164-foot wide bridge, enough for ten or twelve lanes of traffic) into the next environmental analysis, that they don’t want the results of an investment grade analysis to undercut their contrived case for a massive structure.

    State Highway Department Forecasts are Flawed

    As we’ve written before, the IBR project is a scene-for-scene remake of the Columbia River Crossing debacle. Just as they are doing now, the state highway departments published grossly inflated traffic forecasts.  In 2010, the Oregon State Treasurer hired Rob Bain, an internationally recognized expert on toll revenue financing, and author of “Toll Road Traffic and Revenue Forecasts: An Interpreters Guide” to assist in the financial analysis of the CRC.   He found numerous flaws and biases–which prompted calls for the investment grade analysis that produced dramatically different results than the highway department projects.  Specifically, Bain reviewed the CRC traffic and revenue forecasts prepared for the project’s environmental impact statement on behalf of the Oregon State Treasurer.  He stated:

    • The traffic and revenue (T&R) reports fall short when compared with typical ‘investment grade’ traffic studies. As they stand they are not suitable for an audience focussed on detailed financial or credit analysis.
    • The traffic modelling activities described in the reports are confusing and much of the work now appears to be dated. Although a number of the technical approaches described appear to be reasonable, many of the modelling-related activities seem to ‘look backwards’; justifying model inputs and outputs produced some years ago. There is a clear need for a new, updated, forward-looking, comprehensive, ‘investment grade’ traffic and revenue study.
    • No mention is made in the reports of historical traffic patterns in the area or volumes using the bridges. This is a strange omission. Traffic forecasts need to be placed in the context of what has happened in the past. If there is a disconnect (between the past and the future) – as appears to be the case here – a commentary should be provided which takes the reader from the past, through any transition period, to the future. No such commentary is provided in the material reviewed to date.
    • Traffic volumes using the I-5 Bridge have flattened-off over the last 15-20 years; well before the current recessionary period. . . . the flattening-off is a long-term traffic trend; not simply a manifestation of recent circumstances. The CAGR for the period 1999 – 2006 reduces to 0.6%

    An investment grade analysis is the bare minimum that’s needed to make a responsible and informed decision about a multi-billion dollar project.  The only reason not to ask these questions now, and to get clear answers, is because the two state DOTs know that the financial risks will prompt legislators and the public to seriously question this massive boondoggle.

    A note on nomenclature:  Level I, Level 2, Level 3

    Highway departments frequently label traffic forecasts as being one of three levels, ranging from a rough sketch level (Level 1), to a somewhat more detailed Level 2, and up to the financial gold standard, Level 3, an investment grade analysis.  As noted, neither the federal government nor private bond markets will make loans based on Level 1 or Level 2 studies:  they are inadequate to accurately forecast traffic for making financial decisions.  This chart from Penn State University describes the general differences between these three levels of analysis:

    Editor’s Note:  Nomenclature section added August 4, 2022

    Which metros are vulnerable to gas price hikes?

    Green cities will be less hurt by higher gas prices; Sprawling cities are much more vulnerable to gas price hikes.

    In sprawling metros like Atlanta, Dallas, Orlando, Nashville and Oklahoma City, higher gas prices will cost the average household twice as much as households living in compact metros like San Francisco, Boston, Portland and Seattle.

    Rising gas prices are a pain, but they hurt most if you live in a sprawling metro where you have to drive long distances to work, shopping, schools and social activities.  Some US metros are far less vulnerable to the negative effects of rising gas prices because they have dense neighborhoods, compact urban development, good transit, and bikeable, walkable streets.  Among the 50 largest metro areas, the best performers enable their residents to drive less than half as much as the most car-dependent metros.  Those who live in metro areas where you have to drive, on average, 50 miles or more per day (places like Oklahoma City, Nashville and Jacksonville) will be hit twice as hard by higher fuel prices than the typical household living in a place like San Francisco, Boston or Portland, where people drive, on average, fewer than 25 miles per day.  When gas prices go up, it’s easy being green:  These compact, less car-dependent metros and their residents, will experience far less economic dislocation than metros where long daily car trips are built-in to urban form.

    Gasoline prices have shot up in recent days, thanks to the Russian invasion of Ukraine.   A year ago, average gas prices nationally were under $3 gallon.  In February, they averaged around $3.30 per gallon.  After the Russian invasion began, oil prices and gas prices jumped.  On March 14, the national average was $4.30, and rising rapidly, with much higher prices in some markets.

    There’s the usual barrage of media hand-wringing about the impact of high gas prices, notwithstanding the widespread support for backing Ukraine, even if it means higher oil prices.  Some 71 percent of Americans favored banning Russian oil imports even at the cost of higher gas prices.  As high as they seem, gas prices today are just now approaching the levels recorded in 2008, when gas prices peaked at $5.09 per gallon (in 2022 dollars).

    In our largely car-dependent nation, higher gas prices feel painful, but some Americans feel the pain far more deeply than others, and some feel it not at all.  There’s been more than a little bike advocate schadenfreude on Twitter, pointing out that those who travel by bike or on foot aren’t feeling the pain of higher gas prices.

    But this isn’t just about individual choices and behavior:  whole communities can be more or less vulnerable to gas price shocks, depending on how much land use patterns effectively necessitate driving.

    Some metro areas are vastly more car-dependent than others, and as a result, are more vulnerable to gas price hikes.  We can get a good idea of which metros will be most affected by price hikes by looking at data on average travel distances in different cities.  The big data firm Streetlight Data published its estimates of the amount of daily driving per person for large US metros.  We’ve tabulated their publicly released data for the period just before the advent of the Coronavirus pandemic, to get a reasonable baseline for comparing travel patterns.

    On average, the residents of the typical large metro area in the US drive about 30 miles per person per day (that’s a bit higher estimate than the one provided by the US Department of Transportation).  But there are extremely wide variations in average driving among metro areas.  In general, older, denser metros with more extensive transit systems seem to have dramatically less driving per person than newer, sprawling Sunbelt metros with weak transit.

    The metros least likely to feel the pain of higher gas prices include Buffalo, San Francisco, Boston, New York, Portland and Seattle, where metro residents drive about 25 percent less than average.

    On the other hand, the metros most vulnerable to higher gas prices are those where, due to job and population sprawl, people tend to drive much further.  These highly vulnerable metros include Oklahoma City, Orlando, Nashville, Dallas, Charlotte and Atlanta, where the typical resident drives 50 or more miles per day, according to the Streetlight estimates, nearly double the typical metro area.

    Average Miles Driven Per Person Per Day Prior to Covid-21 Pandemic (Streetlight Data)


    As we’ve pointed out before, residents of more compact metro areas, with better transit and closer destinations earn the equivalent of a huge green dividend, even when gas is cheap, because they spend far less on cars and gasoline.  Meanwhile, their counterparts in decentralized metros pay a “sprawl tax.”  When oil prices rise, the pain falls disproportionately on those who live in metros where they have to drive a lot.

    The differences are significant.  The households living in metros where people drive 50 miles per person per day are conservatively buying twice as much fuel as those living in metros where people drive only 25 miles per day.  So while a family in a compact metro area would be buying say 100 gallons or so of fuel a month, its counterpart in a sprawling metro would be buying 200 gallons.  So a $1 increase in the price of gas would hit about $1,200 harder over the course of a year in a sprawling metro than in a compact one.

    In the face of rising fuel prices—whether from a war, or from the the long overdue need to reflect the true social and environmental costs associated with fossil fuels—communities where people don’t have to drive as much, or drive as far, have a real economic advantage over more car-dependent places.  That’s a consideration that ought to play a larger role in local, state and national policies going forward.




    Oregon crosses the road-pricing Rubicon

    Starting this spring, motorists will pay a $2 toll to drive Oregon’s historical Columbia River Gorge Highway.

    Instead of widening the road, ODOT will use pricing to limit demand

    This shows Oregon can quickly implement road pricing on existing roads under current law:  No EIS, No equity analysis

    If you can do it there, why not anywhere?  It’s up to you ODOT.

    The Columbia River Gorge, just east of Portland, is one of the nation’s scenic wonders. It was formed where the Columbia River cut a path through the volcanic Cascade Mountain Range, and consists of 50 miles of spectacular river views framed by soaring bluffs, green forests and snow-capped peaks. It’s also home to one of the nation’s oldest and most scenic highways, the Columbia Gorge Highway, built in between 1913 and 1922. It was a kind of engineering marvel of its time, crafting and sometimes carving a winding two-lane roadway along the river and into the cliffs of the Gorge.

    In the 1960s the old highway was fully replaced by the construction of Interstate 84, but the old road has been maintained and in places restored because of its scenic beauty, and direct access to waterfalls and hiking trails. Less than an hour from Portland, it’s a major tourist and recreational site; Multnomah Falls is the state’s most-visited tourist destination.  And that’s become a problem.

    On any summer day, or any (somewhat dry) weekend, you’ll find visitors flocking by the thousands to drive the old scenic highway, particularly the stretch between Vista House and Multnomah Falls, which offers a series of postcard views. (This stretch of roadway is also routinely used for filming car commercials).

    In recent years, however, traffic has overwhelmed the old highway. The road itself is narrow and winding, and there’s little parking at the parks, waterfalls and trailheads. With great regularity, the highway itself has been jammed, and cars are stopped and idling in front of Multnomah Falls. The traffic is both unsafe and also mars the natural beauty of the location.


    Into this fray has stepped the Oregon Department of Transportation. Thankfully, they’re not doing what they usually do, which is proposing to widen the roadway to accommodate even more traffic. Instead, for the first time, they’re implementing a permit system to ration the flow of cars on the old highway to levels that it can accomodate without destroying the experience for those seeking to see one of Oregon’s most beautiful spots.

    Starting the week before Memorial Day, and until Labor Day, you’ll need to buy a permit in order to travel on the waterfall-dotted portion of the Columbia River Highway.  As Oregon Public Broadcasting reports, this will be a “peak hour” pricing program:

    The permit will be required for the approximately 14-mile stretch between Vista House and Ainsworth State Park from 9 a.m. to 6 p.m. ODOT is still deciding how many permits to allow per day, as the permits do not guarantee parking.

    Let’s be clear: What they’re doing is taking an existing road, and they’re tolling it: imposing limits on how many vehicles can use it so that it works better. This is a huge policy breakthrough for a department that has never seriously done anything to moderate traffic demand. (It’s strongest effort to date has been funding for half-hearted public relations campaigns that gently imply that people might want to drive less).

    ODOT is planning to charge $2.00 for these permits.  This will mostly just recoup their direct administrative costs. But if they do it right, it won’t take much of a fee to bring traffic levels down. Just requiring a permit will force people to plan ahead, and will keep people from overwhelming the Gorge on a sunny early spring weekend day. And the fees levied for these permits could be used to expand ODOT’s existing bus service “Columbia Gorge Express” which provides rides to key Gorge destinations. Getting more visitors on buses will reduce traffic and pollution in the Gorge.

    Crossing the Rubicon:  The Gorge Highway toll shows ODOT can implement road pricing quickly if it wants to.

    For more than a decade, ODOT has been dragging its bureaucratic feet in implementing road pricing.  The 2009 Legislature instructed the agency to run a test of pricing in the Portland area; instead the agency counted a special game-day street parking surcharge near the Timber’s soccer stadium as its “pricing” plan.  The 2017 Legislature directed ODOT to implement pricing on Portland’s two major freeways (I-5 and I-205); so far, they’re still just working on the planning.

    The agency has argued that it has to undertake extensive environmental reviews, that it must consult widely about the potential equity implications of pricing, and that it would be unprecedented (and somehow unfair) to extend pricing to an existing roadway.  All those concerns have gone out the window in its announced plans for the Columbia River Gorge.

    In ancient Rome, the Rubicon was the boundary which the Roman legions (and their ambitious commanders) were forbidden to cross. When Julius Caesar crossed the Rubicon River it led to the political upheaval that replaced the Republic with his empire. When it comes to road pricing, The Columbia River Gorge could serve as Oregon’s road pricing Rubicon. We could harness the power of pricing to tailor demand for the transportation system to the levels that are compatible with our livability and environmental objectives.  Notice how Oregon DOT spokesman Don Hamilton explains the rationale for the Gorge highway tolling project:

    “The Gorge is really Oregon’s crown jewel. Everybody in Oregon and in the region is very proud of the Columbia River Gorge,” Hamilton said. “We’re trying to continue to make this accessible and trying to ease the crowds a little bit to make sure that we can still have access to the Gorge and make sure it doesn’t get overrun.”

    What ODOT needs to do next is apply this same reasoning to the rest of the overcrowded bits of its transportation system: i.e. urban freeways in Portland. Hamilton’s reasoning applies with even greater force to congested freeways. To paraphrase:

    “We’re trying to make this accessible and ease the crowds a little bit so we can still have access to the city and make sure it doesn’t get overrun.”

    If roads are jammed to capacity, the solution is not an expensive, disruptive and environmentally damaging expansion, it’s putting in place some kind of pricing or permitting system that limits the volume of cars and trucks on the roadway to levels it can handle without becoming jammed and making the roadway worse for everyone.

    There’s an important historical parallel. The construction of the Columbia Gorge Highway a century ago showed the limits of the old horse-and-buggy system of road finance in Oregon, and directly led to Oregon’s first-in-the-nation adoption of a gasoline tax in 1919 to finance a statewide system of roadways.  At the time, the gas tax was a huge innovation in public finance. In the 21st Century, it’s time to implement a new way of paying for roads that works better, is fairer, and minimizes congestion and environmental harm.  Extending ODOT’s Gorge highway pricing system to the rest of the states roads should be next.


    A reporter’s guide to congestion cost studies

    Reporters:  read this before you write a “cost of congestion” story.

    Congestion cost studies are a classic example of pseudo-science:  Big data and bad assumptions produce meaningless results

    Using this absurd methodology, you can show:

    Waiting at traffic signals costs us $8 billion a year—ignoring what it would cost in time and money to have roads with no traffic lights.

    Our lack of flying cars costs us hundreds of billions of dollars of travel time—never mind that putting everyone in a flying car would be financially and physically impossible.

    Something is actually a “cost” only if there’s a cheaper and physically possible alternative

    There’s a robust literature debunking the congestion cost studies from Texas Transportation Institute, Inrix, and Tom-Tom.

    Every year or so, one or more traffic-counting organizations trots out a report claiming that congestion is costing us tens of billions dollars each year.  Despite the “big data” and elaborate estimates, the results are simply bunk, because they’re based on a flawed premise.  Each of these reports calculates as the “cost” of congestion how much longer a trip takes at peak hours compared to off-peak hours, but fails to define what actions or policies could produce such a change in traffic, and how much they would cost.  Every one of these reports tallies up the supposed “costs” of congestion, without telling how to solve the problem or what it would cost.

    Traffic Lights Cost Billions

    You can apply this idea of computing a “cost” to any kind of waiting.  We’ve done it, tongue-in-cheek, but calculator in hand, for cappuccino.  Others take this notion seriously.  For example, crack statisticians at the University of Maryland have sifted through reams, nay gigabytes, of big data, and have produced a comprehensive, nationwide estimate of the amount of time lost when we sit, waiting for red lights to turn green.

    According to these University of Maryland estimates, time lost sitting at traffic signals amounts to 329 million vehicle hours of delay, and costs us $8.6 billion dollars per year.  They estimate that time spent waiting at traffic signals is roughly three-fifths as great as the 561 million vehicle hours of delay associated with routine “recurring” traffic congestion.

    This University of Maryland study calculates that roughly 19 percent of all traffic congestion is due to waiting at traffic signals.  Those traffic lights do get in your way and slow you down.

    Traffic signals cause delays as vehicles queue at intersections. In 10 states, traffic signals are the top cause of traffic congestion, though congestion levels overall remain relatively low in those states. For example, even though Alaska ranked highest in the country in percentage of delay caused by signals at 53%, it ranked 42nd in terms of total hours of delay caused by signals.

    As an accounting exercise, there’s little reason to doubt these calculations. But whether they constitute a “loss” is highly doubtful, because there’s no question that we’d all collectively lose more time in travel if there were no traffic lights.  The policy implication of this finding is not that we should be tearing out or turning off traffic signals.  That would be absurd, of course.  And what the claims of time spent waiting at traffic lights constitute an actual “loss” rests on the assumption that there’s some other traffic-light free way of managing the flow of traffic at intersections that would involve less total travel time for those now waiting.  Simply getting rid of traffic lights—and say replacing them with stop signs—would likely decrease the throughput of many intersections and actually increase delays (though it might beneficially reduce traffic speeds and improve safety for vulnerable road users). Theoretically one might replace every single traffic light in the US with a fully grade separated interchange without stops.

    Let’s suppose, for a moment, that you could instantly replace all of the 330,000 or so traffic signals in the US with grade-separated interchanges that eliminated traffic signals.  That might eliminate all the time “lost” by vehicles waiting at traffic lights, but it would come at a cost.  At say, $10 million per intersection (which is probably a conservative estimate) that would cost about $3.3 trillion, all that to save maybe $8.6 billion per year.  Time spent waiting at traffic lights is costly, only if you ignore the vastly greater cost of doing anything to try to reduce it.

    It’s easy to point out that the theory about the “time loss” due to traffic lights is pretty silly.  But what’s true of the elaborate (but fundamentally wrong-headed) estimates of the time “lost” to traffic signals is that it also holds for all the other estimates of supposed congestion costs.  For years, a range of highly numerate charlatans have been purporting to compute the value of time lost to traffic congestion. The congestion cost studies generated by the Texas Transportation Institute, Inrix, Tom-Tom and others invariably conclude that traffic congestion costs us billions of dollars a year.  Their copious data creates the illusion of statistical precision without providing any actually useful knowledge.  They generate heat, but don’t shed any light: The congestion cost estimates are part of the propaganda effort of the road-builders, who assert we need to spend even more billions to widen roads to recoup these losses.

    It’s an example of a measurement that’s literally true, but quite meaningless.  It’s true in the sense that people probably due spend millions of hours, collectively sitting at traffic lights or traveling more slowly because of congestion.  It’s meaningless, because there’s not some real world alternative where you could build enough road capacity to eliminate these delays.  So, as an elaborate accounting exercise, you can use big data and computing power to produce this estimate, but the result is a factoid that conveys no useful, actionable information—just as we’ve shown with our Cappuccino Congestion Index, which totes up the billions of dollars American’s “lose” waiting in line at coffee shops.

    Where are my flying cars?  Think of all the congestion costs they’ll save!

    The sky’s the limit if you want to generate large estimates of the supposed time “lost” due to slower than imaginable travel.  Consider for example flying cars, which according to this year’s Consumer Electronics Show (CES), are just about to darken our skies.  One company, ASKA, is showing a four-seat prototype that can whisk you and a friend at speeds of up to 150 miles per hour, land in the space of a helipad, and park in an area no larger than a conventional parking space.

    An Aska-A5 flying car ($789,000) at CES. (CNET)

    Unsurprisingly, the flying car advocates are pitching it as a solution to traffic congestion (move over Elon Musk):

    . . . who doesn’t want to hop over the traffic? The Aska A5 can fly at a maximum speed of 150 mph and travel 250 miles on a single charge. That could cut a 100-mile car trip down to just 30 minutes. Aska’s Kaplinsky sees the A5 flying car tackling long commutes, allowing them to move to more affordable communities further away from big cities and reduce the number of regular cars they own, he said, adding that most people would probably use them when needed through a ride-sharing service

    If you could travel by flying car to all your destinations, it would shave hours a day off your total travel time.  Imagine all the time we could save if everybody had a flying car, and what those savings would be worth.  With a spreadsheet and some travel data, you could work out an estimate of how many million hours might be saved and how many tens or hundreds billions of dollars that saved travel time would be worth.  You could produce a report arguing that the personal flying car shortage costs us in lost time and money.  It would be a large but meaningless number, because there’s no world where its financially feasible, much less physically possible, for everyone to take every trip by flying car.  The price per flying car is a cool $789,000 (plus operating costs), and there aren’t enough heliports or heliport-adjacent landing spots to accommodate everyone; not to mention that there’s no air traffic control system for thousands of such vehicles moving over cities.  The only way to make meaning of such numbers is in the context of plausible, real-world alternatives.  And that’s exactly what these cost of congestion studies almost invariably fail to consider.  Something is only a “cost” if there’s an actual practical alternative that would save the lost time without incurring even greater monetary costs in doing so.  Imaginary savings from an impossible, or impossibly expensive alternative aren’t savings at all.

    It’s tempting to believe that more data will make the answers to our vexing problems, like traffic congestion, clearer.  But the reverse is often true:  an avalanche of big data obscure a fundamental truth.  That’s what’s going on here.

    More Background on Congestion Cost Reports

    City Observatory has written extensively on the flaws of past congestion cost studies.  Here are some of our commentaries:

    Want to know more?

    Really want to wonk out on all the methodological, conceptual and data flaws in these congestion cost reports?  Here are two key resources:  First, our own Measuring Urban Transportation Performance report:


    And second, Todd Litman of Victoria Transportation Policy Institute’s critique of the urban mobility report.


    More Congestion Pseudo Science

    A new study calculates that twenty percent of all time “lost” in travel is due to traffic lights

    Finally, proof for the Lachner Theorem:  Traffic signals are a major cause of traffic delay

    Another classic example of pseudo-science:  Big data and bad assumptions produce meaningless results

    When I was in graduate school, I shared a house in Berkeley with five roommates.  Once a week we’d pool our food dollars, and pile into Archie Lachner’s ’67 Falcon and drive across town to Lucky, Safeway or the Co-Op, and mount a group shopping expedition for the week.  This was in the late 70s, just after Berkeley had installed a series of traffic diverters to stop cut-through driving in residential neighborhoods.  Our driver, Archie, repeatedly chose routes that were blocked by one diverter and then another.  He cursed at the inconvenience:  “These traffic diverters, they get in your way, they slow you down.”  That prompted a heated debate about the merits of diverters.  Archie defended the inherent right of drivers to go wherever they wanted.  Others in the car said they could see how people who lived on these streets might appreciate the diverters cutting down on or at least slowing traffic. Archie had to turn around at least twice to avoid diverters, and as we finally got near the grocery store, we came to to a stop at a red traffic signal.  From the back seat, someone said:  “These traffic lights, they get in your way, they slow you down.”    Offended, Archie, spun the wheel and drove home–“if you can’t respect the driver, you won’t get a ride.”  Despite the protests, Archie drove a couple of miles back home, and the five other roommates had to repeat the trip in another car.


    Traffic signals cause 20 percent of all time lost to congestion!

    Thus was born the Lachner theory of traffic congestion:  Traffic lights get in your way and slow you down.  For decades the theory has been wanting for actual quantification, but at last, we have it.  Crack statisticians at the University of Maryland have sifted through reams, nay gigabytes, of big data, and have produced a comprehensive, nationwide estimate of the amount of time lost when we sit, waiting for red lights to turn green.

    According to these University of Maryland estimates, time lost sitting at traffic signals amounts to 329 million vehicle hours of delay, and costs us $8.6 billion dollars per year.  Time spent waiting at traffic signals is roughly three-fifths as great as the 561 million vehicle hours of delay associated with routine “recurring” traffic congestion.

    This new study from the University of Maryland finally vindicates the Lachner theorem.  By their reckoning, roughly 19 percent of all traffic congestion is due to waiting at traffic signals.  Those traffic lights do get in your way and slow you down.

    Traffic signals cause delays as vehicles queue at intersections. In 10 states, traffic signals are the top cause of traffic congestion, though congestion levels overall remain relatively low in those states. For example, even though Alaska ranked highest in the country in percentage of delay caused by Signals at 53%, it ranked 42nd in terms of total hours of delay caused by signals.

    As an accounting exercise, there’s little reason to doubt these calculations. But whether they constitute a “loss” is highly doubtful, because there’s no question that we’d all collectively lose more time in travel if there were no traffic lights.  The policy implication of this finding is not that we should be tearing out or turning off traffic signals.  That would be absurd, of course.  And what the claims of time spent waiting at traffic lights constitute an actual “loss” rests on the assumption that there’s some other traffic-light free way of managing the flow of traffic at intersections that would involve less total travel time for those now waiting.  Simply getting rid of traffic lights—and say replacing them with stop signs—would likely decrease the throughput of many intersections and actually increase delays (though it might beneficially reduce traffic speeds and improve safety for vulnerable road users). Theoretically one might replace every single traffic light in the US with a fully grade separated interchange without stops.

    Let’s suppose, for a moment, that you could instantly replace all of the 330,000 or so traffic signals in the US with grade-separated interchanges that eliminated traffic signals.  That might eliminate all the time “lost” by vehicles waiting at traffic lights, but it would come at a cost.  At say, $10 million per intersection (which is probably a conservative estimate) that would cost about $3.3 trillion, all that to save maybe $8.6 billion per year.  Time spent waiting at traffic lights is costly, only if you ignore the vastly greater cost of doing anything to try to reduce it.

    It’s easy to point out that the Lachner Theorem about the “time loss” due to traffic lights is pretty silly.  But what’s true of the elaborate (but fundamentally wrong-headed) estimates of the time “lost” to traffic signals is that it also holds for all the other estimates of supposed congestion costs.  For years, a range of highly numerate charlatans have been purporting to compute the value of time lost to traffic congestion. The congestion cost studies generated by the Texas Transportation Institute, Inrix, Tom-Tom and others invariably conclude that traffic congestion costs us billions of dollars a year.  Their copious data creates the illusion of statistical precision without providing any actually useful knowledge.  They generate heat, but don’t shed any light: The congestion cost estimates are part of the propaganda effort of the road-builders, who assert we need to spend even more billions to widen roads to recoup these losses.

    It’s an example of a measurement that’s literally true, but quite meaningless.  It’s true in the sense that people probably due spend millions of hours, collectively sitting at traffic lights or traveling more slowly because of congestion.  It’s meaningless, because there’s not some real world alternative where you could build enough road capacity to eliminate these delays.  So, as an elaborate accounting exercise, you can use big data and computing power to produce this estimate, but the result is a factoid that conveys no useful, actionable information—just as we’ve shown with our Cappuccino Congestion Index, which totes up the billions of dollars American’s “lose” waiting in line at coffee shops.

    The sky’s the limit if you want to generate large estimates of the supposed time “lost” to slower than imaginable travel.  Consider for example flying cars or helicopters.  If you could travel by helicopter to all your destinations, it would shave hours a day off your total travel time.  With a spreadsheet and some travel data, you could work out an estimate of how many million hours might be saved and how many billions of dollars that saved travel time would be worth.  You could produce a report arguing that the personal helicopter shortage costs us in lost time and money.  It would be a large but meaningless number, because there’s no world where its financially feasible, much less physically possible, for everyone to take every trip by helicopter.

    The only way to make meaning of such numbers is in the context of plausible, real-world alternatives.  And that’s exactly what these cost of congestion studies almost invariably fail to consider.  Something is only a “cost” if there’s an actual practical alternative that would save the lost time without incurring even greater monetary costs in doing so.  Imaginary savings from an impossible, or impossibly expensive alternative aren’t savings at all.  All of the evidence about induced travel shows that expanding capacity to try and reduce time “lost” to congestion is ultimately futile:  more capacity encourages more travel, induces more sprawl, and does nothing to reduce congestion and delay.

    It’s a welcome sign that one recent report acknowledged this fundamental fact.  To their credit, at least Tom-Tom acknowledges that adding capacity is futile, or even-counterproductive:

    Developing road infrastructures and increasing the capacity isn’t the solution. “When a new road is built, it is only a matter of time before more vehicles are added to the road, offsetting this initial easing: it’s called the traffic demand dilemma”, Ralf-Peter Schäfer said. Change behaviours and traffic patterns can make a significant difference. Congestion is non-linear: once traffic goes beyond a certain threshold, congestion increases exponentially. Discouraging drivers to drive during peak rush hour can lead to big improvements, as proven during the pandemic.

    And the purveyors of congestion cost estimates almost never point to the only solution that’s been proven to reduce congestion:  road pricing.  Even a modest system of time-based user fees could dramatically reduce congestion.

    It’s tempting to believe that more data will make the answers to our vexing problems, like traffic congestion, clearer.  But the reverse is often true:  an avalanche of big data obscure a fundamental truth.  That’s what’s going on here.


    Freeway widening for whomst?

    Widening freeways is no way to promote equity.  The proposed $5 billion widening of I-5 between Portland and Vancouver is purportedly being undertaken with “an equity lens,” but widening Portland’s I-5 freeway serves higher income, predominantly white workers commuting from Washington suburbs to jobs in Oregon.

    The median income of peak hour, drive alone commuters to Oregon from Clark County is $106,000; significantly higher than for the region as a whole (about $78,000).  

    More than 53 percent of peak hour drive alone commuters are from households with incomes over $100,000; fewer than 15 percent of these peak hour car commuters have incomes under $50,000 annually.

    Some 86 percent of peak hour, drive-alone commuters are non-HIspanic whites, according to the 2019 American Community Survey; only 14 percent of these peak hour car commuters are persons of color.  Peak hour drivers are half as likely to be people of color (14 percent) as are residents of the region (28 percent).

    Clark County is less diverse than the rest of the Portland metro area; its residents of color are vastly more likely to work at jobs in Clark County than to commute to jobs in Oregon.

    The proposal to spend $5 billion to widen a 5-mile stretch of I-5 between Portland and Vancouver is being marketed with a generous dose of equity washing.  While it is branded the “Interstate Bridge Replacement” or IBR,  replacing the bridge is less than a quarter of the total cost; most of the expense  involves plans to double the width of the freeway to handle more peak hour traffic. The project has gone to some lengths to characterize suburban Clark County as an increasingly diverse population to create the illusion that the freeway widening project is primarily about helping low and moderate income households and people of color travel through the region.  A quick look at Census data shows these equity claims are simply false.  Peak hour freeway travelers commuting from homes in Washington to jobs in Oregon are overwhelmingly wealthy and white compared to the region’s average resident.


    Equity? A proposed super-sized $5 billion freeway would mostly serve peak hour commuters with incomes over $100,000, 86 percent of whom are non-HIspanic whites.

    What this project would do is widen from 6 lanes, to as many as 14 lanes, five miles of Interstate 5 between Portland and Vancouver.  The principal reason for the project is a claim that traffic volumes on I-5 cause the road to be congested.  But congestion is primarily a peak hour problem, and is caused by a large and largely uni-directional flow of daily commuter traffic.  About 60,000 Clark County residents work at jobs in Oregon, and they commute across either the I-5 or I-205 bridges.  Fewer than a third that many Oregonians work in Clark County, with the result being that the principal traffic tie-ups coincide with workers driving from Clark County in the morning, and back to Clark County in the evening.  Plainly, this is a project that is justified largely on trying to provide additional capacity for these commuters.  That being the case, who are they?

    Census data show that the beneficiaries of the IBR project would overwhelmingly be whiter and higher income than the residents of the Portland metro area.  As with most suburbs in the United States, Clark County’s residents, who are those most likely to use the IBR project, are statistically whiter and wealthier than the residents of the rest of the metropolitan area.  In addition, the most regular users of the I-5 and I-205 bridges are much more likely to be white and higher income than the average Clark County resident.  This is especially true of peak hour work commuting from Clark County Washington to jobs in Oregon, which is disproportionately composed of higher income, non-Hispanic white residents.

    Peak hour, drive-alone commuters are overwhelmingly white and wealthy

    Data from the American Community Survey enable us to identify the demographic characteristics of peak hour, drive-alone commuters going from Clark County Washington to jobs in Oregon on a daily basis. Here are the demographics of the nearly 20,000 workers who drive themselves from Clark County to jobs in Oregon, and who leave their homes between 6:30 AM and 8:30 AM daily.  Some 53 percent of peak hour, drive-alone commuters from Clark County to Oregon jobs lived in households with annual incomes of more than $100,000.  The median income of these peak hour drivers was $106,000 in 2019, well above the averages for Clark County and the region.

    Fully 86 percent of the peak hour, drive-along commuters from Clark County to Oregon jobs were non-Hispanic whites.  Only about 14 percent of these peak hour drivers were persons of color.  The racial/ethnic composition of these peak hour car commuters is far less diverse than that of Clark County, or the region.  Clark County workers who work in Clark County are about 50 percent more likely to be people of color than those who commute to jobs in Oregon.

    Clark County is whiter and wealthier than the region and Portland

    Suburban Clark County, Washington is whiter and wealthier than the rest of the Portland metropolitan area, and the City of Portland. Clark County may be more racially and ethnically diverse than it once was, but so is the entire nation.  And it’s still disproportionately whiter and wealthier than the rest of the region.  Only about 23 percent of its residents are people of color, compared to about 38 percent for the region as a whole, and about 30 percent for Portland, according to the 2019 American Community Survey. Clark County’s median household income of $80,500 is higher than for the region ($78,400) and for the City of Portland ($76,200).

    Few low income and workers of color commute to Oregon from Clark County

    Not only is Clark County less diverse than the rest of the Portland region, only a small fraction of its low income workers and workers of color commute to jobs in Oregon at the peak hour.  More than ten times as many low income workers and workers of color who live in Clark County work at jobs in Clark County than commute to jobs in Oregon.  About 38,000 Clark County workers in households with incomes of $50,000 or less work at jobs in Clark County; only about 2,800 are peak hour, drive-alone commuters to jobs in Oregon.  About 31,000 Clark County workers of color work at jobs in Clark County.  If we’re concerned about addressing the transportation needs of low income workers and workers of color in Clark County, we should probably focus our attention on the vast majority of them who are working at jobs in the county, not the comparatively small number commuting to Oregon.

    Middle and upper income households are far more likely to commute to jobs in Oregon

    In general, for Clark County residents, the higher your income, the more likely you are to commute to a job in Oregon.  Only about 1 in 5 workers in households with incomes less than $40,000 in Clark County commute to jobs in Oregon.  About 30 percent of workers in middle and upper income families in Clark County commute to Oregon jobs, meaning that these higher income households are about 50 percent more likely to commute to jobs in Oregon than lower income households.


    Data notes

    Data for this post is from 2019 American Community Survey, via the indispensabile  University of Minnesota IPUMS project:

    Steven Ruggles, Sarah Flood, Ronald Goeken, Josiah Grover, Erin Meyer, Jose Pacas and Matthew Sobek. IPUMS USA: Version 10.0 [dataset]. Minneapolis, MN: IPUMS, 2021.

    Biased statistics: Woke-washing the I-5 Boondoggle

    The Oregon and Washington transportation departments are using a biased, unscientific survey to market their $5 billion I-5 freeway widening project.

    The survey over-represents daily bridge users by a factor of 10 compared to the general population.

    The IBR survey undercounts lower and middle income households and people of color and overstates the opinions of White non-hispanics, higher income households, and Clark County residents

    As we’ve noted, highway builders are increasingly engaging in woke-washing, claiming—after decades of experience in which freeway projects have devastated communities of color and destroyed city neighborhoods across the country—that wider freeways will somehow be a good thing for low income people and people of color.

    The latest example of this comes from the sales campaign to promote the $5 billion I-5 freeway widening between Portland and Vancouver Washington, misleadingly branded as the “Interstate Bridge Replacement” (IBR) project.  The reality is pretty simple:  the primary beneficiaries of a wider roadway would be higher income, overwhelmingly white commuters who drive daily from suburbs in Washington State to jobs in Oregon.  As we documented last month, the peak hour drive-alone car commuters who cross the I-5 and I-205 bridges from Washington State to jobs in Oregon are whiter and wealthier than the region’s population, with median incomes of $106,000, and 86 percent non-Hispanic whites.

    But the IBR project has carefully constructed an alternate reality in which this car-centric freeway widening project is really something that benefits low income people and people of color.  The project’s promotional materials—which actually don’t show the project, or acknowledge its price tag, or the fact that it will charge tolls to bridge users—prominently features stock images of people of color.

    Here’s what we mean by “woke-washing.”  The project’s home page featured this image . . .

    See our commitment to equity: We bought this stock photo! (Source: Interstate Bridge Replacement Project, March 7, 2022).

    . . . which is a stock photograph used by hundreds of websites, mostly those focusing on women’s health.  (Just an aside: A true health-oriented and equity focused project wouldn’t build a 12-lane wide, 5 mile long freeway guaranteed to increase air pollution and with a long history of destroying neighborhoods.)

    In addition to its woke imagery, the IBR project supplements this messaging with a pseudo-scientific web-based survey which purports to show that the project is really for lower income people of color.

    Selling a $5 billion freeway widening with a woke-washed fable

    The IBR staff have developed a fictional “just so” story of how the freeway widening project is needed to help low income households and people of color, who’ve moved to Clark County for cheaper housing, but have to travel to jobs and other opportunities in Oregon.  The survey is grounded, not in actual scientific data, but the project’s own unscientific and biased web-based survey.

    Here is IBR staff person Jake Warr, making this false claim to the January 20, 2022 Executive Steering Committee meeting:

    One thing that really came out through this survey that I want to highlight is when we . . . asked how often people drive across the bridge, we found a higher percentage of folks who identified with a race or ethnicity besides white or or in addition to white/Caucasian, the non-white respondents really reported more frequently traveling across the bridge.

    So that 53 percent‑that’s listed there, 53 percent‑of our of our BIPOC survey respondents reported traveling across the bridge either daily or a few times a week. That’s compared to closer to 40 percent for the white respondents.

    IBR’s unscientific and biased web-based survey.

    So just something that that really kind of drives home a point that we’ve suspected. It provides further data that you, we’ve seen a trend in our region of folks of color being pushed to further areas of the region, being pushed north of the river, or seeking out more affordable housing north of the Columbia River, but still relying on services jobs etc, in Multnomah County.

    And so, there’s that piece that I think this speaks to. We also suspect that related to Covid, as people were answering this question in the context this pandemic, there might be some explanation there, as we know that BIPOC individuals tend to be, disproportionately rely needing to work still in a location and not be able to work from home.

    That might have contributed to this but just something that we really found was was a poignant data piece to point out.

    The trouble is, this claim is easily disproved by referring to valid survey data from the Census Bureau which shows that commuters across the I-5 and I-205 bridges are actually disproportionately white, and higher income.  Low income workers, and those of color, are dramatically under-represented among bridge commuters.

    A biased, unscientific survey from the IBR

    The trouble with web-based surveys is they suffer from self-selection bias.  Only highly motivated people take such surveys, and the opinions, experience and demographics of these people differ substantially, and systematically, from the general population.  As a result, it’s simply invalid to make statistical claims (such as people of color are more likely to use the bridge frequently).  That’s especially true when there’s valid scientific data from the American Community Survey, which shows exactly the opposite: peak hour users (for whom the bridge is being expanded) are 86 percent non-Hispanic white and have average incomes of $106,000).

    To see just how biased the unscientific IBR web-survey is, we can compare it to other surveys conducted with more valid methodologies.  The correct way to do surveys is with an random selection methodology; the IBR actually commissioned such a survey in 2020.  In its random survey of more than 900 Portland area voters, 13 percent of respondents reported never crossing the I-5 bridge over the Columbia, compared to just 1 percent in the unscientific online survey.  The random survey of voters showed only 5 percent of respondents crossed the I-5 bridge every day, compared to 19 percent in the unscientific online survey.  As a result, the unscientific online survey implies the ratio of daily users to non users is 19 to 1 (there are 19 times as many daily users as never users), while the random survey shows that there are two and a half times as many non-users as daily users of the I-5 bridge.  That means that the unscientific survey overweights the role—and opinions—of daily users relative to non users by more than an order of magnitude relative their share of the overall population of the Portland metropolitan area.

    Source: IBR Community Opinion Survey, 2020

    Demographic bias in the IBR unscientific web survey

    A quick look at the American Community Survey, which is conducted annually by the Census Bureau, shows that the demographics of the IBR’s unscientific web-based survey are dramatically different from the metro area.

    One essential for surveys is that participants should be randomly selected.  If they’re not randomly selected, there’s little guarantee that the results will be representative of the larger population. One of the sure tells of a non-random survey is that the characteristics of survey participants don’t match up well with the characteristics of the overall population of the area being surveyed.  That’s the case here.  The IBR survey systematically over-represents some groups, and systematically underrepresents others, which should cast doubt on the validity of its results.  The survey systematically over-represents white, non-Hispanic people, higher income households, and residents of Washington State, and systematically under-represents people of color, low and moderate income households, and Oregon residents.  Here are the details.

    Income:  Higher incomes over-represented.  The respondents to the unscientific web-survey are much higher income than the overall population.  Some 44 percent of survey respondents had household incomes over $100,000; only 38 percent of the region’s households had incomes that high.

    Race and Ethnicity:  People of color under-represented.   The respondents to the unscientific web-based survey are much more likely to be non-Hispanic white than the overall population; some 85 percent of survey respondents were non-Hispanic white compared to 72 percent of the region’s population.  People of color were 28 percent of the region’s population, but only 15 percent of survey respondents.  People of color were undercounted by almost half in this unscientific survey.

    Residence:  Clark County over-represented.  The respondents to the unscientific web-based survey are disproportionately residents of Clark County.  Clark County accounts for less than 20 percent (488,000 of the region’s 2.5 million residents) but accounts for 43 percent of those taking the survey.  Clark County resident views are given more than double the weight of view of other of the region’s residents in this unscientific survey.

    Age:  Young people significantly under-represented. There’s also a strong generational bias:  only 5 percent of survey respondents are under 25, compared to nearly 30 percent of the population.  And these people will be the ones who have to live with the environmental consequences of the project.

    No doubt the highway agencies will point with pride to the large number of completed surveys–more than 9,000 to date.  But large numbers are irrelevant if you don’t have a random sample.  For a metropolitan area the size of Portland, you need only about 400 to 800 survey participants to come up with statistically valid results,  if you have a random sample.  If you don’t have a random sample, then even very large numbers (and IBR surveyed only about one-third of one percent of the region’s residents) just aren’t meaningful.  The underlying problem that invalidates the survey is called “Self-Selection Bias.” Because this isn’t a true random survey, and because respondents choose whether to participate, there’s no guarantee that the survey data reflect the views (and experiences) of the larger population.  Because those who are predisposed to care about this issue are likely to differ systematically from the rest of the population, the survey produces results that are biased.

    Not asking the most important question:  Who wants to pay a toll?

    There’s a lot more to dislike about the survey beyond its poor quality sampling strategy and biased sample.  The questions posed in the survey don’t get at the real issues raised by the freeway widening project.  The project’s financial plan shows that it won’t be built without tolls—something you’d be hard-pressed to learn from any of the “public information” work.  The last estimates prepared for the Columbia River Crossing showed I-5 tolls would be a minimum of $2.30 during off peak hours, rising to $3.25 during rush hour, with additional surcharges for those who didn’t buy transponders for their cars in advance.  The survey didn’t reveal these toll rates, or ask people whether they might prefer a smaller, less expensive bridge with lower tolls, to a larger one with these high tolls, or whether they’d really rather keep the existing bridge if it meant they could avoid tolling altogether.  Despite the fact that the survey avoided talking about tolls, many survey respondents raised the question in answering open-ended questions.

    It’s rather like a taste test survey that asks people whether they’d prefer filet mignon to a hot dog, without revealing the price tag of either alternative.  For a project that claims so prominently to care about “centering equity,” failing to reveal that people might have to pay on the order of $1,600 per month to commute daily across this bridge is a monumental omission.  But it’s no accident:  the project’s “public information” campaign is designed is an intentionally misleading way to manufacture consent, not to accurately measure public attitudes.

    Surveys can be a useful way to gauge public opinion, if they’re undertaken in a scientifically valid fashion.  But if you aren’t careful, you end up with a classic, garbage-in, garbage-out exercise.  That appears to be the case with survey work commissioned by the “Interstate Bridge Replacement” project, a thinly veiled marketing campaign for freeway widening funded by the Oregon and Washington transportation departments—with “communications” consultants reaping more more than $4 million for their services in the past few years.




    The I-5 bridge “replacement” con

    Oregon and Washington highway builders have re-branded the failed Columbia River Crossing as a “bridge replacement” project:  It’s not.

    Less than 30 percent of the cost of the nearly $5 billion project is actually for replacing the existing highway bridge, according to independent accountants.

    Most of the cost is for widening the freeway and rebuilding interchanges for miles north and south of the bridge crossing, replacing the current bridge is somewhere between $500 million and one billion.

    Calling $5 billion, 5-mile long freeway a “replacement bridge” is like saying if you buy a new $55,000 truck it’s a “tire replacement.” 

    Nearly a decade ago, the “Columbia River Crossing—the multi-billion dollar plan to build a wider I-5 freeway between Portland and Vancouver—collapsed of its own fiscal weight, after both the Oregon and Washington Legislatures refused to pony up an estimated $450 million each (as well as signing a blank check to cover future cost overruns and revenue shortfalls). Project advocates delayed for as long as they could revealing the project’s true price tag and actually asking for the money, and when they finally did, legislators balked.

    Promoters of the newly re-chrisented “Interstate Bridge Replacement (IBR) Program” have been assiduous in their efforts not to talk about the scale or cost of the project. In two years, they’ve yet to produce a single, new comprehensive illustration of the project—something that’s a standard fare in megaprojects.

    That new name is part of the sale pitch.  Ever since attempting to breathe life back into the failed Columbia River Crossing project, the Oregon and Washington Departments of Transportation and their coterie of consultants have been engaged in an extensive effort to rebrand the project to make it more salable. (According to Clark County Today, over the past two years, $5.3 million—more than a quarter of the project’s $21 million spending—has been for “communications.”)

    It’s no longer ever referred to as  the “Columbia River Crossing”—although the project’s expensive PR consultants failed to get that talking point to the White House, as President Biden recently referred to it by it’s obsolete moniker.  instead, it’s the far more modest “I-5 bridge replacement program”.  The project’s public materials talk mostly about the existing bridge, and as we’ve noted, almost never reveal that the total project is 5 miles long, that it contemplates widening this stretch of freeway to 12 (or more lanes), will cost upwards of $5 billion, and require minimum tolls of $5 for every round trip across the river.  Project staff are even leery of letting anyone look at computer renderings of the project.

    The drawings of the Columbia River Crossing hint at just how massive this project would be.  The following animated GIF shows the design for the CRC as it crosses Hayden Island, superimposed on an aerial view of the existing freeway.  And none of what’s shown in this particular illustration includes the actual bridge structure crossing the Columbia River (which would be out of frame to the left).

    The plans for Hayden Island show that much of the area would be paved over in a complex web of on- and off-ramps, flyovers, and multi-lane arterials.  Little wonder the residents of the island are strongly opposed to the project, saying:  “the massive footprint over Hayden Island .  .  . will destroy our community.”  (Hi-Noon Newsletter, January 26, 2022).

    On and off ramps for the Columbia River Crossing on Hayden Island, south of the Columbia River.

    Calling it just a “replacement” is PR gimmick to conceal all these elements of the project.  But it also conceals where the real money is going:  the reality is that the “replacement” of the two existing I-5 bridges, is just a small part of the project’s total costs—less than 30 percent according to independent estimates.

    The “bridge” part of the IBR is less than 30 percent of total costs

    In 2012, forensic accountant Tiffany Couch undertook a detailed audit of the CRC cost estimates.  Her analysis showed that the portion of project costs attributable to the bridge structure was $796.5 million—just a shade under $800 million.  Her analysis showed these costs represented just 23 percent of the total $3.49 billion price tag for the entire project..

    Acuity Group, Inc., Report #6 Columbia River Crossing – Cost Allocation Discrepancies, April 8, 2013

    The estimates by Acuity Group differ from the summary level budget breakdowns publicly distributed at the time by the CRC project staff.   According to Acuity, CRC transferred a portion of the costs associated with interchange overpass construction to the “bridge” portion of the project, effectively understating the cost of the freeway widening on either side of the river, and overstating the cost of the river crossing itself:

    According to the CRC’s own detailed budgets, the costs to build the interchanges in Oregon and Washington are expected to cost hundreds of millions more than what is being reported to legislators, public officials, and the citizens of Oregon and Washington. Conversely, the CRC’s own detailed budget shows that the cost to tear down and rebuild the interstate bridge is hundreds of millions less than what is being reported.

    According to the forensic accountants, ODOT and WSDOT shifted a portion of the cost of reconstructing interchanges north and south of the bridge by allocating all of the costs associated with overpass structures for these interchanges to the category “interstate bridge”:

    . . . we found that when we allocated the cost of the overpasses associated with each interchange to the cost of the interstate bridge, we were able to reconcile to the CRC’s public communications and maps.

    Replacing the existing bridge capacity might be only $500 million

    Even at $800 million, this price estimate is too high to count as a “replacement” cost, because  much of the cost is associated with increasing the bridge’s capacity to 12 lanes, rather than simply replacing the existing 6 traffic lanes.  Inasmuch as the CRC plan calls for building two side-by-side bridges (each about 90 feet wide), the cost of “replacing” the existing structure with a new one is just the cost of one of these two bridges.  That means the cost of a like-for-like bridge replacement would be less than $500 million.

    The CRC and IBR projects are proposing two new bridges: only one is a “replacement;” the other is an expansion.

    It also now appears that the revived IBR project will be even larger and more expensive than the CRC.  For example, it has at a minimum added in some expenses that were cut out of the final CRC design, such as the North Portland Harbor Bridge, spanning the a slough south of the Columbia River (which would add about $200 million to the project’s cost).

    What this means is that, if the “IBR’ were just about replacing the I-5 Columbia River bridges, its cost would be far smaller—in all likelihood less than $1 billion.  A right-sized bridge would be much more affordable, and wouldn’t raise the strong environmental objections that are associated with the DOTs freeway widening plans.

    The IBR Project is still hiding the cost

    The epic failure of the Columbia River Crossing had everything to do with the project’s unwillingness to talk frankly about finances, and the same mistake is being repeated this time as well.  It’s fair to ask, why should we rely on ten-year old cost estimates in sussing out the actual cost of “replacing” the current bridges?

    The reason is that, so far, after more than two years of work to revive the project, ODOT and WSDOT have yet to produce any new cost estimates.  Their “draft” financial plan, released in November 2020, is based on the old CRC budget, with some adjustments for inflation.  In the past year, none of the meetings of the “Executive Steering Group” supposedly charged overseeing the project has discussed project costs or financing.

    The fact that the project hasn’t done new, ground-up cost estimates isn’t an oversight—it’s a conscious strategy, to avoid revealing the true cost and scale of the project—and subjecting themselves to the kind of scrutiny offered in the Acuity forensic analysis of the CRC budget.

    It’s a bit like going to the car dealership to get a new set of radials for your fifteen-year old F150, and coming back home in a  new $50,000 pickup truck, and telling your spouse that it’s a “tire replacement” program.

    It’s always been a bloated boondoggle

    In less guarded moments, influential local politicians have been outspoken about the excessive costs generated by ODOT and WSDOT.   Congressman Peter DeFazio famously declared the Columbia River Crossing project to be a gold-plated monstrosity.  In the Oregonian on August 14, 2011, Representative DeFazio said:

    “I kept on telling the project to keep the costs down, don’t build a gold-plated project,” a clearly frustrated DeFazio said. “How can you have a $4 billion project? They let the engineers loose, told them to solve all the region’s infrastructure problems in one fell swoop… They need to get it all straight and come up with a viable project, a viable financing plan that can withstand a vigorous review.”
    (Manning, Jeff. “Columbia River Crossing could be a casualty of the federal budget crunch”, The Oregonian, August 14, 2011).
    Later, Representative DeFazio told Oregon Public Broadcasting:
    “I said, how can it cost three or four billion bucks to go across the Columbia River?  . . . The Columbia River Crossing problem was thrown out to engineers, it wasn’t overseen: they said solve all the problems in this twelve-mile corridor and they did it in a big engineering way, and not in an appropriate way.”
    “Think Out Loud,” Oregon Public Broadcasting, August 18, 2011.

    The irony is that if this project were just about replacing the bridge, rather than building a massive freeway, not only would the project be vastly cheaper, there’d almost surely be less public opposition to the project.  The objection isn’t to having a safe, functional bridge, its to building a giant highway that will worsen pollution and bankrupt taxpayers and commuters.

    Transportation trends and disparities

    If you aren’t talking about our two-caste transportation system, you’re not really addressing equity.

    Portland’s regional government is looking forward at trends in the transportation system and their implications for equity.  In December, City Observatory submitted its analysis of these trends for Metro’s consideration.

    Local and regional leaders are increasingly promoting concerns of equity in transportation, as well they should.  But many analyses of equity leave out the most fundamental inequity in the structure of transportation:  our explicit two-caste system that privileges those who can afford and can operate cars, and systematically disadvantages everyone else:  those too young, too old, too infirm or too poor to own and operate a motor vehicle.  Those in the lower caste are condemned to lives of impaired access to the economy and society, and greater risk of death and injury when they do travel. Many of the other observed inequities in transportation flow directly from this two caste system.

    If governments are serious about rectifying inequities in transportation they have to look past symptoms and superficial manifestations to underlying causes.  A careful consideration of these trends will take them in this direction.


    Trend Disparities
    Portland will continue to have a two-caste transportation system, with priority for those who can afford to, and are legally and physically able to operate a car (the upper caste), and lower priority for those too poor, too young, too old, to operate a car (the lower caste). Most of the other inequities (safety, pollution, lack of access and discrimination) flow from this two-caste system. Low income people, people of color, and the old and the young are disproportionately consigned to being in the lower caste by our car-dependent transportation system.






    Portland area transportation greenhouse gas emissions have increased by 1,000 pounds per person annually (14 percent) over the past few years, and show no signs of declining, despite state, regional and local plans calling for a reduction in GHGs. The region will have to take much bolder action than any laid out in the RTP to comply with adoption laws. Climate change caused by GHG emissions disproportionately come from higher income households and lower density sprawling neighborhoods, and disproportionately affects low income neighborhoods.



    ODOT plans to spend billions of dollars widening area freeways, which will induce additional travel; Gas taxes from road use don’t cover anything approaching the cost of building and maintaining freeways, meaning that their costs are subsidized by non-users. Freeways are only usable to people who can afford the roughly $5,000 annual cost of owning and operating a car. Car ownership is much lower among low income populations and people of color.   A car dependent transportation system doesn’t work for those who can afford to own a car and those who can’t or shouldn’t drive.
    The number of persons killed on Portland area streets and roads has increased steadily. Pedestrians and other vulnerable road users account for half of deaths. Most transportation spending is devoted to enabling vehicles to move faster making roads more dangerous for non-car travelers People of color, low income people, and the young and old are disproportionately likely to be pedestrians, cyclists and vulnerable road users. Spending most transportation dollars on freeways, which are the least deadly roadways is inequitable.
    Gasoline prices and gas taxes don’t cover the fiscal, social or environmental costs caused by driving. These costs, which range into the billions of dollars annually, are shifted to non-users.


    Under-charging users for the costs of driving results in more driving, and more social costs that would otherwise occur, and unfairly imposes these damages and costs on non-users, who tend to be disproportionately low income and people of color.
    Public policies will continue to allow unpriced use of public roads by cars while charging prices for use of transit. Congestion on public streets by unpriced private automobiles diminishes the speed and efficiency of public transit, which lowers its productivity, decreases its services levels and competitiveness, which lowers ridership and increases costs. Low income people and people of color, as well as the very young and very old are more likely to be transit-dependent than the overall population. They disproportionately bear the costs of worse bus service caused by the unpriced use of public streets by private cars.


    Public policies will continue to subsidize free on street parking for most car owners at a cost of tens or hundreds of millions of dollars a year. Free and subsidized parking only benefits those who own cars, and disproportionately benefits higher income and whiter populations.
    Roads and streets continue to contribute 50 percent or more to stormwater runoff, which causes pollution, and is expensive to fix.   Yet streets and roads, and their users pay nothing toward costs of stormwater collection and treatment. These costs are largely shifted to water users, especially households, many of whom don’t own or drive cars. Low income populations and people of color are disproportionately likely to be responsible for paying costs of stormwater due to costs shifted on to residences.





    Adjacency is not a good measure of equity







    Currently Metro relies on measures of adjacency (i.e. the demographic composition of census tracts adjacent to transportation infrastructure) to determine whether projects are equitable; This approach ignores the negative effects of proximity to many types of infrastructure, particularly highways)..
    Accessibility Measures should be used, rather than mobility.









    The performance of the transportation system should be judged by accessibility (the number of destinations one can easily reach), rather than by mobility (distance and speed traveled).   Maximizing accessibility is consistent with the region’s environmental, social and land use objectives; maximizing mobility undercuts key objectives and is more expensive.
    Equity is best served by direct payments rather that more spending to increase supply.



    Measures such as Portland’s transportation wallet can promote equity by giving more purchasing power and a wider array of options to low income households and targeted populations.
    Target VMT reductions. Reduced VMT is needed to achieve the state and region’s legislatively mandated GHG reduction goals. Portland decreased VMT 1.5 percent per year between 2005 and 2013. VMT reduction saves money and stimulates the local economy, which benefits disadvantaged populations. The 1.5 mile per day decrease in average trips between 2005 and 2013 saved the region $600 million per year on transportation expense, which benefited the local economy.
    Transportation spending targets peak hour car trips.


    Peak hour car commuters have vastly higher incomes than the general population, and those who commute by transit, bike or walking
    Green Dividend: Measures that reduce transportation costs have, in the past, created a “green dividend” for local households. Failure to continue to decrease VMT and transportation expense would be a missed opportunity to improve the region’s economy.



    Transportation is costly: the average household spends 15 percent of its income on transportation.   Policies that reduce the amount of travel that households need to make, as measured by average VMT, reduce household expenses and increase household disposable income. Transportation expenditures are particularly burdensome for lower income households.
    Demand for Walkability. Walkable neighborhoods are in high demand and short supply. More housing in dense, high demand locations results in fewer VMT, lower GHG emissions, and higher use of transit, biking and walking.



    More and more people are interested in living in walkable urban neighborhoods, which are in short supply.   The failure to build enough housing in walkable neighborhoods drives up housing prices, and makes it more difficult for low income households to be able to live in walkable neighborhoods, where transportation costs are lower.

    Metro’s “Don’t Look Up” Climate Policy

    Metro, Portland’s regional government, says it has a plan to reduce transportation greenhouse gases

    But in the 8 years since adopting the plan, the agency hasn’t bothered to look at data on GHGs—which have increased 22 percent, or more than one million tons annually.

    Metro’s Climate Plan is “Don’t Look Up” 

    In the new movie “Don’t Look Up,” Jennifer Lawrence and Leonardo DiCaprio play two scientists who identify a planet-killing comet headed for earth.  Their warnings go largely ignored, and by the end of the movie, there’s an active anti-scientific movement, which as the comet becomes visible in the sky, tells its adherents to simply “Don’t look up.”

    The movie is an allegory for our climate peril:  faced with mounting scientific evidence about the trajectory of climate change, and the increasingly evident manifestation of heat waves, storms, flooding and fires, too many of our leaders are simply looking away.

    And in Portland, which prides itself as being a green leader, the regional government has, effectively been pursuing a “Don’t Look Up” climate policy.

    Noble intentions, soaring rhetoric

    Here’s the background.  In 2007, the State Legislature set a goal of reducing Oregon greenhouse gas emissions by 75 percent by 2050.  And in 2014, Metro, Portland’s regional government adopted what it called a “Climate Smart Strategy” to reduce greenhouse gasses.

    On paper, seems good.

    The Metro plan had a few policy ideas for reducing greenhouse gas emissions, for example by expanding transit and promoting more compact land uses, which would enable more cycling and walking.  But for the most part, it relied on expectations that federal and state regulations and car makers would figure out a way to quickly make cars non-polluting.  Recognizing—at the time, at least—that there was a lot of uncertainty in the efficacy of these policies and the evolution of technology, Metro promised that if its efforts weren’t reducing greenhouse gasses, it would revisit the plan and take even tougher measures.

    Here it is, eight years later.  How is that “Climate Smart Strategy” working out?

    Well, you might read through Metro planning documents, but nowhere in them will you find any data on the change in transportation-related greenhouse gases in Metro’s planning area in the years since 2014.  In essence, after adopting its plan, Metro hasn’t looked up.

    But just like in the movie, scientists are looking up.  And what they see, specifically in Portland, is that the Metro strategy is failing—greenhouse gas emissions are increasing, not decreasing, as called for in Metro’s plan.

    Here, the parts of Leonardo DiCaprio and Jennifer Lawrence are played by real-life Boston University physicists Conor Gately, Lucy Hutyra and Ian Sue Wing.  Their research was sponsored by NASA, published by the National Academy of Science, and their database is maintained by the Oak Ridge National Laboratory.  What they’ve done is to create a nearly four-decade long, very high resolution map of greenhouse gas emissions from on-road transportation in the US.  They’ve mapped emissions down to a 1 kilometer (0.6 Mile) square grid for the entire nation, for each year from 1980 through 2017.  (There are more details about the project below). Their data is the best evidence we have on the trajectory of this comet.  And for Portland, the news is not good.

    Here’s what their data show for the tri-county Portland metro area:

    The green line on the chart is the actual amount of greenhouse gas emissions from transportation in Clackamas, Multnomah and Washington Counties from 1990 through 2017.  The blue line shows the trajectory of emissions needed to achieve the greenhouse gas reduction goals spelled out in Metro’s 2014 climate action plan.  In 2013, the year before Metro adopted its plan, emissions were about 6 million tons.  The plan envisioned the emissions levels going down by roughly a million tons by 2017.  But instead, as the green line shows, transportation greenhouse gas emissions in the Portland area increased by nearly 1 million tons a year after 2013, to 7 million tons.

    Metro’s “Climate Smart Strategy” isn’t just somehow behind schedule.  It is failing.  Emissions are increasing, not decreasing.  The comet is accelerating towards earth. So what are the leaders doing?

    Not looking up

    Metro’s climate plan promised to track emissions.  To be sure, Metro has published annual sustainability reports since 2014.  And they proudly mention the adoption of the Climate Smart Strategy.  But the only thing Metro tracks in these reports is greenhouse gas emissions (and other environmental effects) of its own internal business operations.  There’s absolutely no mention of overall regional trends from the transportation system Metro is charged with planning.  Neither does the 2018 Regional Transportation Plan provide a time series of data showing the trend in regional transportation greenhouse gas emissions.

    Metro’s plan also promised to take additional and tougher measures if those in the Climate Smart Strategy weren’t working fast enough.  On page 1 of the 2014 strategy document, Metro committed to periodically assessing its progress and said:

    If the assessment finds the region is deviating significantly from the Climate Smart Strategy performance monitoring target, then Metro will work with local, regional and state partners to consider the revision or replacement of policies, strategies and actions to ensure the region remains on track with meeting adopted targets for reducing greenhouse gas emissions.

    But if you don’t track your progress, you don’t have to admit you’re failing and you don’t have to  bother with considering more serious steps to reduce greenhouse gases.  Don’t. Look. Up.  It’s a recipe for disaster, and it’s the approach Metro is taking.

    The science behind the DARTE database.

    The tragedy here is that we have sound scientific data that tell us what is happening.  The research, undertaken over a period of years, sponsored by NASA, gives us a very granular, long-term picture of how our climate efforts are fairing.  You can’t claim to be taking climate change seriously if you aren’t paying attention to this kind of data.

    Gately, C., L.R. Hutyra, and I.S. Wing. 2019. DARTE Annual On-road CO2 Emissions on a 1-km Grid, Conterminous USA, V2, 1980-2017. ORNL DAAC, Oak Ridge, Tennessee, USA.

    Their results were featured in the New York Times in October 2019.  We alerted Metro staff to the availability and importance of this data in October 2019 (Cortright to Kloster, October 16, 2019).

    ODOT’s forecasting double standard

    Oregon’s highway agency rigs its projections to maximize revenue and downplay its culpability for climate challenge

    ODOT has two different standards for forecasting:  When it forecasts revenue, it says it will ignore adopted policies–especially ones that will reduce its revenue.  When it forecasts greenhouse gas emissions, assumes policies that don’t exist–especially ones that will magically make greenhouse gas emissions decline.

    Revenue forecasts are “purely based on historical data” and don’t include adopted policies.  Greenhouse gas emission forecasts are based on “goals” and “wishes” and are explicitly not an extrapolation of past trends.

    The inflated revenue forecasts are used to justify (and help fund) highway widening; the greenhouse gas emission forecasts are used to absolve the agency from any responsibility to reduce driving related greenhouse gas emissions.

    As we’ve pointed out, the Oregon Department of Transportation keeps two sets of books when it comes to climate emissions.  It tells the public that it cares about climate and greenhouse gas emissions in its largely performative “Climate Action Plan,” but when it comes to the agency’s budget, it tells financial markets it’s counting on Oregonians burning just as much gas—and creating just as much carbon pollution—a decade from now as they do today.

    ODOT’s officials have defended their revenue forecasts as being merely passive representations of current trends, unaffected and unfiltered by state policy objectives.  Somehow these actions that produce revenue are beyond either their control or responsibility.

    But when it comes to the agency’s climate plan, they’ve gone out of their way to make highly speculative assumptions that all kinds of other actors—consumers, automobile manufacturers, the federal government and other state agencies—will make radically different decisions or implement entirely new policies that lead to reductions in greenhouse gases.

    ODOT has a double-standard for forecasting—when it comes to forecasting climate, and especially establishing its responsibility for greenhouse gas emissions—it will make elaborate and speculative assumptions about other people doing things that will make the problem go away.  When it comes to estimating its own revenue (which it then uses to justify building new roadways and borrowing for more), it assumes that nothing will change and that it can safely ignore already adopted legal requirements to implement congestion pricing and limit greenhouse gases—both of which will reduce gas tax revenue.  It’s a deceitful, inconsistent and self-serving approach to forecasting.

    ODOT Revenue Forecasts:  We assume nothing will change and ignore our own adopted laws.

    Earlier, we pointed out that ODOT’s revenue forecasts are utterly at odds with claims it will reduce transportation greenhouse gas emissions, as mandated by state law, and directed by Governor’s executive order.  ODOT representatives defended their forecasts in the media by saying that the agency’s forecasting approach was merely to extrapolate existing trends, and that its forecasts were in no way a reflection of its policy objectives.

    Here’s ODOT spokesman Don Hamilton responding to Willamette Week.

    “ODOT revenue forecasts are based purely on consumer patterns and historical data,” says ODOT spokesman Don Hamilton. “They are not based on what we want to see.”

    The forecasts also don’t take into account the reductions in driving that may come with “congestion pricing” or other ODOT initiatives, Hamilton says.

    “As Oregon executes many of its climate-focused programs, we expect gas sales to decline, and we will revise our gas sales forecasts to reflect those changes as they occur.”

    Oregon Public Broadcasting’s Dave Miller pushed the agency’s top planner, Amanda Pietz to explain the discrepancy:

    Dave Miller: . . .  I want to focus on a new critique that I’m sure you’re aware of. It came about a week and a half ago from the frequent ODOT critic Joe Cortright, the economist. He put out a report digging into the agency’s estimates given to financial markets about expected gasoline tax revenues through the end of this decade. This was his summary: “What ODOT official revenue forecasts are telling us is that the agency fully expects us to be generating just as much greenhouse gasses from driving in 2030 as we are today. Indeed,” he wrote, “the agency is counting on it to pay its bills.” Amanda Pietz, how do you explain this?

    Amanda Pietz: I think it goes back to the earlier statement I was making. When we do our revenue forecasts it’s often looking back at the trends then and projecting those forward without necessarily seeing some of the interventions take hold and create those changes.[Emphasis added].

    Dave Miller: I’m slightly confused by that, and that jibes with what an ODOT spokesman said when there was an article about it this week in Willamette Week. But aren’t you supposed to give bond markets a projection that is as accurate as possible? If the whole point is [to say] “trust us, we’ve got revenue coming in, we can back these bonds and here’s our estimate for how the money is going to be coming in,” why don’t you factor in all the things you say you’re going to be doing so economic markets can know to trust you?

    Amanda Pietz: Part of what is done when we look at things is [that] we have to rely on something very solid – a clear policy change, a solidified investment that’s been amended into our investment strategy in a way that’s very clear, it’s solid. I think what you’re seeing is an agency that’s recognized that we’re a contributor to the problem in the last year and [is] starting to make some changes and modifications. Now when those take hold and the degree to which they’re solidified [so] that we can roll them into our financial assumptions, my guess is another six months to a year before you start to see some of those. Another key example of that is DEQ has its Climate Protection program which will set limits on fuel sales that will have a big impact on that revenue forecast. That’s in draft form, not finalized. When that’s finalized, becomes implemented, and there’s clarity around what that looks like, that’s when it gets rolled into the financial assumptions. Similar things for us, too. I mentioned we’re investing over $50 million dollars in transportation electrification. We should see fuel sales drop as a result of that. Until we figure out exactly where we’re placing that, how we’re going to leverage with our private partners to put those in the right locations, [that’s when] we can factor that into our revenue forecast.[Emphasis added].

    ODOT Climate Forecasts:  Wishes and speculation, including magical policies that don’t exist

    When it comes to making forecasts about future automobile emissions, and whether the agency will need to do anything to curtail the growth of driving in order to achieve the state’s statutory greenhouse gas reduction goals ODOT has an entirely different approach to forecasting.  It makes heroic assumptions about things that might happen, if somebody else does them.  It pretends that policies that don’t exist will be adopted and aggressively implemented. And all of these assumptions are skewed in a very particular way, i.e. to reduce or eliminate any need for ODOT to take responsibility for cutting greenhouse gases from cars and driving in Oregon.

    These assumptions are built into the State Transportation Strategy (STS), developed by ODOT to sketch out how Oregon might reduce transportation greenhouse gases in the decades ahead.  In a memo prepared for the Land Conservation and Development Commission, explaining the STS modeling, Brian Gregor, who was ODOT’s modeler, explained ODOT’s approach to estimating future greenhouse gas emissions from cars.

    The members on the Core Tech Team from the Departments of Environmental Quality and Energy agreed that the STS “trend line” is a reasonable reflection of goals that California, Oregon, and other states participating in the multi-state ZEV standards wish to achieve. They caution, however, that this planning trend does not reflect recent trends in vehicle fuel economy. Substantial efforts on the part of states and the federal government will be necessary to make this planning trend a reality. [Emphasis added].

    A footnote on page 30 of the LCDC report makes this point even more clearly:

    It is important to note that these ‘trend lines’ represent the trend in the model results given the vehicle assumptions in the STS recommended scenario. They do not represent an extrapolation of past trend. [Emphasis added].

    The contrast couldn’t be sharper:  when it comes to estimating an elevated level of future revenue, ODOT discounts anything that will reduce driving or pollution, and won’t even consider the impact of policies, like congestion pricing, which were approved by the Legislature in 2017.  But when it comes to optimistic speculation about technologies or policies that might lower future vehicle emissions—absolving ODOT of the need to act—the agency will definitely count on policies that haven’t been adopted by anyone.  It’s a clear and calculated strategy to avoid responsibility for doing anything to address climate change.

    Clearly, ODOT’s current revenue forecasts are counting on the failure of the state’s climate efforts.  They’re assuring financial markets that Oregon will collection hundreds of millions of dollars in motor fuel tax revenues with which to repay bonds it will use to expand the state’s highways, encouraging and subsidizing more driving and greenhouse gas emissions.  It may seem like an arcane detail, but it’s the kind of technocratic climate arson that’s routinely practiced by state highway departments.


    Metro’s failing climate strategy

    Metro’s Climate Smart Strategy, adopted in 2014, has been an abject failure

    Portland area transportation greenhouse gasses are up 22 percent since the plan was adopted: instead of falling by 1 million tons per year, emissions have increased by 1 million tons annually, to more than 7 million tons, putting us even further from our climate goals.

    Metro’s subsequent 2018 RTP has watered down the region’s climate effort far below what is needed to comply with Oregon’s statutory greenhouse gas reduction goal, based on the assumption that 90 percent of emission reductions would be accomplished with cleaner vehicles.

    All of Metro’s key assumptions about transit, vehicle turnover, technology adoption, and driving, have been proven wrong.

    The plan has set a goal for reducing vehicle miles traveled that is actually weaker than the reductions the region achieved in the decade prior to the adoption of the “Climate Smart Strategy.”

    The agency has not acknowledged the failure of its climate efforts, and is at the same time moving forward to allow the Oregon Department of Transportation to build a series of freeway widening projects that will add more than 140,000 tons of greenhouse gasses per year.

    Metro, Portland’s regional government, talks a good game when it comes to climate. It has adopted a so-called “Climate Smart” strategy, and a regional transportation plan that it claims will lead to a reduction in greenhouse gasses. But a close analysis of the Metro’s planning documents and other independent information shows the plan is failing, and is far too feeble to come anywhere close to achieving the state’s adopted legal goal of reducing greenhouse gasses by 75 percent by 2050.

    1. We’re going in the wrong direction:  Portland transportation GHG up 22 percent

    The clearest measure of failure is the one million ton increase in annual greenhouse gas emissions in Portland over the past few years. Carbon emissions accounting is technical and complex, but for Portland, for the past five years, when it comes to transportation greenhouse gas emissions, and whether we’re making progress, there are just three numbers you need to know:  6, 5, and 7.  In 2010, (the base year for Metro’s Climate Smart Plan), the tri-county area produced about 6 million tons of greenhouse gasses from transportation.  The plan set a goal of reducing transportation greenhouse gasses by about 63 percent by 2035 (the plan’s terminal year), which means that to be on track, the region would need to lower its emissions to about 5 million tons of transportation GHGs by 2017.  But the data from the DARTE national transportation greenhouse gas inventory shows that the region’s emissions increased to more than 7 million tons.  So instead of reducing greenhouse gasses by at least a million tons, we’ve actually increased greenhouse gasses by more than a million tons.  We’re not just “not making progress,” we’re going rapidly in the wrong direction.  Since 2010, we’ve fallen about 2.5 million tons behind the path we need to be on in order to meet the goal laid out in Metro’s Climate Smart Strategy.  



    Metro’s monitoring report, prepared as part of the 2018 Regional Transportation Plan, fails to acknowledge that the region is manifestly failing to reduce GHGs.

    2. Metro’s 2018 Regional Transportation Plan doesn’t even propose to get us to the adopted state GHG Goal

    Metro’s climate plans are spelled out in two documents, a “Climate Smart Strategy” (CSS) adopted in 2014, which proposed a 20 percent reduction in vehicle miles traveled, and a subsequent 2018 Regional Transportation Plan (RTP).  The adopted 2018 Regional Transportation Plan borrowed much of the rhetoric from the 2014 Climate Smart Strategy, but without any announcement or fanfare, radically watered down the region’s greenhouse gas reduction objective.  The CSS set a goal of reducing GHG’s by 63 percent by 2035; the 2018 RTP modified this to a GHG reduction of only 19 percent by 2040 (RTP Table 7.31 “Projected Mobile Source Greenhouse Gas Emissions by Investment Strategy.).

    The following chart shows the difference in the two plans. The starting dates for the two plans are set to the base years for their climate calculations (2010 for the CSS, 2015 for the RTP).  The glide slope lines are computed as the average annual percentage reduction in greenhouse gases needed to reach the end year target.

    Metro’s Climate Smart goal falls far short of what’s needed to meet Oregon’s statutory greenhouse gas emissions reduction, and even further short of meeting Governor Brown’s Climate Emergency Executive Order—which calls for an 80 percent reduction in greenhouse gas emissions by 2050.  Metro is relying as its justification for these goals a claim that is following guidance from LCDC.  But in fact, Metro is planning for a reduction in vehicle miles traveled than is only one-fifth as much as called for in state regulations (see #4 below), and our analysis shows that overly optimistic assumptions used by LCDC mean that VMT reductions actually need to be much larger than specified in the LCDC targets (Appendix B).  Not only is it failing to comply with the LCDC regulations (as explained here), those regulations have set planning goals that are now inadequate.  Also:  LCDC’s regulations don’t supersede or repeal the state statutory mandate to reach a 75 percent reduction in GHG by 2050, and Metro’s Climate Smart Strategy and 2018 Regional Transportation Plan are inadequate to put the region on track to do its share to achieve the 2050 goal of a 75 percent reduction in transport greenhouse gas emissions.

    3. Metro’s plans assumes other people will reduce transport GHGs, not Metro, and its assumptions have been proven wrong

    Both the Regional Transportation Plan and the earlier Climate Smart Strategy rely almost entirely on optimistic assumptions about vehicle fuel economy, electrification, fewer trucks and SUVs, and cleaner fossil fuels. Roughly 90 percent of the reduction in per capita greenhouse gasses claimed by Metro come from actions over which it has no control. Its strategy is far less about what it will do to address climate change, and almost entirely wishful thinking about what others will do.

    Metro’s 2014 Climate Smart Strategy was based on assumptions that other entities (some unspecified combination of the federal government, state government, auto makers, car buyers) would take actions that reduce greenhouse gas emissions per vehicle mile traveled by 38 percent between 2010 and 2035.  Metro’s plan actually contains no actions that influence per vehicle mile vehicle emissions.

    (Source: Metro Climate Smart Strategy (2014).  Right hand column data supplied by City Observatory; sources noted in Appendix B).  

    Similarly the 2018 RTP is based on even more aggressive assumptions about cleaner vehicles, drawn from the Oregon Department of Transportation’s Statewide Transportation Strategy.

    None of the key assumptions in Metro’s climate plans are being realized. Federal fuel economy standards are being watered down, SUV and light truck sales are more than double market share assumed in Metro’s modeling, older, dirtier vehicles are lasting longer and being driven further, and vehicle electrification is proceeding too slowly to achieve adopted goals.  Further data for each of these points is provided in Appendix B.

    • Metro assumed that average vehicle fuel economy would more than double. Actual fuel economy has barely moved in the past decade.
    • Metro assumed that people would buy new cars more often, and scrap old cars more quickly causing average vehicle age to decline (get newer) by 25 percent, with average age declining from 10 years to 8 years.  Instead, average vehicle life has increased to almost 12 years.
    • Metro assumed most people would buy more small and efficient passenger cars, and fewer trucks and SUVs.  Metro assumed that lighter more efficient passenger cars would make up 70 percent of the market, outselling trucks and SUVs more than 2-to-1.  The opposite has happened:  the market for passenger cars has collapsed to less than 30 percent market share.
    • Metro didn’t make explicit predictions about vehicle electrification, but data from ODOT show that by 2029, no more than 3 percent of the state’s light duty vehicle fleet is expected to be electric.

    4. Metro has a feeble and ever-shrinking goal for reducing vehicle miles traveled.

    There are basically two ways to reduce greenhouse gas emissions:  Cleaner cars or less driving.  Metro policies have almost no influence on cleaner cars; in contrast, Metro’s policies, including land use planning, permitting more road capacity, and assuring alternatives, like biking, walking and transit, can all influence the amount of driving.

    It’s a bit of a simplification, but these two concepts can be reduced to two measures:  Grams of carbon per vehicle mile (cleaner cars), and vehicle miles traveled (less driving).  As discussed above, Metro’s RTP is overwhelmingly counting on “cleaner cars” as providing roughly 90 percent of the reduction in transportation GHGs through 2040, and counting on less driving to provide only about 10 percent of greenhouse gas reductions.

    For any given level of pollution per mile, increases in vehicle miles traveled result in increases in greenhouse gas emissions.  Transportation planners focus on “vehicle miles traveled per capita” to measure the level of driving in a metropolitan area.

    Metro’s initial plan, the 2014 Climate Smart Strategy, set a goal of reducing per capita VMT by 20 percent by 2035.   As presented in the original Climate Smart Strategy, Metro identified a goal of reducing VMT per capita by 20 percent from 2010 levels, from 20 miles per person per day to 16 miles per person per day. (This is from page 65 of Metro’s 2014 Climate Smart Strategy).

    In the 2018 RTP, Metro changed the yardstick and twice moved the goalposts on VMT reductions.  First, it changed the yardstick, measuring  VMT per capita in a much narrower way (looking only at miles traveled by regional residents inside the metropolitan planning area).  The new yardstick looked at a base of 13 miles per person per day, compared to 20 miles per person per day.  This new system of measurement excludes looking at about one-third of all vehicle travel in the Portland region.

    Second, it retroactively changed the reported goals for the Climate Smart Strategy, lowering the baseline level of travel to 19 miles per person per day, and raising the 2035 “monitoring target” to 17 miles per day.  So while the as published 2014 Climate Smart Strategy visualized a 20 percent reduction in VMT from 20 to 16 miles per day; the 2018 RTP reported that the Climate Smart Strategy envisioned only about a 10 percent reduction in VMT, by two miles per person per day, from 19 to 17 miles.

    Third, the 2018 RTP presented the 10 percent reduction as a goal, but then substituted the new yardstick (i.e. 13 miles per person per day in the base year, now 2015, and pushed out the terminal year for reaching the new goal of 12.4 miles per person per day to 2020.  2018 RTP (Chapter 7 “Outcome Measures”) and Appendix J “Climate performance monitor”).


    But while Metro proclaimed as its goal reducing vehicle miles traveled by 10 percent, the plan’s analysis concluded that the measures included in the RTP would only reduce driving by a fraction of that amount by 2040.  The climate analysis contained in the 2018 RTP called for reducing VMT by 10 percent per capita, but the performance monitoring report in Appendix J of the 2018 RTP concludes that full implementation of the RTP would result in a decrease of more than 5 percent, “not reaching the target.”  The actual figures shown in the report (a decline from 13 miles per person per day to 12.4 miles per person per day) amounts to a 4.6 percent decline in VMT per capita.

    Elsewhere, the RTP concedes that the plan will reduce per capita VMT by about 4 percent.

    The reductions in vehicle miles traveled anticipated in the 2018 RTP are far smaller than needed to comply with LCDC regulations guiding climate planning.  Metro would need to achieve VMT reductions of about 20 percent per capita to comply with these guidelines.  The projected 4 percent decline in VMT/capita envisioned in the 2018 RTP is less than one-fourth the progress needed to meet the state guideline.  In addition, as explained in Appendix B, the state target  for VMT reduction is far too low to achieve the state’s greenhouse gas emission reduction requirements because state and local agencies have dramatically over-estimated likely progress in reducing vehicle emissions.

    Actual Performance Compared to Metro Goals

    To evaluate the VMT goal, it is necessary to put the vehicle miles traveled per person per day statistic in context.  Metro, using data from the Federal Highway Administration has produced a data series showing historical VMT per capita for the Portland area going back to 1990.

    Vehicle Miles Traveled, a core measure of transportation activity, which has been trending down since the late 1990s, has essentially stopped declining. In the decade before the Climate Smart Strategy was adopted, Portland area VMT per capita was declining at a rate of about 1.2 percent per year. The Climate Smart Strategy failed to even plan for continuing that trend; according to Metro’s own estimates, since 2014, VMT per capita has almost flat-lined, declining just 0.15 percent per year.  The 2018 RTP has even lower expectations, lowering VMT by just 4.6 percent over the 25-year period from 2015 to 2040, which works out to an annual decline of  0.2 percent per year.  

    Metro’s 2018 RTP predicts that the agency’s policies will produce a far slower rate of VMT reduction that the region accomplished over the period 2004-2013 (prior to the adoption of the first Climate Smart Strategy).  The 2018 RTP lowers the VMT reduction goal set in the 2014 CSS by more than 75 percent, from a 20 percent reduction over 25 years to a 4.6 percent reduction.  That’s not enough of a reduction in driving to meet the targets called for in LCDC regulations, nor is it enough to achieve the state’s goal of reducing greenhouse gas emissions to 25 percent of their 1990 levels by 2050.

    Summary of Metro Area VMT Reduction Performance and Goals

    5. Transit Ridership, a key factor in reducing GHG, is failing to meet projections.

    One key strategy to reduce greenhouse gas emissions is to shift trips from private automobiles to mass transit.  Metro’s regional transportation plan calls for reducing vehicle miles traveled and decreasing greenhouse gas emissions by increasing the share of the region’s trips taken by bus and light rail.  Each successive regional transportation plan since 2004 has projected that transit ridership levels under the plan will double in the next ten to twenty years.  

    Metro’s transit ridership projections have been grossly overstated in every Regional Transportation Plan, and TriMet’s operating plans show it has no intention (or ability) to carry as many passengers as the RTP assumes in order to make progress.  The RTP assumes transit ridership will more than double between 2015 and 2040, from 250,000 originating riders to more than 600,000 originating riders, which shows no signs of happening.  Even prior to the Covid pandemic, transit ridership was falling, down 7 percent from its peak in 2012.  Rather than growing at more than three and a half percent per year—pre-pandemic—ridership has been declining at about one percent per year.


    Every RTP has consistently predicted high levels of transit growth that have not materialized.  The 2004 RTP predicted 2020 ridership would be 383,000, the 2010 RTP predicted 2020 ridership would be 349,000, the 2014 RTP predicted ridership in 2020 would be 326,000; actual ridership (as noted) is about 250,000 (pre-Covid).

    The consistent failure of the region to realize the gains in transit ridership called for in the last four RTPs suggests that we will need to do much more to reduce VMT and greenhouse gasses.  It also suggests that Metro’s transit ridership model is biased and inaccurate.

    6. Approving more highway capacity would increase greenhouse gas emissions

    Even though its climate plan is failing, Metro is giving the Oregon Department of Transportation the greenlight to spend billions of dollars expanding area freeways that are likely to lead to huge increases in greenhouse gas emissions. The RMI induced travel calculator, calibrated based on award-winning, peer-reviewed research from the University of California, Davis, estimates that the Rose Quarter Freeway widening project will produce an addition 40,000 tons of greenhouse gasses per year and the revived Columbia River Crossing will likely produce a further 100,000 tons of greenhouse gasses per year.

    The Induced Travel Calculator shows that revived Columbia River Crossing project (now rebranded as “I5 Bridge Replacement Program“) would produce an additional 155 to 233 million miles of travel annually, leading to burning an additional 11 million gallons of gas.  That in turn  would translate into additional annual greenhouse gasses of about 100,000 tons (at roughly 20 pounds of CO2e per gallon of gas).


    The same calculator shows that the proposed widening of I-5 at the Rose Quarter will likely produce 60 to 90 million additional vehicle miles of travel per year, lead to burning about 4 million additional gallons of gas per year, and generate about 40,000 tons of additional greenhouse gases.

    7. Metro isn’t pursuing pricing, which has been proven to be effective

    Metro has taken no action to implement any of the pricing options that its own research rates as “highly effective” in reducing greenhouse gas emissions, including road pricing, gas taxes, vehicle miles traveled fees, parking charges and pay as you drive insurance. It’s gone out of its way to gainsay effective pricing measures, and used its public relations budget to promote false claims about vehicle idling.

    One key reason for the increase in driving since 2014 has been the significant decline in oil and gasoline prices.  Metro’s model, calibrated based on behavioral responses to the earlier higher prices, and the assumption that declining prices wouldn’t affect demand for travel, have failed to predict the increase in driving.

    8.  Metro has done nothing to fix its failing climate strategy

    In spite of the failure to advance its goals, Metro has proposed no new or stronger measures to reduce GHGs, even though its climate smart initiative says it will do so.  Metro’s 2014 Climate Smart Strategy (on page 1) promised to periodically check to see whether progress was being made toward the goals it laid out.  If further promised:

    If the assessment finds the region is deviating significantly from the Climate Smart Strategy performance monitoring target, then Metro will work with local, regional and state partners to consider the revision or replacement of policies, strategies and actions to ensure the region remains on track with meeting adopted targets for reducing greenhouse gas emissions.

    Similarly, the 2018 RTP (Appendix J) makes the same commitment on page 10.

    The data from DARTE show that Metro is plainly not meeting the initial greenhouse gas reduction goals set in the initial Climate Smart Strategy, nor is it on track to meet the much watered-down goal laid out in the 2018 RTP.  Similarly the “fleet and technology assumptions” built into both the CSS and the RTP have been proven wrong.  Yet the Metro has not acknowledged either of these basic facts, nor has it proposed any additional steps to reduce current high levels of greenhouse gasses to get them back on track.  Instead, it is going along with proposals from the Oregon Department of Transportation to spend billions widening area highways—which will add to Metro area greenhouse gasses.  (As explained in Appendix B, both the Land Conservation and Development Commission and the Oregon Department of Transportation have likewise failed to acknowledge increasing transportation greenhouse gas emissions, and have failed to update their incorrect modeling assumptions, and to revise policy targets, as both have committed to in their plans and regulations).

    Appendix A.  Sources, Data and Methodology

    Metro’s description of its climate strategy is taken from the 2014 Climate Smart Strategy and the 2018 Regional Transportation Plan.

    Data on Portland area transportation greenhouse gasses are from the DARTE national transportation greenhouse gas emissions inventory, which contains estimates covering the years 1990 through 2017 at a very fine geographic scale.  DARTE is the most comprehensive and uniform national estimate of local transportation greenhouse gas emissions. We report DARTE data for Clackamas, Multnomah and Washington counties, the geography most closely corresponding to the Portland “metropolitan planning area” used in Metro’s 2018 RTP.  For purposes of comparison, we factor up Metro’s figures by 18-20% (depending on year) to be directly comparable to the larger geography of the DARTE database.

    We compute emission reduction trajectories needed to meet state greenhouse gas requirements, and trajectories implied by Metro’s plans by computing a constant annual (negative) growth rate—or “glide slope”—needed to move from base year to final year emissions levels.  For example, in 1990, Portland area transportation GHGs were 5.7 million tons; a 75 percent reduction from that level (to meet the state goal) implies a 2050 level of emissions of 1.4 million tons.  To reach that level from 2013 actual emissions of 6.0 million tons requires a reduction of 3.8 percent per year for each year from 2013 through 2050.  We compute glide slopes for other plans (ODOT’s STS; Metro’s RTP) in the same fashion.

    The 2018 RTP contains two conflicting estimates of how much reduction the plan will actually provide.  Chapter 7 of the RTP says that the 2015 level was 13 VMT per capita per day, and that the plan would reduce this to 12.3 VMT per capita per day by 2040.  The Climate Smart Appendix to the report, Appendix J, says that the 2015 baseline level was 12.7 VMT per capita per day, and would be reduced to 12.3 VMT per capita per day by 2040.  Chapter 7 figures imply a 4.6 decline in VMT by 2040; Appendix J implies the decline will be only 2.3 percent.  We assume that the correct level of VMT in the base years is 13 VMT per person per day, corresponding to a 4.6 percent decline in VMT by 2040.

    Appendix B:  Metro and State incorrect assumptions about cleaner vehicles

    Guided by state rules, Metro’s emissions modeling assumes “cleaner cars” through a combination of improved fuel economy (higher MPG standards), faster vehicle turnover (replacing dirty old cars with cleaner new ones), and smaller, more efficient vehicles (more cars, fewer trucks and SUVs).  None of these assumptions have been realized in the time since Metro and state climate plans were published.

    1. Fleet fuel economy has not measurably improved.  Modeling for the climate smart initiative assumed rapid and prolonged improvements in vehicle fuel economy, due to rising federal fuel economy standards.  But the impact of increased new car standards on actual levels of real-world fuel efficiency have been modest.  Here is the data on actual average fu